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PC RES 4457
Resolution No. 4457 Page 2 H. That the initial Draft Housing Element was circulated for public review r between June 30, 2021 and July 30, 2021 and has subsequently remained available for on-going public review and comment thereafter. I. That the State Department of Housing and Community Development (HCD) has reviewed the Draft Housing Element between June 30 and August 30, 2021 and provided verbal comments to the City on August 12, 2021 followed by formal written comments on August 27, 2021. J. 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. K. That on September 7, 2021 , the City Council held a public hearing 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. L. That on September 14, 2021, the Planning Commission conducted a duly- noticed public hearing to consider the Initial Study, proposed Negative Declaration, and General Plan Amendment (GPA) 2021-0002, at which hearing, members of the public were afforded an opportunity to comment upon the project and the Planning Commission recommended that the City Council certify the Negative Declaration and adopt GPA 2021-0002 updating the Housing Element. 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 GPA 2021- 0002, and a Negative Declaration was prepared for the project. N. That a public hearing was duly called, noticed, and held on GPA 2021-0002 on October 5, 2021, by the City Council to consider and provide further opportunity for the general public to comment on and respond to the proposed Housing Element Update. The City Council adopted Resolution No. 21-86 certifying the Negative Declaration prepared for GPA 2021-0002 and Resolution No. 21-87 approving the City of Tustin 6t" cycle Housing Element update, O. That on October 14, 2021 the City resubmitted the revised Housing Element addressing HCD's comments and on January 12, 2022, HCD provided the City with its findings of the revised Housing Element. Resolution No. 4457 Page 3 P. That on March 22, 2022 the City submitted to HCD additional revisions to the City's Housing Element addressing HCD findings and on May 18, 2022, HCD provided the City with additional findings on the revised Housing Element. Q. That on July 21, 2022 the City submitted additional revisions to the City's Housing Element addressing HCD's findings and on September 1, 2022, HCD provided the City with a verbal approval of the revised Housing Element. R. That the City is in compliance with AB 215 and the most recent revisions were made available to the public from September 2, 2022 to September 8, 2022. Per AB 215, updates have been posted for public review and can be accessed online at www.tustinca.org/HousingElement. S. That a public hearing was duly called, noticed, and held on GPA 2022-0002 on September 13, 2022, by the Planning Commission to consider and provide further opportunity for the general public to comment on and respond to the revised Housing Element Update. T. That revisions to the Housing Element (GPA 2022-0002) includes clarification language and refinements that do not require subsequent environmental analysis. Therefore, the Initial Study and Negative Declaration, certified by the City Council on October 5, 2021 by adoption of Resolution No. 21-86, is adequate for GPA 2022-0002. II. The Planning Commission hereby recommends that the City Council approve GPA 2022-0002, 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 13th day of September, 2022. DAVID J. MELLO, JR. Chairperson JUS�f[ A L. WILL OM Planning Commission Secretary Resolution No. 4457 Page 4 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. 4457 was duly passed and adopted at a regular meeting of the Tustin Planning Commission, held on the 13th day of September, 2022. PLANNING COMMISSIONER AYES: cxu, xzGucxz, KOZA.K, MASON, MELLO (5) PLANNING COMMISSIONER NOES: PLANNING COMMISSIONER ABSTAINED: PLANNING COMMISSIONER ABSENT: zjk,,&at�_' J INA L. WILLKOM PlWnning Commission Secretary Attachment: Exhibit A: 2021-2029 Final Revised Housing Element w 4 t Ir e , 1 ;0lj� } ` idRai yj OL WWI ti 1 � o d - a S� .C�YS , � F t w a City of Tustin Final Revised Housing Element 2021 =2029 September 2022 r y , ® ED lair 1 Final Revised Housing Element 2021-2029 TUSTIN GENERAL PLAN SEPTEMBER 2022 This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 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 II. SUMMARY OF ISSUES,NEEDS, CONSTRAINTS AND OPPORTUNITIES II-1 Summary Of Housing Needs II-1 Preservation Of Units At Risk Of Conversion II-19 Summary Of Housing Issues II-28 Housing Constraints II-291-lousing Opportunities II-88 III.HOUSING ELEMENT GOALS AND POLICIES III-1 Housing Supply/Housing Opportunities III-1 Maintenance And Conservation III-3 Environmental Sensitivity III-4 Related Goals And Policies III-4 IV. HOUSING ELEMENT IMPLEMENTATION PROGRAM IV-1 Housing Programs IV-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 SEPTEMBER 2022 ii LIST OF TABLES Tables Page TABLE II-1: POPULATION GROWTH 2010-2018 II-2 TABLE II-2: POPULATION PROJECTIONS 2025-2045 II-2 TABLE II-3: EMPLOYMENT BY OCCUPATION II-3 TABLE II-4:EMPLOYMENT PROJECTIONS II-3 TABLE II-5: LIST OF MAJOR EMPLOYERS II-4 TABLE II-6:JOBS-HOUSING BALANCE II-5 TABLE II-7: HOUSEHOLD INCOME DISTRIBUTION OVERVIEW II-7 TABLE II-8: NUMBER OF HOUSEHOLDS WITH COST BURDEN II-8 TABLE II-9: NUMBER OF HOUSEHOLDS WITH COST BURDEN II-8 TABLE II-10: TENURE OF HOUSEHOLDS WITH HEAD OF HOUSEHOLD AGED 65 YEARS OR OLDER II-10 TALBE II-11: ESTIMATED HOUSEHOLD INCOME DISTRIBUTION-HOUSEHOLDS WITH HEAD OF HOUSEHOLD AGED 65 YEARS OR OLDER II-10 TABLE II-12: SENIOR HOUSEHOLDS BY TENURE II-11 TABLE II-13 RACE AND ETHNICITY II-11 TABLE II-14 DISABILITY DEMOGRAPHICS II-12 TABLE II-15 DEVELOPMENTAL DISABILITY DEMOGRAPHICS II-14 TABLE II-16 TUSTIN EMPLOYMENT IN AGRICULTURE II-17 TABLE II-17 AT-RISK UNITS II-19 TABLE II-18 ASSISTED HOUSING INVENTORY II-20 TABLE II-19 ORANGE COUNTY FAIR MARKET RENT II-23 TABLE II-20 COST OF PRESERVATION II-24 TABLE II-21 COST OF REPLACEMENT II-27 TABLE II-22 NEW AND RESALE PRICE OF HOMES AND CONDOMINUMS II-31 TABLE II-23 AVERAGE RENTAL RATES 2021 II-32 TABLE II-24 SUMMARY OF RESIDENTIAL ZONING REGULATIONS II-35 TABLE II-25 INCLUSIONARY HOUSING OPTIONS FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS II-46 TABLE II-26 FEE OPTIONS FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS II-47 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 iii TABLE II-27 FEE PER UNIT FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS II-47 TABLE II-28 INCLUSIONARY HOUSING FEE COMPARISON II-49 TABLE II-29 SUMMARY OF HOMELESS ACCOMODATION ZONING REGULATIONS II-57 TABLE II-30 MONTHLY VACANCY RATE VILLAGE OF HOPE II-59 TABLE II-31 MONTHLY VACANCY TUSTIN TEMPORARY EMERGENCY SHELTER II-60 TABLE II-32 EMERGENCY SHELTER/TRANSITIONAL HOUSING FACILITIES/HOMELESS RESOURCES II-61 TABLE II-33A DEVELOPMENT FEES II-67 TABLE II-33B DEVELOPMENT FEES II-69 TABLE II-34 HOUSING TYPES AND PERMIT PROCESSING REQUIREMENTS II-73 TABLE II-35 PROJECT BUILDING PERMIT TIMEFRAME II-77 TABLE II-36 QUANTIFIED OBJECTIVES II-86 TABLE IV-1 HOUSING ELEMENTS PROGRAMS 2021-2029 IV-1 LIST OF FIGURES Figures Page FIGURE II-1: IMPACT FEE ZONES II-56 FIGURE II-2: PLANNING FEES II-57 FIGURE II-3: RESIDENTIAL BUILDING PERMIT PROCESS II-62 FIGURE II-4: CONDITIONAL USE PERMIT CUP PROCESS AND TIMELINES II-64 FIGURE II-5: STREAMLINED ADMINISTRATIVE REVIEW PROCESS II-64 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 lU 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 ended on October 15,2021 • 2021 -2029: The current Housing Element planning period began 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 I-1 SEPTEMBER 2022 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 Il 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 I-2 SEPTEMBER 2022 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. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN I-3 SEPTEMBER 2022 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, and also incorporates new residential development opportunities presented by the Red Hill Avenue Specific Plan and the Downtown Commercial Core Specific Plan, Tustin Legacy Specific Plan and other parts of the City. 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. The following provides a brief summary of the City public participation opportunities the City provided during the Housing Element preparation process. 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: • Public Meetings - Multiple public workshops and public hearings held providing opportunities for community and public participation and input, CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN I-4 SEPTEMBER 2022 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 nineteen (19) public comments during the comment period. The majority of comments were received between June 30, 2021 and July 30, 2021 and a summary of all of the comments are provided below.The public comment period has been continuously open since June 30,2021.More than half of the comments received during the beginning of the comment period 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, released in June 2021, was subsequently revised on August 17 and September 7,2021 by the City Council during public meetings. Specifically, the revisions added and redistributed units to The Tustin Market Place and the Enderle Center sites. These revisions also included adjustments to the distribution of units at various income levels (based on RHNA percentages) evenly and proportionately throughout the sites. • Concern over the apportionment, density and geographic placement of additional low-income housing primarily identified to occur within the Tustin CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN I-5 SEPTEMBER 2022 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. • 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. • Request for the City to consider utilizing skilled and trained workforce policies. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN I-6 SEPTEMBER 2022 At the September 14, 2021 Planning Commission public hearing, the Commission received additional public comments from the Kennedy Commission and Tustin Planning Partnership. The concerns generally expressed include the following: • Concern that site analysis is deficient relative to physical viability and allocation of lower income sites at Tustin Market Place and Enderle Center. • Concern that proposed update is creating inconsistencies that are contrary to the City's land use and Zoning Code and affordable housing policies. • Concern regarding public participation and outreach to underserved, minority and special needs population, site inventory analysis, bed counts of emergency and transitional housing projects within the City, ADU calculation and analysis, impact of local ordinances on the cost of housing and lack of analysis regarding special needs populations and resources available. These comments were similar to those comments received by the City from HCD and Public Law Center which the City has addressed in the revised Draft Housing Element. At the conclusion of the September 14, 2021 meeting, the Planning Commission unanimously voted 5-0, adopting Resolutions No. 4439 and 4440 with the recommendations that the City Council approve the Housing Element Update and the accompanying Negative Declaration 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 funding recipients, multi-family apartment managers(TEAMs),and online survey respondents. As of September 23, 2021, two (2) public comments were 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 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. A second comment letter was received by the City of Irvine but cited no major concerns. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN I-7 SEPTEMBER 2022 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. On September 30, 2021, the ALUC considered the draft Housing Element and determined that the Housing Element and it is consistent with Airport Environs Land Use Plans (AELUPs) for the John Wayne Airport and Heliports. The current draft Housing Element has carried over two (2) key policies from the previous element: 1. Buildings and structures shall not penetrate Federal Aviation Regulation (FAR) Part 77 Imaginary Obstruction Surfaces for John Wayne Airport unless found consistent by the Airport Land Use Commission(ALUC).Additionally, in accordance with FAR Part 77,applicants proposing buildings or structures that penetrate the 100: 1 Notification Surface shall file a Form 7460 -1 Notice of Proposed Construction or Alteration with FAA. A copy of the FAA application shall be submitted to ALUC and, the applicant shall provide the City with FAA and ALUC responses. 2. Development projects that include structures higher than 200 feet above existing grade shall be submitted to ALUC for review. In addition, projects that exceed a height of 200 feet above existing grade shall file Form 7460 -1 with the Federal Aviation Administration FAA). October 5, 2021, the Tustin City Council considered and adopted two Resolutions (No. 21-86 and 21-87),approving the 6th cycle of the City of Tustin Housing Element Update, and authorized staff to submit the adopted Housing Element to HCD for certification. The City subsequently submitted the draft Housing Element to HCD on October 14, 2021 and received a letter of finding from HCD on January 12,2022. The City revised the draft Housing Element to address the findings and provided the public an opportunity to review the revisions in accordance to Assembly Bill No. 215 for a minimum of seven (7) days, from March 15, 20222 through March 21, 2022. Prior to CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN I-8 SEPTEMBER 2022 resubmittal to HCD, the City considered public input and revised the draft Housing Element,as needed.On March 23,2022,the City resubmitted a revised draft Housing Element,addressing HCD's finding. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN I-9 SEPTEMBER 2022 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 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- 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-1 SEPTEMBER 2022 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 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 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 II-2 POPULATION PROJECTIONS IN TUSTIN,CA 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 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-2 SEPTEMBER 2022 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 II-3 shows the breakdown of employment by occupation. TABLE II-3 EMPLOYMENT BY OCCUPATION IN TUSTIN,CA 2018 Occupational Category Number Management,business,science,and arts occupations 81293 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 II-4 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 II-4 EMPLOYMENT PROJECTION IN TUSTIN,CA 2016-2040 Percent 2016 2020 2025 2030 2035 2040 Change (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,2018 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-3 SEPTEMBER 2022 Table 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 II-5 LIST OF MAJOR EMPLOYERS IN TUSTIN,CA 2021 Company/Address No.Emp. Product/Service Tustin Unified School District 2,850 Education 300 South C Street,Tustin 92780 SchoolsFirst 983 Financial Services 14171 Red Hill Avenue,Tustin,CA 92780 Young's Market Company LLC 681 Distributor 14402 Franklin Avenue,Tustin,CA 92780 Costco Wholesale 658 Wholesale Trade 2700 Park Ave., Tustin 92780; 2655 El Camino Real, Tustin,CA 92782 New American Funding 645 Financial Services 4511 M ford Rd Ste.100,Tustin,CA City of Tustin 409 Government 300 Centennial Way,Tustin 92780 Avid Bioservices,Inc. 230 Manufacturing 2642 Michelle Drive #200,Tustin 92780 Vita Best Nutrition 215 Manufacturing 2802 Dow Avenue,Tustin,92780 Kaiser Foundations Hospitals, 2521 Michelle Drive, 200 Medical Tustin 92780;1745217+h Street,Tustin 92780 Logomark,Inc. 196 Wholesale Trade 1201 Bell Avenue,Tustin 92780 Source City of Tustin Comprehensive Annual Financial Report for the Year Ended,2020 Jobs-Housing Balance 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-4 SEPTEMBER 2022 jurisdiction has reached an equilibrium between employment and housing opportunities. Table 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 II-6 JOBS-HOUSING BALANCE CITY OF TUSTIN,ORANGE COUNTY,SCAG 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 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-5 SEPTEMBER 2022 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 two (2) - nine (9) units structures, approximately 24 percent (6,041) are comprised of 10 or more units structures, and two (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. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-6 SEPTEMBER 2022 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 II-7 HOUSEHOLD INCOME DISTRIBUTION OVERVIEW IN TUSTIN,CA 2017 Income Owner Owner Renter Renter Total Household Income less-than or 1,155 31.8 2,470 68.1 3,625 =30% AMI Household Income >30% to 1,075 27.5 2,840 72.5% 3,915 less-than or=50% AMI Household Income >50% to 1,820 36.7 3,135 63.3% 4,955 less-than or=80% AMI Household Income >80% to 1,450 47.3% 1,610 52.6% 3,060 less-than or=100% AMI 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-7 SEPTEMBER 2022 TABLE II-8 NUMBER OF HOUSEHOLDS WITH COST BURDEN IN TUSTIN,CA COMPARISON,2012 AND 2017 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 II-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 26.85 percent experiencing a cost burden whereas 16.61 percent of owners experience cost burden. TABLE II-9 NUMBER OF HOUSEHOLDS WITH COST BURDEN IN TUSTIN,CA Cost Burden Owner Renter Total Cost Burden less-than or=30% 8,150 6,415 14,565 Cost Burden>30% to less-than or=50% 2,870 3,670 6,540 Cost Burden>50% 1,480 3,360 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-8 SEPTEMBER 2022 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 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-9 SEPTEMBER 2022 Table I1-10 shows the tenure of households with the head of household aged 65 years or older in the City of Tustin 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 II-10 TENURE OF HOUSEHOLDS HEAD OF HOUSEHOLD AGED 65 YEARS OR OLDER IN TUSTIN,CA 2018 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 I1-11 shows the estimated household income distribution for householders aged 65 years or older in 2018. Approximately 18.2 percent of elderly senior 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 II-11 ESTIMATED HOUSEHOLD INCOME DISTRIBUTION HOUSEHOLDS WITH HEAD OF HOUSEHOLD AGED 65 YEARS OR OLDER IN TUSTIN,CA 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 I1-12 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- CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-10 SEPTEMBER 2022 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 II-12 SENIOR HOUSEHOLDS BY TENURE IN TUSTIN,CA 2018 Owner costs Gross rent as as Total Elderly Senior- percentage percentage Jurisdiction Population Headed Owner Renter of of Households household household income income 30%> 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 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 racial and ethnic patterns data and analysis for Tustin is provided in Appendix D. TABLE II-13 RACE AND ETHNICITY,TUSTIN,CA 2020 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-Hispanic 17,542 21.93% Native American,Non-Hispanic 418 0.52% Two+Races,Non-Hispanic 1,949 2.62% Other,Non-Hispanic 169 0.23% Source:County of Orange,Analysis of Impediments,2020 Persons With Disabilities Health and safety are directly linked to housing, and yet, many people with disabilities face enormous barriers in finding suitable housing to accommodate their needs. Additionally, because people with disabilities have faced a history of institutionalization-in state hospitals, developmental centers,jails and prisons,etc. - CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-11 SEPTEMBER 2022 ensuring that appropriate community-based housing with appropriate supports exists is critical. People with disabilities are also overrepresented in the unhoused population and any solutions related to homelessness must address appropriate accommodations and accessibility. Many individuals with ambulatory, self-care, or independent living difficulties are able to live independently with appropriate supports in place.These supports include caregivers or In-Home Supportive Services (IHSS). Many seniors,for example,are able to continue living independently as they age and avoid institutionalization by making physical modifications to their homes or obtaining supportive services. According to the 2014-2019 ACS, 6.6 percent or 5,238 persons in Tustin have one or more disabilities.Approximately 2,291 persons 65 and older in Tustin,or 28.4 percent, have one or more disabilities. Demographics by disability and age cohort are identified in Table II-14. The most common disability in the city was ambulatory difficulty, with 8.1 percent of total population and 14.9 percent of senior population having an ambulatory disability. The least common disability in the city is vision difficulty, with 2.6 percent of total population and 3.0 percent of senior population having a vision difficulty. The tables below quantify the number of persons with disabilities in Tustin and further provides a breakdown of the persons with disabilities by race/ethnicity. The race with the highest percentage of disability is White alone(8.5 percent) followed by Black or African American alone (6.5 percent). The ethnicity with the highest population of disability is White alone,not Hispanic or Latin(10.3 percent). TABLE II-14 DISABILITY DEMOGRAPHICS,TUSTIN,CA 2014-2019 Disability Total Percent Total Age 65+ Percent With a hearing difficulty 1,359 4.3% 800 8.3% With a vision difficulty 825 2.6% 287 3.0% With a cognitive difficulty 1,867 5.9% 591 6.1% With an ambulatory difficulty 2,573 8.1% 1,445 14.9% With a self-care difficulty 1,179 3.7% 573 5.9% With an independent living 2,125 6.7% 1,147 11.8% difficulty Total Disability 5,238 6.6% 2,291 28.4% Total Population 79,667 8,057 Race/Ethnicity White alone 3,294 8.5% Black or African American 138 6.5% alone CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-12 SEPTEMBER 2022 TABLE II-14 DISABILITY DEMOGRAPHICS,TUSTIN,CA 2014-2019 Disability Total Percent Total Age 65+ Percent American Indian and Alaska 0 0.0% Native alone Asian alone 918 5.1% Native Hawaiian and Other 6 5.0% Pacific Islander alone Some other race alone 599 3.6% Two or more races 283 7.7% White alone,not Hispanic or 2,598 10.3% Latino Hispanic or Latino(of any 1,412 4.4% race) Source:ACS 2014-2019 Many disabled persons receive Social Security Income (SSI) assistance; however, benefit payments are well below the level necessary to afford market rate housing in the Tustin community. The City supports a number of affordable housing facilities, as identified in Table I1-17. Large family day care homes with seven or more individuals are permitted uses in all residential districts within the city.According to the California Department of Social Services, there are currently 10 adult residential facilities located in the City of Tustin that accommodate adults with disabilities. The City's process and policies to provide reasonable accommodation to populations with disability are discussed within Housing Constraints,below. Developmental Disabilities According to Section 4512 of the Welfare and Institutions Code, a "developmental disability" means a disability that originates before an individual attains age 18 years, continues, or can be expected to continue, indefinitely, and constitutes a substantial disability for that individual, which includes mental retardation, cerebral palsy, epilepsy, and autism. Many developmentally disabled persons can live and work independently within a conventional housing environment. More severely disabled individuals require a group living environment where supervision is provided. The most severely affected individuals may require an institutional environment where medical attention and physical therapy are provided. Because developmental disabilities exist before adulthood, the first issue in supportive housing for the developmentally disabled is the transition from the person's living situation as a child to an appropriate level of independence as an adult. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-13 SEPTEMBER 2022 The California Department of Developmental Services provides community-based services to persons with developmental disabilities and their families through a statewide system of 21 regional centers. The goal of these centers is to: 1) prevent/minimize institutionalization of developmentally disabled persons and their dislocation from family and community; and 2) enable this population to lead more independent and productive lives. The Regional Center of Orange County (RCOC) serves approximately 22,000 individuals with developmental disabilities and their families. Within Tustin s two zip codes,the Regional Center currently provides services to 643 residents with developmental disabilities, generating an estimated need for 244 housing units: TABLE II-15 CDISABILITY DEMOGRAPHICS,TUSTIN,CA 2014-2019 Zip Code 0-17 years 18+years TOTAL 92780 238 223 461 92782 108 74 182 Citywide Total 346 297 643 Est.Housing Need' 147 97 244 Source:Regional Center of Orange County(RCOC),2021 1 The following need factors developed by the Golden Gate Regional Center can be used to estimate housing needs for the developmentally disabled population by age group:age 0-14 25%need hsg;age 15-22 50%need hsg;age 23-54 35%need hsg;age 55-65 25%need hsg;age 65+20%need hsg.Therefore,percentages were averaged for the overlapping age cohorts,which yield an estimated factor of 0-17 42.5%need hsg and 18+32.5% need hsg As identified by RCOC, among Tustin residents served by the regional center, approximately 86 percent live with a parent, family member or guardian; 8 percent live as independent or in supported living;2 percent live in a community care facility; and 3 percent live in another type of accommodation.These percentages highlight the need for people with developmentally disabled family members to have a variety of housing choices to provide ongoing care and support. The RCOC has several informational resources on their website about housing options for people with developmental disabilities. In 2013,the RCOC published a paper in conjunction with the Regional Centers Housing Advocacy Council that looked at the housing needs of developmentally disabled persons in the county.2 The paper stated that the housing needs for developmentally disabled residents mirrored those of seniors and aging adults and safe, affordable housing options were needed. The regional centers have identified a number of community-based housing types appropriate for persons living with a developmental disability: licensed community care facilities and group homes; supervised apartment settings with support services; SB 962 homes (for persons with special health care and intensive support needs); and for persons able to live more independently, rent subsidized homes, inclusionary housing, and Section 8 rental vouchers.In addition to services offered through the Regional Center, CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-14 SEPTEMBER 2022 Project Independence in Costa Mesa has assisted hundreds of developmentally disabled individuals to gain the necessary skills to live independently. Orange County has the following housing facilities to serve persons with developmental disabilities3: 1. Harbor Village in Costa Mesa - apartment complex that is a joint project between the RCOC and the California Department of Developmental Services. Approximately 52 units are leased to persons with developmental disabilities and 15 of these units are certified to serve people with significant needs. 2. Integrity Cottages in Anaheim- a former motel that has been converted into 48 affordable rental units. 3. Parc Derian in Irvine-4 units in this new complex are designated for persons with developmental disabilities. Other units are set aside for veterans and formerly homeless households. Footnotes 1. California Department of Developmental Services, Consumer County by California ZIP Code and Residence Type. 2. Regional Center and Early Start Consumers,June 2020. 5 Regional Center of Orange County, "Housing for People with Developmental Disabilities in Orange County,"January 20,2013. 6 3. Regional Center of Orange County website: www.rcocdd.com/housing Given the variety of persons with disabilities and demonstrated need for a variety of housing types for persons with development disabilities, especially for this eliving with a parent, the City of Tustin is proposing a new program to facilitate and incentivize the construction ohf housing that implement the Universal Design concept. The City will establish a new Program 2.4d which will amend the code to establish a new Universal Design program which strives to produce dwellings that are accessible regardless of race, age, sex, culture, gender, weight and ability. Universal design avoids using special assistive technology, and instead employs design features and consumer products that are easy to use and widely acceptable. By January 2024, the City will amend the zoning code to adopt a Universal Design that incentives developers who implement Universal Design features in projects to be eligible for fee reduction or other development incentives. The program will incentive the development of two Universal Design units on an annual basis, starting in 2024 through 2029. Large Households CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-15 SEPTEMBER 2022 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. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-16 SEPTEMBER 2022 TABLE II-16 EMPLOYMENT IN AGRICULTURE INDUSTRY,TUSTIN,CA 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; (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. 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-17 SEPTEMBER 2022 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-18 SEPTEMBER 2022 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.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 Table II-17 includes at-risk units within the city for the 6th planning cycle(2021-2029). Tustin Gardens is a Section 223(a) (7)/221(D) (4) project with a Section 8 contract for 99 units and is extended on an annual basis. The contract was due to expire on July 31, 2022; however, the City has confirmed that the contract has been extended for a new 20-year period which means the contract now expires on July 31, 2041. As a result,these 99 housing units are no longer considered at risk for this planning period. Table II-18 includes a full inventory of assisted housing within the city. The following table provides a summary of the affordable housing projects at-risk of expiring during this planning period. TABLE II-17 AT-RISK UNITS,TUSTIN,CA Expiration Very- Low- Moderate- At- Project Name Date Low Income Income Total Units Risk Units Units Units Chatham 2027 0 212 0 212 Yes Village Westchester 2029 0 149 0 149 Yes Park Flanders 2029 32 16 9 57 Yes Pointe Total 32 377 9 418 Source:City of Tustin,2021 As listed above, Westchester Park, Flanders Pointe and Chatham Village are at-risk communities within Tustin that could be converted towards the end of the planning period. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-19 SEPTEMBER 2022 TABLE II-18 ASSISTED HOUSING INVENTORY,TUSTIN,CA Type/Length Tenant Owner: of Earliest Date Project Name Federal, Type Name, Type(s)of Gov't Affordability Potential #of Bedroom Built Condition Address State,or (Le' Address, Local Assistance Controls Conversion Units Elderly, Mix (if (if known) Tel.# (including Date(s) Familknown) Sec.8 Tustin Goldrich&Kest Fed. HUD -- July/2014 99 Elderly 1001-br 1979 Good Gardens 5150 Overland Ave. 223(a)(7)/221(D)( 100 275 E. 6th, Culver City,CA 4) Tustin, CA 90230 Section 8 92780 Kenyon RPK Development Fed. HUD 207/223(f) January 2040 71 Family 1964 Good Pointe 2566 Overland Ave. 17021-17121 Suite 700 Kenyon Los Angeles,CA Drive 90064 Tustin, CA 92780 Westchester Westchester Park,L.P. State California Tax Income 149 Family 17-1br N/A Good Park(Orange Credit Allocation restricted. 10/2029 93-2br Gardens) Committee No rent 39-3br 1602 Nisson restrictions Rd. Tustin, CA 92780 Flanders Tustin Affordable State California Income 10/2029 57 Family 50-2br 1966 Good Pointe Housing Corp. Statewide restricted. 7-3-br 15520 Tustin Communities No rent Village Way Development restrictions Tustin,CA Authority,1999 92780 Anton Anton Development State California Tax Income May 2070 225 Family 78-1br 2015 Excellent Legacy Company Credit Allocation restricted. 117-2br 3100 Park 1610 R Street,Suite 250 Committee 30-3br Avenue Sacramento,CA 95811 Tustin,CA 92782 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-20 SEPTEMBER 2022 TABLE II-18 ASSISTED HOUSING INVENTORY,TUSTIN,CA Type/Length Tenant Project Name Owner: Federal, of Earliest Date Name, Type(s)of Gov't Affordability Potential #of Type Bedroom Built Condition Address State,or (Le., Address, Local Assistance Controls Conversion Units Elderl Mix (if (if known) Tel.# (including Date(s) Family) known) Sec.8 Coventry Meta Housing State CTCAC Regulatory July 2067 153 Senior 80-1 br 2012 Excellent Court Corporation Agreement 73-2br 16000 1640 S.Sepulveda Blvd., Cambridge Suite 425 Way Los Angeles,CA 90025 Tustin,CA 92782 Tustin Grove Tract 14934 Local Redevelopment DDA1 N/A 21 Family 21-3br N/A Very Tustin,CA Agency Good 92780 Ambrose Tract 15707 Redevelopment DDA1 N/A 5 Family 5-3br N/A Very Lane Local Agency Good Tustin,CA 92780 Heritage Tustin Heritage Place, Local County Revenue Income 04/2057 54 Senior 42-1br 2001 Very Place L.P. Bonds, Tax restricted, 12-2br Good Tustin,CA Credits, RDA Senior 62+ 92780 Loans Chatham Fairfield Residential Local Southern Income 212 Family 126-1br 1969 Good Village Corp. California Home restricted. 2026 86-2br (Hampton Finance Agency No rent Square) restrictions 16331 McFadden Ave. Tustin,CA 92780 Amalfi Irvine Company LOCdJ Density Bonus Income October/207 37 Family 21-1br 2015 Excellent 16000 Legacy 131 Theory restricted 0 16-2br Road Irvine,CA 92617 Tustin,CA 92782 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-21 SEPTEMBER 2022 TABLE II-18 ASSISTED HOUSING INVENTORY,TUSTIN,CA Type/Length Tenant Project Name Owner: Federal, of Earliest Date Name, Type(s)of Gov't Affordability Potential #of Type Bedroom Built Condition Address State,or (Le., Address, Local Assistance Controls Conversion Units Elderl Mix (if (if known) Tel.# (including Date(s) Family) known) Sec.8 Tustin Field I Various owners Local Redevelopment Ownership 45 years of 78 Family 27-2br 2006 Excellent Tustin,CA Agency income initial 51-3br 92782 restricted. purchase date Tustin Field Various owners Local Redevelopment Ownership 45 years of 40 Family 40-3br 2007 Excellent II Agency income initial Tustin,CA restricted. purchase 92782 date Arbor Walk Various owners Local Redevelopment Ownership 45 years of 10 Family 10-3br 2006 Excellent Tustin,CA Agency income initial 92780 restricted. purchase date Cambridge Various owners Local Redevelopment Ownership 45 years of 50 Family 11-1br 2006- Excellent Lane Agency income initial 13-2br 2007 Tustin,CA restricted. purchase 12-3br 92782 date Camden Various owners Local Redevelopment Ownership 45 years of 63 Family 22-2br 2006- Excellent Place Agency income initial 15-3br 2007 Tustin,CA restricted. purchase 92782 date Clarendon Various owners Local Redevelopment Ownership 45 years of 42 Family 42-3br 2006- Excellent Tustin,CA Agency income initial 2007 92782 restricted. purchase date TOTAL 1,193 N/A-Not available iDDA-Disposition and Development Agreement Source:Comprehensive Housing Affordability Strategy 2008-2018,City of Tustin CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-22 SEPTEMBER 2022 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. The City currently enacts Program 3.7, which allows the City to ensure tenants are properly noticed regarding at-risk units and to work with potential purchasers or property owners to provide technical assistance, where feasible, to public and nonprofit agencies interested in purchasing and/or managing units at risk. Additionally, the City has included Program 3.9, which commits the City to registering through HCD so it is aware of any units at-risk of conversion. Program 3.1 requires developers to process a conditional use permit,provide relocation assistance,and/or to provide incentives and assistance for purchase of the units by low- and moderate-income households whenever a project proposes to convert affordable apartments and condominiums. 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 household. The FMR for Orange County for Fiscal Year (FY) 2020 and 2021 is identified below. TABLE II-19 ORANGE COUNTY FAIR MARKET RENT,2020-2021 Year EfficiencyOne- 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-23 SEPTEMBER 2022 This section includes an analysis of potential rent subsidies needed to preserve the City's at-risk affordable housing stock. The analysis assumes that all housing units would be occupied by very low-income households and calculates the total monthly rent income supported by the maximum allowable housing costs at these income levels. The maximum allowable housing costs were calculated as 30 percent of the very-low-income households as outlined by the 2021 HCD State Income Limits for Orange County. The occupancy assumptions used for this analysis are as follows: • A one-bedroom unit assumes a two-person household. • A two-bedroom unit assumes a three-person household. • A three-bedroom unit assumes a four-person household. • A four-bedroom unit assumes a five-person household. The rent subsidy amount was calculated by subtracting the total monthly rent income supported by the housing costs of very-low-income households from the 2021 HUD Fair Market Rents for each project and unit size. Table II-20 below summarizes the analysis and estimates the total cost if rent subsidies were to be used to preserve the affordability of the various at-risk affordable housing developments in Irvine TABLE II-20 COST OF PRESERVATION Chatham Westchester Flanders Project Units Village Park Pointe Total 1 br 126 17 - 143 2 br 86 93 50 229 3 br - 39 3 42 4 br - - - 0 Total Monthly Rent Income Supported by Housing Cost $299,653 $229,213 $80,731 $609,596 of Very Low Income Households Total Monthly Rent Allowed by Fair Market $438,354 $374,732 $126,231 $939,317 Rents Total Annual Subsidies $138,702 $145,520 $45,500 $329,721 Required Source:HUD User FY 2021 Fair Market Rent Documentation System CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-24 SEPTEMBER 2022 The total annual subsidy amount would be $329,721 to preserve all 414 at-risk units in Tustin for one year. Therefore,the total cost to extend the affordability of all units for 20 years would be approximately$6,594,420. The California Department of Housing and Community Development maintains a list of entities with the capacity to oversee preservation of affordable housing. These entities have interest to purchase federally-assisted multifamily rental housing projects within Orange County pursuant to California Government Code Section 65863.11: • Neighborhood Housing • Poker Flats LLC Services of Orange County Inc. • Coalition for Economic • Century Housing Corporation Survival • Civic Center Barrio Housing • A Community of Friends Corp. • CSI Support&Development • Long Beach Affordable Services Housing Coalition,Inc . ROEM Development • Housing Corporation of Corporation America • City of Newport Beach • Nexus for Affordable Housing . Abbey Road Inc. • Orange Housing Development • Jamboree Housing Corporation Corporation • Riverside Chartable . Innovative Housing Corporation Opportunities, Inc. • Hart Community Homes • L +M Fund Management LLC • Keller& Company In the event that a development becomes at risk of conversion to market-rate housing, the City will maintain contact with the qualified entities who may have an interest in acquiring at-risk units. The City will assist the entities in identifying potential funding sources to acquire the at-risk units. Potential funding sources that could be used to preserve the affordability are discussed in Appendix C, Affordable Housing Resources. Potential funding sources identified include: • Senate Bill 2 Grants • City Non-profit Partnerships • California Debt Limit Allocation Committee (CDLAC) • Community Development Block Grant funds • New Development CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-25 SEPTEMBER 2022 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 II-17 includes at-risk units within the city for the 6th planning cycle(2021-2029). Table II-18 contains 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. 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 Programs 3.7 and 3.9. Replacement of Affordable Units Another option for maintaining the City's affordable housing inventory is to replace existing affordable housing units with new construction and application of new affordability covenants once the current covenants expire. Based on the HUD Total Development Cost (TDC) Limits. These development costs include land and acquisition, construction, architecture and engineering, interest and financing charges, developer fees,and other miscellaneous soft costs. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-26 SEPTEMBER 2022 TABLE II-21 COST OF REPLACEMENT Year Project 1 Project 2 Project 3 Average Address 10861 Acacia 16790 S.Harbor 3312 W.First St. - Pkwy Blvd. City Garden Grove Fountain Valley Santa Ana - Units 47 50 75 - Total Development $19.2 mil $29.6 mil $29.7 mil - Costs Cost per Unit $408,510 $592,000 $396,000 $465,503 Source:Jamboree Housing,2022;Orange County Register,2020;Multi-Housing News,2019. As shown above in Table II-21, the average development cost per unit in the Tustin area is $465,503. Therefore, the total estimated cost to replace 414 at-risk units with new construction would be approximately$192.7 million. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-27 SEPTEMBER 2022 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-28 SEPTEMBER 2022 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-29 SEPTEMBER 2022 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 2021), monthly mortgage payments on median priced single-family detached homes CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-30 SEPTEMBER 2022 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 II-22 and II-23). TABLE II-22 NEW AND RESALE PRICE OF HOMES AND CONDOMINIUMS TUSTIN AND NEIGHBORING JURISDICTIONS 2020 Median Home Median Home %Change from city Zip Code Price-Q2 20201 Price-Q2 20191 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% Garden 92841 $715,000 $615,000 +16.3% 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% Irvine 92606 $815,000 $799,500 +1.9% 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 $1,060,0002 $930,0002 +17.2% 92706 $730,000 $650,000 +12.3% 92707 $497,500 $500,000 -0.5% CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-31 SEPTEMBER 2022 TABLE II-22 NEW AND RESALE PRICE OF HOMES AND CONDOMINIUMS TUSTIN AND NEIGHBORING JURISDICTIONS 2020 Median Home Median Home %Change from City Zip Code Price-Q2 20201 Price-Q2 20191 2019 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 The greatest impediment to homeownership, however, is credit worthiness. According to the Federal Housing Authority, lenders consider a persons debt-to- income ratio,cash available for down payment,and credit history,when determining a maximum loan amount. Many financial institutions are willing to significantly decrease down payment requirements and increase loan amounts to persons with good credit rating. TABLE II-23 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 bedrooms 6,325 720 SF $2,331 3 bedrooms 2,044 1,087 SF $3,227 4 bedrooms 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. 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-32 SEPTEMBER 2022 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 I1-24). 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 Program 1.10, Development and Permit Streamlining, and Program 1.5, Zoning Code Streamlining Program. 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. Parking requirements could be a potential constraint for single-family and multi- family residential development. Required parking for multi-family projects is two CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-33 SEPTEMBER 2022 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 1.2,that commits to adopting new objective design standards that facilitate high-quality residential development; while ensuring the provision of adequate parking. Additionally,Program 1.13 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-34 SEPTEMBER 2022 TABLE II-24 SUMMARY OF RESIDENTIAL ZONING REGULATIONS CITY OF TUSTIN Minimum Density Lot Building Front Interior Corner Rear Zoning Lot Area Max. Coverage Height Yard Side Yard Side Yard Yard Parking du/ac R-A 7,200 7 40 30 feet 20 feet 5 feet 10 feet 5 feet,but 2 car garage Residential square percent no less per dwelling, Agricultural feet than 1,000 3 car garage District feet clear per dwelling and with five or unobstruc more ted on bedrooms open space. E-4 10,000 7 40 30 feet 20 feet 10%of lot 10%of lot 20 2 car garage Residential square percent width width percent per dwelling, Estate District feet lot depth 3 car garage per dwelling with five or more bedrooms R-1 Single- 7,200 7 40 30 feet 20 feet 5 feet 10 feet 5 feet,but 2 car garage Family square percent no less per dwelling, Residential feet than 1,000 3 car garage District feet clear per dwelling and with five or unobstruc more ted on bedrooms rear 1/3 of lot. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-35 SEPTEMBER 2022 TABLE II-24 SUMMARY OF RESIDENTIAL ZONING REGULATIONS CITY OF TUSTIN Minimum Density Lot Building Front Interior Corner Rear Zoning Lot Area Max. Coverage Height Yard Side Yard Side Yard Yard Parking du/ac R-2 Duplex 3,500 15 40 30 feet 20 feet 5 feet 10 feet - 2 car garage Residential square percent per dwelling; District feet one of which shall be garage space R-2 Duplex 3,500 15 50 35 feet 20 feet 5 feet 10 feet 10 feet 2 car garage Residential square percent per dwelling; District feet one of which (single shall be structure) garage space R-3 Multiple 1,750 25 65 35 feet 15 feet 5 feet 10 feet 10 feet 2 assigned Family square percent covered Residential feet spaces per District unit,plus one unassigned open space per 4 units R-4 Suburban 7,2000 25 2 stories 20 feet 5 feet 10 feet 25 feet 2 assigned Residential square or 35 feet covered District feet spaces per unit,plus one unassigned open space per 4 units CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-36 SEPTEMBER 2022 TABLE II-24 SUMMARY OF RESIDENTIAL ZONING REGULATIONS CITY OF TUSTIN Minimum Density Lot Building Front Interior Corner Rear Zoning Lot Area Max. Coverage Height Yard Side Yard Side Yard Yard Parking du/ac MPH Mobile Minimum 10 75 30 feet Trailer 2 spaces per Home Park 5-acre site percent park-none. mobile home District for mobile Individual lot,plus 1 home lot-5 feet guest space park. (measure for each 10 Travel from curb trailer to actual mobile home shall not structure, lots. exceed hitch 10%of excluded). total spaces in mobile home ark. P-D Planned 10,000 Range To be To be To be To be To be 2 assigned Development Inc. determine determine determine determined determine covered spaces District 4.485 d with d with d with with d with per unit,plus (low) adoption adoption adoption adoption of adoption one unassigned 11.834 of P-D of P-D of P-D P-D District of P-D open space per (rued) District District District District 4 units 17.39 (high) Source:City of Tustin,Zoning Code,2021 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-37 SEPTEMBER 2022 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. RHASP and DCCSP 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 following two specific plan areas will also accommodate additional residential units.: • Downtown Commercial Core Specific Plan(DCCSP) (adopted July 3,2018) • Red Hill Avenue Specific Plan (RHASP) (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. he 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. A total of 137 units have been entitled at this site and building ad grading plans are nearing the conclusion of the plan check review and would shortly thereafter be permitted for construction. Residential Allocation Reservation Process Prior to adoption of the DCCSP and RHASP, the project areas were zoned for commercial use. Both Specific Plans retain commercial focus; however, they also introduce residential uses to serve as an economic engine to invigorate the businesses within the areas. The two Specific Plans do not entitle residential uses by right and there are no "growth caps" built into the DCCSP and RHASP. Rather, the Specific Plans establish a process called Residential Allocation Reservation (RAR) as a pre- requisite for allocating residential units that have been analyzed within Program EIR for the respective Specific Plan. The intent of this approach is to allow for a streamlined process for developers to benefit by tiering of the already certified CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-38 SEPTEMBER 2022 environmental studies. Additional units can be added in the future with the appropriate environmental review (i.e. supplemental or addendum to EIR). RAR Review Process Overview The Specific Plan provides a two-step residential allocation reservation ("RAR") application process: (1) a preliminary allocation ("Preliminary RAR") application, and (2) a final allocation ("Final RAR") application. At the Preliminary RAR stage, the Community Development Director("Director") reviews and considers whether a proposed project substantially complies with the applicable portions of the Specific Plan. If it does, the Director "shall make the Required Findings (approve the first phase of the Preliminary RAR process, which shall provide a preliminary allocation of residential units for the project." If it does not, the Director must inform the applicant in writing of the standards with which the project does not substantially comply within thirty days of receiving the application (Gov. Code, § 65943, subd. (a).)To approve the Preliminary RAR,the Director must find the project substantially conforms to applicable Specific Plan provisions. Preliminary RAR Review Considerations The Community Development Director may approve the submitted plans if he/she finds that the location, size, architectural features, and general appearance of the proposed development will not impair the orderly and harmonious development of the area, the present or future development therein, the occupancy thereof, or the community as a whole. In making these findings, the Community Development Director shall consider the following for all new development projects within the DCCSP and RHASP: 1) The development is consistent with the overall vision,goals,and intent of the RHASP. 2) The development is consistent with the policies and intent of the Development Plan,including the Urban Design plan. 3) The project,including the proposed uses and requested entitlements,comply with the Permitted Land Use and Activities Table and complements and contributes to the project area. 4) The development substantially complies with or obtained approval of a modification to conformance with the Commercial and/or Mixed-Use Development Standards. 5) The development substantially complies with or has obtained approval of a modification to conformance with the Commercial and/or Mixed-Use Design Criteria. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-39 SEPTEMBER 2022 6) Compliance or modification thereto with applicable Development Standards and Design Criteria is demonstrated and ensured through Design Review of the project site plan,building elevations,floor plan,parking plan,landscaping plan,lighting plan,access plans,refuse plans,and any other applicable plan(s) or document(s). 7) Required parking for the project is provided entirely on-site, or by an alternative means, which is approved concurrently or made a condition of approval. Approval of a parking alternative will have a beneficial impact and does not adversely affect development or the surrounding area. 8) The development demonstrates high-quality architectural design and site planning and reflects the nature of the site and the surrounding area through the following: a) Incorporating roof forms and facades that provide building articulation, create visual interest, and reduce the appearance of uniform building massing. b) Creating a design that is both cohesive and varying with respect to architectural style, architectural details, windows, doors, colors, and materials. c) Facilitating pedestrian orientation through building placement, building scale,and architectural design. d) Ensuring associated elements including parking, service areas, landscaping, lighting and pedestrian access, and amenities are functional and serve to enhance the overall appearance and experience of the project. e) Siting and designing structures that relate to and respect adjacent development and sensitive land uses. 9) The development is supported by existing infrastructure or will be supported by infrastructure improvements paid for by the developer. 10) The developer consents to enter into a mutually agreeable Development Agreement if the City requests one. 11) The project impacts are assessed through the approved RHASP Program EIR or through subsequent environmental documentation in compliance with the CEQA guidelines. Preliminary RAR Findings for Approval Findings required for approval of the RAR include the following: 1) The project is substantially consistent with the uses, design criteria, and development regulations of the RHASP. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-40 SEPTEMBER 2022 2) The project implements the vision of the Specific Plan related to excellence in architectural design, provision of substantial usable common open space, provision of public art (which may consist of murals, sculpture, decorative fountains or other art deemed acceptable) connectivity to adjacent parks and/or schools if appropriate,and pedestrian connections. 3) The number of units requested is within the thresholds established by the Specific Plan's Program EIR. 4) The overall project meets the findings for Design Review per Tustin City Code 9272 as follows: a) To provide for the review of building design, site planning, and site development in order to protect the increasing value, standards, and importance of land and development in the City due to the urbanization of Orange County. b) To retain and strengthen the unity and order of the visual community. c) To ensure that new uses and structures enhance their sites and are harmonious with the highest standards of improvements in the surrounding area and total community. RAR Process-Potential Constraints During the draft Housing Element review,HCD staff identified the need to evaluate the RAR process as a potential governmental constraint to housing development as the process creates"uncertainty" and generally is a discretionary review process that requires review by the Community Development Director. In addition,the City was advised to consider and propose a Program(s) to address such a potential for a housing development constraint. The RAR process and structure was created with public input during the Specific Plan preparation process, prior to its adoption. Upon considerations of HCD's input the City understands the perception that the RAR process could be perceived as a barrier to development due to the discretionary review process and decisions making authority that lies with the Community Development Director. The City has revised Program 1.4(a) to incorporate the following: • Conduct an analysis of the Residential Allocation Reservation (RAR) process applicable in the following Specific Plan areas: DCCSP and RHASP and identify any potential barriers to housing developments. • Amend DCCSP and RHASP Specific Plans review procedures and/or applicable Specific Plan sections to eliminate governmental constraints that may pose a barrier to housing development,with an emphasis on eliminating redundant processes,ambiguities and discretionary action(s). CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-41 SEPTEMBER 2022 • Amend DCCSP and RHASP to provide for additional housing units aligned with economic objectives and infrastructure capacities by re-evaluating the housing units allocated to each geographic area in each Specific Plan. • Conduct environmental analysis, as needed, to accommodate additional housing units in each Specific Plan area,aligned with economic objectives and infrastructure capacities. In addition, the City is currently engaging with a consultant to provide recommendations for amendments and policy changes to both specific plans based on market factors and with the goal of incentivizing housing development, and the report will be completed by December 2022. Any recommended policy changes will be incorporated into the Specific Plans. Furthermore, City's Design Review process is in place for Tustin to ensure that incremental development complements the City's historic character and to ensure that new development enhances the quality of life for the community. However,the process may pose a constraint to development by requiring compliance with subjective design guidance which potentially adds additional review times which results in additional project costs. As part of Program 1.2, the City will amend the Tustin City Code 9272 (Design Review) to remove subjective design guidance will and adopt objective design standards to facilitate high-quality, streamlined residential development. These new objective design standards would serve to further increase certainty and reduce inefficiencies related to project's design review and approval. 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 (Lrmally MCAS Tustin) The Tustin Legacy 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-42 SEPTEMBER 2022 to market demand, the City processed an amendment to the Tustin Legacy Specific Plan that allowed for additional renter-occupied units, including affordable rental units. Within Neighborhood D of the Tustin Legacy 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. 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 is market demands will influence the timing of development at Tustin Legacy. 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 Tustin Legacy 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 Tustin Legacy 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 I1-21 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-43 SEPTEMBER 2022 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, 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 PC Zone 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-44 SEPTEMBER 2022 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 encourages development of housing for lower income households within the Red Hill Avenue and Downtown Commercial Core Specific Plan areas. The City's density bonus program will be updated in compliance with current State law.The City also enacts an inclusionary housing ordinance under Chapter 9B of the City's Municipal Code, Voluntary Workforce Housing Incentive Program. The ordinance is specifically applicable to the RHASP and DCCSP areas. Unlike the other cities within Orange County, Tustin s Inclusionary Housing Ordinance is voluntary. This means it only becomes applicable when a developer makes the voluntary election to request the discretionary and valuable benefit of adding residential units. If the subject area already provides residential zoning, unlike other cities' ordinances,Tustin does not require inclusionary housing. The City's ordinance is similar to a housing residential overlay zone, whereby the underlaying zone is unchanged and in the case of Tustin, the underlaying zone maintains the commercial development rights. In the case of Tustin, the "overlay zone" allows residential development subject to meeting the Ordinance's criteria summarized in the table above, where the development of residential units requires compliance with the providing of affordable units and in some case, the payment of an in-lieu fee. The table below provide a summary of the percent of units required to be affordable and the various options available to satisfy the requirements.This table describes the applicability of the four options available to satisfy the ordinance requirement,for an example 137 unit residential project. The in-lieu fee only applies to two of the four options shown in the table below. As the table shows, the requirement may be satisfied with the provision of affordable units, or a combination of the provision of units and the payment of an in-lieu fee. The in-lieu fee only applies to half the base units. For example, a project with 137 units, which included Density Bonus units. The base units was 114 units. The Developer will pay to City an in-lieu fee totaling $786,657, which is calculated by multiplying the $13,801 voluntary housing incentive program in-lieu fee by 57 (one- half (1/2) the 114 base units provided on-site). Other cities calculate the fee per unit for all units. If Tustin is to calculate per unit basis,the in-lieu fee of$786,657 divided by 137 units and would equate to as little as $5,742 per unit,which is well below other cities in Orange County. If this is translated to per square foot cost,with an average size of unit being 1,300 square feet, Tustin s CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-45 SEPTEMBER 2022 in-lieu fee would be $4.41 per square foot, which is much lower than other cities in Orange County. TABLE II-25 INCLUSIONARY HOUSING OPTIONS FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS Options far Projects with 2D or.more residentia l u nits Example for La IC u la(ions: lla"Base Units"plus 23 Density Ed Units 137 Total Units M new MS+dentrtrd projects shot?inctudC offordofC encs. Requirement Average In- it un [okutorions art the numberof units is hosed on tyle number of fakulation Affordable for on-Site IM1-Ileu Fee lieu ver fee for Carr "Dose ufi+r5"prat trsrd fog the p.ojeer.. p units roJett 0.41te OpdM231C1) L5%ofthe"ban units"SKALI BE AFFORDABLE =X14.35% 17 No[wpplk6y a6 G%of15%sh.0 be offorobbir Ln vrry fowirxomr hoosrhoVl =114'6% 45%01$v%shm be ollibowe to bwancomc hoosehoky =114.4.5% 5 a.;%o(t5�s+wu ar a(JarwG�e m moQrrotc,+x'nnr nousrnords =114.4.5% s OR 0n tr a99zs ption 17.5:4 of the"baso un ill'SHALL BE RF FORDABLE =114112.5% 14 Nat Applkabfe O [a)[2) 7.5%nf 1l.5%Sbwne n&,dnhfe rn rery inw.—,hnu[ehne& _110.7.5% 4 3N of 12.5%rWR or rlord a to modrrrrtrdhcanr hovsehofds =114'5% 6 OR 69523 0.0100. 5%af She"base units'SHALL BE AFFORDABLE to very low =$766,6571 -option -114•SK B $ 786,6s1 $ 5,742 site (alfa11a1 income housMlds plus payment of an In-lieu Pee[see below) 137 OR 89923 0-00 OFF 10%of the"hast units"SHALL BE AFFO RDRB LE to law intone =ID',Y. 11 $196,6571 site •Option housholds plus payment of an In-lieu lee lseebelawJ =114• $ 796,45S7157 $ 5,747 iaH6y[by 89925{4)111 •aphons{a){3F(a)and[a)[3)[4}require payment of on in•lieu fee calculated by: $15,801 x Half the number of base units =$13,801 x 57 $ 786,657 Nores:Per TCC 89924,In cwpunng tM coral numherM voiunrxrr worhlarrp hn,ning Inrenrive program unir%r"uIred in a rr9drn+lal pmjen,frazrmns shall he —M&d up to rhe r whose nuirlse, For comparison, in La Habra, per a city staff report, a 30-unit project would be required to provide $1,00,000 in-lieu fee which is based on the city's calculation for building five affordable units with an assumed valuation of $200,000 per unit. In Huntington Beach, the cost per unit escalates with the cost for a project with 9 units being$16,500 per unit. In Santa Ana the cost is$15 per square foot and San Clemente is$7.63 per square foot. Tustin's program has proved successful in implementation with the approval of a 137 units project in 2021 and another 42 unit project is currently under review by the City which will also include the provision of on-site affordable units to very low income households and the payment of an in-lieu fee totaling$262,219. The table below describes the applicability of the four options available to satisfy the ordinance requirement,for a project with fewer than 20 units. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-46 SEPTEMBER 2022 TABLE II-26 FEE OPTIONS FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS Options for Residential Projects with fewer than 20 units: The primary mranS of complying Shall be the provision of on-site units- f`0`ever,d Je eloPer may only Salisfy the requirements by means of an on-site 89925{a} alternative to on voluntary workforce housing incentive program units in accordance with the requirements and procedures of this Section 89913. Requirement may be satisfied,in whole or in part,by the construction Off-Site B9925(b) of new units,or the conversion of existing market rate units to voluntary workforce housing incentive program units,offsite within the city's jurisdictional boundary- in-lieu 89925[c) Requirement may be Satisfied in whole or in part,by payment to the =$12,651 x 19 $ 240,369 payment City's established in-lieu fee. land Requirement may be sat isfled,in whole or in part,by an alternative M25(d) option acceptable to the City,which may include without limitation the dedication dedication of land for affordable housing. It should be noted, that the in-lieu fee for projects under 20 units is reduced as the project size becomes smaller. TABLE II-27 FEE PER UNIT FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS 2022 Tustin In-Lieu Fee Per Unit For project with fewer than 20 units In-lieu per unit reduced for smaller projects 1 -4 units $9,200 5-9 units $10,350 10-14 units $11,501 15-19 units $12,651 This ensures that smaller projects are not cost burdened. In smaller projects, on-site units are not required to be constructed. A typical cost for constructing a 1,000 square foot unit on-site is approximately $200,000. As an example, for a 19-unit project, a total of 3 affordable units would have been required at$600,000 or more,if subjected to 15% affordable units on site. Instead,project developer could opt to pay in lieu fee of $12,651 per unit. This is considerably lower than adjacent cities such as Irvine at $17,000 per unit,Huntington Beach at$16,500, Santa Ana at$15,000 per unit and La Habra at$200,000 per unit. A memorandum titled, Inclusionary Housing Ordinance Information and Comparison, dated August 17, 2021 was prepared by the City's Community Development Department for City Council. The memo was prepared in consistency with the City's CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-47 SEPTEMBER 2022 desire to remain informed in order to create affordable and workforce housing options. The analysis prepared identified that 140 market rate units have been built and the City has collected over $1,979,600 in In-Lieu fees in the Downtown Commercial Core Plan. The Fund is to be expended exclusively to provide housing to extremely low, very low, low, and moderate-income households in the City of Tustin, along with administration and compliance monitoring of the voluntary workforce housing incentive program which includes the following: • Assistance with affordable housing projects with"gap" financing • Assistance with extension of affordable deed restrictions on applicable units At that time, the City was also reviewing a pending development application (13751 and 13841 Red Hill Avenue) which was approved and resulted in six new very low- income units and add approximately$730,000 to the fund. Staff reviewed a sampling of fifteen (15) other Orange County cities, and of those, nine (9) do not have an inclusionary housing ordinance, and six (6) cities have a mandatory affordable housing requirement,which allows the payment of in-lieu fees under certain circumstances. Based on the research conducted, the City's fees and program are comparable or lower to other Cities' ordinances in Orange County. Below is a summary of the six cities with inclusionary housing ordinances. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-48 SEPTEMBER 2022 TABLE II-28 INCLUSIONARY HOUSING FEE COMPARISON CRY Indusiorl APPMee6lFity Afjordas le In-Lieu Fee Allowed? la"i-Fes Resources Link Ordtuttpe Requirements. to Habra Mandatory Prajec{s with "5 or.,I Yes TBO;Pawnent of per unit Cost not hitp:ilwwvr_lahabra[Icy cOm/Ooeumant[emer/ 10«more units prmvided on-site lbased on the View/11635/0rd-18331hii. Inds valuatbn of per unit) E.ample: Assumed valuation per unit Is$200,000 30 units proposed is.eul.ined to be affordable 15 nits) $2000W a5=$l million Huntington Mandl—, prmjects with 10%of total Yes fmr protects wish 9 on .Three Units$9,630/unit Mtps.//hvntinRtonbeach.le¢istar.cmmNiew.asha?M-F Beach 3olmmm units(Romalor fewer units •Four Unit,$10,600{unit &10=1228132&GU10=F3A3]la 1 -SO68-aC01-AElC- untr For-Sale) •Five units$11,780/unit 810329008361 Fee is based on sliding scale .Sit unit:$12,960/unit •Seven units$16,160/unit •Eight Units$15.330/unit hUos,!/www.mcode,us/codes/huminalmnbeach/view.o • Nine units$16.500hnit ho?took-zonin¢ontle-23-230-,_230 26&frames=on IMne MaMatary Ismject.with Is%of total Yes for project with$0 is, $17.000 per u n it prior to 2007. CHAPTER 2.3.-AFFOR[iABLE HOu51NG 50«mom units Ie55 until TOO based on formula. IMPI FMFW iA71 PRI IMne CA l ..its $aada Ano m.nd ry Pmjett with 5 For 521x,In Yes •Pm)ects with 5 1m 20 i nils:$5 per SF yp�n ial lo[s/uniAsor of total units of hdbitable Spate LOdngCa.Jn_ ore formoderate •Pfoj"with 20+units.$$per$P of laLL8lt:5i habitable space ncd�aeM;15% •Minn..0csmber 1,2021 cost shall of total units berind to$15 per SF of for low-Income habitable space 0a 10%very 1 - nceme W Habra Mini Projects with 15%of total Y. no,Payment of per ,it Coll not Mtp://www.lahabra[ity pm/OmcumentCenters 10 or more units provided onsite lbased on[he View/11635/Ord-1833?pidEd= units valuation of per unit) xample: Assumed valuation per unit Is$200.000 3C units proposed 15%ren iced to be affordable 15 units) $200000.5=$1 minion Huntlnst'" Mandatary projects with 10%Ttmtal res fprprajedswbh9mr Three 59,a30luni[ nrtps.(Lunrinaionbeach leaislar.cmm/view.ashatM=F Beach 3or more unitstRomislor fewer units •Four units$10,600junit &10=72281321L61110=F3A37114-5068-4C01-AE1C- onits For-Sale) •Five Units$11,780/unit 8F0329008361 Fee is based on sliding ladle .$1.Units$12,960/unit •Seven units$1gm0/Inn •Eight units 515.330/unithops,//www.mcmde,ws/codes/nunungtanbeacn/view.It •Nm.units$16,5001unit ho?tooit•xonine rode-23-230 i-230 268iframes=on IMne McMatary prgect.with 15%of total Yes for project with$0 is, $17,000 per u n it prior to 2007, CHAPTFP 2.3..AFFOR[iABtE H(1u51N6' 50«mnre units I.,until TOO based on formula. IMVIEMEN IAIIpN PR0fF0lIRF llnnina l l im—C I units $ante Ana Mandatory project with ---a 1p% Yes •Projects with 5 to 20 units;SS per Sr 'yp�n ig lots/unins« of total units of habitable space f,02.^.BCSJn_ ore formoderate •Project;with 20,units:$S per SF of l+ro¢rr.s habitable space For li 15% •Effil irve Ocspber 1,3021 cost shall of total units be caromed to$15 per SF of for low-income habitable space 0. l0%nary I w 'come Based on the foregoing, the based upon the foregoing, the City's current Ordinance is not considered as a constraint, due to the many options provided to satisfy the requirement. However, the City's current ordinance will be evaluated as part of Program 1.4 "(New) Voluntary Workforce Housing" in conjunction with the reassessment on the effectiveness of the DCCSP and RHASP to determine if adjustments are desired.The City is currently engaging with a consultant to provide recommendations for amendments and policy changes based on market factors, and the report will be completed by December 2022. Any recommended policy changes will be incorporated into to Zoning Code within 12-months of the City receiving the completed report. The City has amended Program 1.4 to incorporate changes to respond to identified constraints resulting from the study." CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-49 SEPTEMBER 2022 Housing for Persons with Disabilities/Reasonable Accommodation As discussed in previously and shown in Table I1-14, the City of Tustin includes a population of approximately 5,238 persons with a disability, or 6.6 percent of the population. As the population ages, the proportion of persons with disabilities generally increases. The City's population of persons with disabilities is inclusive of all races,ethnicities,and sexes.The City's population of disabled persons is relatively comparable or smaller compared to the County's disabled population, as discussed in Appendix D. Nevertheless, the City continues to assess and remove potential barriers to the provision of reasonable accommodation of housing persons with disabilities and the construction of new group homes and residential care facilities in the city. 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). CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-50 SEPTEMBER 2022 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. The City of Tustin, as described in Tustin City Code (TCC) 9278, provides for the reasonable accommodation of regulations and procedures to ensure equal access to housing, and to facilitate the development of housing, for individuals with disabilities. A request for reasonable accommodation may be made by any individual with a disability, a parent or legal guardian of a minor with a disability, his or her other legally authorized representative, or a developer or provider of housing for individuals with disabilities,when the application of a land use,zoning or building regulation, policy,practice or procedure, or other requirement acts as a barrier to fair housing opportunities. The request may be made by filing a completed development application form with the Community Development Department and would need to include the following information: • A description of the requested accommodation; • A reference of the specific code for which accommodation is being requested; • The basis for the claim that the applicant is considered disabled; • Reason(s) that the requested accommodation is necessary for the individual with disability to use and enjoy the dwelling; • Confirmation that the property is the primary residence of the disabled person; • Plans and detailed information of any proposed physical improvements to the property; and • Any other information necessary to evaluate the proposed request for reasonable accommodation. Requests for reasonable accommodation are administrative in nature, and the Community Development Director has the authority to grant reasonable accommodation requests, without a public hearing. The decision to grant, grant with conditions, or deny a request for reasonable accommodation must be consistent with fair housing laws and required findings below: • The housing, which is the subject of the request for reasonable accommodation,will be occupied as the primary residence by an individual with a disability • The requested accommodation is necessary to make housing available to an individual with disabilities protected under the fair housing laws CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-51 SEPTEMBER 2022 • The requested accommodation would not impose an undue financial or administrative burden on the City; and • The requested accommodation would not require a fundamental alteration in the nature of the City's land use and zoning codes and policies. The application and review process is designed to be a streamlined review process that is based on the facts provided by the requestor. The ability to grant with conditions, ensures that the department has the flexibility to consider the unique nature of the applicant's request and grant the accommodation that best suits the needs of the requestor. As per the application materials listed above and required finding,the intent is only to verify that the request of the applicant and to ensure that the beneficiary of the reasonable accommodation is being properly considered in accordance with fair housing laws and the city codes. The city code has a few provisions that may act as constraints for those seeking reasonable accommodations,including the following: • 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. • 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. • An approved reasonable accommodation is a personal accommodation for the disabled individual requesting such accommodation and does not run with the land. • At such time that the reasonable accommodation is no longer necessary or the disabled individual no longer resides at the property,the property shall be restored to its previous condition unless the Community Development Director determines that it would be impractical or financially unfeasible to return the property to its previous condition. • A deed restriction shall be recorded against the property to ensure compliance with conditions of approval, potential removal of the accommodation, and use restrictions. • Presently, applicants for reasonable accommodation must provide a $500 deposit which is billed hourly for staff time. • Requires that an applicant for reasonable accommodation to provide confirmation that the property is the primary residence of the disabled person. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-52 SEPTEMBER 2022 The City will complete a code amendment as identified in a new program(Program 2.4d) to ensure that the code does not require the property to be in compliance with existing codes, so that the reasonable accommodation can proceed without the needs for any additional investments, which may prevent someone from seeking a reasonable accommodation. In addition, the code will be amended to state that a Reasonable Accommodation shall not be required to be reviewed with other requested entitlements, and rather, that it can be acted upon independent of any other applications. The City will also remove the annual inspection as they may be a deterrent to anyone seeking a reasonable accommodation. The code will also be amended to state the any reasonable accommodation may be transferred to another person with the same or similar accommodation,upon the City receiving a request to transfer the accommodation,which would serve the property a desirable location for persons with disabilities. The code will also be amended to clearly state that the reasonable accommodation shall not conditionally require the return of the property to its original condition as they may be a deterrent for some seeking a reasonable accommodation. The code will be amended to remove the deed restriction recordation so that is does not serve as a constraint for those seeking an accommodation. And finally, the City will take a resolution to the City council to remove the current applicable fee and remove the requirement that the applicant provide confirmation that the property is the primary residence of the disabled person since a disabled person may spend time at other properties other than their primary residence. 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 also discussed in Appendix D. Emergency Shelters,Transitional Housing,and Supportive Housing Homelessness is a statewide concern that affects many cities and counties. Throughout the country, homelessness has become an ongoing problem. Factors contributing to homelessness include the general lack of housing affordable to low-and moderate-income persons,increases in the number of persons whose incomes fall below the poverty level,reductions in public subsidy to the poor,and the deinstitutionalization of the mentally ill.The issue of homelessness is considered regional in nature.Nomadic tendencies of homeless persons make it difficult to assess the population accurately. Orange County's 2019 Sheltered Point-In-Time Count was taken on the night of Tuesday, January 22, 2019. In Tustin, the 2019 Point-In-Time count identified 95 unsheltered homeless persons and 264 sheltered homeless persons, for a total of 359 homeless persons. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-53 SEPTEMBER 2022 SB 2 defines the following: "Emergency Shelters" as housing for homeless purposes intended for occupancy of less than six (6) months, where no person is denied occupancy because of inability to pay. "Transitional housing" is rental housing for stays of at least six (6) months where the units are re-circulated to another person after a set period. "Supportive Housing" has no limit on the length of stay, provides supportive services and is occupied by low-income persons with disabilities and certain other disabled persons. SB 2 requires the City to identify the needs for Emergency Shelters in its Housing Element and to designate zoning districts adequate to accommodate the need. In those districts,emergency shelters must be allowed without a conditional use permit or other discretionary approvals. The City may apply certain written, objective development and management standards,such as number of beds and length of stay, if no zoning district exists that meets this standard. Alternatively,a community may require a conditional use permit for emergency shelters if they already have enough shelters to satisfy the need; or have entered into partnership agreement with up to two other communities to develop an emergency shelter that will meet their collective needs. Transitional and Supportive Housing must be treated as a residential use of property, subject to only to same restrictions that apply to other housing of the same type in that zone. Homeless Accommodation-Implementation With the closure of the Marine Corps Air Station (MCAS) Tustin, the City was provided with opportunities to address homeless accommodations. As part of the conveyance process and under the Base Closure Community Redevelopment and Homeless Assistance Act of 1994 (The "Redevelopment Act"), the City of Tustin as, the Local Redevelopment Agency (LRA) was required to consider the interest of the homeless in buildings and property on the base in preparing the Reuse Plan (MCAS Tustin Specific Plan/Reuse Plan), now known as the Tustin Legacy Specific Plan (TLSP). In developing the Reuse Plan, one criterion the Secretary of Housing and Urban Development(HUD)utilized to determine the adequacy of the Reuse Plan was whether the Plan considered the size and nature of the homeless population in the communities,in the vicinity of the installation,and availability of existing services to meet the needs of the homeless in such communities. At the time of the preparation of the Reuse Plan, it was estimated that there was a total net homeless need of 411 persons in the City of Tustin and City of Irvine (a portion of the TLSP is located within the City of Irvine jurisdiction). A large portion of this homeless need was identified as necessary to support emergency transitional housing for youth and individuals. The local homeless need as described in both Tustin and Irvine's Consolidated Plans also indicated a gap in the continuum of care in the areas of vocational and job training/educational opportunities, some emergency and transitional housing units for individuals and families, support services,and affordable ownership units.Accordingly,the Homeless Assistance Plan CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-54 SEPTEMBER 2022 for TLSP was adopted to addresses the problem of homelessness by utilizing the continuum of care model promulgated by HUD for accommodating the needs of the homeless in a manner which is consistent with the Consolidated Plans approved for the cities of Tustin and Irvine. The fundamental components of the continuum of care system implemented with the TLSP: • Provides emergency shelter beds; • Offers transitional housing and support services which enable homeless persons to progress to self-sufficiency;and • Provides opportunities for permanent affordable housing by the private sector. As a result, the adopted TLSP provided sites and designated land uses to accommodate the identified homeless needs. The following sites were set aside in implementing the homeless accommodation at TLSP: • An approximate five(5)acre transitional/emergency shelter site was set aside for accommodation of the homeless at Tustin Legacy(formerly MCAS Tustin). The City acquired a site from the Department of Navy;initially ground leased the site, and ultimately conveyed the site to the Orange County Rescue Mission at no cost and facilitated the construction of Village of Hope, a 262- bed emergency housing facility, without the need for a Conditional Use Permit. The project has been completed and Village of Hope is currently operating and will be expanded in the near future to include 125 additional beds. • A four (4) acre site was recommended by the City of Tustin and deeded directly by the Department of Navy at no cost to the Orange County Social Services Agency for the development of an abused and neglected children and their families and emancipated youth facility with 90 bed capacity.The project is complete. • A total of 50 transitional housing units were originally included in the Base Reuse Plan. Based on further negotiations with non-profit homeless providers, a total of 32 new transitional housing units were constructed and conveyed at no cost to non-profit homeless providers at TLSP.These units are dispersed throughout the TLSP community to allow integration into the community. The sites are designated as residential sites and the units were constructed in conjunction with market rate units subject to only those restrictions that apply to other residential uses.The units are transparent since the units are developed identical to those of market rate units in terms of size, materials, locations, etc. No special or other entitlement applications were required for the creation of these units other than those typically required for development of residential units at TLSP. In addition to the homeless accommodation on-site at TLSP, the City also facilitated the purchase of a 16 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-55 SEPTEMBER 2022 unit transitional housing facility off-site for one of the homeless providers. The City subsidized the creation of these units through the use of housing set aside funds and Federal HUD Homeless Assistance funds. Emergency Shelters, Transitional Housing and Supportive Housing Emergency Shelters is defined as housing for homeless purposes intended for occupancy of less than six (6) months,where no person is denied occupancy because of inability to pay. In the City of Tustin, emergency shelters are designated as permitted uses within Planning Area 3 of the TLSP(see Table II-28).Planning Area 3 is a five (5) acre site that had been a no cost conveyance to the Orange County Rescue Mission for the development of an emergency/transitional shelter that is known as Village of Hope. The City facilitated the development of the Orange County Rescue Mission Village of Hope and waived permits fees as this was a public/private partnership.The project originally consisted of 192 units and now has been expanded to 262 beds capacity is available for emergency housing needs. Transitional housing is defined as rental housing for stays of at least six (6) months where the units are re-circulated to another person after a set period. This housing can take several forms, including group housing or multi-family units, and often includes a supportive services component to allow individuals to gain necessary life skills in support of independent living. Tustin's Zoning Code accommodates transitional housing within several zoning districts depending on the project's physical structure: 1) transitional housing operated as a residential care facility is permitted/conditionally permitted depending on the number of occupants in residential districts; and 2) transitional housing operated as rental apartments, it is permitted by right as a multi-family residential use where multifamily housing is permitted. Supportive housing is defined as permanent(no limit on the length of stay),provides supportive services and is occupied by low-income persons with disabilities and certain other disabled persons. Services may include assistance designed to meet the needs of the target population in retaining housing,career counseling,mental health treatment, and life skills. Tustin's Zoning Code permits supportive housing as a residential use,provided supportive services are ancillary to the primary use. Emergency shelters are permitted within Planning Area 3 of the TLSP. Transitional homes and supportive housing are also designated as permitted uses within Planning Areas 1 and 3 of the TLSP. Community care facilities such as group homes, foster homes, elderly care facilities, etc. with six (6) or fewer people are outright permitted within any residentially zoned property. Table II-29 summarizes zoning regulations for homeless accommodation. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-56 SEPTEMBER 2022 TABLE II-29 SUMMARY OF HOMELESS ACCOMMODATION ZONING REGULATIONS Permitted/ Housing Type Conditionally Zoning Permitted Emergency Shelters Permitted Planning Area 3 of Tustin Legacy Specific Plan Planning Area 3 of Tustin Transitional Home Permitted Legacy Specific Plan;All residentially zoned properties Planning Areas 1 and 3 of Supportive housing Permitted Tustin Legacy Specific Plan; All residentially zoned properties Community Care Facility for Permitted All residentially zoned six(6) or fewer properties Family care home, foster All residentially zoned home, or group home for six Permitted (6)or fewer' properties 'Includes congregate care facility,single room occupancy hotel,and children's intermediate care shelter Source:City of Tustin The following are emergency/transitional/supportive homes that are provided at Tustin Legacy Specific Plan area: • A 262-bed emergency shelter at the Village of Hope operated by the Orange County Rescue Mission. • A 90-bed intermediate care shelter for abused children and their parents operated by the Orange County Social Services Agency. • Six (6) units at Tustin Field I operated by Salvation Army. • Sixteen (16) units in Buena Park operated by the Salvation Army. The City assisted in acquisition and contributed grant funds to acquire the units. • Fourteen (14) units at Columbus Grove operated by Families Forward, formerly Irvine Temporary Housing.' • Six (6) units at Columbus Grove operated by Human Options. ' Although these units are located in the City of Irvine,these units were negotiated as part of the base realignment/conveyance process with Tustin as the Local Redevelopment Authority. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-57 SEPTEMBER 2022 • Six (6) units at Columbus Grove operated by Orange Coast Interfaith Shelter. • A 77-bed temporary emergency shelter operated by Temporary Shelter Inc. With the exception of the emergency shelter, these units are transparent and dispersed throughout the community consistent with the City's goals and policies to provide adequate supply of housing to meet the need for a variety of housing types and the diverse socio-economic and to promote the dispersion and integration of housing for all socio-economic throughout the community. The City's policies for homeless accommodation do not create constraints in the location of adequate emergency shelters, transitional homes, shelters, and supportive housing. In addition, current provision of homeless accommodation supports not only the need of the City but the county as well. Shelters Capacity and Vacancy Rate The Village of Hope, a 262-bed transitional housing facility operated by the Orange County Rescue Mission (OCRM) is expanding to include 125 additional beds. When completed,the facility will provide 387 beds.The facility and entitled new expansion are located at 1 Hope Drive in Tustin Legacy Neighborhood A. The Village of Hope is the City's largest shelter operation. Table II-30 provides the vacancy rate reported by the Orange County Rescue Mission Village of Hope. Generally, the shelter has an average vacancy rate of 50% for homeless individuals consisting of single men, single women, single women with children, single men with children, and two parent families. The largest homeless sub-population on the Village of Hope campus is single women with children. The Orange County Rescue Mission Village of Hope priority is to serve Tustin homeless population prior to taking any other referrals from other cities or the County. The Orange County Rescue Mission Village of Hope also provides a food service program of approximately 550 meals daily to the Armory. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-58 SEPTEMBER 2022 TABLE II-30 MONTHLY VACANCY RATE VILLAGE OF HOPE(2021) Average Total Month Monthly Available Remaining Vacancy Rate Bed Beds' Beds Occupancy January 129 258 129 50% February 128 258 130 50% March 128 258 130 50% April 139 258 119 46% May 146 258 112 43% June 146 258 112 43% July 138 258 120 47% August 127 258 131 51% September 119 258 139 54% October 121 258 137 53% November 141 258 117 45% December 133 258 125 48% Based on 84 beds for single men,66 beds for single women,56 beds for families,52 beds for women with children. Source:Orange County Rescue Mission On October 26, 2018, the City of Tustin entered into a Settlement Agreement in litigation entitled "Orange County Catholic Worker et al. vs. County of Orange, et al".As part of the Settlement Agreement,Tustin agrees to provide a minimum of 50- bed,emergency homeless shelter facility that is ADA accessible and serves homeless men, women, and families from within Tustin only. The facility's primary focus is assisting program participants with creating a housing plan, making connections to housing resources and finding transitional and permanent housing as soon as possible. The Tustin Temporary Emergency Shelter(TTES)provides a total capacity of 77 beds. Generally,the shelter has an average vacancy rate of 47%.The shelter provides shelter for women,men,couples,and families.The shelter is located on a 1.5-acre site at TLSP and consists of individualized sleeping areas,integrated healthcare, 24/7 intake and orientation, and 24-hour access to Orange County Behavioral Health staff. The expectation of the TTES operations is to provide a transitional emergency facility with the goal of transitioning persons experiencing homelessness into permanent housing as quickly as possible, with the understanding that each guest is unique and may require additional services in the transition into appropriate permanent housing. Table II-31 provides monthly vacancy rate for TTES. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-59 SEPTEMBER 2022 TABLE II-31 MONTHLY VACANCY RATE TUSTIN TEMPORARY EMERGENCY SHELTER (2021) Average Total Month Monthly Available Remaining Vacancy Rate Bed Beds' Beds Occupancy January 32 77 45 58 February 35 77 42 55% March 37 77 40 52% April 38 77 39 51% May 39 77 38 49% June 41 77 36 47% July 40 77 37 48% August 42 77 35 45% September 50 77 27 35% October 45 77 32 42% November 46 77 31 40% December 46 77 31 40% Source:City of Tustin,Economic Development Department Orange County's 2019 Sheltered Point-In-Time Count taken on the night of Tuesday, January 22, 2019 identified 95 unsheltered homeless persons and 264 sheltered homeless persons were counted, for a total of 359 homeless persons identified in Tustin. Based on average monthly vacancy rates above, the City has capacity to accommodate unsheltered homeless persons year-round. In addition to existing vacancy,Village of Hope will provide additional capacity with the future expansion of 125 additional beds. In addition to the homeless accommodation, the City also encourages the provision of services to support the community of continuum of care model to end the cycle of homelessness and to provide participants with tools to once again become contributing members of the community as follows: • Private sector opportunities are provided to create a balanced mix of housing types on the base. In the past, through inclusionary Zoning standards in the TLSP, a total of 8,792 affordable units or 20.8 percent of total authorized units at TLSP are required to allow participants with opportunity to achieve self-sufficiency. Specific affordable housing requirements would be established at the time of development project approval to ensure conformity with the Housing Element of the City's General Plan and any provisions of California Community Redevelopment Law. Recently, with the provision of Surplus Land Act, new residential development projects are required to set aside twenty-five (25) percent of the total units for affordable housing. • Adult education and training opportunities will be provided by the South Orange County Community College District within the CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-60 SEPTEMBER 2022 educational village at the Advanced Technology Education Park(ATEP) campus. The first building is complete and is operated by Irvine Valley College focused on engineering and robotics. The second building is in design and will be operated by Saddleback College focused on culinary arts and automotive design. • Rancho Santiago Community College District Sheriffs Training Academy includes a 52,000-square-foot facility on 15 acres provides Peace Officer Standards on Training(POST) certified instruction through its Law Enforcement Basic Academy,as well as advanced officer training. The new state-of-the-art facility also serves all Orange County law enforcement agencies and functions as a regional training center bringing together local and federal agencies to train and collaborate in law enforcement and homeland security matters. The new Orange County Sheriff's Regional Training Academy can accommodate 800 students annually. Table II-32,Emergency Shelter/Transitional Housing Facilities/Homeless Resources, provides a summary of support services provided by a variety of non-profit organizations within the city. TABLE II-32 EMERGENCY SHELTER/TRANSITIONAL HOUSING FACILITIES/HOMELESS RESOURCES Facility Services Provided Operates a food service program,dental Village of Hope services,and 262 bed emergency shelter at the Village of Hope,operated by the Orange County Rescue Mission. Provides shelter,food,clothing,job training, Sheepfold and job-referral services to women with children. Temporary housing for teenagers in crisis. Laurel House The facility also provides food,informal counseling,and access to medical care and clothing. 90 beds intermediate care shelter for abused Tustin Family Campus children and their parents operated by the Orange County Social Services Agency. St.Cecilia's Distributes food supply to needy populations. Red Hill Lutheran Operates emergency food program where a person can receive food supply. Collects food supplies and distributes the Tustin Presbyterian food to various organizations involved in providing homeless services. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-61 SEPTEMBER 2022 TABLE II-32 EMERGENCY SHELTER/TRANSITIONAL HOUSING FACILITIES/HOMELESS RESOURCES Facility Services Provided Aldersgate Refers interested persons to Ecumenical Services Alliance in Santa Ana. Salvation Army Six(6) transitional units at Tustin Field I operated by Salvation Army. Acquisition of 16 transitional units in Buena Park operated by Salvation Army. The City Salvation Army assisted in acquisition and contributed grant funds to acquire the units. Fourteen(14) transitional units at Columbus Grove operated by Families Forward, Families Forward formerly Irvine Temporary Housing in Irvine. Provides rapid-rehousing services including Families Forward-Rapid Re-Housing individualized support and accountability to Program homeless parents working to locate housing, improve financial stability,and create a sustainable future for their children. Human Options Six(6) transitional units at Columbus Grove operated by Human Options Orange Coast Interfaith Shelter Six(6) transitional units at Columbus Grove operated by Orange Coast Interfaith Shelter. Tustin Family and Youth Center Distributes food supplies to needy populations. Provides emergency funding grants to Goodwill of Orange County address immediate and critical needs of veterans and their families,focusing on veterans on the verge of homelessness. Mercy House Offers low-thresholds emergency shelter services with case management services. Operated by the Rescue Mission,the Veterans outpost Veterans Outpost offers transitional housing for up to 71 people,along with veteran- specific services. Operated by Temporary Shelter Inc.,TTES Tustin Temporary Emergency Shelter provides 77 beds low-barrier emergency shelter,integrated healthcare,and 24-hour access of OC Behavioral Health staff Source:City of Tustin CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-62 SEPTEMBER 2022 Group Homes Large family day care homes with seven or more individuals are permitted uses in all residential districts. The operation of large family care home is subject to the submittal of an application and review by City staff. The applicant is also required to submit a list of property owners within a 100-foot radius of the exterior property boundary of the proposed day care home, which is used by the City for public notification. Public hearings are not held unless it is requested by the applicant or a property owner within a 100-foot radius. If no hearing is requested, the permit shall be granted if the large family day care home complies with the provisions of the Tustin City Code. A permit is not granted for a new large family day care home that would be established within 300-feet of the exterior boundaries of any existing licensed large family day care home. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-63 SEPTEMBER 2022 Fees Like cities throughout California,the City collects development fees to recover some of the capital costs of providing community services and the administrative cost associated with processing applications. New housing typically requires payment of the following fees: school fees,park fees,sewer and water connection,power,phone, cable tv and building permits, not all collected by the City. Various fees and assessments are charged by the City and other outside agencies(e.g.,school districts, sewer district,transportation corridor,water district,etc.)to cover costs of processing permits and providing services and facilities, such as utilities, schools and infrastructure. These fees are necessary to pay for services rendered during the processing of the project, but can, however; add to housing costs. In addition, subdivisions and multi-family projects may incur the cost of preparing environmental documentation, traffic studies, soils reports, and filing fees for tentative and final maps. These are requirements of California law. Such fees are typically based on the rates of city employees (including overhead) and the number of hours spent processing the application or performing the associated work. The City's development fees, impact fee zones, and planning fees are provided in Table II-33a, II-33b, and Figure II-2. These fees are assessed based on the concept of cost recovery for services provided. Additionally,planning processing fees cover the cost of City resources in reviewing and assisting in processing of proposed ministerial and discretionary planning actions. Development impact fees are required to provide essential services and infrastructure to serve new residents. As shown in Tables II-32a and II 32b include park, school, transportation fees. These fees are pass-through fees required by the respective agencies. Impact fees are governed by State law to demonstrate a nexus between development and potential impacts. Planning and Permitting fees (Figure II-2) are charged on an at-cost basis to cover staff services and administrative expenses for processing development applications. Based on a recent fee survey completed in 2021, the City's fees are comparable or lower than fees charged by surrounding jurisdictions located in Orange County. Applicable project fee costs are respective to overall development costs and anticipated costs of units.Generally,fees are less for developments that include fewer units and slightly greater for developments with many units, but fee cost per unit generally decreases as the number of units increase. An example of project development fees is provided below for the 137-unit Red Hill Avenue mixed-use condominium project which included six (6) very-low income affordable residential units and 7,000 square feet of retail commercial space, which was entitled and approved in 2021. Total City fees for this project are just over CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-64 SEPTEMBER 2022 $408,000 equating to$2,981 per unit and representing a faction of a percentage of the total project development costs. City Fees (137 units mixed use project including six (6) affordable units) Processing fees: $52,000 Plan Check fees: $162,742 Permit fees: $193,741 Total Project Fees: $408,483 Fees per Unit: $ 2,981 As another example,for a 149-unit housing development project(Levity at TLSP),the percentage of fees to total development cost would be small portion of the total project development costs. City Fees (218 housing units; breakdown: 117 detached homes, 129 triplex homes,and 154 stacked flats and townhomes- *approximated fees) Processing Fees* $ 20,500 Plan Check fees: $ 266,898 Permit Fees $ 865,497 Total Project fees: $1,152,986 Fees per Unit: $ 5,288 In summary, Tustin's development fees represent a small proportion of the overall valuation of residential development. The fees are lower than Orange County jurisdictions and have not served as a constraint to development. In addition,AB 641 helps to address the cash flow problems inherent in many affordable housing projects during the construction phase.For affordable housing developments in which at least 49 percent of the units are affordable to low or very low income households,the City will now allow deferral of local developer fees until certificate of occupancy. Excessive fees do contribute to the total cost of development and impact the final purchase or rental price, which could be considered a constraint to development, specifically affordable housing. However, the City has committed to 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 (Program 1.18). Additionally, the City's Voluntary Workforce Housing Program collects in-lieu housing fees from developments subject to the City's affordable housing provisions. Monies in the program are expended exclusively to provide housing affordable to extremely low, very low, low, and moderate-income households. The City commits to partnering with affordable CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-65 SEPTEMBER 2022 housing developers and nonprofit groups to facilitate development of affordable housing in the city(Programs 1.1 and 3.4).Therefore,with programs in place,the City does not identify fees as a constraint to development. Improvements 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.In its review of projects,staff works with the applicant to identify cost-effective site planning which minimize site improvement costs. Both on-site improvements and off-site improvements required for new construction affect the cost of housing. On-site improvements typically include street frontage improvements including streets,curbs,gutters,and sidewalks.Underground utilities which add cost to housing include sewer lines, storm drains, water, power and telephone lines.Off-site improvements typically include drainage facilities,parks(or park-in-lieu fees), traffic improvements and water treatment plants and sewer treatment plants. While affecting the cost of housing, these improvements are necessary to ensure public health and safety. The cost of these required off-site improvements vary depending on the nature of development(i.e.,vacant land,infill development). The City may also impose development fees on future housing developments in order to recover some of the cost of installing off-site improvements including upgrading the circulation system and other urban service systems to serve increased density. The developed portions of Tustin have the majority of necessary infrastructure,such as streets,electrical and water facilities already in place.The City has analyzed the Housing Element sites and determined that site improvements are not an impediment to their development. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-66 SEPTEMBER 2022 TABLE II-33A DEVELOPMENT FEES FEE TYPE LAND USE FEE RATE Residential Single Family Dwellings $350.00 per unit Duplexes $350.00 per unit Multifamily dwellings, $350.00 per unit plus$100.00 per bedroom over New Construction Townhouses,or one(1)in each unit Tax Condominiums Mobile home park pads $100.00 per pad Commercial/Industria Commercial/Industrial $0.10 per sq.ft.of gross floor area,including any 1 area upon orwithin a building designed for parking Hotel or motel rental $100.00 per unit unit without a kitchen The fee is calculated on a per unit basis for each When a public park or public recreational facility project,reflecting the fair market value of land is not provided within a proposed residential required for park purposes.The value shall be subdivision,the subdivision is less than fifty(50) determined by a Master Appraisal Institute parcels, or the project is a conversion of an (MAI)appraiser acceptable to the City and the Park Fees existing apartment complex to a multi-owner expense of the subdivider. occupancy not exempted in the Subdivision DCCSP:The fee shall be based upon the fair Code,a park fee will be required. market value of the amount of land which would otherwise be required for dedication. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-67 SEPTEMBER 2022 RHASP:Calculate the amount of land which A park fee is also required for non-subdivisions would otherwise be required for dedication: within the Downtown CommercialCore Specific Plan(DCCSP)and the Red Hill Avenue Specific (#of Dwellings)x(0.003 Acre/Person)x Plan(RHASP). (2.24 Person/Dwelling Unit) Afterwards multiply the amount of land computed requiredfor dedication by $2,500,000/Acre School Tustin Residential $4.08 per sq.ft.of building area District Unified Commercial/Industrial $0.66 per sq.ft.of building area Fees School Updated District every July Irvine Residential $4.08 per sq.ft.of building area 1st Unified Commercial/Industrial $0.66 per sq.ft.of building area School District CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-68 SEPTEMBER 2022 TABLE II-33B IMPACT FEES FEE TYPE LAND USE IMPACT FEE RATE Transportation Single FamIly $6,056 per unit Corridor Fees Zone A Multi-Family $3,536 per unit Non- $8.42 per sq.ft.of building area Foothill/Eastern Residential Transportation Single FamIly $4,310 per unit CorridorAgency Zone B Multi-Family $2,513 per unit Updated every July 1s' Non- $4.88 per sq.ft.of building area Residential Any residential project 1. Multiplying the voluntary workforce housing incentive Affordable HousineFees providing voluntary workforce program in-lieu fee by one-half(1/2)the number of base (Only applicable to housing incentive units unitsprovided on-site RHASP and DCCSP) pursuant to Subsection(a)(3)of Tustin City Code B9923 must (In-Lieu Fee)x(Base Units Provided On-site) also pay the City a voluntary workforce housing incentive 2 program in-lieu fee calculated 2. Multiplying the voluntary workforce housing incentive by either: program in-lieu fee by one-half(1/2)the residential project's totalsquare feet of residential area Effective January 2022- January 2023 Fee=$13,801 (In-Lieu Fee)x(Residential Project's Total Sq.Ft.of Residential per unit Area) 2 For residential projects where an application was received but not deemed complete on or before April 17, 2018, use calculations from 2 above. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-69 SEPTEMBER 2022 Figure II-1.Impact Fee Zones ® MAJOR THOROUGHFARE AND BRIDGE FEE PROGRAM -*T TO FCALF FOOTHILIJEASTERN TRANSPORTATION CORR0OR AGENCY 7 cc E i !ZGNE e; i4F g!r' ZONE B k am¢ vi v P ti rN j J 3 f TM Pap N fry j wyw ST. ZONE A ZaNE B .# r i i gra ` , } ZONE B # n,sns LEGACY b TU TI -`So �h er 7'udn uwong4ov�^i,1TG-0,WCA9 Jun 12,YPiY-Q:STun CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-70 SEPTEMBER 2022 Figure II-2. Planning Fees NO. CASE TYPE FEE NO. CASETVPE I FEE NO. CASE TYPE FEE Conditional Use Perm its and Am endments Zoning Adm inistrator Review Signage Administrative 1 Major $5,000 Deposit 24 Adjustment/Minor $50ODeposlt 46 Temporary Sign Perm It $110 Fee Am endm ent 2 Minor $2,500 Deposit General Plan Amendments 47 Master Sign Program $500 Deposit 3 ABCucense $1,000 Deposit 25 Major General $10,000 48 Sign Cade Exception $500 Fee Plan Am endm ent Deposit 4 Soil Remediation $1,000 Deposit 26 Minor General $5,000 Deposit Variances and Amendments,Us a Determinations, Plan Am endm ent Development Agreements and Appeals 5 Am endm ent to $1,000 Deposit 27 Land Use Map $5,000 Depost 49 Major Vaiac $5,000 Dept CnndltlonofApprova Adm lnl strative Legal Review and 6 Amendment $500 Deposit 28 Outside Actual Costs 50 Minor Variance $1,000 Deposit Consultants endm 7 Time Extensions $250 Fee Specific Plan Amendments 51 Condition, o nditlo ns, fApproval $1,000 Deposit of A 8 Code Am endm ent $10,000 Deposit 29 Major Specific $5,000 Deposit 52 Time Extensions $250 Fee Plan Am endm no Minor Specific Design Reviews and Amendments 30 Plan Amendment $2,500 Deposit 53 Zone Ch an ge $10,000 Deposrc 9 Major $5,000 Deposit Subdivisions a nd Amendments 54 Use Determination $500 Deposit 10 Minor New $2,500 Deposit 31 Tentative Tract/ $5,000 Deposit 55 Development $5,000 Deposit Parcel Map Agreements 11 Minor Rem odel $1,000 Deposit 32 Final Tract Map $2,500 Deposit 56 Appeals $1,000 Deposit 12 Am endm ant to $500 Deposit 33 Final Parcel Ma $2,500 Deposit Plannin Review of Suildin plan Check Subm ittals Conditions of Approval posi p posi g g 13 Time Extensions $250 Fee 34 Lot Line $2,500 Deposit 57 New Construction 20%Perm It Fee Adjustment posi 14 Concept Plan Review $5,000 Deposit 35 Lot Merger $2,500 Deposit 58 Remo del/Tenant 20%Perm It Fee Improvements $500 Per She et, Reversionm 15 Preliminary Review Max,$2,000 36 Acreage $500 Deposit 59 Landscape Plan Review 20%Perm It Fee Deposit Environmental 37 Certlficate of $1,000 Deposit Other Fees Com pll ance posi Am endm ents to Written Zoning 16 EIR $20,000 Deposit 38 Conditionsof $1,000 Deposit 60 Confirmation/Non- $200 Parcel Approval Conforming Status Letter 17 Supplemental/ $10,000 Deposit 39 Time Extension $250 Fee 61 Annual Parking $70/Parking Addendum EIR Exception Fee Exception Space Negative Declaration/ Master 18 Ml ti gated Negative $2,500 Deposit 40 Association $3,000 Deposit 62 Annexation $10,000 Deposit Declaration Documents,CC&R Review 19 Initial Study $1,000 Deposit TemporaryUses 63 News Rack Perm It $500 Deposit Notice of Completion/ Temporary Use Planning Service-Hourly 20 Determination/ Actual Costs 41 Perm It $250 Fee 64 Act ual Cost Rate Exem ptlon Docum ant Fees 42 Large posi Gathering $1,000 Deposit 65 Fee Not Listed Per Director Perm It Determination 21 Black and White Copy $0.10 Per Page 43 Time Extension $120E- 22 Color Copy $030 Per Page 44 FilmPermit $50OFee City Council Resolution No.21-54 Adopted luiy 20,2021 3 aherPlansandMaps AMnalco 4s Reasonable Effective October 1,2021 Amom modation $50OFee CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-71 SEPTEMBER 2022 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. Depending on the magnitude and complexity of the development proposal, the time that elapses from application submittal to project approval may vary considerably.Factors that can affect the length of development review on a proposed project include the completeness of the development application and the responsiveness of developers to staff comments and requests for information. Approval times are substantially lengthened for projects that are not exempt from the California Environmental Quality Act (CEQA), require rezoning or general plan amendments,or encounter community opposition.The City recommends that applicants for all permits or reviews request a preapplication meeting with the respective department to confirm City requirements as they apply to the proposed project;review the City's review process,possible project alternatives or revisions; and identify information and materials the City will require with the application, and any necessary technical studies and information relating to the environmental review of the project. City Staff reviews all permit applications for completeness, and discretionary applications must then receive a recommendation through a staff report prior to a review by the appropriate authority. Various applications may also require public noticing and a public hearing. The following table summarizes types of housing permitted in each zone and type of review required. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-72 SEPTEMBER 2022 TABLE II-34 HOUSING TYPES AND PERMIT PROCESSING REQUIREMENTS Zone By Right CUP Design Review Notes RA- Single Family,ADUs, Administrative See Program 1.2 which commits to the Residential JADUS Not Required (Director Review) development of Objective Design Standards Agricultural E4- Residential Single-family,ADUs, Not Required Administrative See Program 1.2 which commits to the Estate JADUs (Director Review) development of Objective Design Standards District R1- Residential- Single-family,ADUs, Not Required Administrative See Program 1.2 which commits to the Family JADUs (Director Review) development of Objective Design Standards District Apartment Homes,Bungalow PD- Courts, Discretionary Planned (Planning Condominiums, District was specifically created to authorize Development Not Applicable Community Commission) garden apartment development opportunities District apartment projects,Stock cooperatives *Single-family, *Administrative See Program 1.2 which commits to the R2-Duplex ADUs,JADUs; **Triplexes(single (Director Review) development of Objective Design Standards Residential Duplexes or two **Discretionary District detached single- structure) (Planning Program 1.5,City will amend Zoning Code to family dwellings Commission) allow triplexes by Right R3-Multiple *Single-family, **Triplexes(single Family ADUs,JADUs; structure); Administrative Zoning district includes objective design and development standards Residential Duplexes or two Boarding houses; (Director Review) District detached single- Condominiums CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-73 SEPTEMBER 2022 TABLE II-34 HOUSING TYPES AND PERMIT PROCESSING REQUIREMENTS Zone By Right CUP Design Review Notes family dwellings; Program 1.5,City will amend Zoning Code to Multiple family allow triplexes by Right dwellings,apartment houses. MHP- —Discretionary Mobile Not applicable Mobile home (Planning Zoning district includes objective design and Home Park parks; development standards District Commission) Apartment houses See Program 1.2 which commits to the PD- Bungalow courts development of Objective Design Standards Planned Condominium Administrative Development Not applicable Community (Director Review) Program 1.5,City will amend Zoning Code to District Apartment allow residential uses by Right projects RA- Residential "Single-family, *Administrative See Program 1.2 which commits to the Agricultural ADUs,JADUs; Not Required (Director Review) development of Objective Design Standards District E4- Residential "Single-family, Not Required *Administrative See Program 1.2 which commits to the Estate ADUs,JADUs; (Director Review) development of Objective Design Standards District *Administrative RHASP-Red (Director Review) Specific Plan includes objective design and Hill Avenue Mixed-Use Not Required With concurrent development standards.The RHASP Land Specific Plan Residential Unit Use Plan allows for a total of 500 residential Allocation from 500 units within the Specific Plan area. residential unit bank CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-74 SEPTEMBER 2022 TABLE II-34 HOUSING TYPES AND PERMIT PROCESSING REQUIREMENTS Zone By Right CUP Design Review Notes detached and Tustin attached single- Administrative Zoning district includes objective design and Legacy family,multifamily Not Required (Director Review) development standards. Specific Plan products,and Site#1.Specific Plan will be amended to affordable housing, allow for additional units per Program 1.1. as well as mixed-use DCCSP- *Administrative Specific Plan includes objective design and (Director Review) Downtown Mixed-Use,Live- with concurrent development standards.The DCCSP Land Commercial Work Not Required Residential Unit Use Plan allows for a total of 887 residential Core Specific units(140 units have been constructed) Plan Allocation from 747 within the Specific Plan area. residential unit bank Planned Site#17(Enderle Center).Residential overlay Community Administrative zone will be added to residential by right; District- Not Applicable Not Applicable (Director Review) refer to Program 1.5 Commercial See Program 1.2 which commits to the development of Objective Design Standards Specific Plan Site#18(The Market Place).Residential No.8 Administrative overlay zone will be added to residential by Planned Not Applicable Not Applicable (Director Review) right;refer to Program 1.5. Community See Program 1.2 which commits to the Commercial development of Objective Design Standards Source:City of Tustin CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-75 SEPTEMBER 2022 Housing Types-By Right Projects that do not require a Conditional Use Permit and are permitted by-right can obtain building permits directly.The process to obtain residential building permits is outlined in Figure II-3,Residential Building Permit Process. Figure II-3.Residential Building Permit Process Submit Plans to First review- 10 c Send Applicant City with payment days .0 Corrections or (online or in- °" a Subsequent Issue Permit person) Reviews- 5 days Approximate application processing time can range from three (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. Length of Time between Application Approval and Building Permit Issuance New Housing Element law now also requires an examination of the length of time between receiving approval for a housing development and submittal of an application for building permits. The time between application approval and building permit issuance is influenced by a number of factors, none of which are directly impacted by the City. Factors that may impact the timing of building permit issuance include: completion of construction drawings and detailed site and landscape design; securing construction and permanent financing; real estate transaction schedules, and retention of a building contractor and subcontractors. As a smaller city,Tustin staff have the advantage of working closely with applicants through the review and approval process,thereby helping to expedite the issuance of building and zoning permits. Furthermore, the City's uses in-house and contracts staff for building plan check which allows for the close monitoring of projects which results in the expeditious review of project. The City has a long-time commitment to complete first plan check for development projects within ten(10) business days. In Tustin, approved housing projects are constructed in a reasonable time period, given the complexities that developers navigate that are outside of the City's control. Here are some recent example projects with the timing noted: In general,smaller,less complex projects are generally issued building permits within one year of project approval,whereas more complicated projects may take up to two years. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-76 SEPTEMBER 2022 TABLE II-35 PROJECT BUILDING PERMIT TIMEFRAME,TUSTIN,CA Project Name Approval Building Permits Time Between Obtained Obtained Approval and Permit Issuance in Months Brookfield Development- October 2021 22 Months "The Landing" December 400 units 2019 Red Hill Avenue Applicant has not Five (5)months since Specific Plan September submitted for plan check approval;no permits as Area-"The 2021 Hill" or obtained permits of March 2022 137 units Downtown Commercial Core Specific December April 2018 16 months Plan Area- 2016 "Vintage" 140 units Source:City of Tustin,Community Development Department Conditional Use Permit Process New residential projects not permitted by right require a conditional use permit (CUP) and may be approved if the following determinations are made by the Planning Commission: • whether or not the establishment, maintenance or operation of the use applied for will, under the circumstances of the particular case, be detrimental to the health, safety, morals, comfort and general welfare of the persons residing or working in the neighborhood of such proposed use, or • whether it will be injurious or detrimental to property and improvements in the neighborhood or the general welfare of the City. • If the Planning Commission finds that the aforementioned conditions will not result from the particular use applied for, it shall grant the Conditional Use Permit. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-77 SEPTEMBER 2022 The City will amend the Zoning Code to allow residential uses By Right.The average time to process a CUP is between three(3) and six(6) months.Figure II-4,Conditional Use Permit Process below provides a flowchart demonstrating the typical process to obtain a CUP. CUP processes are not considered a constraint to the development of units identified to meet the RHNA since housing sites in the Tustin Legacy Specific Plan,Downtown Commercial Core Specific Plan and Red Hill Avenue Specific Plan allow residential development by right and would only be subject to Design Review and a concurrent consideration for a residential unit allocation from the residential unit bank (applicable to Redhill Avenue Specific Plan and Downtown Commercial Core Specific Plan), both of which are subject to administrative level Community Development Director Review. Other housing sites will be rezoned within the one year of the Housing Element cycle to allow housing by right which are described in Programs 1.1 and 1.5. Figure II-4. - Conditional Use Permit CUP Process and Timelines Are6mioaryR dew __ Formal Application I (optional) submittal Applicant modifies �_..._..__..___..._._..._.. application/Plans and resubmits plans Application Review for completeness and CECIA requirements(30-day review) Application Application Complete and project is scheduled Incomplete for public hearing within thirty{30)days Pu blit Nottc'is mailed,puhlish=_d and posted at least II ten I� calerdardaysbeforepublichearing J Hold public hearing;Project is presented to the Zo n ng Adm inistrator o r Planning Commission "AppealPerFod Decision to Deny NOT ❑ecision appealed.' Decision to Aoorove NOT Appealed.Applicant may not Appealed.Applicant may proceed with the project proceed with the project. Streamlined reviews for Subdivision Maps and Environmental Reviews All three Specific Plans have adopted and approved EIRs. Developers can rely upon the approved EIR when designing their projects. This allows developers to rely on the certainty of gaining approval of a project which is significant and important for CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-78 SEPTEMBER 2022 new projects. For the other identified housing sites, the city will be undertaking a comprehensive EIR analysis during the rezoning process which will streamline development process of the sites, since the environmental review would have been completed prior to development proposals submitted to the City. Following the rezoning, developers would be able to propose developments that comply with objective design standards and the environmental assumptions included in the Final EIR This process significantly streamline and shorten the amount of time needed to complete development application. The City of Tustin Subdivision Code requires Planning Commission approval for Tentative Map. Subsequent Final Map can be approved administratively by the Community Development Director. Processing time for these projects may take approximately 6-8 months. The City concurrently processes entitlement application for a single project in order to save the applicant time and review costs. 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. In addition, 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. Objective Design Standards - Tustin Legacy, Red Hill and Downtown Commercial Core Specific Plans These Specific Plans contain objective design standards that serve to provide staff, builders, and design professionals, and other users with a concise document which clearly outlines the desired design elements for residential project so that the Design Review expectations are clear and the process runs smoothly, to avoid ambiguity. In addition, per Program 1.2a, the City will create objective design standards for other parts of the city that are outside of these Specific Plan areas. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-79 SEPTEMBER 2022 Priority Processing The City assigns priority to the plan review and permit issuance for low-income housing projects which eliminates the potential increase in financing costs caused by permit processing a delays Design Review Process In accordance with Section 9272 (Design Review) of the Tustin City Code,individual development projects are be subject to a design review process and it is an administrative review that is carried out by the Community Development Director and does not require a public hearing.This entire process is completed within the 30- day review timeframe allotted by the Permit Streamlining Act.As part of the Design Review process, the Community Development Department has the following responsibilities: 1. To provide for the review of building design, site planning and site development in order to protect the increasing value, standards and importance of land and development in the City due to the urbanization of Orange County. 2. To retain and strengthen the unity and order of the visual community. 3. To ensure that new uses and structures enhance their sites and are harmonious with the highest standards of improvements in the surrounding area and total community. 4. To ensure the necessary linkages are provided between the development project and the Planning Area/Neighborhood in which it is located. 5. The integrity of the Specific Plan and purpose and intent of each Neighborhood is maintained. The City of Tustin employs a streamlined, interdepartmental development review process known as the Design Review Committee in order to generate high-quality projects in a timely manner. We accomplish this by first encouraging applicants to discuss preliminary project concepts with City staff to identify potential concerns. The intent is to screen for major obstacles prior to submittal to avoid the applicant committing time and resources to construction documents that will need to be extensively modified.The Design Review process is in place for Tustin to ensure that incremental development complements the City's historic character and to ensure that new development enhances the quality of life for the community. However, the process may pose a constraint to development by requiring compliance with subjective design guidance which potentially adds additional review times which results in additional project costs. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-80 SEPTEMBER 2022 As part of Program 1.2, the City will amend the Tustin City Code 9272 (Design Review) to remove subjective design guidance will and adopt objective design standards to facilitate high-quality, streamlined residential development. These new objective design standards would serve to further increase certainty and reduce inefficiencies related to project's design review and approval. The following chart depicts the City's current administrative review process for design review: Figure II-5. - Streamlined Administrative Review Process r•ai1-1ira'r Yevi e•,v Formal Application (optional) submittal applicant modifies application plans and Application Review for resubmits plans completeness and CEQA requirements(30-day review) Application Incomplete dpplication deemed Complete r Project Project Denied Approved 10-day Appeal Period 1 Derision to Deny7N( De�asion appealed.' Decision to Approve NOT appealed.Applicant t appealed.Applicant may proceed with the p _J proceed with the project. Waived Fees For projects of significant benefit to the low-income community, certain fees such as Park In-lieu fees, can be waived by the City Council. Other fee deferral could also be provided to affordable housing developers upon City Council approval. Residential Unit Allocation (Red Hill Avenue and Downtown Commercial Core Specific Plans) CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-81 SEPTEMBER 2022 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 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 entitlement application for the project is submitted, reviewed and approved by the City following required hearings before the Planning Commission and/or 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 potential 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. Lot Consolidation The success of development on the opportunity sites that contain multiple parcels will be dependent upon consolidation of individual parcels into larger development sites. Within the last housing cycle, the City has had success in encouraging the assembly of property to spur development. Examples of recent projects with lot consolidation include: • Brookfield Development-400 units approved and in construction; • Red Hill Avenue Specific Plan Area-137 units approved;and • Downtown Commercial Core Specific Plan Area-140 units and construction completed. The City will create a Lot Consolidation Overlay(LCO)Program No.1.19(see Section IV). The intent of the LCO is to encourage the consolidation of lots by providing incentives such as: • Reduce development standards • Additional density bonus beyond the State's maximum ratio • Reduced application fees CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-82 SEPTEMBER 2022 • Priorities in the application process Lot consolidation incentives will be clearly defined in the Overlay to be adopted by the City by 2024.In order to further encourage the consolidation of individual parcels within the opportunity sites,the City will contact the property owners of each of these sites and discuss the City's goals for residential development and available regulatory and financial assistance. For property owners receptive to lot consolidation,the City will aid to facilitate the parcel merger process in a streamlined and timely manner. Housing opportunity Sites 17 and 18,those that have a single ownership,and/or may require lot consolidation could be facilitated by a lot line adjustment(LLA),a process which is detailed in the Tustin City Code 9322 and the administrative process further detailed in the City existing Subdivision Manual,which provide a step by step process in preparing and filing a Lot Line Adjustment request with the City. A LLA is an administrative review process,and any land taken form one parcel can be added to an adjacent parcel.No public hearing are required for a LLA request. The Administrative Authority for LLA applications is under the Community Development Director. The application process for a LLA is streamlined and is cost effective. A LLA can be approved if the following criteria are met: • The project site described in the proposal consists of legal parcels and no greater number of parcels will result from the lot line adjustment. • Any land taken form one parcel will be added to an adjacent parcel and no additional parcels will result from the lot line adjustment. • The parcels proposed by the lot line adjustment will comply with all applicable zoning and building regulations and City's General Plan. • The proposal is consistent with the General Plan. The rezoning process of sites suitable to meet RHNA will ensure that the proper zoning is in place to allow for housing units at these sites to meet RHNA. Therefore, this LLA process would be a streamlined process to adjust property lines in order create parcels of the adequate size to meet RHNA. The City already has a process in place to streamline LLA and therefore a program is not necessary at this time since a LLA is not a constraint to development but rather a tool. Cumulative 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-83 SEPTEMBER 2022 In addition,the City has adopted a variety of zoning tools that provide development options that promote the development of residential developments. As described in Table II-22 (Summary of Residential Zoning Regulations) along with the various Specific Plans and Planned Community Districts which allow for a variety of residential housing products. In 2018 the City adopted the Red Hill Avenue Specific Plan(RHASP) and Downtown Commercial Specific Plan (DCCSP), which will facilitate the development of mixed- use housing developments along Red Hill Avenue and in key segments within the City's downtown area. The Specific Plans encompasses two key areas where a significant portion of residential growth is expected to occur during the current Housing Element planning period. The development standards in the various zones have not been found to constrain housing development as projects have been able to maximize the number of units on site, while taking advantage of the maximum allowable heights. For example, in the DCSSP and RHASP,the reduced setback requirements are typical for higher-density housing development opportunities available in the region that provide minimal light and air for development and do not unreasonably constrain housing opportunities. In the DCCSP, residential developments opportunities where added in areas previously reserved for solely non-residential development. In the DCCSP, residential development are allowed in a vertical format with either, three (3) story, four (4) story,or five (5) stories,with no maximum floor area ratio. Another example is the Red Hill Specific Plan which encompassing approximately 36 acres of land area that has been up zoned to allow higher density residential developments in an area that previously did not allow residential development,with no define floor are ratio. In the Tustin Legacy Specific Plan (TLSP), the zone allows for a variety of housing types, and include medium and high densities allowing 60+ du/acre, with flexible development standards. Furthermore,a Voluntary Workforce Housing Incentive Ordinance was also adopted during this same timeframe and is applicable to both DCCSP and RHASP areas to encourage development of affordable housing. The Ordinance utilized affordable housing provisions included in the State Density Bonus Law. This would allow developer to be able to comply with both provisions while benefitting from relaxed development standards and obtain concession and/or incentives under State Density Bonus Law. At the time of this update, the first mixed use project along Red Hill Avenue within the RHASP has been approved for 137 housing units including five(5) percent Very- Low Income affordable units, as allowed by the City Voluntary Housing Ordinance, approved at a density of 40 du/acre. This is the first housing development project to CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-84 SEPTEMBER 2022 comply with this Ordinance and includes the provision of 20 percent density bonus housing units.Furthermore,the project took advantage of a concession and incentive request, pursuant to State Density Bonus law for a reduction in open space,reduced parking ratios, and the waiver for park fees for the affordable units provided. The waiver of park fees is a development incentive option available by the City's Subdivision Ordinance and is subject to approval by the City Council which requires that the incentive be associated with the provision of affordable housing development. More recently,AB 1763 made a number of changes to density bonus requirements for affordable projects. The bill requires a density bonus to be granted for projects that include 100 percent lower income units but allows up to 20 percent of total units in a project that qualifies for a density bonus to be for moderate-income households. Under the revised law, density bonus projects must be allowed four incentives or concessions, and for developments within 1/2 mile of a major transit stop, a height increase of up to three additional stories or 33 feet. A density bonus of 80 percent is authorized for most projects,with no limitations on density placed on projects within 1/2 mile of a major transit stop. The bill also allows developers to request the elimination of minimum parking requirements for rental units affordable to lower- income families that are either supportive housing or special needs housing, as defined. AB 2345 signed by the Governor in September 2020 further incentivizes the production of affordable housing. Housing Program 1.3 commits to amending the zoning ordinance to ensure the affordable housing density bonus regulations conform to current state law. The City has not processed any zone changes since 2018.In 2018,two were processed for the establishment of the RHASP and DCCSP areas. Since adoption of either Specific Plan, the City has not received any requests for projects (within the entire City) below the City's allowable densities. There have not been any zone change applications processed for any housing developments between 2013 and present. Furthermore,the City does not currently allow short-term rental in the City that could directly impact the cost and supply of residential development. The City monitors closely its development standards and their impact on development. Periodically, the City made amendments to its Zoning Ordinance as part of code streamlining to ensure development standards respond to market trends and Program 1.5 has been included to continue to address necessary code changes to respond to and facilitate housing development and the changing housing market. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN II-85 SEPTEMBER 2022 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). The City has identified the following quantified objectives for the 6th planning cycle (2021-2029). TABLE II-36 QUANTIFIED OBJECTIVES Income New Construction Rehabilitation Conservation/ Preservation Very Low- 1,7241 32 Low- 1,046 13 377 Moderate- 1,132 12 9 Above Moderate- 2,880 Total 6,782 25 418 Pursuant to Government Code Section 65583(a)(1),Ci7s share of extremely-low-income units is 862(50 percent of the total Very-Low Income new construction objective). As described previously, the City anticipates preservation of several affordable housing projects that are at-risk of expiring during this planning period. Additionally, under Program 3.10, Housing Rehabilitation to Address Substandard Housing, the City commits to assisting in rehabilitation of five (5) low to moderate income housing units each year beginning in 2024. Appendix B, Housing Sites Inventory Assessment, with associated Attachments provides the focused analysis for the City's new construction to meet their Regional Housing Needs Allocation (RHNA). 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-86 SEPTEMBER 2022 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 2022 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 2022 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN III-3 SEPTEMBER 2022 Policy 4.4: ADAPTIVE REUSE - Encourage the adaptive reuse of historic resources to support affordable housing. 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 2022 HOUSING IMPLEMENTATION PROGRAM The Housing Implementation Program provides for specific actions the City intends to undertake to achieve the goals and policies of the Element.The Housing Implementation Program 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 in conjunction with the 61h 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 IV-1)identifies existing and new housing programs to be implemented during the 2021-2029 planning 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-1 SEPTEMBER 2022 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-2 SEPTEMBER 2022 HOUSING PROGRAMS The following matrix identifies existing and new housing programs to be implemented during the 2021-2029 planning period.Table IV-1 is divided into five goals and describes each program and associated quantified objective and timeframe.It should be noted that a number of programs fall under multiple goals and policies described in Section III.Those programs are only listed once to avoid duplication. TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency Goal 1:Adequate Housing Supply 1.1(New)Residential Development-Available Sites (Existing)Tustin Legacy Specific Plan(TLSP) Housing General Fund Complete Specific Plan By October 2022 or Implementation Authority, amendment within three(3)years if a. Implement the Specific Plan for the Tustin Legacy area.This Economic deadline is extended program will rezone properties identified in Appendix B, Development Site Inventory Assessment Table B-2.The Specific Plan Department, amendment will include the following in conjunction with Community Prioritize the processing of the By-Right Approval of Projects with 20 Percent Development housing related entitlements As requested between Affordable Units on"Reuse"Sites in compliance with Department for TLSP by assigninga 2021-2029,Report Government Code Government Code 65583.2(h)and(i). designated project anager wally in April • 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 Process entitlement for TLSP local government review must not require a CUP,planned area unit development permit,or other discretionary review or approval. • Accommodate a minimum of 16 units per site. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-3 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency • Require a minimum density of 20 units per acre. • 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. (Modified)Utilization of Planned Community Community City General Fund; Support applications for the Districts,Overlay Districts,and Specific Plans Development Housing Authority creation of new mixed-use (Available Sites) Department, developments,particularly b. Utilize Planned Community Districts,Overlay Districts, Housing when the projects include and/or Specific Plans to facilitate mixed-use developments Authority, affordable housing,through to assist in the development of new affordable ownership Economic the following actions: and rental housing. Development Post available sites and Post to City website by Department capacity of Specific Plan January 2022 areas on the City website • Promote City's density bonus program,Article 9, Post to City website by Chapter 1 of the Zoning July 2022 Incentives for the Between 2021-2029, development of affordable Report in April housing and include on City website. • Continue to provide at least 10 regulatory and Post procedures on City technical assistance website by December meetings with affordable 2023 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-4 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency housing developers and non-profit organizations Develop streamlined procedures for affordable ownership and rental housing development applications (New)Downtown Commercial Core Specific Plan Housing General Fund Process entitlements for As requested 2021-2029; (DCCSP)Implementation Authority DCCSP Report in April C. Implement the Specific Plan for the Downtown Commercial Community • 374 housing units by Core area. Development October 2025 Department • 373 housing units by Economic October 2029 Development Department (New)Red Hill Avenue Specific Plan(RHSP) Housing General Fund Process entitlements for RHSP; As requested 2021-2029; Implementation Authority, no amendment needed to meet Report in April d. Continue implementation of the Specific Plan for portions of Community RHNA and prioritize by Red Hill Avenue north and south of the I-5 freeway Development assigning a designated project Department manager. • 258 housing units by October 2025 • 105 housing units by October 2029 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-5 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency (New)By-Right Approval of Projects with 20 Percent Community General Fund Amend Zoning Code By October 2022,or Affordable Units on"Reuse"Sites Development within three(3)years if e. Amend Zoning Code,pursuant to AB 1397(passed in 2017) Department deadline is extended to provide by-right approvals of development projects in which the project applicant voluntarily includes 20 percent of the units as housing affordable to lower income households,on sites being used to meet the 6th cycle RHNA that represent"reuse sites'from previous Housing Element cycles.The"reuse"sites are specifically identified in the Appendix B-Sites Inventory. (New)Residential Mixed-Use Development- Community General Fund Add a residential overlay zone By October 2022,or Available Sites Development and amend General Plan; within three(3)years if f. (New)Process Enderle Center and Tustin Market Place Department Include development deadline is extended Zoning and General Plan Amendments.The rezoned sites standards allowing a minimum will meet the requirements of Government Code 65583.2. of 30 du/acre. (New)By-Right Residential Development to Meet Community General Fund Amend Zoning Code By October 2022,or RHNA Development within three(3)years if g. The City will update its Zoning Code to allow by-right Department deadline is extended residential development pursuant to Government Code 65583.2 provisions.This program applies to areas rezoned for residential development after October 15th,2021 to achieve the City's 6th Cycle RHNA objectives. City will update the Zoning Code to include provision of by- right development in areas rezoned to meet the City's RHNA objectives.The rezoned sites will meet the requirements of Government Code 65583.2,including but not limited to: CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-6 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency • Minimum density of 20 units per acre, • Minimum site size to permit at least 16 units on site,and • Zoned to allow ownership and rental housing by-right in which at least 20 percent of the units are affordable to lower-income households. (New)Extremely Low Income Households Housing General Fund Expand affordable housing By October 2029 Authority, inventory by 50 units over Community eight years(10 extremely low; h. Facilitate affordable housing development including Housing Authority ( housing for extremely low income and very low-income Development Fund 20 very low20 extremely income households,and households with special needs(such as Department CDBG Fund units). persons with disabilities and farmworkers). Other State or federal • Provide technical Grants assistance to 10 By October 2025 developers regarding City mixed use zoning and density bonus incentives; • Create and distribute an Affordable Housing Guide that explains By October 2023 how to use affordable housing incentives • Adopt an ordinance to allow the provision of fee deferral and/or fee By October 2024 waiver when associated with housing developments to meet RHNA CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-7 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency • Provide technical By October 2023 assistance and permit fast-tracking for new ADU/SB9 development proposals and a minimum of six projects that include housing affordable to lower income households on an annual basis through 2029.City staff will fast track a minimum of 10 ADU and/or SB 9 developments in high opportunity areas (Census tracts 756.05, 524.19,756.06,and 756.07)on an annual basis,which means that review times will be reduced by 25 compared to year 2022 review timeframes and for all affordable housing projects by assigning a designated "streamlining staff liaison"to the project. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-8 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency Monitor development proposals within the Tustin Legacy Community General Fund Review project(Design Bi-weekly basis from Specific Plan area to ensure 25 percent of the total amount of Development Review)agendas on a bi- 2021-2029. units proposed are low income,very low income,or a mix of Department weekly basis to monitor for the two to comply with the Surplus Land Act. new housing developments to Economic ensure compliance with SLA Development and affordable housing Department provisions. 1.2(New)Objective Design Standards Objective Development Standards Community General Fund,Grant Remove subjective design Amend TCC 9272 a. Amend Zoning Code to remove subjective design guidance Development Funding if available guidance in TCC 9272(Design (Design Review)to in TCC 9272(Design Review),and adopt objective design Department Review)and adopt Objective remove subjective design standards to ensure that the City can provide clear guidance Design Standards which will guidance and also on design to streamline the development of high quality apply citywide develop and adopt new residential development;ensuring the provision of adequate Citywide Objective private open space,parking,and use of city's private streets Design Standards by standards consistent with State law(SB 35). December 2024 Design Guidance Community Grant Funding, Educate public via City's Post to City'website By b. Provide educational materials and consultations regarding Development General Fund website,and counter December 2024 Objective Design Standards(SB 35) Department consultations,approximately Minimum of 10 weekly 100 consultations total per design consultations year. starting January 2025. (New)Parking Standards Community General Fund Develop parking standards By October 2024 C. Develop parking standards to facilitate residential housing Development that incentivize creative production as part of mixed-use developments,adaptive re- Department parking strategies such parking use projects and new residential developments. credits for transit rich development and allowance of CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-9 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency parking structures and parking lifts,by-right and subject to Objective Design Standards. 1.3(Modified)Density Bonus Program a. Promote use of the State's Density Bonus Law to facilitate Community General Fund Encourage the use of density Advertise on City the construction of affordable housing,including extremely Development bonus incentives by website by October 2022 low-income housing. Department advertising on City's website and by providing information on available sites and Bi-weekly review of regulatory incentives in development projects conjunction with discussions between 2021-2029. with development applicants. b. Update City Density Bonus Ordinance;ensure it is Community General Fund Update ordinance By December 2022 consistent with State law. Development Department 1.4(New)Voluntary Workforce Housing&Specific Plan Reassessments a. Engage a real estate and economic development consultant Community General Fund Conduct analysis and By December 2022 to evaluate the City's current Voluntary Workforce Housing Development evaluation of the Voluntary Ordinance in conjunction with the reassessment on the Department; Workforce Housing Ordinance effectiveness of the Downtown Commercial Core Specific Housing and DCCSP and RHASP Plan(DCCSP)and Red Hill Avenue Specific Plan(RHASP), Authority (Specific Plans)and develop adopted in 2018,to identify development constraints and recommendations for policy adjustments necessary to incentivize housing development CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-10 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency and subsequently amend the TCC to remove development changes that remove constraints. development constraints. Amend the TCC Code "Voluntary Workforce By December 2024 Housing"to implement recommendations to remove any identified housing development constraints Conduct an analysis of the By December 2022 Residential Allocation Reservation(RAR)process applicable in the following Specific Plan areas:DCCSP and RHASP and identify any potential barriers to housing developments. Amend DCCSP and RHASP Specific Plans review By December 2025 procedures and/or applicable Specific Plan sections to eliminate governmental constraints that may pose a barrier to housing development,with an emphasis on eliminating redundant processes, CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-11 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency ambiguities and discretionary action(s). Amend DCCSP and RHASP to provide for additional housing By December 2025 units aligned with economic objectives and infrastructure capacities by re-evaluating the housing units allocated to each geographic area in each Specific Plan. Conduct environmental analysis,as needed,to By December 2025 accommodate additional housing units in each Specific Plan area,aligned with economic objectives and infrastructure capacities. 1.5(New)Zoning Code Streamlining Program a. Implement zoning code amendments to facilitate Community General Fund Annually review Annually application and project review streamlining and compliance Development zoning code and with State law to meet housing needs. identify potential improvements to streamline development and permit Amend zoning code as appropriate CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-12 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency and adopt within 12- month timeframe • Amend Zoning Code to remove the CUP requirement for By October 2023 triplexes in the R2 and R3 zones. • Amend the Zoning By October 2023 Code to remove the Conditional Use Permit(CUP),when currently required,for residential uses City- wide in all zones. b. Amend existing commercial and industrial Specific Plans Community General Fund Conduct analysis and By December 2025 for potential inclusion of additional residential units within Development evaluation the respective areas. Amend Specific Plans and By December 2029 Zoning map as appropriate 1.6(Modified)Mobile Home Programs a. Continue to maintain the City's mobile home park zone and Community General Fund Annual review and report Annually process conditional use permit applications as received for Development manufactured homes. Department b. Amend the zoning code to outline mobile home park closure Community General Fund Conduct analysis and By December 2023 procedures and provide reasonable protection for residents Development evaluation in accordance with State Mobile home Park law. Department Amend zoning code CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-13 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency c. Seek funding and determine financial feasibility for a Mobile Community HCD Grant Funding Annually check the HCD Annually in March of Home Assistance Program that provides financial and Development website for potential funding each year. technical assistance to mobile home parks and their Department; sources and apply for eligible conversion to resident ownership to maintain affordable Housing programs. housing within existing mobile home park(s). Authority 1.7(Modified)Accessory Dwelling Units Program a. Promote the construction of accessory dwelling units in new Community General Fund,SB2 Update ADU Ordinance in By January 2022 and existing residential areas by updating City codes in Development Grant Funding accordance with State Law compliance with State law and focusing on education and awareness. Update website with ADU By June 2022 permit guidance Process approximately 5 Process applications ADU/JADU applications per within the timeframe year. prescribed by State Law, as may be amended b. Create an ADU/SB 9 accelerator program and focus in High Community General Fund,SB2 Develop and adopt an By December 2024 Opportunity Areas within the northeast portion of the City Development; Grant Funding ADU/SB9 accelerator where there are predominately single family residences in Housing program. order to expand housing choices.This program could include Authority Mail out information a permit fee waiver for affordable housing units,permit fast tracking(refer to Program 1.1h),and technical assistance.This pertaining to the new By January 2025 program will also create a one-stop-shop comprehensive accelerator program for ADUs resource for homeowners interested in developing an ADU and SB 9 developments, specifically to high opportunity and/or SB9 developments. This program will complement revised Program 11(h) Streamlining and Permit Fast areas. Tracking for new ADU/SB9 development proposals. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-14 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency C. Establish an Accessory Dwelling Unit Legalization and Community General Fund Establish SB13 Program By December 2023 Delay of Enforcement program to allow owners with Development existing unpermitted ADUs to legalize the structure per Department Senate Bill 13,Gov.Code,§65852.2,subd.(n);and Health& Safety Code,§17980.12). d. ADU Monitoring Program and Database Community General Fund Annual Report Annually in April Development Department 1.8(New)Partnerships with Non-Profit Organizations a. To further facilitate affordable housing,including extremely Community General Fund Hold meeting,open house, Annually in September low-income housing, the City will proactively build Development and/or or video series targeted relationships with the building and housing community Department; to building and housing including nonprofits,and establish an array of regulatory and Housing community including financial tools to assist residential development. Authority; nonprofits,to present Economic residential development Development opportunities in the City and Department financial tools available. Make information on financial resources and regulatory tools By December 2022 available on the City's website. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-15 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency a. (New)Continue to coordinate and support community- Community General Fund Meeting,open house,and/or Inform providers based organizations that support after school programs,self- Development video series targeted to annually in February help training,food-assistance and counseling and access to Department; nonprofits that provide family beginning in 2023. other resources,especially in low resource areas of the City Housing resources,to present potential and communities with higher proportion of special needs Authority; partnership opportunities. populations. 1.9(Modified)Deed Restrictions a. Continue to require appropriate deed restrictions where Community Tax-Exempt Mortgage Include conditions of approval Bi-weekly review of newly approved or extended affordable housing units will Development Revenue Bonds and at entitlement and require development projects be required to record a 55-year deed restriction for rental Department; other various recordation of deed restriction between 2021-2029. units and 45 years for ownership units to ensure continued Housing resources prior to issuance of Certificate affordability for extremely low-,low-,or moderate-income Authority; of Occupancy for affordable housing constructed or rehabilitated with the assistance of units for applicable housing any public funds,as may be legally required. Economic Development development projects. Department 1.10(Modified)Development and Permit Streamlining a. Utilize pre-application conferences and expedited permit Community General Fund Approximately 50 Minimum of four(4) processing procedures to streamline development review Development consultations per year monthly consultations and permit processing. Department starting January 2024. b. Track the processing time frames for processing of reviews Community General Fund Develop development permit By December 2022 and permits for low-and moderate-income housing and Development tracker Department CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-16 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency where possible,adjust internal procedures to shorten review timeframes. C. Continue the services of the City's Community Development Department as a central clearinghouse with individuals Community General Fund Review number of days to Bi-annual reviews in June assigned the responsibility of expediting development Development process an application,at least and January,starting in permits required from various departments and agencies.Use Department biannually and implement January 2023 technology and revise internal processes to reduce processing revised procedures to shorten time,which in turn reduces development costs. review times,when possible. d. Streamline environmental reviews for major mixed use and Community General Fund Develop a list of on-call By December 2023 residential related projects by tiering environmental reviews. Development consultants to assist with fast- Department tracking environmental reviews Require Program Annually,project by Environmental Impact Reports project basis. (EIR)on all major development projects whenever possible. 1.11(New)Inventory of Available Sites and Monitoring No Net Loss: a. Maintain a current inventory of residential and mixed-use Community General Fund Annual website updates with By December 2023 sites. Monitor development of vacant and nonvacant sites Development residential and mixed-use sites inventory and ensure that adequate sites are available to meet Department inventory. the remaining RHNA by income category. Provide list(vacant and nonvacant sites)on city Update annually by May, website,especially for starting in January 2023 prospective residential CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-17 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency developers,to facilitate the development of housing in the City 1.12(Modify)Bonding Programs a. Utilize housing revenue bond financing resources and Low- Community State and Municipal Complete analysis of available Annually in June Income Housing Tax Credits on new construction and Development Bonds;Private Activity programs annually. between 2021-2029 acquisition/rehabilitation projects that help meet the City's Department; Mortgage Bonds affordable housing needs. Housing Revenue issued by Authority California Statewide Communities Development Authority and others; California Low-Income Housing Tax Credits; California Debt Limit Allocation Committee (CDLAC) 1.13(New)Adaptive Reuse of Historic Resources to Facilitate Affordable Housing production a. Promote current program that allows the adaptive reuse of Community General Fund Promote program through City By December 2023 historic resources for affordable housing and evaluate the Development website and historic use of alternate parking strategies under Program 1.2(c). Department preservation interest groups. Develop memo to evaluate the By December 2023 use of alternate parking CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-18 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency strategies for adaptive historic reuse. 1.14 Ongoing Review of Housing Element Programs a. From the date of adoption of the Housing element,prepare Community City General Fund; Prepare Annual Report to the Submit Annual Report to an annual report to the Planning Commission assessing Development Staff time Planning Commission and the HCD by April l each previous years'accomplishments toward meeting Housing Department City Council annually. year. Element objectives.Submit the Annual Report to the State HCD. 1.15(New)Monitor Changes in Federal and State Housing,Planning,and Zoning Laws a. City will continue to monitor federal and state legislation Community City General Fund; Prepare annual legislation Report Annually in April that could impact housing and comment on,support Development Staff time update. legislation that promotes the equitable provision of Department affordable housing or oppose legislation that negates that purpose and will respond with appropriate changes to remain compliant with State law. 1.16 Consolidated Plan a. Continue to prepare regular updates of the Consolidated Community Variety of local,State, 2020-2025 Consolidated Plan Update by December Plan that provides a comprehensive assessment of housing Development and Federal funding; adopted in April 2020;next 2026 needs,a housing development plan incorporating Federal, Department City General Fund update 2026 State and local public and private resources,and a one-year Staff time implementation plan in coordination with Affirmatively Furthering Fair Housing Practices. Prepare annual Action Plan Annual Action Plan 1.17 Public Improvement Financing CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-19 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency a. Continue to assess opportunities to utilize public Community Developer funded Continue to use special On-going. As improvement financing techniques for other areas of the Development assessment district funding at development progresses City and determine whether or not they are financially Department; Tustin Legacy and its use in at Tustin Legacy,the City feasible.In creating any new community assessment Economic other developing areas. will evaluate financing districts,an evaluation should be completed of the devel- Development; mechanism to fund oper's activity to advance pay off bonds at the close of Finance infrastructure escrow. Department improvements. 1.18 Fees,Exactions,and Permit Procedures a. The City will waive and modify various fees or exactions Community City General Fund Adoption of a revised policy Annually beginning normally required where such waiver will reduce the Development relative to deferment of January 2023 affordability gap associated with providing housing for the Department impacts fees will be evaluated elderly and for very-low and low-income households. and considered on an annual basis. 1.19 Lot Consolidation Overlay Program a. Create a Lot Consolidation Overlay(LCO)Program(see Community City General Fund Adopt Code Amendment to By October 2024 Section IV).The intent of the LCO is to encourage the Development provide Lot Consolidation consolidation of lots by providing incentives Department development incentives such as: • Reduction in development standards • Additional density bonus beyond the State's maximum ratio • Reduced application fees CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-20 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency • Priorities in the application process Goal 2.Fair Housing and Specials Needs 2.1(Modified)Emergency,Transitional,and Supportive Housing a. The Municipal Code will be amended to include definitions Various Non- Variety of private Update City Municipal Code By October 2023 of transitional and supportive housing,consider Profit funds;CDBG funds transitional and supportive housing to be a residential use, Organizations, and explicitly permit transitional and supportive housing subject only to those zoning regulations that apply to other Housing residential dwellings of the same type in the same zone. Authority, Transitional and supportive housing meeting certain Community criteria will be allowed by-right in zones where residential Development uses are permitted,including mixed-use and nonresidential Department, zones,per AB 2162 and AB 2988. Economic Additionally,the City will amend the Municipal Code to Development include definition and provision of Low Barrier Navigation Department Centers(LBNC)in compliance with AB 101 and AB 139, which require the provision and emergency shelters by- right in areas zoned for mixed uses and nonresidential zones permitting multifamily uses if it meets specified requirements.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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-21 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency b. Facilitate continued operation of Sheepfold homes and Community CDBG funds Continue to provide financial Annually in July Laurel House in Tustin,which provide housing facilities for Development assistance through the battered homeless women and children Department allocation of CDBG funding C. Continue to support countywide efforts to assist approved County of Orange, CDBG funds,HUD Continue to participate on the Attend quarterly homeless providers as part of the Tustin Legacy Reuse Community SHP funds Association of California meetings beginning in effort. Development Cities-OC Housing and February 2022) Department, Homeless Committee Housing Allocate CDBG funds to non- Authority profits to provide 150 individuals services such as Annually,between 2021- counseling,education,job- 2029. training and other techniques to stop the cycle of homelessness. Retain 262 emergency shelter beds and expand emergency shelter bed inventory by 125 By December 2024 beds. Retain 50 transitional housing units. On-going,between 2021- Continue to support 24 2029;Report annually in units of transitional April housing for families (operated by Salvation Army) CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-22 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency • Continue to support 6 units of transitional housing for women and children (operated by Human Options-Dove Housing) • Continue to support 6 units-in long-term 12-24 months transitional housing for families with children(operated by Orange Coast Interfaith Shelter) • Continue to support 14 units of transitional housing to families with children who are homeless due to a short or temporary financial hardship(operated by Families Who Care, formerly Irvine Temporary Housing) d. Provide educational resources for prevention of extremely Housing HUD Section 8 Post information to City Post by January 2023; low-income households from becoming homeless by Authority and Program,CDBG website and provide Update Annually in providing links and program information on City's website Community informational materials to April and at the Tustin Library,Senior Center,and Family and Development Tustin Library,Senior Center, Youth Center. Department and Family Youth Center CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-23 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency 2.2 Economic Integration within Sphere of Influence a. Request that the Orange County Planning Commission and County of Orange, City General Fund; Report number of requests in Annually in April the Environmental Management Agency(EMA)notice the Community Staff time annual report. City of Tustin of any proposed development activities and Development encourage and support the County of Orange in its efforts Department to provide affordable housing opportunities for low,very- low,and extremely low-income families within Tustin's sphere of influence. 2.3(Modified)Senior Services a. Continue implementation of the City's comprehensive Parks and City General Funds Serve more than 75,000 seniors Report annually in April transportation program,case management,information and Recreation annually referral,and shared housing program. Department 2.4(Modified)Housing for Persons with Disabilities a. Continue to work with the Regional Center of Orange Community General Fund Implement an updated Develop outreach County to develop and implement an outreach program Development outreach program with program by June 2022 (i.e.brochures,pamphlets,informational flyers,etc.that can Department State and Federal information posted on the 's rams;City's y be shared and posted on the City's website)that informs pCity's website along with Develop outreach families within the City of affordable housing and services General Fund social media usage. materials by September available for persons with developmental disabilities. 2022 Post outreach materials to City website by October 2022 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-24 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency b. Develop zoning and development standards that will allow Community General Fund Revise City's Zoning Code. By January 2024 and encourage the construction and expansion of affordable Development housing including but not limited to single-room occupancy (SRO)housing and permanent and supportive housing(i.e. motel conversion ordinance). C. Remove Reasonable Accommodations request application Community General Fund Adopt a revised fee Resolution. By June 2023 fee. Development CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-25 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency d. Revise Zoning Code(Remove constraints) Community General Fund Revise Zoning code By December 2023 (1)Revise so that the reasonable accommodation can Development (Reasonable Accommodation proceed without the need for any additional corrections of Section)to remove constraints nonconformities to property. identified in Program 2.4d. (2)State that a Reasonable Accommodation may be acted upon independently of any other applications (3)Remove the annual inspection requirement. (4)Revise so that any reasonable accommodation may be transferred to another person with the same or similar needs. (5)State that a reasonable accommodation shall not conditionally require the return of the property to its original condition. (6)Remove the deed restriction recordation. (7)Remove the requirement that an applicant provide confirmation that the property is a primary residence of the disabled person. e. Amend the code to establish a Universal Design Incentive Amend the zoning code to Amend the code and Program.Universal Design strives to produce dwellings adopt a Universal Design that adopt incentives by that are accessible for all people regardless of race,age,sex, incentivizes developers who January 2024. culture,gender,weight and ability.Universal design avoids implement Universal Design using special assistive technology,and instead employs features in projects to be design features and consumer products that are easy to use eligible for fee reduction or Promote Universal and widely acceptable. other development incentives. P Design Program and The program will incentive the adopted incentives by development of two Universal sending informational Design units on an annual program literature to developers on an annual CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-26 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency basis,starting in 2024 through basis starting March 2029. 2024. 2.5(New)Affirmatively Furthering Fair Housing (New)Fair Housing Education Community General Fund,CDBG Report confirmed incidents of Annually by April, a. Provide educational materials to promote fair housing laws Development Funds discrimination in the sale or starting April 2023. including but not limited to housing referral services. Department; rental of housing;and report Police on the increase/decrease in the Department; number of complaints/cases of Parks and discrimination in the sale or Recreation; rental of housing Department; Community Update website and provide Development; educational material related By January 2023 but not limited to:Directory of Senior Citizen's Services prepared by the Area Agency on Aging Senior Citizen's Office;Social Service Assistance Booklet prepared by Connection Plus;and Orange County Housing Directory prepared by OCHA and the OCHA Advisory Committee. (New)Increase Accessibility of Fair Housing Community General Fund Translate official City By January 2023 Services/Engage Linguistically Isolated Development announcements(i.e. b. The City will provide bilingual communications,including Department community meeting,hearings, but not limited to interpreters and translation services,in etc.)to Spanish and official governmental actions and communications disseminate printed copies of information to renters, CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-27 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency including meeting and hearing notices and presentations. property owners,and via social By engaging linguistically isolated populations in the media,in order to expand decision-making process,they are better able to advocate knowledge of affordable for their needs and concerns regarding affordable housing housing options in High and access to opportunities. Opportunity Areas. Increase attendance, representation,understanding by linguistically isolated residents,at community meeting,public hearings and City Council meetings. The City will conduct at least one community informational meeting in areas that lack affordable housing opportunities and that exhibit high segregation,on an annual basis until 2029. (NEW)DISSEMINATE HOUSING AND ANCILLARY Community General Fund Increase the distribution of Annually,starting in RESOURCE INFORMATION&ENGAGE LIGUISTICALLY Development translated materials to low 2023 through 2029 ISOLOATED Department resources areas located in the C. Translate the City's Tustin Housing Authority website and southwest of the City by factsheets promoting affordable housing opportunities and mailing out postcards to each ancillary support services,such as transit and child care, household in select census into Spanish,and distribute to low resources areas. tracts,containing information related to housing choices, CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-28 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency transit,child care,and education resources. (New)Housing Discrimination Community General Fund Contract with fair housing Annually,starting July d. Contract with a non-profit fair housing provider,(i.e.non- Development provide annually. 2022 profit organization such as Fair Housing Foundation),to Department provide education to property owners and landlord to prohibit housing discrimination,as well as fair housing Conduct an annual training Trainings annually, testing and investigation to look for evidence of differential with the Fair Housing beginning July 2022 treatment and disparate impact. Foundation to provide landlords education on housing discrimination, specifically targeted towards fair housing issues identified in AFFH. Conduct annual fair housing Report on Fair housing testing and investigation. testing conducted annually,beginning June 2023 2.6 Housing Referral Program a. Continue to provide housing referral services to families in Police City General Fund, 7,500 referrals to social Annually between 2021- need of housing assistance and information by.This Department; CDBG Funds agencies 2029;Report in April program consists of three City departments disseminating Parks and information to the public at all times. Recreation; 937 referrals annually Department; 50 referrals for shared • The Police Department refers homeless people to Community housing by 2029 different agencies that provide shelters and food for Development various segments of the population. Department; The Parks and Recreation Services Department CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-29 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency provides housing information and social service information to the senior population. • The Community Development Department provides housing and social service information to all segments of the population as part of its City Hall operations, which is conducted in person,by phone,and online, including referrals provided by CDBG funded non- profits. 2.7(New)Farmworker Housing (New)Farmworker Housing Community General Fund City will update the Zoning By October 2022 a. The City will update their Zoning Code to comply with Development Code to include provision of provisions of the Health and Safety Code Section 1702.15, Department farmworker housing as which allows employee housing for six or fewer employees appropriate under Health and to be treated as a single-family structure and permitted in Safety Code Section 1702.15 the same manner as other dwellings of the same type in the and 1702.16. same zone,and 1702.16,which 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. 2.8(New)Tustin Legacy Specific Plan Improvement Program (New)Tustin Legacy Specific Plan Improvement Program: Community Tustin Legacy(MCAS) City will implement projects as By October 2029 Tustin Legacy(Tract 744.15)is a Master Planned Community Development Fees,Developer Fees, identified in the City's Capital that is currently being developed.Although the tract has Department and General Fund Improvement Program,Tustin been identified as low resource,it has been substantially Legacy Backbone enhanced with new resources within recent years including Infrastructure Program,and services and amenities such as elementary school,high Tustin Legacy Specific Plan. school,Junior College,new grocery store,shopping and CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-30 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency dining,medical offices,Acute Rehabilitation Center,Animal Shelter,Sherriff Academy,Transitional and Emergency shelters,Sports Park,and County Facility for abused and neglected women and children. In addition,substantial infrastructures have and will continue to occur such as water,power,sewer,streets,sidewalks,pedestrian walkways,landscaping,water treatment facility.The area comprises 1,600 acres,of which 600 acres remain for future development of a diverse housing stock,community amenities,and resources.By 2029,the City will continue to implement projects that increase assets in the Specific Plan area as proposed by developers and identified in the Tustin Legacy Backbone Infrastructure Program,which includes: • The Landing at Tustin Legacy:residential projects with development of open space,park areas,and community amenities • Tustin Legacy Linear Park at Armstrong Avenue and Warner Avenue • Alley Grove Public Promenade and recreational courts • Neighborhood D South Infrastructure Construction -Phase 2 • South Hangar Historic resource renovation and preservation Renovation • Armstrong Avenue Pedestrian Bridge • Warner Avenue Pedestrian Bridge CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-31 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency • Tustin Legacy Community Dog Park Police substation at Tustin Legacy Goal 3:Preserve and Improve Housing Opportunities 3.1 Condominium Conversions a. Require developers converting apartments to Community City General Fund Post requirements on Post by October 2022 condominiums to process a conditional use permit,provide Development highlighted City webpage and relocation assistance,and/or to provide incentives and Department provide consultations to assistance for purchase of the units by low-and moderate- developers approximately 5 Report consultations income households. per year. Annually in April 3.2(Modified)Home Ownership Assistance Housing State and Federal Provide educational resources Annually,start by a. Facilitate the process of homeownership,especially first- time homebuyers,by providing a virtual one stop shop Authority; sources on city website and social December 2024 Community media. clearinghouse through a non-profit organization(i.e. Development Affordable Housing Clearinghouse)and explore participation in the Orange County Mortgage Assistance Program(MAP) Conduct review and analysis By October 2023 for MAP participation. b. Search and apply for funding opportunities such as HELP, Housing State and Federal Annually check the websites of Annually,in April HOME funds,and other State and Federal programs. Authority sources HUD,State HCD,and Orange starting in 2023. County Housing Authority for potential funding sources and apply for eligible programs concurrently during application for SB 2 Permanent CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-32 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency Local Housing Allocation (PLHA)funds. 3.3 Housing Authority a. Contract with the Orange County Housing Authority Orange County HUD,CDBG Continue to contract with the Annually,as needed in (OCHA),where necessary,for the development and Housing OCHA April. operation of federally assisted low-and moderate-income Authority;Tustin Quarterly Meetings;Report housing programs. Housing Annually Quarterly Meetings Authority and Community Development b. Participate in educational campaign for property owners Housing Federal,State,and Bi-annual education media Bi-annually and on-going regarding State and Federal laws prohibiting Authority and Local grant funding campaign;post on City website discrimination,in coordination with non-profit fair Community housing services organization Development 3.4(New)Annual City Housing Check-In with Developers a. City will coordinate an annual check-in(i.e.survey or Community General Fund Conduct an annual C annual Annually by June of each meeting)with s developers to promote affordable housing Development, check-in such as a survey or year,starting June 2023 development opportunities within the City. Public Works, meeting to educate private Economic sector of housing opportunity Development and sites to meet RHNA Housing Authority 3.5 Rental Assistance CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-33 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency a. Provide rental assistance,through the County Section 8 County of Orange, HUD Through the Orange County Report annually in April, program,to extremely low and very low income Housing Housing Authority,the City during planning period. households. Authority, will continue to provide Community Section 8 rental assistance to Development extremely low to very low- Department income residents with approximately 425 Tustin residents assisted. Promote availability on city Annually update in websites January Reach out to landlords of low- Biannually in January income apartment complexes and June to provide education and materials about the Section 8 program. 3.6 Affordable Senior Housing Project and Senior Board and Care Facility a. Continue to provide opportunities to provide a range of Community None necessary Provide at a variety of Annual report in April. housing options to address the diverse needs of Tustin's Development affordable housing options for senior population. Department seniors located at: • 16000 Cambridge Publish locations on City Street(Coventry Website and verify Court-153 units) wally in April CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-34 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency • 311 Sycamore Avenue (Heritage Place-54 units) • 275 E.611,Street (Tustin Gardens-99 units) • 17432-17442 Mitchell Avenue(Tustin Terrace-20 units) 3.7(Modified)Preservation of Assisted Housing a. Preserve units at-risk of conversion to market-rate housing Community State and Federal Establish annual monitoring Develop monitoring Development Funds procedures for rent restricted procedures by December Department, units provided through City 2023 and begin Housing incentives and/or financial implementing Authority assistance.Contact property Procedures by January owners within at least one year 2024. of potential affordability expiration to initiate preservation discussions. 3.8(New)Middle Income Housing Opportunities Community General Fund Review and analyze benefits By December 2025 a. Complete a cost-benefit analysis of obtaining membership Development from potential participation in with the CaICHA-through its Essential Middle-Income Department, CaICHA program. Rental Housing ("Program"). Housing Program( g ) Authority Identify rental properties for potential acquisition and By December 2025 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-35 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency conversion to affordable housing. 3.9(New)"Qualified Entities" a. Publish contact information for organizations that Community General Fund Registration into program. By December 2022 specialize in providing affordable housing and may be able Development to preserve at-risk subsidized units. Department Publish on website. Publish on City website by December. Annually,by April between 2021-2029 3.10(Modified)Housing Rehabilitation to Address Substandard Housing a. Partner with a non-profit to develop and launch a CDBG Housing Available federal, Conduct review and analysis By December 2025 funded Housing Rehabilitation Program to facilitate the Authority; state,and local and develop a program repair of dilapidated housing to address lack of plumbing, Community resources framework for kitchen facilities and repairs to provide relief of Development implementation. overcrowding.Program participants will be provided Department grants and/or loans to conduct necessary housing updates. The program will focus on improving housing conditions in Facilitate four(4) tracts 744.06,744.07,744.08,755.12,755.13,755.14,755.15 rehabilitation projects to assist (areas with high segregation index as defined by with reducing overcrowding Dissimilarity Index values which indicate geographical per year and another four(4) segregation patterns in census tracts) projects will assist with general habitability repairs,with a total of eight(8)dwellings assisted annually.starting in July 2024, the City in partnership with a CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-36 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency non-profit,will conduct targeted outreach through annual mailings to the southwest areas of City within low resources areas and populations,about available rehabilitation assistance.All program literature will be provided in English and Spanish.Progress will be evaluated and reported Annually,beginning annually in the City's CDBG January 2026. Annual Report. 3.11(New)Quality Rental Housing Inspection Program a. Establish a multi-family quality rental housing inspection Community CDBG,Home Elevate the quality of housing By July 2025 program. Development in segregated areas in order to Department transform the area into a desirable housing location by all socio-economic groups.The City will conduct at least five multi-family quality rental housing inspections in the program's first year,and will increase the number of annual inspections by 2,each year thereafter until 2029. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-37 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency The program will focus on improving housing conditions in tracts 744.06,744.07,744.08, 755.12,755.13,755.14,755.15 (areas with high segregation index as defined by Dissimilarity Index values which indicate geographical segregation patterns in census tracts). The City will receive at least one monthly referral from the City's Neighborhood Improvement Task Force (NITF)(NITF includes Code Enforcement,Police,Social Service/County,School District representatives,City staff form various Departments)to identify households in need of this tenant protection and anti- displacement focused program;focused on improving the quality of single family and multi-family residential dwellings by providing technical assistance and funds to repairs substandard housing conditions. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-38 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency 3.12 CHILD-CARE RESOURCES a. Create a"Financial Assistance for Child Care'webpage Economic General Fund Single-parent households By December 2022 with information and links to Children's Home Society of Development require special consideration California(CHS)and the Orange County Department of Department/ and assistance because of their Education(OCDE).These programs provide funding to greater needs for daycare, low-income families for child care services.The City will Community healthcare,and other facilities. work with Tustin Preschool,Kiddie Academy of Tustin,or Development According to HCD,female- other local preschool programs within Census tract 755.14 Department headed households with to advertise and promote financial assistance through children tend to have lower pamphlets,e-blasts,and other applicable online community incomes,thus limiting housing forums(such as Facebook and NextDoor). availability for this group.The City will assist in providing free childcare services to relieve general living expenses of female-headed households, specifically in Census tract 755.14.The City will provide services to relieve general living expenses of female- headed households, specifically in Census tract 755.14. 3.13 INCREASE HOUSING SUPPLY FOR LARGE Community General Fund HOUSEHOLDS Development Department CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-39 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency b. Amend the zoning code to require all new multi-family Community General Fund Amend the code. By December 2024 projects to provide at least five(5)percent large family units Development (3+bedrooms)which will prevent overcrowding and Department further cost burden,by addressing demand for such units Facilitate the creation of four Annually,start January (4)large family units will be 2025 through 2029 and increasing the large units into the local housing inventory. generated annually,and 32 total by 2029. Goal 4:SUSTAINABLE HOUSING 4.1(Modified)Code Enforcement Program a. Encourage property maintenance and enforce building Community City General Fund Investigate substandard Report annually in April codes to address and prevent substandard housing Development housing an on-going basis; conditions,removal of graffiti and other deferred Department approximately 25 cases per maintenance issues on public property. year. Report annually in April Remove approximately 4,000 cases of graffiti annually. Conduct approximately 100 Water Quality inspections,in Report annually in April. conjunction with the Water Quality Control Ordinance and the National Pollutant Discharge Elimination System (NPDES)permit process to protect neighborhoods from pollution. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-40 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency b. Encourage proactive maintenance and improvement to Community City General Fund Advertise available home Report annually in April existing housing. Development improvement financing Department programs on an on-going basis. Post and update information on website and at the public Report annually in April service counters. 4.2(Modified)Cultural Resources District a. Preserve neighborhoods and structures that reflect the Community CDBG,City General Process approximately 20 Report annually in April City's heritage .in the City's Cultural Resources Overlay Development Fund,State grants Certificate of Appropriateness District. Department on an annual basis. Update citywide historic By December 2021 resources survey 4.3(Modified)Energy Conservation a. Partner with utility companies to promote energy Community General Fund;grant Promote utility company Report annually in April conservation and rebate programs(i.e.installation of Development funding. rebates during design review photovoltaic systems,tank-less water heater,natural gas Department and public counter recharge connection,electric vehicle recharge connection, consultations;approximately wind power generator,etc.) 100 total per year. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-41 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency 4.4(Modified)Sustainable Building a. Promote energy efficiency by orienting homes to maximize Community General Fund Promote via City's Design Report annually in April natural day lighting. Development Review process and counter Department consultations;approximately 100 total per year. b. Require buildings and structures to not penetrate Federal Community General Fund Educate via City's website, Report annually in April Aviation Regulation(FAR)Part 77 Imaginary Obstruction Development Design Review process and Surfaces for John Wayne Airport unless found consistent by Department counter consultations; the Airport Land Use Commission(ALUC).Additionally, approximately one(1)total per in accordance with FAR Part 77,require applicants year. proposing buildings or structures that penetrate the 100:1 Notification Surface to file a Form 7460-1 Notice of Proposed Construction or Alteration with FAA.A copy of the FAA application shall be submitted to ALUC and,the applicant shall provide the City with FAA and ALUC responses. C. Require development projects that include structures higher Community General Fund Educate via City's website, Report annually in April than 200 feet above existing grade to be submitted to Development Design Review process and Airport Land Use Commission for review.Require projects Department counter consultations,as that exceed a height of 200 feet above existing grade to file applicable;approximately one Form 7460-1 with the Federal Aviation Administration (1)total per year. (FAA). 4.5(Modified)Water Efficiency a. Promote water-efficient landscapes,efficient irrigation,and Community General Fund Educate via City's website, Report annually in April use of permeable paving materials. Development project review process and Department counter consultations; CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-42 SEPTEMBER 2022 TABLE IV-1 HOUSING ELEMENT PROGRAMS 2021-2029 Program Responsible Funding Source Quantified Objective Timeframe Agency approximately 100 total per year. b. Develop educational and trainings materials,to promote Community General Fund Educate via City's website, Report annually in April water efficiency. Development Design Review process and Department counter consultations; approximately 100 total per year. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-43 SEPTEMBER 2022 This page has been intentionally left blank. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN IV-44 SEPTEMBER 2022 APPENDIX A REVIEW OF PAST PERFORMANCE CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-1 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 HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-2 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 HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-3 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 HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-4 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 HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-5 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 HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-6 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 HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-7 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 1 100 'Numbers include total,actual number of units with permits issued and completed. z While 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 HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-8 APPENDIX A - ATTACHMENTS REVIEW OF PAST PERFORMANCE CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-9 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 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-10 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 Goalr 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 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. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-11 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete Goal 1: Adequate Housing Supply 1.1 Available Sites Continue Community City General Assist in the Tustin Legacy Positive On-going to utilize Planned Community Development Fund;City and development of new (previously referred Districts and Specific Plans to Department, Agency staff time affordable owner and to as MCAS): Tustin LeQacy Continue authorize and encourage mixed- Successor Agency, involved rental housing through The City entered into This program will be use developments. (See Zoning City Council development in MCAS AM isCornpleted2015 agreements with included in the 2021- Studies Program). -Tustin and infill areas. several developers at 2029 Housing The City supports 37 Moderate the Tustin Legacy for Element. Housing Element Policies:1.1,1.5, applications for the 496 Upper Income implementing the 1.9 creation of new mixed- Anton LeQaoi: affordable housing use developments Completed 2015 component of the particularly when the Specific Plan and projects involve 88 Very Low secured units for affordable housing 73 Low housing,including low 64 Moderate income households. Other City Areas DCCSP Habitat for Specific Plan approved Huramfity Veteran's in 2018 which added Hous.hiu[140 S.A into this area of the Streetadjaceritto City the opportunity Old Tomi]: for 887 residential Coatpleted 2018 units to be developed. To date,140 upper 1 Low income units have 1 Moderate been built with a workforce housing in- City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-12 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete lieu fee provided. All future development will require participation in workforce housing options contributing to affordable housing mostly through mixed use. RHASP Specific Plan approved in 2018 which added into this area of the City the opportunity for 500 residential units to be developed. All future development will require participation in workforce housing options contributing to affordable housing mostly through mixed use. 1.2 Mobile Homes Community City General The City will continue Between 2013-2021, Positive On-going Development Fund;processing to maintain the existing no applications for Continue to maintain the City's Continue mobile home park zone and fees(recoverable) mobile home park zone. mobile homes or City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-13 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete process conditional use permit Department,City manufactured homes Existing mobile home This program will be applications as received for manu- Council were received parks continue to be included in the 2021- factured homes. maintained. 2029 Housing Housing Element Policies:1.1, 1.4 Element and future applications will be processed as received in a timely manner. 1.3 Second Residential Units Community City processing The City has updated Between 2013-and Positive On-going Development fees(recoverable) its Zoning Code to spring 2021: Continue to provide opportunities On April 4,2017,the Continue Department,City allow second units to be 15 ADUs were City Council adopted for affordable second residential Council developed within Single This program will be dwelling units on Single-family Family zoned constructed Ordinance 1479 related included in the 2021- Residential District lots where to accessory dwelling properties without the 4 ADUs are under 2029 Housing feasible through existing Zoning need for any construction and units(ADUs),formerly Element with Ordinance provisions. known as second discretionary actions. have not yet received exploration of Housing Element units,m ement Policies:1.1,1.8 a final additional During the planning compliance with new period,five(5)second 8 ADUs are in the state regulations. Programs future applications will be units are anticipated. plan check process processed as 2 ADUs were received in a timely withdrawn manner. 1.4 Deed Restrictions Community Tax-Exempt All affordable housing 2016-2019: 2 Positive On-going Require appropriate deed restric- Development Mortgage created during the affordable Continue Department, Revenue planning period will be condominium units tions to ensure continued afforda- Successor Agency, Bonds required to record deed for a 60-year period; This program will be bility for low-or moderate- City Council restriction to ensure Habitat for Humanity included in the 2021- income housing constructed or continued affordability of Orange County City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-14 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete rehabilitated with the assistance for a minimum of 45 2017: 1 residential 2029 Housing of any public funds as may be years. structure authorized Element. legally required. for continued use by the City requiring For affordable units, Housing Element Policies:1.1 projects will that the property owner enter into a continue to include housing agreement conditions of ensuring that the approval at dwelling remain entitlement and affordable to required recordation low/moderate of deed restriction income for a 55-year prior to issuance of period. Certificate of Occupancy. 2021:Tustin Gardens with potential continuation for 20 more years of 100 deed restricted units Anton in Tustin Legacy 225 55-year deed restricted affordable units (262 total includes 37 density bonus units) 1.5 Pre-application Community City General Continue Positive On-going Conferences Development Fund;City Continued to utilize Continue Department processing fees Continue to utilize procedures for (recoverable) pre-application This program will be pre-application conferences and included in the 2021- City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-15 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete processing procedures to expedite processing procedures 2029 Housing permit processing. to expedite processing Element. Housing Element Policies:1.12 1.6 Permit Processing for Community City General Continue Positive On-going Low-and Moderate-Income Development Fund;City All affordable housing Continue Housingprocessing fees projects were (recoverable) This program will be Ensure that processing of permits recipients of such included in the 2021- for low-and moderate-income streamlined housin are fast-tracked with low- processing,including 2029 Housing and moderate-income housing three in the Tustin Element. permits being given priority over Legacy;Amalfi,Anton Continue to process other permit applications. projects and Village of applications in a Hope veterans housing timely manner Housing Element Policies:1.12 and homeless facility. City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-16 1.7 Permit Coordination Community City General Continue Between 2013-2020 Positive On-going. Continue the services of the City's Development Fund;City 1,562 New residential Continue processing fees Community Development (recoverable) projects processed This program will be Department as a central 2013: 758 included in the 2021- clearinghouse with individuals assigned the responsibility of 2014: 46 2029 Housing expediting development permits Element. required from various 2015: 241 departments and agencies. 2016: 141 Housing Element Policies:.1.12 2017: 17 2018: 42 2019: 262 2020: 55 5,307 Residential additions and alterations processed 2013: 458 2014: 66 2015: 571 2016: 817 2017: 866 2018: 825 2019: 1,069 2020: 635 1.8 Housing for People with Community General Fund Implement outreach Positive On-going Developmental Disabilities Development program through City The Housing Section Continue Department website and social Work with the Regional Center of media. of the City's website This program will be Orange County to implement an was updated to outreach program that informs include affordable included in the 2021- families within the City of rental opportunities City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-17 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete affordable housing and services including a map of all 2029 Housing available for persons with affordable rental Element. developmental disabilities. opportunities in the Housing Element Policies:1.11, City. 1.13,1.15 Staff attended task force relative to housing needs of developmentally disabled. Staff met with affordable housing developers to discuss developmentally disabled housing within Tustin Legacy. Continued ongoing efforts. 1.9 Housing for the Disabled Community State and Federal Refer individuals to Positive On-going Development programs;City's agencies providing Require new multifamily Department General Fund. supportive housing that Objectives met and Continue housing units and apartment continues. accommodates This program will be conversions to condominiums to independent living. included in the 2021- comply with State specifications Add procedures and/or 2029 Housing pursuant to SB 520 for undertake appropriate Element. accommodation of the disabled. amendments to existing The City will conduct analysis, standards to ensure add procedures,and/or compliance with SB 520. undertake appropriate City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-18 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete amendments to existing standards and complying with Chapter 11 of the California Building Code (requires portion of multi-unit dwellings to be accessible dwelling units)to ensure accommodation for the disabled. Housing Element Policies:1.11, 1.13,1.15 City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-19 1.10 Transitional Housing Various Non- Variety of • Promote,assist,and 2014: Laurel House Positive Ongoing Encourage the continuation of the Profit private funds; facilitate the transitional housing Organizations, CDBG funds development of was transferred to the Cin-going assistance; Continue Sheepfold homes and Laurel during the planning be House in Tustin,which provide Successor Agency, emergency and Orange County period,$33,000 of This program will housing facilities for battered Community transients'shelters Rescue Mission for CDBG funds were included in the 20211- - homeless women and children. Development through continued continued assistance distributed to 2029 Housing support of the to the homeless, Element. These homes are located in single- Department women,and teens. organizations that family neighborhoods and County Homeless provide services to provide a much-needed service Assistance Program 2015: The City homeless individuals. for homeless women and • Support local conveyed two(2) children. In addition,explore agencies that provide four-plexes to the additional program options to homeless services by Orange County assist in the provision and providing financial Rescue Mission funding for other programs such assistance of (OCRM)in order to as transitional housing and single approximately provide transitional room occupancy housing. $5,000-$10,000 housing to homeless Housing Element Policies:1.11, annually. veterans. 1.14 • Consider the 2016:Tustin Veterans adoption of a Single Outpost was Room Occupancy completed in June Ordinance to 2016,with the facilitate the capacity to house 26 development of SRO homeless veterans units. and their families. 2018,The City Amended the Homeless Assistance Agreement with Families Forward,to allow the conversion of 14 units from transitional to permanent supportive housing for homeless,low income families. City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-20 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete 2020: The City entered into a Disposition and Development Agreement with Family Promise to develop short- term/transitional housing for homeless families with children. In 2018,the City Council authorized the construction of the Tustin Temporary Emergency Shelter ("TTES"),a low- barrier,fifty-seven (57)bed shelter serving the homeless with ties to Tustin. In 2019,the Housing Authority entered into an agreement with Temporary Shelter,Inc,to operate TTES. Construction was completed in 2019. City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-21 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete 1.11 Temporary Housing for County of Orange, CDBG funds, • Continue to At Tustin Legacy: Positive On-going Homeless Community HUD SHP funds participate on the o Construction of a The MCAS Tustin Continue Development Orange County City 192-bed facilityat Specific Plan now The City will also support Department Managers/Planning P ( This program will be countywide efforts to assist the Village of Tustin Legacy Specific b e operated provided sites included in the 2021- approved homeless providers as Force Directors SB 2 Task Ho P P Y Plan) P 2029 Housing part of the MCAS Tustin Reuse Orange County and designated land effort. • Continue to support Rescue Mission uses to accommodate Element. 192 emergency completed and the identified homeless Housing Element Policies:1.11, Cit 1.14 housing units to Y conveyed the needs.Y single men and approximate 5-acre women at Tustin property to the OC Legacy(Orange Rescue Mission at County Rescue no cost. Mission). o Expansion plans of • The City plans to the existing above- assist 200 individuals referenced Village by means of of Hope facility integrating capacity from 192 counseling, beds to 387 beds, education,job- construction of a training and other new parking lot, techniques to stop and establishment the cycle of of an ancillary homelessness. church use. A 0.57-acre parcel • Continue to support was conveyed to 24 units of the Orange County transitional housing Rescue Mission in for families November 2016 to City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-22 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete (operated by construct the Salvation Army) parking lot and construction is •Continue to support complete. 6 units of transitional housing for women o 6 new units at and children Tustin Field I to (operated by Human Salvation Army Options-Dove provided at no Housing) cost. • Continue to support o Acquisition 6 units-in long-term contribution of 16 12-24 months- units in Buena transitional housing Park for the for families with Salvation Army children(operated was completed. by Orange Coast The City assisted Interfaith Shelter) in acquisition and contributed grant •Continue to support funds to acquire 14 units of the units at no transitional housing cost to Salvation to families with Army. children who are homeless due to a o 14 new units,in short or temporary coordination with financial hardship the City of Irvine, (operated by obtained by Tustin Families Who Care, and conveyed to Irvine Temporary Housing at the City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-23 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete formerly Irvine Columbus Grove Temporary Housing) project in Irvine at no cost to Irvine •Continue to support Temporary the Tustin Family Housing; Campus(operated complete. by the County of Orange) 0 6 new units at Columbus Grove to Human Options at no cost; complete. 0 6 new units at Columbus Grove to Orange Coast Interfaith Shelter at no cost;complete. o h12014,the City Council authorized the conveyance of two(2)fourplexes to Orange County Rescue Mission in order to provide transitional housing for homeless City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-24 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete Veterans; complete. o In 2018,the City Council authorized the construction of the Tustin Temporary Emergency Shelter ("TTES"),a low- barrier,fifty-seven (57)bed shelter serving the homeless with ties to Tustin. In 2019, the Housing Authority entered into an agreement with Temporary Shelter,Inc,to operate TTES.In 2019,construction was completed and TTES opened. o In addition,CDBG funds were allocated to non- profit organizations City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-25 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete assisting homeless individuals. 1.12 Number Unutilized 1.13 Bonding Programs Community State and Complete analysis of Neutral NA Utilize housing revenue bond Development Municipal available programs on No tax-exempt bonds On-going financing resources and Low- Department; Bonds;Private as needed basis. were issued between Housing Activity Continue Income Housing Tax Credits on Authority Mortgage Bonds 2013-2020 new construction and Revenue issued This program will be acquisition/rehabilitation projects by California included in the 2021- that help meet the City's Statewide 2029 Housing affordable housing needs. Communities Element. Housing Element Policies:1.7,3.2 Development Authority and others;California Low-Income Housing Tax Credits;variety of other sources 1.14 Economic Integration County of Orange City General Ongoing request to both Positive On-going within Sphere of Influence Fund;Staff time agencies. This is an ongoing Continue Request that the Orange County effort to ensure Planning Commission and the En- coordination between This program will vironmental Management Agency the County and the included in the 20211- - 2029 Housing (EMA)notice the City of Tustin of City within the Element. any proposed development City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-26 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete activities within Tustin's sphere of Tustin's sphere of influence. influence. Housing Element Policies:1.1,1.6 1.15 Senior Housing Successor Agency; HELP;Low- Preservation of 100 at- 100 units-Tustin Positive On-going Community Income Housing risk units at Tustin Gardens Continue to preserve existing sites The City monitors the Modify Development Tax Credits; Gardens,and and identify new sites thatare project and its Department Private Activity identification of new This program will be suitable for senior housing Bonds issued by senior housing sites. affordability on an included in the 2021- projects.These sites will be pro- California ongoing basis. 2029 Housing moted for private development Statewide and Element and likely and applications will be made for others expanded to include any available subsidy funds. CDLAC Tax Exempt Housing Element Policies:1.1, Bonds for Rehab 1.11,1.13 /Preservation and PLHA funds(SB2), and Voluntary Workforce Housing Incentive Funds. The City will continue to monitor projects on an on- going basis. 1.16 Senior Services Program Parks and City General Assist 950 elderly From 2013-2020 Positive On-going Recreation Funds annually 17,198 of our elderly The City far exceeded Continue Develop a comprehensive transportation program,case Department population utilized the objective by the transportation City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-27 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete management,information and system services assisting an average of This program will be referral,and shared housing provided through the 2,150 elderly annually. included in the 2021- program. City. 2029 Housing See also shared Element. Housing Element Policies:1.15, 2013: 1,336 persons housing for the 2.3 assisted objective results which 2014: 1,448 persons too were positive. assisted 2015: 2,271 persons assisted 2016: 1,993 persons assisted 2017: 2,544 persons assisted 2018: 2,678 persons assisted 2019: 2,532 persons assisted 2020: 2,396 persons assisted 1.17 Recycling Single-Family Community City General Eight(8)housing units Undeterminable Positive On-going Uses in R-3 Zones into Development Fund;Staff time are anticipated Continue support of Continue Multiple-Family Units Department applications as received. This program will be Continue to encourage developers included in the 2021- to consolidate individual lots into City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-28 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete larger cohesive developments. 2029 Housing Density bonuses,parking Element. reductions,height and lot coverage exceptions,and reduction of processing fees may be considered as an incentive to consolidate lots. Housing Element Policies:1.2 1.18 Ongoing Review of Community City General Prepare Annual Report The City submitted On-going Housing Element Programs Development Fund;Staff time to the Planning annual reports to HCD Continue Department Commission and the on or before the April From the date of adoption of the City Council annually. V deadlines. This program will be Housing element,prepare an included in the 2021- annual report to the Planning 2029 Housing Commission assessing previous Element. years'accomplishments toward meeting Housing Element objectives.Submit the Annual Report to the State HCD. Housing Element Policies:all policies City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-29 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete 1.19 Consolidated Plan Community Variety of local, Prepare Consolidated Positive On-going Development State,and Plan in 2014 The City of Tustin shall prepare Department Federal funding; The City prepared and Continue an update of the Consolidated the City Council City General This program will be Plan that provides a comprehen- Fund Staff time Prepare Action Plan adopted the 2015-2020 included in the 2021- sive assessment of housing needs, annually Consolidated Plan on 2029 Housing a housing development plan April 21,2015. Element. incorporating Federal,State and The City prepared and local public and private resources, and a one-year implementation the City Council plan. adopted,the 2020-2025 Consolidated Plan on Housing Element Policies:1.12, April 21,2020. 1.16,1.18,2.1,4.1,4.2,4.3,4.4,5.1, 5.2,5.3,5.4,5.5 Action Plans continue to be prepared and adopted annually. 1.20 Zoning Studies Successor Agency City General Initiate Zoning Studies DCCSP area 140 new Positive On-going and Community Fund, by 2015 and complete units constructed to To facilitate the new construction Development any proposed date(all within the In 2018,the Tustin City Continue goals of the 2012 Regional Housing Department amendments by 2021. Vintage Council adopted anew This program will be Needs Assessment,the City Development). Of specific plan document, included in the 2021- intends to undertake zoning note,this development the Downtown 2029 Housing studies to consider new programs participated in the in- Commercial Core Element. to encourage and promote lieu fee option Specific Plan(DCCSP). affordable housing and regarding affordable This plan introduced Opportunities will recommend appropriate housing provisions. mixed-use and infused continue to be amendments for actions by the All units were market the potential for 887 explored relative to Planning Commission and the City rate. units into the area this these and Council.These studies include: through a Residential potentially other Allocation Reservation zoning related City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-30 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete (1) Creation of zoning provisions (RAR)review process. studies. which will accommodate Said plan was an mixed uses in portions of the Orange County City,particularly in the Old American Planning Town Commercial Area; Association award (2) Provide relaxation of certain winner. development standards and In 2018,the Red Hill incentives for projects which Avenue Specific Plan include affordable housing (RHASP)was adopted units particularly housing by the Tustin City units for the extremely-low Council. The RHASP income upon City Council's introduced mixed-use approval; to the area and Housing Element Policies:1.1,1.12 similarly identified the potential for 500 new units in conjunction with the RAR review process. In 2018,the City adopted the Workforce Housing Ordinance which currently affects both the DCCSP& RHASP areas. In 2020,City staff prepared for both the DCCSP and the RHASP areas streamlined City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-31 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete 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. 1.21 Private Streets City of Tustin None necessary Continue Positive On-going The City of Tustin has adopted Private street Continue standards for private streets in standards were new residential developments.To implemented in most This program will reduce construction costs, Tustin Legacy area included in the 20211- - developers may be permitted to residential 2029 Housing Element. install private rather than public developments that streets,wherever feasible. occurred during this Housing Element Policies:1.17 time period. City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-32 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete 1.22 Building Codes City of Tustin, City General On-going During this reporting On-going Community Fund;Staff time period,the City The State of California has Continue Development adopted the 2013,then determined that the over-riding Department 2016,and now the 2019 This program will be value is the protection of the California Building included in the 2021- health and safety of residential Codes. 2029 Housing occupants.Continue to adopt the Element. California Building Code pursuant to the state directives and where local amendments are proposed to reflect local climatic, geologic or topographic conditions,and minimize, wherever possible,impacts on provision of housing. Housing Element Policies:5.4 City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-33 1.23 Site Improvements Community Developer Evaluate the use of Positive On-going. Development funded special assessment The requirement for the developer Assessments were Continue Department, district funding at to construct site improvements issued for a Tustin Legacy and its This program will be often results in passing these costs Community Facilities on the housing consumer.These use in other developing District Annexation included in the 2021- areas. costs are reflected in the cost of Area at Tustin Legacy 2029 Housing housing that eliminates an even in 2014(CFD 14-01)for Element. greater proportion of the the Standard Pacific population from financially development of 375 qualifying for the purchase of single family housing.The financing of public residential units. improvements by a special Assessments were assessment district or community issued fora new facility district on a per parcel benefit basis may enable a greater Community Facilities 018-1 proportion of the market to District qualify for housing.Assessment Improvemmenteat Area 1 district financing has been (CFD 18-01 IA 1)at Tustin Legacy in 2018 implemented in the East Tustin and Tustin Legacy areas and is for the Lennar Homes f Southern Californiabeing used to pay for public ( tc improvements.The City will (formerly Cal assess opportunities to continue to Homes)development c utilize these public improvement of flats, and single-family financing techniques in newly flats,and single-family homes and for developing areas such as Tustin of Legacy and determine whether Brookfield Homes they are financially feasible. In Southern California, a creating any new assessment future development of 400 townhomes,flats, districts,an evaluation should be completed of the developer's and single-family homes. activity to advance pay off bonds at the close of escrow. Additional efforts will Housing Element Policies:1.7 continue to be ongoing. As development progresses at Tustin Lea ,the Cit will City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-34 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete continue to evaluate financing mechanisms to fund infrastructure improvements. City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-35 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete 1.24 Fees,Exactions,and Community City General Defer development Neutral On-going Permit Procedures Development Fund; impact fees during Adoption of a new Continue Department, economic downturns. Consider waiving or modifying policy has been various fees or exactions normally evaluated and This program will required where such waiver will considered on an included in the 20211- - reduce the affordability gap annual basis. No 2029 Housing changes to date Element. associated with providing housing of the elderly and for though continually very-low and low-income being monitored and households. considered. Housing Element Policies:1.12 Of note,the City Council adopted a policy in 2008 to temporarily defer the payment of specific development impact fees to prior to final inspection or issuance of Certificate of Occupancy. City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-36 1.25 Environmental Community General Fund; On-going Effective On-going Constraints Development Private During the Housing Continue Department, developer cost Continue to alleviate the necessity recoverable Element Planning This program will be of delays in processing,and miti- Period,amendments to included in the 2021- gating requirements incorporated the Tustin Legacy into the development plans by re- Specific Plan included 2029 Housing Element. quiring program environmental amendments to the impact reports(EIR)on all major associated Final development projects whenever Program EIS/EIR and possible. Mitigation Monitoring Program. It continues Housing Element Policies:1.12 to serve as the program FIR for the implementation of Tustin Legacy. Additionally,with the preparation of the Downtown Commercial Core Specific Plan and Red Hill Avenue Specific Plan,Program EIRs and associated Mitigation Monitoring Programs were prepared and serve as the environmental implementation provisions for both areas providing alarge cost savings to future developers. 1.26 Density Bonus Program Community General Fund, Process all requests for Effective On-going Promote Density Bonuses to Development density bonuses. Department In 2015,two apartment Continue facilitate the construction of developments that affordable housing. Under State were granted density This program will be included in the 2021- 0ty of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-37 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete law,applicants may file for bonuses by the City in 2029 Housing density bonuses when projects November 2012 were Element incorporate units for very low, completed. The low,moderate-income units or Amalfi development is senior citizens. a 533-unit complex Housing Element Policies:1.8 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 resulted with these two developments 1.27 MCAS-Tustin Successor Agency General Fund Process entitlements for See Program 1.1 Positive On-going Implementation WAS Tustin Achieved Continue Implementation of the Specific Plan for MCAS-Tustin site This program will included in the 2021- 1- Housing Element Policies:1.1,1.3, 2029 Housing 1.5 Element City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-38 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete Goal 2. Equal Housing Opportunity 2.1 Fair Housing Community CDBG funds Assist approximately Effective On-going The City shall continue to provide Development 400 Tustin residents Fair Housing Continue Department, annually,3,000 housing counseling services to City's contractor residents by 2021. Foundation estimated This program will be assure equal housing that the number of opportunities within the City. Tustin residents included in the 2021- The City allocates approximately provided with direct 2029 Housing $15,000 annually for handling client assistance Element tenant/landlord disputes, during this planning housing discrimination cases, period was 1,333. counseling,tenant rights,fair housing education,and education Yearly educational and outreach activities within the City.The City will continue to promote the fair occurred including workshops and open housing educational resources houses to assist Tustin offered by adding the services on residents. the City's webpage,Code Enforcement brochure,and the The City responds to Community Development any general housing Directory. and discrimination Housing Element Policies:2.1,2.2, complaints. 2.4 2.2 Shared-Housing TLC,Parks and CDBG funds Continue Effective On-going Recreation Continue to provide coordination Services The City provided Continue and support to a home sharing coordination and City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-39 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete program funded in part by the Department,and support through the This program will be Community SeniorServ,formerly Community referenced program included in the 2021- known as Feedback Foundation, Development and providers. In 2029 Housing Inc,as part of TLC Department 2020,the Community Element (Transportation Lunch and SeniorSery(formerly Counseling)and the Orange known as Feedback County Housing Authority. Foundation)changed Housing Element Policies:2.3 over to Meals on Wheels Orange County and no longer provides a home sharing program. The City is still partnering with Meals on Wheels Orange County and will provide transportation again for seniors to attend the Senior Center Congregate Meal program when they resume and the facility opens backup. The Covid-19 pandemic had an effect on this program and the ability to service seniors at the facility. See also Senior Services Program. City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-40 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete For senior housing requests,seniors are referred to the Office on Aging Orange County,which provides resources for senior housing and case management. City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-41 2.3 Housing Referral Program Police City General • 7,500 referrals to Effective On-going Department; Fund,CDBG social agencies by Continue to provide housing Funds 2021 The Economic Continue referral services to families in Parks and Development Department and This program will be need of housing assistance and Recreation • 50 referrals for P included in the 20211- - information.This program Department; shared housingb Tustin Housing y 2029 Housing consists of three City departments Community 2021 Authority provides Element disseminating information to the Development; housing and social public at all times. service information to interested parties. • The Police Department refers To assist referrals,the homeless people to different agencies that provide shelters Housing Section of the and food for various City's website is segments of the population. updated on an ongoing basis to • The Parks and Recreation include affordable Services Department rental opportunities provides housing information and senior housing and social service resources. information to the senior citizen population. The City does not keep specific counts of • The Community referrals. See also Development Department other programs that provides housing and social touch on the objective service information to all measurements(i.e., segments of the population shared housing,etc.). during regular city hall business hours.The Community Development Department also serves as a clearinghouse for the Community Development Block Grant Program and represents the City at Housing Authority and OCHA Advisory Committee Meetings. City departments utilize the City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-42 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete following documents and also make these documents available to the public: • Directory of Senior Citizen's Services prepared by the Area Agency on Aging Senior Citizen's Office • Social Service Assistance Booklet prepared by Connection Plus • Orange County Housing Directory prepared by OCHA and the OCHA Advisory Committee. Housing Element Policies: 2.1,2,2,2.3,2.4,2.5 Ongoing Review of Housing See Progam1.18 Element Programs Consolidated Plan See Program 1.19 Goal 3: Ownership Housing City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-43 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete 3.1 Condominium Community City General Impose requirements Effective On-going Conversions Development Fund, where applicable. No units converted Continue Department,City Continue to require developers Council, This program will be converting apartments to condo- included in the 2021- miniums to process a conditional 2029 Housing use-permit,provide relocation Element assistance,and/or to provide incentives and assistance for purchase of the units by low-and moderate-income households. Housing Element Policies:3.1,3.2, 3.3 3.2 State Home-Ownership Housing State and Federal Assist 30 First time With the dissolution of On-going Assistance Authority sources homebuyers by 2021 Redevelopment eliminated low-and Modify-The The Housing Authority applies moderate-income Housing Authority for and will explore the use of housing funds,a major will add the funding other funding opportunities such funding source,has opportunities of as HELP,HOME funds,and other MCC and continue rams. State and Federal ro made more difficult programs. to fund this program to look for other Housing Element Policies:3.1,3.3 at the local level.The opportunities. Housing Authority continually explores the use of other funding opportunities. Bonding Programs See Program1.13 City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-44 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete Ongoing Review of Housing See Program1.18 Element Programs Consolidated Plan See Program1.19 Goal 4: Affordable Housing Preservation 4.1 Housing Authority Orange County HUD,CDBG, Continue Effectively continued On-going Contract with the Orange County Housing Continue Continue Housing Authority,where necessary,for the development This program will and operation of federally assisted included in the 2021b- - low-and moderate-income 2029 Housing Element housing programs. Housing Element Policies:1.3,1.7, 1.14 City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-45 4.2 Rental Assistance County of Orange HUD Issue 200 Effective On-going Housing certificates/vouchers Encourage the availability of Authority annually-1,600 by 2021. The Orange County Continue Section 8 rental assistance Housing Authority certificates and voucher certificate issued the following This program will program assistance funds through annual voucher counts included in the 20211- - 2029 H the Orange County Housing for Tustin residents: 2029 Housing Element Authority by participating in the 2013: 330 vouchers application process i.e.advertise, promote on website,at library, 2014: 342 vouchers senior center etc.when 2015: 525 vouchers application are available;offering City Hall as the application and 2016: 550 vouchers information center for Section 8 (includes 55 Veterans vouchers;,engaging and Affairs Supportive participating with the County's Housing(VASH housing advisory committee to vouchers) ensure priorities are given to Tustin residents,and promote 2017: 566 vouchers Section 8 program to apartments (includes 51 VASH owners to expand Section 8 vouchers) housing inventory within the City 2018: 561 vouchers of Tustin.To encourage the (includes 50 VASH maintenance of existing and vouchers) establishment of new certificates, support the County's efforts to 2019: 579 vouchers obtain continued Federal funding. (includes 48 VASH vouchers) Housing Element Policies:4.1,4.2 2020: 572 vouchers (includes 52 VASH vouchers) 4.3 Affordable Senior Community None necessary Maintain 74 units of Effective-continually On-going Housing Project and Senior Development affordable Senior maintained. Continue Board and Care Facility Department Housing. This program will To maintain 74 units of affordable included in the 2021- 1- housing for Seniors located at 2029 Housing 17432-17442 Mitchell Avenue(20 Element City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-46 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete units)and 54 units affordable senior apartments at 1311 Sycamore Avenue(Heritage Place). Housing Element Policies:5.1,5.2, 5.3,5.4 4.4 Preservation of Assisted Community State and Federal Pursuant to The 100 at-risk units Effective On-going and Housing Development Funds Government Code (Tustin Gardens) modify as additional Tustin has four(4)low-income contact with Tust Department, Section 65583.1(c), were maintained. The City maintains in housing projects will Housing preserve at minimum fall within this housingproject with a total of 517 Also,despite the Gardens and has been P J Authority 100units currently program category units"at-risk"of conversion toelimination of a major monitoring their identified as"at-risk" over the next market rate during the planning at Tustin Gardens for funding source,the annual renewal option. planning period period. If project owners choose the time frames Housing Authority Annual Monitoring: to convert the projects to market Housing required by applicable was also able to The Housing This program will be Authority Government Code Authority annually rate housing,the City will preserve a total of included in the 2021- coordinate the provision of two low-income 2029 Housing working with a Section mails letters to financial and administrative non-profit 65583.Lunits and one very (c)(2)(C)(i)or homeowners Element resources to preserve these units 4%Tax Credit low-income unit in affordable Health and Safety Code requesting as affordable housing. and Bond housing developer section foreclosure by documentation Financing,other purchasing them and a) Monitor Units at Risk: sPreserve 100 units at selling them to other verifying continuing funding sources g compliance with the Maintain contact with owners Tustin Gardens families. P of at-risk units as potential affordability covenants conversion dates approach to they entered into with Community State grants and the Cit when the determine whether Section 8 y y Development HUD funds contracts or affordability purchased their covenants have been renewed Department,Housing affordable unit. or are planned to be renewed. Authority Discuss with the owner of the City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-47 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete "at-risk"projects the City's Affordable Units at desire to preserve the units as Risk of Foreclosure: affordable. The Successor Agency, b) Work with a nonprofit now Housing affordable housing developer Authority,prepared to apply for 4%Tax monthly foreclosure Credit/Bond Financing for the reports to all City acquisition and rehabilitation operating departments of Tustin Gardens,preserving in order to monitor 100 at-risk units. and keep City sensitive to the c) Tenant Education. Work with implications on tenants of at-risk units in property conditions danger of converting. Provide and blight as a result tenants with information of the foreclosure regarding potential tenant activity associated purchase of buildings with periods of including written information economic downturn in and any related workshops. the residential and Act as a liaison between commercial markets, tenants and nonprofits potentially involved in The Housing constructing or acquiring Authority(created y 2011)was created by replacement housing. If existing staff is not able to the City Council to provide adequate staffing for assist the City in this program,provide outside increasing,improving consultants to support the and preserving its supply of affordable program. housing. City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-48 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete d) Reserve Fund. Continue to In 2014,as a result of monitor other potential increased foreclosure funding sources,such as State activity,the City grants and HUD funds. Council approved an Housing Element Policies:4.1,4.2, Affordable Housing 4.3,4.4 Default Revolving Fund in order to cure homeowner defaults under the City and Agency's Affordable Housing Program. The Fund ensures the City has the opportunity to exercise its option rights to purchase the home prior to the home being sold in a Trustee's Sale and the City losing affordable housing supply. The State of California Department of Finance denied the transfer of redevelopment funds to the Default Revolving Fund and the fund was dissolved. The loss of a funding source made City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-49 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete it more difficult to purchase homes prior to foreclosure, resulting in a reduction in the City's affordable housing supply. The dissolution of Redevelopment eliminated a major funding source available to preserve units at risk of their affordability expiring. Staff has continued to explore other funding options. 4.5 Temporary Housing Housing HUD Section 8 Promote,assist,and Effective On-going Assistance for Extremely Low- Authority and Program,CDBG facilitate programs to Income Households Community prevent extremely low- In accordance with Continue AB 987,the Housing De be Assist in the provision of Development income households to Authority maintains This program will temporary and emergency partment become homeless a list on the City's included in the 20211- - providing links andd 2029 Housing housing assistance to prevent website of all program information on Element homelessness for the extremely affordable ownership low-income households as well as City's website and at units and affordable coordination with regional,state the Tustin Library, rental units in the and federal assistance programs Senior Center,and City of Tustin.In for assisting these households in addition,links to City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-50 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete the percentage of their incomes Family and Youth other affordable that are applied to rent(i.e. Center housing sites and increase in allocation of Section 8 documents are also existing rental certificates,etc.). provided on the Housing Element Policies:1.7, website. 1.11,1.15,1.18 4.6 Housing Rehabilitation Housing Available Subject to available The Authority was On-going Allocate available resources to Authority federal,state, funding able to effectuate the Continue finance the rehabilitation of and local rehabilitation of two resources (2)four-plexes by This program will be residential units in target areasresources them to the included in the 2021- Orange County Rescue 2029 Housing Mission for the Element purpose of providing transitional housing to homeless veterans.The Tustin Veterans Outpost was completed in June 2016 and can serve up to twenty-six(26) veterans at one time. Mobile Homes See Program 1.2 Deed Restrictions: See Program 1.4 Transitional Housing See Program 1.10 City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-51 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete Ongoing Review of Housing See Program 1.18 Element Programs Consolidated Plan See Program 1.19 Goal 5: Neighborhood Conservation 5.1 Enforcement of Building Community City General Investigate 30 Effective On-going and Housing Codes Development Fund substandard housing While specific metrics Continue Department cases annually and Continue to enforce building and 240cases by 2021. are not kept by the This program will be housing codes to ensure health City,the City's Code and safety,rectify Code violations Enforcement Staff included in the 2021- and thereby improve the overall estimated that over 2029 Housing 300, character of the community. 2property Element Enforcement will include maintenance and identifying substandard housing housing code related units and those that are otherwise inspections were identified as a threat to the health conducted between and safety of occupants. Actions 2013 and 2020. The will be taken pursuant to the law City has been to demolish,rebuild,or correct successful in getting the code violations. This program property owners to includes notification of taxing abate code violations. agencies upon failure to gain code Most tenant calls that compliance from the property owner to allow City to recover are generally received by Code Enforcement enforcement cost. are very minor City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-52 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete Housing Element Policies:5.3,5.4 concerns and most tenants are referred to the Fair Housing Foundation for assistance Also,the Fair Housing Foundation,under contract with the City, provided workshops and open houses to assist Tustin residents. City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-53 5.2 Cultural Resources Community CDBG,City Rate historic structures Effective On-going District Development General Fund, where applicable and Department State grants process certificates of Process Certificates of Continue There are large number of strut- appropriateness as Appropriateness as This program will be tures in thee City that were received. received. included in the 2021- constructed before and after the Certificates of 2029 Housing turn of the century.Continue to Appropriateness Element utilize the City's Cultural issued for Resources Overlay District to safe- guard the heritage of the City by improvements to preserving neighborhoods and properties located within the Cultural structures that reflect the City's heritage and past.Through the Resources District by year: District,promote the public and private enjoyment,use and 2013: 13 preservation of culturally 2014: 14 significant neighborhoods and structures.Continue to require 2015: 30 that any alteration of a designated 2016: 25 resource or construction improvements in the District 2017: 13 conform to the requirements of the Cultural Resources Overlay 2018: 26 District.Owners of historic 2019: 32 landmarks or properties within the District are required to obtain 2020: 10 a certificate of appropriateness The City is in the before beginning any type of process of an update to exterior construction,alteration, the City's Historical or demolition.A certificate of Resources Survey and appropriateness certifies that the Report which is to be proposed changes are consistent completed in 2021. with the design guidelines and are appropriate within the district context. Housing Element Policies:5.5 City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-54 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete Ongoing Review of Housing See Program 1.18 Element Programs Consolidated Plan See Program 1.19 Building Codes See Program 1.22 Goal 6: Environmental Sensitivity 6.1 Energy Conservation Community None necessary Require all new units Effective On-going Development within planning period. Require all new construction to be Department 1.7, force. See Program Continue subject to State energy conserva- 1.7,Permit tion requirements(Title 24)as a Coordination,for This program will condition for the issuance of a statistics. included in the 20211- - building permit. 2029 Housing Element Housing Element Policies:6.2 6.2 Energy Rebate Program Community General Fund, Seek available grants to Effective On-going Partner with Utility Companies to Development potential Grants partner with utility Since 2013,all Continue promote energy rebate programs. Department companies to promote properties within the No fee or discounted permits for energy rebate City may benefit from This program will be energy efficient projects over and Programs. inclusion in the included in the 2021- above the Title 24 requirements 2029 Housing may be explored. Examples California HERO Element include installation of Program to finance photovoltaic systems,tank-less distributed generation renewable energy City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-55 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete water heater,natural gas recharge sources,energy and connection,electric vehicle water efficiency recharge connection,wind power improvements and generator,etc. electric vehicle charging Housing Element Policies:6.6 infrastructure. Availability of grants explored. City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-56 6.3 Solar Energy and Community None necessary On-going Effective On-going Conservation Development CEQA checklist Continue DepartmentRequire that environmental updated to include be analysis and subdivision plans greenhouse gas This program will included in the 2021-1- address energy conservation emissions. measures and solar access. With 2029 Housing Supported solar panels Element the passage of AB 32,the City in installation in anticipation with the State residential and mandates will set thresholds within its CEQA checklist and commercial buildings. require developers to address During the planning energy conservation measures period,the City issued applicable to their proposed the following number of residential and non- development proposals. residential solar panel Housing Element Policies:6.2,6.3 permits: 2013: 98/3 2014: 91/0 2015: 186/4 2016: 200/1 2017: 164/2 2018: 120/6 2019: 210/4 2020: 169/9 To date,the City Council has approved three(3)PACE vendors.The Property Assessed Clean Energy (PACE)program provides upfront financing to residential, commercial and City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-57 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete industrial property owners for water conservation and energy efficiency improvements. 6.4 Building Orientation Community None necessary On-going Effective On-going Promote energy efficiency by Development DepartmentOn-going Continue/Modify orienting homes to maximize natural day lighting. The City This program will will work with potential included in the 2021t- - developers during the conceptual 2029 Housing Element review level(Design Review)by promoting building siting that maximizes natural day lighting. Housing Element Policies:6.2,6.3 City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-58 6.5 Water Efficiency Community None necessary Promote water efficient In response to On-going Development programs by Assembly Bill 1881,the Promote water-efficient Department conducting workshops City in coordination Continue landscapes,efficient irrigation, and providing with the League of This program will be and use of permeable paving education materials on Cities Orange County included in the 2021- materials. Through educational the City Website,public Division and the 2029 Housing materials and trainings,the City counter and at schools. Orange County Water Element will promote water efficiency methods to its residents. District prepared and Landscape beautification which adopted the Water results in water conservation Efficiency Landscape could be encouraged through Ordinance. The City's website also has been planting of drought tolerant updated with plants,installation of drip information and irrigation,installation of rain detector/sensor irrigation,etc. guidelines to achieve water efficiency. The Incentives such as over the counter permit plan check, City adopted an discounted fee,or waiver of ordinance addressing permit fee could be considered. synthetic turf landscaping,including Housing Element Policies:6.4 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. An annual report summarizing activities between January 1st and December 31st of City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-59 each year since 2016 has been provided to the State Department of Water Resources. The City issued the following annual number of permits for commercial projects, residential and landscape rehabilitation projects, respectively,subject to the Water Efficient Landscape Ordinance: 2016: 0/2/0 2017: 0/6/0 2018: 2/4/2 2019: 2/0/3 2020: 2/0/19 In 2013,the City also participated in the SoCal Water Smart program where rebates were provided for eligible water saving projects. 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 City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-60 TABLE A-2 EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS 2013-2021 Program Parameters Results Program Responsible Funding Quantified Units Effectiveness Timeframe Agency Source Objective Continue/Modify/ Delete Orange County American Planning Association award. 6.6 Green Building Community General Fund Continue to explore Effective On-going Development green building and Streamline processing for Department sustainable building Ongoing Continue approved green building. design to help conserve No Green Building This program will be Housing Element Policies:6.2,6.3, energy consumption. A Program adopted to included in the 2021- 6.5 fee waiver,discounted date. 2029 Housing permits fees,or rebate Element may be considered in promoting Green Building program. Ongoing Review of Housing See Program 1.18 Element Programs Consolidated Plan See Program 1.19 City of Tustin Appendix A Draft Housing Element SEPTEMBER 2022 A-61 TABLE A-3 PROGRESS TOWARDS OBJECTIVES 2013-2021 CITY OF TUSTIN Quantified I Extremely Very Unit Type/Description Objectives Accomplishments 1 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 1,247 818 881 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 g Undeterminable in R-3 district Subtotal 3,000 514 303 348 1,835 RHNA 1,227 283 195 224 525 Difference 1,773 231 108 124 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 HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-62 TABLE A-3 PROGRESS TOWARDS OBJECTIVES 2013-2021 CITY OF TUSTIN Quantified Extremely Very Unit Type/Description Objectives Accomplishments 1 Low Low Low Moderate Upper Ot Note-5,307 8 residential additions Total Rehabilitation Undefined and alterations realized during the planning period PRESERVATION Tustin Gardens 1 100 100 1 100 Total Preservation 100 100 100 OTHER FOCUSED AFFORDABLE HOUSING PROGRAMS Homeless Assistance& Variety of A variety of support Supportive Services Programs- services provided Undefined 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 1 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 HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 A-63 APPENDIX B SITES INVENTORY CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-1 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). This discussion includes the following topics: • Housing Units Approved/Entitled/Pending and Permitted • Suitable Sites Identification and Assessment • Sites to Accommodate Low and Very Low Income RHNA 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 556 housing units that are captured from approved/entitled, pending and permitted(projects under construction).A total of 6,226 additional housing units are therefore needed to achieve the total assigned RHNA of 6,782 housing units. TABLE B-1 SUMMARY OF RHNA CREDITS AND REMAINING NEED CITY OF TUSTIN 2021-2029 Units ADUs Net RHNA Income Group RHNA A roved Permitted Need Very Low 862 6 1 855 Extremely Low' 862 7 2 853 Low 1,046 0 4 1,042 Moderate 1,132 0 4 1,128 Above Moderate 2,880 531 1 2,348 Total 6,782 544 12*/** 6,226 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 There are 544 housing units in three (3) projects with a total of seven (7) extremely- low, six (6) very-low, and 531 above-moderate income housing units that were approved/entitled at the time of the preparation of this Housing Element and are CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-2 SEPTEMBER 2022 being included in the RHNA count. In addition, 12 ADUs have been approved and permitted for construction. Brookfield Development (Part of Site 1B) This is an entitled 400-unit above-moderate-income development planned in the Tustin Legacy Specific Plan (TLSP) area within Neighborhood D South. The project is currently under construction. 13751 &13841 Red Hill Avenue (Site 3) This is a mixed-use project with a total of 137 housing units (six [6] very-low-income and 131 above-moderate-income). The project was approved by City Council on August 17,2021. Construction drawings have not yet been submitted into plan check to obtain building permits. This site currently contains no residential development and the City does not prescribe specific FARs for the RHASP area,but rather, bases development decisions on RAR and individual project review. The existing improvement-to-land value is estimated to be approximately 0.18 based on the latest County property tax information for fiscal year 2021-2022.Values less than 1 suggests the site is currently underutilized. House of Ruth- Transitional Housing Units This entitled project will consist of seven (7) transitional housing units at 1941 El Camino Real, on a 0.38-acre vacant parcel, to serve extremely low income homeless families (2 to 7 persons per unit). It includes two (2) density bonus units. The project also incorporates non-site support services to avoid long-term homelessness. The project is currently in plan check and the project is anticipated to begin construction in 2022. ADUs/JADUs- Other Housing Category There are currently twelve (12) accessory dwelling units (ADUs) that are permitted and under construction within the City. Suitable Sites Identification and Assessment The City analyzed and assessed a number of sites and areas throughout the community to accommodate the City's remaining RHNA. While many sites were considered, eighteen (18 sites and one housing category (ADUs/JADUs) have been identified for Tustin s qualifying sites to accommodate remaining RHNA. Attachment B-1,Sites Identification to meet RHNA,provides a detailed listing of the approved/entitled sites and sites to accommodate remaining RHNA. Attachment B- 1A, provides a summary of the realistic capacity. Figure B-2, Site Identification to CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-3 SEPTEMBER 2022 Meet RHNA, provides a map of the site locations. Additionally, site aerials and individual site APN maps with summaries are provided for reference, organized by each of the three respective specific plans (Sites 1 - 16- TLSP, DCCSP,RHASP), two additional sites (Sites 17 and 18), as well as a two "other' categories (Transitional Housing Units and ADUs/JDUs) in Attachment B-2. Attachment B-3, provides a summary of "Buffer" sites that would provide suitability for additional residential development to meet the City's RHNA in the event that identified sites become no longer feasible for development of affordable or market rate housing. Tustin Legacy Specific Plan (TLSP)Area The Tustin Legacy Specific Plan (SP-1) area contains two geographic areas, referred to as Neighborhoods in the TLSP,where residential housing sites will be concentrated for this planning period: Neighborhood D and Neighborhood G. The land is vacant and is owned and development is controlled by the City. The zoning for the site is Tustin Legacy Specific Plan area (SP-1) and the General Plan designation is TLSP. According to the existing Specific Plan,a total remaining capacity of 3,325 units exists throughout the Tustin Legacy area. Sites 1A and 1B are located in Neighborhood D.Neighborhood D has a total of 84.73 acres and is divided into two areas:South(44.86 acres) and North(39.87 acres). Site 2 is located in Neighborhood G which is in the northeastern portion of the TLSP site and includes approximately 50 acres.Sites within Tustin Legacy do not have a density prescribed to the planning area per the TLSP; however, there is a development cap on the number of housing units in each of the planning areas. The following elaborates on the development capacity for each Neighborhood and planning area. Site 1A- (TLSP) 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 555 additional housing units within this area to meet RHNA. The focused vacant land is 39.87 acres. It is currently situated within four parcels. The rezone is included in the City's Programs in Section IV. Neighborhood D North was not identified in either of the past two planning cycles as vacant land available for housing to meet RHNA. The housing units are expected to be constructed during the planning period. Site 1B- TLSP 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 and is currently in construction.The remainder of this area,19.42 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-4 SEPTEMBER 2022 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 1,296 housing units are currently allocated in Neighborhood D South to meet RHNA.The City is planning a rezone(Specific Plan Amendment-see Programs in Section IV) by October 2022,unless extended by law,to accommodate a minimum of 100 additional housing units within this area,to bring the total number of housing units to 1,396 housing units to meet RHNA. 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 rental housing that was developed over 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 2- (TLSP) 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) by October 2022,unless extended by law,to accommodate a minimum of 200 additional housing units within this area, to bring the total number of housing units to 2,229 housing units to meet RHNA. The rezone is included in the City's Programs in Section IV. There are 13 contiguous parcels designated for residential development with one parcel at 10 acres and the rest at smaller acreages. 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. Red Hill Avenue Specific Plan (RHASP)Area The Red Hill Avenue Specific Plan(RHASP),SP-13,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- unit capacity, consisting of 137 housing units (114 base units and 23 bonus units) approved for construction(Site 3 located at 13751 &13841 Red Hill Avenue) and 386 housing units remaining throughout the Specific Plan area. Remaining units in the RHASP include 258 housing units to the north of the freeway and 105 housing 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-5 SEPTEMBER 2022 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 high density residential zones maximum density) as long as the total dwelling units allocated to the Specific Planning Area is not exceeded.Therefore,densities above 25 units per acre are achievable in the RHASP area. RHASP was accompanied by a Program Environmental Impact Report, approved and certified by the City Council, which affords future developers significant time and costs savings,yielding building of housing units in a more expedient mariner. The Zoning is SP 13, known as the RHASP, and the General Plan designation is RHASP. The maximum allowable building height for residential mixed-use development in the RHASP is four (4) stories (50 feet). Four (4) sites within the RHASP area have been identified to meet RHNA: Site 4- (RHASP) 13822-13852 Red Hill Avenue (Red Hill Plaza) This non-vacant site consists of four parcels on 7.08 acres, all under one ownership. The current land use is a shopping center with commercial, retail and restaurants with a construction dating back to 1973 with over fifty percent of the land area developed with surface parking areas. The center has not undergone any major renovations and remains largely outdated. Recent development inquiries for this parcel have been received due to a recent change in ownership structure. Development interest discussions have involved the property owners and interested developers and the City.This site currently contains no residential development and the City does not prescribe specific FARs for the RHASP area, but rather, bases development decisions on RAR and individual project review. With the recently approved mixed-use project across the street from this site, revitalization of the area can be anticipated in the near future. A total of 226 units have been assigned to Site 4. The existing improvement-to-land value is estimated to be approximately 0.30 based on the latest County property tax information for fiscal year 2021-2022.Values less than 1 suggests the site is currently underutilized Site 5- (RHASP) 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 an outdated restaurant use and the original construction date of building is 1973. The building has not undergone any recent renovations and at least fifty percent of the site is developed with surface parking areas.A total of 32 units have been assigned to Site 5. This site currently contains no residential development and the City does not prescribe specific FARs for the RHASP area, but rather, bases development CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-6 SEPTEMBER 2022 decisions on RAR and individual project review. The existing improvement-to-land value is estimated to be approximately 0.54 based on the latest County property tax information for fiscal year 2021-2022. Values less than 1 suggests the site is currently underutilized. Site 6- (RHASP) 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 one active service station and the other remains vacant and inactive. The various buildings on the site have construction dates ranging between 1966-1973. The various building in Site 6 have not undergone any recent major renovations and remain largely outdated. A total of 105 units have been assigned to Site 6. This site currently contains no residential development and the City does not prescribe specific FARs for the RHASP area,but rather, bases development decisions on RAR and individual project review. The existing improvement-to-land value for the parcels that are developed is estimated to be approximately 1.10 based on the latest County property tax information for fiscal year 2021-2022.Values less than 1 suggests the site is currently underutilized.However,as previously stated, site improvements are outdated and the site is partially vacant, suggesting redevelopment potential. Downtown Commercial Core Specific Plan (DCCSP)Area The Downtown Commercial Core Specific Plan, SP-12, was adopted in 2018 and is centered around the intersection of Main Street and El Camino Real in Old Town Tustin. 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 housing units remain. The DCCSP also provides the unique RAR, which is approved either by the Community Development Director or the Planning Commission/City Council, as applicable. The maximum density on an individual parcel may exceed 25 dwelling units per acre (the General Plans High-Density-Residential zones maximum density)as long as the total dwelling units allocated to the Specific Plan area is not exceeded. Therefore, densities above 25 units per acre are achievable in the DCCSP area.This Specific Plan CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-7 SEPTEMBER 2022 was accompanied Program Environmental Impact Report approved and certified by the City Council,which affords future developers significant time and 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. 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 DCCSP area: Site 7- (DCCSP) 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 (345 W. First St.). Combined, the two parcels are 1.1 acres. The DCCSP's Housing Allocation Bank's 45 units for this Development Area is assumed on this site. This site currently contains no residential development and the City does not prescribe specific FARs for the DCCSP area,but rather, bases development decisions on RAR and individual project review. The existing improvement-to-land value is estimated to be approximately 1.98 based on the latest County property tax information for fiscal year 2021-2022.Values less than 1 suggests the site is currently underutilized. However, site this site is partially undeveloped, with no building improvements and the other portion of the site contains a large parking lot area and considered underutilized,therefore,the site has potential for redevelopment. Sites 8 and 9- (DCCSP) Development Area 2 The two (2) sites in Development Area 2 are non-vacant sites. Site 8 is non-vacant site (Bel Air Motor Hotel located at 140 W. First Street) and is 1.0 acre, on one parcel,under one ownership. Site 9 includes two parcels: A City-owned property located at 150 E. First Street and the adjacent restaurant building at 105 El Camino Real which is privately owned.The City owned property was once operated as Tustin War Memorial which contains a multi-war memorial with four plaques along the north wall of the building. The Tustin War Memorial building is currently vacant and is permanently closed. At one time, this building was shared with the Tustin War Memorial and The Learning Village Preschool, however, the school closed in 2018 as did the War Memorial and the site has since remained unoccupied. The commercial building at 105 El Camino CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-8 SEPTEMBER 2022 Real is an underutilized parcel with building that had not been improved since its construction in 1974 with over fifty percent of the site dedicated to surface parking lot. The two parcels combined are approximately 0.88 acre. This site currently contains no residential development and would achieve full residential buildout of the site (on the remaining parcel avoiding the existing memorial),since the City does not prescribe specific FARs for the DCCSP area, but rather, bases development decisions on RAR and individual project review. The existing improvement-to-land value is estimated to be approximately 0.36 on the developed portion of the site based on the latest County property tax information for fiscal year 2021-2022. Values less than 1 suggests the site is currently underutilized. The Housing Allocation Bank's 92 units for this Development Area are assumed between these two sites. Site 10- (DCCSP) 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 and its construction dates back to 1962. The center has not undergone any major remodels in the past and remains largely outdated. A major building tenant was a grocery store which vacated in the 2015-2016 timeframe and that tenant space has since remained 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 large size, could possibly be developed with additional units if a transfer of units from another Development Area was requested and approved. This site currently contains no residential development and the City does not prescribe specific FARs for the DCCSP area,but rather,bases development decisions on RAR and individual project review. The existing improvement-to-land value is estimated to be approximately 0.36 on the developed portion of the site based on the latest County property tax information for fiscal year 2021-2022.Values less than 1 suggests the site is currently underutilized. Sites 11,12,13,and 14- (DCCSP) Development Area 4 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 within these four sites which total approximately four (4) acres. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-9 SEPTEMBER 2022 Site 11 consists of six contiguous small vacant parcels totaling 1.02 acres. These six vacant parcels are held by one owner. The site is located at 225-255 El Camino Real and 250 Prospect Avenue. Site 12 consists of three contiguous vacant parcels totaling approximately 2.29 acres arranged in an L-shaped configuration. All three parcels are held by one owner. The site is located at the NEC of El Camino Real and Sixth Street (generally at 542 El Camino Real). Site 13 is a vacant 0.25-acre parcel located at 125 W. Main Street located adjacent to developed land area. Site 14 is a vacant 0.44-acre parcel located at 420 El Camino Real.The vacant site is L- shaped, wraps around a building and is adjacent to community serving uses which makes it ideal for infill development. Sites 15 and 16-DCCSP Development Area 6 Site 15 is vacant and site 16 is non-vacant. All 260 units for this Development Area, identified in the Housing Allocation Bank,are assumed between these two sites. Site 15 consists of 2.73 acres on three parcels under one owner 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 at the southwest corner of El Camino Real and Sixth Street. The site is 7.81 acres and all three parcels that comprise this parcel are under one owner. 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. Since then, the property owner and the representative have actively engaged in consultation with the City staff on the project site design and layout responding to the pandemic new opportunities (outdoor dining and open space). This site currently contains no residential development and the City does not prescribe specific FARs for the DCCSP area, but rather, bases development decisions on RAR and individual project review. The existing improvement-to-land value is estimated to be approximately 5.10 on the developed portion of the site based on the latest County property tax information for fiscal year 2021-2022. Values less than 1 suggests the site is currently underutilized. This site's improvement-to-land value is high;however, as described, interest to redevelop the site indicates redevelopment potential. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-10 SEPTEMBER 2022 Enderle Center The non-vacant site 17 (Enderle Center) consists of approximately 11.6 acres, under the ownership of a single family.Of the site area,7 acres have been identified suitable for housing development. Currently the site supports a commercial center, with redevelopment,the site is expected to accommodate 413 housing units.The City has been approached by several developers showing interests in redeveloping the shopping center with mixed-use development. Additional information regarding realistic capacity of the developed site is provided in the following section. This site currently contains no residential development and with a rezone would be allowed up to 413 housing units with no maximum FAR, similar to the DCCSP and RHASP areas. The existing improvement-to-land value is estimated to be approximately 2.5 based on the latest County property tax information for fiscal year 2021-2022.Values less than 1 suggests the site is currently underutilized. This site's improvement-to- land value is high; however, as described, interest to redevelop the site indicates redevelopment potential. The Market Place The non-vacant site 18 (The Market Place) consists of approximately 76 acres, under single ownership,the Irvine Company. Of the site area,approximately 18 acres have been identified suitable for housing development. Currently a commercial center, with redevelopment it is expected to accommodate 900 housing units. Additional information regarding realistic capacity of the developed site is provided in the following section. This site currently contains no residential development and with the rezone a total of 900 units would be allowed and no maximum FAR would be prescribed similar to the DCCSP and RHASP areas. The existing improvement-to- land value is estimated to be approximately 0.82 based on the latest County property tax information for fiscal year 2021-2022. Values less than 1 suggests the site is currently underutilized. 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, DCCSP, Enderle, and Market Place areas. It is estimated that between these areas, a total of 648 of the 1,724 very-low income units, and 404 of the 1,046 low-income units would be developed in these areas. That results in approximately 36 percent of very-low and 39 percent of low income housing units anticipated to be developed within non-vacant areas, which is lower than the stipulated 50 percent. Further, not all the sites in these areas are non- vacant, resulting in an even lower percentage of housing units expected on non- CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-11 SEPTEMBER 2022 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 B-12 SEPTEMBER 2022 Table B-2 Sites to Meet RHNA(With Income Distribution) Site Reference Vacant or Very Low Capacity Units Very Units Low Units Units Non- &Low Low Income Moderate Above Vacant Income Income Income Moderate Units on Income Vacant Pro ert TLSP- Neighborhood D North(includes Vacant 296 555 230 66 72 187 Specific Plan amendment)(Site 1A) TLSP- Neighborhood D- South(includes Specific Plan Vacant 532 1,396 314 218 244 620 amendment)(Site 113) (includes approved entitlements) TLSP- Neighborhood G (includes Specific Vacant 878 2,229 526 352 383 968 Plan amendment) (Site 2) RHASP(Sites 3-6) 1 Vacant 6 500 124 79 83 214 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-13 SEPTEMBER 2022 Site Reference Vacant or Very Low Capacity Units Very Units Low Units Units Non- &Low Low Income Moderate Above Vacant Income Income Income Moderate Units on Income Vacant Pro ert 3 Non- Vacant Site 3(Approved Vacant) Entitlements) Non- Vacant- 6 137 6 0 0 131 Approved Housing Project Site 4 Non-vacant 0 226 67 56 60 43 Site 5 Non-vacant 0 32 8 5 3 16 Site 6 Non-vacant 0 105 43 18 20 24 DCCSP(Sites 7-16) 4 Vacant 5 Non- 39 747 187 117 125 318 Vacant Site 7 Non-vacant 0 45 6 3 3 33 Site 8 Non-vacant 0 46 11 6 5 24 Site 9 Non-vacant 0 46 11 6 6 23 Site 10 Non-vacant 0 200 65 47 22 66 Site 11 Vacant 10 40 8 2 10 20 Site 12 Vacant 12 68 10 2 20 36 Site 13 Vacant 0 12 0 0 3 9 Site 14 Vacant 5 30 3 2 10 15 Site 15 Vacant 12 60 9 3 15 33 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-14 SEPTEMBER 2022 Site Reference Vacant or Very Low Capacity Units Very Units Low Units Units Non- &Low Low Income Moderate Above Vacant Income Income Income Moderate Units on Income Vacant Pro ert Site 16 Non-vacant 0 200 64 46 31 59 Site 17-Enderle Non-vacant 0 413 102 67 69 175 Center Site 18-The Market Non-vacant 0 900 225 141 150 384 Place Projected ADU& 35 9 6 6 14 JADUs Entitled Units Vacant- (Transitional Homes)-approved Approved 7 7 0 0 0 entitlements, Housing Project permits in progress. RHNA 6,782 1,724 1,046 1,132 2,880 Assigned Distributions 1,796 6,782 1,724 1,046 1,132 2,880 Achieved Assigned Distributions Achieved with 20% 8,138 1,724 1,046 1,132 4,236 Buffer(within TLSP Neighborhood G) Note:Percentage of total Very Low-and Low-Income units on vacant land is 75 percent. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-15 SEPTEMBER 2022 Zoning Appropriate to Accommodate Very Low and Low Income RHNA Government Code Section 65583.2(c)requires,as part of the analysis of available sites, a local government to demonstrate the projected residential development capacity of the sites identified in the housing element can realistically be achieved.The following factors are considered when determining the realistic capacity of a site: • Land use controls; • Site improvements; • Typical densities of existing residential development;and • Current and planned utilities. Zoning Sites 1 through 16, identified 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. This is evidenced by existing residential development taking place within the master planned community and in the surrounding cities and described in Table B-4. Sites 17 and 18, Enderle Center and The Market Place, are currently zoned as Planned Community Commercial (PC COM) and Planned Community Mixed-Use (PCMU) - SP 8 (East Tustin Specific Plan), respectively. These zoning designations do not currently support residential development. Both sites would be rezoned under Program 1.1 to allow for high density residential/mixed use development.There are no provisions that would deter accommodating very low- or low-income housing. Table B-3, Zoning / Size / Lot Consolidation Potential / Available Infrastructure, below,is a snapshot of sites appropriateness regarding these respective factors.Some housing sites are candidates for lot consolidation or splits to increase development potential of the site. The City's process for lot splits and lot consolidations are outlined in Section II of this Housing Element. Table B-3 Zoning/Size/Lot Consolidation Potential/Available Infrastructure Site Site Reference Appropriate Site Size Lot Available # Zoning (Acres) Consolidation Infrastructure Potential Tustin Legacy Specific Plan Area 1 Vacant, Yes* Varies Yes Planned as Neighborhood part of D North and Master South. Planned CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-16 Site Site Reference Appropriate Site Size Lot Available # Zoning (Acres) Consolidation Infrastructure Potential Community and analyzed in certified EIR 2 Vacant, Yes Varies Yes Planned as Neighborhood part of G Master Planned Community and analyzed in certified EIR Ree]Hill Avenue S eci fc Plan Area 3 Vacant,13751- Yes 3.37 Approved Yes,analyzed 13842 Red Hill Project in certified Avenue entitled for EIR (Approved housing project) 4 Non-vacant, Yes 7.08 Yes Yes,analyzed 13822-13852 in certified Red Hill EIR Avenue 5 Non-vacant, Yes 0.90 No-One Yes, analyzed 1571 El Camino Parcel/Yes in certified Real with EIR Adjacent Site 4 6 Non-vacant, Yes 5.95 Yes Yes,analyzed 14081-14231 in certified Red Hill EIR Avenue, Stater Bros. Shopping Center Downtown Commercial Core Specific Plan Area 7 Non-vacant Yes 1.1 Yes Yes,analyzed and vacant; in certified Non-vacant at EIR 365 W. First St. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-17 SEPTEMBER 2022 Site Site Reference Appropriate Site Size Lot Available # Zoning (Acres) Consolidation Infrastructure Potential (Think Physical Therapy) & Vacant Lot Frontage of Villa Viento A artments 8 Non-vacant, Bel Yes 1.0 No-One Yes,analyzed Air Motor Parcel in certified Hotel at 140 W. EIR First Street 9 Non-vacant, Yes 0.88 Yes Yes,analyzed Tustin War in certified Memorial at EIR 150 E. First& Wienerschnitzel Street at 105 El Camino Real 10 Non-vacant, Yes 16.47 Yes,Though Yes,analyzed Larwin Square Same in certified at SWC First Ownership EIR Street& Newport Avenue 11 Vacant lots, Yes 1.02 Yes,Though Yes,analyzed Farmer's Same in certified Market Related Ownership EIR Properties at 225-255 El Camino Real& 250 Prospect Avenue 12 Vacant lots, Yes 2.29 Yes,Though Yes,analyzed NEC of El Same in certified Camino Real& Ownership EIR Sixth Street at generally 542 El Camino Real CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-18 Site Site Reference Appropriate Site Size Lot Available # Zoning (Acres) Consolidation Infrastructure Potential 13 Vacant Lot,125 Yes 0.25 No-One Yes,analyzed W. Main Street Parcel in certified (adjacent to EIR Arvida Book Store, previously Mrs. B's) 14 Vacant Lot,420 Yes 0.44 No-One Yes,analyzed El Camino Real Parcel in certified EIR 15 Vacant Lot Yes 2.73 Yes-3 of 4 Yes,analyzed Adjacent to I-5 Parcels in certified Freeway&East Under Same EIR of Jack in the Ownership Box Restaurant at 14042 Newport&El Camino Real 16 Non-vacant, El Yes 7.81 Yes,Though Yes,analyzed Camino Plaza Under Same in certified at SWC of El Ownership EIR Camino Real& 6th Street, (generally at 620 El Camino Real,634 El Camino Real, No Listed Address) Other Sites 17 Non-vacant, Requires 11.62(7 acres Yes, same Yes, site Enderle Center Rezoning suitable for ownership located near development) major arterials streets existing infrastructure and there is adequate CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-19 SEPTEMBER 2022 Site Site Reference Appropriate Site Size Lot Available # Zoning (Acres) Consolidation Infrastructure Potential capacity for development. 18 Non-vacant, Requires 76.937(18 No Yes, site The Market Rezoning acres suitable located near Place(East for major Tustin Specific development) arterials Plan) streets existing infrastructure and there is adequate capacity for development. *Site 1A,1B(TLSP Neighborhood D-South)and Site 2(TLSP Neighborhood G)has appropriate zoning, but a rezone(Specific Plan Amendment)to accommodate residential development is proposed to occur within three years. 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 design by imposing limits on overall unit counts within the Specific Plan area, without specific density restrictions for individual sites. Sites 17 and 18 would be rezoned to include a residential overlay that would allow for high density residential/mixed use development. 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 or more per acre which would be the case within identified housing sites. Therefore, these sites have appropriate density to accommodate lower income units. Development Trends/Realistic Capacity Recent development trends in the City were used to aid in determining the realistic capacity of housing sites identified for future residential development in meeting the City's RHNA allocation. Recent development projects that include residential uses are included in Table B-4 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-20 TABLE B-4 Realistic Capacity Develo ment Trends Project(Year)/ Zone Units Area Density Description ac. du/ac.) The Bowery Specific Development(SD)- 1,150 14.6 79 (2020)/mixed-use Santa Ana Broadstone Arden Specific Development(SD)- 1,221 18.8 65 (2020)/apartments Santa Ana Anton Legacy TLSP 225 7 32 (2015)/apartments Tustin 13751 &13841 Red RHASP 137 3.4 41 Hill Avenue Tustin (2021)/mixed-use Brookfield/single TLSP 400 25.4 14-29 and multi-family Tustin residential Tustin Legacy: TLSP 1,208 19 60-65 Multi-Family Tustin mixed-use Development(In- process) City of Irvine' Median Density of High - - 70 Density Residential Developments City of Santa Anal MEMU Overlay Zone Recent - - 45-90 Developments Sources: 'City of Irvine Second Draft 2021-2029 Cycle Housing Element Update,November 19,2021 2CiLy of Santa Ana General Plan Housing Element 2021-2029,October 21,2021. Higher-density residential development is now common in recent developments within one to two miles of the Specific Plan areas (see Table B-4). The following capacity assumptions were made based on recently proposed and approved development in Tustin and the surrounding area. The minimum densities exclude areas that may be used for infrastructure, ingress/egress, parking, commercial components when part of a mixed-use development (Refer to Attachment B-1A for net area calculations): • The TLSP area is anticipated to provide capacity of 0 555 units over approximately 40 acres in Neighborhood D North (40 du/ac minimum); 0 1,396 units over approximately 45 acres in Neighborhood D South (45 du/ac minimum);and CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-21 SEPTEMBER 2022 o 2,229 units over approximately 50 acres in Neighborhood G(50 du/ac minimum). Recent developments proposed and approved in the TLSP area show that densities have been between 32 and 62 dwelling units per acre.Further,CBRE Inc. was retained to market the Tustin Legacy Multifamily Mixed-Use Development Site, identified as a 19.4-acre site with 1,208-unit capacity (approximately 62.2 dwelling units per acre).1 As mentioned previously,sites within TLSP do not have a density prescribed; rather, there is a unit development cap in each of the planning areas. The prescribed capacity would be within the proposed development cap, except for Neighborhood D North where residential was not previously planned.However,the TLSP would be amended to add 555 units to the TLSP Neighborhood D North. Development conditions would be comparable to the other TLSP area. Therefore,it would be reasonable to assume the TLSP area to be developed at comparable density(including the proposed 40-50 du/ac. densities)based on existing and proposed development trends in the TLSP area and vicinity. Mixed-use development is permitted and encouraged in Specific Plan areas. However, this is not anticipated to reduce residential development capacity for several reasons: o 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 TLSP alone) is planned for and accommodated. The TLSP has adequate sites to accommodate non-residential uses and there is no expectation that the demand for nonresidential uses will both utilize the available capacity and displace potential residential development. o 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 TLSP. The TLSP, 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 and updated regularly in support of an environmental impact report (EIR) (State Clearinghouse No.1994071005) prepared in compliance with CEQA.The EIR determined the utility plan identified in the Specific Plan would be adequate 1 CBRE,Inc.,2021. Tustin Legacy Multifamily Mixed Use Development Opportunity. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-22 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 TLSP, the Anton Legacy project is an example of a large site (7 acres) that was developed with significant affordable housing units. The project was constructed as a 225-unit 100 percent 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 TLSP encompasses the former Marine Corps Air Station Tustin, which closed in 1999. Since that time, hazardous waste remediation has been occurring across the site by the BRAC (Base Realignment and Closure) Cleanup Team (BCT). A small portion within the southern part of Neighborhood D North is continuing to undergo remediation; however, proposed housing sites are outside of the remediation area. Therefore, the presence of continued remediation activities on the Tustin Legacy site will not impair the site's ability to support the number of anticipated residential units. 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 to the City are planned for development as part of a regional park and community college campus. • The RHASP area is anticipated to provide capacity of 0 395 units over approximately 10 acres north of I-5 (40 du/ac) and 0 105 units over approximately 6 acres south of I-5 (18 du/ac). A recent development in the RHASP was proposed and approved in 2021 at a density of approximately 41 dwelling units per acre. The project site is approximately 3.4 acres in size and was a result of lot consolidation of two parcels. Other developments in the surrounding area support similar densities as well on similar size lots. Additionally,the RHASP uses a RAR to allocate 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 proposed number of units within the RHASP would be within the remaining allotted capacity of the planning CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-23 SEPTEMBER 2022 area.Therefore, it would be reasonable to assume 18 to 40 dwelling units per acre based on existing and proposed development trends in the RHASP area and vicinity. • The DCCSP area is anticipated to provide capacity of 0 45 units over approximately 1 acre in DA1 (41 du/ac minimum); 0 92 units over approximately 2 acres in DA2 (48 du/ac minimum); 0 200 units over approximately 17 acres in DA3 (12 du/ac minimum); 0 150 units over approximately 4 acres in DA4 (38 du/ac minimum); and 0 260 units over approximately 11 acres in DA6 (27 du/ac minimum). 0 140 units entitled and constructed over 6.8 acres in DA6 (20.6 du/ac minimum). A total of 887 residential units have been allocated through the DCCSP within six Development Areas. The DCCSP is subject to voluntary inclusionary housing provisions (City's Voluntary Workforce Housing Incentive Program)that requires a developer of a residential project of twenty (20) or more units to provide affordable units on-site whenever a developer is requesting a residential bank allocation using the City's administrative residential allocation reservation process. For projects under 20 units, the developer may elect to pay an in-lieu fee or provide the units off-site. It is assumed that developments proposed in the DCCSP area would be over 20 units per acre. The DCCSP was recently adopted in 2018, and development patterns have not yet been established for the area. Similar to other specific plan area,the DCCSP operates on a RAR The average of four Tustin projects identified in Table B-4 equals approximately 38 du/ac.Therefore,it would be reasonable to anticipate a similar development density for DCCSP housing sites. Densities proposed under DA1 and DA2 include 41 and 48 du/ac. As shown in Table B-4,recent mixed-use projects in the City range between 16 to 62 du/ac. Therefore, the City's is taking a conservative approach in anticipating development to take place at 41 and 48 dwelling units per acre based on existing and proposed development trends in the DCCSP area and vicinity. • Enderle Center and Tustin Market Place CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-24 The following provides further analysis of the two additional sites added to the sites inventory after receiving public input, requesting a reduction in the number of units in the TLSP area and requesting identification of sites in other parts of the City. General The City included two sites located in commercial zones as suitable housing sites for rezoning to allow mixed-use development, which would introduce the opportunity to allow higher density housing in either horizontal or vertical mixed-use developments. The City incorporated these sites in recognition of several factors. First, in response to real estate market changes which places a new demand for commercial development to adapt to changes in retail land uses in particular with the increasing popularity of e-commerce. Second,to plan for lower-income,multi-family residential development to be located throughout the City, particularly in proximity to resources such as parks, schools, public amenities and services, and employment centers. Finally, the inclusion of these two non-residential commercial center as suitable sites for residential development aligns with community input received during the public outreach process,requesting that the City identify additional adequate sites outside of the TLSP area. Ultimately, the redistribution of units these two sites will further facilitate the equitable dispersion of housing units of various income levels throughout the City. The City identified: (1) The Enderle Center and (2) The Market Place in Tustin as adequate for housing development which will provide housing capacity with planned zoning and land use changes. These two sites have capacity for 413 housing units and 900 housing units, respectively, with a combined total capacity of 1,313 housing units. Each identified site is adjacent to developed land and based on documentation outlined within this element,each site has sufficient infrastructure and is accessible to support housing development. In selecting both of these sites, the anticipated development density is conservative and based on development trends in nearby communities (refer to Table B-4). Furthermore,the anticipated development does not rely on the demolition of any existing building but rather focuses on areas used for surface parking;and Program 1.2 provides that parking may be replaced with parking structures,as needed,to provide required parking. Finally,as part of the program,the city will develop parking standards that incentivize creative parking strategies such parking credits for transit rich development and allowance of parking structures and parking lifts, by right and subject to CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-25 SEPTEMBER 2022 Objective Design Standards(refer to Program 1.2).Environmental constraints are factored into the Sites Inventory; however, these two sites are not impacted by any environmental constraints. Redevelopment of the sites would be taking place on already developed land which contains asphalt parking lots. Retail - Changes in Consumer Preference The COVID-19 Pandemic accelerated the evolution of the retail commercial real estate market away from the large traditional brick-and-mortar footprints.According to a Retail Market Report produced by CoStar(a leading commercial real estate analytics database) in February 2021, more retail square footage was vacated than occupied (i.e.,the net absorption) in Orange County in 2020.More specifically,858,000 more square feet of retail space was vacated vs. occupied and rent growth declined by 2.1 percent in 2020. This market data clearly indicates a lack of demand for retail space in the County and that there is an oversupply of space given demand. CoStar also shows that vacancy rates in the County have increased from a five-year low of about 3.5 percent in the middle of 2018 to over 4.5 percent in the middle of 2020. CoStar forecasts that vacancy rates will increase to over 5.0 percent by 2024. These market changes support the City's decision to include new non- residential sites for re-zoning during the planning period,to allow for higher- density housing in either vertical or horizontal mixed-use development. Housing Capacity Evaluation For the purposes of assessing realistic density for sites where current zoning does not allow for residential development for these two sites, the City reviewed and analyzed recent development in the City and nearby cities. Table B-4 summarizes recently approved or housing development projects in construction which demonstrates the viability for future housing developments at these two sites. Furthermore, the City has first-hand knowledge and experience that mixed- use developments continue to be viable opportunities for housing development.In late 2021,the City released a Multi-family mixed use offering seeking interest in the delivery of 1,208 residential units (906 market rate,302 lower income) on 19 acres of city owned property which would develop at approximately 60-65 dwelling units per acre. The multifamily mixed use offering was advertised to all entities identified in subdivision (a) of Section 54222 of the Government Code and were invited to participate in the CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-26 competitive bid process (over 430 entities). The City received a high level of interest and received responses from numerous developers that met the terms of the offering, and the City is still finalizing our selection. The City utilized the surplus land exemption granted in Government Code section 54221 (f) (1) (F) (ii) of the SLA for a mixed-use development that is more than one acre in area, that includes not less than 300 housing units, and that restricts at least 25 percent of the residential units to lower-income households, as defined in Health and Safety Code Section 50079.5 as affordable housing pursuant to Section 102(a).While the process and required level of affordability under the SLA exemption creates many challenges for developers, the City is encouraged as many high-quality developers demonstrated that they are still interested, and submitted proposals to develop a high density multifamily mixed use project. Site 17- (Enderle Center) The Enderle Center is anticipated to provide capacity of 413 units over approximately 7 acres (59 du/ac). During the preparation of the Housing Element Update, the City was in contact with the property owner representative. The property owner expressed their support of the re-zoning. Furthermore, the City has been approached by several developers showing interests in redeveloping the shopping center with mixed-use development. This demonstrate the viability of the site to be redeveloped within the planning period, if not, sooner towards the beginning of the new planning period. TABLE B-5 Enderle Center Existing Zone: Planning Community Commercial Allow mixed-use development with minimum 30/du acre(Refer to Program Proposed Zone: 1.1) Total Area: 11.62 Area Suitable for residential development: seven(7)acres(60 percent of the site) Proposed Housing Capacity: 413 units Proposed Density: 59 du/ac Rezone properties to allow mixed-use, During Planning Period: allowing residential development. The Enderle Center is located within the northern edge of Tustin, southwest of 17th Street and Enderle Center Drive. The Enderle Center is directly north CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-27 SEPTEMBER 2022 of residential development and has existing infrastructure that would be available to serve mixed-use development. Anticipated density is planned to be 59 dwelling units per acre.This density was determined by identifying the area as having capacity for 413 residential units based on an estimated seven (7)-acre site available for redevelopment. As shown in Table B-4, recent mixed-use projects in the City range between 16 to 65 du/ac. Therefore, the City's is taking a conservative approach in anticipating development to take place at 59 dwelling units per acre based on existing and proposed development trends in the region. The site does not currently support residential land use;however,the site has been identified as underutilized by the City based on other surrounding development trends and compatible for mixed-use development. Approximately seven (7) acres consist of underutilized buildings and expansive surface-level parking lots and are suitable for redevelopment to accommodate housing development.Program 1.1 would add an overlay zone to allow for residential development as part of a mixed-use development at up to 59 dwelling units per acre. Parking displaced as a result of redevelopment would be accommodated by vertical parking structures located within proposed development structures. With Program 1.2,parking structures would be permitted by right,making it easier to build parking structures to make up the loss for surface parking. Site 18-The Market Place The Market Place Center is anticipated to provide capacity of 900 units over approximately 18 acres (50 du/ac). The Tustin Market Place is located north of Jamboree Road and El Comino Real near the intersection of I-5 and SR-261.The Market Place is a commercial shopping center which is under one ownership, The Irvine Company. The large site size and single ownership make this site advantageous for development, as consolidation would not be necessary. This retail center originally developed in the 1990s with big-box spaces and large parking fields that lacks the walkable, place-making attributes of today's successful retail centers. The existing layout of this retail center, which is adjacent to the 5 Freeway and close to employment,makes these properties underdeveloped. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-28 TABLE B-5 The Market Place Existing Zone: PCMU-SP 8 (East Tustin Specific Plan) Allow mixed-use development with minimum 30/du acre(Refer to Program Proposed Zone: 1.1) Total Area: 76.93 acres Area Suitable for residential development: 18 acres(24 percent of the site) Proposed Housing Capacity: 900 units Proposed Density: 50 du/ac Rezone properties to allow mixed-use, During Planning Period: allowing residential development. The Tustin Market Place is directly south of residential development and has existing infrastructure that would be available to serve mixed-use development. The Irvine Market Place, a comparable development southeast of Bryan Avenue and Jamboree Road, is anticipated to support multi-family housing as well.The City of Irvine has identified a density of 50 dwelling units per acre for portion of sites located in the City of Irvine. The site does not currently support residential land use;however,the site has been identified as underutilized by the City based on other surrounding development trends and compatible for mixed-use development. As shown in Table B-4, recent mixed-use projects in the City range between 16 to 65 du/ac. Therefore,the City's is taking a conservative approach in anticipating development to take place at 50 dwelling units per acre based on existing and proposed development trends in the region. Zoning for this site would be amended to allow multi-family residential/mixed use development and modified development standards appropriate for facilitating affordable housing. Program 1.1 would add an overlay zone to allow for residential development as part of a mixed-use development with a minimum density of 30 dwelling units per acre. Approximately 18 of the 76.93 acres consist of expansive surface-level parking lots that are mostly not occupied and are suitable for redevelopment at greater density. The anticipated development over 18 acres would take place on underutilized asphalt parking lot areas. Parking displaced as a result of redevelopment would be accommodated by vertical parking structures located within proposed development structures. With Program 1.2, parking structures would be permitted by right, making it easier to build parking CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-29 SEPTEMBER 2022 structures to make up the loss for surface parking. In addition, Program 1.1 would add an overlay zone to allow for residential development as part of a mixed-use development with a minimum density of 30 dwelling units per acre. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-30 ATTACHMENTS ASSOCIATED WITH APPENDIX B SITE INVENTORY ASSESSMENT CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-31 SEPTEMBER 2022 Attachment B-1 Sites Identification to Meet RHNA* Identified in Previous 4" Vacant or &/Or 5th Site Site General # Site Reference Non- Cycles/Was Size APNs Ownership Zoning Plan Capacity Vacant Counted (Acres) Towards RHNA Tustin Legacy Specific Plan Area 1 Neighborhood D PA 8,13&14 Vacant Yes(both)/ 1A North[requires rezone] Yes 39.873 City of Tustin SP 1 TLSP 555 0.002 430-381-38 2.466 430-381-41 1.235 430-381-91 36.170 430-381-95 16 Neighborhood D-South 44.861 1,396 Brookfield Development- 25.437 Tract 18197 (Approved/Permitted)and also 5.289 Lot 2 requires rezone to add a minimum 2.778 Lot 5 of 200 additional units 2.639 Lot 6 2.572 Lot 7 4.012 Lot 8 3.984 Lot 9 4.163 Lot 10 Multifamily 19.424 Tract 18197 7.039 Lot 11 6.934 Lot 12 5.451 Lot 13 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-32 Identified in Previous 4" Vacant or &/Or 5th Site Site General # Site Reference Non- Cycles/Was Size APNs Ownership Zoning Plan Capacity Vacant Counted (Acres) Towards RHNA 2 Neighborhood G PA 15 Vacant Yes(both)/ 50.321 City of Tustin SP 1 TLS 2,229 No 3.573 0.665 430-381-27 1.559 430-381-28 1.349 430-381-29 46.748 10.010 430-391-03 4.946 430-391-27 9.086 430-391-28 3.396 430-391-56 0.107 430-391-59 0.139 430-391-60 5.000 430-391-61 3.316 430-391-62 7.212 430-391-63 3.536 430-391-64 Red Hill Avenue Specific Plan Area Planning Area—North of 1-5 395 units 3 13751-13841 Red Hill Avenue Non- Yes 3.37 SP 13 RHASP 137 (Approved Entitlements) Vacant Opportunity 0.46 500-141-09 WASL Investors V, site(5th only)/ LLC,a Delaware Not for RHNA Limited Liability Company CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-33 SEPTEMBER 2022 Identified in Previous 4" Vacant or &/Or 5th Site Site General # Site Reference Non- Cycles/Was Size APNs Ownership Zoning Plan Capacity Vacant Counted (Acres) Towards RHNA 2.91 500-141-10 WASL Investors V, (Vacant) c/o Irvine Asset Group,LLC 4 13822-13852 Red Hill Avenue(Red Non- No/No 7.08 SP 13 RHASP 226 Hill Plaza) Vacant 13822 Red Hill Avenue 4.9 500-022-12 RHP8 LLC No address listed 0.28 500-022-09 RHP1 LLC 13852 Red Hill Avenue 1.9 500-022-04 RHP1 LLC 5 1571 EI Camino Real(Denny's Non- No/No 0.90 500-022-02 RHP2 LLC SP 13 RHASP 32 Restaurant) Vacant Red Hill Avenue Specific Plan Area Planning Area—South of 1-5 105 units 6 14081-14231 Red Hill Avenue Non- No/No 5.95 SP 13 RHASP (Stater Bros.Shopping Center) Vacant 14081 Red Hill Avenue 0.53 432-041-04 Huber G.Wilson 14131 Red Hill Avenue 0.16 432-041-17 Huber G. Wilson/Old Town Inc. 14171 Red Hill Avenue 0.83 432-041-19 Huber G.Wilson 14171 Red Hill Avenue 2.60 432-041-20 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-34 Identified in Previous 4" Vacant or &/Or 5th Site Site General # Site Reference Non- Cycles/Was Size APNs Ownership Zoning Plan Capacity Vacant Counted (Acres) Towards RHNA Huber G. Wilson/Armand 14213 Red Hill Avenue 1.50 432-041-21 Pedicini Huber G. Wilson/Armand 14231 Red Hill Avenue 0.33 432-041-14 Pedicini Huber G. Wilson/Maria Pedicini Downtown Commercial Core Specific Plan Area Development Area 1 45 units 7 365 W.First St.(Think Physical Non- No/No 1.1 SP 12 DCCSP Therapy)&Vacant Frontage of Villa Vacant Viento Apartments 365 W.First Street 0.6 401-523-30 365 West First Street LLC Vacant Frontage of Villa Viento 0.5 401-523-15 Tustin-First Apartments (portion) Investment Co Development Areal 92 units 8 Bel Air Motor Hotel at 140 W.First Non- No/No 1.0 401-571-14 GLM Ventures LLC SP 12 DCCSP Street Vacant DA-2 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-35 SEPTEMBER 2022 Identified in Previous 4" Vacant or &/Or 5"' Site Site General # Site Reference Non- Cycles/Was Size APNs Ownership Zoning Plan Capacity Vacant Counted (Acres) Towards RHNA 9 Tustin War Memorial at 150 E.First Non- No/No 0.88 SP 12 DCCSP Street&Wienerschnitzel at 105 EI Vacant DA-2 Camino Real 150 E.First Street(Tustin War Mem) 0.43 401-583-01 City of Tustin 105 EI Camino Real(Restaurant) 0.45 401-583-15 Holmes John M the Holmes Family Trust Development Area 3 200 units 10 Larwin Square at SWC First Street& Non- No/No 16.47 SP 12 DCCSP Newport Avenue Vacant DA-3 630 E.First Street 12.20 401-601-01 Larwin Square SC Weinberg LLC 13341 Newport Avenue 0.81 401-601-04 PK II Larwin Sq.SC 13421 Newport Avenue Tustin 0.32 401-601-05 PK II Larwin Sq.SC 13451 Newport Avenue 0.38 401-601-06 PK II Lawrin Sq.SC 13471 Newport Avenue 0.39 401-601-07 PK II Larwin 550 E First St 1.00 401-601-08 Haggen Property South LLC CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-36 Identified in Previous 4" Vacant or &/Or 5th Site Site General # Site Reference Non- Cycles/Was Size APNs Ownership Zoning Plan Capacity Vacant Counted (Acres) Towards RHNA 275 Centennial Way 0.46 401-601-09 PK II Larwin Square 662 E First Street 0.91 401-601-10 PK II Larwin Square Development Area 150 units 11 Farmer's Market Related Properties Vacant Yes(both)/ 1.02 SP 12 DCCSP at 225-255 EI Camino Real&250 No DA-4 Prospect Avenue 250 Prospect Avenue 0.17 401-584-04 Mary M.Prescott No Address Listed 0.17 401-584-05 Mary M.Prescott 255 EI Camino Real 0.17 401-584-06 Mary M.Prescott 245 EI Camino Real 0.17 401-584-07 Mary M.Prescott 235 EI Camino Real 0.17 401-584-08 Mary M.Prescott 225 EI Camino Real 0.17 401-584-09 Mary M.Prescott 12 NEC of EI Camino Real&Sixth Street Vacant Yes(both)/ 2.29 SP 12 DCCSP at generally 542 EI Camino Real No DA-4 520 EI Camino Real 0.50 401-623-14 Prescott Mary M. Exemption Trust Address unavailable 1.1 401-623-15 Prescott Mary M. Exemption Trust 135 W.6th Street 0.69 401-623-16 Prescott Mary M. Exemption Trust 13 125 W.Main Street(adjacent to Vacant No/No 0.25 401-573-13 PacificSA-P 12 DCCSP Arvida Book Store,previously Mrs. Maintenance& D4 B's) Repair Inc. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-37 SEPTEMBER 2022 Identified in Previous 4" Vacant or &/Or 5th Site Site General # Site Reference Non- Cycles/Was Size APNs Ownership Zoning Plan Capacity Vacant Counted (Acres) Towards RHNA 14 420 EI Camino Real Vacant No/No 0.44 401-622-18 Radon Davor SP 12 DCCSP DA-4 Development Area 6 260 units 15 Vacant Lot Adjacent to 1-5 Freeway Vacant Yes(5th cycle) 2.73 SP 12 DCCSP &east of Jack in the Box Restaurant /No DA-6 at 14042 Newport&EI Camino Real No address listed 0.77 432-074-02 All parcels owned 14042 Newport Avenue 0.675 432-074-07 by Tustin Capital, No address listed 0.378 432-074-08 LLC&Kim Michael No address listed 0.906 432-074-09 16 EI Camino Plaza at SWC of EI Camino Non- No/No 7.81 SP 12 DCCSP Real&6th Street Vacant DA-6 620 EI Camino Real 3.5 401-631-01 ECP Investors LLC 634 EI Camino Real 4.2 401-631-15 ECP Investors LLC No Listed Address 0.11 401-631-13 ECP Investors LLC Other Areas of City 17 Enderle Center,near 17thSt,Enderle Non- No/No 11.62 401-251-04 Bruce A.Enderle, PC PCCB 413 Center Dr.,Yorba St.and Vacant (7.0 ac. 401-251-06 Scott W.Enderle, COM Vandenburg Suitable 401-252-05 Wallace Enderle for develop- 401-252-06 Trust,Wallace ment) 401-252-08 Owens Enderle 401-252-09 Trust 2 401-252-10 401-253-04 410-253-03 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-38 Identified in Previous 4" Vacant or &/Or 5th Site Site General # Site Reference Non- Cycles/Was Size APNs Ownership Zoning Plan Capacity Vacant Counted (Acres) Towards RHNA 18 The Market Place,near Interstate-5 Non- No/No 76.93 500-291-25 Tustin Market SP 8 PCCB 900 and Jamboree Rd,nearthe Cityof Vacant (18 ac. 500-312-10 Place I LLC PC Irvine. suitable COM for develop- ment) 19 House of Ruth Transitional Housing Vacant Yes(both)/ 0.38 500-071-12 City of Tustin R4 HDR 7 Units at 1941 EI Camino Real (Entitled, No Plan check and permits currently underway) Other ADUs&JDUs Non- No/No NA NA NA Varies Varies 35 Vacant TOTAL ESTIMATED UNIT CAPACITY 6,782 Note:Unit capacity incorporates anticipated TLSP rezone(Neighborhood D—North) CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-39 SEPTEMBER 2022 Attachment B-1A Sites Identification to Meet RHNA-Realistic Capacity Estimates REALISTIC CAPACITY Density(Gross Land Area) Density(Net Land Area)* Site #of Units #of Acres Density #of Units #of Acres Density TLSP Nbrhd"D"North 1A 555 40 14 555 14 40 TLSP Nbrhd"D"South 1B 1,396 45 31 1,396 31 45 TLSP Nbrhd"G" 2 2,229 50 41 2,229 45 45 RHASP-North 3,4,5 395 11.35 35 395 10 40 RHASP-South 6 105 6 18 105 6 18 DCCSP DA1 7 45 1 45 45 1 45 DCCSP DA2 8,9 92 2 46 92 2 46 DCCSP DA3 10 200 17 12 200 17 12 DCCSP DA4 11,12,13,14 150 4 38 150 3.5 43 DCCSP DA6 15,16 260 10.54 25 260 9.5 27 Enderle Center 17 413 11.62 36 413 7 59 The Market Place 18 900 76.93 12 900 18 50 Notes: *Excludes areas that may be used for infrastructure,easements,ingress/egress,parking,commercial components when part of mixed-use developments,etc. Note:Acreages have been rounded to the nearest whole number. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-40 r Suitable Sites for Additional . Residential Development ■� fo Suitable Site Locations ® Downtown commercial Core Specific Plan � ly� •• Red Hill Avenue Specific Plan f ®Tustin Legacy Specific Plan Enderle Center -Tustin Marketplace Municipal Boundaries l� N Mile CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-41 SEPTEMBER 2022 Attachment B-2 Tustin Legacy Specific Plan Site Aerials Individual Site APN Maps Tustin P) Site 2 TLSP NEIGHBORHOOD G 2,029 remaining units in this area Amend TLSP to accommodate a minimum of 200 additional housing Site 1A units to meet RHNA TLSP NEIGHBORHOOD D NORTH 50.321 acres (VACANT) • Area does not have residential units planned Amend TLSP to accommodate D North a minimum of 555 additional Li units to meet RHNA 39.873 acres(VACANT) D SITE 1B sbut TLSP NEIGHBORHOOD 0 SOUTH 1,296 remaining units in this area(includes 400 approved units-Brookfield) Amend TLSP to accommodate a minimum of 100 additional housing units to meet RHNA • 45 acres IVA L The sites in TLSP are vacant.DRvelopmentis under CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-42 SITE IA: NEIGH6ORHOOO O North(Rezone) 39.873 Acres Zoning: SP 1 $ General Plan: TLSP 555 Units Address APN Asre Total Acreage Tustin r� Legac4 ...... 381-3& 0X022 11 i3Bi /a rx Specific 4300 Plan 39.873 430.381-41 2.466 1 North 1 430-381-91 1.235 3 `�t d } ,rsillKK 1430-381-95 36.17 1 Source:Orange Cou n t4 A55e55cr Parcel iiWMr nR' (U[i¢J. ..04.0— Map trAViNb—Map m.,.,w.,r in` ❑ CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-43 SEPTEMBER 2022 Site 1B NEIGHBORHOOD D SOUTH • 45 Acres 1396 Units _ • Zoning:SP 1 General Plan:TLSP Includes 6rookfield Develepment(400 units) �►';'' t� �* 1,208 Future Units—Multiple Family ,moi _�.a �_;"'a� x' s ® ��*y •,x m Address APN Acre Total Acreage � ^°�^^• "`" a Lot 2 5.2$4 '�•. 'rd, 'ma � nor� ::®1tlT� Lot 5 2.778 a Loth 2.639 � �� _` ,• •' Lot 7 2.572 A„ " e.. \ wr rn 19 Lot 8 4.012 ^� � South Lot 9 3.984 44.8fi Brookfield Tract Lox 10 4,163 18197v� a Lat 11 7.039 Lot 12 6934 Lat13 5.451 Source:Orange County Assessor Map CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-44 ua38 NEIGHBORHOOD G ` Addres APN Acre 1�� 430-381- 27 x.555 Ne"hbcr =I hwdG VQ 18 ,;,n•� 0 a 430.381- 1573 28 1.559 all- 430 ll430 361 25 1.349 G he . u.rrig. Source:Orange County Assessor Parcel Map —w m' WO in. !0.M.v "° Z, Za CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-45 SEPTEMBER 2022 Continued NEIGHBORHOOD G —.39 a- Address APN Acre Total 1—�;, Acreage w•13 43n-371- ,,,•. �' �-,. �` w39 .7.9.76 mcr�i rn sc+�>Jv„=r I .a�. �• Y ,.4.30-i 11- E- •;`' ;9 9.086 Sfi 3.396 46.748 °' Fay. nxa 430-391• ,wCii p�Err c .. NQhhorhe ss 6.107 od G m 430-391- 6U 0.139 ,_ 430-391• 61 5 430-391- 430-391• J� ... FQc .•. 63 7.212 430-391- fiA 3.536 �tl.1�076 Seurce:Crange C o u my Assesso r Pa rcel �„C„„ , a a�w ������ , �� 42 r Map 3S CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-46 Attachment B-2 Red Hill Avenue Specific Plan Site Aerials/Individual Site APN Maps Tustin —_ 22=132-:211! gi 13751-13831 RED H LL AVENUE ed Hill plaza -226 h"units(2 Parcels)Entitled project in 2421 7.08 acre137 housing a its approved � xo-xi-xnxs � 3.37 acres Ho..Y�Elennn ��, r� �'SkTy/ +•�y e \ .,�.. y .00 Y e RED HILL kk AVENUE , SPECIFIC PLAN 4 ", e. F1571 EL CAM]NO REAL-32 housing units AREA "; ,Nf f 0.90 acres �,, •Ism--.— _.` �."� _sr�s�*+ ^� .—• l � Site 6 14081-14231 kEO HALL AVENUE shopping Center- 105 housing units 5.95 acres CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-47 SEPTEMBER 2022 mo-14 SITE 3: 13751 — 13841 RED s HILL AVENUE r (2 Parcels)Pending Project 3.37 Acres Zoning: SP 13 a o 0 o General Plan: RHASP Address APN Acre Total c s x Acreage 13751 Red 0 n�w w• �. Hill 500.141- ® r a Avenue 09 0.46 �,fbroe 13841 Red Hill 500-141- .• .�_.-_-_.,�rwr— - Avenue 10 2.91 Source:Realquest will rkl fACi IA�'!7 .Yd-n.1S ,�• 7W sa/�+ F7 M1Kf,q.V�V Y.0 ldf@kAAv. um.r rmEt mwr .xh:.• CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-48 SITE 4; 13822—13852 RED HILL / wo-42 AVENUE a Red Hill Plaza � 7.08 Acres-RHASP Zoning: SP 13 General Plan: JI �V, J --� L_ J 13822 Red WO-022- I' Hill Avenue 12 4.9 No Address 500-022- 7.08 0 0e ® 8 Listed 09 0.28 nsai m 3 13852 Red 500-022- an Hill Avenuel 04 1 1.9 104 03 I I' I I• q •`.• wmr ron rwur sa Source:RealQ.uest rv+n,a us :x ir:. H9ft� v.x 4-iA 3fN i✓,w r �i� ux r nvw CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-49 SEPTEMBER 2022 SITE 5: 1571 EL CAMINO REAL f x=02 Denny's Restaurant a 0.90 Acres Zoning: SP 13 General Plan: S �l RHASP Address APN Acre Total AcreageIxo ssrsei suo•0zz-ox 0-9 0.e Source:RealQuest rr nn �ca. er ire �. ,-. .. d. ❑ CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-50 SITE 6: 14031-14231 RED HILL AVENUE St.t,,U,xh—Shvppiny Center 5.95 3.nr., Inn np SP L3 Cent l Plan:RHASP Add—e APN ACRES Tutal Acreage IV i 7 JJ L 1 � + 14061 Red Hill 432-041-04 0153 nprAvr 8 1�® Avenue , 1� 1 14231 Red HIII 432-041.14 0.33 Avenue D 5,95 au a •."� 14131 Red Hill 432-041-17 0116 Avenue , S 14171 Red HIII 432-04119 0.83 Avenue '. 14171 Red Hill 432-041-20 2,60 Avenue e a.t } r,rca aac 1— .vrxmeq 14213 Red Hill 41.1-1-21 1.50 i Avenue 03 40 r �, o m AN �ra��[r.n U[r wr.ib li rww it.ire.rs ..w. �wasu CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-51 SEPTEMBER 2022 Attachment B-2 Downtown Commercial Core Specific Plan Site Aerials/Individual Site APN Maps SITE SITE 8 365W.FIRSTST.&VA( NT IA N6AOWJA!' WJAIR 0W.FIRST STREET Tustin VIENTO APTS.—45 units MOTOR HOTEL-l ACRLIACRE5 I :a SITES s° SITE g t t zosi—zaza � "� ' � �' ' " •• Mouxink ElemenC _ i I 4 J� 1' Fr v. a SITE _ 150E.FIRSTSTREET&10SELCAMINOREAL I TUSTIN WAR MEMORIAL AND I' p WIENERSCHNITZEL +' .. 0.88ACRE5 o SITE ao" I Sit DOWNTOWN COMMERCIAL CORE SPECIFIC PLAN AREA ire ° CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-52 SITE 7: 365 W. FIRST ST. & VACANT LAND ADJACENT TO VILLA VIENTO APARTMENTS Approx.1,1 Acres Zoning; SP 12 C z; General Plan: DCC5P a z9 C- Addre. APN Acre Tt.1 r3 165 W.First 401-523-30 0.6 St pn C Vacant 40L-523-15 0.5 Frontage of {portion] Apartrrent, fw L P A,mr Source:City'315 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-53 SEPTEMBER 2022 SITE 8, 140 W.FIRSTSTREET l J L Bel Air Motor Hotel s r dwxe L '• 1 Acre Zoning:SP 12 General Plan: OLLSP ° k Address APH Acne Total Acreage ry m a'.rr axe 140 401• 0jWest 571-14 1 acre 1 acre First =c. Street p i , i Source:Real4uest � 1 F e q•�sr CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-54 SITE 9: 150 E. FIRST STREET & 105 ELCAMINOREAL Tustin War Memorial and Wienerschnitzel 0.88 Acres Zoning: SP 12 General I " —4 A"' Plan: DCCSP p arsrrx rasFIR. a aa:A 11 k Address APN Acre Yard A'w� sef 1 N Acre �.y A,�4�2 4�y rry•� ryry ff �U y� kl V if 150 E.First 401-583-01 0-43 i 4 [ffr 'Stmt 0.88 I wa - 105 EI 401-583-15 0.45 ,(Rtacr t L , T —L A -� rt [amino Reall - nawCt .[arcs i 101.ff . •A f�7dflf 0 G ( 0 9 CflaO4O` Sri-r] " �f7 x lluj rawrAo L wM(XI WT%Z4 rf .A.I.Y' ti.-r..•ti s:.tl,i'.in aiii SfBPS•W a W,% A u.i'.P 4 M a Ntx 91 QAC'NG.T 4.x.Y-,5 •'?±90. is^,Es rl-.•T14S1 Iwo x scar nvi-m ro IA w Source:RealQuest �.x. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-55 SEPTEMBER 2022 Tustin SITE 10 LARWIN SQUARE SWC OF NEWPORT AVE&FIRST STREET—200 units Z021—sots 16.47 Acres NouRinp rleme�rt DOWNTOWN COMMERCIAL `:r CORE > .. SPECIFIC PLAN AREA SITE CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-56 SITE 10: LARW I N SQUARE IN-bo 6A7a°,es Zoning:SP 12 General Plan: DCCSP _ T Address APN Acro TotalAereaga -- 630 E 15T 5T 401-501-01 12-20 , 13341 401-601-04 0.81 _ v NEWPORT AVE e •, I! nm 0.32 A" i NEWPORT AVE 401.609-05 13451 _.' 'sail NEWPORT AVE 401-601-04 0.38 16.47 •„ €; 13471 Newport urr '......_...._..-.. 401-601-07 0.39 .....J Ave ....,...... ,0 550E IST ST 401.601.08 L00 i _...._....._..._..� ,.....__......,. 27S CAG CENTENNIAL 401-601-09 WAY 662E IST ST 0.91 I� ❑ Source:6ealquest CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-57 SEPTEMBER 2022 SITE 11 SITE 12 Tustin 225—255 EL CAMINO REAL' NEC of EI CAMINO REAL&SIXTH STREET &250 PROSPECTAVE. 542 EL CAMINO REAL;VACANT VACANT2.25 Acres 1.02 ACRES 7021-8029 " � w ; SITE ; ' SITE r f DOWNTOWN „ ^, COMMERCIAL SITE 13 RE 125 W.MAIIVSTREET—ADJACENT TOARVIDA SITE 14 12 SPECIFIC BOOKSTORE;VACANT 420 EL CAMINO REAL;VACANT PLAN AREA0.25 acres 0.44 Acres SITE k s �f ° '�!! Y I _ Sites: , r , 0 1 I .� �1 SITE 11, 12, 13,14— �., � � � r ! , •� i 150 units CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-58 SITE 11: 225—255 EL CAMINO REAL r 3..w'____.___ wr 58 &750 PROSPECT AVE. w Baa rrxr a+.a lir Farmer's Market Tempo raryy Use Y '7�+ 4P Pub°�wi 1,02 Acres Zoning.. SP 12 Generali :.w"wa wre,,rnm Plan: DCCSP 4iF+ Add r;;;T APIN Acres .- irrNcr irrsrrN frgrfN w w '� J_.5CI a r BLKA e u,r581 A'• " Averlutt 4071-584-04 0.17 1r Noz-ddress Co00 r lis,L-d 401-584-CS 17 s� 255 EI Camino . MCI Rcal 401 584 061 D 1 1.02 ' Pe,N(D 4 245 EI Apr. ri " en iarao Camino Real 401-584-07 0.17235 El J w ' F1•M ` M � I. Camino sis+r erT1 eaa . . Real 401-584-08 C.1! a L 225 EI Camino s � Real 1401-584-091 0.17 1trar �tn.e,lx •a. _, re fx�f�. ,t�a:�r.r Vrr 4 I xe 114 ween sax v wx 91 ow w 555 RI[19-15 5w:oo iw�:r.rs '1a: 3,YAw Source: Realauest and Orange County PLIHIL 1Ijurks 1=1 ap we 9mr 9mr PA 21-if 3„!;� CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-59 SEPTEMBER 2022 ar62 SITE 12: NEC of EI CAMINO „ � REAL&SIXTH STREET J l"' "I '` _� 542 EL CAMINO REAL 2.29 Acres Zoningg: SP 12 General Plan: OCCSP e" Address APN Acre Total + d Acreage r�, ,ll`-:x.A,�� •�, C 520 EI xurr Camino Real 401-623-14 0.50 Rz rx 2.29 LI �< 2 mc. x . No Listed 9 ° p Address 401-623-15 1.1 n � 135 W 6th 401-623-16 0.69 � •R ,°-.rz.ra--r .4 i Mair sfa_r L 3 Nrrx 1 r , f'ox 63 61 §� 61 Smfx mrnr rNfl x rA➢ Source:RealQuest worn +xrr ra u- Ailtt M , n'-1.rN+.lq+f sow .,.a.5 .SA.tl05A�F� CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-60 SITE 13: 125 W. MAIN STREET—ADJACENT TO _ ARVIDA BOOK STORE 0.25 Acres Zoning:SP 12 w Q General Plan: DCCSPAddress APN Acre TotalAcreage ;a ,vC70p Cl 125 W. 401-573- Mam St 13 0.25 0.25 •. "€ - -«--- I �.�.:�..�.�.�...�,,�:�,: 1 •;�•--•is; wCY�fA� riWa'xTr i�.!-W Q Source:RealQuest x..P +.oar,m.-a a%�gal u�s� CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-61 SEPTEMBER 2022 SITE 14:420 El Camino Real 0.44 Acres Zoning: SP 13 General Plan:DCCSP T -7 Sam W! Address APNI Acre Total C Acreage 420 El 401-522- 0.44 0.44 0 j Camino is z.. ]a-" .L Real T1 all, 11"ry A ww IW1 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-62 Tustin SITE 16 EL CAMINO PLAZA SWC OF SIXTH STREET&EL CAMINO REAL 7.81 Acres DOWNTOWN SITE 15w COMMERCIAL 14042 NEWPORT AVE.&EL CAMINO REAL CORE VACANT;2.73 Acres SPECIFIC PLAN `:,q + r a a AREA Sites 15&16 .. SITE " v _ I ' SITE s 260 housing units '' {' CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-63 SEPTEMBER 2022 SITE 15: 14042 NEWPORT "i00 AVE.& EL CAMINO REAL 2.73 Acres Zoning: SP 12 General Plan: DCCSP .K�-1 — � Addness ApN Acre Total ' ..Acreag! °,wa 77" 14042 Newport 432-074- Avenue 32-074Avenue 02 [}77 al R.cr Q 0 G `•• 14442 Newport 432-074 Avenue 07 0.675 0 14042 L M y ; Newport 432-074 1^ 0 Avenue 1 08 1 0,378 1 r. 14042 Newport 432-074 95 Avenue 09 0.906 2.73 . rxn sv ivi�,nc v i.-m Source:RedlUuvA and Orange County Public Works WL •:.m...xu, E,I CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-64 rr � SITE 16: EL CAMINO PLAZA `.1 +o+63 `'€ 7.81 Acres Zoning:SP 12 General Plan: ' r•p awuo ,.� �. ,ra� • ++ DCCSPIF I ne 620 EI 21 Y ; Camino J r Rea 1 401-631-01 3.5 14, l; 634 EI Camino 7.81 Real 1401-631-151 4.2 1aaecn�6 r , F No Listed F u Address 401-631-13 0.11 J Le L •, B r 8--e mx Source:RealQuest and City of Tustin GIS Database , ,w, �M mr.xv.aa...� fIAY AC.,N YY.M•M 14.'.�1.A...Vf CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-65 SEPTEMBER 2022 Tustin SITE 1.7 -� ENDERLE CENTER—413 housing units 202,_202" Tota I:11.62 Acres (Acreage suitable for redevelopment 7 acres) SITE sE� _,b Zz— CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-66 Enderle Center SITE#17:ENDERLE CENTER 11.62 acres Zoning:PCC General Plan:PCCB _ ! gvr rrexrN � t . 14081 Yorba St 401-251-04 1.05 P 1724017th St 401-251-06 0.54 1728017th St 401-252-05 0.52 1730017th St 401-252-06 3.53 - 401-252-08 1.05 � — +��• "' 17480 17th St 401-252-05 D.3 / 5+`� 0 •O `�'- "' 1744D 17th St 401-252-10 3.32 ass°a 14032 Enderle ';£ 401-253-03 D.5 Center Dr �;o�wV�d. - 401-253-04 0.81 r �� 7i4-bh Total Site Acreage 11.62 raacr "y5?`- Total Acreage Suitable e Residential Development 7 ""RE"BE4" d evt Partially orwholly suitable for residential development CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-67 SEPTEMBER 2022 Tustin SITE 18 THE MARKETPLACE—900 housing units Total:76.937 Acres -a (Acreage suitable for redevelopment 18 acres) 2021-2023 • - M , 1 SITE rr 1 w � I h a CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-68 Market Place SITE#18;THE MARKETPLACE i MIM akSSC 76.937 acres Zoning:SP-8 General Plan:PCCB 377 2870 EI Camino Real 500-291-02 5.464 , 2982 EI Camino Real 500-291-04 5.18 3v2 •©� 2992 EI Camino Real 500-291-06 0.5 ~ 3002 EI Camino Real 500-291-07 0.41 - r 3010 EI Camino Real 500-291-08 0.31 2996 EI Camino Real 500-291-11 0.59 `'*o~_ ✓t' 4 +n*}1w}• 500-291-12 0.12 •-r'� �-.�1.�,. :.1T t - s L3 - 500-294-21 0.25 3020 EI Camino Real 500-291-23 0 3040 EI Camino Real 500-291-24 07.78 �I , 3030 El Camino Real 500-291-25 19.226 2762 EI Camino Real 500-291-26 1.562 n 2762 EI Camino Real 500-291-27 5.645 �.�. .O e= 2741 EI Camino Real 500-312-02 3.214 - 500-312-03 6.11 2851 El Camino Real 500-312-04 4 9 s• �' 4r 2961 EI Camino Real 500-312-06 2.88 3025 EI Camino Real 500-312-08 0226 -� J� 3015 EI Camino Real 500-312-09 0.315 500-312-10 18.655 s �� •d Total Site Acreage 76.937 Total Acreage Suitable for 18 Residential Development Ai y Partially or wholly suitable for — ?•""' ""' - -� residential development CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-69 SEPTEMBER 2022 Tustin Transitional Housing 1941 EL zoz,_xo�$ REAL—ENTITLED Nouein�Element House of Ruth Q Transitional Home Units) a } J w ¢ k l k' SITE w CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-70 ADUs/JADUs—35 housing units Tustin _= Citywide: ADUs/JADUs 2021-2029 Nuusinii Element � yt W— •----�yy—rte' it 4� CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-71 SEPTEMBER 2022 Attachment B-3 Buffer Site Site Reference Vacant or Identified in Site APNs Ownership Zoning General Capacity # Non- Previous Vh Size Plan Vacant &/Or 5`h (Acres) Cycles/Was Counted Towards RHNA Tustin Legacy Specific Plan Area 1 Neighborhood D PA 8,13&14 Vacant Yes(both)/ City of Tustin SP 1 TLSP 1A North[requires rezone] Yes 39.873 714 0.002 430-381-38 2.466 430-381-41 1.235 430-381-91 36.170 430-381-95 2 Neighborhood G PA 15 Vacant Yes(both)/ 50.321 City of Tustin SP 1 TLSP 642 [requires rezone] No 3.573 0.665 430-381-27 1.559 430-381-28 1.349 430-381-29 46.748 10.010 430-391-03 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-72 Attachment B-3 Buffer Site Site Reference Vacant or Identified in Site APNs Ownership Zoning General Capacity # Non- Previous Vh Size Plan Vacant &/Or 5`h (Acres) Cycles/Was Counted Towards RHNA Tustin Legacy Specific Plan Area 4.946 430-391-27 9.086 430-391-28 3.396 430-391-56 0.107 430-391-59 0.139 430-391-60 5.000 430-391-61 3.316 430-391-62 7.212 430-391-63 3.536 430-391-64 TOTAL ESTIMATED UNIT CAPACITY 1,356 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN B-73 SEPTEMBER 2022 Attachment B-4 HCD Required Site Inventory Form To Be Submitted Following Housing Element Adoption-As Allowed CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 B-74 APPENDIX C AFFORDABLE HOUSING RESOURCES CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 C-1 APPENDIX C AFFORDABLE HOUSING RESOURCES The City has compiled a list of funding sources for a wide variety of major housing assistance programs available from federal and state agencies and private lending institutions that can assist in meeting the City's housing needs. 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 6th Cycle Housing Element CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 C-2 Update and, secondly, an implementation tool associated with the Housing Element Update. 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 CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 C-3 costs for navigation centers and emergency shelters, and the new construction, rehabilitation, and preservation of permanent and transitional housing. • Preservation At-Risk Housing Rental Units/CDLAC 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 414 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 Community Development Block Grant (CDBG) funds to continue its financial support of homeless assistance CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 C-4 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. • 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 Coe Commercial 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 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. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 C-5 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 HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 C-6 This page intentionally left blank. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 C-7 APPENDIX D AFFIRMATIVELY FURTHERING FAIR HOUSING CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 D-1 APPENDIX D AFFIRMATIVELY FURTHERING FAIR HOUSING 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 resources and opportunities. 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 jurisdictions 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-2 SEPTEMBER 2022 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. 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-3 SEPTEMBER 2022 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 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-4 SEPTEMBER 2022 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. • 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 TLSP 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 for Hispanic/White and Black/White populations (as defined by Dissimilarity Index values which indicate geographical segregation patterns) • Disproportionate housing problems for the city's Hispanic and Black residents (problems include 1) housing unit lacks complete kitchen facilities;2) housing unit lacks complete plumbing facilities;3)household is overcrowded;and 4)household is cost burdened); • Concentrated female-headed households and LMI population within Census tract 755.14; CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-5 SEPTEMBER 2022 • 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 County and all participating jurisdictions have a role to play in implementing those goals. In addition,the City of Tustin committed to individual goals and actions,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. Additionally, goals and actions were included as programs in the Housing Element(Section IV) to address constraints that are not currently being adequately addressed within the City. Overview of AS 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-6 SEPTEMBER 2022 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-7 SEPTEMBER 2022 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 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) CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-8 SEPTEMBER 2022 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 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. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-9 SEPTEMBER 2022 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 • 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). 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-10 SEPTEMBER 2022 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 • 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-11 SEPTEMBER 2022 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% ° Hispanic 859,086 6.70/° Hispanic 32,982 41.22% 5,700,860 44.44% 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% ° origin Vietnam 234,251 1.93/° #5 country of Korea 1,446 1.81% Korea 224,370 1.85% origin CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-12 SEPTEMBER 2022 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 #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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-13 SEPTEMBER 2022 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/°° difficulty Self-care 1,162 1.46% 312,961 2.60/°° difficulty Independent 2,353 2.95% 496,105 4.13% living difficulty Total 6,477 8.1% 158,784 5% (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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-14 SEPTEMBER 2022 Figure 1: Census Tracts in the City of Tustin 7Mdt 7�Ji VUI VII 7Wr�i City of Tustin - Census Tracts City Boundary Q Cencus Tracts Not Analyzed 0 Tustin Cencus Tracts N 0 0.5 1 Miles City of Irvine,County of Las Angeles,Bureau of Land Management,Esri,HERE, I i i i Garmin.INCREMENT P,USGS,EPA Source:AFFH 13ata Viewer CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-15 SEPTEMBER 2022 Figure 2:2020 TCAC/HCD Opportunity Areas (Tustin) o na im — Ragional Park f1 an Aveti P - r`q E•Chapman•Ave 0 h. m 1. Vv AlmaixJ A'v,- aah'Crove'FWY„`R'_e `h='�uW N Fairhaven , ._ Memorial Z � tpbc A 2 it �� ��UY l•.G�IJ ` 1 r o .�o� 1 Cly Q Santa Aiio N UJCJ9 S6 V7 • F ' 0 J 4%f vtil LL2M -� � �•tl{' Hicks C M e 71 c V!.6l_Y� uuUy�vE.E.4X/ 4 � f fl'j F 40S V7 't• `� `TIbilinwr IA've ,..:rf�,,J J��SCy 'Tim,, 111 uth e rvine City of Tustin Rant h TCAC Opportunity Areas 2021Park Oak Highest Resourceya° may •. Ccouro if 3 High Resource fijA',ti� fik'Nr ® rseGo Moderate Resource(Rapidly Changing) F r- Moderate Resource 4 Ajro , Low Resource High Segregation&Poverty B`t`u % Q City Boundary k'd Vltlians Sand Canyon jpast` Urnvcr�, It�3} N 0 0.5 1 Miles Regional City of Irvine,County of Los Angeles,Bureau of Lanrd''Management,Esi i�HERE, I I I I Park Garmin,INCREMENT P,USGS METVN SA-NGA EPA USDA Source,AFFH Data Viewer 4 f. pr French Hlrf CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-16 SEPTEMBER 2022 Figure 3:2021 HCD/TCAC Opportunity Areas (County) n hill.,L ,— Whittier mWhittief -. ,° _�, Easleadr Wo HJ�nIII Vail 11 k cr+iNo vatt>=v m .... A,A I 1M7N0-N1CC5 y .N..:i::.f iF i r r.nfl�, i a.rrrt -.- A,rtrs 4L,kk El , . I 7 ES CAC VALLEY EA M�x `• �t.. 1 ;„t„ya� -r� c�rotwffin • � 73 'r • _� � P,I Sri iRt t '� r• r �I �°d of �, }f a rn Ai.. Ar.�, n�. ,r�.yt i 1� C:.C.ur.i trl•llir5� �t f Orange County TCAC Opportunity Areas 2021 SANTA MARS S ighest Resource High Resource Moderate Resource(Rapidly Changing) Moderate Resource GamG Pa Low Resource Mb—C. High Segregation&Poverty Missing/Insufficient Data County Boundary N 0 25 5 Mitles A I I I I 1 Garmin,USGS,NGA,EPA,USDA,NPs Source;AFFH Data Viewer CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-17 SEPTEMBER 2022 Figure 4: Areas of Minority Concentration in Tustin o na elm — ti" y� F.lagional Z -. Park �vCh PmanA,,e Orange , E-Chapman-Ave ,,,7nycn,,,r,�,,�P i s Vd Ahno lx1 Ave .. 'S ' •: 1 F'�+l6ry f Cd'� F La ire U Ave v If HF r • s 2 Garyeh.Grove"F+KY"�.` c� o Fairhaven _ y Memorial av Park Nrxtl7 Tustin �- Yol >w J tp� 1 17th St - A g loge y J a z2 � r � 1 1•• o Santa Ana !3rd Sl Eat , w o Mill= Q y C::LL'R�SSY�N • F r(t � 2 n m c r y r Mao G'•UM MEEO S1 A1orew pi 'inm Cil= hUCMa C. v, ve `�' C � P'v v' ukap "NIP IT Dyei Rj w ss � y '�A P` • f)o A', G -"' C Aft. •'o 7t.inflav;erAme '•� �� <fy se, t�� uth a" 16/1 Fij Grit_ In Ant4n?tay S,an•piego'Fwy Mo37y a �' �4a Irving Ranch City of Tustin Par" p ` ` ;, F f Oak Racial Demographics 2018 (Block Group) 4a°Q � °courGe _ �,"d' ryJ F'h.,. c 0 <20% i rcL 0 21-40% e s 41-60% 61-80% >81% Q City Boundary Sand Canyon$pap Unn�e-L!•,"`' t3�) N 0 0.5 1 Miles City of Irvine,County of Los Angeles,Bureau of Lan @�inagement,E ,HERE, I l l I Garmin,INCREMENT P,USGS,ME'M'AW f'A,USDA Source,AFFH Data Viewer French HIO e CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-18 SEPTEMBER 2022 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 Dissimilarity Index 1990 2000 20102020 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-19 SEPTEMBER 2022 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 lack/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 sian/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(as defined by TCAC Opportunity scores). 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 (I-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(as defined by Dissimilarity Index values).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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-20 SEPTEMBER 2022 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 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-21 SEPTEMBER 2022 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 Other Multifamily n/a n/a CV 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). CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-22 SEPTEMBER 2022 Figure 5: Percent Population with Disabilities in Orange County a.. , Chino Hills Mttm L.— A-h it ti-r maA-hither ' ch,�o Eastvale Jul Valli I ?� E iL H"1.ian UVail, yv 7 f t4 CHIN IO i ,- / v-�r•,w na La ey� IO VALLEY .�ud,�are, gut Re�arvohon m - Chl NILS -. s Chino Hila 'Norwalk s,a�irk ,rli Bellflower —A s,„A,1, r 5S 7 E5 CAL VALLEY The D Retroat e - 73 I I al . e .IliM73J 1, o - rt, PI •.r lit, - o - v _ e L 1 D. 'e P'A arc tiA fti r'A A:r - no 9fa le V L lJ fu"A I' Beach Orange County Population with a Disability(Tract)-ACS(2015-2019) 0«o% �nN P6 Writ Co 0 Loi zai 20%-30% 30%-4C% �>40% Q county Boundary AN 6 2.5 5 Miles I I I I Esri,HERE,Garmin,USGS,NGA,EPA,USDA,NPS Source:AFFH Data Viewer CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-23 SEPTEMBER 2022 Figure 6: Percent Population with Disabilities in Tustin OtAnaheim — . Fs�g ion al �J-: PmanAva 'r�tlige + — r5 E-Chapman•Ave •s v'd Almaid Ave m , I O4)W T. c F La,0 Ave e 2 �.! VZONTOW a�aan Groue,Fwy" a 41 N `J North T tin tPE.=- -- E c Vigo 1 u Santa Aiia S a u:• qr i ifl � hii. Fli,rrler Ave SI Air, hicks C t9rc � %MN Rpm I 251 v c 4 J v, n aw F Dye Rd S 1 .F A, r uth SaneDrefloFwyrr,p IrvineQ_ yt� ^c • iii. tlt 4 Rant h Park l City of Tustin f�> oak Creek Golf or Population with a Disability (Tract) - ACS (2015-2019) .> ., Courw <10% 0 10%-20% n r- �� 20%-30% /m ,aD% / Q City Boundary F133 N 0 0.5 1 MilesA Irvine,County of Los Angeles,Bureau of La ns,"`Management,Esn,HERE, I I I Garmin,INCREMENT P,USGS,MtTF,NASA.LPA,USDA Source:AFFH Data Viewer ` CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-24 SEPTEMBER 2022 Figure 7: Percent Population of Adults Living Alone - Tustin ,i dN 'A Chapman Ave Orange + ��E•ChapmawAve_.,/`. nter Vv Almo nJ Ave m m fSQ y F L a 4'e m A c, 22{�++++� 1 Caja°h.Grova'FWy: _ in Memorial Park L`�D Fno tfnit;, m I IJ-itli TLI- stol - 01111 1 J 17th St r to An - I Cage 'AJ SthSt ti,'Ul rpt -I�tPOW 1 'Tanta Aro BINd rjti ca I r� rlrsks Cany I111C.A_�ib ! %@A RPM rijr "! WCJX56 EX�h�!-CS ,,. q,, >q 7� arner-Ave—err f ++ ✓ � 6��a v E Ayer R[:' n C U Mer stlnllOvvef Ave !; th stim tSnta n 10.0 Ranch �u Park �; 'r._�'. OF C� �. Oak e John yar�A 5'AF, �F,F M1 Creek Golf Ways '��aF r {_ c Course ab Airpprt-qra kv,. 11 -- County a� - Michelsn, {, c City of Tustin Percent of Population 18 Years and Over in Households Living Alone (2019) 90'F City Q City Boundary 9h a yy a N A0 0.5 1 Miles ity cf Irvine,County of Los Angeles,Bureau of Lan Wr,a�nagement,E HERE, I I I I I Garmin,INCRE„NZ€�VT P,USGS,MER A,USDA Source:AFFH Data Viewer Tench Ntd -•r .9 r CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-25 SEPTEMBER 2022 Figure 8: Percent Population of Adults Living with their Spouse -Tustin OtAnaheim i z 'Ch PM Are Ir — � r`q E•Ghapman•Ave � •;p Vv Almaid Ave 'y °'tee F La JeO Ave 2 araah•Gros" .:. .. N O G� Foothill( m e'y rr I th T fi tlaW L :i ni rn - n S7.ris4,yT71.1('Gy ..1 uy:�w 1 mi UUCJ936 L/21".dy;�rJ kale Z It Santa Ana 1 •.I 1. GO - �t L Me' ; ,. aif m I ur U) - urk 'I'i til AII;;,. UU /2�6!!'3 4 Hf[k5 f U�bL'�l � � ASL � V1 J G PL N Ul F Dyer Rd ri J z C�s, ,�� n„�,_�r A•ne �er, � uth San DitgoFwy"1-, a �� Irvine Z�y'ae —San Ram h Park '�.. a ' Oak 110 Creek Golf or Course City of Tustin n Percent of Population 18 Years and Over in Households Living with Spouse F <a0% •i” z0%-40% 4 ,q ib, Q 40%-60% 60%-80% r: ti 1 i}�4u !rW Q City Boundary 11DP,^c1`>°��' F133] S" N A 0 0.5 1 Miles Irvine,County of Los Angeles,Bureau of Lan�daManagement,Eyri,HERE, I I I Garmin,INCREMENT P,USGS,METIA Fi�PA,USDA Source:AFFH Data Viewer cn HiN �- CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-26 SEPTEMBER 2022 Figure 9: Percent of Children in Married Couple Households -Tustin o na /�', z z an Ave Orange r`q E•Chapnnan•Avej .slnie,n v4"', 1. v,d Almaid Ave y F La VeO Ave e y aeh•Groua N Fairhaven _ Mannor I m E t1 rr J North T tPlac 17th St p G� z o= G 3rd SI Santa Arta a fi 1l �Y MAI E C1 = ,z t,• UlC:A9l'b s m L IMA U2.C.41/a - Q hii•. F.i,rI A.;� �I�j St Arc,:,: Hicks C c 4 V1 J i PL N Ul nUTA:ky.li U2 E.hLYJ tN�r ','�� F Dye f K'd 5 J n ,��A•re Oeery,,, V ��� uth ,.San DiecJaFwy^r - k Irvine ri Ram h `s Park City of Tustin '1y _ Creek Golf 6,r;. e Courw Percent of Children in Married-Couple Households 4 � zQ%-40% e� y 0 40%-60% - >80% _Ir Q City Boundary {133} N A 0 0.5 1 Miles Irvine,County of Los Angeles,Bureau of La nod`Management,E�ri,HERE, I I i i I Garmin,INCREMENT P,USGS,Mt"iM 'WA,USDA 3-. Source:AFFH Data Viewer ch.HAN CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-27 SEPTEMBER 2022 Figure 10: Percent of Children in Single Female-Headed Households -Tustin Or na eim E•Chapm i .li li.lr d. PmanAva r`q an•Avej �_rrnianv4,1,y A 1. v,r Almaid Ave i Od,W T. - / <� F La ureO Ave o� 2 0-.1.1a - ,FwY - n aeh•Groue N Fairhaven Marnor®I Park roothil"p� a'� 2611 m sy E Z = North T telae' 1 7th St aAm n 1 9e z p f Santa Ana V s ro st eat - 0 1 N E'C 111 ti � w aha I11JC.A'�' WC.A95D UPJ�R3��Y! tilC� �.., as o n L Mc ill ® V n "rh. U2.CE2J:3 � � fib\ ,"" F.i,rI hicks C 261 1*02 - � 4 J yL Wer �w r F Dye Rd r� J Uth G y19t ✓i s.. a I t. n-.v c`5 sfAItl i ,ye n ry ,.San DiegalF.wy Irvine Zy�e ��4 "�• Rant h Park l GKN *tom fi Oak Creek Golf or City of Tustin . fik1Nr c°°rte Percent of Children in Female-Headed Households O C 4 �'�10✓ ,� .Y, IJ Air 40%-60% Q City Boundary 331] IN A 0 0.5 1 Miles Irvine,County of Los Angeles,Bureau of La nod`Management,E�ri,HERE, I I I Garmin,INCREMENT P,USGS,Mt"iM 'WA,USDA 3.. Source:AFFH Data Viewer ch.HAN CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-28 SEPTEMBER 2022 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. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-29 SEPTEMBER 2022 Figure 11: Low and Moderate Income (LMI) areas in Orange County I Chino Hills hlva Ln ma Whittier _- �a,,,o Eastvale Jurupa vau w L r _ GHYNiC VALLEY ;h m A— C",'NOH/LLS 'J Gh.-HIM, A� _ —_� NoICO �^ .Not ,alk 5 Bel lb�wer Corona --�' Artes— �IF611ertbn ` Buena Oil � � . .j" F kfitYr,•.s F 55 7 ESCAL VALLEY the .- 0 Ballast l`lilll!A1JJ L1.r.JlJ.J f ;. 7_L1A.CfJ41ACC ll.LiLW I � I " V D. L SANTA MA.RG 1 Orange County Low to Moderate Income Population(Tract)-(HUD) <25% 25%-50% _50%-75% 75%-t00% QCounty Boundary N 0 2.5 5 Miles City of Irvine,County of Los Angeles,Bureau of Land Management,Esri.HERE, b b I Esri,HERE,Garmin,USGS,NGA,EPA,USDA,N Source:AFF"Data Viewer CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-30 SEPTEMBER 2022 Figure 12: Low and Moderate Income (LMI) areas in Tustin QtAnaheim 11a,,cr n A — � Park =h PmanAva r`q E•Chapman•Ave CfrnianV4,',yls 1. v,r Almaid Av,- 04), e O 1 r aF La VeO Ave 2 -a�aenGroue,Fwy" tFairhaven Memorol ForkNorth T tin h St p rn .� ^.,.1 Wf:AN�(12X10.•!_5 kge LLN 1 �•1II t 1 Otiiili:.l9 1 v . rj c` ? ® L F.t - V Vii St Arc,:,: Hicks C V1 J � PL w n G tier aw F Dye Rd _ r� 1 3 uth e'b�,. `vG� ' ' =,.San Ditgoa.Fw, ii...�`II1Q k 1'�'��n�4''"�l!• g Rant h �� Park City of Tustin °k Golf Low to Moderate Income Population (Tract) - (HUD) Cour e 1 kvy S' 'o` <25% E� y n 25%-50% - 759/.-100% ti 10- w 3 Q City Boundary F133} s- N 0 0.5 1 Miles A Irvine,County of Los Angeles,Bureau of La nod"'Management,Er,HERE, I I I Garmin,INCREMENT P,USGS,M�''iAWA,USDA Source:AFFH Data Viewer Ch.HAN CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-31 SEPTEMBER 2022 Figure 13: Racially Concentrated Areas of Poverty (RECAPS) in Orange County LI; e MSL nmvLunn Whittier" .. �.r,,,,:. Ea�t..-lr •°Up=yy L ' CHINO VALLEY H � � CHINO HILLS --- r cno,YONdis �Walk smmPar M G4u pall" Be_ll6fl_o_w_e_r ° Corocta—yam ■ —0y...Ane- M ail—, SS T ES CAL VALLEY t ,1 u LY ( e�1,-� lig i I 73 IA 1.1 I ,it � - o L Orange County Racially or Ethnically Concentrated Areas of Poverty(R/ECAPs) O 0-Not a R/ECAP 1-Rf ECAP Area Poverty Status(Tract)-ACS(2015-2019) CO U NTY \ <loo/, 0 10%-20% 20%-30% \\\ 340% % ->40% OCounty Boundary 9 N 0 2.5 5 Miles A City of Irvine,County of Los Angeles,Bureau of Land Management,Esr� RE, Es I 1 r I rl,HERE,Garmin,USGS,NGA,EPA, SDA,TIS Source:AFFH Data Viewer CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-32 SEPTEMBER 2022 Figure 14: Racially Concentrated Areas of Poverty (RECAPs) in Tustin OfAnaheim C�' RBQpRaI Park Lt'C Pri Ava _r1�,;1,1�= ��. F.;-I,,:i1`rr,;n - �. Al Almani A,,c m y m t p <a, — o� F La be4'�Ave 2 � 0 Gay pen•GroV e� rn Faur, W a r`rii Foothill North T n rol tplac V 171hSt r Fege 7i z I 1 z 1. I Santa Alla _ ,.. o V, yr w - ✓, E-Cogger A,, av'SI An7re,v r 1 � k+ck C❑ i a P F Dyer Rd wg C1 � uth ast zo � ,•I`,tw ono .-"r.,r. ti City of Tustin Ranch .Q `eek _,.. 1.` Racially or Ethnically Concentrated Areas of Poverty(R/ECAPs) s Park is 4% r. Oak 0-Not a R/ECAP n a C reek Golf .oC ?JI 1-R/ECAPArea 1o11 o Course �taY J c� Poverty Status(Tract)-ACS(2015-2019) <10% ti 10%-20% yti� s jz A fro ., , 0 20%-30% � rn m ->40% Q City Boundary �a5� 110�',e S`s' 1133 IN 0 6.5 1 Miles ity of Irvine,County of Los Angeles,Bure�ofLanMnagement,E HERE, r i I Garmin,INCREMENT P,USGS, -n A,USDA Source:AFFH Data Viewer French Hirt 3_� CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-33 SEPTEMBER 2022 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 ($105,126) and has a predominately non-White population. According to the 2020 Al,Tustin isolation index for White population was 52.44, which is moderate compared to other jurisdictions within Orange County and is lower than the county's calculated overall value (55.16). Table 7:White Household Income and Percent Population (2019) Tustin e Oran (city) Santa Ana Irvine Orange Orange County Median Household 84,697 91,793 66,145 105,126 90,234 Income All 931304 95,827 70,084 111,574 95,934 Households White alone' 101,658 95,702 79,000 113,779 100,723 White 59.01% 74.03% 28 47.80/° 59.25/°87% ° Population Notes: 1.White Alone refers to people who reported White and did not report any other race category. Source:2015-2019 American Community Survey 5-Year Estimates The City of Tustin has a lower median income than Orange County,but overall percentage of the White population is almost identical.As shown in Figure 15,both income and White populations tend to be concentrated within the northern portion of the city. Although census tracts of high income and predominately White populations do not exactly overlap,there appears to be an area of lower income and non-White majority near census tract 755.14. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-34 SEPTEMBER 2022 Figure 15:White Population and Median Income Distribution F`arF .a Orange e cr:.pm.at,Ave ©range c pm—Ave orth l North Tmt d� v� .: 3.. Santa Ana",' © fl a 4T�SX' FJ I ©all 6 © 91, a 4A'i8� t IDa� ©tea a Q a © Q fl �yicks Can © © / ycks Cany 4c'2l§ S �S Irvine s / Irvine s e90 Cr 1e90 Cr e � ea4 F City of Tustin City of Tustin Median Income(Block Group) White Majority ")###' 0`$B F-1<$ss, Slim(gap<10%) o<s><z� eH�t,z�z�B�zreMeH,a�h<omel Sizeable(gap 10%-50%) - ®creanar man$125,000 - Predominant(gap>50%) CM ca'--" 0 City Boundary a Bio<xeP N.meer 0 o s 1 Mles cit f Irvine.Count f los An ler,'Bureau of La nn N o 0.5 1 Miles c'i of Irvine,count f los An I l I nn re �O 9e l l l l >Y ru geles.INCREMf E,ud Management,Esri,HERE.Garmih,USGS,NG//rtrtrtrtrtrt,EPA. Management,Esri,HERE,Garniln,INCREMENT P, USvP,NPS U5G5,METI/NASA,EPA.USDA s ,..- a � olza -,,sl i Stf(�►j- a2- �a.� eao,_ >sl i50 fi�,> CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-35 SEPTEMBER 2022 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-36 SEPTEMBER 2022 Table 8 :Opportunity Map Scores-City Environment Low Economic Educational al Transportati Tustin Opportunity Opportunity Transit 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-37 SEPTEMBER 2022 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-38 SEPTEMBER 2022 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-39 SEPTEMBER 2022 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. 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-40 SEPTEMBER 2022 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 compared to Black and Hispanic residents. In specific,Hispanics in Tustin have the highest CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-41 SEPTEMBER 2022 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-42 SEPTEMBER 2022 Table 10:Access to Opportunity Indicators by Race/Ethnicity(1 of 2) Opportunity Census Tracts City of County of Indicators 524.19 525.02 525.24 744.07 744.08 755.04 755.05 755.06 Tustin Orange Poverty Rate Population Below Federal 2.6% 7.4% 4.3% 17.8% 6.7% 5.6% 11.0% 4.8% 31.9% 40.6% Poverty Level White alone 46.4% 47.9% 35.4% 11.4% 10.3% 54.7% 44.9% 46.9% 2.4% 1.6% Black or African 0.4% 1.0% 5.2% 1.1% 3.4% 0.4% 3.0% 2.3% 0.1% 0.2% American alone American Indian and o 0 0 0 0 0 0 0 0 Alaska Native 0.0/0 0.0/0 0.0/0 0.0/0 0.0/0 0.3/0 0.3/0 0.0/0 22.2/0 20.3/o alone Asian alone 35.1% 17.9% 32.4% 3.8% 3.6% 9.7% 7.3% 15.9% 0.1% 0.3% Native Hawaiian and 0%0 ° Other Pacific 0.0/0 0.0/0 0.0/0 0.0/0 0.0/0 2.4/0 0.0/0 40.0/0 34.1/o Islander alone Hispanic or Latino(of any 11.1% 28.0% 23.5% 82.8% 79.9% 30.5% 39.9% 32.4% 31.9% 40.6% race) CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-43 SEPTEMBER 2022 School Proficiency Total Title 1 1 - 1 - 2 - - 10 135 Schools Total Schools - 1 - 1 - 2 - - 19 607 Percent of - 100 - 100 - 100 - - 52.6 22.2 Schools Unemployment 3%8% 4 7% 3 2% 1.7% ° Rate(2019) 3.3/° 1.8/° 1.4/° 2.4/° 2.80/° 3.00/° Job Proximity <29 mins. 55.6% 73.9% 77.6% 73.3% 57.1% 71.4% 66.6% 70.9% 66.4% 57.6% 30-59 mins. 35.8% 21.3% 16.2% 22.1% 37.6% 24.3% 24.9% 21.0% 26.9% 32.6% 60 mins.or 8.6% 4.8% 6.2% 4.7% 5.2% 4.2% 8.5% ° more 8.5% 8.1% 6.8% 9.7% Transit Metrics All Transit Performance 0.0 6.2 3.8 5.3 4.6 6.0 7.3 5.9 4.8 4.2 Score Transit Trips Per Week 0 706 248 704 546 1,530 1,615 1,115 138 528 within 1/2 Mile CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-44 SEPTEMBER 2022 Transit Routes 0 8 3 7 5 8 9 7 1 4 within 1/2 Mile Jobs Accessible 0 304,241 145,104 257,864 218,602 311,834 333,019 244,043 17,685 172,595 in 30-Min Trip Commuters Who Use 0.00 1.00 0.43 2.74 3.52 0.00 2.28 0.55 1.11 2.28 Transit (percent) CalEnviroScreen CES 3.0 Score 16.66 22.75 19.35 32.39 32.75 27.08 21.69 20.99 23.00 27.93 CES 3.0 29.47 44.61 36.69 63.78 64.42 54.05 42.45 40.76 43.49 50.01 Percentile Pollution 5.03 7.24 5.45 7.21 6.06 6.22 5.72 4.44 5.54 5.18 Burden Score Population Characteristics 3.31 3.14 3.55 4.49 5.40 4.36 3.79 4.73 4.06 5.17 Score CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-45 SEPTEMBER 2022 Table 10:Access to Opportunity Indicators by Race/Ethnicity(2 of 2) Opportunity City of County Indicators Census Tracts Tustin of Orange 755.07 755.12 755.13 755.14 755.15 756.06 756.07 757.01 Poverty Rate Population Below Federal 15.5% 14.0% 9.1% 27.6% 23.3% 5.4% 10.2% 5.3% 11.4% 10.90% Poverty Level White alone 30.3% 15.7% 17.1% 11.3% 27.3% 66.6% 47.1% 40.3% 31.9% 40.6% Black or African 3.4% 9.0% 1.5% 2.3% 1.6% 0.0% 0.1% 1.0% 2.4% 1.6% American alone American Indian and o 0 0 0 0 0 0 0 0 Alaska Native 0.0/0 0.0/0 0.4/0 0.0/0 0.0/0 0.0/0 0.0/0 1.4/0 0.1/0 0.2/o alone Asian alone 15.1% 16.2% 19.2% 11.2% 39.4% 18.5% 36.2% 8.4% 22.2% 20.3% Native Hawaiian and 0%0 ° Other Pacific 0.0/0 0.0/0 0.0/0 0.5/0 0.0/0 0.0/0 0.0/0 0.1/0 0.3/o Islander alone CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-46 SEPTEMBER 2022 Hispanic or Latino(of any 48.0% 55.8% 56.9% 74.2% 28.4% 13.4% 13.5% 46.1% 40.0% 34.1% race) School Proficiency Total Title 1 2 1 - - 3 - - - 10 135 Schools Total Schools 5 1 - - 4 3 1 - 19 607 Percent of 40 100 - - 75 0 0 - 52.6 22.2 Schools Unemployment 4%6% 4 3% 5 1% 4.3% ° Rate(2019) 1.3/° L1/° 2.3/° 2.0/° 2.80/° 3.00/° Job Proximity <29 mins. 76.2% 71.7% 71.1% 70.6% 60.0% 68.2% 56.2% 56.5% 66.4% 57.6% 30-59 mins. 15.0% 23.1% 27.4% 22.2% 28.7% 24.5% 37.1% 33.4% 26.9% 32.6% 60 mins.or 8.8% 5.2% 1.4% 7.2% 11.3% 7.3% 6.8% 10.1% 6.8% 9.7% more Transit Metrics All Transit Performance 5.7 5.9 5.1 5.4 6.4 1.2 1.3 3.7 4.8 4.2 Score CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-47 SEPTEMBER 2022 Transit Trips Per Week 953 440 391 447 1,162 116 53 651 138 528 within 1/2 Mile Transit Routes 6 4 3 6 13 2 2 6 1 4 within 1/2 Mile Jobs Accessible 287,408 291,211 270,358 238,339 498,552 53,469 25,551 253,231 17,685 172,595 in 30-Min Trip Commuters Who Use 1.90 8.45 0.00 8.66 1.94 0.52 1.95 2.32 1.11 2.28 Transit(%) CalEnviroScreen CES 3.0 Score 22.63 28.04 27.06 34.00 36.62 5.58 8.30 21.77 23.00 27.93 CES 3.0 44.39 55.97 54.02 66.72 71.09 3.92 9.22 42.57 43.49 50.01 Percentile Pollution 4.98 5.31 5.27 5.22 8.91 4.47 4.22 5.90 5.54 5.18 Burden Score Population Characteristics 4.55 5.28 5.14 6.51 4.11 1.25 1.97 3.69 4.06 5.17 Score Sources:2015-2019 American Community Survey 5-Year Estimates;AllTransit Metrics,2021;CalEnviroScreen 3.0,2021;2019-2020 California Department of Education(CDE)Every Student Succeeds Act(ESSA)Comprehensive Support and Improvement(CSI)data file Notes:City and County CalEnviroScreen Scores represent the average of all Census tracts included within the jurisdiction. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-48 SEPTEMBER 2022 Figure 16: CalEnviroScreen 3.0 Percentile Scores I[..,Lind. . aguna Niguel )Laguna Beach IOna n �s II , 7t \ I. 1 ION VFr. I., Orange County CalEnviroScreen Percentiles _ 1-10%(Lowest Score) 11-20% 21-30% 31-40% � 41-60% l 51-60% 61-70% 71-80% 81-90% 91-100%(Highest Score) County Boundary N 0 3 6 Miles A l I I I I City of Irvine,County of Los Angeles, Bureau of Land Management,Esri,HERE, Source:CalEnviroScreen 4.0-Feb.2021 Update Garmin,USGS,EPA,NPS CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-49 SEPTEMBER 2022 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. 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 problems 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-50 SEPTEMBER 2022 Table 11: Any Housing Problem by Tenure and Race,Tustin Demographics of Households with Disproportionate Housing Needs Households experiencing any of 4 % with housing problems #with problems #households 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-51 SEPTEMBER 2022 Table 12:Any Housing Problem by Tenure and Race, County Demographics of Households with Disproportionate Housing Needs Disproportionate Housing Needs Jurisdiction 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 8.78% Total 52,728 987,550 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 Race/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 Native American,Non-Hispanic 44 2,179 24.97% Total 267,641 987,550 127.10% Source:County of Orange,Analysis of Impediments,2020 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-52 SEPTEMBER 2022 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-53 SEPTEMBER 2022 Figure 17:Distribution of Cost Burdened/Overpayment Households Park Orange,f E CHep—ri Aye Orange e c... .,..,, A— e� 9 n San "an 4osB fmm E�1 rmm 4t1�RIJQ3 Qr� irfli§PYl(13 /\�yf$2$ Cany p .iii � li ul• . 3a O e ee \� �•..�..�� �ivt 4.. City of Tustin City of Tustin Overpayment by Renters Overpayment by Home Owners 20,a6% 40%-6o% 4J o-60% 60% 0 c iy 9oundary \ Q City Boundary 0 05 1 MAss Cit I Irvine,Coun f Loz An Ies R...au of—d N 0 05 1 Mllee Cit f Irvine,Count f Los An les,Bureau of Land aq uln rn Hn 9e A l i l yn yo ge IS Management,lt,Esri,HERE,METI/n,INCREMENT P, Management,Esri,HERE,G.-in,USGS,NGA,EPA. USGS,METI/NASA,EP,USgA USDA,NPS I CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-54 SEPTEMBER 2022 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-55 SEPTEMBER 2022 Figure 18: Distribution of Overcrowded Households • CHINV AliLS _ — Atlirt':Hr"A„, I Norwalk sm�nr"a,k a `^ BEIIIIOW 2r —CIXOna'_"'..' F� 6 IE ES CAL VAL L.LV '.IJ Fs4roa1 �f ) L 1 r1 ih -�F I f Lake I I• li ... II. lV S7 L N, - I.r t u � � SANTA MARGARITA A91Ae MOVNFAINS -. Orange County Overcrowded Households <_8.2(Statewide Average) + <1z <15 c2020 <_70 County Boundary AN 0 3 6 Miles I I I I I City of Irvine,County of Los Angeles, Bureau of Land Management,Esri,HERE, Source:CHHS Data-Tract Garmin,INCREMENT P,USGS,EPA CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-56 SEPTEMBER 2022 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 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. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-57 SEPTEMBER 2022 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-58 SEPTEMBER 2022 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 /°/° CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-59 SEPTEMBER 2022 $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).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. 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.The shelter services a large area including many portions of Orange and San Bernardino Counties. Sheepfold shelter provides shelter (45 beds),food,clothing,job training, and job-referral services primarily to battered women and children.Guests are admitted on a first-come,first-served basis. Additionally,the City supports a temporary housing shelter in the TLSP area,Tustin Temporary Emergency Shelter (TTES), operated by Temporary Shelter Inc. TTES provides 77 beds low-barrier emergency shelter,integrated healthcare,and 24-hour access of OC Behavioral Health staff. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-60 SEPTEMBER 2022 Table 16:Publicly Supported Housing(Tustin) Low Total Census Race by Housing Sites(percent) Race by Census Tract Project Name Type Income Units Units Property Property Property Property Tract Tract Tract Tract Tract White Black Hispanic Asian White Black Hispanic Asian Tustin Section 100 100 29.0 - 12.1 59.0 755.05 41.5 2.8 38.8 9.2 Gardens 8 Anton Legacy LIHTC 161 225 37.9 7.8 33.1 16.9 755.15 27.4 1.1 36 31.7 Apartments Coventry LIHTC 97 240 40.5 5.1 8.6 26.9 755.07 31.1 3.8 45 16.7 Court Hampton Square LIHTC 212 350 12.2 1.5 78.1 1.0 744.07 10.8 1.3 84.1 2.0 Apartments Heritage Place at LIHTC 53 54 38.8 3.0 13.4 25.4 755.15 27.4 1.1 36.0 31.7 Tustin Westchester LIHTC 149 150 13.1 3.4 75.4 7.2 755.13 14.4 3.6 57.9 20.5 Park Source:County of Orange,Analysis of Impediments,2020 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-61 SEPTEMBER 2022 Additional homeless assistance programs have been provided at the TLSP 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 TLSP,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 262-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.For further information,Section II of this Element includes a full discussion of homelessness accommodation within the city. Table 17. Emergency Shelter/Transitional Housing Facilities Facility Services Provided Village of Hope Operates a food service program,dental services,and 262 bed emergency shelter at the Village of Hope,operated by the Orange County Rescue Mission. 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. Tustin Family Campus 90 beds intermediate care shelter for abused children and their parents operated by the Orange County Social Services Agency. St. Cecilia's Distributes food supply to needy populations. Red Hill Lutheran Operates emergency food program where a person can receive food supply. Tustin Presbyterian Collects food supplies and distributes the food to various organizations involved in providing homeless services. Aldersgate Refers interested persons to Ecumenical Services Alliance in Santa Ana. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-62 SEPTEMBER 2022 Salvation Army Six(6) transitional units at Tustin Field I operated by Salvation Army. Acquisition of 16 transitional units in Buena Salvation Army Park operated by Salvation Army. The City assisted in acquisition and contributed grant funds to acquire the units. Families Forward Fourteen(14) transitional units at Columbus Grove operated by Families Forward, formerly Irvine Temporary Housing in Irvine. Families Forward-Rapid Re-Housing Provides rapid-rehousing services including Program individualized support and accountability to homeless parents working to locate housing, improve financial stability,and create a sustainable future for their children. Human Options Six(6) transitional units at Columbus Grove operated by Human Options Orange Coast Interfaith Shelter Six(6) transitional units at Columbus Grove operated by Orange Coast Interfaith Shelter. Tustin Family and Youth Center Distributes food supplies to needy populations. Goodwill of Orange County Provides emergency funding grants to address immediate and critical needs of veterans and their families,focusing on veterans on the verge of homelessness. Mercy House Offers low-thresholds emergency shelter services with case management services. Veterans outpost Operated by the Rescue Mission,the Veterans Outpost offers transitional housing for up to 71 people,along with veteran- specific services. Tustin Temporary Emergency Shelter Operated by Temporary Shelter Inc.,TTES provides 77 beds low-barrier emergency shelter,integrated healthcare,and 24-hour access of OC Behavioral Health staff 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 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-63 SEPTEMBER 2022 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. • 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-64 SEPTEMBER 2022 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 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-65 SEPTEMBER 2022 Table 21:Tustin Loan Application Actions by Race(2019) App. Preapproval Race and Loan approved App. App' File closed for Purchased request Grand Ethnicity originated but not Denied withdrawn incompleteness loan approved Total accepted by applicant but not accepted White 1,255 51 268 276 95 113 1 2,059 Black or African 17 1 7 4 2 2 33 American Asian 625 24 113 154 49 63 2 1,030 American Indian or 11 3 3 2 2 21 Alaska Native Native Hawaiian or 5 1 1 7 Other Pacific Islander 2 or more minority 2 1 1 4 races Race Not 431 27 102 120 54 306 1,040 Available Other 127 1 20 16 6 3 0 173 Hispanic or 256 18 74 67 43 18 476 Latino Source:Federal Financial Institutions Examination Council(FFIEC)Home Mortgage Disclosure Act(I-IMDA)Dataset,2019 Notes:Other includes Free Form Text and Joint applicants CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-66 SEPTEMBER 2022 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 11508 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-67 SEPTEMBER 2022 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 prior to the initial the housing element submittal in June 2021 to HCD;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. Additional public meetings were held on August 17,2021,September 7th and 30th,2021 and October 5,2021. At the August 17,2021 meeting,City Council solicited public input and reviewed and approved the inclusion of additional housing sites,the Tustin Market Place and the Enderle Center that could potentially be developed with residential units. The redistribution of units throughout the City is intended to further facilitate the equitable dispersion of housing units of various income levels. Specifically,the revision reallocates units previously allocated to Tustin Legacy,by redistributing those units to the Tustin Market Place and the Enderle Center. In addition,during this meeting the units were further distributed within Tustin Legacy to additional neighborhoods to ensure that units are dispersed throughout the City. On September 7,2021, City Council solicited public input,and reviewed and approved revisions that further CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-68 SEPTEMBER 2022 facilitate the equitable dispersion of housing units of various income levels throughout the City. Specifically,the revision redistributed 582 units (517 Preservation of At-risk units and 65 ADUs) to the Tustin Market Place and the Enderle Center,as noted above,to further distribute units throughout the City. On September 30,2021,the Airport Land Use Commission held a public hearing and the Board determined that the Housing Element is consistent with the Airport- Environs Land Use Plan for John Wayne Airport(AELUP for JWA). Due to the Covid Pandemic,public gatherings and meetings were not permitted and therefore 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 have continuously been 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. 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-69 SEPTEMBER 2022 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. 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 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. 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$816,755 from HUD under the Community Development Block Grant (CDBG) program for the Program Year 2021-22. 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 2021-2022. The City lists its current projects and provides project status on the City website. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-70 SEPTEMBER 2022 Figure 19:Distribution of Predominantly White and Predominantly Hispanic Population - - Park Orange E Chapman Ave Orange 11 E cnapman Ave ILII i. 'C G Nortl-i l u MUD uP II Stag III ' i l l ttFY;� O 7n,93 4 Egm nag S t,Lr'dQ3 zmmalM W W cks Cany t SEA \� i A� @Y-x8ZM& ?EaE9349 Im Vk1aEffl9 Irvine i�lr,ine sd�0".90 C ea _ saw 049.Crca c City of Tustin City of Tustin White Majority Hispanic Majority 'S1 ("'-111) ©Slim(gap,10%) Siaeaale(gap 10/–50%) Sizeable(gap 10%-50%) ®�I P-cdominant(gap>50%) Predominant(gap>50%) City Boundary \ Q City Boundary 1 e�,y of I—,C...ty of to:Angeley'Buraao of rand N o , aes ary or Irvine,co�nry nt ro:Angeles,anrean of land r} I I ales in Management Eari,HERE,Garmin�USGS,NGS�''RA, A i E N In Management Esri HERE Garmin INCRE��JJENT P USCW,NPS' USGS,METIAASA,EPr, SQA 5C. Note:The population of some areas in the United States I dominated heavily by one racial or ethnic group.These areas stand out on this map.The strength of the color indicates the extent to which one group is dominant over the next most populous. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-71 SEPTEMBER 2022 Additionally,various City housing projects are currently under covenants per AB 987. Table I1- 16 in Section I1 of this Housing Element includes 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 has been extended for a new 20-year period which would mean the contract would expire on July 31, 2041. 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. The City currently enacts Program 3.7,which allows the City to ensure tenants are properly noticed regarding at-risk units and to work with potential purchasers or property owners to provide technical assistance,where feasible,to public and nonprofit agencies interested in purchasing and/or managing units at risk. Additionally,the City has included Program 3.9, which commits the City to registering through HCD so it is aware of any units at-risk of conversion.Program 3.1 requires developers to process a conditional use permit,provide relocation assistance,and/or to provide incentives and assistance for purchase of the units by low-and moderate-income households whenever a project proposes to convert affordable apartments and condominiums. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-72 SEPTEMBER 2022 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. • Hispanic and Black 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. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-73 SEPTEMBER 2022 Figures 20 and 21 detail the designations of vacant and non-vacant land identified to meet the RHNA in the City of Tustin. The sites inventory includes land that is currently zoned as specific plan,medium-and high-density residential,and land that can potentially be designated as high-density residential in the future. 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(see Appendix B). 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 spread throughout various areas of Tustin,with a majority of the units being allocated in tracts 755.05, 755.07, 755.12, 755.13 and 755.15 (TLSP). 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,two underutilized sites with potential for mixed use,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.Although the TLSP area has been identified as low resource,it has been substantially enhanced with new resources within recent years. Improvements include schools,parks, grocery stores and retail services,medical offices,childcare centers, County's Tustin Family campus including transitional homes for abused and neglected children and family,Head Start pre-school, social services,community resources, employment centers,transportation,and a variety of housing.With recent improvements,the TLSP surpasses other areas in the City for livability and well- rounded services for households with various income levels.RHASP and DCCSP are also part of specific plans adopted in 2018 that are anticipated to facilitate development and implementation of new high resource areas.Although the most up-to-date data sources were utilized,recent updates to the specific plan areas may not yet be fully captured and reflected within ratings and data sources utilized to prepare this analysis. 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-74 SEPTEMBER 2022 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 (see Appendix B). 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 TLSP 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. 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, 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 TLSP 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-75 SEPTEMBER 2022 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-76 SEPTEMBER 2022 Figure 20:Location of Sites to Meet RHNA Suitable Sites for Additional Residential Development i ®bddlad�.4ra�� >� ®°mpg .�, �A�rl A p�6 J �j Suitable Site Locations Downtown Commercial Core Specific Plan Red Hill Avenue Specific Plan Tustin Legacy Specific Plan ��1 y Enderle Center Tustin Marketplace Municipal Boundaries N Mile CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-77 SEPTEMBER 2022 Figure 21:Focused Locations of Sites to Meet RHNA IInIT� Enderle Center(Site#19) dC1� 9 9 u0 El10 _� [�❑0 B 1}14 0 �6 a D 15 a L a a Tustin Legacy Specific an Red Hill Avenue 19 ,\ % Specific Plan Tustin Marketplace (Site#20) v 16�lA N N N CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-78 SEPTEMBER 2022 Figure 22: Location of Sites in Opportunity Zones ■N MW 0. a 0 0 IrI 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, I i I Garmin,INCREMENT P,USGS,EPA Source.AFFH Data Viewer CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-79 SEPTEMBER 2022 Table 23. 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 - 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 - CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-80 SEPTEMBER 2022 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 - Block Group 4 74.63 - Source:AFFH Data Viewer 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 percent 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-81 SEPTEMBER 2022 Table 24. Percent 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 (RHASP) 8.80 755.15 (TLSP) 12.00 Source: AFFH Data Viewer 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).Housing units allocated to this area are predominately within tract 755.15 (TLSP). Other areas that were identified as low resource and contain housing sites are part of the DCCSP and RHASP areas(tracts 755.05, 755.12,and 755.13). 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. 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 have been allocated to tracts that 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. Tustin Legacy (Tract 744.15) is a Master Planned Community that is currently being developed.Although the area comprises 1,600 acres,there are 600 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: CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-82 SEPTEMBER 2022 • 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 Head Start preschool 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 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 II(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) Surrounding tracts in TLSP are anticipated follow similar development patterns. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-83 SEPTEMBER 2022 Areas identified as low resource that include housing sites and are part of the DCCSP and RHASP areas (tracts 755.05, 755.12,and 755.13) are similar to TLSP such that the areas have been included as part of a City's specific plan and are identified for future improvements.These areas are mostly vacant and surrounded by existing development, opposed to TLSP,which is largely undeveloped. Specific plans were developed for these areas to expedite the (re)development of the sites and implement the City's vision for these areas as high-resource, successful,mixed-use areas. Table 25. 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 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-84 SEPTEMBER 2022 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. 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 for Hispanic/White and Black/White populations (as defined by Dissimilarity Index values which indicate geographical segregation patterns) • Disproportionate housing problems for the city's Hispanic and Black residents (problems include 1) housing unit lacks complete kitchen facilities;2) housing unit lacks complete plumbing facilities;3) household is overcrowded;and 4) household is cost burdened) • 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. 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 CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-85 SEPTEMBER 2022 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. 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-86 SEPTEMBER 2022 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: 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 (S132) 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. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-87 SEPTEMBER 2022 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 to opportunity outside of high resource areas,and provide education and enforcement to implement State law prohibiting discrimination. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-88 SEPTEMBER 2022 AFFH Fair Contributing Factor Strategies to Address AFFH Issue Supporting Programs Housing Issue Housing Mobility 1. lack of affordable housing opp-t.,ih-for H—mg Mobility Strategiescons of mn,.vv,e barriers to PUBLIC OUTREACH-ENGAGE UGUISTICALLY ISOLATED FET.u,residents h.nsine m aro as of.PP„h,,Av a ndstrategically,,,I—ing Revised Pr 25 2023,tcanslateoffxialG annonnceme is ..con., ,esti. h..m tc.toy h 2. High segregation for Hispanic/WMte and access. �� @)o By Ty n (e unity. g gs,e ) panic Black/White populations(as defined by and disse.,h,ate printed copies of inf.rnutim to ranters,property.wnets,and via social media,m order to expand Dissm,ilmity Index values wMch indicate Opportunity aroas are rated"high”or"l.l'ms.n.e based on knowledge of affordable]rousing options m High Opp.,h-4 Areas. Mcal se h [hems edncati.n employment,ec —i,development,safe and decent Conm�uni ene gent Dew,nent t ge.gap g 'on rogapa ) h.nsing low rates of violent crime,transportation,and other h✓Dbp, opportunities m,lnding mcreafion,food and healthy Action O,dcomes: rant(air,water,safeneighb.A,—d,safety from TheCiLie to inc ease attendance,. tafion,.nde,standin Im siica6 fated msidents,at c.nmmnM vs.n.mntal hazards,social services,md,.ltural imdti.tions). t}, g.a r presen gby gni yis. Ty meting public hearings and City Council meetings.By engaging Hispanic p.p.lafions in the decision-nuldng process, they am better able M advocam for theirneeds and concerns mgardmg affordable h.nsingand access to opportunities.The City will conduct at least one,...,uni y nd—ti...I.meting in areas that lack affordable housing.pp.rtumh-and that—hibit Mgh segmgad..,.n m—.1 W—. QUALITY RENTAL HOUSING INSPECTION PROGRAM New Program 3.11:By 2025 through 2029,establish.—th-family q.aBty rental h.usmg msp-h—progam. Can,—dy D...b—t Department Action Outcomes: GW} goal is t.elevate the q.aBty.f housing in segregated aroas in order t.t.nsf.m,the area int.a desi.ble housing location by a6-6——A,gr..ps and t.protect existing tenants from displa,e.mnt and t.provide.,-.pants the opportunity t.five in suitable housing conditions that aro not characterived with substandard conditions such as lack.f pt—,b-g.r.ve —ding. Theprog ME focus.nin,pr.vingh..singc.nditions m tracts 744.06,744.07,744.09,755.12,755.13,755.14,755.15L—. with hieh seereeatw,index as defined by Dissf.ulmity Index valves luch indican ee.emnh-t seereeatl.n Pathema. sus tracts). The City l6 receive at least.roe m.nthty referral fro.,the Cil}/s Neighborhood Improvement Task I—.(NITF)(NITF mcl.des Code Enf..ement,Polis,Social Service/C.nnty,School District repmsentatives,City staff fora,various Dep.,b—.N)to identify h...h.lds in need.f this tenant protection and mddispla,ement focused progmfocnsed.n m,pr.vthg the quaaty.f single fm ty and—tti fm ity residential dwellings by providmg technical assistance and funds t.repass substandard housing condiIn— The City will c..d.,t at leis[five—tti family quaBty rental housing i—pecfi.ns in the progani s fast year,and will -mase the number.f annual inspections by 2,each year themafter,—ht 2029. New Housing 1. Disparity in fficess t..pportmity between New Hosing Choices and Affordability in Aroas.f ADU/SB 9 ACCELERATOR PROGRAM Choices and the northeast(higher ms.nses),where there Opportunity mems nr..rotlne h—mg sunnly,choices and Revised Program 1.7b:The City will create m ADU/SB 9 accelerator pmga.,and foes in High Opportunity Amus Aff.edabiityin am pmd..unam p.p.latom f WMt. affordability in amas.f Meh.nnortunily and outside.f areas.f w tlri,the northeast r0.n.f the C' hem them are d.niln teL le-fandl deuces in order t.e d Areas of Opp-h ity residents,and southwest(rower ms.nrces).f --t.t d poverty. piti., w pm a y sing y mai xPm the city,where there am pmd..unate h—mg,hrox s.Tlus pr.g,—could include a p—it fee waiver for affordable hosmg-dts,p—it fast tra,kmg(mfer lafions.f Hi dt.P-gam 1.lh),and txhm,.l assistance.Ttds prog—will con,plen,ent mvised Progan,I.l(h)Streandaring and pop. spm,1-ients aPemut Fast T—kthg for new ADU/SB9 devel.pn..t proposals. 2. la,k.f affordable housing opportunities for Hisp.,i,residents Community D...b—t Department Action Outcome: By 2025,the City will adopt a pr.ga.,and n,.fl..t inf.muti.n perlah,mg t.the new accelerator pr.ga.,for ADUs and SB 9 develop—N,specifically t.high opportunity auras. STREAMLINING AND PERMIT FAST TRACIUNG CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERALPLAN D-89 SEPTEMBER 2022 AFFH Fair Contributing Factor Strategies to Address AFFH Issue Supporting Programs Housing Issue Revised Program 1.1(h):By 2075,provide techoi-I assistmhce and pehndt fasttt—k og for new ADU/SB9 development proposals and a mvdnmm of six projects that include housing affordable to lower income hou]colds on ahh annual basis through 2029. Cau,—dy Develoy—t D,m,h ant Action Outcome: City staff will fast track a nhinin vnh of 10 ADU and/or SB 9 developments in high opportunity amas(Census t—E, 756.05,524.19,756.06,and 756.07)on ual W as,which means that inview tinhes will be reduced by 25%compared to year 2022 review timeframes and for all affordable housing projects by assigning a designated"A.—t mg staff liaison'to the project. PUBLIC OUTREACH-DISSEMINATE HOUSING AND ANCILLARY RESOURCE INFORMATION&ENGAGE UGUISTICALLY ISOLOATED New Program 2.5(c):Annually,starting in 2023 through 2029,translate the City Tustin Housing Authority website and factsh-N pmnwting affordable housing opporh.,ih-and ancillary support services,such as transit and cldld care,into Spanish,and dishibute to low resources ares. Cau,—dy Develoy—t D,m,h e d Action Outcomes:lo—the dishibohm of translated materiak to low&sources areas located io the southwest of the City by n.iling out postcards to each household m select census trffits,containing infomhation mW d to housing choices,transit,child care,and education resovmes. Place-Based 1. Disparity in fficess to oppoltooity between Pt—based Strategies to Encourage Conmmunity Conservation HOUSING REHABILITATION TO IMPROVE HOUSING CONDITIONS,INCLUDING OVERCROWDING Strategies to the northeast(higher&sources),where them and Revitalization mvotves approaches that am focused on Neu, iced Pr 3.10: l 202 the Ci will artner with a nom rofit to develo d launch a CDBG funded Encourage am peedondnate populations of White nservine and minmvine assets in amas of lower onnortunily --9 °� By Ju y 4, ty p p pan Community residents,and southwest(lower msoumes)of and concentrated poverty such as targeted investment in HousingRehabilitation-vid m ti facilitate the&pas of dilapidated housing to address lack of plumbing,Mtchen Revitaliavtion the city,where them am peedondnate neighborhood&vitalization,preserving or mhabilitaN gexishng —do,s and&pass to provide mf of overcrowding.Progrnnh participants wail be provided grnnts and/or loans th populations of Hispanic residents affordable housing,00toy—ghdrast-d ee,schools, onduct necessary housing updates. 2. Disproportionate housing problems for the employment,parks,t—T-tatim and other conmiooity The City's goal is to protect existing tenants from displacement and to provide occupants the opportunity to live in so ftable dh`} Elispaoic and Black residents(problems hemties. housing conditions that are not characterized with substandard conditions such as lack of plumbing or overcrowding.The include 1)housing unit Ucks complete program will focus on miproving housing conditions in tracts 744.06,744.07,744.03,755.12,755.13,755.14,755.15(amas kitchen f..hh-;2)housmg unit lacks with 1-h seeceeatwn index as defined by Dissin Amty Index values which indicate Re—ohical--two nattems in omplete plunhbing facilities;3)household is sus true). c ded;and 4)household is cost ren burdAction Outcomes: ened) 3. Disproportionatehousingproblenhsfacedby The program will facilitate four(4)rehabilitation projects to assist with reducing overcrowding per year and another four large fondly hou]holds (4)projects will assist with general haMtabihty&paha,with a total of eight(8)dwellings assisted ehmuaily.Starting in July,2024,the City in partnership with a nonprofit,will conduct targeted outreach thmugb annual ne ilings to the southwest areas of City within low resources amas and populations,about available eehabilitation assistance.Ali program titeratum will be provided in English and Spanish.Progress will be evaluated and&ported annually in the Gh` CDBGArmual Report. Cau,—dy Development Depmtn—t M CREASE HOLISM G SUPPLY FOR LARGE H OU SEH OLDS New Program 3.13:By January 2024,the City will amend the zoningcode to eequire all new nmtti-fmlily projects to provide at least five(5)percent large family units(3+bedrooms)which will prevent overcrowding and further cost burden,by add—mg denund for such whits and increasing the large units into the local housing inventory. Cau,—dy Development D,m,h ant Action Outcomes:Pour(4)large family hits will be generated ehmuaily,and 32 total by 2029. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERALPLAN D-90 SEPTEMBER 2022 AFFH Fair Contributing Factor Strategies to Address AFFH Issue Supporting Programs Housing Issue QUALITY RENTAL HOUSING INSPECTION PROGRAM New Progr 3.11:By 2025,Establish a nmtti-f—ily quality rental housing inspection program. Ca ,m dy Deoebpncnt D,w,h ent Action Outcomes: GWty goal ie to eIe t.the quality of h—mgm segregated areas in order to tmnsf.mc the ams int.a desirable housing location by all-d.—i,goups and to protect e,d tmg tenants from displacement and to provide occupants the opportunity to live in suitable housing conditions tlnt aro not characterised with substandard..di In-such as lack of ptumb-g or.vemr.wdmg. The pr.gam will focus on mip—mg housing conditions m trwN 744.06,744.07,744.08,755.12,755.13,755.14,755.15 lamas with]deh seaeeation index as defined by Di,smitmity Index values which indican e —Phical seeceeatim patterns' sus t—N. The City will receive at least one mm,thty referral from the GWt Neighborhood Improvement Task Force(NHT)(NHT mcludes Code Enf.mement,Police,Social Service/County,School District repmsentatives,City staff form various Dl partments)to identify households in need of this tenant protection and mtidisplacement focused progam;focused on miproving the quality of single fm ty and nmtti fm ity residential dwellings by providing technical assistance and funds to repass substandard housing conditions. The City will conduct at least five nmtti fandly quality ramal housing inspections in the progani s fast year and will emase the number of annual inspections by 2,each year themafter until 2029. TUSTIN LEGACY SPECIFIC PLAN IMPROVEMENT PROGRAM:- N— ROGRAM:New Program 2.8:Tustin legacy(Tract 744.15)is a Master Planned C.nanvnity that i—Ey—Ey being developed. Although the tract has been identified as I.w msoume,it has been substantially enhanced with new resources within --t yThe area comprises 1,500 acres,of which 800 aerasi,for futum development of a diverse housing stock,c. ity m mfies,and ros.umes.By 2029,the City MH c..tL..t,implement projects that ire assets in the Specific Plmi area as proposed by devel.pem and id.,Ehi d fn the Tustin Legacy Backbone Infiast—h—Pygmy whichincmdes: • Brookfield at Tustin Legacy and Levity msid.nfiatpr.je N with develop..t.f.Pe space,park areas,and miry an..d. • T.A i Legacy Linear Park Between Amistrong Avenue and Wamer Avenue Alley Grove C.n mty Plan • Neighborhood D S..th Infrastructure C..traction-Ph—2 • Tustin Ranch Road Pedestrian Bridge • South Hangar Renovation-Phare 1(f.r future reuse.f site) • Armstrong Avenue Pedestrian Bridge • Wamer Avenue Pedestrian Bridge Cau,dy Devebp—t D,w,h ent Action Outcomes: The City MH facilitate development.f infias[mcture,housing,and c.nmmunity m mfies within the USE am Improvements wiH provide increased access t.safe and decent housing,transportation —t—,and a 1—Ithy lent.By 2029,the City mfidpats the Tnstm legacy(Tract 744.15)t,be idenfitwd as a"high msoume"ar cording t.TCAC/HCD Opportunity Map criteria. protecting Existing 1. Disproportionate housing pr bt...for the Pr to tmg E dsfing Residents from Displacement comprises QUALITY RENTAL HOUSING INSPECTION PROGRAM Residents from dWty Hispanic and Black residents(pr.btems strategies tlut t t mmd.,N i f 1. d t en,NPr 3.11: 2025,Fstabfia nm sh tti-fmiil hon Displacement and de 1)housing unit lacks complete llm itv and c. mtmted p.vell and pmserve housing °� �' y qu Ty nentai h. m g inspec program. kitchen fadlifies;2)housing unit lacks choices and aff.rd.bifity. Con ty Devebp,mW D,w,h ent m tete lumbin facifities;3 h.useh.Elis CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERAL PLAN D-91 SEPTEMBER 2022 AFFH Fair Contributing Factor Strategies to Address AFFH Issue Supporting Programs Housing Issue rowded,and 4)household is cost Action Outcomes: burdened)-Specificatty,FET.,.. Gh'/ goat is to e1—t.the q..hty of housing.segregated areas m order I.tra.4—the ama int.a desirable housing househotds wero identified as having 1—d—by ati so.i—......groups and to protect exisfmg tenants from displace.rent and to provide occupants the substanttat overcrowding opportunity to live in suitable housing conditions that aro not characterised with substandard conditions such as lack of 2 C.n.e. dfe Mthiheaded households and I.MI popptulation within Census tract 755.14 plvniling or.vesr.wding. The pr.ga..will focus on m.p—mg housing conditions m tracts 744.06,744.07,744.08,755.12,755.13,755.14,755.15 I—with hien—ho,index as defined by Di,smitmity Index values which indi.ath ee.emphi.al seere¢atim patterns' sus trffits). The City will receive at least one...nthty referral from the Gt}/s Neighborhood Improvement Task Force(NITF)(NITF .etudes Code EA--L Police,Social Service/County,School Dishict repmsentatives,City staff f.rn.various Departn..N)to identify households in need of this tenant protection and mddisplace..ent focused progmny focused on m.pr.vthg the quality of single fanny and nmtti-fmity residential dwellings by providing technical assistance and funds I.repairs substandard housing condiIn— The Gty will conduct at least five nmtti-fmity quality rental housing inspections m the pr.gani s fast year,and will emase the number of ar 1 mqs fins by 2 each year thematter until 2029.Cm LD-CARE RESOURCES New Program 3.12 By D—mber 2022.the Gty will.mate a"Financial Assistance for Gild Care"webpage with inf.rnut-and links to Git&—en H.—S—ty of California(CHS)and the O—g.County Department of Education (OCDE).These progams provide funding to l.w-in.me fmities forcMtdcam services.The City will work with Tustin P—hoof,Kiddie Acade.,y of Tustin,or other local p—hoot pr.ga..s within Census ft-t 755.14 to advertise and promote financial assistance thro.gb pampht.N,e bt.At,and other appli,.bt...Ii.......uty forums(such as Fa..book and N—tD..r). Ecomn,ic D...lopu,nt De..bm—t Dep,h—t Action Outcome:Sing4,pamnt h...h.lds mgvim special consideration and assistance because.f thea Beater needs for daycare,healthcare,and other facilities.A...rdmg I.HCD,fem.4,headed h...h.lds withddldren tend I.have I.—inc es,thus ti.itfng housing availability for this gr..p.The City will assist in providing f,—child,—services t.relieve gen.mt tm g—penses.f ferule-headed households,specifi,.Uy in Census tract 755.14.The Gty will provide rvrces I.relieve general h—g-penses.f fe.,.k headed h...h.lds,specifically.Census tract 755.14. CITY OF TUSTIN DRAFT HOUSING ELEMENT GENERALPLAN D-92 SEPTEMBER 2022 APPENDIX E PUBLIC PARTICIPATION CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 E-1 APPENDIX E PUBLIC PARTICIPATION (COMMUNITY ENGAGEMENT) CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 E-1 £1 - x u 7 y � ,A y 7 e ..r 4� r F P ' I 'N IL 0- E , � r City of 202 7 — 2029 Housing Element Update Community Engagement Plan Tustin d.. 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 Z) 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. —"� -ILr 1 " ro 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. Islet Affordable Housing Advocates Allsift 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 November Jan/ - • September ,, October I May 2021 b ► 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 / Media P• i ;0 *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 ii .,,rrrm�mm�r�r�rrao- City of Tustin 2021 — 2029 Housing Element Update Community Engagement Plan P a g e 9 Appendix B Index of Interested Parties Index of Interested Parties Housing Element Survey Respondents r' O rn O O O O O O N O N O O N N N O O O O N O N 0110 O Q N 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) 0) 01 01 an an an an an an an an an 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 to C C C v v v v v v v v v v v v v v v v v v v v v v (o vn to C 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 L -0 O UCC cO a) M m 'L Ln _ C aJ O dA N In x (0 7 G O G J 4� = to V1 LL C (0 C Z C J M — Z i-� O Z L 47 Q > (o J _ ai co v J z co � co t CC> a) (o a) c c � v4 Co Lt) 4' 4 co c a) C m m m " c>o •L co a t E -a _ E `° O '�o t � 2 o o0 t z Q >> 0 -M w a z m 0 � 2 - � � z 4 Q 'm � 2 o = � 0 Ln 0 Q u � 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 (o co co M O _ L C ; C N O U co aJ N Q --,e � L O � � � � � C�C � p � � 5O •L LO J Q L � Q (O i cr a7 a7 J C = co = °J a7 a7 +J C 'F, — O a) O O m -0 m m aJ M co Co O p Q — CCI W co d' W � Q — � Q U C J V) J �1 0 0 Index of Interested Parties Community Development Block Grant Interested Parties List Min -1 0000 0 0000 qt o 0 0 0 0 0 -11 o ONO 0 0 0-1 o LNn 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 +-+ O t O t co L N tV L mu L m m m U QJ tV tV tV U l6 c l7 E u l7 E E c E m C C c 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 coo mmcco > > > 0 > cco N H U N Q J U' N Q N L L Q f— N J i Q J (n (n f— N L L L J L N O r` O' O O 0 N N N N L O O U j � a � 0 4J m > Ln 4J o to : L 4J >' (p L U > 0' � Y 4J U L Q U 3 L 7 0 L tV L L L N III III III Q L O L O' ° ti4 }' L � L N N L L +-+ v N O U C O' L O C N c .+-+ tV L O L U Ln Y O' N m m Ln rIjW W n- >- r r, m tV T of �c U m W ip L > co c rl Ln se O L > c + +Up - 4J U Ln Ln O v� {A W N U C +' c �' m O . X L L Z .' X X X �o U l6 N N w j C7 w Q Q O w Z w X w E > m O O 000 000 000 W W L tD 00 Lr) W c-I > c-I Ln oo r, Ln O c-I O' ° Z O > Z Z m r, Ln qt 0o0 0O'0 N o0 O Lr)O 00 O O N W O O � O tDD O 0 0 00 O O O O � o N Q N rl N rl Ln r- rl Ln qt rl —i —i rl N D- Ln rl N M 00 M d qt 4 rl N d d d lb rl rl C � 7 � O C U :3 O' O pO U c v > ti4 N o c O O > > U p O U L n c c c U -C O ate-+ � -C ° E 7 0 ° O' tLo ° C QJ L > U U L U U 0 0 N U U o 'o o v O ° ao O a 4) C 0 :3 ° L b4 L C U U O in o L U c o c U U U + 0 °° tLo v ao ° v 00 c •oU' O v c ago ago a°o C -0 > J ° O C C WO tV tiO m 7 O' >, v U O' v L C L -C O O O L O' }+ tV tV U E N L ° l6 CO a L QJ 4J N U W V N L L D C C C N 7 0 = O J N N a > Q = vI Q o ao ao 3 N O O o = o 0 0 o L C > C O' C C O O 7E-j U- _a O O -0 LO Q Q Q O O N i 0) C +�.+ U C +.+ 7 7 O 7 O N 7 7 d L _ _ tV O O O = O' uo N m 0 co -0 -0 -0 z E E E v v o = _ o o E E E .E h0 0 '� > > E E f6 E E > fl L L U L L 0 N N O L L L }' O O c� O O 'i to E to to to to O O E O Q Q Q Q m m U U U U U U C U U U 0 W W W W W W U U U 2 2 2 2 S a-+ O V C N E C Ln UO v C CO 7 -0 UO CO C �n tV tV .� •L O to C N �G Q O Ln O O L C U- n ate-+ to E O _ U t a-+ O C C E L to to i i C Q, N > OJ 4J L L l6 N Q C O L i Y 4J tV 4J 7 4J N +� to to O > L _ C uo tV to U _' C W 4' U Q C 2Ln -0 M L M m M ° C L l6 C N c = o > f 0 v J > o' = E l7 U v Q Q U C -0 U OJ c6 OJ c6 C N O i0 > .c� -0 c6 C 4J (n Q to U L _ U C C L �[ CO L to _ aO �' �0 L to OO (o -0 C OJ C L +.+ O L OJ L' m U v E M ao v ° o ° N v v L C o U L m - 0 Z m �° 2 - 2 vI GD u U z a w l7 vI m U U 9 i2 !2 a 2 2 - U _3 Cf 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) Lf) 00 rl lD rl O O O 0 0 0 0 0 0 0 M O O O O O iD rl � Ln O 00 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 L n3 n3 > U 41 41 (6 00 00 O O N n3 n3 L n3 (6 (6 (6 (6 (6 (6 (6 (6 (6 (6 (6 (6 m O O = C O C C C C C C C C L C C C C C Q v Q Q Q Q Q Q v O Q Q Q Q Q 00 CCO •� m Q Q +-+ C C +-+ +-+ +-+ +-+ +-+ +-+ C 4J +-+ +-+ +-+ +-+ +-+ }' }' � C •+-+ +�-+ � +�-+ b4 +l6-+ 4J n3 n3 C t6 C C C C C C (0 Y C C C C C 3 C C b4 7 D 0 C C n3 C N N N N (6 L > (6 (6 (6 (6 (6 (6 L (6 (6 (6 (6 (6 (64J � � n3 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 Z 2 2 J w 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 v ate-+ 00 Li > +-+ co co 7 N N N v Z 'i +' 7 :3 N Ln +L., v N N (n 7 4J 4J n3 +-+ +-+ +-+ O C +-+ QJ 4J 4J m +-+ > C L C C 4J > O 4J 4J 4J (n 4J Y N O cr > > - Q E N Q Q Q 4J 4J 4J L > QJ - Q > n3 C E C Lf) +-+ +-+ N M O +-+ +-+ +-+ v +-+ N Q v t v p > L > (n N O v Q O +-+ + CL + + O c c L L N N N > (n _ O (o U �c c v ,n t - L Li >, c N N n3 N M n3 n3 +-' 4J O L L L 0 L O Ln }' O C •L C N 0) +-' N U M L t rl rl N N r- a-+ iD = O O t0 •i w C ate-+ +' ~ U w ~ x ri n3 x + Y w (0 L 00 0 p O L L O U Z w �O Z O > > w r-Aw w w w w m O Q O Y w w Z E 0 Q m w O rl Ln N rl m 00 00 O I'D O O O rl rl O m rl O N O qt O Ln Ln v rl rn N 00 O —1 —1 00 N M —1 —1 —1 N m OM . N M 00 O 01 O Ln to Ln r-A I- O� c�-I O m n N rl rl rl rl D_ rl rl rl rl N N N N rl rl rl D_ M N rl rl N 00 rl rl rl rl N Dl M D- M rl C O 7 o }0 E >- U — :3 CL c uo u L C N v UO O O C t U N N 7 f- c C Q >, O U C i 0� U c .> — C C IO L LO •E Q > V O O O Y v `� v °co c v uo c a u U c v U- " E (6 U C v C — O uo Q v m C O L N E O U :� uo '� U }' v 00 v N v i �O — O •C w N 7 7 C - O , M D U C M O v � U v — u U O ' � C p p O = O O O D_ �n 7 - 0 Z 0 —:3 v C C O •L O > U O (o U U v O v U 2 (n 3 E O w c 'n m c i c c O L v v H v v Y E T O T n3 •E E T v Ln `-' +� v U Q LA v u v N ago ago •� o c u c o L� o f 0) a a v N v O LL t n3 n3 +� +� +� U U (o L O E +� E c v m n3 E (n U : L L Q > L V 'n 'n O Q O C v Q -C n3 >' U O v v m c O = 0 0 O ° U - U N caoo o c U 2 D_ Q c 2 � (0 L L t Q c n3 (n (n v v v o U ,_ v — b4 Q Q v +� +� -0 > -0 Q ago 0 o ao o f (o +� c c c c w (n > s c c c ao o n3 n3 v v O O °p U > > > w c7 +� ao p > O O i v v v v L C OO C CL 4J Q C O c uoCJ CC C V CE (3) >. c O L O 4J n3 CL N L 0) CL 3 C (6 QJ N v U O m c � � j `J° u c t j 0) cEo N cLo v v �_ o o v °; ° E C U > 0 C N > C Y 7 n3 (0 � n3 = O = (0 C (0 U O t (6 (6 (0 (0 4J O p >� 4J p p D t0 M w 0 � M Q 0 Q Z 0 U U C J J w D_ 00 J > 0 m J J N m \ 0 0 o m / o 0 / / / / / / / / @ \ \ \ \ \ \ \ \ 9 \ \ K \ \ { _ { \ \ . < 0 < ® E ± » \ a \ / x \ } e % u 7 7 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 \\ _ g / @ \ \ E \ \ 2 > a > z \ < / \ / \ \ ƒ / \ \ Index of Interested Parties Outside Agencies and Developers List `o a E O v o O E v o v a a a v 9 w E ° o `o p E E „ `O a O E ° a v u p °' u O Q o a 9 E 3 w o `o < _ - 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 m N 0o m v o .. �+ m o � m 5 m' " u `° " 5 g a 5 5 5 H V V ru QmQ m m j mQ Y mQ m o o m " m m Q m m �' V �Q' '� a a VV 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, \ .v a a - a a a v a v a a s m a > r a a a a a L " v v v cc ° ° ° c c c c c ° ° c c ° c 3 "' c c c c c U ¢ V H H H .n .n �° - V H .n .n H .n l7 vi l7 vi - `J° H vi H O vi - 2 H LL H V O O V 0 v o0 0 0 o � Q > vi ai > ai am m a> y r w2w> 6;1 a > m° N a a' oo o .r". r ° -o oLvo a r� y r o N v c n m o `°° 3 "' o y°o ° n --vo o -°°� '° o w o ,°, " 3 > n, E x N > m = v E E O t7 tD r o 1O o t7 ¢ �° .n .�Y. m 3 v 1O -° O Z 3 Z z m �° u 3 Z m° 3 0 ^ o m° o vi `-' z Z m° a 3 m a w m Y 0 p o m "' "' " n W m o o "' m o o o .~1O. T > V O c Q o C 00 U v=Oi i ol V o u o r o o °_ V v o v ° � 071 — ,� o r o o v m r m v v v Y o - O o0 o O " O V N uo >. o m o > w V v - c 0 O c m o Y o v " 3 oa " '" o v LL v c w o u c I 2 a o = a V o .L V ,� u c v o m v i m - o u E o o = o mo", 3 0 07! I oo �o x w o v � = o z i u r v o > L V ",� m 2 2 c o m Y c > a`' v v V V c ._ o J 2 .n °_ '" - V m ¢ 071 "kn Q E _ -° o v E - V. v = v m n v V O v v a c m LL x U E ., v c v >' c r 2 °- 4 0 V V o v �' v L a s O a v av o a s c v E a a v r`a o o L o a v �°z u v °1 c° tQ.i _ _ - E :a -o Y m v ._ u '^ E m E - c° > a° a v "v v v c > ro v E o c rco V � v E o0 o v - ro v E v V E > >J _ °' w v o > D O a H �i a tw 0 0 H D J 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 E N ° ° m v o E c v J ° v F- V l7 v m N v ° r a > E v U r V V v _ j '° _ ° _ > v "' o ami z m - v o v _ > m v v v v ^ v 3 n, v rca .` ami - E > c l7 c Ov w o° m° = a g o a x° v tD 2 �i 3 w o ° o w `o a o 0 0 0 E a o o a -E o a o a 0 3 0 o v E o E ° - a 0 0 o v o v 9 ° t u 0 - u " E o ° L o E v o ° E 9 E o - E o 0 o c v2 `0 v w w E E 0 r r m o 00 0 0 � m r m m 1O m m g ° 5um � uQmggg � � � g � � � g � g � � gg � g tg = umVv v mmmQ _ mmm m mm °1 mm tg mm °� o v Q y aci aci VGaci aci ac V4 Vo V V V LL - a rmvoo o ` = v � o L .L � = .L .� .L0 .L ^= .L .L = = � L .L = � oo a _ a ^ Z, V _ _ _ _ _ a _ _ 0 m a 0 0v o 0 Y 0 0 Y o N N o V v z a o v v i v ai > ai -° v D ai v ai v >a > a a L > V a N v v $ Y 3 a m > v L o v >' W. m = Q ar g Q m a 3 v 3 r t r > Uj > v o0 `E l7 m l7 w D _ �n ry w Y in rLa - z m N = z Y n ? o E o V w0 V y z° o �' 3 a a LLi ° o >° ° `° o m .`n. '^ o o x m o .. o o- E V T T E> V v .. UI O u 0 1 O V ,;.j J m `0 0 ° o v Q v ov°o m ° o m v v v °' v - oo - o u = T o ° o - ° O o c Y ra ao L uu3oo p " Vlu l7 �l . O E L ., oo a o V -c ar ? L ° L o -o V N O EO vo J vOi N m . m vi 2 .n �o .n m O O 2 m. N O o m J a, m - y, c T - E T> oo E > ° o f ,� E > V '^ T `0 }>, v v '" o ° o c ai ° oo a o o ° t., '" 2 V 2 ° t°.i `° 0 3 >, o 0 0 ° ° °boo v ° = zoo o v u > m > G > -° m o0 o E ° v u V J o'o - °' ar °' ar o O o- ,Q V x V o V c '. o - ate v c c V O 2 00 .n - V J 2 ° c° V r>'o -° O 3 V - .N V o �_ .n v 'L v v c o v = - O Y ° E v y 2 ° v ¢ c v Y -° v -° ar ° x v v E t a ar E V v v = '^ S o o v v V v ° r°o`v e v v o a `o a E E E l7 ° E ° ' �o0 2 � r°a o v � � D N � � ? E ° E o x x J u z" 3 0`� c� a m a o` a 2° = w o Y a Y o` o o` a 3 a a u u b w w w v m V it 0 O D D 0 x a > v > v v v a v v v v w w V vOi w a w a o O Oo 9 E v o O O O Y N o V r v o ° 2i o- oo L -0 2 > v N o w = c r°a LL o v 2 rho L ro o ° o LD ¢ u a ov w v w v m �j N c o 0 v m m 0 v ° o Y a -° T 2' a n, ar 12 L °' m - m -oo u m° m o 2 m Y z 2 V w w w m a �n l7 l7 2 a l7 vi E O v v v > a 0 3 � a r Y 0 0 0 ov m m u00i v N v o1Oo T �n m r r oo O A r r m r oo m o ° w m m ° o QQ � Oi Oi W N Oi Oi Oi Oi Oi W Oi Oi Oi Oi O Q�Q Q�Q W W U Oi W W Oi Oi W Oi > Q Ol Ol 0O N Q Q Q Q Q u U U g55 � VVVVV � gSVVV N � � � g � � ggNOg VV16 16 16 0I a s g a a a a a v LL a a a a `0 00 v 5 u a v a s o v a - x v ai m Q ._ m ai m ai m w c c Y .L c c c c c Y c c c c v c o o .L .� .n .n .n .n .n .n O .n .n .n .n Z 2 V - H H 2i .n H O V .n .n - O .n V 0 0 m 0o v o 0 v UI UI Y Y O ^ V UI N N UI Bw m v Z ai = O v �^ mm - c Q m Q Q > m° v v v '^ v > a } > v > 3 Q v o d a Q Q 3 ,� ° ° L m m a - - o. r > o c c - o r r r r Q ° 3 o L D a n m m v E E N $ W° W° 3 m o v o o - v 7 0 3 v u v m v .^Yi ,� ~ v v v v - `^ y m v O` V v `0 u -m 3 3 w o o z o 0 3 3 w Y "' w w w m a ° �° E o z z .n u u 3 ° v o O N O m m o w w m m m 0 o N O o m p o 0o m o �j o m N o v'^i o o v 0o m m m m m n n o m m o m o o m in in in in v - � v v ° > V � N H 3 u V c O F O > - c O O u O V L ip =O =O -O N 'a N 0 J C m N N V m V - E -O V o o O >' >' w- o 0o m V E =O v >. o o y0 y0 N oD N mw Tm vi o mo o m m O 0 w u x 3 0 Y o v V V v - v v o ° o m x N `° u '" �. v v Y v '" o u o v ° c - m v w o Y O O o o N ra o >. '^ v E - v `0 v ro `° m v o V o n c 0 d - m = 0 0 - O ° v v v a v `�°, u u `0 a ¢ V V V o o a .Q = u V = ° a Q a - O v o 0 0 0 E E o o v O O .� �.i > > > °u > v °1 .� n c .n > > Y w x W l7 l7 l7 = z z 0 0 0 0 0 0 a vvi O vvi H H > > u x .n o D D o D o > O x - ¢ O `o v 0 o n o v o p v v " o c c ° 'o 4 Y n ra _ O > oo=o Vin o m v w v E u u v m m v v v v > a > v = o v v V Y Y } m Q D Q z 0 V V m d D W Y Y W V1 V1 Index of Interested Parties Adjacent Jurisdictions, Utilities, and College Districts List E L O w- U U m v 'C m m O O E m C C m "O U m m ?m p m �n L T ?� C J ZY V0 1 (D O` 3 m OU O 4 } Y T m J m m m O `I C m m 0 m m m C J _T 3 to r m O m U +@' o L ` U L m M "O m U Q Y U Y V1 Q Q V1 0 F- 0 O E v 0O L O mp U E U 0 0 O O j j c m O U m -Jp 3 O O m0 j O U m O .� p o o m u L u °1 = O o c m o 0 0 Y u o o f r o E u o 3 u u m $ O E o _ c U 3 `o $ � J a ^' o 3 Lu o- u O p o E O-Om _pm mLo = 3 E OE Oor v _ OJ OEW E Q u U Y m m U 00 00 N a U m Y O bmp N ON 0 O 0)m O N N Q Q< O M U 0) N C p 00) O pNO U UE O) M mm 00 O O O1U m 00 O m 0) Um O O vo -.0 o •--I l0 00 00 U ^ r C O C C O N p0 Q I� E l0 V V O N N N Q O 0 m 12 Q Q O C Q N Qm UN Ol Mr 0 N N m O U Q V1 U 0 N0 U Om 0 0) p 000 Cm m p x U w N Opj N 00 = I- NN U m O C C N V1 V 12 O j 0) m m V1 bA UC C "O m Ol Ol Ol C C N M m N O p X C m ` U bmp C U N N N m "O 3 `""� m V1 > m m O J C C C O M -p ~ > 3 L u c > O m m m m m0 2 C N "00 m M O N C t6 N O! Q m C N m Q C C C > p o N pj, m JO m N '� �O. J m m J O v in Jc u v m v r v m tit� o U v v �n > 00 "' o Q m L r M L .. m 0) O O O-C t m O` C .ti U C C L C C D Q O V1 3 N a Q U x J (� x L .--I V V O m J m m m m v m m = x }' m '0•cc@ . o D 0 , m mo v , O OO r N Ou' o O O0) MO O O O 00 M m O O m z m .-I 00 C m O > p C L m _U Y m m a m m x m K m Y m _� Q C O . 0 Yi E - E C E 0 O m O .n 0 C D_ C p �! p_ O C C � " p O O t O = , Y p U O p u y T m io p u C7 C7m u. Q o J m O p !a m m 0 p m m U u c N o 'c a x p 0 U T L C C C m v u f6 m o 'C i UO m U U O 0 o c 0 _c o 0 o m a m E c c " v U w m w u u u C C O u U O m c v O E 0 c O O O O - C v H C C C E E E m p -p 0 E U in m E U _m - O U O O u. m 00n Q D m m m O V1 Y o m m 0 0 K N O C d c y m Y Y m m c Y m m L L L O O O C L C U U m r U m Q O C C C C y 0 t O C o` QrU cC m '1 xi' oJ m a w 0 ° ° Y Y y ° a o o Ou uu u u 0 o Index of Interested Parties Orange County Housing Developers List 0 O E � o $ v E v o o ° wUm y EU ra N E E O o COEoo =OO oOC ; }°+ EE p . ° o Oo mo >v ao O E Li v v io c c .o Y° v v 3 c w m 0 v Y o $ v o 3 Q '> � v v = c m c °1 E `- m E ._ E2 E o o E m o a 0 0 D o v o 3 o f o o c W c c c c w w v c c c c o 3 m m to o ll/ , O N .--I O oo 0�0 O m r r 2 - m V . � m W o loo loo N o o o N o o oo T to to M ^ M LD LD `""� T Ol N T T V V N N ry N l0 V N N oo N a ^ 1p N N to op D7 D7 r m m of U M M of of 'C o- to to V N U U op oo N O D U r a `� U v O O D U ° of of m N m m m l6 m I� D7 w N fa .y L L .--I m •--I Q .--I Q L L .--I U o L f6 L L f6 D7 N to U U LD N LD U to U U U to to U N LD LD Q U U U Q C of C N N m N o� N NN m N N m m N N U N N o. m m o. Q o) f6 o) v m m o' v o) m c o) o) t m m m U o o a aUa ma U o o U v U U m o o U = U o w U v o o J a v v 5 3 3 5 m 5 o > a 3 3 > _o 3 c > > m 3 3 o > m '> v v > o o v v > v p v v v p m > c oo o o N o OO N O O o O O! O! O O o O .-I V1 o j O O O V1 V1 M o O N M O M O j w N N O al al as N `� v1 NO C c > ` N M r > > o OO N aj ? OI V1 N > N > T o d ^ > o o = v Omo 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 Q u > 3 u v a t U v o21 ,a o v U U v o oo ai t m u a t c a m 6 > > o 3 v o o a m in m m _o m a` a `° ` a aD a m 3 m H m m �n 3 3 �° ° 12 > o ai -m -° Q m O U vyi c .� Z o o a ,� o Z Z .� .� v oo m m U O o a Z m v m o rn m o o .� .� o o .� m •@ .� o. o �n �n �n o a m o o N v a �n o �n n o o m o o n o n c V1 to V/ of N to N O V1 to V/ I� of V/ of .-I O O to O O L .-I V ll1 .-I I� .--I M N .--I V LD .--I N ll/ oo ll/ oo ll1 M N V V f6 C _O = N m E C � � m OI C = L J N U � Y C N O E i2 C ° Y O D Em °- c x t! o u N C U xas C O N u U a U C � C C ob N C O! u w 'O u u > oa' o i o 12 .m v E E E = E E v = E o E 7 'o o c u o >• o o u v t m ° E v x x E v a o o c d x > a = a as c x O U - u 2 m ° c a° m o tt o n x° E -o Z v m E o v ' v o S z c > = 0 N c v v12 v u c E U u �' r r r u m vti m r �° r a m O m u ¢ ,° > Index of Interested Parties Tustin Home Owners Association/Property Management Companies List c n! C m J T 01 m T c = E w m v c w m a c m E c v m c 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 = 0 T m° = t O E T E m c w O m a v N t m N N Y } E T U N U L m 0 _m N >' c C N m r 01 t bD C m ° m J J O LL N t m N m m m a m m 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 = U a m = a m = a a m m c Q o W .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 m Q C nj nj o > > r v m o > > > °3° o v v v v v m v c v v c o Z- :. � c c s T- :. :. O � 3 :, c c a r U m n ° u E c E v m ° m > c a v o v > c v E w m m c m c m °p v E E T o m v c v aci ' c v c c E m " c `c w E m J m o' a m E a E m V c w v v m m u o T c v m m E > a m m °' `° c m o a v m a w c m v 3 m c E m C u c w c " ft � v u o a a m c m v : 'u O c v — v ¢ m v m ° E c E a° O v a 3 E E p m n a O m o v E > Y m y m y aci m m o. f6 m m \ a a p O _ c c u E v O o o >' `.' v r°pa >' m_0 Q- T U T U d m , m U U T.m O "p Q T C Q m m u U bvU O! C N m U O c c o m v u c � aci c at O c m m e u cm m e 01 cc = �' v O C Q 2 o „ c c S ° a° a m c > ° -p E w o a ° o c ovn a m E m c ° o .m > o o T a Q T O c is m NE u) u 2 u p_Y c m '^ in 'm w tuna m v u N Q a m p, mo->m u p O u 3 v uYO a o a a E m > o LL a o � a m a 0. m u a ' -` o ° a T T m v E u a m vo a o r O T a� v "' .c p C7 u v O p 0 u J m a t u >J .�Q 0 0 0 0 = = o O O . E m O E U Q u m v u O u v f6 u u m E u 0 o u " 'c O w u E ' v ` v m �' a o a u_°, ¢ v 0 3 QO p 'c o ° O E E " o 'u is a o v Q c O m E 0 E m c o m 0 0 ° v " x0 m O o x w O p E x o E v u ° QO Q °'z m Q Q c O E O E a c E x p "O Q m O Q x 6 u r N E u EO � U 0 c x O m O m x E o " x U v > U` i u ., u O = O -p in m 'O > E U m v U Q a Q u m O m - 0 Y v1 m x a x x O — c O O O m O >, >, m , Y a \ a > = N m U r Q c c p Q > > - -°p c m x a°n m N O m Y O U u U � p_= O 'u u O V N O u u f0 0 3 m m o - o E m > U ,� o v .� m c Y 3 c c 3 3 v m N o f6o v v v '^ v v v F- E = v a m 3 v E E v c m c m o v m m p E p 3 > r v a a m s o m x v m m m > > °i ° +m' 2 m N o _ u v m c m c c c E p v ' E E E O a m m ° m o 0 0 E c ° v O m m m m m m o 0 o v c v o 0 Q Q Q a` Q m m m m m` m` m U U U U w w w w C7 (D C7 - -a � � r a a a a a a a c � C o a o N 3 a o m o E c t E m ° T O` -6 °U T ° L C U 6 t ° 01 c N L - ° E m° E n m r o = i r r m o v o v `c c m o v �_ o c m v m v v u = T � "O T w C m C in >, m C �, U U m c c c t6 m 3 J Vm1 I m m t6 t6 T m c t6 C 0`0 Y U 0`0 T c 01 v t t m C N O C != N m O t C O N [2 .S O m m J "O O N C O m ro m N t 5 00 m m m D m m Z V1 m X m U 0 Y Y Q D U Q m m m O r Y V1 Y V1 I m m N N N p N M M M 00 0) Nu U Nm L Um l0 l0 m m U rOQl Q ^Ol m l0 U l0 Q ^ �ly0 rQ m ^ pl0 QN Q ^w 0) Q O O O O V m Q m 0-m r M mmM m M M mN 00 l0 00 O 0 rnm M m M M M M 0) 0) 0) 0) 0) 0) 0) l0 m - m U -M " -M v U u U a 0) 0)a a Q Q a a v U a a a = a c 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 = a a U t a Y oa Y N O! Y c c N w w a c t w t6 C m N c b0 O! C N C O! t6 C N t6 C N .°- t6 t t6 c O! C O! C 01 j N j > > > > J6 O > > > N m C > t6 J m > m 12 > J > m> m J > m J > m c m O > J > Q z r z r r r U - z Q �n r a O r r r F- CL a E U E c c m w m v c - v o v c ar p wo v c E c E v 'w' m� E c m 01 E v ° a gEOw� Eo >. EE y(D °m° v o m o al w c v c �n m U c m c 01 E T -W, v, c ° Q a .� o m e a T ¢ a m 01 > E m c E aT C >, O. O) t6 W om0 N c m m C C E E T m m O >,Vm1 O ° \ U T m N N C C N 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 2 m v 0` a E c v m � a T m v !� ° m c T a o m � � .m p c m - a a o= o` � � a u -u O w 'u v m a >, r O O O 4 m m ai c 'U o Q Q` 2 m a T E N Q o ° U - W O a ° a s m an d 'U 01 2 c >, 0J m N p u m a E u E � ova c '.' m o oo>. O 2 a 3 c o m ,m m m p u - p� m m` > ¢ '^ 0 > E ' w �' T p_ °" a > c Q O r°pa a C v Q a C 0v0° a E o o uo 4 uO = O. m > mo Y c ° ° E .m O w A o 2 a c 4 m u. ar > ¢ T v E m c O m u v E m o 0 'EEu O �-a O a a 0 j O "wm6 �_ O u m > .m Cuoc -O 'u a O O! U Q° C �, 2 = v j \ E U E O� C O U 3 Off" t6 Y O U N t6 Y Y Y-u U Y - b0 0 c U 2 O a Y Q OO u T'E cc m C E a .Q N u "00 N a "00 O a O 3 ` 'UO \U Q m0 N j > > u Q Ja K 2 "m0` E to v 00 c O ua O � E E E v0 E o v o > w ¢ u a E a= E ° c o x ° a r p = ut = -0 - vm ° o E o c u m c m 3 c c E > O = 3 m o o o o a ° - a c o > 3 v v u O a m o E u v = m - 0 0 0 w v o-¢ - O Q O - u u - O a O c m m m U U O — U Q U T O Q m C O U E O - = Y C 01 ° > U L L L L N v S O p m ° m m v ° N = u O O Q m O Y C7 C7 'm c O `I O E C "O "O "O pr-�a r-�a m u u 'm`� m �n �n > O 'u N u S O U V v v > S u O O o OI 2 o m 0 0 0 o m m °p ° ° m ° = 3 3 > o o m m ° a a U U LL LL C7 C7 C7 a a m m m m r > > > c m m = u u u u o = v v `� E E - _ '^ c c c c c c c c c c c c c c c c c c c c c c m > > O t6 t6 t6 t6 t6 t6 t6 t6 t6 N N N L L T T S v v J J J J J J J J J J J J J J J J J J J J J m O! O! 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 OI L O bmU CO E N U m > O m x > N ._ 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 O! O! t6 C C C C C C by Y C +' a+ 'a+ 'a+ 'a+ 'Z- 3 3 +> > N N C 2 E N T by � m C C O U 3 c v c c o x v m E E E E Y OO" N N N N N a U = on un E a > O c cm m r°Ao v on a 2 Q ��� � m 0 U O N " —E " O .p U O t m v N v N C u u 0 0 0 0 0 .? c 0 o \a` a aa c F EN u a u U 0 0 m ',- O, N p a QO v p ., u v 3 x c_ _ v c 0 '— o u m E � a v u 6 _ x x o a o t v C7 H -o O v m c E c r°no c Z c f0 O Ul j j t > > � � � U x H H in H APPENDIX F REFERENCES CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 F-1 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). 5. Tustin Legacy Specific Plan,Adopted February 2003,Amendments through November 2014. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 F-2 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. 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. CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 F-3 26. California Department of Housing and Community Development, Affirmatively Furthering Fair Housing in California 27. 2020 Orange County Analysis of Impediments 28. Multihousing News,2019.Jamboree to Break Ground on Largest Veterans Housing Community in Orange County, CA.Accessed on July 12,2022. https://www.multihousingnews.com 29. Orange County Register,2020. Fountain project Fountain Valley helps start 50-unit affordable apartment project. Accessed on July 12,2022. htts://www.ocregister.com/ 30. Jamboree Housing Corps.,n.a.Multigenerational Workforce Community Garden Grove Church partnership creates family, senior housing, services. Accessed on July 12,2022.https://www.jamboreehousing.com/ CITY OF TUSTIN HOUSING ELEMENT GENERAL PLAN SEPTEMBER 2022 F-4