HomeMy WebLinkAbout08 GENERAL PLAN AMENDMENT 2022-0002, 2021-2029 (SIXTH CYCLE) HOUSING ELEMENT UPDATEDocuSign Envelope ID: 5C373DDE-C7CC-4C88-991A-CEEBBBFD10B1
MEETING DATE
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SUBJECT:
SUMMARY:
Agenda Item
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AGENDA REPORT Reviewed:
City Manager
Finance Director
OCTOBER 4, 2022
MATTHEW S. WEST, CITY MANAGER
JUSTINA L. WILLKOM, COMMUNITY DEVELOPMENT DIRECTOR
GENERAL PLAN AMENDMENT (GPA) 2022-0002,
2021-2029 (SIXTH CYCLE) HOUSING ELEMENT UPDATE
On October 5, 2021, the City Council adopted Resolution No. 21-86, certifying the
Negative Declaration for GPA 2021-0002 and Resolution No. 21-87, approving GPA
2021-0002, updating the City's Housing Element of the General Plan. GPA 2022-0002 is
an update to the adopted Housing Element (GPA 2021-0002) in response to the State
Department of Housing and Community Development (HCD) review to comply with State
Housing Element law. Per AB 215, updates have been posted for public review and can
be accessed online at www.tustinca.org/HousingElement.
The Planning Commission, at its September 13, 2022 meeting, recommended approval
of the Housing Element Update to the City Council for consideration during its October 4,
2022 meeting. City staff will subsequently transmit the revised adopted Housing Element
to HCD by October 15, 2022.
RECOMMENDATION:
That the City Council Adopt Resolution No. 22-47, approving GPA 2022-0002, updating
the Housing Element to comply with State Housing Element law.
FISCAL IMPACT:
The Housing Element Update is a City -initiated project. There are no direct fiscal impacts
anticipated as a result of adopting the Housing Element Update. However, the
implementation of the policies and programs within the Housing Element may result in
fiscal impacts to the City which will be addressed at projects or programs implementation.
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CORRELATION TO THE STRATEGIC PLAN:
The proposal supports the implementation of Goal A within the City's Strategic for
Economic and Neighborhood Development: Enable business opportunities and job
development and to enhance the vibrancy and quality of life in all neighborhoods and
areas of the community.
APPROVAL AUTHORITY:
Government Code Sections 65353 through 65355 require:
• The Planning Commission to hold at least one (1) public hearing before approving
a recommendation on the amendment to the General Plan.
• The Planning Commission to make a written recommendation on the amendment
to the General Plan. A recommendation for approval shall be made by affirmative
vote of not less than a majority of the total membership of the Commission. The
Planning Commission shall send its recommendation to the legislative body (the
City Council).
• The City Council to hold at least one (1) public hearing prior to amending a General
Plan.
BACKGROUND:
The following provides a general timeline describing the City's efforts to meet the statutory
Housing Element deadline and to address HCD's review comments over the past thirteen
(13) months.
• Initial Housing Element Submittal to HCD
o July 1, 2021 — Submitted draft Housing Element Update to HCD.
o August 12, 2021 - HCD staff and City met to discuss potential HCD
Findings.
o August 27, 2021 - HCD finding letter received.
o August - September 2021 — Staff revised Housing Element in response to
HCD Findings.
• September 14, 2021 — Planning Commission recommended adoption of Housing
Element.
• September 30, 2021 — Airport Land Use Commission finds the Housing Element
consistent with Airport Environs Land Use Plan for John Wayne Airport.
• October 5, 2021 — the City Council adopted the 2021-2029 Housing Element.
• 1St resubmittal to HCD
o October 14, 2021 — Resubmitted adopted Housing Element Update to HCD.
o January 12, 2022 — HCD finding letter received.
• 2nd resubmittal to HCD
o March 22, 2022 - Resubmitted revised Housing Element to HCD.
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o May 9, 2022 — HCD staff and the City met to discuss potential HCD
Findings.
o May 18, 2022 — HCD findings letter received.
• 3rd resubmittal to HCD
o July 21, 2022 — Resubmitted revised Housing Element to HCD.
o August 25, 2022 — HCD staff and the City met to discuss the City's submittal.
o September 1, 2022 — HCD staff and the City met for follow-up edits and
HCD provided the City with a verbal approval of the revised Housing
Element.
o September 12, 2022 — HCD approves revised Housing Element
determining that the draft element, incorporating revisions submitted, meets
the statutory requirements of State Housing Element Law described in
HCD's May 18, 2022 review.
• September 12, 2022 — HCD determined Tustin's revised Housing Element
compliant with statutory Housing Element law contingent upon re -adoption.
• September 13, 2022 — The Tustin Planning Commission recommends approval
of the Housing Element Update to the City Council.
A detailed timeline and links to the documents referenced in this timeline can be accessed
at www.tustinca.org/HousingElement.
DISCUSSION:
Proposed General Plan Amendment (GPA) 2022-0002
The City of Tustin has prepared the 2021-2029 Housing Element of the General Plan in
accordance with Government Code Section 65580 et seq. The City is required by State
law to periodically update its Housing Element, a mandatory component of the City's
General Plan. The proposed update to the Housing Element covers the Sixth Cycle
planning period from October 15, 2021, to October 15, 2029. The Housing Element is
the City's housing policy and planning document that identifies housing needs and
constraint, sets forth goals, policies and programs that address the future housing needs
for all income levels over an eight-year planning period that coincides with a Regional
Housing Needs Allocation (RHNA).
HCD Review
Since the October 5, 2021, approval date of the Housing Element by the City Council,
several revisions have been made to the Housing Element to address additional HCD
findings (Attachment A — HCD January and May 2022 letters). The City's revisions to
address the findings are summarized in Attachment B — Responses to Comments dated
March, July, and September 2022. The following recaps the nature of the revisions:
Affirmatively Furthering Fair New programs were added to specifically
Housing (AFFH) address contributing factors and strategies
identified by the AFFH analysis. Programs were
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City Council Report
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Adoption of 2021-2029 Housing Element
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The Draft Housing Element (Attachment C) incorporates revisions requested during the
August 25 and September 1, 2022 meetings with HCD staff. At the September 1, 2022
meeting, HCD staff has provided a verbal approval and staff subsequently received a
letter of approval from HCD on September 12, 2022 (Attachment D).
Public Outreach
AB 215 (2021) requires local governments to make the first draft of their Housing Element
update available for public comment for at least 30 days. Further, if any comments are
received, a local government must take at least ten (10) additional business days to
consider and incorporate public comments into the draft revision before submitting to
HCD.
For subsequent revisions, cities are required to post the draft revision on the local
government's website and to email a link to all individuals and organizations that have
previously requested notices relating to the local government's Housing Element at least
seven (7) days before submitting the draft revision to HCD. The City is in compliance
with AB 215. 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.
revised to include metrics and milestones that
could be measured towards progress.
• Village of Hope was removed from RHNA
because the units did not fit the Census
Sites Inventory
definition of "unit".
• Realistic Capacity analysis expanded to
describe how RHNA densities were reached,
and example projects provided.
• Land use control, fees and exactions, permitting
Governmental Constraints
and processing procedures, design review
processing procedures, and reasonable
accommodations analyses sections expanded.
Non-governmental constraints
• Length of time to process a project addressed.
Programs
• Amend and add various programs to address
HCD findings.
• Expanded analysis added regarding
Special Housing Needs
demographics of persons with disabilities and
amended Reasonable Accommodation
program.
• New analysis added; cost of preservation and
At -risk Units
replacement tables added; entities with the
capacity to oversee preservation were added
and also potential funding sources.
The Draft Housing Element (Attachment C) incorporates revisions requested during the
August 25 and September 1, 2022 meetings with HCD staff. At the September 1, 2022
meeting, HCD staff has provided a verbal approval and staff subsequently received a
letter of approval from HCD on September 12, 2022 (Attachment D).
Public Outreach
AB 215 (2021) requires local governments to make the first draft of their Housing Element
update available for public comment for at least 30 days. Further, if any comments are
received, a local government must take at least ten (10) additional business days to
consider and incorporate public comments into the draft revision before submitting to
HCD.
For subsequent revisions, cities are required to post the draft revision on the local
government's website and to email a link to all individuals and organizations that have
previously requested notices relating to the local government's Housing Element at least
seven (7) days before submitting the draft revision to HCD. The City is in compliance
with AB 215. 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.
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City Council Report
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Adoption of 2021-2029 Housing Element
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The City also carried out a comprehensive community outreach plan during the
preparation of the Housing Element including the following:
• Public Meetings - Multiple public workshops and public hearings held, providing
opportunities for community and public participation and input, including with
residents, stakeholders, Planning Commission and City Council, and options for virtual
community participation;
• Online Community Survey - Two (2) separate releases of an online community
survey in English and Spanish provided to gather public feedback related to local
housing needs;
• Mailings - Direct mailing and email notifications delivered to Tustin residents,
businesses, apartment owners, service providers, and other agencies in English and
Spanish;
• Stakeholders - Individual stakeholder meetings held with multiple organizations as
part of the consultation process;
• Website - Creation of a focused webpage on the City's website dedicated to the
Housing Element Update which was routinely maintained and updated with pertinent
information;
• Social Media and Multi -Media News Releases - Specific information, provisions and
updates advertised in English and Spanish through the City's website, social media
posts, paid advertising via social media and in newspaper and magazine publications,
press releases, video features, flyers, postcards, and posters; and
• On-going public input - Opportunities for review and comment of the Draft Housing
Element update using all the community outreach methods and media listed above.
Planning Commission Action and
Public Input at September 13, 2022 Planning Commission Hearing
On September 13, 2022, the Planning Commission adopted Resolution No. 4457 and
recommended that the City Council approve General Plan Amendment 2022-0002 updating
the Housing Element (Attachment E). During the public hearing one (1) person spoke
citing the benefits of local hire and skilled workforce and requested the City to consider
the inclusion of skilled and trained workforce policies and requirements to benefit the local
area economically and mitigate greenhouse gas, air quality and transportation impacts
within the Housing Element.
SB 197
In June 2022, California State Senate passed Senate Bill 197 (Housing Budget Trailer
Bill), which provides additional time for local agencies to complete rezoning required by
the adopted Housing Element. Before SB 197, cities had 120 days from the Housing
Element adoption deadline (or by February 12, 2022) to complete any necessary
rezoning. SB 197 provides local governments that adopt a substantially compliant Sixth
Cycle Housing Element by October 15, 2022, three (3) years and 120 days from the
statutory deadline of October 15, 2021 to complete the required rezoning. Accordingly,
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Adoption of 2021-2029 Housing Element
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it is imperative that the City adopts a substantially compliant Sixth Cycle Housing
Element by October 15, 2022, to allow the City to have until February 2025 to
complete the rezoning.
ENVIRONMENTAL REVIEW:
On October 5, 2021, the City Council adopted Resolution No. 21-86 (Attachment G),
certifying the Negative Declaration for GPA 2021-0002 and Resolution No. 21-87,
approving GPA 2021-0002, updating the Housing Element.
The Housing Element Update is a policy document, and its adoption would not, in itself,
produce environmental impacts. No actual development or re -zoning is proposed as part
of the Housing Element Update. The Housing Element Update would not directly result in
changes to land use or zoning designations that would place housing within an area of
potential exposure to hazardous materials. Development proposed as a result of the
Housing Element Update would also be required to obtain City approval on a project -by -
project basis for any discretionary action and undergo a separate environmental process
to access potential environmental impacts. Furthermore, mitigation measures that are
required by underlying EIR's would be implemented as development is proposed.
Therefore, the adopted ND concludes that the Housing Element would have no impact.
The Housing Element has been revised further in response to the State Department of
Housing and Community Development's review to comply with State Housing Element
law. The revisions to the Housing Element include clarification language and refinements
that do not require subsequent environmental analysis.
PUBLIC HEARING NOTIFICATION:
On September 22, 2022, a public hearing notice was published in the Tustin News.
Approximately 400 public hearing notices were mailed to those included on the Housing
Element Interested Party List which included community online survey respondents,
individuals and organizations that have requested to be notified of housing topics
including the housing element update, residents and businesses, organizations receiving
CDBG program funding, the CBDG Interested Party List, outside agencies, housing
service providers, Orange County housing developers, apartment managers, neighboring
cities and various housing and special needs organizations. An email notification of the
October 4, 2022 City Council meeting was also sent to the City's Housing Element
Interested Party List along with an electronic copy of the public hearing notice. Public
Hearing Notice was also posted at Tustin City Hall, the Senior Center and the Tustin
Library.
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RECOMMENDATION:
The Draft Housing Element included herein addresses the requirements of the Housing
Element Law and Guidelines. In addition, comments and concerns of the Planning
Commission, City Council, HCD, affected agencies, and the public have been carefully
analyzed and addressed within the document.
The Planning Commission, at its September 13, 2022 meeting, recommended approval
of the Housing Element Update to the City Council for consideration during its October 4,
2022 meeting.
Accordingly, staff recommends that the City Council adopt Resolution No. 22-47 approving
the Sixth Cycle of the City of Tustin Housing Element Update and authorize staff to submit
the adopted Housing Element to HCD for certification.
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Irma Huitron
Assistant Director - Planning
Attachments:
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Justina L. Willkom
Community Development Director
A. HCD Review Letters:
1. HCD letter dated January 12, 2022
2. HCD letter dated May 18, 2022
B. City's Response to Comments
1. Response to Comments dated March 22, 2022
2. Response to Comments dated July 21, 2022
3. Response to Comments dated September 2, 2022
C. Draft Housing Element — Tracked Changes (September 2022)
D. HCD Approval Letter Dated September 12, 2022
E. Planning Commission Resolution No. 4457
F. Planning Commission Draft Minutes — September 13, 2022
G. City Council Resolution No. 21-86 certifying the Negative Declaration for the 6th
Cycle Housing Element Update
H. City Council Resolution No. 22-47
0 Exhibit A: Final Draft General Plan Housing Element and Appendices
ATTACHMENT A
HCD REVIEW LETTERS:
• HCD LETTER DATED JANUARY 12, 2022
• HCD LETTER DATED MAY 18, 2022
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT s
2020 W. EI Camino Avenue, Suite 500 ° °
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453 \#
www.hcd.ca.gov
January 12, 2022
Justina L. Willkom, Director
Community Development Department
City of Tustin
300 Centennial Way
Tustin, CA 92780
Dear Justina L. Willkom:
RE: City of Tustin's 6t" Cycle (2021-2029) Adopted Housing Element
Thank you for submitting the City of Tustin's (City) housing element adopted
October 5, 2021 and received for review on October 14, 2021. Pursuant to
Government Code section 65585, subdivision (h), the California Department of
Housing and Community Development (HCD) is reporting the results of its review.
The adopted housing element addresses some statutory requirements described in
HCD's August 27, 2021 review; however, additional revisions are necessary to fully
comply with State Housing Element Law (Article 10.6 of the Gov. Code), as listed in the
enclosed Appendix. The element will meet the statutory requirements of State Housing
Element Law once it has been revised and re -adopted to comply with the listed
requirements.
For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a
local government fails to adopt a compliant housing element within 120 days of the statutory
deadline (October 15, 2021), then any rezoning to accommodate the regional housing needs
allocation (RHNA), including for lower-income households, shall be completed no later than
one year from the statutory deadline. Otherwise, the local government's housing element will
no longer comply with State Housing Element Law, and HCD may revoke its finding of
substantial compliance pursuant to Government Code section 65585, subdivision (i).
Public participation in the development, adoption and implementation of the housing
element is essential to effective housing planning. Outreach to lower-income and
special needs groups during the public participation continues to be important
throughout the housing element revision process. The City should continue to engage
the community, including organizations that represent lower-income and special needs
Justina L. Willkom, Director
Page 2
households, by making information regularly available and considering and
incorporating comments where appropriate.
Several federal, state, and regional funding programs consider housing element
compliance as an eligibility or ranking criterion. For example, the CalTrans Senate Bill
(SB) 1 Sustainable Communities grant, the Strategic Growth Council and HCD's
Affordable Housing and Sustainable Communities programs, and HCD's Permanent
Local Housing Allocation consider housing element compliance and/or annual reporting
requirements pursuant to Government Code section 65400. With a compliant housing
element, the City will meet housing element requirements for these and other funding
sources.
For your information, some general plan element updates are triggered by housing
element adoption. HCD reminds the City to consider timing provisions and welcomes
the opportunity to provide assistance. For information, please see the Technical
Advisories issued by the Governor's Office of Planning and Research at:
http://opr.ca.gov/docs/OPR Appendix C final.pdf and
http://opr.ca.gov/docs/Final 6.26.15.pdf.
HCD is committed to assist the City in addressing all statutory requirements of State
Housing Element Law. If you have any questions or need additional technical assistance,
please contact Colin Cross, of our staff, at colin.cross(a)-hcd.ca.gov.
Sincerely,
Paul McDougall
Senior Program Manager
Enclosure
APPENDIX
CITY OF TUSTIN
The following changes are necessary to bring the City's housing element into compliance with
Article 10.6 of the Government Code. Accompanying each recommended change, we cite the
supporting section of the Government Code.
Housing element technical assistance information is available on HCD's website at
http://www.hcd.ca.gov/community-development/housing-element/housing-element-memos.shtml.
Among other resources, the housing element section contains HCD's latest technical assistance
tool, Building Blocks for Effective Housing Elements (Building Blocks), available at
http://www.hcd.ca.gov/community-development/building-blocks/index.shtml and includes the
Government Code addressing State Housing Element Law and other resources.
A. Housing Needs, Resources, and Constraints
1. Affirmatively furtherfing] fair housing in accordance with Chapter 15 (commencing with
Section 8899.50) of Division 1 of Title 2 ... shall include an assessment of fair housing in
the jurisdiction (Gov. Code, § 65583, subd. (c)(10)(A))
Strategies and Actions: The element is revised to include a matrix demonstrating the
connection between contributing factors and affirmatively furthering fair housing
(AFFH) programs (pp. D-93-96). However, the element relies solely on programs
which are not transformative, meaningful, or specific. For example, some of these
actions simply involve coming into compliance with state law. The element must be
revised to include programs that go beyond status quo actions and include
quantifiable objectives and concrete actions. Programs must include metrics and
milestones for evaluating progress on programs, actions, and fair housing results.
2. An inventory of land suitable and available for residential development, including
vacant sites and sites having realistic and demonstrated potential for redevelopment
during the planning period to meet the locality's housing need for a designated income
level, and an analysis of the relationship of zoning and public facilities and services to
these sites. (Gov. Code, § 65583, subd. (a)(3).)
Progress in Meeting the Regional Housing Needs Allocation (RHNA): The element is
revised to describe the 125 homes in the Village of Hope project as units, rather than
beds. However, it appears that these do not meet the Census definition of a unit,
due to their shared eating facilities. Please be aware that to be credited towards the
RHNA, the additional approved capacity must meet the Census definition of a unit.
The element should adjust the inventory as appropriate.
Zoning for Lower -Income Households: The element is revised to clarify that the
Specific Plan land use designations for original sites 1-16 do not have density
limitations, and therefore satisfy the City's default density of 30 du/ac. However, the
adopted element adds two new sites, both of which have the Planned Community
Commercial/Business land use designation, which is not described. The element
City of Tustin's 6t" Cycle Adopted Housing Element Page 1
January 12, 2022
must clarify what densities are allowed on these sites, what approvals are required
to reach at least 30 units per acre, and any relevant action the City may be taking to
ensure the viability of these sites for residential development.
Realistic Capacity: The adopted element is revised to add three examples of large-
scale development nearby, including a single development located in Tustin at 32
du/ac. However, the element still does not identify the City's capacity assumptions or
provide support for the capacity methodology. For example, the element has been
revised to assume 430 units for Site 1 (Tustin Legacy Specific Plan (TLSP)
Neighborhood D—North) [p. B-12] but does not explain the trends and factors used to
determine this capacity. The element should describe the factors that led to this
assumption and should relate the assumptions to trends in residential development.
A full analysis should address the differences in density between the sample
projects located outside of Tustin and the sample project located in Tustin, and
whether the City has potential constraints to development that may hinder its ability
to achieve higher densities. For more information, please refer to HCD's prior
review.
In addition, this analysis must still adjust for the likelihood of nonresidential
development in any zones that allow a mix of uses. The element does add some
information regarding mixed-use projects and residential projects near specific plan
areas (pp. B-17-18) but relate these examples to the capacity assumptions. This
analysis is especially important for the added Sites 17 (Enderle Center) and 18
(Market Place), which are located in the Planned Community Commercial / Business
district and may require rezoning to allow residential uses. For more information,
please refer to HCD's prior review.
Suitability of Nonvacant Sites: The element does not address HCD's findings
regarding the suitability of nonvacant sites and the Caltrans -owned Site 15.
Furthermore, the additional Sites 17 (Enderle Center) and 18 (Market Place) require
analysis demonstrating potential for redevelopment within the planning period.
Please see HCD's prior review.
Small and Large Sites: The element does not provide any additional description of
the City's lot consolidation capacity as required. Please see HCD's prior review.
Additionally, the element includes a new Site 18 (Market Place) which totals 48.65
acres, but must still provide evidence to HCD that the site is adequate to
accommodate lower-income housing, including but not limited to an analysis of the
site's potential for redevelopment and any steps that may need to be taken to
facilitate residential development (e.g., development of a specific plan, lot splits,
etc.). The element should adjust program actions as appropriate.
Infrastructure: The element is revised to clarify sufficient planned infrastructure for
the TLSP area (p. B-18). However, the element does not describe infrastructure
capacity for other Specific Plan areas or for the new Sites 17 (Enderle Center) and
18 (Market Place). The element must be revised to address this requirement for all
sites in the inventory.
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January 12, 2022
Environmental Constraints: The adopted element addresses environmental hazards within
the TLSP very generally, stating "the presence of continued remediation activities on the
Tustin Legacy site will not significantly impair the site's ability to support the number of
residential units anticipated" (p. B-18). This is not adequate to address this requirement. A
full analysis should address what the actual hazards are, describe the remediation activities
and provide their status and timeline, clarify whether these hazards are located within the
TLSP neighborhoods identified for the RHNA, and fully examine their impact on identified
sites.
Zoning for a Variety of Housing Types:
Emergency Shelters: The element is revised to state that emergency shelters are
"permitted, and are presently in operation, in parts of the Tustin Legacy Specific Plan"
(p. B-18). This is not adequate to satisfy this requirement. A full analysis must identify a
zone in which emergency shelters are permitted without discretionary action,
demonstrate the suitability of this zone for such uses, and demonstrate that emergency
shelters are subject only to development standards that comply with Government Code
Sec. 65583(a)(4). Please see HCD's prior review.
Farmworkers /Employee Housing Act: The adopted element claims because there are
no agricultural activities in Tustin, "it is therefore concluded that no farmworker housing
is required" (p. B-18). This does not address HCD's finding regarding the Employee
Housing Act. Please see HCD's prior review.
3. An analysis of potential and actual governmental constraints upon the maintenance,
improvement, or development of housing for all income levels, including the types of
housing identified in paragraph (1) of subdivision (c), and for persons with disabilities
as identified in the analysis pursuant to paragraph (7), including land use controls,
building codes and their enforcement, site improvements, fees and other exactions
required of developers, and local processing and permit procedures. The analysis shall
also demonstrate local efforts to remove governmental constraints that hinder the
locality from meeting its share of the regional housing need in accordance with
Government Code section 65584 and from meeting the need for housing for persons
with disabilities, supportive housing, transitional housing, and emergency shelters
identified pursuant to paragraph (7). Transitional housing and supportive housing shall
be considered a residential use of property, and shall be subject only to those
restrictions that apply to other residential dwellings of the same type in the same zone.
(Gov. Code, § 65583, subd. (a)(5).)
Land -Use Controls: The element is revised to address parking requirements. However,
the element adds a cumulative analysis of land use controls (p. II -49) which does not
address the ability to achieve maximum densities as is required. Please see HCD's
prior review.
Fees and Exactions: The element is revised to include a table of planning fees (pp. 11-
41-45). However, these fees are not contextualized or analyzed, and the table is
labeled "FY 08-09": it is not clear whether these are the current fees. The element
should ensure a current fee table is included and provide analysis.
City of Tustin's 6t" Cycle Adopted Housing Element Page 3
January 12, 2022
In addition, the element is revised to provide an estimate of the total cost of fees for a
typical multifamily project (p. II -37). However, this discussion does not provide a sense
for fees as a proportion of development costs, and does not provide an estimate of
total fees for a typical single-family development. Please see HCD's prior review.
Local Processing and Permit Procedures: The element is not revised to address this
finding. Please see HCD's prior review.
Design Review: The element is revised to provide some information on the design
review process; however, it must still describe and analyze decision-making criteria
and/or approval findings. Additionally, the element provides contradictory information
regarding whether a Planning Commission hearing is needed, stating both that "The
Design Review application does not necessarily require a public hearing or Planning
Commission approval" (p. II -48) and that "... in the R-2 or R-3 zones formal Design
Review is required and approval by the Planning Commission" (p. II -49). The element
should clearly describe the process for design review as it pertains to the various
zones and any other relevant factors.
The revised element also reveals several potential constraints. For example, a Major
conditional use permit (CUP) is required in addition to design review for new
apartments of three or more units; the element does not clarify whether this applies to
all zones and it does not analyze the requirement as a potential constraint.
Furthermore, the element notes that an additional CUP is required if a proposal
deviates from parking requirements. The element must analyze these requirements as
potential constraints and should include programs to address and mitigate or remove
the constraints as appropriate.
Housing for Persons with Disabilities: The adopted element includes expanded
discussion of the City's reasonable accommodation process (pp. II -32-3). However, the
element still does not profile or analyze the approval findings for this process. In
addition, revisions to the element indicate a fee is required for a complete application,
which, according to the planning fee schedule (p. II -42), may be several hundred
dollars or more; the element also notes that "a deed restriction is recorded against the
property to ensure compliance with conditions of approval, potential removal of the
accommodation, and use restrictions" (p. II -33). These potential constraints should be
specifically addressed in the element's analysis of the City's reasonable
accommodation procedure and the element should commit to modifying its reasonable
accommodation ordinance to remove the fee via a program action.
Local Ordinances: The element must specifically analyze any locally adopted
ordinances such as inclusionary ordinances or short-term rental ordinances that
directly impact the cost and supply of residential development. With revisions, the
element mentions an inclusionary ordinance for the Red Hill Avenue and Downtown
Commercial Core Specific Plan areas (p. II -50), but does not provide any detail or
analysis. The element must be revised to provide specific analysis and programs
should be added or modified if necessary.
4. An analysis of potential and actual nongovernmental constraints upon the
City of Tustin's 6t" Cycle Adopted Housing Element Page 4
January 12, 2022
maintenance, improvement, or development of housing for all income levels, including
the availability of financing, the price of land, the cost of construction, the requests to
develop housing at densities below those anticipated in the analysis required by
subdivision (c) of Government Code section 65583.2, and the length of time between
receiving approval for a housing development and submittal of an application for
building permits for that housing development that hinder the construction of a locality's
share of the regional housing need in accordance with Government Code section
65584. The analysis shall also demonstrate local efforts to remove nongovernmental
constraints that create a gap between the locality's planning for the development of
housing for all income levels and the construction of that housing. (Gov. Code,
§ 65583, subd. (a)(6).)
The adopted element is revised to state that the City has not received development
applications at densities below those identified in the element for Specific Plan areas,
but it must also provide this information for the rest of the City. The element is not
revised to address the requirement regarding the length of time between receiving
approval for a housing development and the submittal of an application for building
permits. Please see HCD's prior review.
5. Analyze any special housing needs such as elderly; persons with disabilities, including
a developmental disability, large families; farmworkers; families with female heads of
households; and families and persons in need of emergency shelter. (Gov. Code,
§ 65583, subd. (a)(7).)
The element must quantify the number of persons with developmental disabilities and
analyze the special housing needs of persons with disabilities more generally.
6. Analyze existing assisted housing developments that are eligible to change to nonlow-
income housing uses during the next 10 years due to termination of subsidy contracts,
mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd.
(a)(9) through 65583(a)(9)(D).)
The adopted element does not address this requirement. The City's response -to
comments document, submitted alongside the element, claims that it does not apply
because at -risk units are no longer being credited towards the RHNA. The element
must include this analysis regardless of utilization to accommodate the RHNA. Please
see HCD's prior review.
B. Housing Programs
Include a program which sets forth a schedule of actions during the planning period,
each with a timeline for implementation, which may recognize that certain programs
are ongoing, such that there will be beneficial impacts of the programs within the
planning period, that the local government is undertaking or intends to undertake to
implement the policies and achieve the goals and objectives of the Housing Element
through the administration of land use and development controls, the provision of
regulatory concessions and incentives, and the utilization of appropriate federal and
City of Tustin's 6t" Cycle Adopted Housing Element Page 5
January 12, 2022
state financing and subsidy programs when available. The program shall include an
identification of the agencies and officials responsible for the implementation of the
various actions. (Gov. Code, § 65583, subd. (c).)
The adopted element is revised to address most of HCD's comments regarding
specific actions, timeline for implementation, objectives, and responsible agency.
However, Program 1.19 (Fees, Exactions, and Permit Procedures) should still be
modified to include a specific commitment. Please see HCD's prior review.
2. Identify actions that will be taken to make sites available during the planning period
with appropriate zoning and development standards and with services and facilities to
accommodate that portion of the city's or county's share of the regional housing need
for each income level that could not be accommodated on sites identified in the
inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and
to comply with the requirements of Government Code section 65584.09. Sites shall be
identified as needed to facilitate and encourage the development of a variety of types
of housing for all income levels, including multifamily rental housing, factory -built
housing, mobilehomes, housing for agricultural employees, supportive housing, single -
room occupancy units, emergency shelters, and transitional housing.
(Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding A2, the element does not include a complete site analysis;
therefore, the adequacy of sites and zoning was not established. Based on the results
of a complete sites inventory and analysis, the City may need to add or revise
programs to address a shortfall of sites or zoning available to encourage a variety of
housing types.
In addition, the element is revised to include the by -right provisions found in
Government Code 65583.2(h) & (i) (pp. IV -2-3). However, Program 1.1 (Residential
Development—Available Sites) appears only to apply these provisions to "reuse sites"
or sites used in previous inventories. Program actions must be revised to ensure that
these provisions apply to all sites being rezoned to accommodate a shortfall in the
RHNA during the planning period. Please see HCD's prior review.
3. The Housing Element shall contain programs which assist in the development of
adequate housing to meet the needs of extremely low-, very low-, low- and moderate -
income households. (Gov. Code, § 65583, subd. (c)(2).)
The element is revised to add the words "extremely low-income (ELI)" to several
programs, but does not include an explicit ELI program or make any other specific
amendments to the existing programs. This is not adequate to satisfy the requirement.
The element must include a program containing a specific commitment that seeks to
assist in development for ELI households. The program(s) could commit the City to
adopting priority processing; granting fee waivers or deferrals; modifying development
standards; granting concessions and incentives for housing developments; assisting,
supporting, or pursuing funding applications; and/or proactively working with housing
developers to identify development opportunities.
City of Tustin's 6t" Cycle Adopted Housing Element Page 6
January 12, 2022
4. Address and, where appropriate and legally possible, remove governmental and
nongovernmental constraints to the maintenance, improvement, and development of
housing, including housing for all income levels and housing for persons with
disabilities. The program shall remove constraints to, and provide reasonable
accommodations for housing designed for, intended for occupancy by, or with
supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
As noted in Findings A3 and A4, the element requires a complete analysis of potential
governmental and nongovernmental constraints. Depending upon the results of that
analysis, the City may need to add or modify programs to address and remove or
mitigate any identified constraints.
5. Promote and affirmatively further fair housing opportunities and promote housing
throughout the community or communities for all persons regardless of race, religion,
sex, marital status, ancestry, national origin, color, familial status, or disability, and
other characteristics protected by the California Fair Employment and Housing Act
(Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and
any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd.
(c) (5).)
As noted in Finding All, the element does not contain programs that satisfy the AFFH
requirements for specific and meaningful actions to overcome fair housing issues.
Based on a complete analysis, the element must add or revise programs.
C. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed,
rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd.
(b)(1 & 2).)
The adopted element does not address this finding. The City's response -to -comments
document claims that quantified objectives for rehabilitation and conservation are not
required because those actions are "not proposed to meet the RHNA target"; this is
inaccurate. Quantified objectives should estimate the number of units likely to be
constructed, rehabilitated, or conserved/preserved by income level during the planning
period based on programmatic actions and housing needs. Please see HCD's prior review
to meet this statutory requirement.
City of Tustin's 6t" Cycle Adopted Housing Element Page 7
January 12, 2022
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT :
2020 W. EI Camino Avenue, Suite 500 ° ° •,�n �,,
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
May 18, 2022
Justina L. Willkom, Director
Community Development Department
City of Tustin
300 Centennial Way
Tustin, CA 92780
Dear Justina L. Willkom:
RE: City of Tustin's 6t" Cycle (2021-2029) Adopted Housing Element
Thank you for submitting the City of Tustin's (City) housing element adopted
October 5, 2021 and received for review on March 22, 2022. Pursuant to Government
Code section 65585, subdivision (h), the California Department of Housing and
Community Development (HCD) is reporting the results of its review. Our review was
facilitated by a telephone conversation on May 9, 2022 with you and Irma Huitron,
Assistant Director of Planning.
The adopted housing element addresses most statutory requirements described in
HCD's January 12, 2022 letter; however, additional revisions are necessary to fully
comply with State Housing Element Law (Article 10.6 of the Gov. Code), as follows:
Affirmatively furtherfing] fair housing in accordance with Chapter 15
(commencing with Section 8899.50) of Division 1 of Title 2 ... shall include an
assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd.
(c) (10) (A).)
Promote and affirmatively further fair housing opportunities and promote housing
throughout the community or communities for all persons regardless of race,
religion, sex, marital status, ancestry, national origin, color, familial status, or
disability, and other characteristics... (Gov. Code, § 65583, subd. (c)(5).)
Strategies, Actions, Metrics and Milestones: The element is revised to include
further description of certain program actions. These are not adequate to meet
the requirement for specific, meaningful, and transformative affirmatively
furthering fair housing (AFFH) actions. Many new program actions, such as
Programs 1.8 (Partnerships with Nonprofit Organizations) and 2.5 (Affirmatively
Furthering Fair Housing), are limited to outreach. While HCD applauds targeted
and proactive outreach activities, these alone are not adequate to satisfy the
Justina L. Willkom, Director
Page 2
requirements for meaningful and transformative programs. Other programs, such
as 1.4 (Voluntary Workforce Housing), 3.1 (Condominium Conversions) and 3.5
(Rental Assistance) are pre-existing policy commitments that do not constitute
new and transformative actions. Still others, such as 1.17 (Public Improvement
Financing) and 3.10 (Housing Rehabilitation), include exploratory goals rather
than a specific commitment. AFFH program actions should provide specific policy
commitments, go beyond compliance with State law, address fair housing topics
beyond outreach, and respond to the identified contributing factors. HCD can
provide samples and other guidance under separate cover.
AFFH program actions must also provide meaningful metrics and milestones for
measuring progress towards identified fair housing goals during the planning
period; the element is not revised to include such metrics and milestones.
Examples include, but are not limited to, a program to incentivize voucher use in
high -opportunity areas which commits to objectives for the number of households
assisted, or a program to establish anti -displacement policies which targets a
decrease in the percentage of households that are considered vulnerable
according to the Urban Displacement Project. HCD can provide samples under
separate cover.
2. An inventory of land suitable and available for residential development, including
vacant sites and sites having realistic and demonstrated potential for
redevelopment during the planning period to meet the locality's housing need for
a designated income level, and an analysis of the relationship of zoning and
public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
Identify actions that will be taken to make sites available during the planning
period with appropriate zoning and development standards and with services and
facilities to accommodate that portion of the city's or county's share of the
regional housing need for each income level that could not be accommodated on
sites identified in the inventory completed pursuant to paragraph (3) of
subdivision (a) without rezoning, and to comply with the requirements of
Government Code section 65584.09. Sites shall be identified as needed to
facilitate and encourage the development of a variety of types of housing for all
income levels, including multifamily rental housing, factory -built housing,
mobilehomes, housing for agricultural employees, supportive housing, single -
room occupancy units, emergency shelters, and transitional housing. (Gov.
Code, § 65583, subd. (c)(1).)
Realistic Capacity: The element is revised to include updated estimates of
realistic capacity. However, many of these estimates are internally inconsistent
and/or make inaccurate calculations. For example, the element claims that the
Tustin Legacy Specific Plan (TLSP) is "anticipated to provide capacity of 555
units over approximately 40 acres in Neighborhood D North (40 units/acre)" (p.
B-20). However, this calculation does not work out to 40 du/ac; 555 units across
Justina L. Willkom, Director
Page 3
40 acres would only achieve a density of approximately 14 units/acre. Based on
our conversation, HCD understands that these calculations may include acreage
that will not be used for housing, and that the sites are expected to achieve
densities in line with the sample projects from Table B-4. The element should be
revised to clarify and confirm the densities assumed for each site, and to provide
accurate calculations of capacity. Based on the outcomes of this analysis, the
element may need to add or modify programs.
Zoning for a Variety of Housing Types (Employee Housing): The element is
revised to include Program 2.7 (Farmworker Housing), which commits to
compliance with the Employee Housing Act (Health and Safety Code, § 17000 et
seq.), specifically, sections 17021.5 and 17021.6. However, the element
incorrectly paraphrases the Act, stating that the City will allow "farmworker
housing to be developed within areas that allow agricultural use" (p. IV -25).
Section 17021.5 requires employee housing for six or fewer employees to be
treated as a single-family structure and permitted in the same manner as other
dwellings of the same type in the same zone. Section 17021.6 requires employee
housing consisting of no more than 12 units or 36 beds to be permitted in the
same manner as other agricultural uses in the same zone. Program 2.7 should
be revised to ensure compliance with the Employee Housing Act.
3. An analysis of potential and actual governmental constraints upon the
maintenance, improvement, or development of housing for all income levels,
including the types of housing identified in paragraph (1) of subdivision (c), and
for persons with disabilities as identified in the analysis pursuant to paragraph
(7), including land use controls, building codes and their enforcement, site
improvements, fees and other exactions required of developers, and local
processing and permit procedures. The analysis shall also demonstrate local
efforts to remove governmental constraints that hinder the locality from meeting
its share of the regional housing need in accordance with Government Code
section 65584 and from meeting the need for housing for persons with
disabilities, supportive housing, transitional housing, and emergency shelters
identified pursuant to paragraph (7). (Gov. Code, § 65583, subd. (a)(5).)
Address and, where appropriate and legally possible, remove governmental and
nongovernmental constraints to the maintenance, improvement, and
development of housing, including housing for all income levels and housing for
persons with disabilities. The program shall remove constraints to, and provide
reasonable accommodations for housing designed for, intended for occupancy
by, or with supportive services for, persons with disabilities. (Gov. Code, §
65583, subd. (c)(3).)
Permit Processing and Procedures: Program 1.5 is revised to commit to
amending the zoning code "to allow apartments three or more by -right" (p. IV -10).
However, this language is limited, and does not clarify the applicable zone(s).
Justina L. Willkom, Director
Page 4
Based on our conversation with the City, HCD understands that the City intends
to remove the Conditional Use Permit (CUP) for residential uses City-wide.
Program 1.5 should be revised to commit specifically to the removal of this CUP
for all zones.
Design Review: The element is revised to provide more information about the
City's design review process, including a list of the design review
"responsibilities" of the Community Development Department. However, the
element does not analyze this process as a potential constraint. For example, the
element does not address the fact that design review appears to apply to every
single development proposal; nor does it discuss the subjective nature of the
"responsibilities" listed. The element must also describe and analyze the
Conditions of Approval and Guiding Principles as found in Tustin City Code
Section 9272, many of which contain subjective language and may pose a
constraint to housing development. The element should be revised to analyze the
design review process as a potential constraint, including analysis of the process'
impact on factors such as supply, affordability, timing, and developer certainty.
Programs should be added and modified as appropriate.
Housing for Persons with Disabilities: The element is revised to describe the
City's reasonable accommodation procedure in further detail. These revisions
reveal that the City requires an applicant for reasonable accommodation to
provide "confirmation that the property is the primary residence of the disabled
person" (p. II -37). This requirement may pose a constraint to housing for persons
with disabilities. The element should analyze the requirement for consistency
with HUD/DOJ guidance and add or modify programs as appropriate.
Local Ordinances: The element is revised to provide more information about the
City's inclusionary housing ordinance. This discussion should also describe what
percent of units are required to be affordable and analyze the requirement as a
potential constraint. In addition, although the element describes the policy as
voluntary, it appears to be mandatory for housing development, as it is triggered
"when the developer makes the voluntary election to request the discretionary
and valuable benefit of adding residential units" (p. II -35). The element should
clarify what specifically triggers the inclusionary requirements, and analyze this
as a potential constraint, as it may disincentivize the addition of residential units
to mixed-use properties. Finally, the in -lieu fees provided appear high and may
pose a constraint, and the element does not clarify whether these fees are per-
unit. The element must be revised to provide specific analysis of these potential
constraints and add or modify programs as appropriate.
Programs: As noted above, the element requires a complete analysis of potential
governmental and nongovernmental constraints. Depending upon the results of
that analysis, the City may need to revise or add programs and address and
remove or mitigate any identified constraints.
Justina L. Willkom, Director
Page 5
4. Analyze any special housing needs such as elderly, persons with disabilities,
including a developmental disability; large families; farmworkers; families with
female heads of households; and families and persons in need of emergency
shelter. (Gov. Code, § 65583, subd. (a)(7).)
The element is revised to analyze the special housing needs of persons with
disabilities. However, the element must still quantify the number of persons with
developmental disabilities and add or modify programs as appropriate based on
the outcomes of a complete analysis.
5. Analyze existing assisted housing developments that are eligible to change to
non -low-income housing uses during the next 10 years due to termination of
subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov.
Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).).
The element is revised to update the assessment of risk for at -risk units and
commit to new program actions related to tenant noticing. However, the element
still does not estimate the costs of replacement versus preservation, identify
entities with the capacity to oversee preservation, or identify specific funding
sources that could be used to preserve the affordability. The element must
provide this analysis for the at -risk units identified.
The element will meet the statutory requirements of State Housing Element Law once it
has been revised and re -adopted to comply with the above requirements.
For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021),
as the City failed to adopt a compliant housing element within 120 days of the statutory
deadline (October 15, 2021), Program 1.1 (Residential Development —Available Sites)
to rezone to accommodate the regional housing needs allocation (RHNA) must be
completed no later than one year from the statutory deadline. Otherwise, the local
government's housing element will no longer comply with State Housing Element Law,
and HCD may revoke its finding of substantial compliance pursuant to Government
Code section 65585, subdivision (i).
Public participation in the development, adoption and implementation of the housing
element is essential to effective housing planning. During the housing element revision
process, the City must continue to engage the community, including organizations that
represent lower-income and special needs households, by making information regularly
available while considering and incorporating comments where appropriate. Please be
aware, any revisions to the element must be posted on the local government's website
and a link must be emailed to all individuals and organizations that have previously
requested notices relating to the local government's housing element at least seven
days before submitting to HCD.
Justina L. Willkom, Director
Page 6
For your information, some general plan element updates are triggered by housing
element adoption. HCD reminds the City to consider timing provisions and welcomes
the opportunity to provide assistance. For information, please see the Technical
Advisories issued by the Governor's Office of Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html
Several federal, state, and regional funding programs consider housing element
compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill
(SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD's
Affordable Housing and Sustainable Communities programs; and HCD's Permanent
Local Housing Allocation consider housing element compliance and/or annual reporting
requirements pursuant to Government Code section 65400. With a compliant housing
element, the City will meet housing element requirements for these and other funding
sources.
HCD is committed to assist the City in addressing all statutory requirements of State
Housing Element Law. If you have any questions or need additional technical
assistance, please contact Colin Cross, of our staff, at colin.cross(a-)_hcd.ca.gov.
Sincerely,
W4t7' 1
Paul McDougall
Senior Program Manager
ATTACHMENT B
CITY'S RESPONSE TO COMMENTS:
• RESPONSE TO COMMENTS DATED MARCH 22, 2022
• RESPONSE TO COMMENTS DATED JULY 21, 2022
• RESPONSE TO COMMENTS DATED SEPTEMBER 2, 2022
City of Tustin 6th Cycle Housing Element 2021-2029 — Response to Comments Summary
Refer to HCD Findings Letter Dated January 12, 2022
Resubmittal to HCD Date: March 22, 2022
HCD Comment
Page No.
City of Tustin Response
Updated to reflect compliance with AB 215
INTRODUCTION
1-1
and other minor edits.
AFFH
The element is revised to include a matrix demonstrating the connection
D-87
The matrix has been revised to provide
between contributing factors and affirmatively furthering fair housing (AFFH)
additional context for how supporting
programs (pp. D-93-96). However, the element relies solely on programs which
programs would contribute to meaningful
are not transformative, meaningful, or specific. For example, some of these
change regarding the AFFH contributing
actions simply involve coming into compliance with state law. The element
factors. New programs were added to
must be revised to include programs that go beyond status quo actions and
specifically address contributing factors
include quantifiable objectives and concrete actions. Programs must include
identified by the AFFH analysis. Programs
metrics and milestones for evaluating progress on programs, actions, and fair
were revised to include metrics and
housing results.
milestones that could be measured towards
progress.
Sites Inventory
1. The element is revised to describe the 125 homes in the Village of Hope
II -46
Village of Hope was removed from RHNA
project as units, rather than beds. However, it appears that these do not
because the units did not fit the Census
meet the Census definition of a unit, due to their shared eating facilities.
(Removed
definition of "unit". However, these are still
Please be aware that to be credited towards the RHNA, the additional
from APP
identified in Section II under Emergency
approved capacity must meet the Census definition of a unit. The element
B - Sites
Shelters, Transitional Housing, and
should adjust the inventory as appropriate.
Inventory)
Supportive Housing.
2. The element is revised to clarify that the Specific Plan land use
B-26/13-27
Densities for the Market Place & Enderle
designations for original sites 1-16 do not have density limitations, and
have been included. The requirement for
therefore satisfy the City's default density of 30 du/ac. However, the
rezoning is described as well. Rezoning has
adopted element adds two new sites, both of which have the Planned
also been included as a Program under
Community Commercial/Business land use designation, which is not
Program 1.1.
described. The element must clarify what densities are allowed on these
sites, what approvals are required to reach at least 30 units per acre,
and any relevant action the City may be taking to ensure the viability of
these sites for residential development.
City of Tustin 6th Cycle Housing Element 2021-2029 — Response to Comments
Summary Refer to HCD Findings Letter Dated January 12, 2022
Resubmittal to HCD Date: March 22, 2022
HCD Comment
Page No.
City of Tustin Response
3. The adopted element is revised to add three examples of large-scale
B-19 to
Realistic capacity analysis has been included.
development nearby, including a single development located in Tustin
B-28
Examples of recently approved projects
at 32 du/ac. However, the element still does not identify the City's
were provided and discussion was included
capacity assumptions or provide support for the capacity methodology.
to describe how capacity assumptions were
For example, the element has been revised to assume 430 units for Site
reached when determining RHNA allocations
1 (Tustin Legacy Specific Plan (TLSP) Neighborhood D—North) [p. B-12]
to various sites. Projects from surrounding
but does not explain the trends and factors used to determine this
cities were included for additional context,
capacity. The element should describe the factors that led to this
but not as a basis for determining density
assumption and should relate the assumptions to trends in residential
and capacity of the sites.
development. A full analysis should address the differences in density
between the sample projects located outside of Tustin and the sample
project located in Tustin, and whether the City has potential constraints
to development that may hinder its ability to achieve higher densities.
For more information, please refer to HCD's prior review.
4. In addition, this analysis must still adjust for the likelihood of
B-19 to
See response above.
nonresidential development in any zones that allow a mix of uses. The
B-28
element does add some information regarding mixed-use projects and
Examples used to determine capacity and
residential projects near specific plan areas (pp. B-17-18) but relate
density of the housing sites include mixed
these examples to the capacity assumptions. This analysis is especially
use projects.
important for the added Sites 17 (Enderle Center) and 18 (Market
Place), which are located in the Planned Community Commercial /
Business district and may require rezoning to allow residential uses. For
more information, please refer to HCD's prior review.
S. The element does not address HCD's findings regarding the suitability
B-3 to
The site formerly identified as Caltrans -
of nonvacant sites and the Caltrans -owned Site 15. Furthermore, the
B-11
owned is actually privately owned. Site
additional Sites 17 (Enderle Center) and 18 (Market Place) require
information has been revised accordingly.
analysis demonstrating potential for redevelopment within the
Additionally, information has been provided
planning period. Please see HCD's prior review.
regarding suitability of redevelopment of
nonvacant sites, including poor conditions,
developer interest, and improvement -to -
land value ratio for site underutilization.
City of Tustin 6th Cycle Housing Element 2021-2029 — Response to Comments
Summary Refer to HCD Findings Letter Dated January 12, 2022
Resubmittal to HCD Date: March 22, 2022
HCD Comment
Page No.
City of Tustin Response
Nonvacant sites selected to accommodate
RHNA show strong redevelopment potential.
6. The element does not provide any additional description of the City's
II -69
The City's lot consolidation process has been
lot consolidation capacity as required. Please see HCD's prior review.
B-27
revised within Section II. A lot consolidation
Additionally, the element includes a new Site 18 (Market Place) which
overlay has been included as Program 1.19 to
totals 48.65 acres, but must still provide evidence to HCD that the site
encourage consolidation of lots. Lot splits
is adequate to accommodate lower-income housing, including but not
discussion as an administrative process has
limited to an analysis of the site's potential for redevelopment and any
been included and does not pose a
steps that may need to be taken to facilitate residential development
constraint as an administrative process.
(e.g., development of a specific plan, lot splits, etc.). The element should
adjust program actions as appropriate.
Discussion has been added to Appendix B
regarding lot size and adequacy to
accommodate lower income housing.
7. The element is revised to clarify sufficient planned infrastructure for the
B-15
Table B-3 Includes a column stating the
TLSP area (p. B-18). However, the element does not describe
availability of infrastructure for each site.
infrastructure capacity for other Specific Plan areas or for the new Sites
Sites included in specific plans have
17 (Enderle Center) and 18 (Market Place). The element must be revised
infrastructure planned within the plans. For
to address this requirement for all sites in the inventory.
sites not within specific plans, discussion of
availability of connections to existing
infrastructure has been added to table.
8. The adopted element addresses environmental hazards within the TLSP
B-22
Discussion has been included to clarify
very generally, stating "the presence of continued remediation
housing would not be proposed within area
activities on the Tustin Legacy site will not significantly impair the site's
where remediation is still taking place.
ability to support the number of residential units anticipated" (p. B-18).
This is not adequate to address this requirement. A full analysis should
address what the actual hazards are, describe the remediation activities
and provide their status and timeline, clarify whether these hazards are
located within the TLSP neighborhoods identified for the RHNA, and
fully examine their impact on identified sites.
9. Emergency Shelters: The element is revised to state that emergency
11-39
A full analysis has been included in Section
shelters are "permitted, and are presently in operation, in parts of the
11.
City of Tustin 6th Cycle Housing Element 2021-2029 — Response to Comments
Summary Refer to HCD Findings Letter Dated January 12, 2022
Resubmittal to HCD Date: March 22, 2022
HCD Comment
Page No.
City of Tustin Response
Tustin Legacy Specific Plan" (p. B-18). This is not adequate to satisfy this
requirement. A full analysis must identify a zone in which emergency
shelters are permitted without discretionary action, demonstrate the
suitability of this zone for such uses, and demonstrate that emergency
shelters are subject only to development standards that comply with
Government Code Sec. 65583(a)(4). Please see HCD's prior review.
10. Farmworkers / Employee Housing Act: The adopted element claims
II -14
A statement was added that farmworkers
because there are no agricultural activities in Tustin, "it is therefore
may commute from surrounding areas.
concluded that no farmworker housing is required" (p. B-18). This does not
Additionally, Program 2.7 was included that
address HCD's finding regarding the Employee Housing Act. Please see
will revise the City's Zoning Code to comply
HCD's prior review.
with the State Health & Safety Code.
Governmental Constraints
11. Land -Use Controls: The element is revised to address parking
II -70
Cumulative discussion was updated to
requirements. However, the element adds a cumulative analysis of land
include analysis of land use controls on the
use controls (p. II -49) which does not address the ability to achieve
ability to achieve maximum allowable
maximum densities as is required. Please see HCD's prior review.
densities.
12. Fees and Exactions: The element is revised to include a table of
II -36
Fees were updated and analysis was added.
planning fees (pp. II -41-45). However, these fees are not contextualized
Programs are in place to offset fees for
or analyzed, and the table is labeled "FY 08-09"; it is not clear whether
affordable housing developers, and fee
these are the current fees. The element should ensure a current fee
amounts are consistent or less than
table is included and provide analysis.
surrounding jurisdictions. Fees are not
considered a constraint.
13. In addition, the element is revised to provide an estimate of the total
II -36
This information has been included.
cost of fees for a typical multifamily project (p. II -37). However, this
discussion does not provide a sense for fees as a proportion of
development costs and does not provide an estimate of total fees for a
typical single-family development. Please see HCD's prior review.
14. Local Processing and Permit Procedures: The element is not revised to
II -59
City's permit processing and approval
address this finding. Please see HCD's prior review.
procedures by zone and housing type has
been included. The analysis includes an
evaluation of the processing and permit
4
City of Tustin 6th Cycle Housing Element 2021-2029 — Response to Comments
Summary Refer to HCD Findings Letter Dated January 12, 2022
Resubmittal to HCD Date: March 22, 2022
HCD Comment
Page No.
City of Tustin Response
procedures' impacts as potential constraints
on housing supply and affordability.
Additional tables, flowcharts, and timelines
have been added for clarity of process.
Constraints were addressed and discussed.
15. Design Review: The element is revised to provide some information on
II -67
Additional information regarding the design
the design review process; however, it must still describe and analyze
review process has been included, as well as
decision-making criteria and/or approval findings. Additionally, the
a table outlining the various requirements
element provides contradictory information regarding whether a
for each type of project. Discrepancies were
Planning Commission hearing is needed, stating both that "The Design
revised.
Review application does not necessarily require a public hearing or
Planning Commission approval" (p. II -48) and that "... in the R-2 or R-3
zones formal Design Review is required and approval by the Planning
Commission" (p. II -49). The element should clearly describe the process
for design review as it pertains to the various zones and any other
relevant factors.
16. The revised element also reveals several potential constraints. For
II -59
Constraint analysis has been expanded to
example, a Major conditional use permit (CUP) is required in addition to
describe why constraints do not exist. Table
design review for new apartments of three or more units; the element
II -27 provides permit process for each type
does not clarify whether this applies to all zones and it does not analyze
of zone.
the requirement as a potential constraint. Furthermore, the element
notes that an additional CUP is required if a proposal deviates from
Program 1.5 added, City will amend Zoning
parking requirements. The element must analyze these requirements as
IV -10
Code to allow apartments of three or more
potential constraints and should include programs to address and
(including triplexes) by Right.
mitigate or remove the constraints as appropriate.
17. Housing for Persons with Disabilities: The adopted element includes
II -36
The discussion now includes an analysis of
expanded discussion of the City's reasonable accommodation process
required approvals and deeds as a
(pp. II -32-3). However, the element still does not profile or analyze the
constraint to reasonable accommodation for
approval findings for this process. In addition, revisions to the element
persons with disabilities. Additionally,
indicate a fee is required for a complete application, which, according
Program 2.4 was modified to include
City of Tustin 6th Cycle Housing Element 2021-2029 — Response to Comments
Summary Refer to HCD Findings Letter Dated January 12, 2022
Resubmittal to HCD Date: March 22, 2022
HCD Comment
Page No.
City of Tustin Response
to the planning fee schedule (p. II -42), may be several hundred dollars
additional actions that would remove
or more; the element also notes that "a deed restriction is recorded
identified constraints.
against the property to ensure compliance with conditions of approval,
potential removal of the accommodation, and use restrictions" (p. 11-
33). These potential constraints should be specifically addressed in the
element's analysis of the City's reasonable accommodation procedure
and the element should commit to modifying its reasonable
accommodation ordinance to remove the fee via a program action.
(Irma)
18. Local Ordinances: The element must specifically analyze any locally
II -34
Analysis has been included to discuss the
adopted ordinances such as inclusionary ordinances or short-term
City's inclusionary housing ordinance as a
rental ordinances that directly impact the cost and supply of residential
potential constraint. Because of the success
development. With revisions, the element mentions an inclusionary
the RHASP and DCCSP have had in attracting
ordinance for the Red Hill Avenue and Downtown Commercial Core
development, the ordinance is not
Specific Plan areas (p. II -50), but does not provide any detail or analysis.
considered a constraint. The ordinance is
The element must be revised to provide specific analysis and programs
comparable to surrounding cities'
should be added or modified if necessary.
requirements.
Nongovernmental Constraints
19. The adopted element is revised to state that the City has not received
II -63
Discussion of length of approval time
development applications at densities below those identified in the
between application and building permit
element for Specific Plan areas, but it must also provide this information
issuance has been included.
for the rest of the City. The element is not revised to address the
requirement regarding the length of time between receiving approval
II -72
There have not been any zone change
for a housing development and the submittal of an application for
applications processed for any housing
building permits. Please see HCD's prior review.
developments during the 5th housing cycle.
Information has been included in discussion.
Special Housing Needs
20. The element must quantify the number of persons with developmental
II -11
This section has been revised.
disabilities and analyze the special housing needs of persons with
disabilities more generally.
Rl
City of Tustin 6th Cycle Housing Element 2021-2029 — Response to Comments
Summary Refer to HCD Findings Letter Dated January 12, 2022
Resubmittal to HCD Date: March 22, 2022
HCD Comment
Page No.
City of Tustin Response
At -risk Units
21. The adopted element does not address this requirement. The City's
II -16
This section has been updated to include
response -to comments document, submitted alongside the element,
total count of at -risk units and programs to
claims that it does not apply because at -risk units are no longer being
address potential conversions.
credited towards the RHNA. The element must include this analysis
regardless of utilization to accommodate the RHNA. Please see HCD's prior
review.
Housing Programs
22. The adopted element is revised to address most of HCD's comments
IV -16
Language of Program 1.19 (now 1.18) has
regarding specific actions, timeline for implementation, objectives, and
been revised to include commitment
responsible agency. However, Program 1.19 (Fees, Exactions, and
language.
Permit Procedures) should still be modified to include a specific
commitment. Please see HCD's prior review.
23. As noted in Finding A2, the element does not include a complete site
APP B
A site analysis has been appended and
analysis; therefore, the adequacy of sites and zoning was not
emailed.
established. Based on the results of a complete sites inventory and
analysis, the City may need to add or revise programs to address a
shortfall of sites or zoning available to encourage a variety of housing
types.
24. In addition, the element is revised to include the by -right provisions
IV -5
Program 1.1 e now includes provision of by -
found in Government Code 65583.2(h) & (i) (pp. IV -2-3). However,
right housing for reuse sites in compliance
Program 1.1 (Residential Development—Available Sites) appears only to
with gov. code.
apply these provisions to "reuse sites", or sites used in previous
inventories. Program actions must be revised to ensure that these
provisions apply to all sites being rezoned to accommodate a shortfall
in the RHNA during the planning period. Please see HCD's prior review.
25. The element is revised to add the words "extremely low-income (ELI)"
IV -6
Program 1.1 h has been included for ELI
to several programs, but does not include an explicit ELI program or
households.
make any other specific amendments to the existing programs. This is
not adequate to satisfy the requirement. The element must include a
program containing a specific commitment that seeks to assist in
City of Tustin 6th Cycle Housing Element 2021-2029 — Response to Comments
Summary Refer to HCD Findings Letter Dated January 12, 2022
Resubmittal to HCD Date: March 22, 2022
HCD Comment
Page No.
City of Tustin Response
development for ELI households. The program(s) could commit the City
to adopting priority processing; granting fee waivers or deferrals;
modifying development standards; granting concessions and incentives
for housing developments; assisting, supporting, or pursuing funding
applications; and/or proactively working with housing developers to
identify development opportunities.
26. As noted in Findings A3 and A4, the element requires a complete
-
Noted. Program modified as necessary and
analysis of potential governmental and nongovernmental constraints.
notes on this RTC list.
Depending upon the results of that analysis, the City may need to add
or modify programs to address and remove or mitigate any identified
constraints.
27. As noted in Finding Al, the element does not contain programs that
See Response 1.
satisfy the AFFH requirements for specific and meaningful actions to
overcome fair housing issues. Based on a complete analysis, the
element must add or revise programs.
Quantified Objectives
28. The adopted element does not address this finding. The City's
II -16
A table has been included with this
response -to -comments document claims that quantified objectives for
information on II -73. Only new construction
rehabilitation and conservation are not required because those actions
is being applied towards RHNA, however,
are "not proposed to meet the RHNA target"; this is inaccurate.
the table compiles at -risk and rehabilitation
Quantified objectives should estimate the number of units likely to be
efforts the City plans to undertake during
constructed, rehabilitated, or conserved/preserved by income level
the planning period.
during the planning period based on programmatic actions and housing
needs. Please see HCD's prior review to meet this statutory
requirement.
City of Tustin
Draft Housing Element Resubmittal July 2022
Response to Comments Summary
HCD Comment
Revised Housing Element
No. (May 18, 2022 Letter)
City Response
(July 2022) Page No. and/or
Table No.
1. AFFH - Strategies, Actions, Metrics and
City revised AFFH programs Table to include Contributing Factor,
Pgs. D-94 thru D-97
Milestones are not adequate to meet the
Strategies to Address AFFH Issue and Supporting Program in a
requirement for specific, meaningful, and
new table format.
transformative affirmatively furthering fair
housing (AFFH) actions. Many new program
actions are limited to outreach. While HCD
Expanded analysis regarding fair housing concerns.
Pg. D-5
applauds targeted and proactive outreach
activities, these alone are not adequate to
satisfy the requirements for meaningful and
Clarified analysis.
Pgs. D-20, D-50, D-74
transformative programs. Other programs
are pre-existing policy commitments that do
not constitute new and transformative
Expanded analysis.
Pg. D-87
actions. Still others include exploratory
goals rather than a specific commitment.
Revised program with AFFH program actions with meaningful
AFFH program actions should provide
metrics and milestones for measuring progress:
specific policy commitments, go beyond
compliance with State law, address fair
Amended Program No. 1.1.h
Pg. IV -8
housing topics beyond outreach, and
Amended Program No. 1.7b
Pg. IV -14
respond to the identified contributing
Amended Program No. 2.5b
Pg. IV -26 thru IV -27
factors. AFFH program actions must also
New Program No. 2.5c
Pg. IV -28
provide meaningful metrics and milestones
New Program 2.8 (Tustin Legacy)
Pgs. IV -30 thru IV -31
for measuring progress towards identified
Amended Program 3.10
Pgs. IV -36 thru IV -38
fair housing goals during the planning
New Program No. 3.11
Pg. IV -38
period.
New Program 3.12
Pgs. IV -38 thru IV -39
New Program 3.13
Pg. IV -39
Realistic Capacity: The element's updated Amended Suitable Sites Identification and Assessment section to Pg. B-3
estimates of realistic capacity are internally refer to new Table B-1 A, located in Attachment B of the Housing
inconsistent and/or make inaccurate Element document.
calculations. For example, the element
claims that the Tustin Legacy Specific Plan
(TLSP) is "anticipated to provide capacity of Clarified total acreage of Sites 11 thru 14. Pg. B-9
555 units over approximately 40 acres in
Neighborhood D North (40 units/acre)."
However, this calculation does not work out
City of Tustin
Draft Housing Element Resubmittal July 2022
Response to Comments Summary
HCD Comment
Revised Housing Element
No. (May 18, 2022 Letter)
City Response (July 2022) Page No. and/or
Table No.
to 40 du/ac; 555 units across 40 acres
Expanded analysis to clarify the areas excluded from the density Pgs. B-21 thru B-24
would only achieve a density of
calculations summarized in new Table B -1A.
approximately 14 units/acre. Based on our
conversation, HCD understands that these
calculations may include acreage that will
Added Table B-1 A to describe Realistic Capacity for each of the Pgs. B-40 thru B-41
not be used for housing, and that the sites
RHNA sites. Table B -1A provides accurate calculations and
are expected to achieve densities in line
confirms the densities assumed for each site.
with the sample projects from Table B-4.
The element should be revised to clarify
and confirm the densities assumed for each
site, and to provide accurate calculations of
capacity.
2. Zoning for a Variety of Housing Types
Amended Program No. 2.7 as requested per the Finding Pg. IV -29
(Employee Housing): The element is
described.
revised to include Program 2.7 (Farmworker
Housing), which commits to compliance with
the Employee Housing Act (Health and
Safety Code, § 17000 et seq.), specifically,
sections 17021.5 and 17021.6. However,
the element incorrectly paraphrases the Act.
Program 2.7 should be revised to ensure
compliance with the Employee Housing Act.
3. Permit Processing and Procedures:
Amended Program No. 1.5 to remove CUP requirements for Pg. IV -12
Program 1.5 is revised to commit to
residential uses citywide.
amending the zoning code "to allow
apartments three or more by -right" (p. IV -
10). However, this language is limited, and
does not clarify the applicable zone(s).
Based on our conversation with the City,
HCD understands that the City intends to
remove the Conditional Use Permit (CUP)
for residential uses City-wide. Program 1.5
should be revised to commit specifically to
the removal of this CUP for all zones.
Local Ordinances: The element is revised
City of Tustin
to provide more information about the City's
program is structured, and also to clarify the percentage of units
Draft Housing Element Resubmittal July 2022
required to be affordable and analysis provided to regarding
discussion should also describe what
Response to Comments Summary
percent of units are required to be
HCD Comment
affordable and analyze the requirement as a
Revised Housing Element
No. (May 18, 2022 Letter)
City Response
(July 2022) Page No. and/or
Table No.
3. Design Review: The element must also
New analysis added. City will amend City Code 9272 relating to
Pgs. II -78 thru II -79
describe and analyze the Conditions of
Design Review to remove subjective design guidance and adopt
Approval and Guiding Principles as found in
objective design standards to facilitate high-quality, streamlined
Tustin City Code Section 9272, many of
residential development. The new objective design standards
which contain subjective language and may
would serve to further increase certainty and reduce inefficiencies
pose a constraint to housing development.
to project's design review and approval process.
The element should be revised to analyze
the design review process as a potential
constraint, including analysis of the process'
Amended Program No. 1.2a
Pg. IV -9
impact on factors such as supply,
affordability, timing, and developer certainty.
Programs should be added and modified as
appropriate.
3. Housing for Persons with Disabilities:
Expanded Analysis Added regarding demographics of persons
Pg. II -47
The element is revised to describe the City's
with disabilities.
reasonable accommodation procedure in
further detail. These revisions reveal that
the City requires an applicant for
Constraint identified in findings letter added to analysis. City will
Pg. II -50
reasonable accommodation to provide
remove the requirement that the applicant provide confirmation
"confirmation that the property is the primary
that the property is the primary residence of the disabled person
residence of the disabled person" (p. II -37).
since a disabled person may spend time at other properties other
This requirement may pose a constraint to
than their primary residence i.e. home daycare, grandma/grandpa
housing for persons with disabilities. The
home, etc.
element should analyze the requirement for
consistency with HUD/DOJ guidance and
add or modify programs as appropriate.
Amended Program No.: 2.4d
Pgs. IV -25 thru IV -26
New Program No.: 2.4e
Local Ordinances: The element is revised
New analysis added and new tables to explain how the city's Pgs. II -42 thru II -47
to provide more information about the City's
program is structured, and also to clarify the percentage of units
inclusionary housing ordinance. This
required to be affordable and analysis provided to regarding
discussion should also describe what
potential constraints. Fees for comparable programs and cities
percent of units are required to be
were added to the analysis.
affordable and analyze the requirement as a
potential constraint. In addition, although
No. HCD Comment
(May 18, 2022 Letter)
the element describes the policy as
voluntary, it appears to be mandatory for
housing development, as it is triggered
"when the developer makes the voluntary
election to request the discretionary and
valuable benefit of adding residential units"
(p. 11-35). The element should clarify what
specifically triggers the inclusionary
requirements, and analyze this as a
potential constraint, as it may disincentivize
the addition of residential units to mixed-use
properties. Finally, the in -lieu fees provided
appear high and may pose a constraint, and
the element does not clarify whether these
fees are per unit. The element must be
revised to provide specific analysis of these
potential constraints and add or modify
programs as appropriate.
Programs: As noted above, the element
requires a complete analysis of potential
governmental and nongovernmental
constraints. Depending upon the results of
that analysis, the City may need to revise or
add programs and address and remove or
mitigate any identified constraints.
City of Tustin
Draft Housing Element Resubmittal July 2022
Response to Comments Summary
Revised Housing Element
City Response (July 2022) Page No. and/or
Table No.
Tables added which demonstrate examples projects and Table Nos. II -25, II -26, II -27, II -
applicability of the ordinance. Tables provide a summary of the 28
percent of units required to be affordable and the various options
available to satisfy the requirements.
Amended Program No.: Program 1.4
Programs revised accordingly. See other rows for reference to
New or Amended Program and corresponding pages.
The following provides a summary of the program that were
amended or added as part of the July 2022 Draft Housing
Element Revisions:
Amended Program No. 1.1.h
Amended Program No.: Program 1.4
Amended Program No. 1.5 to remove CUP requirements for
residential uses citywide.
Amended Program No. 1.7b
Amended Program No. 1.2a
Amended Program No. 2.5b
Amended Program No.: 2.4d
New Program No.: 2.4e
New Program No. 2.5c
Pg. IV -11
See other rows for reference to
New or Amended Program and
corresponding pages.
No. HCD Comment
(May 18, 2022 Letter)
4. Persons with Development Disabilities:
The element is revised to analyze the
special housing needs of persons with
disabilities. However, the element must still
quantify the number of persons with
developmental disabilities and add or
modify programs as appropriate based on
the outcomes of a complete analysis.
At -Risk Units: The element is revised to
update the assessment of risk for at -risk
units and commit to new program actions
related to tenant noticing. However, the
element still does not estimate the costs of
replacement versus preservation, identify
entities with the capacity to oversee
preservation, or identify specific funding
sources that could be used to preserve the
affordability. The element must provide this
analysis for the at -risk units identified.
City of Tustin
Draft Housing Element Resubmittal July 2022
Response to Comments Summary
City Response
Amended Program No. 2.7 as requested per the Finding
described.
New Program 2.8 (Tustin Legacy)
Amended Program 3.10
New Program No. 3.11
New Program 3.12
New Program 3.13
New analysis added and new development disabilities
demographics table.
New Program 2.4e.
Revised Housing Element
(July 2022) Page No. and/or
Table No.
Pgs. II -12 thru II -16
Table No. II -15, Pg. II -14
Pg. IV -25
New analysis added; cost of preservation and replacement tables Pgs. II -25 thru II -28
added; entities with the capacity to oversee preservation were
added and also potential funding sources.
New Tables added to summarize cost of preservation and Table Nos.: 11-20, II -21
replacement.
6. Housing Element Re -Adoption: The The revised July 2022 Housing Element is tentatively scheduled
element will meet the statutory requirements for re -adoption pending HCD's review of these revisions. The
of State Housing Element Law once it has tentative public hearing dates are:
been revised and re -adopted to comply with 0 Planning Commission: September 13, 2022
the above requirements. 0 City Council: October 4, 2022
5
City of Tustin
Draft Housing Element Resubmittal July 2022
Response to Comments Summary
HCD Comment Revised Housing Element
No. (May 18, 2022 Letter) City Response (July 2022) Page No. and/or
Table No.
AB 215 and Public Participation: During
the housing element revision process, the
City must continue to engage the
community, including organizations that
represent lower-income and special needs
households, by making information regularly
available while considering and
incorporating comments where appropriate.
Please be aware, any revisions to the
element must be posted on the local
government's website and a link must be
emailed to all individuals and organizations
that have previously requested notices
relating to the local government's housing
element at least seven days before
submitting to HCD.
The City can contemplate earlier dates, depending on when it
receives HCD's determination on these latest revisions.
SB 197, which was signed into law on June 30, 2022, changed the
rezoning deadlines for jurisdictions with statutory housing element
deadlines in 2021, which applies to Tustin, a jurisdiction located in
the Southern California Association of Governments (SCAG)
region. Accordingly, the City of Tustin plans having a compliant
and adopted housing element by October 15, 2022.
The revisions summarized in this summary table were posted for
public review on the City's dedicated housing element website:
www.tustinca.org/HousingElement and a link was also emailed to
all individuals and organizations that have previously requested
notices relating to the local government's housing element,
pursuant to AB 215 for seven (7) days from July 13, 2022 through
July 19, 2022. The document continues to be posted past July 19,
2022 and City staff is consistently checking our dedicated email
inbox Housing Element(c�TustinCa.org for emailed comments
beyond these dates and is continuing to remain available to
respond to any comments that may be submitted in the future.
The City received four comments during the public review period
and a summary of each comments is provided in Attachment 1
along with the City's response. The comments did not result in any
necessary revisions to the Draft Housing Element. The revised
Housing Element complies with State law.
Footer changes with new date: "July 2022" Footer changes with new date: "July 2022" throughout document
throughout document. Table of contents and Table numbers updated, as needed.
Table of contents and Table numbers
updated, as needed.
Footer changes with new date:
"July 2022" throughout
document.
Table of contents and Table
numbers updated, as needed.
Attachment 1
2021-2029 Housing Element Update - Public Comments Received
July 13, 2022 through July 19, 2022 (A13215)
ALL Comments Received are a Public Record
Date:
Comment From:
Comment Details:
City Response:
City's RHNA sites analysis and Housing Element contain the
7/13/2022
Jackie Young
EMAIL: Does not want additional/high
required anaylsis per State law for complaint Housing
density housing in Tustin.
Elements.
EMAIL: Would like to identify opportunity
development. Requested
sites for infill deve lop a
City reponded to email with Irma Huitron's contact
7/13/2022
Parker Freiderich
current status of phone number
information and no call call back or email has been received
provided.
by the City to date.
EMAIL: Requested to be added to interest list
Repondent is already on the City's interest list and an email
7/14/2022
Ben Savill
for future updates, and wanted to review the
was send providing link to document and instructions for
recent updates.
viewing document at City Hall.
7/14/2022
Candice Longo
Center. Requested a return phone call from
regarding the next steps following a Housing Element
staff.
adoption.
EMAIL: Submitted a comment letter
representing the Southwest Carpenters Labor
7/18/2022
Steven Thong
Union, requesting that the City use the local
City acknowldeged receipt of the letter. Housing construction
workforce to benefit the community's
is not proposed as part of the draft Housing Element.
economic development and the
environment.
City of Tustin 6 1 Cycle Housing Element 2021-2029 — Response to Comments Summary Rev. 9-2-2022
Revisions requested during August 25, 2022 and September 1, 2022 meetings with HCD
Resubmittal to HCD anticipated: September 9, 2022
Comment
Page No.
Response
1. Realistic Capacity: There are inconsistencies in the Redhill
APP B
Typographical errors corrected. Numbers were
Avenue Specific Plan (RHASP) numbers of units listed in the
revised throughout Appendix B to be consistent. Site 3
narrative and other tables.
now includes 137 -unit capacity, Site 4 includes 226 -
unit capacity, and Site 5 includes 32 -unit capacity. The
capacities correspond with capacities identified in the
RHASP.
2. Governmental Constraints: City needs to include an analysis of
II -38, IV -12
An overview and analysis of RAR as a potential
the RAR process and add RAR as a potential constraint. Also
constraint to development has been included in
needs to add a program to address this potential constraint.
Section II beginning on page II -38.
In response to the analysis conducted, Action 1.4
(Voluntary Workforce Housing & Specific Plan
Reassessment) has been updated to include specific
City commitments to remove potential development
constraints related to the RAR process for the DCCSP
and RHASP.
3. AFFH: Enhancement to the Anti-Displacement/Quality Rental
IV -37, IV -39, D-
Action 3.10 was modified to include geographic target.
Housing/Tenant Protection programs are needed. Also connect
94
Action 3.11 was updated to include specific actions to
or refer to other programs that would complement the
improve housing conditions.
programs.
AFFH Fair Housing Table was updated to include
specific actions for implementing Actions 3.10 and
3.11. Additionally, detail was added regarding the
connection between the various programs and
implementation/quantified objectives.
4. ADU/SB9 Program: Enhance the program by adding potential
D-93
Program 1.7b was updated to describe fast tracking
fee waiver, fast tracking permit processing, and technical
options that will be considered for the ADU
assistance.
accelerator program. Actions are further described in
the AFFH Fair Housing Table.
ATTACHMENT C
DRAFT HOUSING ELEMENT — TRACKED
CHANGES (SEPTEMBER 2022)
Also available at:
www.tustinca.org/HousingElement
Draft Housing
Element
TUSTIN
GENERAL PLAN
MARCH -SEPTEMBER 2022
This page intentionally left blank.
CITY OF TUSTIN HOUSING ELEMENT
GENERAL PLAN SEPTEMBER 2022
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 -196
Summary Of Housing Issues II -282
Housing Constraints II -292-3
Housing Opportunities II -8873
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
k1 ri ri 01931"111
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
GENERAL PLAN
WA
IV -1
Housing Programs
IV -1
HOUSING ELEMENT
SEPTEMBER 2022
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 II4EMPLOYMENT 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 -165 TUSTIN EMPLOYMENT IN AGRICULTURE II -174
TABLE II -176 AT -RISK UNITS II -196
TABLE II -187 ASSISTED HOUSING INVENTORY II -20477
TABLE II -198 ORANGE COUNTY FAIR MARKET RENT II -230
TABLE II -20 COST OF PRESERVATION II -24
TABLE II -21 COST OF REPLACEMENT II -27
TABLE II -229 NEW AND RESALE PRICE OF HOMES AND CONDOMINUMSII-3126
TABLE II -230 AVERAGE RENTAL RATES 2021 II -3226
TABLE II -244 SUMMARY OF RESIDENTIAL ZONING REGULATIONS II -352
TABLE II -25 INCLUSIONARY HOUSING OPTIONS FOR RESIDENTIAL PROJECTS WITH
FEWER THAN 20 UNITS II -46
TABLE II -26 FEE OPTIONS FOR RESIDENTIAL PROTECTS WITH FEWER THAN 20 UNITS
II -47
CITY OF TUSTIN
GENERAL PLAN
ill
HOUSING ELEMENT
SEPTEMBER 2022
TABLE II -27 FEE PER UNIT FOR RESIDENTIAL PROTECTS WITH FEWER THAN 20 UNITS
II -47
TABLE II -28 INCLUSIONARY HOUSING FEE COMPARISON II -49
TABLE II -229 SUMMARY OF HOMELESS ACCOMODATION ZONING
REGULATIONS II -5743
TABLE II -3023 MONTHLY VACANCY RATE VILLAGE OF HOPE II -594 5
TABLE II -3124 MONTHLY VACANCY TUSTIN TEMPORARY EMERGENCY
SHELTER II -6046
TABLE II -3225 EMERGENCY SHELTER/TRANSITIONAL HOUSING
FACILITIES/HOMELESS RESOURCES II -6147
TABLE II -33A DEVELOPMENT FEES II -67
III:1j1�QC3Gts7��]�►�hLIC�aC�M�hl�Zkr'�
TABLE II -3427 HOUSING TYPES AND PERMIT PROCESSING REQUIREMENTS II -7855
TABLE II -3528 PROJECT BUILDING PERMIT TIMEFRAME II -7555
TABLE II -3629 QUANTIFIED OBJECTIVES II -7288
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
GENERAL PLAN
IPA
HOUSING ELEMENT
SEPTEMBER 2022
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 JULY" f °r== R T4 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 II and Appendix D for additional information on the City's demographic
profile.
SCOPE AND CONTENT OF ELEMENT
The State Legislature recognizes the role of the local general plan, and particularly
the Housing Element, in implementing statewide housing goals. Furthermore, the
Legislature emphasizes the promotion of and affirmatively furthering fair housing
opportunities throughout the State, regional and local levels of government and for
all economic segments of a community. The Legislature's major concerns with
regard to the preparation of Housing Elements are:
o Recognition by local governments of their responsibility to consider
economic, environmental and fiscal factors and community goals set forth in
the General Plan in contributing to the attainment of State housing goals;
o Recognition of responsibility by the State and local governments to utilize
vested powers to facilitate, improve and ensure the provision adequate
housing for all economic segments within a community;
o Cooperative efforts by all levels of government to provide housing to low -
and moderate -income households;
o Cooperative participation of government and the private sector in an effort to
expand housing opportunities and accommodate housing needs; and
o Designating and maintaining a supply of land and adequate suitable sites
suitable, feasible and available for housing development.
The State Department of Housing and Community Development (HCD) set forth
specific requirements regarding the scope and content of housing elements.
CONSISTENCY WITH STATE PLANNING LAW
The preparation of the City's Housing Element is guided by and must conform to
Section 65580 et seq. of the California Government Code. In the introduction of these
Government Code sections, the Legislature establishes a policy that the availability
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN I-2 JULY" f °r== R T4 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 JULY" f °r== R T4 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 JULY" f °r== R T4 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 JULY" f °r== R T4 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
policies.
CITY OF TUSTIN
GENERAL PLAN
for the City to consider utilizing skilled and trained workforce
DRAFT HOUSING ELEMENT
I-6 JULY1ra °�� RC14 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 JULY" f °r== R T4 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 JULY" f °r== R T4 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 JULY" f °r== R T4 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
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
Percent Growth
Jurisdiction
20101
20142
20183
2030
2035
2040
2045
2014-2018
2010-2018
Tustin
75,540
80,617
79,787
-1.0%
5.6%
Anaheim
87,932
90,576
92,564
1.5%
4.7%
336,265
346,961
352,018
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
-0.1%
2.2%
325,483
334,924
332,727
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
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
Percent Change
2025
2030
2035
2040
2045
(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 1 42,448 1 100.0%
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 --11- 4
EMPLOYMENT PROTECTION IN TUSTIN. CA 2016-2040
Source: Center for Demographic Research at Cal State Fullerton - OCP, 2018
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -3 SEPTEMBER 2022
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—_11- 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; 1745217th 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 -_11- 6
JOBS -HOUSING BALANCE
CITY OF TUSTIN, ORANGE COUNTY, SCAG REGION, 2019
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
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.
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- 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
Cost Burden
Owner
Renter
Total
Cost Burden less -than or = 30%
8,150
>30% to less than or =
21870
3,345
1,540
1,715
3,340
3,915
50% AMI
3,360
4,840
Cost Burden not available
90
150
240
Household Income
11,375
13,595
26,185
Source: Comprehensive Housing Affordability Strategy
(CHAS), 2013-2017 estimates
>50% to less than or =
2,875
2,710
640
590
4,840
4,955
80% AMI
Household Income
>80% to less than or =
11125
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 -_11- 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 II -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 II -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 --Il- 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 II -12
below, in the City of Tustin, 64.6 percent, or 2,913, of all senior (65 years or older)
headed households were owners. In comparison, 35.4 percent, or 1,596, of all senior -
headed households were renters. However, countywide 75.7 percent of senior -
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
Race/Ethnicity
SENIOR HOUSEHOLDS BY TENURE IN TUSTIN, CA 2018
Percent
White, Non -Hispanic
Owner costs
Gross rent
Black, Non -Hispanic
as a
as a
Total Elderly Senior-
percentage
percentage
Jurisdiction Headed Owner
Renter of
of
Population
Households
household
household
Two+ Races, Non -Hispanic
income
income
Other, Non -Hispanic
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 auantifv 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
difficulty
2,125
6.7%
1,147
11.8%
Total Disability
5,238
6.6%
2,291
28.4%
Total Population
79,667
8,057
Race/Ethnici!y
White alone
Black or African American
3,294
138
8.5%
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 II -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. Additional infor-matie
is also pfavided in Appendix P.
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, pilepsy, 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 housingfor or the
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -13 SEPTEMBER 2022
developmentally disabled is the transition from the person's living situation
as a child to an appropriate level of independence as an adult.
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 -178 years 18+ years
TOTAL
92780789 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), 20210
I 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
AAs identified by RCOC, among Tustin residents served by the regional center
approximately 86X 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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -14 SEPTEMBER 2022
adults and safe, affordable housing options were needed. The regional centers have
identified a number of community-based housing_Ues 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,
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, Tune 2020. 5 Regional Center of
Orange County, "Housing for People with Developmental Disabilities in
Orange County," lanuary 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 hypes 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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -15 SEPTEMBER 2022
consumer products that are easy to use and widely acceptable. By Tanuary 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
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -16 SEPTEMBER 2022
full-time, year-round. Tustin is an urbanized community with no undeveloped
parcels zoned for agriculture as a principal use; however, some residential zones
allow a range of agriculture and related uses. However, some farmworkers may
commute to nearby farming operations outside of the city.
TABLE II -156
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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -17 SEPTEMBER 2022
In accordance with HUD's Continuum of Care (CoC) Program, Orange County's 2019
Sheltered Point In Time Count, Everyone Counts, is a biennial unsheltered count and
an annual sheltered count of all individuals experiencing homelessness in the
community on a single point in time, took place the night of Tuesday, January 22,
2019. The count revealed that 6,860 individuals in the County were experiencing
homelessness. Although some individuals may identify with more than one
subpopulation of the individuals counted, 52.02 percent were chronically homeless,
33.73 percent had substance use issues, 31.17 percent had a physical disability, 26.82
percent had mental health issues, 14.03 percent has a developmental disability, 9.50
percent experienced domestic violence, and 1.80 percent were HIV/AIDS positive.
The City of Tustin had 359 individuals total, 95 unsheltered and 264 sheltered.
There are numerous factors that contribute to homelessness in Tustin and Orange
County. The known causes of homelessness include unemployment, limited skills,
and a breakdown in the family as a social and economic unit. Additionally, cutbacks
in social service programs and the de -institutionalization of the mentally ill have
contributed to the homeless population. A new trend, however, is emerging as a
significant contributing element to homelessness: a fast-growing lack of affordable
housing, which could exacerbate any of the above conditions, but may increasingly
become a standalone cause of homelessness.
Homelessness is further discussed in Appendix D.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -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 -167 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 I1-178 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 -167
AT -RISK UNITS, TUSTIN, CA
Very- Low-
Moderate-
Expiration
At -
Project Name Low Income
Income
Total Units
Date
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 -387
ASSISTED HOUSING INVENTORY, TUSTIN, CA
Type/ Length
Tenant
Project Name
Owner:
Federal,
of
Earliest
T e
Type
Date
Address
Name,
State, or
Type(s) of Gov't
Affordability
Potential
# of
(i.e.,
Bedroom
Built
Condition
Address,
Local
Assistance
Controls
Conversion
Units
Elderly,
Mix
(if
(if known)
Tel. #
(including
Date(s)
Family)
known)
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. 6f,
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.
7-32-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
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
II -20 SEPTEMBER 2022
TABLE II -387
ASSISTED HOUSING INVENTORY, TUSTIN, CA
Type/ Length
Tenant
Project Name
Owner:
Federal,
of
Earliest
Type
Date
Address
Name,
State, or
Type(s) of Gov't
Affordability
Potential
# of
(ie.,
.
Bedroom
Built
Condition
Address,
Local
Assistance
Controls
Conversion
Units
Elderly,
Mix
(if
(if known)
Tel. #
(including
Date(s)
Family)
known)
Sec. 8)
Tustin, CA
92782
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
Local
Density Bonus
Income
October/207
37
Family
21-1br
2015
Excellent
16000 Legacy
131 Theory
restricted
0
16-2br
Road
Irvine, CA 92617
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -21 SEPTEMBER 2022
TABLE II -387
ASSISTED HOUSING INVENTORY, TUSTIN, CA
Type/ Length
Tenant
Project Name
Owner:
Federal,
of
Earliest
Type
Date
Address
Name,
State, or
Type(s) of Gov't
Affordability
Potential
# of
(ie.,
.
Bedroom
Built
Condition
Address,
Local
Assistance
Controls
Conversion
Units
Elderly,
Mix
(if
(if known)
Tel. #
(including
Date(s)
Family)
known)
Sec. 8)
Tustin, CA
92782
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
1 DDA - 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- 498
ORANGE COUNTY FAIR MARKET RENT, 2020-2021
Year Efficiency One- Two- Three- Four -
Bedroom Bedroom Bedroom Bedroom
FY 2021 $1,678 $1,888 $2,331 $3,227 $3,716
FY 2020 $1,563 $1,785 $2,216 $3,098 $3,578
Source: HUD User FY 2021 Fair Market Rent Documentation System
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -23 SEPTEMBER 2022
This section includes an analysispotential rent subsidies needed to preserve the
City's at -risk affordable housing stock. The analysis assumes that all housing units
would be occupied beery 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 subsidv amount was calculated by subtracting the total monthlv 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
Total Monthly
Rent Income
Supported by
Housing Cost $299,653 $229,213 $80,731 $609,596
of Veru
Income
Households
Total Monthly
Rent Allowed $438,354 $374,732 $126,231 $939,317
by Fair Market
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
TABLE II- 20
COST OF PRESERVATION
Chatham Westchester Flanders
Project Units
Total
Village Park Pointe
1 br
126 17 -
143
2 br
86 93 50
229
3 br
39 3
42
Total Monthly
Rent Income
Supported by
Housing Cost $299,653 $229,213 $80,731 $609,596
of Veru
Income
Households
Total Monthly
Rent Allowed $438,354 $374,732 $126,231 $939,317
by Fair Market
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 Coun!y pursuant to California Government Code
Section 65863.11:
• Neighborhood Housing
Services of Orange Counted
• Century Housing Corporation
• Civic Center Barrio Housing
Corp.
• Long Beach Affordable
Housing Coalition, Inc
• Housing Corporation of
AmPric .q
• Nexus for Affordable Housing
• Orange Housing Development
Corporation
• Riverside Chartable
Corporation
• Hart Community Homes
• Keller & Company
• Poker Flats LLC
• Coalition for Economic
Survival
• A Community of Friends
• CSI Support & Development
Services
• ROEM Development
Corporation
• City of Newport Beach
• Abbey Road Inc.
• Jamboree Housing
Corporation
• Innovative Housing
Opportunities, Inc.
• L + M Fund Management LLC
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 owners behalf to utilize the incentives found in this
option.
Table II -176 includes at -risk units within the city for the 6th planning cycle (2021-2029).
Table II -178 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 maintainingthe he 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
charees, developer fees, and other miscellaneous soft costs.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -26 SEPTEMBER 2022
Cost per Unit JIQ8 510 K210-0-90 K26,000 J165,503
Source: Tamboree 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
TABLE II- 21
COST OF REPLACEMENT
Year
Project 1
Project 2
Project 3Average
10861 Acacia
16790 S. Harbor
Address
3312 W. First St. -
Pkwy
Blvd.
-
C
Garden Grove
Fountain Valley
Santa Ana -
Units
47
50
75 -
Total
Development
$19.2 mil
$29.6 mil
$29.7 mil =
Cost per Unit JIQ8 510 K210-0-90 K26,000 J165,503
Source: Tamboree 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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -29 SEPTEMBER 2022
are most attributed to a reduction in land costs; when that cost is spread on a per unit
basis.
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
inancing:The availability of financing affects a persons 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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -30 SEPTEMBER 2022
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
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-221-9 and--II-203).
TABLE II- 22-9
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%
92843
$431,000
$560,000
-22.9%
Grove
92844
$425,000
$485,000
-12.4%
92845
$749,000
$659,000
+13.7%
92602
$1,300,000
$1,243,500
+4.5%
92603
$970,000
$1,087,500
-10.8%
92604
$811,500
$750,000
+8.2%
92606
$815,000
$799,500
+1.9%
Irvine
92612
$686,500
$663,500
+3.5%
92614
$820,500
$730,000
+12.4%
92618
$920,000
$966,750
-4.8%
92620
$954,500
$1,030,000
-7.3%
92865
$755,000
$640,000
+18.0%
92866
$735,000
$738,500
-0.5%
Orange
92867
$737,500
$737,000
+0.1%
92868
$550,000
$472,500
+16.4%
92869
$655,250
$670,000
-2.2%
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -31 SEPTEMBER 2022
TABLE II- 22-9
NEW AND RESALE PRICE OF HOMES AND CONDOMINIUMS
TUSTIN AND NEIGHBORING JURISDICTIONS 2020
City
Zip Code
Median Home
Price- Q2 20201
Median Home
Price- Q2 20191
% Change from
2019
Average
Rent
92701
$300,000
$380,000
-21.1%
1 bedroom
92703
$575,000
$493,000
+16.6%
6,325
92704
$550,000
$510,000
+7.8%
Santa Ana
92705
$1,060,0002
$930,0002
+17.2%
$3,716
92706
$730,000
$650,000
+12.3%
Total
92707
$497,500
$500,000
-0.5%
'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 person's debt -to -
income ratio, cash available for down payment, and credit history, when determining
a maximum loan amount. Many financial institutions are willing to significantly
decrease down payment requirements and increase loan amounts to persons with
good credit rating.
TABLE II- 230
AVERAGE RENTAL RATES 2021 -1sT QUARTER
CITY OF TUSTIN
Number of Bedrooms
Number of
Units
Average Square
Footage
Average
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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -32 SEPTEMBER 2022
Governmental Constraints
In addition to market factors, housing affordability is also affected by factors in the
public sector. Local policies and land use regulations can impact the price and
availability of housing, and the provision of affordable housing.
Land Use Controls
In efforts to protect the public's health, safety, and welfare, government agencies may
place administrative constraints on growth through the adoption and
implementation of land use plans and ordinances. The General Plan may restrict
growth if only limited areas are set aside for residential land uses, and if higher
residential densities are not accommodated. The zoning ordinance may impose
further restrictions if development standards are too rigid, or if zoning designations
do not conform to existing land uses. On the contrary, the zoning ordinance may also
be utilized as a tool in encouraging and directing affordable housing, i.e., relaxed
development standards, higher density, provision of incentives (waiver of fees,
expedited review process, etc.) in exchange of the production of affordable housing,
etc.
Residential Land Use Designations
Tustin's existing zoning ordinance allows for a range of residential densities from an
effective density of 4.35 units per net acre in the E-4 Residential Estate District to 24.9
units per net acre in the R-3 Multiple Family Residential District. Tustin s General
Plan allows a maximum of seven (7) units per acre with effective density of 5.61
dwelling units per acre within the Low -Density Residential land use to a maximum
of 25 units per acre with effective density of 21.53 dwelling units per acre within High
Density Residential land use. Ten (10) units per net acre are also permitted in the
MHP Mobile home Park District (see Table I1-244).
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -33 SEPTEMBER 2022
formal Design Review is required and approval by the Planning Commission.
Approximate application processing time can range from 3 months, for smaller
projects, to 9 months, for larger projects depending on if there is a subdivision
included with the application and the level of environmental review.
Parking requirements could be a potential constraint for single-family and multi-
family residential development. Required parking for multi -family projects is two
covered spaces, in either a garage or carport, for each dwelling unit, plus one
unassigned guest space for every four units. For Tustin, this is not considered overly
excessive given the older age of many of the existing multiple family residential units
and the fact that many units or complexes have non -conforming parking. Parking
requirements for single-family residential includes two -car garage per dwelling, or
three -car garage per dwelling with five or more bedrooms. Parking is a significant
area of concern within several areas of the City, especially in the higher -density
residential areas.
At the time of this update, the City is currently reviewing the City's permit parking
requirements and overall process. A new program has been included in this Housing
Element, Program 1.2, 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_4
SUMMARY OF RESIDENTIAL ZONING REGULATIONS
CITY OF TUSTIN
Zoning
Minimum
Density
Lot
Building
Front
Interior
Corner
Rear
Parking
Lot Area
Max.
Coverage
Height
Yard
Side Yard
Side Yard
Yard
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
II -35 SEPTEMBER 2022
TABLE— II -241
SUMMARY OF RESIDENTIAL ZONING REGULATIONS
CITY OF TUSTIN
Zoning
Minimum
Density
Lot
Building
Front
Interior
Corner
Rear
Parking
Lot Area
Max.
Coverage
Height
Yard
Side Yard
Side Yard
Yard
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
II -36 SEPTEMBER 2022
TABLE— II -241
SUMMARY OF RESIDENTIAL ZONING REGULATIONS
CITY OF TUSTIN
Zoning
Minimum
Lot Area
Density
Max.
du/ac
Lot
Coverage
Building
Height
Front
Yard
Interior
Side Yard
Corner
Side Yard
Rear
Yard
Parking
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
Incl.
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
(med)
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. These pians incl de-
• 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.
The Red Hill Avenue Specific Plan (RHASP) introduced mixed-use to the area and
similarly identified the potential for 500 new units in conjunction with the RAR
review process. 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. No • its have been eenstr-ueted i this area
to date3 however, thefe is an applieation pending for a development project eurvendy
under- Eensider-ation w44n this area-.
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 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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -38 SEPTEMBER 2022
streamlined process for developers to benefit by tiering of the already certified
environmental studies. Additional units can be added in the future with the
appropriate environmental review (i.e. supplemental or addendum to EIRE
RAR Review Process Overview
The Specific Plan provides a two-step residential allocation reservation ("RAR")
application process: (1)apreliminary 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 substantiallv complies with or has obtained avvroval 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).
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 massin&.
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 Plari s Program EIR.
4) The overall project meets the findings for Design Review per Tustin Cite
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 Programs) to address such a potential for a
housing development constraint.
The RAR process and structure was created with public input duringthe he 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 gEypotential 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 (formally 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 II -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
(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 tier unit. which is well below other cities in Orange Countv. If this is translated
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -45 SEPTEMBER 2022
to per square foot cost, with an average size of unit being 1,300 square feet, Tustin s
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 PROTECTS WITH FEWER
THAN 20 UNITS
ir
Options for Projeuls with 20 or more resldanGal units
t=rample fns iafeurati-
114 "Base UniUm plu52} Density 60Tu5 UnN =197 Tow {1RItF
A0 new res+drntrpu prpjcCti 8hnfi ncfude ❑,UPrdafC units.
Requirement
Cokufotiorls on the number, of unrts is bored on the numbfr o/
Calculation
ae-she
in -lieu fee
"6t5e un.t5 the prCj,,r
Affordable
Units
On Rx 89923
15% of the `base units" 5HAii. BE AFFORDABLE
=116 - n%
17
Not Ap pikable
optlon {a}(1)
6%of 15% h.0 be effprdubk to very tow .me hausehpMs
=114' 6%
+
4.5%ol".%j4W04e o/]4ropbk
=114'4.5%
s
4.5% al 15%sholf be p/JmOaDk fOrnpderors`rrxome howerwfds
=114'4.5%
5
OR
On-site Option (1101
12.3% of the'baw unlW SHALL 9E AMROA.rc
-114-12A%
14
Nd1AFWi1ta
]S%gJ 1).S%snnfJf j/nrrmpip rn very fpw o'.rnrrrt rtswlehnW�
v114'7.5%
9
5% of 12.53 shelfbe.1,1odvbfe to nwdrote+rnccme housebufds
=114'%'%
6.
OR
69923
On ur Of6
'OPtwn
5% of the -baae unite" SMALL BE AfFOROAaL1 to very low
°114 5%
6
$ 786,557
sne
(a1(311a)
income housholds plus payment of do In lieu fee (see below}
OR
69923
On of OH-
'C]pti6tl
10% of the 'base unhs SHALL BE AFFORDABLE to low Income
=114' 10%
I.d
3 78fi,fi57
rite
housfoldr plus payment of an kAhw Fee }sec below)
Opl'ons {a){3)(aj and (di{3){L} rcgaire payment of
89923{bii Y)
an In -lieu fee Calculated by'
_ $13,801.. Half the number of base units
=$13A01 x57
$ 7aa.667
NOtes:Per TCC 89424, m computing
ibe total number of volunrary wondoroe housMg Irwtntla+e pr[gram urks rewned in a reskentlal Project, fractions;ball he
ru4adM up to the nest whole number.
A:vcraga In- fuer anis
t�eu lee ins Cttgi
projcCt
=$786,657/ $ 5.742
137
= 5796,557 / 5 5,742
137
For comparison, in La Habra. Der a city staff report, a 30 -unit Droiect 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
beim $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 PROTECTS WITH FEWER THAN 20 UNITS
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 PROTECTS WITH FEWER THAN 20 UNITS
2022 Tustin
In -Lieu Fee Per Unit
rorproject with fewer than 20 units
In -lieu per unit reduced for
smaller projects
1-4 units
$9,200
Options for Residential projects with fewer than 20 units,
$10,350
10-14 units
The primary means of complying shall be the provision of on-site units.
15-19 units
$12,651
However, a developer may Only satisfy She recluilement5 by means Of an
on-site
39925la}
alternative to on-site voluntary workforce housing incentive program
units in accordance with the requirements and procedures of this
Section 119923.
Requirement may be satisfied, in whole or in part, by the construction
off-site
69925(h1
of new units, orthe conversion of existing market rate units to voluntary
workforce housing incentive program units, offsite within the City's
Jurisdictional boundary.
in -lieu
B9925 (C i
Requirement may be wtisRed 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 satisried, in whole Or in part, by an alternative
139925(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 PROTECTS WITH FEWER THAN 20 UNITS
2022 Tustin
In -Lieu Fee Per Unit
rorproject 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 nroiects are not cost burdened. In smaller nroiects, 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.
MEN
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -47 SEPTEMBER 2022
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
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
City
Ineludible y
Hooding
OrdinanceMhrAd
licability
'uMb
Affordable
gegointments
I. -Lie. Fee Allowred3
1". Fee
R.AOUMlS u�
W test.
Mandatory
Projecla With
15%.Rota]
Yes
PBV', Payment V per unit cost not
htlo:!lwww.lanabrxllv.comlOocmment[dn[err
View/11435/0rd-1333?Ohdld=
10 ur more
units
provided on-site"are, on [he
units
valual of per unit)
Example:
Assumed valuate, ",,,it Is $200AW
30 oohs proposed
15% required to be affordable 15 units)
$200,000, 5=$1 million
Hindu ton
Mandatary
Pr jectswlth
10%.Ronal
Yesfar%jets WRh9or
Three Unils$9,430/unit
h�s(/hyntingyonbeacly)l gls[ar.comNieWashy7M=f
&IO=7228132&Gil@=E3A.37144-50r58yC01-AElC-
Beach
Sar more
units (Pental or
fewer units
• Four Unit, W fiAV/unit
SF0329000361
units
kr-Sale)
• Five Units$11,780/unit
Fee is based on slidles scale
. Sse Unlis$12,9FA/unit
• S— Units 514,140/unit
MCPs:Ilwww.asotleus/roles/hunliat¢lonheattr./view.P
• Eight Units 515,330/unit
ho?[Dolt-zonln¢ eatle-23-230-I-230 26tLlrames.on
• Nine Unit,$16,500/unit
Ingle.
Mandatory
Project with
15% of fetal
Yes for Project will 50 or
53],000 per un h poor to 2007,
CHAFr€n2-3.-AFFOPnARLF HOUSING
Sn or more
winds
less unlit
Teo Ms. on formula.
IMPLEMENTATIt1N PPOCPm14F l Zoning l lrvine CAI
unit
Sent. Mi
Mandatory
Project with$
Farliale 109E
Yes
• P,.)—with S to 20 units:$5 per 5F
l.tskellsar
of total units
of habitable spare
SOa_1[mci^
are
formotlerate
Projects wish 20, units $5 per SF of
2EOP3251
income
ha bitab le space
For Mor, 15%
Effective October 1, 2021 cast shall
of, ralunits
bes reverted to 515 per 5F of
MrBow-Income
habitable. space
10%very
le—
La Hb.
Mandatary
Prjeclswith
15% of wtal
Yes
Tau; Paymenl of per or cost taihtim:!/www.lahabracitv.mMVxumentCentev/
View111435/Ord183326itl1d=
]Owmore
units
provided on-site lbased an [he
units
val.etinn of per anal
Example:
a .nail valuation per unit Is 52(1
30 wits proposed
15% renal red w be affordable I5 units)
5200,0 5=$1 million
Hundrel
Mandatory
P Jetaswith
10% of total
Yes far P1.1—with9 or
• Three Unils$9,430/unit
h1IDs l/huniln¢lanfreach.leehs[ar.cpmNiew.asM1e?M=F
&10=722F1132&GAIL=F3A3714n-5060-aCOl-AElC-
eexit
Sar more
units faemal or
I— units
• Four Unit,$10,517p/unit
8FV3290il
units
For -Solei
• Five Units$11,7801unit
Far is based on slldleg-le
• Ste VM1lta $12.96u/unit
• Sexen Units $14,140/unit
hltos:/lwww.ornde us/codes/humfxletonheoclYvlew.o
• Eight Units$15,330/unit
hh7tapsmnonln¢ mtlr23-P30.i-230 26%ImmeTon
• N19¢Units $15,5001unt
Irvine
Mandatary
Prjectwith
15% of total
Yes for Pro9ed with 50 or
$ 17.000 pet un R prbr to 2007.
CHARTER 2-3.- A11010A0LE 40 USIN6
50w mare
units
less urlts
T80 based on formula.
lMPLEMENTATIONPPOCEOU RE Zan I re I CAI
units
M n
Salla M¢
Mandatory
Prject whh5
Far Safe: 30%
Yea
• Pro)e� "It 5 to 20 units: S5 per SF
•aotential
lots/un",
of total units
ofhabinblespace
shanees In
are
lar moderale
• Projects with 202 units $5 per SF of
2[011[211
Ino9me
habil space
For Rl 15%
• Effee- Ortmber 1, 2023 cost shall
of total units
be reversed to 515 per 5F of
for few-I.nmme
Wbitab3e space
OR
10%Very low-
incmne
Based on the forezoinz• the based upon the foregoing, the Citv'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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -49 SEPTEMBER 2022
completed report. The City has amended Program 1.4 to incorporate changes to
resvond to identified constraints resulting from the studv."
pT-ogfam has been highly benefieial in affording the City resources to impleffie
affordable housing pfojeets.
Housing for Persons with Disabilities/Reasonable Accommodation
As discussed in previously and shown in Table II -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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -50 SEPTEMBER 2022
The City also requires new multi -family housing units and apartment conversions to
condominiums to comply with State specifications pursuant to SB 520 for
accommodation of the disabled.
A Residential Care facility serving six (6) or fewer persons is a permitted use in all
residential districts. The City's Zoning Ordinance does not contain maximum
concentration requirements for a residential care facility serving six (6) or fewer
persons. Facilities serving more than six (6) persons are conditionally permitted
within Planned Development District (P -D), Multiple Family Residential District (R-
3), Suburban Residential District (R4), and Retail Commercial District (C-1).
It is the policy of the City of Tustin to comply with the federal Fair Housing
Amendments Act of 1988 and the California Fair Employment and Housing Act to
provide individuals with disabilities reasonable accommodation in regulations and
procedures to ensure equal access to housing and to facilitate the development of
housing for individuals with disabilities. Tustin City Code Section 9278, Reasonable
Accommodation, addresses this and establishes a process for individuals with
disabilities to make requests for reasonable accommodation when reasonable
accommodation is warranted based upon sufficient evidence.
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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -51 SEPTEMBER 2022
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
• 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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -52 SEPTEMBER 2022
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 proper!y is the primary residence of the disabled person.
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 pend 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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -53 SEPTEMBER 2022
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.
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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -54 SEPTEMBER 2022
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
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -55 SEPTEMBER 2022
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
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 -282). 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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -56 SEPTEMBER 2022
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 -229 summarizes zoning regulations for homeless accommodation.
TABLE II -229
properties
SUMMARY OF HOMELESS ACCOMMODATION ZONING REGULATIONS
Permitted/
Supportive housing Permitted
Housing Type Conditionally
Zoning
Permitted
Emergency Shelters Permitted
Planning Area 3 of Tustin
All residentially zoned
Legacy Specific Plan
properties
Planning Area 3 of Tustin
Transitional Home Permitted
Legacy Specific Plan;All
residentially zoned
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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -57 SEPTEMBER 2022
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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -57 SEPTEMBER 2022
• 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.
• 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 -302-3 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.
i 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 -58 SEPTEMBER 2022
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 -3124 provides monthly vacancy rate for TTES.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -59 SEPTEMBER 2022
TABLE II -3023
MONTHLY VACANCY RATE VILLAGE OF HOPE (2021)
Month
Average
Monthly
Bed
Occupancy
Total
Available
Beds'
Remaining Vacancy Rate
Beds
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%
i 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 -3124 provides monthly vacancy rate for TTES.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -59 SEPTEMBER 2022
TABLE II -3124
MONTHLY VACANCY RATE TUSTIN TEMPORARY EMERGENCY SHELTER (2021)
Average Total
Month Monthly Available Remaining Vacancy Rate
^ Bed Beds* Beds
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 11-60 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 -3225, 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 -3225
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
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.
Tustin Presbyterian
CITY OF TUSTIN
GENERAL PLAN
Collects food supplies and distributes the
food to various organizations involved in
providing homeless services.
DRAFT HOUSING ELEMENT
II -61 SEPTEMBER 2022
Human Options
TABLE II -322-5
EMERGENCY SHELTER/TRANSITIONAL HOUSING FACILITIES/HOMELESS
operated by Human Options
RESOURCES
Facility
Services Provided
Aldersgate
Refers interested persons to Ecumenical
Distributes food supplies to needy
Services Alliance in Santa Ana.
Salvation Army
Six (6) transitional units at Tustin Field I
Provides emergency funding grants to
operated by Salvation Army.
address immediate and critical needs of
Acquisition of 16 transitional units in Buena
veterans and their families, focusing on
Park operated by Salvation Army. The City
Salvation Army
assisted in acquisition and contributed grant
Offers low -thresholds emergency shelter
funds to acquire the units.
services with case management services.
Fourteen (14) transitional units at Columbus
Families Forward
Grove operated by Families Forward,
Veterans Outpost offers transitional housing
formerly Irvine Temporary Housing in
for up to 71 people, along with veteran -
Irvine.
specific services.
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-2-6a33a, II-2,6b33b, and Figure 1I-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 11 -26a -32a and II_ -2632b include park,
e
school, transportation fees. --These fees are pass-through fees required by the
respective agencies.—_Impact fes are governed by State law to demonstrate a nexus
between development and potential impacts.
Planning and Permitting fees (Figure 11-2) 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: $--s-_ 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
FEE TYPE
New Construction
Tax
Park Fees
TABLE II -26A 33A
DEVELOPMENT FEES
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
Townhouses, or one (1) in each unit
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
Hotel or motel rental
unit without a kitchen
When a public park or public recreational facility
is not provided within a proposed residential
subdivision, the subdivision is less than fifty (50)
parcels, or the project is a conversion of an
existing apartment complex to a multi -owner
occupancy not exempted in the Subdivision
Code, a park fee will be required.
$100.00 per unit
The fee is calculated on a per unit basis for each
project, reflecting the fair market value of land
required for park purposes. The value shall be
determined by a Master Appraisal Institute
(MAI) appraiser acceptable to the City and the
expense of the subdivider.
DCCSP: The fee shall be based upon the fair
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
A park fee is also required for non- subdivisions
within the Downtown CommercialCore Specific
Plan (DCCSP) and the Red Hill Avenue Specific
Plan (RHASP).
RHASP: Calculate the amount of land which
would otherwise --be required for dedication:
(# of Dwellings) x (0.003 Acre/Person) x
(2.24 Person/ Dwelling Unit)
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -68 SEPTEMBER 2022
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
Affordable HousingFees
(Only applicable to
RHASP and DCCSP)
CITY OF TUSTIN
GENERAL PLAN
Any residential project
providing voluntary workforce
housing incentive units
pursuant to Subsection (a)(3) of
Tustin City Code B9923 must
also pay the City a voluntary
workforce housing incentive
program in -lieu fee calculated
by either:
Effective January 2022 -
January 2023 Fee = $13,801
per unit
1. Multiplying the voluntary workforce housing incentive
program in -lieu fee by one-half (1/2) the number of base
unitsprovided on-site
(In -Lieu Fee) x (Base Units- Provided On-site)
2
2. Multiplying the voluntary workforce housing incentive
program in -lieu fee by one-half (1/2) the residential project's
totalsquare feet of residential area
(In -Lieu Fee) x (Residential Project's Total Sq. Ft. of Residential
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.
DRAFT HOUSING ELEMENT
II -69 SEPTEMBER 2022
TABLE II-26B33B
IMPACT FEES
FEE TYPE
LAND USE
IMPACT FEE RATE
Single Family
$6,056 per unit
Transportation
Zone A Multi -Family
$3,536 per unit
Corridor Fees
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
Affordable HousingFees
(Only applicable to
RHASP and DCCSP)
CITY OF TUSTIN
GENERAL PLAN
Any residential project
providing voluntary workforce
housing incentive units
pursuant to Subsection (a)(3) of
Tustin City Code B9923 must
also pay the City a voluntary
workforce housing incentive
program in -lieu fee calculated
by either:
Effective January 2022 -
January 2023 Fee = $13,801
per unit
1. Multiplying the voluntary workforce housing incentive
program in -lieu fee by one-half (1/2) the number of base
unitsprovided on-site
(In -Lieu Fee) x (Base Units- Provided On-site)
2
2. Multiplying the voluntary workforce housing incentive
program in -lieu fee by one-half (1/2) the residential project's
totalsquare feet of residential area
(In -Lieu Fee) x (Residential Project's Total Sq. Ft. of Residential
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.
DRAFT HOUSING ELEMENT
II -69 SEPTEMBER 2022
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -70 SEPTEMBER 2022
Figure II -1. Impact Fee Zones
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -71 SEPTEMBER 2022
Figure- _II -2. Planning Fees
NO I CASE TYPE FEE
NO. :CASE TYPE I FEE
NO. CASE TYPE FEE
Cor i ona l Use permits. and Amendmems
Inning Administrator Review
Signage
Adm i ni stmt ive
1
Major
$5,000 Deposit
24
Adjustment/Ml nor
$500 Deposit
46
Tem porary Sign Permit $SSU Fee
Amendment
2
Minn,
$2,500 Deposit
General Plan Amendments
47
Master Sign Program $500 Deposit
3
ABC License
$1,000 Deposit
25
Major General
$18,008
48
Sign Cade Excption $500 Fee
Plan Am on dm ant
Deposit
4
Soil Remediation
$1,000 Deposit
26
Minor General
$5,000 Deposit
Variances and Ame midments, Use Determinatims,
Plan Amendment
Development Ageem emits and Appeals
5
Am endm emit to
posi
$1,000 Deposit
27
Land Use Ma p
poll
$5,000 Deposit
49
Ma ar Van an ce
j
pose
$5,000 Deposit
Co ntitionsof Approval
Legal Review and
6
Adm lnl strative
$500 Deposit
28
Outside
Actual Costs
50
Minor Variance
$1,000 Deposit
Amendment
Consultants
7
Time Ext ensionsFee
$ 258
Specific
peci Plan Amendments
51
Am endments t0
posi
$ 1,008 Deposit
Conditions of Approval
6
Co de Am endm emit
$10,006 Deposit
29
Majors Pacific
$5,000 Deposit
52
Time Extensions
$250 Fee
Plan Am endment
gmi
Desi Reviews and Amendments
30
Minot Specific
2,500 Deposit
$ posi
53
Change
Zone Chan
10,000 De t
$ posi
Plan Am endm emit
9
Major
$5,000 Deposit
Subdivisions and Amendments
54
Use Determination
$500 Deposit
18
Minor New
$2,508 Deposit
31
Tentative Tract/
$5,800 Deposit
55
Development
$5,008 Deposit
Parcel Map
Agreements
11
Ml nor Rem odel
$1,000 Deposit
32
Final Tract Map
$2,500. Deposit
56
Appeals
$1,000 Deposit
12
Amendmentto
$500 Deposit
33
Final Parcel Map
$2,500Deposit
Plannin Review 6f6uildin Plan Check Submittals
Condition-cAppmva
13
Time Extensions
$258 Fee
34
Lot Line
$2,500 Deposit
57
New Construction
20% Form It Fee
Adjustment
Remodel/ionant
14
Concept Plan Review
$5,000 Deposit
35
Lot Merger
$2,500 Deposit
58
20% Perm It Fee
Improvements
$500 Per Sheet,
15
Preliminary Review
Nfax.$2,000
36
Reversion to
$500 Deposit
59
Landscape Plan Review
20% Perm it Fee
Deposit
Acreage
Environmental
37
Certificate of
posi
$1,000 De t
Other Fees
Com pliant:
Amendments to
Written Zoning
16
FIR
$20,080 Deposit
38
Conditions of
$1,800 Deposit
60
Confirmation/Non-
$208 Parcel
Approval
Conforming Status Letter
17
Supplemental/
$10,006 Deposit
39
Tim e Extension
$250Fee
61
Annual Parking
$70/Parking
Addendum FIR
Exception Fee
Exception Space
Negative Dedaration /
Master
18
Mltgated l ted 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
Temporary Uses
63
News Rack Perm It
$500 Deport
Notice of Completion /
Tem porary Use
Plennin35ervice -Hourly
20
4eterm lnatlon/
Actual Costs
41
Perm It
$2501's.
64
Rate
Actual Cost
Exemption
Document Fees
42
Large Gathering
p°si
$1,000. Deposit
65.
Fee Not Listed
Per Direct or
Permit
Determination
21 Black and White Copy $O.10 Per Page
43
Ti or e Ext or si on
$120 Fee
City CounCflRe5olutlonNo. 21-54
22 Cc for Copy $0.30 Per Page
44
Film Permit
$5001'ee
Adopted July 20, 2021
Effective October 1, 2021
23 other Plans and Maps Actual Cost
43
Reasonable
Ao:ommodation
$500 Fee
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -72 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 -73 SEPTEMBER 2022
TABLE II -2734
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
Residential
Duplexes or twoDiscretionary
structure)
PD -
Planned Not Applicable
Development
Apartment
Homes, Bungalow
Courts,
Discretionary
Condominiums, (Planning
Community
Commission)
District was specifically created to authorize
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 twoDiscretionary
structure)
District
detached single-
(Planning
Program 1.5, City will amend Zoning Code to
family dwellings
Commission)
allow triplexes by Right
R3 - Multiple
*Single-family,
**Triplexes (single
Zoning district includes objective design and
Family
ADUs, JADUs;
structure);
Administrative
development standards
Residential
Duplexes or two
Boarding houses;
(Director Review)
District
detached single-
Condominiums
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -74 SEPTEMBER 2022
*Administrative
TABLE II -2734
RHASP - Red
Hill Avenue Mixed -Use
Specific Plan
See Program 1.2 which commits to the
HOUSING TYPES AND PERMIT PROCESSING REQUIREMENTS
Zone
By Right CUP
Design Review
Notes
Planned
family dwellings;
Condominium
Program 1.5, City will amend Zoning Code to
SEPTEMBER 2022
Multiple family
allow triplexes by Right
(Director Review)
dwellings, apartment
District
Apartment
houses.
allow residential uses by Right
MHP -
projects
**Discretionary
Mobile
Not applicable Mobile home
(Planning
Zoning district includes objective design and
Home Park
parks;
Commission)
development standards
District
See Program 1.2 which commits to the
Agricultural
ADUs, JADUs;
*Administrative
Apartment houses
RHASP - Red
Hill Avenue Mixed -Use
Specific Plan
See Program 1.2 which commits to the
PD -
Bungalow courts
development of Objective Design Standards
Planned
Not applicable
Condominium
Administrative
SEPTEMBER 2022
Development
Community
(Director Review)
Program 1.5, City will amend Zoning Code to
District
Apartment
allow residential uses by Right
projects
RA -
Residential
*Single-family,
Not Required
*Administrative
See Program 1.2 which commits to the
Agricultural
ADUs, JADUs;
(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
Hill Avenue Mixed -Use
Specific Plan
(Director Review)
Not Required With concurrent
Residential Unit
Allocation from 500
Specific Plan includes objective design and
development standards. The RHASP Land
Use Plan allows for a total of 500 residential
units within the Specific Plan area.
residential unit bank
CITY OF TUSTIN
DRAFT HOUSING ELEMENT
GENERAL PLAN
II -75
SEPTEMBER 2022
Planned
TABLE II -2734
Community
Administrative
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
Community
Site #1. Specific Plan will be amended to
See Program 1.2 which commits to the
affordable housing,
allow for additional units per Program 1.1.
Source: City of Tustin
as well as mixed-use
DCCSP -
*Administrative
Specific Plan includes objective design and
Downtown
(Director Review)
development standards. The DCCSP Land
Commercial
Mixed -Use, Live-
Not Required
with concurrent
Use Plan allows for a total of 887 residential
Core Specific
Work
Residential Unit
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;
Not Applicable
District -
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 -76 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.
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 -77 SEPTEMBER 2022
Figure II -3. Residential Building Permit Process
Submit Plans to First review - 10
r. U Send Applicant
CU M
City with payment daysCorrections
s
or
°"
(online or in- °" Subsequent
Issue Permit
o
person) Reviews - 5 days
u °
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 -77 SEPTEMBER 2022
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 -78 SEPTEMBER 2022
TABLE II -3528
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
"The
September
submitted for plan check
approval; no permits as
Area -
2021
or obtained permits
of March 2022
Hill"
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 -78 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
Frel ,F:raryReview _. Formal Application
ioptiomai) submittal
Application Review for completeness
and CEQA requirements (30 -day review)
Application Complete and project is scheduled
for public hearing within thirty J30) days
Public Notice Es mailed, published and posted at least
ten (10) calendar days before public hearing
Hold public hearing; Project is presented to the
Zoning Administrator or Plan ningCommission
Project Project
Dented Approved
10 -day
Appeal Period
Applicant modifies
application/plans
and resubmits plans
Application
Incomplete
Decision toDeny MOT Derision appealed.' l I Decision to rove 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 -79 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, and the Community Development Department serves as the
coordinating agency to facilitate reviews with other in-house departments such as
Police, Public Works/ Engineering, and Parks and Recreation.
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 -80 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 shall 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 -81 SEPTEMBER 2022
As part of Program 1.2, the City will amend the Tustin City Code 9272 (Design
Review) to remove subjective design guidance twill probe -and adopt objective
design standards to further- ensur-e that the City ean provide leeal guidanee on design
0-1
standards 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
.-.... .......................... ...
Preluninary Review -ormal Application
14ptionall submittal J
Applicant modifies
applicatiorniplans and
Application Review for
resubmits plans
completeness and CEQA
requirements (30 --day review)
Application.
Incomplete
Applimtian deemed Complete
Project Project
Denied Approved
10 -day
Appeal Period
Decision to Deny NOT Decision appealed.' Decision to Approve NOT
appealed. Applicant may not U appealed. Applicant may
proceed with the project. I I 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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -82 SEPTEMBER 2022
Residential Unit Allocation (Red Hill Avenue and Downtown Commercial Core Specific
Plans)
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -83 SEPTEMBER 2022
• Additional density bonus beyond the State's maximum ratio
• Reduced application fees
• 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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -84 SEPTEMBER 2022
with the City's Zoning Ordinance are consistent with densities established in the
General Plan.
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 -224 (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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -85 SEPTEMBER 2022
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
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN II -86 SEPTEMBER 2022
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 -87 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 -436
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
1 Pursuant to Government Code Section 65583(a)(1), City's share of extremely -low-income units is 862 (50 percent
of the total Very -Low Income new construction objective).
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 -88 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 ULY 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 ULY 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 ULY 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 ULY 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 6th cycle Housing Element
update. A review of the City's past performance on housing element implementation programs
is contained in Appendix A of the Housing Element.
The following table (Table 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 MARG14 SEPTEMBER 2022
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV-2 MARG14 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 ITI. Those programs are only listed once to avoid
duplication.
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source I 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
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
As requested between
the By -Right Approval of Projects with 20 Percent
"Reuse'
Development
housing related entitlements
2021- 2029, Report
Affordable Units on Sites in compliance with
Department
for TLSP by assigning a
annually in April
Government Code Government Code 65583.2(h) and (i).
designated project manager
• 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 1°°�Cu 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 includeAuthority,
and/or Specific Plans to facilitate mixed-use developments
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
1 2023
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -4 Mmoi 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
0 374 housing units by
Core area.
Development
October 2025
Department
• 373 housing units by
Economic
October 2029
Development
Department
Housing
(New) Red Hill Avenue Specific Plan (RHSP)
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.
• 2258 housing units
by October 2025
• 105 housing units by
October 2029
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -5 MARG14 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 MARG14 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
h. Facilitate affordable housing development including
Authority,
Housing Authority
inventory by 50 units over
housing for extremely low income and very low-income
Community
Fund
eight years (10 extremely low;
households, and households with special needs (such as
Development
20 very low; 20 low income
persons with disabilities and farmworkers).
Department
CDBG Fund
units).
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 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
Provide , rrdt fast
of six lqr-ajeets t4at
Ing
cr a U, Ieiy,.,.
By October 20239
prioritizing projects
-Aff of-d—a-h-l-e- to extremely
,,
hn4i,;ehe1dr Provide
technical 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
opportune areas
(Census tracts 756.05,
524.19, 756.06, and
756.07) on an annual
basis, which means
that review times will
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -8 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
be reduced by 25%
compared to year 2022
review timeframes and
for all affordable
housing projects by
assigning a designated
taff
,streamliningstaff
liaison' to the project.
i. 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.
Economic
new housing developments to
Development
ensure compliance with SLA
Department
and affordable housing
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
Department
Funding if available
guidance in TCC 9272 (Design
(Design Review) to
remove subjective design
in TCC 9272 (Design Review), and Pie -and adopt
Review) and Aadoptief-e€
guidance and also
objective design standards to ensure that the City can
Oebjective Ddesign Sstandards
provide clear guidance on design to streamline the
develop and Aadopt new
development of faei4t^t^ high quality residential
co mi#3F which will apply
Citywide Objective
development; ensuring the provision of adequate private
citywide
Design sStandards by
open space, parking, and use of city's private streets
December
standards consistent with State law (SB 35).
�923i...,-by by 2024
----------r--------- --,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -9 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
Design Guidance
Community
Grant Funding,
Educate public via City's
Post to City' website By
December 20246
b. Provide educational materials and consultations regarding
Development
General Fund
website, and counter
Objective Design Standards (SB 35)
Department
consultations, approximately
Minimum of 10 weekly
100 consultations total per
design consultations
year.
starting January 20254.
(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
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -10 MARG1 SEPTEMBER 2022
TABLE IV-1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
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
Development
General Fund
Conduct analysis and
evaluation of the Voluntary
By December 20223
to lievaluate the City's current Voluntary Workforce
Housing Ordinance in conjunction with the reassessment on
Department;
Workforce Housing, Ordinance
and DCCSP and RHASP
the effectiveness of the Downtown E6inmericalCommercial
Housing
Core Specific Plan DCCSP and Red Hill Avenue Specific
Authority
(Specific Plans) and develop
recommendations for policy_
Plan(RHASPadopted in 2018, to identify development
changes that remove
constraints and adjustments necessary to
incentivize housing development meea and
development constraints.
subsequently amend the TCC to remove development
constraints.
Amend the TCC Code
"Voluntary Workforce
By December 2024
Housing" to implement
recommendations to remove
any identified housing
development constraints
^. ,,.,-.a the DCrcn an- a
nu^cnt,..
u., P,.,.e ff4 er 20-24-
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -11 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
Conduct an analysis of the
Residential Allocation
Reservation (RAR) process
December 2022
applicable in the following
5pecific Plan areas: DCCSP and
RHASP and identify any
potential barriers to housing
developments.
Amend DCCSP and RHASP
Specific Plans review
procedures and/or applicable
By December 2025
Specific Plan sections to
eliminate governmental
constraints that may pose a
barrier to housing
development, with an
emphasis on eliminating
redundant processes,
ambiguities and discretiop2j X
action(s).
Amend DCCSP and RHASP to
provide for additional housing
units aligned with economic
By December 2025
objectives and infrastructure
capacities by re-evaluating the
housing units allocated to each
geographic area in each
Specific Plan.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -12 MARG1 SEPTEMBER 2022
Program
1.5 (New) Zoning Code Streamlining Program
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Responsible Funding Source
Agency
a. Implement zoning code amendments to facilitate Community
application and project review streamlining and compliance Development
with State law to meet housing needs.
General Fund
Quantified Objective
Conduct environmental
analysis, as needed, to
accommodate additional
housing units in each Specific
Plan area, aligned with
economic objectives and
infrastructure capacities.:
• Annually review
zoning code and
identify potential
improvements to
streamline
development and
permit Amend zoning
code as appropriate
and adopt within 12 -
month timeframe
• Amend Zoning Code
to remove the CUP
requirement forallow
triplexes in the R2 and
R3 zonesby-right,
• Amend the Zoning
Code to remove the
Timeframe
By December 2025
Annually
By October 2023
By October 2023
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -13 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
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
c. Seek funding and determine financial feasibility for a Mobile
Community
HCD Grant Funding
Annually check the HCD
Annually in March of
each year.
Home Assistance Program that provides financial and
Development
website for potential funding
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 Programs
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -14 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
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
Update website with ADU
By June 2022
awareness.
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
Development;
Housing
Authority
General Fund, SB2
Grant Funding
Develop and adopt an
ADU SB9 accelerator
program,
Mail out information
By December 2024
Opportunity Areas within the northeast portion of the City
where there are predominately single family residences in
order to expand housing choices. This program could include
a permit fee waiver for affordable housing units, permit fast
pertaining to the new
Tanuary 2025
tracking refer to Program 1.1h), and technical assistance. This
accelerator program for ADUs
program will also
and SB 9 developments,
create a one -stop -shop comprehensive resource for
specifically high opportunity
homeowners interested in developing an ADU and/or SB9
developments. This program will complement revised
areas.
areas.
Program 1.1(h) Streamlining and Permit Fast Tracking for
new ADU/SB9 development proposals.
1}
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).
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -15 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
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.
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -16 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
a. Continue to require appropriate deed restrictions where
Community
Tax -Exempt Mortgage
Include conditions of
Bi -weekly review of
newly approved or extended affordable housing units will
Development
Revenue Bonds and
approval at entitlement and
development projects
be required to record a 55 -year deed restriction for rental
Department;
other various
require recordation of deed
between 2021-2029.
units and 45 years for ownership units to ensure continued
Housing
resources
restriction prior to issuance
affordability for extremely low-, low-, or moderate -income
Authority;
of Certificate of Occupancy
housing constructed or rehabilitated with the assistance of
Economic
for affordable units for
any public funds, as may be legally required.
Development
applicable housing
Department
development projects.
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
where possible, adjust internal procedures to shorten review
Department
timeframes.
c. Continue the services of the City's Community Development
Community
General Fund
Review number of days to
Bi -annual reviews in June
Department as a central clearinghouse with individuals
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
bi-annually 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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -17 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
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:
Community
General Fund
Annual website updates with
By December 2023
a. Maintain a current inventory of residential and mixed-use
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
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
Department;
Mortgage Bonds
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -18 Mmoi SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source
Agency
acquisition/rehabilitation projects that help meet the City's Housing Revenue issued by
affordable housing needs. 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
historic resources for affordable housing and evaluate the Development
use of alternate parking strategies under Program 1.2 (c). Department
1.14 Ongoing Review of Housing Element Programs
General Fund
Quantified Objective
Promote program through City
website and historic
preservation interest groups.
Develop memo to evaluate the
use of alternate parking
strategies for adaptive historic
reuse.
a. From the date of adoption of the Housing element, prepare Community City General Fund; Prepare Annual Report to the
an annual report to the Planning Commission assessing Development Staff time Planning Commission and the
previous years' accomplishments toward meeting Housing Department City Council annually.
Element objectives. Submit the Annual Report to the State
HCD.
Timeframe
By December 2023
By December 2023
Submit Annual Report to
HCD by April 1 each
year.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -19 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
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
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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -20 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
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.
Tr
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
• Priorities in the
application process
Goal 2: Fair Housing and Specials Needs
2.1 (Modified) Emergency, Transitional, and
Supportive Housing
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -21 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
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
Housing
subject only to those zoning regulations that apply to other
Authority,
residential dwellings of the same type in the same zone.
Community
Transitional and supportive housing meeting certain
Development
criteria will be allowed by -right in zones where residential
Department,
uses are permitted, including mixed-use and nonresidential
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.
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -22 Mmoi SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
Authority
Allocate CDBG funds to non-
profits to provide 150
Annually, between 2021-
individuals services such as
2029.
counseling, education, job-
training and other techniques
to stop the cycle of
homelessness.
Retain 262 emergency shelter
beds and expand emergency
By December 2024
shelter bed inventory by 125
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)
• 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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -23 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source
Agency
d. Provide educational resources for prevention of extremely
Housing
HUD Section S
low-income households from becoming homeless by
Authority and
Program, CDBG
providing links and program information on City's website
Community
and at the Tustin Library, Senior Center, and Family and
Development
Youth Center.
Department
2.2 Economic Integration within Sphere of Influence
a. Request that the Orange County Planning Commission and
the Environmental Management Agency (EMA) notice the
City of Tustin of any proposed development activities and
encourage and support the County of Orange in its efforts
to provide affordable housing opportunities for low, very -
low, and extremely low- income families within Tustin s
sphere of influence.
County of Orange,
Community
Development
Department
City General Fund;
Staff time
Quantified Objective I Timeframe
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)
Post information to City Post by January 2023;
website and provide Update Annually in
informational materials to April
Tustin Library, Senior Center,
and Family Youth Center
Report number of requests in Annually in April
annual report.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -24 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
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
State and Federal
outreach program with
program by June 2022
(i.e. brochures, pamphlets, informational flyers, etc. that can Department
programs; City's
information posted on the
Develop outreach
be shared and posted on the City's website) that informs General Fund
City's website along with
materials by September
families within the City of affordable housing and services
social media usage.
2022
available for persons with developmental disabilities.
Post outreach materials
to City website by
October 2022
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 MARG14 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
Development
(Reasonable Accommodation
(1) Revise so that the reasonable accommodation can
Section) to remove constraints
proceed without the need for any additional corrections of
identified in Program
nonconformities to property.
(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
adopt incentives by
January 2024.
Program. Universal Design strives to produce dwellings
that are accessible for all people regardless of race, age, sex,
culture, gender, weight and ability. Universal design avoids
adopt a Universal Design that
using special assistive technology, and instead employs
incentivizes developers who
design features and consumer products that are easy to use
implement Universal Design
and widely acceptable.
features in projects to be
eligible for fee reduction or
Promote Universal
other development incentives.
Design Program and
The program will incentive the
adopted incentives by
development of two Universal
sending informational
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -26 MARG1 SEPTEMBER 2022
TABLE IV-1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
Design units on an annual
program literature to
basis, starting in 2024 through
developers on an annual
2029.
basis starting March
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;
Update website and provide
Community
Development;
educational material related
By January 2023
but not limited to: Directory of
Senior Citizens 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
By January 2023
Services / Engage Linguistically Isolated
Development
official cite .tet., by
b. The City will provide bilingual communications, including
Department
2023 Regular and i^^rease
but not limited to interpreters and translation services, in
- 4 ----A44----% --r-ese -at
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -27 MARG14 SEPTEMBER 2022
TABLE IV-1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
official governmental actions and communications
including meeting and hearing notices and presentations.
By engaging linguistically isolated populations in the
Cbun,._' ...eeti .,.,
Translate official City
announcements (i.e.
community meeting, hearings,
decision-making process, they are better able to advocate
for their needs and concerns regarding affordable housing
and access to opportunities.
etc.)to Spanish and
disseminate printed copies of
information to renters,
property owners, and via social
media, in order to expand
knowledge of affordable
housing options in High
Opportunity Areas.
Increase attendance,
representation, understanding
by linguistically isolated
residents, at community
meeting, ublic 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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -28 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
(NEW) DISSEMINATE HOUSING AND ANCILLARY
Community
Development
General Fund
Increase the distribution of
Annually, starting in
2023 through 2029
RESOURCE INFORMATION & ENGAGE LIGUISTICALLY
translated materials to low
ISOLOATED
Department
resources areas located in the
southwest of the CiMby-
mailing out postcards to each
c. Translate the City's Tustin Housing Authority website and
factsheets promoting affordable housing opportunities and
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,
transit, child care, and
education resources.
(New) Housing Discrimination
Community
General Fund
Contract with fair housing
Annually, starting July
Fd_Contract with anon -profit fair housing provider, (i.e. non-
ment
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -29 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible
Agency
a. Continue to provide housing referral services to families in I Police
need of housing assistance and information by. This
Department;
program consists of three City departments disseminating
Parks and
information to the public at all times.
Recreation;
• The Police Department refers homeless people to
Department;
Community
different agencies that provide shelters and food for
Development
various segments of the population.
Department;
• The Parks and Recreation Services Department
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
a. The City will update their Zoning Code to comply with Development
provisions of the Health and Safety Code Section 1702.15, Department
which allows employee housing for six or fewer employees
to be treated as a single-family structure and permitted in
the same manner as other dwellings of the same type in the
same zone, and 1702.16, which allows- requires employee
housing, consisting of no more than 12 units or 36 beds, to
Funding Source
City General Fund,
CDBG Funds
Quantified Objective
7,500 referrals to social
agencies
• 937 referrals annually
• 50 referrals for shared
housing by 2029
General Fund City will update the Zoning
Code to include provision of
farmworker housing as
appropriate under Health and
Safety Code Section 1702.15
and 1702.16.
Timeframe
Annually between 2021-
2029; Report in April
By October 2022
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -30 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
in the same zonefaffffl-As,afkef hatising to be developed
2.8 (New) Tustin Legacy Specific Plan Improvement Program
(New) Tustin Legacy Specific Plan Improvement Program:
Community
Development
Department
Tustin Legacy (MCAS)
City will implement projects as
By October 2029
Tustin Legacy (Tract 744.15) is a Master Planned Community
Fees, Developer Fees,
identified in the City's Capital
that is currently being developed. Although the tract has
and General Fund
Improvement Program, Tustin
been identified as low resource, it has been substantially
Legacy Backbone
Infrastructure Program, and
enhanced with new resources within recent years including
services and amenities such as elementary school, high
Tustin Legacy pecific Plan.
school, Junior College, new grocery store, shopping and
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -31 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program
• 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
• Tustin Legacy Community Dog Park
Police substation at Tustin Legacy
Goal 3: Preserve and Improve Housing
Opportunities
3.1 Condominium Conversions
Responsible Funding Source Quantified Objective
Agency
a. Require developers converting apartments to Community City General Fund Post requirements on
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
income households. per year.
Timeframe
Post by October 2022
Report consultations
Annually in April
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -32 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
3.2 (Modified) Home Ownership Assistance
a. Facilitate the process of homeownership, especially first-
Housing
State and Federal
Provide educational resources
Annually, start by
time homebuyers, by providing a virtual one stop shop
Authority;
sources
on city website and social
December 2024
clearinghouse through anon -profit organization (i.e.
Community
Development
media.
Affordable Housing Clearinghouse) and explore
participation in the Orange County Mortgage Assistance
Conduct review and analysis
Program (MAP)
for MAP participation.
By October 2023
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
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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -33 Mmoi SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
c. 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 MR
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -34 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
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 —IV
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)
annually in April
• 311 Sycamore Avenue
(Heritage Place - 54
units)
• 275 E. 6th 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,
2023 and begin
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -35 MARG1 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
Housing
units provided through City
implementing
Authority
incentives and/or financial
procedures by January
assistance. Contact property
2024.
owners within at least one year
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
Development
from potential participation in
a. Complete a cost -benefit analysis of obtaining membership
Department,
CaICHA program.
with the CaICHA - through its Essential Middle -Income
g
Housing
Identify rental properties for
Rental Housing Program ("Program').
Authority
potential acquisition and
By December 2025
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
ent3.10 (Modified) Housing Rehabilitation to
Address Substandard Housing
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -36 Mmoi SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
a.
494� and- . flod- fate i fle-o ffi-. h,,..,.,.holds Partner with a
non-profit to develop and launch a CDBG funded Housing
Housing
Authority;
Community
Development
Department
Available federal,
state, and local
resources
Conduct review and analysis
and develop a program
framework for
implementation.
f^r h^�^^N•^,^M^ Noxith
housing who
^^a ^^,;kta ee i br-iagiffg
the^nsing uu�
orgaFdzation, sueh as Habitat
County, to administer the
The Cityyd II - s.i St i n t 4
rph-;hilit;#t .n Af C hnrne
beg nn n,. iR 2024 (25
planning n E)d Facilitate
four U rehabilitation projects
By December 2025
Rehabilitation Program to facilitate the repair of dilapidated
housing to address lack of plumbing, kitchen facilities and
repairs to provide relief of overcrowding. Program
participants will be provided grants and/or loans to
conduct necessary housing updates. 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 highsuhrfandard
segregation index as defined by Dissimilarity Index values
which indicate geographical segregation patterns in census
tracts
to assist with reducing
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -37 Mmoi SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program
3.11 (New) Quality Rental Housing Inspection Program
a. Establish a multi -family quality rental housing
inspection program.
Responsible Funding Source Quantified Objective
Agency
overcrowding per year and
another four (4) projects will
assist with general habitability
repairs, with a total of eighL (8)
dwellings assisted annually.
Starting in July 2024, the CitX
in partnership with a 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 in the City s CDBG
Annual Report.
Community
Development
Department
CDBG, Home
Elevate the quality of housing
in segregated areas in order to
transform the area into a
desirable housing location by
all socio-economic groups. The
City will conduct at least five
Timeframe
Annually, beginning
Tanuary 20264.
By July 2025
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -38 Mmoi SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
housing inspections in the
programs first year, and will
increase the number of annual
inspections by 2, each year
thereafter until 2029.
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 sin le
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -39 Mmoi SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
family and multi -family
residential dwellings by
providing technical assistance
and funds to repairs
substandard housing
conditions.
3.12 CHILD-CARE RESOURCES
a. Create a "Financial Assistance for Child Care'
Economic
Development
Department/
Community
Development
Department
General Fund
Single -parent households
require special consideration
By December 2022
webpage with information and links to Children's
Home Society of California (CHS) and the Orange
and assistance because of their
County Department of Education (OCDE). These
greater needs for daycare,
healthcare, and other facilities.
pro rg ams provide funding to low-income families for
child care services. The City will work with Tustin
According to HCD, female -
Preschool, Kiddie Academy of Tustin, or other local
headed households with
children tend to have lower
preschool programs within Census tract 755.14 to
advertise and promote financial assistance through
incomes, thus limiting housing
pamphlets, e -blasts, and other applicable online
availability for this group. The
community forums (such as Facebook and NextDoor).
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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -40 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
3.13 INCREASE HOUSING SUPPLY FOR LARGE
HOUSEHOLDS
Community
Development
Department
a. Amend the zoning code to require all new multi -family Community General Fund
projects to provide at least five (5) percent large family Development
units (3+ bedrooms) which will prevent overcrowding Department
and further cost burden, by addressing demand for
such units and increasing the large units into the local
housing inventory.
Goal 4: SUSTAINABLE HOUSING
4.1 (Modified) Code Enforcement Program
a. Encourage property maintenance and enforce building Community City General Fund
codes to -address and prevent substandard housing Development
conditions, removal of graffiti and other deferred Department
maintenance issues on public property.
Amend the code. I By December 2024
Facilitate the creation of four Annually, start January
(4) large family units will be 2025 through 2029
generated annually, and 32
total by 2029.
Investigate substandard -Report annually in April
housing an on-going basis;
approximately 25 cases per
year.
Report annually in April
Remove approximately 4,000
cases of graffiti annually.
Conduct approximately 100 Report annually in April.
Water Quality inspections, in
conjunction with the Water
Quality Control Ordinance and
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -41 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
the National Pollutant
Discharge Elimination System
(NPDES) permit process to
protect neighborhoods from
pollution.
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -42 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program
recharge connection, electric vehicle recharge connection,
wind power generator, etc.)
4.4 (Modified) Sustainable Building
a. Promote energy efficiency by orienting homes to maximize
natural day lighting.
b. Require buildings and structures to 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, require applicants
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.
Responsible Funding Source Quantified Objective
Agency
consultations; approximately
100 total per year.
Community General Fund Promote via City's Design
Development Review process and counter
Department consultations; approximately
100 total per year.
Community General Fund Educate via City's website,
Development Design Review process and
Department counter consultations;
approximately one (1) total per
year.
c. Require development projects that include structures higher Community General Fund
than 200 feet above existing grade to be submitted to Development
Airport Land Use Commission for review. Require projects Department
that exceed a height of 200 feet above existing grade to file
Form 7460-1 with the Federal Aviation Administration
(FAA).
Educate via City's website,
Design Review process and
counter consultations, as
applicable; approximately one
(1) total per year.
Timeframe
Report annually in April
Report annually in April
Report annually in April
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -43 MARG14 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source Quantified Objective Timeframe
Agency
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;
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 -44 MARG14 SEPTEMBER 2022
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -45 MARCH SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
APPENDIX A
REVIEW OF PAST PERFORMANCE
A-1
HOUSING ELEMENT
JULY 2022
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
GENERAL PLAN
2022
A-2
HOUSING ELEMENT
iULYPEBRU^ Y
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
GENERAL PLAN
2022
A-3
HOUSING ELEMENT
iULYPEBRU^ Y
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
GENERAL PLAN
2022
A-4
HOUSING ELEMENT
iULYPEBRU^ Y
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 iULYPEBRU" Y
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
GENERAL PLAN
2022
W.
HOUSING ELEMENT
iULYPEBRU^v
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
GENERAL PLAN
2022
A-7
HOUSING ELEMENT
iULYPEBRU^ Y
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
'Numbers include total, actual number of units with permits issued and completed.
2 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
GENERAL PLAN
2022
ME
HOUSING ELEMENT
iULYPEBRU^ Y
New Construction
Preservation
Income Group
Goal
Actual'
Goalz 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.
2 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
GENERAL PLAN
2022
ME
HOUSING ELEMENT
iULYPEBRU^ Y
APPENDIX A -
ATTACHMENTS
REVIEW OF PAST PERFORMANCE
CITY OF TUSTIN
GENERAL PLAN
2022
•
HOUSING ELEMENT
TULYFEBRUA
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
GENERAL PLAN
JULY 2022
A-10
HOUSING ELEMENT
PEPRUAPly
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
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
GENERAL PLAN
JULY 2022
A-11
HOUSING ELEMENT
PEPRUAPly
New Construction
Rehab/Preservation
Housing
Assistance
Income Group
Goal
Actual
Goal' Actual
Goal'
Actual
Very -Low
283
94
171 253
242
243
Low
195
74
49 132
74
74
Moderate
224
114
Above Moderate
525
1,240
Total
1,227
1,522
220 385
316
317
1 While the numbers represent units, it does not account for the funding and other support activities provided.
Data not available for those not presented with numbers.
Source: The City of Tustin, Housing Element, 2013 Table HTM-25, 2014-2021 Housing Needs; Table A-2,
Effectiveness of Housing Element Programs; Table H-20, Housing Element Programs 2013-2021; City of Tustin
Annual Reports 2013 - 2020 - Implementation Status - Housing Programs Progress Report - Government Code
Section 65583 Tables (Tables C or D depending on the year)
Table A-2 provides program by program review of the previous Housing Element
(identified in Table H-20 from the 2013 Housing Element), containing a discussion on
the effectiveness and continued appropriateness of each program. It includes an
identification of units achieved or status thereof, where applicable. Of note, any
extremely low-income units are captured in the very -low income category.
Table A-3, Progress Towards Objectives 2013-2021, following Table A-2 provides a
summary table identifying focused areas with quantified objectives, associated
accomplishments and, where known, the distribution of units by income category.
The focused areas include new construction, rehabilitation, preservation, and other
focused affordable housing programs. The detail is articulated in Table A-2. Of note,
any extremely low-income units are captured in the very -low income category.
CITY OF TUSTIN
GENERAL PLAN
JULY 2022
A-11
HOUSING ELEMENT
PEPRUAPly
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
Tustin Legacy
Continue
Districts and Specific Plans to
Department,
Agency staff time
affordable owner and
to as MCAS):
authorize and encourage mixed-
Successor Agency,
involved
rental housing through
Amal
The City entered into
This program will be
use developments. (See Zoning
City Council
development in MCAS
Completed 2015
agreements with
included in the 2021-
Studies Program).
- Tustin and infill areas.
several developers at
2029 Housing
Housing Element Policies: 1.1, 1.5,
The City supports
37 Moderate
the Tustin Legacy for
Element.
applications for the
496 Upper Income
implementing the
1.9
creation of new mixed-
Anton Legacy:
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 or
Specific Plan approved
Humanity Veteran's
in 2018 which added
Housing [140 S. A
into this area of the
Street adjacent to
City the opportunity
Old Town]:
for 887 residential
Completed 2018
units to be developed.
To date, 140 upper
1 Low
income units have
1 Moderate
been built with a
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 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
workforce housing in -
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.
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 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
1.2 Mobile Homes
Community
City General
The City will continue
Between 2013-2021,
Positive
On-going
Continue to maintain the City's
Development
Fund; processing
to maintain the existing
no applications for
Existing mobile home
Continue
mobile home park zone and
Department, City
fees (recoverable)
mobile home park zone.
mobile homes or
parks continue to be
This program will be
process conditional use permit
Council
Family zoned
manufactured homes
maintained.
This program will be
applications as received for manu-
properties without the
were received
to accessory dwelling
included in the 2021-
factured homes.
need for any
construction and
units (ADUs), formerly
2029 Housing
Ordinance provisions.
discretionary actions.
have not yet received
known as second
Element and future
Housing Element Policies: 1.1, 1.4
During the planning
a final
residential units, in
compliance with new
applications will be
period, five (5) second
8 ADUs are in the
state regulations.
processed as
units are anticipated.
plan check process
received in a timely
2 ADUs were
manner.
1.3 Second Residential Units
Community
City processing
The City has updated
Between 2013- and
Positive
On-going
Continue to provide opportunities
Development
fees (recoverable)
its Zoning Code to
spring 2021:
On April 4, 2017, the
Continue
for affordable second residential
Department, City
Council
allow second units to be
developed within Single
15 ADUs were
City Council adopted
This program will be
dwelling units on Single-family
Family zoned
constructed
Ordinance 1479 related
included in the 2021-
Residential District lots where
properties without the
4 ADUs are under
to accessory dwelling
2029 Housing
feasible through existing Zoning
need for any
construction and
units (ADUs), formerly
Element with
Ordinance provisions.
discretionary actions.
have not yet received
known as second
exploration of
Housing Element Policies: 1.1, 1.8
During the planning
a final
residential units, in
compliance with new
additional
period, five (5) second
8 ADUs are in the
state regulations.
programs; future
applications will beprocessed
units are anticipated.
plan check process
as
2 ADUs were
received in a timely
withdrawn
manner.
City of Tustin
Draft Housing Element
A-14
Appendix A
FEBRUARY
JULY 2022
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
1.4 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
planningperiod 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
2029 Housing
rehabilitated with the assistance
for a minimum of 45
Element.
of any public funds as may be
2017: 1 residential
legally required.
years.
structure authorized
For affordable units,
for continued use by
projects will
Housing Element Policies: 1.1
the City requiring
continue to include
that the property
conditions of
owner enter into a
approval at
housing agreement
entitlement and
ensuring that the
required recordation
dwelling remain
of deed restriction
affordable to
prior to issuance of
low/moderate
Certificate of
income for a 55 -year
Occupancy.
period.
2021: Tustin Gardens
with potential
continuation for 20
more years of 100
deed restricted units
Anton in Tustin
Legacy 225 55 -year
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
A-15
Program
1.5 Pre -application
Conferences
Continue to utilize procedures for
pre -application conferences and
processing procedures to expedite
permit processing.
Housing Element Policies: 1.12
1.6 Permit Processing for
Low- and Moderate -Income
Housing
Ensure that processing of permits
for low- and moderate -income
housing are fast -tracked with low -
and moderate -income housing
permits being given priority over
other permit applications.
Housing Element Policies: 1.12
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible
Agency
Community
Development
Department
Community
Development
Funding
Source
City General
Fund; City
processing fees
(recoverable)
City General
Fund; City
processing fees
(recoverable)
Quantified
Objective
Continue
Continue
Units
deed restricted
affordable units
(262 total includes 37
densitv bonus units)
Results
Effectiveness
Positive
Continued to utilize
pre -application
processing procedures
to expedite processing
Positive
All affordable housing
projects were
recipients of such
streamlined
processing, including
three in the Tustin
Legacy; Amalfi, Anton
projects and Village of
Hope veterans housing
and homeless facility.
Timeframe
Continue/Modify/
Delete
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Continue to process
applications in a
timely manner
City of Tustin Appendix A
Draft Housing Element FEBRUARY
JULY 2022
A-16
1.7 Permit Coordination
Community
City General
Continue
Between 2013-2020
Positive
On-going.
Development
Fund; City
Continue the services of the City's
processing fees
1,562 New residential
Continue
Community Development
(recoverable)
projects processed
This program will be
Department as a central
2013: 758
included in the 2021-
clearinghouse with individuals
2029 Housing
assigned the responsibility of
2014: 46
Element.
expediting development permits
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
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
I:WiVA
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
1.8 Housing for People with
Community
General Fund
Implement outreach
Positive
On-going
Developmental Disabilities
Development
program through City
The Housing Section
Continue
Work with the Regional Center of
Department
website and social
media.
of the City's website
This program will be
Orange County to implement an
was updated to
included in the 2021-
outreach program that informs
include affordable
2029 Housing
families within the City of
rental opportunities
Element.
affordable housing and services
including a map of all
available for persons with
affordable rental
developmental disabilities.
opportunities in the
City.
Housing Element Policies: 1.11,
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.
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
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
1.9 Housing for the Disabled
Community
State and Federal
Refer individuals to
Positive
On-going
Require new multi -family
Development
programs; City's
agencies providing
Objectives met and
Continue
Department
General Fund.
supportive housing that
housing units and apartment
accommodates
continues.
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 52for
undertake appropriate
Element.
accommodation off the disabled.
amendments to existing
The City will conduct analysis,
standards to ensure
add procedures, and/or
compliance with SB 520.
undertake appropriate
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 FEBRUARY
JULY 2022
1.10 Transitional Housing
Encourage the continuation of the
Sheepfold homes and Laurel
House in Tustin, which provide
housing facilities for battered
homeless women and children.
These homes are located in single-
family neighborhoods and
provide a much-needed service
for homeless women and
children. In addition, explore
additional program options to
assist in the provision and
funding for other programs such
as transitional housing and single
room occupancy housing.
Housing Element Policies: 1.11,
1.14
City of Tustin
Draft Housing Element
Various Non -
Profit
Organizations,
Successor Agency,
Community
Development
Department
Variety of
private funds;
CDBG funds
Promote, assist, and
facilitate the
development of
emergency and
transients' shelters
through continued
support of the
County Homeless
Assistance Program
Support local
agencies that provide
homeless services by
providing financial
assistance of
approximately
$5,000410,000
annually.
Consider the
adoption of a Single
Room Occupancy
Ordinance to
facilitate the
development of SRO
units.
A-20
2014: Laurel House
transitional housing
was transferred to the
Orange County
Rescue Mission for
continued assistance
to the homeless,
women, and teens.
2015: The City
conveyed two (2)
four-plexes to the
Orange County
Rescue Mission
(OCRM) in order to
provide transitional
housing to homeless
veterans.
2016: Tustin Veterans
Outpost was
completed in June
2016, with the
capacity to house 26
homeless veterans
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.
Positive
On-going assistance;
during the planning
period, $33,000 of
CDBG funds were
distributed to
organizations that
provide services to
homeless individuals.
Ongoing
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
FEBRUARY
n RY
JULY 2022
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
A-21
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.
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
The City will also support
Development
Department
Orange County City
Managers/Planning
at
192 -bed facilitySpecific
Plan
S now
p (
This program will be
countywide efforts to assist
Directors SB 2 Task
the Village of
Tustin Legacy Specific
included in the 2021-
approved homelessproviders as
Force
Hope operated by
Plan) provided sites
2029 Housing
part of the MCAS Tustin Reuse
Orange County
and designated land
Element.
effort.
Rescue Mission
uses to accommodate
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
A-21
Program
Housing Element Policies: 1.11,
1.14
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agency Source Objective
Continue to support
192 emergency
housing units to
single men and
women at Tustin
Legacy (Orange
County Rescue
Mission).
The City plans to
assist 200 individuals
by means of
integrating
counseling,
education, job -
training and other
techniques to stop
the cycle of
homelessness.
• Continue to support
24 units of
transitional housing
for families
(operated by
Salvation Army)
• Continue to support
6 units of transitional
housing for women
A-22
Units
completed and
City conveyed the
approximate 5 -acre
property to the OC
Rescue Mission at
no cost.
o Expansion plans of
the existing above -
referenced Village
of Hope facility
capacity from 192
beds to 387 beds,
construction of a
new parking lot,
and establishment
of an ancillary
church use. A
0.57 -acre parcel
was conveyed to
the Orange County
Rescue Mission in
November 2016 to
construct the
parking lot and
construction is
complete.
o 6 new units at
Tustin Field I to
Results
Effectiveness
the identified homeless
needs.
Timeframe
Continue/Modify/
Delete
Appendix A
FEBRUARY
JULY 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agency Source Objective
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)
• Continue to support
the Tustin Family
A-23
Units
Salvation Army
provided at no
cost.
o Acquisition
contribution of 16
units in Buena
Park for the
Salvation Army
was completed.
The City assisted
in acquisition and
contributed grant
funds to acquire
the units at no
cost to Salvation
Army.
14 new units, in
coordination with
the City of Irvine,
obtained by Tustin
and conveyed to
Irvine Temporary
Housing at the
Columbus Grove
project in Irvine at
no cost to Irvine
Temporary
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
FEBRUARY
JULY 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible Funding
Agency Source
2013-2021
Quantified Units
Objective
by the County of complete.
Orange)
0 6 new units at
Columbus Grove
to Human Options
at no cost;
complete.
o 6 new units at
Columbus Grove
to Orange Coast
Interfaith Shelter at
no cost; complete.
A-24
o In 2014, the City
Council
authorized the
conveyance of
two (2) fourplexes
to Orange County
Rescue Mission in
order to provide
transitional
housing for
homeless
Veterans;
complete.
o In 2018, the City
Council authorized
the construction of
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
FEBRUARY
JULY 2022
Program
' 1.12 Number Unutilized
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified Units
Agency Source Objective
A-25
the Tustin
Temporary
Emergency Shelter
("TTES"), a low -
barrier, fifty-seven
(57) bed shelter
serving the
homeless with ties
to Tustin. hi 2019,
the Housing
Authority entered
into an agreement
with Temporary
Shelter, Inc., to
operate TTES. Iri
2019, construction
was completed
and TTES opened.
In addition, CDBG
funds were
allocated to non-
profit
organizations
assisting homeless
individuals.
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
FEBRUARY
JULY 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Program Responsible
Agency
1.13 Bonding Programs
Community
Utilize housing revenue bond
Development
Department;
financing resources and Low-
Housing
Income Housing Tax Credits on
Authority
new construction and
acquisition/ rehabilitation projects
that help meet the City's
affordable housing needs.
Housing Element Policies: 1.7, 3.2
1.14 Economic Integration County of Orange
within Sphere of Influence
Request that the Orange County
Planning Commission and the En-
vironmental Management Agency
(EMA) notice the City of Tustin of
any proposed development
activities within Tustin s sphere of
influence.
Housing Element Policies: 1.1, 1.6
City of Tustin
Draft Housing Element
2013-2021
Funding Quantified Units
Source Objective
State and Complete analysis of
Municipal available programs on
Bonds; Private as needed basis.
Activity
Mortgage Bonds
Revenue issued
by California
Statewide
Communities
Development
Authority and
others; California
Low -Income
Housing Tax
Credits; variety
of other sources
City General Ongoing request to both
Fund; Staff time agencies.
A-26
Results
Effectiveness Timeframe
Continue/Modify/
Delete
Neutral NA
No tax-exempt bonds On-going
were issued between
2013-2020 Continue
This program will be
included in the 2021-
2029 Housing
Element.
Positive On-going
This is an ongoing Continue
effort to ensure
This program will be
coordination between
included in the 2021-
the County and the
2029 Housing
City within the
Element.
Tustin s sphere of
influence.
Appendix A
FEBRUARY
JULY 2022
Program
1.15 Senior Housing
Continue to preserve existing sites
and identify new sites that are
suitable for senior housing
projects. These sites will be pro-
moted for private development
and applications will be made for
any available subsidy funds.
Housing Element Policies: 1.1,
1.11,1.13
1.16 Senior Services Program
Develop a comprehensive
transportation program, case
management, information and
referral, and shared housing
program.
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
Successor Agency;
Community
Development
Department
Parks and
Recreation
Department
Funding
Source
HELP; Low -
Income Housing
Tax Credits;
Private Activity
Bonds issued by
California
Statewide and
others
City General
Funds
2013-2021
Quantified
Objective
Preservation of 100 at -
risk units at Tustin
Gardens, and
identification of new
senior housing sites.
Assist 950 elderly
annually
EWA
Units
100 units - Tustin
Gardens
From 2013-2020
17,198 of our elderly
population utilized
the transportation
system services
Results
Effectiveness
Positive
The City monitors the
project and its
affordability on an
ongoing basis.
Positive
The City far exceeded
the objective by
assisting an average of
2,150 elderly annually.
Timeframe
Continue/Modify/
Delete
On-going
Modify
This program will be
included in the 2021-
2029 Housing
Element and likely
expanded to include
CDLAC Tax Exempt
Bonds for Rehab
/Preservation and
PLHA funds (SB2),
and Voluntary
Workforce Housing
Incentive Funds.
The City will
continue to monitor
projects on an on-
going basis.
On-going
Continue
This program will be
included in the 2021 -
Appendix A
FEBRUARY
JULY 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding Quantified
Agency Source Objective
Housing Element Policies: 1.15,
2.3
Units
provided through the
City.
2013: 1,336 persons
assisted
2014: 1,448 persons
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
Uses in R-3 Zones into Development Fund; Staff time are anticipated
Multiple -Family Units Department
Continue to encourage developers
to consolidate individual lots into
Results
Effectiveness
See also shared
housing for the
objective results which
too were positive.
Positive
Continue support of
applications as
received.
Timeframe
Continue/Modify/
Delete
2029 Housing
Element.
On-going
Continue
This program will be
included in the 2021 -
City of Tustin Appendix A
Draft Housing Element FEBRUARY
JULY 2022
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.
1St deadlines.
This program will be
Housing element, prepare an
included in the 2021 -
annual report to the Planning
2029 Housing
m
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 FEBRUARY
JULY 2022
FEW
Program
1.19 Consolidated Plan
The City of Tustin shall prepare
an update of the Consolidated
Plan that provides a comprehen-
sive assessment of housing needs,
a housing development plan
incorporating Federal, State and
local public and private resources,
and a one-year implementation
plan.
Housing Element Policies: 1.12,
1.16, 1.18, 2.1, 4.1, 4.2, 4.3, 4.4, 5.1,
5.2, 5.3, 5.4, 5.5
1.20 Zoning Studies
To facilitate the new construction
goals of the 2012 Regional Housing
Needs Assessment, the City
intends to undertake zoning
studies to consider new programs
to encourage and promote
affordable housing and
recommend appropriate
amendments for actions by the
PlanninLy Commission and the Citv
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
Community
Development
Department
Successor Agency
and Community
Development
Department
Funding
Source
Variety of local,
State, and
Federal funding;
City General
Fund Staff time
City General
Fund,
2013-2021
Quantified
Objective
Prepare Consolidated
Plan in 2014
Prepare Action Plan
annually
Initiate Zoning Studies
by 2015 and complete
any proposed
amendments by 2021.
A-30
Results
Units Effectiveness
Positive
DCCSP area 140 new
units constructed to
date (all within the
Vintage
Development). Of
note, this development
participated in the in -
lieu fee option
regarding affordable
housing provisions.
All units were market
The City prepared and
the City Council
adopted the 2015-2020
Consolidated Plan on
April 21, 2015.
The City prepared and
the City Council
adopted, the 2020-2025
Consolidated Plan on
April 21, 2020.
Action Plans continue
to be prepared and
adopted annually.
Positive
In 2018, the Tustin City
Council adopted a new
specific plan document,
the Downtown
Commercial Core
Specific Plan (DCCSP).
This plan introduced
mixed-use and infused
the potential for 887
units into the area
Timeframe
Continue/Modify/
Delete
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Opportunities will
continue to be
explored relative to
this these and
Appendix A
FEBRUARY
JULY 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters Results
Program Responsible Funding Quantified Units Effectiveness
Agency Source Objective
Council. These studies include:
rate.
through a Residential
(1) Creation of zoning provisions
Allocation Reservation
which will accommodate
(RAR) review process.
mixed uses in portions of the
Said plan was an
City, particularly in the Old
Orange County
Town Commercial Area;
American Planning
Association award
(2) Provide relaxation of certain
winner.
development standards and
the Red Hill
incentives for projects which
ASpecific Plan
Avenue
include affordable housing
(RHASP) was adopted
units particularly housing
the Tustin City
units for the extremely -low
Council. The RHASP
C
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.
City of Tustin
Draft Housing Element
A-31
In 2018, the City
adopted the Workforce
Housing Ordinance
which currently affects
both the DCCSP &
RHASP areas.
In 2020, Citv staff
Timeframe
Continue/Modify/
Delete
potentially other
zoning related
studies.
Appendix A
FEBRUARY
n RY
JULY 2022
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
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.
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
This program will be
new residential developments. To
implemented in most
included in the 2021 -
reduce construction costs,
Tustin Legacy area
2029 Housing
developers may be permitted to
residential
Element.
install private rather than public
developments that
streets, wherever feasible.
occurred during this
time period.
Housing Element Policies: 1.17
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 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
The State of California has
Community
Fund; Staff time
period, the City
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 FEBRUARY
JULY 2022
A-33
1.23 Site Improvements
Community
Developer
Evaluate the use of
Positive
On-going.
The requirement for the developer
Development
Department,
funded
special assessment
district funding at
Assessments were
Continue
to construct site improvements
Tustin Legacy and its
issued for a
This program will be
often results in passing these costs
use in other developing
Community Facilities
included in the 2021-
on the housing consumer. These
areas.
District Annexation
2029 Housing
costs are reflected in the cost of
Area at Tustin Legacy
Element.
housing that eliminates an even
in 2014 (CFD 14-01) for
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 for a new
facility district on a per parcel
Community Facilities
benefit basis may enable a greater
District
proportion of the market to
Improvemmenteat Area 1
qualify for housing. Assessment
(CFD 18-01 IA 1) at
district financing has been
Tustin Legacy in 2018
implemented in the East Tustin
for the Lennar Homes
and Tustin Legacy areas and is
of Southern California
being used to pay for public
(formerly CalAtlantic
improvements. The City will
Homes) development
assess opportunities to continue to
of 218 townhomes,
utilize these public improvement
flats, and single-family
financing techniques in newly
homes and for
developing areas such as Tustin
Brookfield Homes of
Legacy and determine whether
Southern California, a
they are financially feasible. In
future development of
creating any new assessment
400 townhomes, flats,
districts, an evaluation should be
and single-family
completed of the developer's
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
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 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
Legacy, the City will
continue to evaluate
financing mechanisms
to fund infrastructure
improvements.
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
A-35
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Housing Element Policies: 1.12
City of Tustin
Draft Housing Element
FEW
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.
Appendix A
FEBRUARY
JULY 2022
Program Parameters
Responsible
Units
Results
Timeframe
Program
Funding
Quantified
Effectiveness
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
Consider waiving or modifying
Department,
economic downturns.
policy has been
This program will be
various fees or exactions normally
evaluated and
included in the 2021-
required where such waiver will
considered on an
2029 Housing
reduce the affordability gap
annual basis. No
Element.
associated with providing
changes to date
housing of the elderly and for
though continually
very -low and low-income
being monitored and
households.
considered.
Housing Element Policies: 1.12
City of Tustin
Draft Housing Element
FEW
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.
Appendix A
FEBRUARY
JULY 2022
1.25 Environmental
Community
General Fund;
On-going
Effective
On-going
Constraints
Development
Private
During the Housing
Continue
Continue to alleviate the necessity
Department,
developer cost
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
2029 Housing
into the development plans by re-
Specific Plan included
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 EIR 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 a large
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
Department
density bonuses.
In 2015, two apartment
Continue
facilitate the construction of
developments that
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 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
affordable housing. Under State
were granted density
This program will be
law, applicants may file for
bonuses by the City in
included in the 2021 -
density bonuses when projects
November 2012 were
2029 Housing
incorporate units for very low,
completed. The
Element
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
MCAS Tustin
Achieved
Continue
Implementation of the Specific
This program will be
Plan for MCAS -Tustin site
included in the 2021 -
Housing Element Policies: 1.1, 1.3,
2029 Housing
1.5
Element
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
F.M.
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
Department,
400 Tustin residents
annually, 3,000
Fair Housing
Continue
housing counseling services to
City's contractor
residents by 2021.
Foundation estimated
This program will be
assure equal housing
that the number of
included in the 2021-
opportunities within the City.
Tustin residents
2029 Housing
The City allocates approximately
provided with direct
Element
$15,000 annually for handling
client assistance
tenant/landlord disputes,
during this planning
housing discrimination cases,
period was 1,333.
counseling, tenant rights, fair
Yearly educational and
housing education, and education
outreach activities
within the City. The City will
occurred including
continue to promote the fair
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
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 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
Continue to provide coordination
Services
The City provided
Continue
and support to a home sharing
Department, and
coordination and
This program will be
program funded in part by the
Community
support through the
included in the 2021-
Community SeniorServ, formerly
Development
referenced program
2029 Housing
known as Feedback Foundation,
Department
and providers. In
Element
Inc., as part of TLC
2020, the Community
(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
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
FEW El
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
seniors at the facility.
See also Senior
Services Program.
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 FEBRUARY
JULY 2022
A-41
2.3 Housing Referral Program
Police
City General
• 7,500 referrals to
Effective
On-going
Continue to provide housing
Department;
Fund, CDBG
Funds
social agencies by
The Economic
Continue
referral services to families in
Parks and
2021
Development
This program will be
need of housing assistance and
Recreation
• 50 referrals for
Department and
included in the 2021 -
information. This program
Department;
shared housingb Y
Tustin Housing
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
homeless people to different
To assist referrals, the
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 of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 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
City departments utilize the
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 FEBRUARY
JULY 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
Modify - The
The Housing Authority applies
eliminated low- and
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
made it more difficult
MCC and continue
State and Federal 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.
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
RX, FI
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
Bonding Programs
See Program1.13
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
This program will
necessary, for the development
-
included in the 2021b-
and operation of federally assisted
2029 Housing
low- and moderate -income
Element
housing programs.
Housing Element Policies: 1.3,1.7,
1.14
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
A-45
4.2 Rental Assistance
County of Orange
HUD
Issue 200
Effective
On-going
Encourage the availability of
Housing
Authority
certificates/vouchers
annually-1,600 by 2021.
The Orange County
Continue
Section 8 rental assistance
Housing Authority
program will be
certificates and voucher certificate
issued the following
mclThis
ded in the 2021-
program assistance funds through
annual voucher counts
2029 Housing
2029 Ho
the Orange County Housing
for Tustin residents:
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
566 vouchers
Tustin residents, and promote
ludes
Section 8 program to apartments
(incl51 VASH
(inc
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 be
To maintain 74 units of affordable
included in the 2021-
housing for Seniors located at
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
I_Q[01
Program
17432-17442 Mitchell Avenue (20
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
Housing
Tustin has four (4) low-income
housing project with a total of 517
units "at -risk" of conversion to
market rate during the planning
period. If project owners choose
to convert the projects to market
rate housing, the City will
coordinate the provision of
financial and administrative
resources to preserve these units
as affordable housing.
a) Monitor Units at Risk:
Maintain contact with owners
of at -risk units as potential
conversion dates approach to
determine whether Section 8
contracts or affordability
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
Community
Development
Department,
Housing
Authority
Housing
Authority
working with a
non-profit
affordable
housing developer
Community
Development
Funding
Source
State and Federal
Funds
4% Tax Credit
and Bond
Financing, other
funding sources
State grants and
HUD funds
2013-2021
Quantified
Objective
Pursuant to
Government Code
Section 65583.1(c),
preserve at minimum
100units currently
identified as "at- risk"
at Tustin Gardens for
the time frames
required by applicable
Government Code
Section
65583.1. (c) (2) (C) (i) or
Health and Safety Code
section
Preserve 100 units at
Tustin Gardens
OWN
Units
The 100 at -risk units
(Tustin Gardens)
were maintained.
Also, despite the
elimination of a major
funding source, the
Housing Authority
was also able to
preserve a total of
two low- income
units and one very
low-income unit in
foreclosure by
purchasing them and
selling them to other
families.
Results
Effectiveness
Effective
The City maintains
contact with Tustin
Gardens and has been
monitoring their
annual renewal option.
Annual Monitoring:
The Housing
Authority annually
mails letters to
homeowners
requesting
documentation
verifying continuing
compliance with the
affordability covenants
they entered into with
the City when they
Timeframe
Continue/Modify/
Delete
2029 Housing
Element
On-going and
modify as additional
housing projects will
fall within this
program category
over the next
planning period
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
FEBRUARY
JULY 2022
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
covenants have been renewed
Housing
purchased their
or are planned to be renewed.
Authority
affordable unit.
Discuss with the owner of the
Affordable Units at
"at -risk" projects the City's
Risk of Foreclosure:The
desire to preserve the units as
Successor Agency,
affordable.
now Housing
b) Work with a nonprofit
Authority, prepared
affordable housing developer
monthly foreclosure
to apply for 4% Tax
reports to all City
Credit/Bond Financing for the
operating departments
acquisition and rehabilitation
in order to monitor
of Tustin Gardens, preserving
and keep City
100 at -risk units.
sensitive to the
c) Tenant Education. Work with
implications on
property conditions
tenants of at -risk units in
and blight as a result
danger of converting. Provide
of the foreclosure
tenants with information
activity associated
regarding potential tenant
with periods of
purchase of buildings
economic downturn in
including written information
the residential and
and any related workshops.
commercial markets,
Act as a liaison between
tenants and nonprofits
The Housing
potentially involved in
Authority (created in
constructing or acquiring
2011) was created by
replacement housing. If
the City Council to
existing staff is not able to
assist the City in
provide adequate staffing for
increasing, improving
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
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
this program, provide outside
and preserving its
consultants to support the
supply of affordable
program.
housing.
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 HousingDefault
4.3, 4.4
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
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
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
Revolving Fund and
the fund was
dissolved. The loss of
a funding source made
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
accordance with
Continue
Income Households
Community
prevent extremely low-
A
AB 987, the Housing
Assist in the provision of
Development
income households to
Authority maintains
This program will be
temporary and emergency
Department
become homeless by
a list on the City's
included in the 2021 -
housing assistance to prevent
providing links and
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
1
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
homelessness for the extremely
program information on
website of all
2029 Housing
low-income households as well as
City's website and at
affordable ownership
Element
coordination with regional, state
the Tustin Library,
units and affordable
and federal assistance programs
Senior Center, and
rental units in the
for assisting these households in
Family and Youth
City of Tustin. In
the percentage of their incomes
Center
addition, links to
that are applied to rent (i.e.
other affordable
increase in allocation of Section 8
housing sites and
existing rental certificates, etc.).
documents are also
Housing Element Policies: 1.7,
provided on thewebsite.
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
residential units in target areas
resources
(2) four-plexes by
This program will be
conveying 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.
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
I_M.'2I
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
Mobile Homes
See Program 1.2
Deed Restrictions:
See Program 1.4
Transitional Housing
See Program 1.10
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
Continue to enforce building and
Department
cases annually and
240cases by 2021.
are not kept by the
This program will be
housing codes to ensure health
City, the City's Code
included in the 2021-
and safety, rectify Code violations
Enforcement Staff
2029 Housing
and thereby improve the overall
estimated that over
Element
character of the community.
2,300 property
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
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
A-52
Program
to demolish, rebuild, or correct
the code violations. This program
includes notification of taxing
agencies upon failure to gain code
compliance from the property
owner to allow City to recover
enforcement cost.
Housing Element Policies: 5.3, 5.4
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified Units
Agency Source Objective
A-53
Results
Effectiveness
successful in getting
property owners to
abate code violations.
Most tenant calls that
are generally received
by Code Enforcement
are very minor
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.
Timeframe
Continue/Modify/
Delete
Appendix A
FEBRUARY
JULY 2022
5.2 Cultural Resources
Community
CDBG, City
Rate historic structures
Effective
On-going
District
Development
General Fund,
where applicable and
Process Certificates of
Continue
There are a large number of struc-
Department
State grants
process certificates of
Appropriateness as
tures in the City that were
appropriateness as
received.
received.
This program will be
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-
improvements to
guard the heritage of the City by
properties located
preserving neighborhoods and
within the Cultural
structures that reflect the City's
Resources District by
heritage and past. Through the
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 FEBRUARY
JULY 2022
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 I See Program 1.19
Building Codes I See Program 1.22
Goal 6: Environmental
Sensitivity
6.1 Energy Conservation Community None necessary Require all new units
Development within planning period.
Require all new construction to be Department
subject to State energy conserva-
tion requirements (Title 24) as a
condition for the issuance of a
building permit.
Housing Element Policies: 6.2
6.2 Energy Rebate Program
Community
General Fund,
Seek available grants to
Partner with Utility Companies to
Development
potential Grants
partner with utility
promote energy rebate programs.
Department
California HERO
companies to promote
No fee or discounted permits for
Element
distributed eeneration
energy rebate
energy efficient projects over and
programs.
above the Title 24 requirements
may be explored. Examples
include installation of
Effective I On-going
In force. See Program
Continue
1.7, Permit
Continue
Coordination, for
This program will be
City may benefit from
included in the 2021-
statistics.
2029 Housing
California HERO
Element
Effective
On-going
Since 2013, all
Continue
properties within the
City may benefit from
This program will be
inclusion in the
included in the 2021-
California HERO
2029 Housing
Program to finance
Element
distributed eeneration
City of Tustin Appendix A
Draft Housing Element FEBRUARY
JULY 2022
M.1 111
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
photovoltaic systems, tank -less
renewable energy
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
Draft Housing Element
rNe"T97
Appendix A
FEBRUARY
6.3 Solar Energy and
Conservation
Require that environmental
analysis and subdivision plans
address energy conservation
measures and solar access. With
the passage of AB 32, the City in
anticipation with the State
mandates will set thresholds
within its CEQA checklist and
require developers to address
energy conservation measures
applicable to their proposed
development proposals.
Housing Element Policies: 6.2, 6.3
Community None necessary On-going
Development
Department
Effective
CEQA checklist
updated to include
greenhouse gas
emissions.
Supported solar panels
installation in
residential and
commercial buildings.
During the planning
period, the City issued
the following number
of residential and non-
residential solar panel
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,
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element
City of Tustin Appendix A
Draft Housing Element FEBRUARY
JULY 2022
I_WA
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
commercial and
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
DevelopmentDepartment
On-going
Continue/Modify
orienting homes to maximize
This program will be
natural day lighting. The City
included in the 2021-
will work with potential
2029 Housing
developers during the conceptual
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 FEBRUARY
JULY 2022
6.5 Water Efficiency
Promote water -efficient
landscapes, efficient irrigation,
and use of permeable paving
materials. Through educational
materials and trainings, the City
will promote water efficiency
methods to its residents.
Landscape beautification which
results in water conservation
could be encouraged through
planting of drought tolerant
plants, installation of drip
irrigation, installation of rain
detector/ sensor irrigation, etc.
Incentives such as over the
counter permit plan check,
discounted fee, or waiver of
permit fee could be considered.
Housing Element Policies: 6.4
City of Tustin
Draft Housing Element
Community None necessary
Development
Department
Promote water efficient
programs by
conducting workshops
and providing
education materials on
the City Website, public
counter and at schools.
A-59
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 also 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. An
annual report
activities
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
FEBRUARY
n RY
JULY 2022
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
between January 1st
and December 31st of
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
City of Tustin
Appendix A
Draft Housing Element FEBRUARY
JULY 2022
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 efficient
landscaping. Said
video received an
Orange County
American Planning
Association award.
6.6 Green Building
Community
General Fund
Continue to explore
Effective
On-going
Streamline processing for
Development
Department
green building and
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 FEBRUARY
JULY 2022
TABLE A-3
PROGRESS TOWARDS OBJECTIVES 2013-2021
CITY OF TUSTIN
Quantified I Extremely Very
Unit Type/Description I Objectives I Accomplishments' 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)
Undefined
Undeterminable
Neighborhood D
1,048
533
37
496
Neighborhood G
1,247
818
88
73
64
593
Units Approved/Under
12 ADU's
Construction (2020
Undefined
(undefined income)
Annual Progress Report))
Undefined
Undeterminable
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 MID
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
1 124
1,310
1,534
(includes 1,522 units +
12 ADU's approved
and under
ACTUAL TOTAL UNITS
Required
construction)
N] ]
7-1
115
1,240
CONSTRUCTED
1,227
Note: Statistics show
1,562 new residential
projects completed in
planning period -
REHABILITATION
Single and Multi -Family
Rehab
Undefined
Undeterminable
Single Family
Undefined
Undeterminable
Multi -Family
Undefined
Undeterminable
Multi -Family Rental
Acquisition/ Rehab/ Conv
ersion/Resale
Undefined
Undeterminable
CITY OF TUSTIN
GENERAL PLAN
20211ULY 2022
A-62
APPENDIX A
HOUSING ELEMENT
OCTOBER
TABLE A-3
PROGRESS TOWARDS OBJECTIVES 2013-2021
CITY OF TUSTIN
Unit Type/Description
Quantified
Objectives
Accomplishments 1
Extremely
Low
Very
Low
Low
Moderate
Upper
Supportive Services
Programs -
Undefined
services provided
Tustin Legacy New
Of Note - 5,307
8
Construction Inclusionary
452
residential additions
Total Rehabilitation
Undefined
and alterations
Other Administrative
realized during the
Support (Housing
planning period
PRESERVATION
Tustin Gardens I 100 100 100
Total Preservation 100 100 100
OTHER FOCUSED
AFFORDABLE
HOUSING PROGRAMS
Homeless Assistance &
Variety of
A variety of support
Supportive Services
Programs -
Undefined
services provided
Tustin Legacy New
Construction Inclusionary
452
230
Housing Requirement
Other Administrative
Support (Housing
Authority; Density
Variety of
Bonus'; Affordable
Programs -
A variety of support
Housing Assistance
Undefined
services provided
Programs (associated
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)
CITY OF TUSTIN
GENERAL PLAN
20211ULY 2022
A-63
APPENDIX A
HOUSING ELEMENT
OCTOBER
CITY OF TUSTIN
GENERAL PLAN
APPENDIX B
SITES INVENTORY
B-1
HOUSING ELEMENT
JULY 2022
APPENDIX S
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
Income Group
RHNA
Units
Approved
ADUs
Permitted
Net RHNA
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 1(61) 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 EI 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 13-
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 under- the e^rtre'ontrolled e 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 T-L-SPLegacy 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 24258 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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-5 SEPTEMBER 2022
Development Director or the Planning Commission/ City Council, as applicable. The
RAR is the mechanism with an associated process and timeline that allocates units to
a requested development. The units are drawn from a residential allocation bank
which assigns units by area and allows for transferability between areas. The
maximum density on an individual parcel may exceed 25 dwelling units per acre (the
General Plan's 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 manner. 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 2265 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 (DenU'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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-6 SEPTEMBER 2022
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 0.54 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 10566 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 Plar s High -Density- Residential zones maximum density) as long as the
total dwelling units allocated to the Specific Plan area is not exceeded. Therefore,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-7 SEPTEMBER 2022
densities above 25 units per acre are achievable in the DCCSP area. This Specific Plan
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-8 SEPTEMBER 2022
the site has since remained unoccupied. The commercial building at 105 El Camino
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-10 SEPTEMBER 2022
improvement -to -land value is high; however, as described, interest to redevelop the
site indicates redevelopment potential.
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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-11 SEPTEMBER 2022
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 -
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
Property
TLSP -
Neighborhood D
North (includes
Specific Plan
Vacant
296
555
230
66
72
187
amendment) (Site
1A)
TLSP -
Neighborhood D -
South (includes
Specific Plan
Vacant
532
1,396
314
218
244
620
amendment) (Site
1B) (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
GENERAL PLAN
B-13
DRAFT HOUSING ELEMENT
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
Property
3 Non -
Vacant
Site 3 (Approved
Vacant/
Entitlements)
Non-
Vacant-
Approved
6
137
6
0
0
131
Housing
Project
Site 4
Non -vacant
0
2261-65
57-675
36-56-7
38-6049
9-5 433-3
Site 5
Non -vacant
0
32
8
5
3
16
Site 6
Non -vacant
0
1056.6
2-6-4355
184-73-7
18-2040
442434
DCCSP (Sites 7 -16)
4 Vacant
5 Non-
39
747
137
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
GENERAL PLAN
B-14
DRAFT HOUSING ELEMENT
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
Property
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
Place
Non -vacant
0
900
225
141
150
384
Projected ADU &
35
9
6
6
14
JADUs
Entitled Units
(Transitional
Vacant -
Approved
Homes) - approved
7
7
0
0
0
entitlements,
Housing
Project
permits in progress.
RHNA
6,782
1,724
1,046
11132
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.
Zonm
Sites 1 through 16, identified sites -to meet RHNA, have appropriate zoning to allow
residential development; at densities to achieve the estimated capacities and, without
inhibitors, such as stringent standards, that inhibit residential development. 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
Zoning
Site Size
(Acres)
Lot
Consolidation
Potential
Available
Infrastructure
Tustin Legacy Specific Plan Area
1
Vacant,
Yes*
Varies
Yes
Planned as
Neighborhood
part of
D North and
Master
South.
Planned
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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
Red
Hill Avenue S eci c 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
7.08548
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 E1
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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 1-5
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
Zoning
Site Size
(Acres)
Lot
Consolidation
Potential
Available
Infrastructure
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 Development 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-
rocess
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
2City 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, narking, commercial
components when -Dart of a mixed-use development (Refer to Attachment B -1A for
net area calculations):
• The TLSP area is anticipated to provide capacity of
o 555 units over approximately 40 acres in Neighborhood D North (40
du/ac minimum);
o 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).' 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
GENERAL PLAN
B-22
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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
o 395 units over approximately 10 acres north of I-5 (40 du/ac) and
o 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 41 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
GENERAL PLAN
B-24
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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.
(;vvrvrnl
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
GENERAL PLAN
MW
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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
Proposed Zone:
Allow mixed-use development with
minimum 30/ du acre (Refer to Program
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
During Planning Period:
Rezone properties to allow mixed-use,
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
GENERAL PLAN
I
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
TABLE B-5
The Market Place
Existing Zone:
PCMU - SP 8 (East Tustin Specific Plan)
Proposed Zone:
Allow mixed-use development with
minimum 30/du acre (Refer to Program
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
During Planning Period:
Rezone properties to allow mixed-use,
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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*
Site
#
Site Reference
Vacant or
Non-
Vacant
Identified in
Previous 4th
&/Or 5th
Cycles / Was
Counted
Towards
RHNA
Site
Size
(Acres)
APNs
Ownership
Zoning
General
Plan
Capacity
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
1B
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
GENERAL PLAN
mm -
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
B-33
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4th
Vacant or
&/Or 51h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
Vacant
Counted
(Acres)
Towards
RHNA
2
Neighborhood G PA 15
Vacant
Yes (both) /
50.321
City of Tustin
SP 1
TLSP
2,8229
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
GENERAL PLAN
B-33
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
B-34
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4th
Vacant or
&/Or 51h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
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
GENERAL PLAN
B-34
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
B-35
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4th
Vacant or
&/Or 51h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
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
GENERAL PLAN
B-35
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4th
Vacant or
&/Or 51h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
B-37
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4th
Vacant or
&/Or 51h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
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 4 150 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
Pacific
SP 12
DCCSP
Arvida Book Store, previously Mrs.
Maintenance &
DA -4
B's)
Repair Inc.
CITY OF TUSTIN
GENERAL PLAN
B-37
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
FORM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4th
Vacant or
&/Or 51h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
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 & 61h 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 171hSt, 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
GENERAL PLAN
FORM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Note: Unit capacity incorporates anticipated TLSP rezone (Neighborhood D — North)
CITY OF TUSTIN
GENERAL PLAN
1e�3e']
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4th
Vacant or
&/Or 51h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
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, near the City of
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
GENERAL PLAN
1e�3e']
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Attachment B -1A
Sites Identification to Meet RHNA - Realistic Capacity Estimates
CITY OF TUSTIN
GENERAL PLAN
C mll
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Site
Density
(Gross Land Area)
REALISTIC CAPACITY
Density (Net Land Area)*
# 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
819
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
GENERAL PLAN
C mll
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Suitable Sites for Additional►
Residential Development
II
40
r
Suitable Site Locations
I Downtown Commercial Core Specific Plan
Q Red Hill Avenue Specific Plan
® Tustin Legacy Specific Plan
- Enderle Center
- Tustin Marketplace
Q Municipal Boundaries
N
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-41 SEPTEMBER 2022
Tustin
2021-2029
Mousing E]emenl
Attachment B-2
Tustin Legacy Specific Plan
Site Aerials / Individual Site APN Maps
---i IS ".j lig LEGEND
mow/ 1,... .. '•.V
�.-. Ne ghborha oA .A
Site 2
TLSP NEIGHBORHOOD G
Site 1A�'
HIigLEO"l oEA
FTLSP NEIGHBORHOOD D NORTH �Nek rtiooe., '
• Area does not have resident!
units planned
Amend TLSP to accommodat D North
a minimum of 555 additional I
units to meet RHNA ��-J-
39.873 acres (VACANT) F
I L]
oe
Ouch
G • 2,029 remaining units in this area
• Amend TLSP to accommodate a
minimum of 200 additional housing
a units to meet RHNA
_ • 50.321 acres (VACANT)
SITE 18
TLSP NEIGHBORHOOD D SOUTH
• 1,296 remaining units in this area (includes 400
F approved units — Brookfield)
Amend TLSP to accommodate a minimum of 100
1 additional housing units to meet RHNA
• 45 acres (VACANT)
F' -15[G
�a-
The sites in TLSP are vacant. Development is under the control of the City since the City owns the land.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN SEPTEMBER 2022
B-42
SITE 1A: NEIGHBORHOOD D North {Re.ZOV0
39.873 Acres Zoning: SP 1
General Plan. TLSP 555 Units
,address
APN
A1CITii
'I:
arrQa,
TwUn
Legacy
Specific
43[7 381-3$
0.002
Plan
39.873
North
43 i>`331'41
F.4f 6
430-331-91
L235
43[7-381-}5
317
Source: Orange county Assessor Parcel
Map
alp -H
.Y*Mf wj
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-43 SEPTEMBER 2022
Site 113 NEIGHBORHOOD p SOUTH
45 Acres 1396 Units
Zoning: SP 1 General Plan: TLSP
includes Brookfield Development (400 units)
1,208 Future Units- Multiple Family
Address
APO Acre
-
Total
Acreage.
1B
South
Brookfield
f
Tract
1.8191
Lot 2 5.789
44.86
Lot 5 2,778
Lot 6 2-635
Ludt 7 2,572
Lot 4.012
3.
Lot 9 9$4
Lot 14 4.163
Lut11 7.039
Lot 12 6.934
Lot 13 5.451
Source; Orange County Assessor Map
CITY OF TUSTIN
GENERAL PLAN
B-44
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
NEIGHBORHOOD G
Add'e's.
APN
Acre I Tia!
Acreage
d3D-3$1-
Nii*hbar
�7
0.665
430.381-
liaod
3,573
28
3.555
430-381-
25
1.34'4
5ourm Orange County Assessor Parcel Map °N" AV
wcr IC, !FNI Y4 iP'i rc l! ihe:,
„&38
Hl�'J �YW'�1 jr6f 17p � N
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-45 SEPTEMBER 2022
Continued
NEIGHBORHOOD G
Address I APN I Aare
Ac
affrif1s ALK r�a
xW mi -i +o f�
ilp/ Y�5 9Q4 -n fr, f,
45 g5d
46.748 41
�uraf
'9-
430-3911
9
4301-393 4 V Al
62 3.336
430-391-
53 7.232
430-391-
64 3536
Source' Orange [auintyAss essor Parcell �wirr2wn
Map
CITY OF TUSTIN
GENERAL PLAN
NO l •
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
430-391-
03
19,01
430-391-
30.391•29
22
4."6
430-391-
23
9,096
430-391-
56
3.396
430-391•
NAghborho
59
0,109
cid G
430-391-
50
0.339
430.391
51
i
Ac
affrif1s ALK r�a
xW mi -i +o f�
ilp/ Y�5 9Q4 -n fr, f,
45 g5d
46.748 41
�uraf
'9-
430-3911
9
4301-393 4 V Al
62 3.336
430-391-
53 7.232
430-391-
64 3536
Source' Orange [auintyAss essor Parcell �wirr2wn
Map
CITY OF TUSTIN
GENERAL PLAN
NO l •
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Attachment B-2
Red Hill Avenue Specific Plan
Site Aerials / Individual Site APN Maps
SPECIFIC PLAN
Site 4
- 226 housing units
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-47 SEPTEMBER 2022
SITE 3: 13751- 13841 RED
HILL AVENUE
(Z Parcels) Pending Project
3.37 Acres Zoning: SP 13
General Plan: RHASP
Address
AVN
Acre
Total
AcTeage
13751 Red
Hill
500 -141 -
Avenue
09 0.46
3 71
Hill
500-141-
10
2.91
Smrce' KealQue-st
CITY OF TUSTIN
GENERAL PLAN
7
I X4 1 ;11
it is
No.
,or or 14L)
Ck
ft DAM"
--ako
Ell El
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 4: 13822 —13852 RED HILL
AVENUE
a}
Red Hill Plaza
7.08 Acres - RHASP Zoning: SP 13
General Plan:
Address APN Acre
1b al
AcreW
13822 Red 500 -022 -
Hill Avenuel 12 4.9
No Address
500-022-
I
7.08
Listed
09
4,25
13852 Red
300 -022 -
Hill Avenue
04
1.4
Source: RealQuest
-:A .u..6aY'1 ice, i r- i, W, II
�� u meta w aryi.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-49 SEPTEMBER 2022
a}
K
�e
JV
I
Jim
I
� J
a�a ax
o
Mia
Wo Illi
RAW silk
Yi r -A
RW as us lkx 11-rs
ftM +w
v.N if l%I "f -r
-:A .u..6aY'1 ice, i r- i, W, II
�� u meta w aryi.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-49 SEPTEMBER 2022
K
�e
JV
I
-:A .u..6aY'1 ice, i r- i, W, II
�� u meta w aryi.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-49 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
SITES: 1571 EL CAMINO REAL
Denny's Restaurant
O.90 Acres Zoning: 5P 13 General Purr: y,
RHASP y+�LL
Liu
Address APN Acre Total
I
Acreage .'
9
1571 El 500-021-02 � 14
LamlrinReal
5
1 �
I I • � I lI59S d rnr . ,,
I
�
"4
aex ae
I
�+
F
Source: ReaGQuest
Mhz Mil
Jdf sm.
Mk. "A
Iww
It
17* rrsa
mm
59
arra- —
L
w
:X-02
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE6' 14081— 14231 RED HILL AVENUE
Starer Brothers Shopping CenUF
5.95 A-- FonlPrg: 5P 13 Gmn l PIAn: RHAW
Addresses
541. rta•:
R�Iuwsr Neap
DOW AR Pa
L ---j
IILT�l 06
L
b r
.seen
i
AM
ACRES
Tatal Avrea
14081 Red Hill
432.041-04
0.53
Ao.nuE
6
1431 Sed HIMI
t13z-x741-1.4
p.33
�hdeP,J�
5,J5
14,'131Red Hill
43;-041-17
0.1f,
Avenue
�
3
14171 Hid FIIMI
43104115
kM
Avenue
I
14171 Red Hill
432-041-20
2.60
Avenue
14113 AF.41 Hill
432-0 i] -ZS
1,50
AvPn11r
541. rta•:
R�Iuwsr Neap
DOW AR Pa
L ---j
IILT�l 06
L
b r
.seen
i
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-51 SEPTEMBER 2022
u. � - Art
tlr ltrl' L
6
i.
1
tf•ec
�
3
I
a
t
s
mm xsu
P Fm mom 51e.
Aff w, f
]LN l-1µ 1
1.r, i "
.Y., � DSII. r i1g0 1 AeoeO 011 W
n
WKM� x411, m 17Y. v 41
.WCre fw
A -Rkvr
1W Ie Ill . .MF+.M'+a-.-
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-51 SEPTEMBER 2022
Tustin
ii
L'
2027-2029
Housing Etement
Attachment B-2
Downtown Commercial Core Specific Plan
Site Aerials / Individual Site APN Maps
SITE 7
365 W. FIRST ST. & VACANT LAEVO ADJACENTTCI VILLA
VIENTO APTS. — 45 units
1.1 ACRES
�. .. ' SITES '� r
t
DOWNTOWN
COMMERCIAL CORE
SPECIFIC PLAN AREA
CITY OF TUSTIN
GENERAL PLAN
Rr SITE 8
140 W. FIRST STREET
BEL AIR MOTOR HOTEL -1 ACRE
SITE 3
. �4
SITE 9
0 E. FIRST STREET & 105 EL CAMINO REAL
TUSTIN WAR MEMC)RIALAND , AL it. I
WIENERSCHNITZEL
0.88 ACRES
SITE
Sites
I t:. Sites 8 & 9 — 92 units
IT -
mm-
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 7: 365 W. FIRST ST. &
VACANT LAND ADJACENT TO
VILLA VIENTO APARTMENTS
Approx. 1.1 Ares Zoning; SP 12
General Plan: RCCSP
Address
#PSI' _
LL Atre
'
Acreage
355 W.flr3t
401-523-30
0A
91.
1.1
Vacant
401-523.15
0.5
Frontap-of
partlnn]
WIU' IPIr
11.1[1 MC. Uf
Apartrrcr,ts
IVr,x
-4
V-4
5atjr e: City'ii5
"- a rm•5r
� Id4W ria r
L
1
r
r!{�lI IpW ;r.mr+r
ALIS i>ArytlLAY+r
�WIr W. ly
114E
•x 1111 J
N&
WIU' IPIr
11.1[1 MC. Uf
SM r!d
IVr,x
-4
V-4
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-53 SEPTEMBER 2022
SITES: 140 W. FIRST STREET
Bel Air Motor Hotel
1 Arse Ferning: SP 12 General Plan: DCCSP
Address
APN Acre I Total
Acreage
140
401 -
West
571-14
1 acre
1 alre
First
Street
Source: RealQuest
CITY OF TUSTIN
GENERAL PLAN
B-54
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 9: 150 E. FIRST STREET
105 EL CAMINO REAL
Tustin Warr Memorial and WienerschniltzeI
0.88Acres Zomimg. SP 12 General
Plan: DCCSP
,drams
APIA
AM
150 F. First
401-5834D1
01,43
—�
Sboet
+ $
S.
iia i
105 EI
401-583-15
01.45
RkrL10
fffe
3
Camino Real
. +r+•+ kv. +1�1 ruv Sj
RFid dd• am
Source-. RealQuest
55
Tr .,
ti:lh
MAO I � P 'ger
4
• ' � � �. wildt
•.-. h .sem
(D fj C�
NP -5 L
La
a [uBwl
—�
S.
iia i
•4
RkrL10
fffe
3
SLP
55
Tr .,
ti:lh
MAO I � P 'ger
4
• ' � � �. wildt
•.-. h .sem
(D fj C�
NP -5 L
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-55 SEPTEMBER 2022
La
a [uBwl
—�
RkrL10
fffe
3
-�i
Mrd i -d
. +r+•+ kv. +1�1 ruv Sj
RFid dd• am
go. ,-i9
.. +i • W ati a
A1�ka imf
JLliO" mi fw
mm w
PA dW. 1 -4r
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-55 SEPTEMBER 2022
Tustin
a' as
2821-2029
Housing Element
DOWNTOWN
COMMERCIAL
CORE
SPECIFIC
PLAN AREA
CITY OF TUSTIN
GENERAL PLAN
10
LARWIN SQUARE
SWC OF NEWPORT AVE & FIRST STREET 200 units
16.47 Acre
B-56
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 117: LARWIN SQUARE
16.47 acres Zoning: 5P 12 General Plan: DCCSP
Address AP N
Acre Tota! Acreage
630 E 1ST 5T
401-601-01
1.-20
D FI
13341
401-601-04
NEWP4AT AVE
0,32
13421
NEWPORT AVE
AOi-601-05
13451
NEWPORT AVE
401-601-06
0-3$ 16
1.3471 Newpart
Avti
401.601-07
0.39
550 E 1ST ST
401-601.-0
1.00
0.46
375
CENTENNIAL
401-601-09
WAY
0.91
662 E 15T ST
-
A0i-601-1b
Source: RedlQuest
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-57 SEPTEMBER 2022
I SITE 11 1
225 — 255 EL CAMINO REAL
& 250 PROSPECT AVE.
VACANT
1.02 ACRES
k
rz
11, .
r-9
SITE
DOWNTOWN
COMMERCIAL
CORE SITE 13
125 W. MAIN STREET— ADJACENT TO ARVIDA
SPECIFIC 1300K STORE; VACANT
0.25 acres
PLAN AREA SITE
!muff
Sites:
11, 12, 13, 14 —
150 units
CITY OF TUSTIN
GENERAL PLAN
LLE
w
Fl.]W.l
SITE 12
NEC of El CAMINO REAL &SIXTH STREET
542 EL CAMINO REAL; VACANT
2.28 Acres
SITE
SITE 14
420 EL CAMINO REAL; VACANT
0.44 Acres
SITE
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 11. 225 — 255 EL 4AMINO REAL
250 PROSPECT AVE.
Farmer's Market Temporary Use
1.42 Acres Zonirl • SP 12 General
'Plan. DCCSP
Addre55
APP
Acres
Tata
Acreage
0
i
r
Prospect
Avelmve
401-594-44
0.17
No acldi-ess
listed
411-584-05
4.17
255 El
Caminn
Real
4.01-584-06
4.17
245 E1
Camino
Reap
4D1-584-07
0.17
235 El
Camino
Real
4011-5$4-48
0.17
225 El
Camino
Real
.4-01-584-09,4.17
Source', RealCwest and Orange C�OUAty R'ubllr arks
19
M
01
"v)IMI
P
Vra errx 44 1-w
6PY7 AIL H
W7 IR w J4ly- dfi-+S
M:? C .4411 #,MM.14 m3 W
wd fie% 21 Jfe M—oP
L
117
i
r
L
a
57 6 I.—
alit 4H r* • : +-& f*i ++,r
erre eq lA tee, .....w
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-59 SEPTEMBER 2022
117
e. •e
Ifs
�wc€
�fl
a
57 6 I.—
alit 4H r* • : +-& f*i ++,r
erre eq lA tee, .....w
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-59 SEPTEMBER 2022
SITE 12: NEC of EI CAMINO
REAL & SIXTH STREET
542 EL CAMINO REAL
2.29 Acres toning. SP 12 General
Plan: OCCSP
Source: ReaiQuest
CITY OF TUSTIN
GENERAL PLAN
2%, —"V
V T'4rl rry
a�'�.a.� `s7 Sg
.. �b �' � T ��fl� ;li i.. • S7ilM Pt �
• P (D yea}
• � ` e rye �
V y i r rxur
a
L1 arra 1
4;7,4 rNrr u r e
'rRI r ks J AA N•!0 W, aynr�rs #T 1 uu waY NO �.
IRKr N@. Pd!Pi NLA 45-U n+�ai M' s IdV .0 0
IMYL IV "I PA41. tiro. a 4%42
C a1
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
A
-I -
Y
550 EI
,Camino Beal
401-623-14
0,50
2,29
No Listed
Address
401-623-15
1.1
F135F W 5th
401-523-1b
0.69
Source: ReaiQuest
CITY OF TUSTIN
GENERAL PLAN
2%, —"V
V T'4rl rry
a�'�.a.� `s7 Sg
.. �b �' � T ��fl� ;li i.. • S7ilM Pt �
• P (D yea}
• � ` e rye �
V y i r rxur
a
L1 arra 1
4;7,4 rNrr u r e
'rRI r ks J AA N•!0 W, aynr�rs #T 1 uu waY NO �.
IRKr N@. Pd!Pi NLA 45-U n+�ai M' s IdV .0 0
IMYL IV "I PA41. tiro. a 4%42
C a1
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 13: 125 W. MAIN
STREET - ADJACENT TO
ARVIDA BOOK STORE
0.25 Acres Zoning: SP 12
General Plan: DCCSP
Address
APAI
A47re
Total
�7 aw
Acreage
125 W.
401 -573 -
Mai [I ST
13
0,25
, 0.
Source: ReaJQuest
w Lv 13#1
�7 aw
®R
w Lv 13#1
0tl-57
L
UTV
L
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-61 SEPTEMBER 2022
�7 aw
.. .........
0tl-57
L
UTV
L
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 Pfau. DCCSP
.Acldress
4PN
AcM'-1
F
T 7
Ac
420 El
401-522-
0-44
0,44
Caminn
is
Real
CITY OF TUSTIN
GENERAL PLAN
40-;L,
INMI
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
F
T 7
L
pw
a,NhM K
Ax W."
vwwean
.- A
INMI
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 16
EL CAMINO PLAZA
SWC OF SIXTH STREET & EL CAMINO REAL
7.81 Acres
SITE 15 p""r
- TEL
14042 NEWPORT AVE. & EL CAMINO REAL
VACANT, 2.73 Acres k'-
-,.k%
40
SITE
F
DOWNTOWN
COMMERCIAL
CORE
SPECIFIC PLAN
AREA
Sites 15 & 16 —
SITE 260 housing
units
4�
Alf
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-63 SEPTEMBER 2022
SITE IS: 14042 NEWPORT
AVE. & EL CAMINO REAL
2.73 Acres Zoning� SP 12 General
Plan: DCCSP
Addreffs
AAN
AOA
Tool!
AoftW.,
14042
Newport
4�2-074-
Avenue
02
0.77
14042
Newport
432 -074 -
Avenue
07 0.675
14D42
Newport
432 -074 -
Avenue
08 0,378
14042
Newport
432 -074 -
Avenue
09
0.906
2.73
5rDurcf: RealQuest and OranNa Cou" Pwbli� Wwlks
CITY OF TUSTIN
GENERAL PLAN
- fflftw
I Awgn4 P40W
3
LAM v
C
mrK W 4c fqfaPirfW
MFL—"i &% M �Lk'_(' � ". , 1 1, . �
Awl %V AL 441—W, W1. "40 tkl �-, V
111-WeV
L
L-1
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 16: EL CAMINO PLAZA
7.91 Acres Zoning: SP 12 General Plaw
DCCSP
64
IL Gumm
ji
A
Sourre: RealQuest and City of Tustin GIS Database wro, 4E -SM MUA" AM AN 1,0
MACr in M io 'U. jo�?o
CITY OF TUSTIN
GENERALPLAN B-65
OM lqu�W3 k," A .3x7v-7 4.
�Aq.0 NA&A p 40 "'f 0
xw 0 nwa C"', a MWR
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
C-3 rn 1 n o
Real
101 -631 -DI
1�5
534 F1
Carnirio
Real
4DI-bAl-15
4.2
No Listed
Address
401-631-13
0.11
64
IL Gumm
ji
A
Sourre: RealQuest and City of Tustin GIS Database wro, 4E -SM MUA" AM AN 1,0
MACr in M io 'U. jo�?o
CITY OF TUSTIN
GENERALPLAN B-65
OM lqu�W3 k," A .3x7v-7 4.
�Aq.0 NA&A p 40 "'f 0
xw 0 nwa C"', a MWR
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Tustin
20 9
Housinil fJenmrd
CITY OF TUSTIN
GENERAL PLAN
Fl-we"o
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE #17: ENDERLE CENTER
11.62 acres Zoning: PCC
General Plan: PCCB
Partially or wholly suitable for
fesidential development
CITY OF TUSTIN
GENERAL PLAN
Enderle Center
4ok-25
14
- -------------
ASU3_�" S A" A ASW&W 5 ~
W[0,%Wjvf M -&LEM
Aom AW %A." m rjvnF; �, � �W".�
'A
I Mir,
DRAFT HOUSING ELEMENT
B-67 SEPTEMBER 2022
14081 Yorba St
401-251-04
1.05
17240 17th St
401-251-06
0.54
17280 17th St
401-252-05
0.52
17300 17th St
401-252-06
3.53
401-252-98
1.05
17481) 17th St
401-252-09
D.3
17440 17th St
401-252-10
3.32
14032 EnclerlL-
Center Dr
401-253-03
0.5
4{11-253-04
0.81
Total Site Acreage
11.62
Total Acreage Suitable for
Residential Development
7
Partially or wholly suitable for
fesidential development
CITY OF TUSTIN
GENERAL PLAN
Enderle Center
4ok-25
14
- -------------
ASU3_�" S A" A ASW&W 5 ~
W[0,%Wjvf M -&LEM
Aom AW %A." m rjvnF; �, � �W".�
'A
I Mir,
DRAFT HOUSING ELEMENT
B-67 SEPTEMBER 2022
Tustin
2021-2029
Housift Hememt
CITY OF TUSTIN
GENERAL PLAN
SITE 18
THE MARKETPLACE — 900 housing units
Total: 76.937 Acres
(Acreage suitable for redevelopment 18 acres)
, L'i A I A 4r -I.— —
KNOW]
SITE
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE #18: THE MARKETPLACE
76.937 acres Zoning: SP -8 General Plan: PCCB
E-1
2870 El, Camino Real
500-291-02
5.464
2982 El Camino Real
500-291-04
5.1s
2992 El Cam i n D Rea I
50CI-293.-06
0.5
3002 El Camino Real
500-291-07
0.41
3010 El Camino Real
50CI-291-08
033.
2995 El Cam i n o Rea 1
50G-29 1-11
0-5q
500-291-12
0.12
500-291-21
C-25
3020 El Cam i n o Rea 1
500-291-23
().5
3040 El Cam i n o Rea 1
500-291-24
0.78
3030 El Camino Real
509-291-25
19.226
2762 El Camino Real
5OG-291-26
1.562
2762 El Camino Real
50D-291-27
6�645
2741 El Camino Real
500-312-02
3.214
500-312-03
611
2851 El Camino Real
5OD-312-04
4
2961 El Cam i n o Rea 1
50(1-312-06
2.88
3025 El Camino Real
500-312-08
0.226
3015 El Cam i n ci Rea 1
500-312-09
500-312-10
_315
18555
Tota I Site Acreage
76.937
Total Acreage Suitable for
Residential Development
18
Partially or wholly suitable for
residentia I development
Market Place
I onfix A KIU
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-69 SEPTEMBER 2022
Tustin
61
2021-2029
Housing fJenwmt
CITY OF TUSTIN
GENERAL PLAN
Transitional Housing
r0we
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Tustin
2021--2029
"Gusing rjenterd
ADUs/JADUs — 35 housing units
Citywide: ADUs/JADUs
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERALPLAN B-71 SEPTEMBER 2022
Attachment B-3
Buffer
Site
Site Reference
Vacant or
Identified in
Site
APNs
Ownership
Zoning
General
Capacity
#
Non-
Previous 4 1h
Size
Plan
Vacant
&/Or 5 1h
(Acres)
Cycles / Was
Counted
Towards
RHNA
Tustin Legacy Specific Plan Area
I
Neighborhood D PA 8, 13 & 14
Vacant
Yes(both)/
City of Tustin
SID 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
GENERAL PLAN
B-72
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Attachment B-3
Buffer
Site
Site Reference
Vacant or
Identified in
Site
APNs
Ownership
Zoning
General
Capacity
#
Non-
Previous 4 1h
Size
Plan
Vacant
&/Or 5 1h
(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
GENERALPLAN
B-73
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
Attachment B-4
HCD Required Site Inventory Form
To Be Submitted Following Housing Element Adoption - As Allowed
B-74
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
APPENDIX C
AFFORDABLE HOUSING RESOURCES
CITY OF TUSTIN HOUSING ELEMENT
GENERAL PLAN JULY 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.
0 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
GENERAL PLAN
C-2
HOUSING ELEMENT
JULYF-F�� 2022
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.
0 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
GENERAL PLAN
C-3
HOUSING ELEMENT
JULYFIF�� 2022
costs for navigation centers and emergency shelters, and the new
construction, rehabilitation, and preservation of permanent and transitional
housing.
0 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 547 14 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.
0 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.
0 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.
0 Homeless Assistance and Supportive Services
The City has allocated $59,400 in 2021-22 Community Development Block
Grant (CDBG) fundsCPBC; funds to continue its financial support of homeless
assistance and supportive services in the City. The City's goal for this
CITY OF TUSTIN
GENERAL PLAN
C-4
HOUSING ELEMENT
JULYFIF�� 2022
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.
0 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.
0 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 strean-dining 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 Community Development Bloc
Grant (CDBG) funds. For FY 2020-2021, the City of Tustin was allocated
$847,890 in CDBG funds. These funds may be used for a number of
community development purposes besides housing. Given the many
competing needs for these funds and the restrictions on these funds for
CITY OF TUSTIN
GENERAL PLAN
C-5
HOUSING ELEMENT
JULYFIF�� 2022
housing purposes, the City does not typically allocate CDBG funds for
affordable housing development.
As needed and as shown on Table H-19, the City will utilize State and Federal
resources to leverage local resources as these funding sources match the City's
programmatic objectives. This table is a summary of affordable housing
resources.
CITY OF TUSTIN
GENERAL PLAN
C-6
HOUSING ELEMENT
JULYF-F�� 2022
This page intentionally left blank.
CITY OF TUSTIN
GENERAL PLAN
C-7
HOUSING ELEMENT
JULYF-F�� 2022
APPENDIX D
AFFIRMATIVELY FURTHERING FAIR HOUSING
CITY OF TUSTIN
GENERAL PLAN
D-1
HOUSING ELEMENT
JULY 2022
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
jurisdiction!s fair housing enforcement and outreach capacity; and
An analysis and summary of fair housing issues and identification of trends and
patterns within the City of Tustin in comparison to surrounding cities and the larger
Orange County region, including the topics of:
o Integration and segregation;
o Racially or ethnically concentrated areas of poverty;
o Disparities in access to opportunity, including for persons with disabilities; and
o Disproportionate housing needs (such as overpayment, overcrowding, housing
conditions disproportionately affecting protected classes), and displacement risk.
This analysis utilized available federal, state, and local data and knowledge to identify trends
and patterns in fair housing issues and identification of trends and patterns within the City of
Tustin. Orange County's Analysis of Impediments to Fair Housing Choice (AI) was prepared in
May 2020 and contains a thorough examination of structural barriers to fair housing choice and
access to opportunity for members of historically marginalized groups protected from
discrimination by the federal Fair Housing Act (FHA) within Orange County. The Al also
outlines fair housing priorities and goals to overcome fair housing issues. In addition, the Al
lays out meaningful strategies that can be implemented to achieve progress towards the
County's obligation to affirmatively furthering fair housing. The Al was prepared in
consultation with Orange County jurisdictions, including the City of Tustin, and with input
from a wide range of stakeholders through a community participation process. Barriers to fair
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-2 SEPTEMBERMARC44 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
0 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 SEPTEMBERMARC44 2022
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-4 SEPTEMBERMARC44 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 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.
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 SEPTEMBERMARC44 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;
• Hieh seareeation for His-Danic /White and Black /White Do-Dulations (as defined bv
Dissimilarity Index values which indicate geogjaphical segregation patternsl
• 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);
• High segfegation and severe housing issues for- the city's Blaek r-esidents;
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-5 SEPTEMBERMARC44 2022
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:
0 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 corrunitted 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 AB 686
In 2018, the California State Legislature passed AB 686 to expand upon the fair housing
requirements and protections outlined in the Fair Employment and Housing Act (FEHA). The
law:
• requires all state and local public agencies to facilitate deliberate action to explicitly
address, combat, and relieve disparities resulting from past patterns of segregation to
foster more inclusive communities; and
• creates new requirements that apply to all housing elements due for revision on or after
January 1, 2021.
The passage of AB 686 protects the requirement to affirmatively further fair housing within
California state law, regardless of future federal actions. It also preserves the strong policy in
the U.S. Department of Housing and Community Development's (HUD) Affirmatively
Furthering Fair Housing (AFFH) Rule as published in the Federal Register in 2015.
As of January 1, 2019, AB 686 proactively applies the obligation to affirmatively further fair
housing to all public agencies in California. Public agencies must now examine existing and
future policies, plans, programs, rules, practices, and related activities and make proactive
changes to promote more inclusive communities.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-6 SEPTEMBERMARC44 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 SEPTEMBERMARC44 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 AI 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:
0 524.19 (overlaps North Tustin)
0 525.02
0 525.24
0 744.07 (overlaps Santa Ana)
0 744.08
0 755.04 (overlaps Santa Ana)
0 755.05
0 755.06 (overlaps Santa Ana)
0 755.07
CITY OF TUSTIN
GENERAL PLAN
0 755.12
0 755.13
0 755.14
0 755.15 (overlaps a small portion of
Santa Ana and a large portion of
Irvine)
0 756.06 (overlaps North Tustin)
0 756.07
0 757.01 (overlaps North Tustin)
DRAFT HOUSING ELEMENT
D-8 SEPTEMBERMARC44 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:
0 754.03
0 756.03
0 757.02
0 744.06
0 756.05
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 SEPTEMBERMARC44 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
0 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 SEPTEMBERMARC44 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 SEPTEMBERMARC44 2022
Table 2: Race and Ethnicity
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D- 12 SEPTEMBERMARC44 2022
(Tustin, CA CDBG)
(Los Angeles - Long Beach -
jurisdiction
Anaheim, CA) Region
Race/ Ethnicity
Count
Percent
Count
Percent
White, Non-
24,289
30.36%
4,056,820
31.62%
Hispanic
Black, Non-
1,926
2.41%
859,086
6.70%
Hispanic
Hispanic
32,982
41.22%
5,700,860
4C44%
Asian/Pacific
Island, Non-
17,542
21.93%
1,888,969
14.72%
Hispanic
Native American,
418
0.52%
25,102
0.20%
Non -Hispanic
Two+ Races,
1,949
2.62%
267,038
2.08%
Non -Hispanic
Other, Non-
169
0.23%
30,960
0.24%
Hispanic
#1 country of
Mexico
11,270
14.09%
Mexico
1,735,902
14.34%
origin
#2 country of
Vietnam
2,115
2.64%
Philippines
288,529
2.38%
origin
#3 country of
India
2,048
2.56%
El Salvador
279,381
2.31%
origin
#4 country of
Philippines
1,677
2.10%
Vietnam
234,251
1.93%
origin
#5 country of
Korea
1,446
1.81%
Korea
224,370
1.85%
origin
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D- 12 SEPTEMBERMARC44 2022
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D- 13 SEPTEMBERMARC44 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
174,424
1.44%
Kong &
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
0
#10 LEP
Arabic
165
0.23%
Arabic
23,275
0.19%
Language
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D- 13 SEPTEMBERMARC44 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% 1,388,564 47.84%
children
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 SEPTEMBERMARC44 2022
Figure 1: Census Tracts in the City of Tustin
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-15 SEPTEMBERMAR-044 2022
Figure 2:2020 TCAC/HCD Opportunity Areas (Tustin)
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CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
SEPTEMBERMAR-044 2022
Figure 3:2021 HCD/TCAC Opportunity Areas (County)
1'111� Hill, Low,
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D- 17 SEPTEMBERMAR-044 2022
Figure 4: Areas of Minority Concentration in Tustin
.......................
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Source: AFFH Data Viewer Fro nch HO
CITY OF TUSTIN
GENERAL PLAN
D- 18
DRAFT HOUSING ELEMENT
SEPTEMBERMARC44 2022
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z
Park
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.......................
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Racial Demographics 2018 (Block Group) C neek Goll 0
Course
< 20%
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61-80%
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Garmin, IIINCREMENT P, USG , MET10M6UjPA, USIDA
Source: AFFH Data Viewer Fro nch HO
CITY OF TUSTIN
GENERAL PLAN
D- 18
DRAFT HOUSING ELEMENT
SEPTEMBERMARC44 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
Table 4: Dissimilarity Index Scores
Racial/ Ethnic Dissimilarity Index
Value
Level of Segregation
Dissimilarity Index Value (0-
100)
0-40
Low
Non-V\Thite/White
41-54
Medium
32.93
55-100
High
Table 4: Dissimilarity Index Scores
Racial/ Ethnic Dissimilarity Index
1990
Trend
2000
Trend
2010
Trend
2020
Tustin
Non-V\Thite/White
26.33
36.73
32.93
F48.19
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/V\rhite
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 SEPTEMBERMARC44 2022
Table 5: Tustin Isolation Index Scores
Isolation Index
1980
1990
2000
2010
2020
2020
(Orange
County)
White/White
83.7
66.3
54.3
43.2
52.44
55.16
Black/Black
6.1
9.9
3.6
2.7
4.84
3.32
Hispanic/ Hispanic
10.2
27
51.3
51.9
56.10
52.81
,Asian/Asian
4.4
12.1
19.6
26.7
19.86
31.84
Source: County of Orange, Analysis of Impediments, 2020
As shown in Figure 2, the city's highest resource areas are to the northeast and the low resource
areas are to the south and southwest. The city did not include any areas categorized as high
segregation and poverty (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 (1-5) (see Figure 3). Areas that were indicated as
rapidly changing were located along the perimeter between low resource and high resource
areas, particularly on the southern coastal side. The City of Tustin is not classified as a rapidly
changing area. This pattern indicates a rapidly expanding trend of high resources from the
coast, inward towards central Orange County located near 1-5.
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 SEPTEMBERMARC44 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 SEPTEMBERMARC44 2022
Table 6: Disability by Publicly Supported Housing Program Category, Tustin
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 SEPTEMBERMARC44 2022
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
IHCV 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 SEPTEMBERMARC44 2022
Figure 5: Percent Population with Disabilities in Orange County
I'lim Loma
V. h I ttl e r Jurupa Vall�
Hd" V.Ny
WiU13% Ama
t- C 0 VALLEY
41'1�r: Hitt
Norco
\_�,walk C— n.
(,or a_��
LA
ma&mws
Gi
T FSC'At VALtFY
Th.
0 R.ttt
".. �, .. " 1 0 . . \R
SAN TA k1A R- � �
V, ON '.A!
Orange County
Population with a Disability (Tract) - ACS (2015-2019)
< 10m Nhnne
10%-20%
F-1 2o% - 3ov
30%-40%
140%
County Boundary
0 2.5 5 Miles
I I I I Esri, HERE, Garmir, USGS, NGA, EPA, USDIN \ N RS
Source: AFFH Data Viewer N,
CITY OF TUSTIN
GENERAL PLAN
D-23
DRAFT HOUSING ELEMENT
SEPTEMBERMARC44 2022
Figure 6: Percent Population with Disabilities in Tustin
z
z
\I'v C Pm an Ave Orange —il)-E-Chapman -Ave-/-. 1 r, Jr. 1) 1","
W Almond Ave
F La Veta Ave
2 ui
Fairta-n
kleprourul
P�Tk Fo.1hil
I -
North T tin
Plac' W 17th St
A m 20
c' z
z
j
WSW
Santa Ala L'il\
1 3rd St
i ML
m
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7
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Palk
City of Tustin Oak
C mill, Got
Population with a Disability (Tract) - ACS (2015-2019) P*WY cour�
< lc)%
10%-20%
20%-30%
30% - 40%
> 40%
City Boundary
IN 0 0.5 1 Miles Irvine, County of Los Angeles, Bureau A�ufLan %Qna
Garmin, INCREMENT E, JS`GSr M
S.u,-: AFFH D.t. Vi—r ch Hid
CITY OF TUSTIN
GENERAL PLAN
F Kd
Trat-t.: 5,241
im
I -j
Hicks Ca
f
2
gement, Es,rl, HERE,
4*4" EPA, USDA
DRAFT HOUSING ELEMENT
SEPTEMBERMARC44 2022
Figure 7: Percent Population of Adults Living Alone - Tustin
If
Culver
plam
th
151
Za Anton -vine a f"
i
ID, Ranch
e Park
0 k
'a Go.
ak
C k
uilekGoll
se
Course
t It 'kwy
City of Tustin
Percent of Population 19 Years and Over in Households Living Alone (2019)
'J�
City Boundary Dro Vqssh
N 0 0.5 1 Miles �ty cf Irvine, County of Los Angele7s,Bureau cf �Lan qana"emert,F I /HF R F,
6 er
Garmin, INCRIEWNT P, USGS, ��T.I*A"-MA, USDA
Source: AFFH Data Viewer h"
I GENERAL PLAN
D-25
DRAFT HOUSING ELEMENT
SEPTEMBERMAR-044 2022
T
Z
Orange
1,,\ W hapm an Ave
_,7,—E-Chapnrl
W Alwo i KI Ave
4)
T,
F La Veta Ave
22
Qa"q.".Gro1Je'1FWY--�
Uj
0
Fairhaven
Memorial
pa(k
r 11, 1
L
North Tu ill
Plac I W 171h St
a An 0 S
lege 1* el
0
:�
cc
z z
VE
Lt %1"
' 1-1 St
61, Santa Ana
apla Ana Bl,. -J
V
f7
'0 Il -
It,
it
' N S1 AwL i vjml�
Hicks cally
'armIrr-Ave-
E Lqcr Rd
If
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th
151
Za Anton -vine a f"
i
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e Park
0 k
'a Go.
ak
C k
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t It 'kwy
City of Tustin
Percent of Population 19 Years and Over in Households Living Alone (2019)
'J�
City Boundary Dro Vqssh
N 0 0.5 1 Miles �ty cf Irvine, County of Los Angele7s,Bureau cf �Lan qana"emert,F I /HF R F,
6 er
Garmin, INCRIEWNT P, USGS, ��T.I*A"-MA, USDA
Source: AFFH Data Viewer h"
I GENERAL PLAN
D-25
DRAFT HOUSING ELEMENT
SEPTEMBERMAR-044 2022
Figure 8: Percent Population of Adults Living with their Spouse - Tustin
Ip -7-
(n
4
Sunflower Ave
ith
3st Anon B0
23
ow! aniDiegoiFw Irvine 14e� '�ale to
z,- Ranc h -19
,eolk park
Oak
Cmek Golf
1'0 %
Vab 4� cour-
City of Tustin
Percent of Population 18 Years and Over in Households Living with Spouse
�20V
20% - 40%
40% - 60%
60% - 80%
so%
CityBoundary j
N
o 0.5 1 Miles ine, County of Los Angeles, Bureau �cf Wanagem�rt, Esri, HERE,
Garmin, INCREMENT P, USGS,, METI/mW'11)S4bPA, USDA
A
Source: AFFH Data Viewer Hid
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-26 SEPTEMBERMARC44 2022
C Pm an A,,,e
Orange
r —��—E-C . hapm an -Ave
W Alino i KI Ave
cli!
a e
F L V ta Ave
ui
W
Fairhaveri
kkmoru*
Park
Foothili &
I 11L
N orth
Plac' W 17th St
22
.ge I m
c' z
fr_
z
Santa Ala L'11
V.?
13rd S1
L NIL
-,�r A,
-e
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—'�6-5 ....................... . . . . .
. . . ..
un V)
E Dyer Rd
Ip -7-
(n
4
Sunflower Ave
ith
3st Anon B0
23
ow! aniDiegoiFw Irvine 14e� '�ale to
z,- Ranc h -19
,eolk park
Oak
Cmek Golf
1'0 %
Vab 4� cour-
City of Tustin
Percent of Population 18 Years and Over in Households Living with Spouse
�20V
20% - 40%
40% - 60%
60% - 80%
so%
CityBoundary j
N
o 0.5 1 Miles ine, County of Los Angeles, Bureau �cf Wanagem�rt, Esri, HERE,
Garmin, INCREMENT P, USGS,, METI/mW'11)S4bPA, USDA
A
Source: AFFH Data Viewer Hid
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-26 SEPTEMBERMARC44 2022
Figure 9: Percent of Children in Married Couple Households - Tustin
age I
0
z
z
0
Z
Santa Ala I,, n
1 3,d St
Fdowl-r Ave
',V Sl Artf,,, I vun�W�bm Hicks C�
m2 VG@a cb�
kv
E Dyer Rd
-71
(n
4
Sunflower Av
ith
ell,
Anbbon B0
Irvine '�3`e to
,.SAn,Dieq IF -6
Ranc h
Parli,
Oak
City of Tustin C "k Golf
Percent of Children in Married -Couple Households 116� P*W Y IF Co "I"
20% - 40%
40Y. - 60%
EA 60%-80%
> 80%
City Boundary
N 0 0.5 1 Miles Irvine, County, of Los Angeles, Bureau of W
ri 4innagemert. Esri, HERE,
M I
Garmin, INCREMENT P, _JS`G r V -`iWd4,
%�,RPA, USDA
A
Source: AFFH Data Viewer ch Hie
I GENERAL PLAN
D-27
DRAFT HOUSING ELEMENT
SEPTEMBERMARC44 2022
C/Pman Ave
Orange
z
�,)—E-Chaprnan-Av* 6iThyopn V,PW
W Almond Ave
2
F La Veta Ave
10 1
fwy—
C"'O'en-Gr
W
TPbjc'VW,I
Fairha"n
Llemorial
.2
c Park
Focilhili
tol
17th St
North Tu
iAm 0 2
age I
0
z
z
0
Z
Santa Ala I,, n
1 3,d St
Fdowl-r Ave
',V Sl Artf,,, I vun�W�bm Hicks C�
m2 VG@a cb�
kv
E Dyer Rd
-71
(n
4
Sunflower Av
ith
ell,
Anbbon B0
Irvine '�3`e to
,.SAn,Dieq IF -6
Ranc h
Parli,
Oak
City of Tustin C "k Golf
Percent of Children in Married -Couple Households 116� P*W Y IF Co "I"
20% - 40%
40Y. - 60%
EA 60%-80%
> 80%
City Boundary
N 0 0.5 1 Miles Irvine, County, of Los Angeles, Bureau of W
ri 4innagemert. Esri, HERE,
M I
Garmin, INCREMENT P, _JS`G r V -`iWd4,
%�,RPA, USDA
A
Source: AFFH Data Viewer ch Hie
I GENERAL PLAN
D-27
DRAFT HOUSING ELEMENT
SEPTEMBERMARC44 2022
Figure 10: Percent of Children in Single Female -Headed Households - Tustin
z
z
Z
\41 C Pm an Ave Orange _�,)—E-Chaprnan-Ave i.lnjr' n V,'T
VV Almucti Avt 0
00 M
C
F La Veta Ave
2 Uj
Yl
0'en-Grc'J" j,
Fairhan
klernorial
Park
L
North T 'so
1. , I C z
V)
Ell W 1 7th St
Arr
.ge
c' z
z
Santa Ala .2 \.F
1 3rd St
Flow
m
j
F Eaniger Ave
A -,e,,,, p, 2wMam "icks Ca
kv
rc F Dyer Rd
(n
ith
SunflowerAve
Ist
Anton
23
AM
1_
anwDiagoilFw
Irvine
to C4, IS,
0, Ranc h
P30,
e-
Oak
City of Tustin
Cmek Golf
cour�
Percent of Children in Female -Headed Households
< 20%
F 20%-40%
F—] 4{)%-60%
77
'z
City Boundary
IN
0 0.5 1 Miles
Irvine,
County of Los Angeles, Bureau of Land Management, Esyl, HERE,
Garrnln, INCREMENT P, USGS, METIE/NM,��, E'P�, USDA
S—r— AFT Wu� Vi-
I GENERAL PLAN
D-28
DRAFT HOUSING ELEMENT
SEPTEMBERMAR-1044 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 1-5 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
RaciallylEthnically 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 SEPTEMBERMARC44 2022
Figure 11: Low and Moderate Income (LMI) areas in Orange County
Chino Hills i Lurri
1, In I er AC Ea5lvale Ju rupa Vail,
CHINO VALLEY WAJI.4 A—
CHINO HILLS
Ci HAk Nc I.
Ir
a
Orange County
Low to Moderate Income Population (Tract) - (HUD)
- 25%
255� - 50%
50%-75%
75A - 100%
C.—ty B—nd-y
IN 0 25 5 Miles
Source: AFFH Data Viewer
` ' I ' '
I -A I VA, L E I
OF
SA NTA p
City of Irvine, County of Los Angeles Bureau of Land Management, Esl I
Esri, HERE, Gai US65, NGA, EPA, USDA,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-30 SEPTEMBERMAR-1044 2022
OMER=
Orange County
Low to Moderate Income Population (Tract) - (HUD)
- 25%
255� - 50%
50%-75%
75A - 100%
C.—ty B—nd-y
IN 0 25 5 Miles
Source: AFFH Data Viewer
` ' I ' '
I -A I VA, L E I
OF
SA NTA p
City of Irvine, County of Los Angeles Bureau of Land Management, Esl I
Esri, HERE, Gai US65, NGA, EPA, USDA,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-30 SEPTEMBERMAR-1044 2022
Figure 12: Low and Moderate Income (LMI) areas in Tustin
z
z
C Pm an Ave Orange
r —��—E-Chaprnan-Ave-
W AlinuitJ Ave 0
F La Veta Ave
2 Uj
w
'len-Grol"
Fairhav n
&6m.rul az. �Wm
.2 Park FoollvPi 1 -
North Tu III,
Plac' W 17th St
4 nE
2 0
0
0 Z Z
x I
z
C
ve
Santa Ana L '41
13rd St
E C
14-
2 L IJ..
M
F E.,nger Ave
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1*6
Lve
IQ
IF Dyer Rd
4
Sunflower Ave rf
t1A
ith 71.
Anton B0 16
-SMiDjegol rvine too
F
Ranc h
e Park Oak
Cme
City of Tustin k Golf
Co
Low to Moderate income Population (Tract) - (HUD)
2
< 25%
25% - S0%
50% - 75%
75% - 100%
City Boundary
IN
o 0.5 1 Miles Irvine, County of Angeles, Bureau A�of Lar, 44'uagenn�rt, Esri, HERE,
S M�
I
Garrnln, INCREMENT P, -.Sr1(; r M USDA
S—r— AFFH Wt. Vi—r te
I GENERAL PLAN
D-31
DRAFT HOUSING ELEMENT
SEPTEMBERMAR-1044 2022
Figure 13: Racially Concentrated Areas of Poverty (RECAPs) in Orange County
L
El7 IESCAL �ALLE,
Orange County
Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs)
0 - Not . R/ECAP
I - R/CCAP Area
Poverty Status (Tract) - ACS (2015-2019)
CC J NTY
, 10'A
10% - 20%
20% - 30%
30% - 40%
140-A
county 3—d.'y
N 0 2.5 5 Miles
Source AFFH Data Viewer
SANTA MA�.
440UN-
r�ty of Irvine, County of Los Ange'eSr Bureau of Land Management, Es6, �
Esrl, H�RP, Garmin, I.SGS, NGA, EPA, USDA,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-32 SEPTEMBERMARC44 2022
chjn� Hills
Mim Luma
?
Eastvale
Jurupa
CHINIO VALLEY MIMI jk..
CMINO hhLLS
Chl Hah
rs,.%a Ilk
n"
C,orona--
L
El7 IESCAL �ALLE,
Orange County
Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs)
0 - Not . R/ECAP
I - R/CCAP Area
Poverty Status (Tract) - ACS (2015-2019)
CC J NTY
, 10'A
10% - 20%
20% - 30%
30% - 40%
140-A
county 3—d.'y
N 0 2.5 5 Miles
Source AFFH Data Viewer
SANTA MA�.
440UN-
r�ty of Irvine, County of Los Ange'eSr Bureau of Land Management, Es6, �
Esrl, H�RP, Garmin, I.SGS, NGA, EPA, USDA,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-32 SEPTEMBERMARC44 2022
Figure 14: Racially Concentrated Areas of Poverty (RECAPs) in Tustin
C-fjpm an Ave
I W Almond Ave
Orange
Fairhaven
Me mo r U,
Park
CP
z
31
P lac W 1 7t h St
22-
z
Santa Ala
13rd Sl I
LL
'A' S I A rrfr,,, I VU-D�
2
r Dye Rri
z
—E -Ch - apman-Ave-�'�"
Afqrnyofi Vjr?,,
F La Veta Ave
Uj
Ave ()"r"
Ah
'A
Anbn 5�-N
�00
City of Tustin 6, Ftanc h
Is
Racially or Ethnically Concentrated Areas of Poverty (R/ECAP Oak
0 - Not a R/ECAP % 1.6. Creek Got
I - R/ECAP Area I Coarse
Poverty Status (Tract) - ACS (2015-2019)
F-1 < 10%
10% - 20%
> 40%
F—] 20-/ - 30%
30% - 40%
r-1 City Boundary 'PaP Ljnjyci�-'"
N 0 0.5 1 Miles ity of Irvine, County o� Los Anqel:,,*�414.re., �.i �ari
�n aGarmin, INCREMENT P, USGS, M
Sac rc�: APPH Data V[..c,,
CITY OF TUSTIN
GENERAL PLAN
D-33
1 4
Hicks C�
q;�
f
J
gement, Esii, HERE,
'WASA 0A. USDA
DRAFT HOUSING ELEMENT
SEPTEMBERMARC44 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 AI, 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: VQite Household Income and Percent Population (2019)
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 SEPTEMBERMARC44 2022
Tustin
Orange (city)
Santa Ana
Irvine
Orange
County
Median
Household
84,697
91,793
66,145
105,126
90,234
Income
All
Households
93,304
95,827
70,084
111,574
95,934
White alone,
101,658
95,702
79,000
113,779
100,723
White
59.01%
74.03%
28.87%
47.80%
59.25%
Population
Notes:
1.VVhite 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 SEPTEMBERMARC44 2022
Figure 15: White Population and Median Income Distribution
Orange, E Chaprnin Ave�
4—
Orange
E Chapnfiin Ave
rth
9UP
S
Nrfli Tit I
Santa A f i
Ra"Da&M
"Y/,Ck
k Cany
I ryine
I rvi n e
R -p
1�111t'
cl_1_4�
'�F
City of Tustin
City of Tustin Median Income (Block Group)
_�J � $30,000
White Majority __:J'5SS'0w
Slim (gap< 10%) 1 �87,100JHCD 2GZOStat� Wd Inc—)
$12S'wo
Sizeable (gap 10% —SO%) rreater than sr2s,000
Predominant (gap > 50Y.) City B.o'd.,y
City Boundary 9 BWkGmopNumbev
N 0 05 1 mfl.� y of lwine, County of Los Angeles, BUreaki of L-i N 0 ob 1 mil. r ity .1' I,i, C ... ty of Los A.geles, b—, of Land
- gement Esn, HERE Garnoln, USGS, N EPA. Management, Bri, HERE, Garmin, INCREMENT P,
1n. USg NPS u
SG5r MITI/NASA, EPA ' USOA
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-35 SEPTEMBERMARGH 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.
TCACIHCD 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 SEPTEMBERMARC44 2022
Table 8: Opportunity Map Scores - City
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-37 SEPTEMBERMARC44 2022
Economic
Environment
Educational
Low
al
Transportati
Tustin
Opportunity
Opportunity
Transit Index
Index
Opportunity
Index
on Cost
Index
Index
Tustin total Population
White, Non-
77.38
5 5. 5 3
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 SEPTEMBERMARC44 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
Islander, Non -
49.36
46.78
52.50
37.48
36.11
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
Islander, Non -
38.94
46.38
4. S. 3 2
41.97
39.51
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 SEPTEMBERMARC44 2022
Table 9: Opportunity Map Scores - Census Tracts
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-39 SEPTEMBERMARC44 2022
Economic
Environmental
Education
Composite
Final
Census tract
Domain
Domain
Domain
Index Score
Category
Scores
Scores
Score
Highest
0524.19
0.962
0.574
0.863
0.638
Resource
Moderate
0525.02
0.896
0.166
0.199
-0.217
Resource
High
0525.24
0.912
0.376
0.541
0.272
Resource
Low
0744.07
0.12
0.024
0.055
-0.94
Resource
Low
0744.08
0.179
0.047
0.054
-0.839
Resource
Moderate
0755.04
0.702
0.199
0.35
-0.136
Resource
Low
0755.05
0.622
0.22
0.068
-0.462
Resource
Moderate
0755.06
0.614
0.619
0.529
0.189
Resource
Moderate
0755.07
0.626
0.27
0.208
-0.269
Resource
Low
0755.12
0.27
0.218
0.106
-0.575
Resource
Low
0755.13
0.386
0.185
0.199
-0.426
Resource
Low
0755.14
0.187
0.092
0.078
-0.753
Resource
Low
0755.15
0.452
0.005
0.236
-0.839
Resource
Highest
0756.06
0.986
0.534
0.927
0.766
Resource
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-39 SEPTEMBERMARC44 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: Califorr-da 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 SEPTEMBERMARC44 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 econon-dc 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 C
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. hi specific, Hispanics in Tustin have the highest
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-41 SEPTEMBERMARC44 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 SEPTEMBERMARC44 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
.
0.0%
0.0%
0.0%
0.0%
0.0%
0.3%
0.3%
0.0%
22.2%
20.3%
Alaska N ative
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%
0.0%
0.0%
0.0%
0.0%
0.0%
2.4%
0.0%
40.0%
34.1%
Other Pacific
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)
I I
CITY OF TUSTIN DRAFT HOUSING ELEIVIEN I
GENERAL PLAN D-43 SEPTEMBERMARGH 2022
School Proficiency
Total Title 1
Schools
1
1
2
10
135
Total Schools
1
1
2
19
607
Percent of
Schools
-
100
-
100
-
100
-
-
52.6
22.2
Unemployment
4.2%
1.7%
3.8%
4.3%
3.3%
1.8%
1.4%
2.4%
2.80%
3.00%
Rate (2019)
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%
8.1%
6.8%
9.7%
more
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 SEPTEMBERMARGH 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)
I
I
I
I
I
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 SEPTEMBERMARGH 2022
Table 10: Access to Opportunity Indicators by Race/Ethnicity (2 of 2)
Opportunity
City of
County
Census Tracts
Of
Indicators
Tustin
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
.
0.0%
0.0%
0.4%
0.0%
0.0%
0.0%
0.0%
1�4%
0.1%
0.2%
Alaska N ative
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%
0.0%
0.0%
0.0%
0.5%
0.0%
0.0%
0. 0 'Yo
0.1%
0.3%
Other Pacific
Islander alone
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-46 SEPTEMBERMARGH 2022
Hispanic or
Latino (of any
48.0%
55.8%
56.9%
74.2%
28.4%
13.4%
13.5%
4 1 �O
40.0%
34.1%
race)
School Proficiency
Total Title 1
Schools
2
1
-
-
3
-
-
10
135
Total Schools
5
1
4
3
1
19
607
Percent of
Schools
40
100
-
-
75
0
0
52.6
22.2
Unemployment
4.1%
4.3%
5.6%
4.4%
1.3%
1.1%
2.
2. 0
2.80%
3.00%
Rate (2019)
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
f 0, 1
6.8%
9.7%
more
Transit Metrics
All Transit
Performance
5.7
5.9
5.1
5.4
6.4
1.2
3.7
4.8
4.2
Score
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-47 SEPTEMBERMARGH 2022
Transit Trips
Per Week
953
440
391
447
1,162
116
53
6-51
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
2-5-),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 M
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
169
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 SEPTEMBERMARGH 2022
,Norwalk
E-11110-1
Figure 16: CalEnviroScreen 3.0 Percentile Scores
-J6
affld=
Orange County
CalEnviroScreen Percentiles
1 - 10% (Lowest Score)
11 - 2D%
1W 21-30%
31-40%
41-50%
51-60%
61-70%
71-80%
81-90%
91 - 1D0% (Highest Score)
County Boundary
N 0 3 6 Miles
A I I I I
Source: calEnviroscreer 4.0 - Feb. 2021 Update
CITY OF TUSTIN
GENERAL PLAN
D-49
'Z -
I
�CAL VALL�7V
N. L 1�
City of Irvine, County of Los Angeles,
Bureau of Laind Management, Esri, HERE,
Garmin, USGS, EPA, NIPS
DRAFT HOUSING ELEMENT
SEPTEMBERMAR-1044 2022
Countywide, there are disparities across racial//Lethnic 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 need-pLqblems 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-VVhite 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 SEPTEMBERMARC44 2022
Table 11: Any Housing Problem by Tenure and Race, Tustin
Demographics of Households with Disproportionate Housing Needs
Households experiencing any of 4
housing problems
# with problems
# households
% with
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-
Hispanic
2,644
6,089
43.42%
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
Severe Housing Problems
# with severe
problems
# households
% with severe
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-
Hispanic
1,519
6,089
24.95%
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 SEPTEMBERMARC44 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
housing problems
# with problems
# households
% with problems
Race/Ethnicity
White, Non -Hispanic
206,658
540,773
38.22%
Black, Non -Hispanic
8,074
16,719
48.29%
Hispanic
152,740
241,84
63.16%
Asian or Pacific Islander, Non-
Hispanic
84,193
186,038
45.26%
Native American, Non -Hispanic
.78 "/o
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
Severe Housing Problems
# with severe
problems
# households
% with severe
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-
Hispanic
50,205
186,038
26.99%
ative merican, on -Hispanic
44
0
Total
267,641
987,550
27. 10 %
Source: County of Orange, Analysis of Impediments, 2020
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-52 SEPTEMBERMAR-C44 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 SEPTEMBERMARC44 2022
Figure 17: Distribution of Cost Burdened/Overpayment Households
Orange
Orange
E Cha pman A,,
VWM'
01 t
kj� i,"—
�an
>
a 11
. 5]3
VEA
Icks can
6'1171k. canjo
VjDa
Irvine
Irvine
L'Vo c
40,.V. c
City of Tustin City of Tustin
Overpayment by Reriters Overpayment by Home Owners
2 T/. 20% - 4N
20% - 40% 40% - 6U%
40% - SO% 60%-80%
go% � 80%
City Boundary City B.unda ry
N 0 0�5 I Md- C,ty of rvirn,, County f Los Arig.les, Han—, f L I d a 05 1 U11- City f I'me, County of Los Angeles, Bureau of Land
"4ngerrient,it, Lsri, HERL, Garminr INCR MEN'T'P Management, Zsri, HLREr Garmin, USGS, NGA, PA,
USGS, METIfNASA, FPA� USDA USDA,NPS
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-54 SEPTEMBERMARGH 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 SEPTEMBERMARC44 2022
Figure 18: Distribution of Overcrowded Households
Orange County
Overcrowded Households
F-7 158.2 (Statewide Average)
F—] :� 12
!�20
S70
County Boundary
N 0 3 6 M&S
Sour— CHHS Data - 7ract
7470
SAN" MARGAI-1
Ul-. IN 'All'
les,
:RE,
,PA
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-56 SEPTEMBERMAR-C44 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 SEPTEMBERMARC44 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 SEPTEMBERMARC44 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
$14,999
2.5%
3.8%
3.2%
2.6%
$15,000 to
$24,999
2.6%
1.3%
3.3%
2.2%
$25,000 to
$34,999
2.2%
1.8%
3.7%
2.7%
$35,000 to
$49,999
2.1%
1.9%
3.8%
2.5%
$50,000 to
$74,999
2.5%
1.9%
3.7%
2.9%
$75,000 to
$99,999
2.6%
2.2%
3.6%
2.7%
$100,000 to
$149,999
2.7%
1.5%
4.1%
2.8%
$150,000 to
$199,999
2.1%
1.5%
3.6%
2.8%
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-59 SEPTEMBERMARC44 2022
$200,000 or more
5.4 %
4.3%
7.2%
5.8%
Medianm'come
90,939
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 SEPTEMBERMARC44 2022
Table 16: Publicly Supported Housing (Tustin)
Source: County of Orange, Analysis of Impediments, 2020
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-61 SEPTEMBERMARGH 2022
Race by Housing Sites (percent)
Race by Census Tract
Low
Total
Census
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
Park
LIHTC
149
150
13.1
3.4
75.4
7.2
755.13
14.4
3.6
57.9
20.5
Source: County of Orange, Analysis of Impediments, 2020
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-61 SEPTEMBERMARGH 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 11 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
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
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 SEPTEMBERMARC44 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
Veterans outpost
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
Tustin Temporary Emergency Shelter
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
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 SEPTEMBERMARC44 2022
Table 18: Housing by Tenure
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 SEPTEMBERMARC44 2022
City of Tustin
Orange County
Tenure
Estimate
Percentage
Estimate
Percentage
2010
Owner-
occupied
13,109
52.8
599,032
60.8
Renter -occupied
11,730
47.2
385,471
39.2
Total
24,839
984,503
2019
Owner-
occupied
12,759
49.7
595,272
57.4
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 SEPTEMBERMARC44 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 SEPTEMBERMARC44 2022
Table 21: Tustin Loan Application Actions by Race (2019)
Source: Federal Financial Institutions Exammation Council (FFIEC) Home Mortgage Disclosure Act (HMDA) Dataset, 2019
Notes: Other includes Free Form Text and Joint applicants
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-66 SEPTEMBERMARGH 2022
Preapproval
App-
Race and
Loan
approved
App.
App.
File closed for
Purchased
request
Grand
withdrawn
approved
Ethnicity
originated
but not
Denied
incompleteness
loan
Total
by applicant
but not
accepted
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
Other Pacific
5
1
1
7
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
Latinc,
Source: Federal Financial Institutions Exammation Council (FFIEC) Home Mortgage Disclosure Act (HMDA) Dataset, 2019
Notes: Other includes Free Form Text and Joint applicants
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-66 SEPTEMBERMARGH 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
American alone
1,508
1.9
0.8
1.4
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/eflu-tic 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 SEPTEMBERMARC44 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 SEPTEMBERMARC44 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 SEPTEMBERMARC44 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 SEPTEMBERMARC44 2022
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-71 SEPTEMBERMAR-044 2022
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-71 SEPTEMBERMAR-044 2022
Figure 19: Distribution of Predominantly White and Predominantly Hispanic Population
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CITY OF TUSTIN
DRAFT HOUSING ELEMENT
GENERAL PLAN
D-72 SEPTEMBERMARGH 2022
Additionally, various Cily housing projects are currently under covenants per AB 987. Table 11- "
16 in Section 11 of this Housing Element includes an inventory of all units assisted under federal,
state, and/or local progjams, including HUD progjams, st!qte and local bond progjams, 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-73 SEPTEMBERMARC44 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 1-5 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.
• Addifienally-,-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-74 SEPTEMBERMARC44 2022
FigtireEig.ures 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-75 SEPTEMBERMARC44 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 1-5 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-76 SEPTEMBERMARC44 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-77 SEPTEMBERMARC44 2022
Figure 20: Location of Sites to Meet RHNA
Suitable Sites for Additional
Residential Develoment
Lf
0
I
Suitable Site Locations
Downtown Commercial Core Specific Plan
Red Hill Avenue Specific Plan
Tustin Legacy Specift Plan
Enderle Center
Tustin Marketplace
Municipal Boundaries
N
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-78 SEPTEMBERMAR-1044 2022
Figure 21: Focused Locations of Sites to Meet RHNA
Enderle Center (Site #19)
Tustin Marketplace
(Site #20)
N
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-79 SEPTEMBERMARGH 2022
I CD C�L LmAh FL-,
[�p Li
6
14
�1�5
LLV
N
4�
N
Tustin Legacy Specific Plan
Red Hill Avenue
�y Specific Plan
17
iB 1A
Enderle Center (Site #19)
Tustin Marketplace
(Site #20)
N
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-79 SEPTEMBERMARGH 2022
Figure 22: Location of Sites in Opportunity Zones
All
City of Tustin
TCAC Opportunlity Areas 2021
Highest Resource
High Resource
Moderate Resource
Low Resource
High Segregation & Poverty
Site Inventory
City Boundary
N 0 0.5 1 Miles
A I I I I
Source AFFH Data Viewer
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=racf
FTC—a_Ft-.T!j—jZ5V2'4j
�52�5-02
City of Winer County af Los Ange[eSr Bureau of Land Management, Esn, HERE,
Gaurnin, INCREMENT P, USGS, EPA
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-80 SEPTEMBERMAR-044 2022
Table 23. Sites Demographics
Area
Non -White Population
(Percent)
Low to Moderate Income
(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-81 SEPTEMBERMARC44 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-82 SEPTEMBERMARC44 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
1,5600 acres, there are 6800 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-83 SEPTEMBERMARC44 2022
• Education
• Heritage Elementary School
• Legacy Magnet Academy (Grades 6-12)
• 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
• 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)
• Head Start preschool
• Rancho Santiago sheriffs training facility
• Orange County Animal Shelter
• Fire Station
• Army Reserve Center
• Village of Hope transitional homes for individuals and families with children
Employment
• Flight at Tustin Legacy office complex
• Hoag medical center and Health South acute care facility
• Stater Bros. grocery store and other retail and neighborhood services at the
Village at Tustin Legacy
• 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:
• Columbus Square (1,075 residential units consisting of single-family homes,
duplexes and multi -family homes)
• Columbus Grove (465 detached homes)
• Field 1 (376 attached units)
• Field 11 (189 detached units)
• Amalfi Apartments (533 apartment units)
• Greenwood (375 detached single-family units)
• Anton Legacy (225 affordable housing units)
• Levity (218 attached units)
• 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-84 SEPTEMBERMARC44 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-85 SEPTEMBERMARC44 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 dor�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 Vattemisand
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)
sevefe housing issues for- the eity's Blaek fesidents3
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:
0 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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-86 SEPTEMBERMARC44 2022
b) Using best practices from other jurisdictions, explore policies and programs that increase
the supply affordable housing, such as linkage fees, housing bonds, inclusionary
housing, public land set-aside, community land trusts, transit -oriented development,
and expedited permitting and review.
c) Explore providing low-interest loans to single-family homeowners and grants to
homeowners with household incomes of up to 80% of the Area Median Income to
develop accessory dwelling units with affordability restriction on their property.
d) Review existing zoning policies and explore zoning changes to facilitate the
development of affordable housing.
e) Align zoning codes to conform to recent California affordable housing legislation.
2) Goal 2: Prevent displacement of low- and moderate -income residents with protected
characteristics, including Hispanic residents, Vietnamese residents, seniors, and people with
disabilities.
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.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-87 SEPTEMBERMARC44 2022
d) Increase support for fair housing enforcement, education, and outreach.
As identified in the 2020 Al, the following goals were established for the City of Tustin in effort
to address factors outlined above:
1) In collaboration with the Orange County Housing Authority (OCHA):
a) Attend quarterly OCHA Housing Advisory Committee to enhance the exchange of
information regarding the availability, procedures, and policies related to the Housing
Assistance Voucher program and regional housing issues.
b) Support OCHA's affirmative fair marketing plan and de -concentration policies by
providing five-year and annual Public Housing Authority (PHA) plan certifications.
c) In coordination with OCHA and fair housing services provider, conduct landlord
education campaign to educate property owners about State law prohibiting
discrimination based on household income.
2) Through the Fair Housing Foundation:
a) Provide fair housing education and information to apartment managers and homeowner
associations on why denial of reasonable modifications/ accommodations is unlawful.
b) Conduct multi -faceted fair housing outreach to tenants, landlords, property owners,
realtors, and property management companies. Methods of outreach may include
workshops, informational booths, presentations to community groups, and distribution
of multi-lingual fair housing literature.
c) Provide general fair housing counseling and referrals services to address tenant -
landlord issues and investigate allegations of fair housing discrimination and take
appropriate actions to conciliate cases or refer to appropriate authorities.
d) Periodically monitor local newspapers and online media outlets to identify potentially
discriminatory housing advertisements.
e) Include testing/ audits within the scope of work with fair housing provider.
3) Prepare a new Housing Element that is compliant with all current State laws and is certified
by the California Department of Housing and Community Development.
4) Utilize funding through State programs (SB2) to support affordable housing and/or
homeless prevention services.
5) Update zoning ordinance to comply with current State law.
As part of this Housing Element, the City has established several programs that address the
constraints of this AFH analysis, as well as support the goals that were previously established
during development of the County Al. The City's General Plan Housing Element (2021-2029)
includes several goals that will support in furthering fair housing within the city.
Goal 1: Provide an adequate supply of housing to meet the need for a variety of housing
types and the diverse socio-economic needs of all community residents.
• Goal 2: Ensure equal housing opportunities for all existing and future City residents
regardless of race, religion, ethnicity, sex, age, marital status or household composition.
• Goal 3: Increase the percentage of ownership housing to ensure a reasonable balance of
rental and owner -occupied housing within the City.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-88 SEPTEMBERMARC44 2022
e Goal 4: Preserve the existing supply of affordable housing in the City.
To facilitate these goals, several programs will be implemented over the planning period to
ensure the City's goals are met. Several of the City's programs were modified in response to
create measurable actions that will be monitored to progress is made towards AFH constraints
identified as part of this analysis. The following table provides the programs that will be
implemented over the planning period to address.
Supporting programs would facilitate development of new affordable housing opportunities,
provide housing and/or housing services for persons with protected characteristics, protect
existing low-income housing from conversion to market rate housing, promote high-quality
housing/housing rehabilitation throughout the City, and P -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-89 SEPTEMBERMARC44 2022
AFF14 Fair- Housing iss
Contributing Facto
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per -sons Nvith pEoteeted Ehar-aeter-isti
14 (New) Residential
Pr-ogr-afn 1.1 eommits
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housing sites available
Pevelopment Available
the City to implementation
in areas Y-ezaned to
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Sites
of zoning
fneet the City's
for-
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b
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pr-oeedur-es
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a variety
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that ineltide affer-dable
aFeas. The T-T=SP area ineltides
j . ty of tke City's
PJ41NI alloication. However-,
as pFeviatisly
stated,
the T-T=SP
area is rapidly developing
and
ehanging in aieeor-danee
the TJLSP area has been
with the City's plans
rapidly EhaRgiRg and
for- the area.
substantially
Although
ef�haneed
the tr-ac-t has
ivith new
been identified as low r-esotir-Ee,
r-esour-ees Nvitkin r-eEent years.
impr-ovements iRdtfEle
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-90 SEPTEMBERMARGH 2022
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-91 SEPTEMBERMARGH 2022
. ........ ....
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-91 SEPTEMBERMARGH 2022
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and low ineome housing.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-92 SEPTEMBERMARC4=1 2022
AFF14 Fair- Housing iss
Contributing Facto
Supporting Fregra
City eemmitments inc-lude eonducting fair housing testing and edueation thr-ough the City's Eontr-aeted fair llousing
se. ..-es pr-evider, Efforts Nvould lqelp identify factors impaEfing speEifiE paptilations and eommutiities r-egar-Elin
qua!" of life, equitability, and available Y-esottr-ees. Additionally, the City commits to providing a Spanish version
of all flier -s and offieial City announeements by 2023. Translated mater-ials Nvould minimize bafrier-s ift disseminating
tant k4ennation to the City's Hispanie population. Pisplaeement ean bfeadly be under -stood to be Eaused by
disi-minvestment, investment fueled gentrifieation, or- a PFOEess eombining the two. Qutr-eaeh to Hispanie s
residents is important to ensur-e iRElHSiVity in providing meaningful input and par-tieipation in City's
making pfoeesses that influenee Elisplaeement faetofs, stieh as itwestment and developmen
AFFH Fair
Housing Issue
Contributing Factor
Strategies to Address AFFH Issue
Supporting Programs
Housing Mobili!y
1. Lack of affordable housing opportunities for
Housing Mobility Strategies consist of removing barriers to
PUBLIC OUTREACH - ENGAGE LIQUISTICALLY ISOLATED
Revised Progjam 2.5 (b): By 2023, translate official Ci!y announcements (i.e. communi!y meeting, hearings, etc.) to Spanish
Hispanic residents
2. High segiegation for Hispanic/White and
housing in areas of opportunity and strategically enhan "m
access.
Opportunity areas are rated "high" or "low" resource based on
and disseminate printed copies of information to renters, property owners, and via social media, in order to expand
Black/White populations (as defined by
knowledge of affordable housing options in High Opportuni!y Areas.
Community Development DWartment
Action Outcomes:
The City's goal is to increase attendance, representation, understanding by linguistically isolated residents, at community
Dissimilarfty Index values which indicate
education, employment, economic development safe and decent
geographical segregation patterns)
housing, low rates of violent crime, transportation, and other
opportunities, including recreation, food and healLhy
environment (air, water, safe neighborhood, safe!y from
environmental hazards, social services, and cultural
institutions
meeting, public hearings and City Council meetings. By engaging Hispanic populations in the decision-making process,
they are better able to advocate for their needs and concerns regarding affordable housing and access to opportunities. The
Ci!y will conduct at least one communi!y informational meeting in areas that lack affordable housing opportunities and
that exhibit high segregation, on an annual basis.
QUALITY RENTAL HOUSING INSPECTION PROGRAM
New Program 3.11: By 2025 through 2029, establish a multi -family quality rental housing inspection proffam.
Community Development DWartment
Action Outcomes:
City's goal is to elevate the quality of housing in segregated areas in order to transform the area into a desirable housin
location by all socio-econornic groups and to protect existing tenants from displacement and to provide occupants the
ol2l2ortuni!y to live in suitable housing conditions that are not characterized with substandard conditions such as lack of
plumbing or overcrowding.
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 geogjaphical segregation patterns in
census tracts).
The Ci!y will receive at least one monthly referral from the Qy'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 o
improving the quality of single family and multi-fantily residential dwellings by providing technical assistance and funds
to repairs substandard housing conditions.
The Qy will conduct at least five multi -family quali!y 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 D-93 SEPTEMBERMARGH 2022
AFF14 Fair Housing iss
Contributing Facto
Supporting Programs
New Housin
Choices and
Affordabil
Areas of Opportuni
1. Disparity in access to opportunity between
New Housing Choices and Affordability in Areas of
Opportunity means promoting housing supply, choices and
ADU/SB 9 ACCELERATOR PROGRAM
Revised ProWarn 1.7b: The City will create an ADU/SB 9 accelerator program and focus in High Opportunity Areas
the northeast (higher resources), where there
are predominate populations of White
affordability in areas of high opportunity and outside of areas of
within the northeast portion of the City where there are predominately 2ingitfg1aftsingle-family residences in order to
residents, and southwest (lower resources) o
concentrated pover!y.
expand housing choices. This program wil4could include a permit fee waiver for affordable housing units, permit fast
tracking (refer to Program 1.1h), and technical assistance. This program will complement revised Program 1.1 h
the city, where there are predominate
populations of Hispanic residents
2. Lack of affordable housing opportuniti s for
Streamlining and Permit Fast Tracking for new ADU/SB9 development proposals.
Community Development ftartment
Action Outcome:
By 2025, the City will adopt a program and mail out information pertaining to the new accelerator progjarn for ADUs
Hispanic residents
and SB 9 developments, specifically to high opportunity areas.7
STREAMLINING AND PERMIT FAST TRACKING
Revised Program 1.1 (h): By 2023, provide technical assistance and permit fast -tracking for new ADU/SB9 development
proposals and a minimum of six prpjects that include housing affordable to lower income households on an annual basis
through 2029.
Community Development ftartment
Action Outcome:
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 assigLling a desigLiated "streamlining sta
liaison" to the pr9ject.
PUBLIC OUTREACH - DISSEMINATE HOUSING AND ANCILLARY RESOURCE INFORMATION & ENGAGE
LIQUISTICALLY ISOLOATED
New ProWam 2.5 (c): Annually, starting in 2023 through 2029, Ttranslate the City's Tustin Housing Authority website
and factsheets promoting affordable housing opportunities and ancillary support services, such as transit and child care,
into Spanish, and distribute to low resources areas.
Community Development ftartment
Action Outcomes: Increase the distribution of translated materials to low resources areas located in the southwest of the
Qy by mailing out postcards to each household in select census tracts, containing information related to housing
choices, transit, child care, and education resources.
Place -Based
Strategies to
Encourage
Communi!y
Revitalization
1. Disparity in access to opportunity between
Place -based Strategies to Encourage Community Conservation
HOUSING REHABILITATION TO IMPROVE HOUSING CONDITIONS, INCLUDING OVERCROWDING
the northeast (h�her resources), where there
and Revitalization Involves approaches that are focused on
New/Revised Program 3.10: By July 2024, the City will partner with a non-profit to develop and launch a CDBG funded
are predominate populations of White
conserving and improving assets in areas of lower opportunity
Housing Rehabilitation Program to facilitate the repair of dilapidated housing to address lack of plumbing, kitche
residents, and southwest (lower resourcesLof
and concentrated poverty such as targeted investmenth L
facilities and repairs to provide relief of overcrowding. Program participants will be provided grants and/or loans to
the ci!y, where there are predon-tinate
. .
neighborhood revitalization, preserving or rehabflitatm*g existing
conduct necessary housing updates.
The Qy's goal is to protect existing tenants from displacement and to provide occupants the opportuni!y to live in suitable
populations of Hispanic residents
2. Disproportionate housing problems for the
affordable housing, improving infrastructure, schools,
employment, parks, transportation and other communi!y
city's Hispanic and Black residents (problems
amenities.
housing conditions that are not characterized with substandard conditions such as lack of plumbing or overcrowding. The
include 1) housing unit lacks complete
progam will focus on improving housing conditions in tracts 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15 (areas
kitchen facilities; 2) housing unit lacks
with high segiegation index as defined by Dissimilarity Index values which indicate geogjaphical segiegation patterns in
complete plumbing facilities; 3) household is
census tracts).
Action Outcomes.
The progjam will facilitate four (4) rehabilitation projects to assist with reducing overcrowding per year and another four
overcrowded; and 4) household is cost
burdened)
3. Disproportionate housing problems fac
large family households
(4) projects will assist with general habitabili!y repairs, with a total of eight (8) dwellings assisted annually. Starting in
July 2024, the City in partnership with a non-profit, will conduct targeted outreach through annual mailings to the
southwest areas of Ci!y within low resources areas and p2pWations, about available rehabilitation assistance. All
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-94 SEPTEMBERMARG14 2022
AFF14 Fair- Housing iss
Contributing Facto
Supporting Programs
program literature will be provided in English and Spanish. Progress will be evaluated and reported annually in the
Ci!y's CDBG Annual Report.
Community Development ftartment
INCREASE HOUSING SUPPLY FOR LARGE HOUSEHOLDS
New ProWam 3.13: By January 2024, the City will amend the zoning code to require all new multi-farnily projects to
provide at least five (5) percent large family units (3+ bedrooms) which will prevent overcrowding and further cost
burden, by addressing demand for such units and increasing the large units into the local housing inventoLy.
Community Development ftartment
Action Outcomes: Four (4) large family units will be generated annually, and 32 total by 2029.
QUALITY RENTAL HOUSING INSPECTION PROGRAM
New ProWam 3.11: By 2025, Establish a multi -family quality rental housing inspection proffam.
Community Development DWartment
Action Outcomes:
City's goal is to elevate the quality of housing in segiegated areas in order to transform the area into a desirable housing
location by all socio-economic groups- and to protect existing tenants from displacement and to provide occupants the
opportunity to live in suitable housing conditions that are not characterized with substandard conditions such as lack of
plumbing or overcrowding.
The progjam 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 geogVhical segregatio
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 o
improving the quality of single family and multi -family residential dwellings by providing technical assistance and funds
to repairs substandard housing conditions.
The City will conduct at least five multi -family quality rental housing inspections in the prograrn�s first year and will
increase the number of annual inspections by 2, each year thereafter until 2029.
TUSTIN LEGACY SPECIFIC PLAN IMPROVEMENT PROGRAM:
New Progjam 2.8X—.X: Tustin Legacy (Tract 744.15) is a Master Planned Communi!y that is currently being developed.
Although the tract has been identffied as low resource, it has been substantially enhanced with new resources within
recent years. The area comprises 1,500 acres, of which 800 acres remain for future development of a diverse housin
stock, communijy 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 Progam,
which includes:
• Brookfield at Tustin Legacy and Levity: residential projects with development of open space, park areas, and
communi!y amenities
• Tustin Legacy Linear Park Between Armstrong Avenue and Warner Avenue
• Alley Grove Community Plaza
• Neighborhood D South Infrastructure Construction - Phase 2
• Tustin Ranch Road Pedestrian Bridge
• South Hangar Renovation - Phase 1 (for future reuse of site)
• Armstrong Avenue Pedestrian Brid
• Warner Avenue Pedestrian Bridge
Community Development ftartment
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-95 SEPTEMBERMARGH 2022
AFFH Fair Housing iss
Contributing Facto
Supporting Programs
Action Outcomes:
The City will facilitate development of infrastructure, housing, and community amenities within the TLSP area.
Improvements will provide increased access to safe and decent housing, transportation, recreation, and a healthy
envirom-nent. By 2029, the City anticipates the Tustin Legacy (Tract 744.15) to be identified as a "high resource" area
according to TCAC/HCD Opportunity Map criteria.
Protecting Existing
1. Disproportionate housing problems for the
Protecting Existing Residents from Displacement comprises
QUALITY RENTAL HOUSING INSPECTION PROGRAM
New Program 3.11: By 2025, Establish a multi -family quality rental housing inspection program.
Community Development Department
Action Outcomes:
City's goal is to elevate the quality of housing in segiegated areas in order to transform the area into a desirable housing
Residents ftom
Displacement
city's Hispanic and Black residents (problems
strategies that protect residents in areas of lower or moderate
include 1) housing unit lacks complete
opportunity and concentrated poverty and preserve housing
kitchen facilities; 2) housing unit lacks
choices and affordabiliM.
complete plumbing facilities; 3) household is
overcrowded; and 4) household is cost
burdened) - -Specifically, Hispanic
households were identified as having
location by all socio-economic groups and to protect existing tenants from displacement and to provide occupants the
substantial overcrowdin
2. Concentrated female -headed households and
opportunity to live in suitable housing conditions that are not characterized with substandard conditions such as lack of
plumbing or overcrowding.
The program will focus on improving housing conditions in tracts 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15
LMI population within Census tract 755.14
(areas with high segregation index as defined by Dissimilarity Index values which indicate geographical segregatio
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.
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.
CHILD-CARE RESOURCES
New ProWam 3.12: By December 2022, the City will create a "Financial Assistance for Child Care" webpage wi
information and links to Children's Home Socie!y of Califorriia (CHS) and the Orange County Department of Education
(OCDE). These progams; provide funding to low-income families for child care services. The City will work with Tustin
Preschool, Kiddie Academy of Tustin, or other local preschool programs within Census tract 755.14 to advertise and
promote financial assistance through pamphlets, e -blasts, and other applicable online communi!y forums (such as
Facebook and NextDoor).
Economic Development DepartmentlCommunity Development Department
Action Outcome: Single -parent households require special consideration and assistance because of their greater needs
for djjycare, healthcare, and other facilities. According to HCD, female -headed households with children tend to have
lower incomes, thus limiting housing 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 Ci!y will provide
services to relieve general living expenses of female -headed households, specifically in Census tract 755.14.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-96 SEPTEMBERMAR-C44 2022
CITY OF TUSTIN
GENERAL PLAN
APPENDIX E
PUBLIC PARTICIPATION
E-1
HOUSING ELEMENT
JULY 2022
APPENDIX E
PUBLIC PARTICIPATION (COMMUNITY ENGAGEMENT)
CITY OF TUSTIN
GENERAL PLAN
E-1
HOUSING ELEMENT
JUNE 2021
", Fr i
City of Tustin
202 7 — 2029 Housing Element Update
Community Engagement Plan
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City of Tustin
202 7 — 2029 Housing Element Update
Community Engagement Plan
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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 Pa ge 12
Purpose
This COMMUNITY ENGAGEMENT PLAN is for the City of Tustin's 6th Cycle Housing Element (2021-2029). This Plan describes
strategies for engaging with residents and stakeholders through an online survey, education and awareness campaigns, and
publicmeetings. Due to COVID-1 9 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. 1.991000111.1
Background
The City of Tustin is preparing the 2021 — 2029 HOUSING ELEMENT UPDATE to evaluate current and
future housing conditions, and identify housing sites and programs to meet the community's needs. While
updating the housing element is a State requirement, it is also an opportunity to assess its accomplishments
and progress toward meeting housing goals put forth in the previous Housing Element in 2013. The 2021 -
2029 Housing Element will outline the goals, policies and programs needed to promote the development
and preservation of safe, accessible, and diverse housing in the City.
Goals and Objectives
The GOAL of the COMMUNITY ENGAGEMENT PLAN for the 2021 — 2029 Housing Element Update is to
guide the City's community and stakeholder engagement efforts and to provide information about the
importance in participating in the Housing Element Update. The OBJECTIVES of the Community
Engagement Plan include:
Building public awareness of the Housing Element Update, its requirements, and the City's vision
and goals to adequately plan to meet housing needs to all of its residents;
Educating the Tustin community on the requirements of the Housing Element Update, and progress
since the previous Housing Element;
Engaging community members and key stakeholder groups to provide input on potential policies
and programs that will align with Tustin resident's housing needs;
Facilitating discussions with community members and decision makers to identify how and where
additional housing could be located within the City; and,
Providing a concise document to the Tustin City Council and Planning Commission for adoption, with
input and updates from public outreach and engagement activities during the Housing Element
Update.
City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan Pa ge 13
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. 104016�
Affordable Housing Advocates ( ff*41
Alwalk
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
- Jamboree Housing - OC Community
Corp. Housing Corp.
- Tustin Planning - Habitat for Humanity
Partnership
- Linc Housing
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 und er-rep resented community
members as well as youth and seniors. This includes but is not limited to:
- St. Joseph Hospital
- Meals on Wheels
OC
- Alzheimer's of OC
-Neighborworks OC
Disability Advocates
-Community Health
Initiative of OC
- Tustin Community
Foundation
- Lestonnac Free Clinic
- Tustin Public Schools
Foundation
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
Tustin
- moms OC
- Veterans Legal
Institute
- Orange County
Finance Trust
- Big Brothers and Big
Sisters of OC
- OC Food Access
Coalition
- YMCA of OC
- Goodwill of OC
- Patriots & Paws
- Community Action
Partnership of OC
People Experiencing Homelessness
- Legal Aid Society of
OC
- Second Harvest Food
Bank of OC
- Public Law Center
Organizations, groups, or agencies that provide services to people experiencing homelessness in Tustin. This
includes but is not limited to:
- Housing and Homeless
Prevention Unit
- Human Options
- The Eli Home
-Orange County
Housing Finance Trust
- City Net
- Olive Crest
- American Family
Housing
Real Estate Affiliated
- Families Forward
- OC Gateway to
Housing
- OC Social Services
Tustin Family Campus
- Family Promise of OC
- Second Chance OC
- OC Rescue Mission
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 Pa ge 15
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
- Century Housing
- Lennar Corp.
-City Ventures
- Civic Center Barrio
Housing Corp.
- Taylor Morrison
-Greystar
- William Lyon Homes,
Inc.
- Brookfield Residential
Southern CA
Senior Housing and Advocates
-Curt Pringle & Assoc.
-HomeAid Orange County
- Shea Homes
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
-Community Action
Partnership of
Orange County
- OC Office on
Aging
-Orange County
Health Care Agency
Religious Institutions
Justin Housing
Authority
-County of Orange
Senior Services
-Senior Rental
Properties in Tustin
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 underrep resented 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
Foundation Foundation OC
- Tustin Unified
School District
City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan Pa ge 16
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
Do- Housing Element Update Community 10� Joint Community Workshop with
Workshop with the Planning Commission the City Council and Planning No- Draft Document - Public Hearing with the
Commission Planning Commission
November Jan/Feb May 2021 June/July 6, September October
2020 > 2021 > > 2021 > 2021 > 2021 1
11110� Community Survey open
for 30 days
Online Community Survey
Do- June 30 - Reopened the 00- Finalize Document -
Community Survey for 30 days Public Hearing with the
00- Draft Housing Element City Council
Document available for public
review (30 days) and HCD
review (60 days)
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:
Survey results
Reviewed existing housing policies
Potential new housing programs
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
posted as a spotlight feature on the City's website and sent to the web's
subscriber list in English and in Spanish
-POSTED FLYERS - Notifications in English and in Spanish were posted on the
City's e -notice board, Library, Senior Center, Tustin Family Youth Center (TFYC),
and Boys & Girls Club. Additional bundles of flyers were distributed at the
Senior Center (200 flyers), TFYC (200 flyers), and Boys & Girls Club (100
flyers). Additional flyer distribution was offered to individual apartment
locations part of the TEAM (Tustin Effective Apartment Managers) group
-CITY CALENDAR - Meeting information was posted on the City's Calendar
-TUSTIN CHAMBER - Tustin Chamber of Commerce advertised meeting dates on
their website. Flyer graphics shared were in English and in Spanish.
-EMAIL BLASTS - Multiple email notifications were sent to 268 stakeholders and
interested parties. The City Manager's Office utilized their Community Outreach
ListSery to e-mail notifications to over 10,000 subsribers. Graphics included and
attached to email blasts were in English and in Spanish.
-POSTCARD MAILINGS - Postcards containing workshop and public participation
information in English and in Spanish were mailed to 396 interested parties
including residents, businesses, property managers, housing advocacy groups,
non -profits, religious institutions and others. Information regarding workshop
participation was included within the City of Tustin's Strategic Plan postcards
which were distributed to 29,885 Tustin residents and 3,457 Tustin businesses.
-WEBSITE- City developed a
dedicated Housing Element Update
webpage, hosted on the City's
website
*Website includes a project
overview, schedule of activities,
and information on how the public
can get involved
*Website updated regularly with
timeline, meeting updates and
survey information
Dome
r__0 0-0-1
-SOCIAL MEDIA POSTS - UNPAID
AND PAID - Social media posts
were made containing information
on public participation
opportunities regarding the
Housing Element Update survey,
and multiple workshops/meetings,
on all of the City's social meda
platforms
-PRESS RELEASE - A press release
was distributed in English and
Spanish, inviting the public to
review the Draft Housing Element
Update (97 subscribers)
-VIDEO OUTREACH - Mayor
Clark's Corner video advertised
review of the Draft HEU. Video
was posted on all Social Media
outlets including YouTube
*The Tustin Chamber of Commerce
shared workshop/meeting
information on each of their social
media platforms
-NEWSPAPER ADVERTISEMENTS - To build widespread awareness of the
Housing Element Update, the City has made publications in local and regional
news resources in both printed and digital formats
-Tustin News - distributed to over 7,000 Tustin residents
*Irvine Weekly - distributed to over 8,200 Tustin residents, including a digital
distribution, reaching over 33,000 individuals
-PAID SOCIA MEDIA ADS - Paid advertisements on the City's social media
platfroms which enabled notification to a larger population than traditional
nnqtincj-;
,PEI
City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 9
Appendix B
Index of Interested Parties
Index of Interested Parties
Housing Element Survey Respondents
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Index of Interested Parties
Community Development Block Grant Interested Parties List
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Index of Interested Parties
Outside Agencies and Developers List
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CITY OF TUSTIN
GENERAL PLAN
APPENDIX F
REFERENCES
F-1
HOUSING ELEMENT
JULY 2022
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 A 4 A R C__ H
JULY 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 A 4 A R C__ H
JULY 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. Tamboree to Break Ground on Largest Veterans
Housing Communijy in Orange County, CA, Accessed on fuly 12,2022.
https://www.multihousingLiews.com
29. Orange CouM Register, 2020. Fountain project Fountain Valley helps start
50 -unit affordable apartment project. Accessed on July 12, 2022.
https:/ /www.ocregister.com/
2-7—.Tamboree Housing Corps., n.a. Multigenerational Workforce Communfty
Garden Grove Church partnership creates family, senior housing, services.
Accessed on Tuly 12, 2022. https:/ /www.jamboreehousing.com/
CITY OF TUSTIN
GENERAL PLAN
HOUSING ELEMENT
A 4 A R-- C-- H
JULY 2022
F-4
ATTACHMENT D
HCD APPROVAL LETTER DATED SEPTEMBER 12,2022
STATE QF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Govemor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
September 12, 2022
Justina Willkom, Director
Community Development Department
City of Tustin
300 Centennial Way
Tustin, CA 92780
Dear Justina Willkom:
RE: City of Tustin's 6th Cycle (2021-2029) Revised Draft Housing Element
Thank you for submitting the City of Tustin's (City) revised draft housing element update
received for review on July 21, 2022, along with revisions received on September 9, 2022.
Pursuant to Government Code section 65585, subdivision (b), the California Department of
Housing and Community Development (HCD) is reporting the results of its review. Our
review was facilitated by conversations on August 25, 2022 and September 1, 2022 with
you, Assistant Community Development Director Irma Huitron, and consultants Konnie
Dobreva and Danielle Thayer of EPD Solutions.
The draft element, incorporating the revisions submitted, meets the statutory requirements
of State Housing Element Law described in HCD's May 18, 2022 review. This finding was
based on, among other reasons, demonstrated adequate sites to meet the Regional
Housing Needs Allocation (RHNA), the removal of specified governmental constraints, and
a suite of programs that will affirmatively further fair housing (AFFH) through place -based
investments and anti -displacement strategies. The housing element will comply with State
Housing Element Law (Article 10.6 of the Gov. Code) when it is adopted, submitted to and
approved by HCD, in accordance with Government Code 65585.
The element now identifies adequate sites to accommodate the City's regional housing
need for lower-income households demonstrated by Program 1.1 (Residential
Development — Available Sites). This program commits to rezone at least 135 acres by
October 2024 permitting multifamily uses without discretionary action, requiring a
minimum density of 20 units per acre to address the identified shortfall of 3,790 units.
For your information, pursuant to Senate Bill 197 (Chapter 70, Statutes of 2022), as
the City did not adopt a compliant housing element within 120 days of the statutory
deadline (October 15, 2021), the City's adopted element must be found in compliance
Justina Willkom, Director
Page 2
by October 15, 2022 to maintain its scheduled rezone deadline of October 2024
(Program 1.1). If the element is not found in compliance by October 15, 2022, HCD
cannot find the element in compliance until the rezoning is complete.
Public participation in the development, adoption and implementation of the housing
element is essential to effective housing planning. Throughout the housing element
process, the City must continue to engage the community, including organizations that
represent lower-income and special needs households, by making information regularly
available while considering and incorporating comments where appropriate. Please be
aware, any revisions to the element must be posted on the local government's website
and to email a link to all individuals and organizations that have previously requested
notices relating to the local government's housing element at least seven days before
submitting to HCD.
Several federal, state, and regional funding programs consider housing element
compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill
(SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD's
Affordable Housing and Sustainable Communities programs; and HCD's Permanent
Local Housing Allocation consider housing element compliance and/or annual reporting
requirements pursuant to Government Code section 65400. With a compliant housing
element, the City meets housing element requirements for these and other funding
sources.
For your information, some general plan element updates are triggered by housing
element adoption. HCD reminds the City to consider timing provisions and welcomes
the opportunity to provide assistance. For information, please see the Technical
Advisories issued by the Governor's Office of Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html.
HCD sincerely appreciates the hard work and dedication you and Irma Huitron provided
in preparation of the City's housing element and looks forward to receiving the City's
adopted housing element. If you have any questions or need additional technical
assistance, please contact me at melinda.coy(a-)hcd.ca.gov.
Sincerely,
/ tZ "0'
Melinda Coy
Proactive Housing Accountability Chief
ATTACHMENT E
PLANNING COMMISSION RESOLUTION NO. 4457
EXHIBIT A: FINAL DRAFT GENERAL PLAN
HOUSING ELEMENT AND APPENDICES
Also available at:
www.tustinca.org/HousingElement
RESOLUTION NO. 4457
A RESOLUTION OF THE PLANNING COMMISSION OF
THE CITY OF TUSTIN RECOMMENDING THAT THE CITY
COUNCIL APPROVE GENERAL PLAN AMENDMENT 2022-
0002, UPDATING THE TUSTIN HOUSING ELEMENT
PURSUANT TO GOVERNMENT CODE SECTION 65588.
The Planning Commission of the City of Tustin does hereby resolve as follows:
The Planning Commission finds and determines as follows:
A. That California State Law Section 65588 requires each City to review as
frequently as appropriate and to revise its Housing Element as appropriate.
B. That the Housing Element is required to be updated every eight (8) years to
reflect new statutory requirements and accommodation its share of Reginal
Housing Needs Assessment Allocation.
C. That housing is an important issue with the State of California and as such,
each city and county must identify and analyze existing and projected
housing needs within their jurisdiction and prepare goals, policies,
programs, and quantified objectives to further the development,
improvement, and preservation of housing.
D. That in accordance with State Law, the City of Tustin has prepared a Draft
Housing Element for the 2021-2029 period in accordance with California
Government Code Sections 65580-65589.8.
E. That the City conducted extensive community outreach efforts through an
online community survey, social media ads and posts, newspaper
advertisements, mailings to stakeholders and memorialized all outreach
efforts in the 2021-2029 Housing Element Community Engagement Plan.
F. That on November 11, 2020, the Planning Commission held a public
meeting to review the 2021-2029 Housing Element requirements and the
City's strategy for enhancing and preserving the community's character,
and strategies for expanding housing opportunities and services for all
household types and income groups.
G. That a joint public workshop was held on May 11, 2021, to inform the
general public, the Planning Commission, and the City Council with the
purpose and intent of the Housing Element Update.
Resolution No. 4457
Page 2
H. That the initial Draft Housing Element was circulated for public review
between June 30, 2021 and July 30, 2021 and has subsequently remained
available for on-going public review and comment thereafter.
1. 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 (GIPA) 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 6 th cycle Housing
Element update.
0. 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.
11. The Planning Commission hereby recommends that the City Council approve GPA
2022-0002, attached hereto as Exhibit A, for the 6 th Cycle Housing Element.
PASSED AND ADOPTED by the Planning Commission of the City of Tustin, at a regular
meeting on the 13 th day of September, 2022.
Ile
DAVID J, ME�LILO, JR.
4/o JA A /j Chairpers6n
JO AA L. WILII�OM
Piling Commission Secretary
Resolution No. 4457
Page 4
STATE OF CALIFORNIA
COUNTY OF ORANGE
CITY OF TUSTIN
1, 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
1 31h day of September, 2022.
PLANNING COMMISSIONER AYES:
PLANNING COMMISSIONER NOES:
PLANNING COMMISSIONER ABSTAINED:
PLANNING COMMISSIONER ABSENT:
ljv'stINA L. WILLKOM
PKnning Commission Secretary
CHU, HIGUCHI, KOZAK, MASON, MELLO (5)
Attachment. Exhibit A: 2021-2029 Final Revised Housing Element
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2021-2029
TUSTIN
GENERAL PLAN
SEPTEMBER 2022
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CITY OF TUSTIN HOUSING ELEMENT
GENERAL PLAN SEPTEMBER 2022
TABLE OF CONTENTS
Section Page
1. INTRODUCTION TO THE HOUSING ELEMENT 1-1
Purpose Of The Housing Element 1-1
Scope And Content Of Element 1-2
Consistency With State Planning Law 1-2
General Plan Consistency 1-3
Public Participation 1-4
11. SUMMARY OF ISSUES, NEEDS, CONSTRAINTS AND OPPORTUNITIES 11-1
Summary Of Housing Needs 11-1
Preservation Of Units At Risk Of Conversion 11-19
Summary Of Housing Issues 11-28
Housing Constraints 11-29Housing Opportunities 11-88
111. HOUSING ELEMENT GOALS AND POLICIES 111-1
Housing Supply/ Housing Opportunities III -1
Maintenance And Conservation 111-3
Environmental Sensitivity 111-4
Related Goals And Policies 111-4
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
LIST OF TABLES
Tables Page
TABLE II -1: POPULATION GROWTH 2010-2018
11-2
TABLE 11-2: POPULATION PROJECTIONS 2025-2045
11-2
TABLE 11-3: EMPLOYMENT BY OCCUPATION
11-3
TABLE 11-4:EMPLOYMENT PROJECTIONS
11-3
TABLE 11-5: LIST OF MAJOR EMPLOYERS
11-4
TABLE 11- 6: JOBS -HOUSING BALANCE
11-5
TABLE 11-7: HOUSEHOLD INCOME DISTRIBUTION OVERVIEW
11-7
TABLE 11-8: NUMBER OF HOUSEHOLDS WITH COST BURDEN
11-8
TABLE 11-9: NUMBER OF HOUSEHOLDS WITH COST BURDEN
11-8
TABLE 11-10: TENURE OF HOUSEHOLDS WITH HEAD OF HOUSEHOLD AGED
65 YEARS OR OLDER
II -10
TALBE 11-11: ESTIMATED HOUSEHOLD INCOME DISTRIBUTION - HOUSEHOLDS
WITH HEAD OF HOUSEHOLD AGED 65 YEARS OR OLDER
11-10
TABLE 11-12: SENIOR HOUSEHOLDS BY TENURE
11-11
TABLE 11-13 RACE AND ETHNICITY
11-11
TABLE 11-14 DISABILITY DEMOGRAPHICS
11-12
TABLE 11-15 DEVELOPMENTAL DISABILITY DEMOGRAPHICS
11-14
TABLE 11-16 TUSTIN EMPLOYMENT IN AGRICULTURE
11-17
TABLE 11-17 AT -RISK UNITS
11-19
TABLE 11-18 ASSISTED HOUSING INVENTORY
11-20
TABLE 11-19 ORANGE COUNTY FAIR MARKET RENT
11-23
TABLE 11-20 COST OF PRESERVATION
11-24
TABLE 11-21 COST OF REPLACEMENT
11-27
TABLE 11-22 NEW AND RESALE PRICE OF HOMES AND CONDOMINUMS 11-31
TABLE 11-23 AVERAGE RENTAL RATES 2021
11-32
TABLE 11-24 SUMMARY OF RESIDENTIAL ZONING REGULATIONS
11-35
TABLE 11-25 INCLUSIONARY HOUSING OPTIONS FOR RESIDENTIAL PROJECTS WITH
FEWER THAN 20 UNITS
11-46
TABLE 11-26 FEE OPTIONS FOR RESIDENTIAL PROJECTS WITH FEWER
THAN 20 UNITS
11-47
CITY OF TUSTIN
GENERAL PLAN
ill
HOUSING ELEMENT
SEPTEMBER 2022
TABLE 11-27 FEE PER UNIT FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS
LIST OF FIGURES
Figures Page
FIGURE 11-1: IMPACT FEE ZONES 11-56
FIGURE 11-2: PLANNING FEES 11-57
FIGURE 11-3: RESIDENTIAL BUILDING PERMIT PROCESS 11-62
FIGURE 11-4: CONDITIONAL USE PERMIT CUP PROCESS AND TIMELINES 11-64
FIGURE 11-5: STREAMLINED ADMINISTRATIVE REVIEW PROCESS 11-64
CITY OF TUSTIN
GENERAL PLAN
up
HOUSING ELEMENT
SEPTEMBER 2022
11-47
TABLE 11-28 INCLUSIONARY HOUSING FEE COMPARISON
11-49
TABLE 11-29 SUMMARY OF HOMELESS ACCOMODATION ZONING
REGULATIONS
11-57
TABLE 11-30 MONTHLY VACANCY RATE VILLAGE OF HOPE
11-59
TABLE 11-31 MONTHLY VACANCY TUSTIN TEMPORARY EMERGENCY
SHELTER
11-60
TABLE 11-32 EMERGENCY SHELTER/ TRANSITIONAL HOUSING FACILITIES/ HOMELESS
RESOURCES
11-61
TABLE 11-33A DEVELOPMENT FEES
11-67
TABLE II -33B DEVELOPMENT FEES
11-69
TABLE 11-34 HOUSING TYPES AND PERMIT PROCESSING REQUIREMENTS 11-73
TABLE 11-35 PROJECT BUILDING PERMIT TIMEFRAME
11-77
TABLE 11-36 QUANTIFIED OBJECTIVES
11-86
TABLE IV -1 HOUSING ELEMENTS PROGRAMS 2021-2029
IV -1
LIST OF FIGURES
Figures Page
FIGURE 11-1: IMPACT FEE ZONES 11-56
FIGURE 11-2: PLANNING FEES 11-57
FIGURE 11-3: RESIDENTIAL BUILDING PERMIT PROCESS 11-62
FIGURE 11-4: CONDITIONAL USE PERMIT CUP PROCESS AND TIMELINES 11-64
FIGURE 11-5: STREAMLINED ADMINISTRATIVE REVIEW PROCESS 11-64
CITY OF TUSTIN
GENERAL PLAN
up
HOUSING ELEMENT
SEPTEMBER 2022
INTRODUCTION TO THE HOUSING ELEMENT
The availability of decent housing and a suitable living environment for every family
has been an ongom'g 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:
0 2013-2021: The previous planning period began on October 15, 2013, and ended
on October 15, 2021
0 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 11 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 11 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 1-2 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,
envirom-nental 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:
0 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 1-3 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 1-4 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 1-5 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
policies.
CITY OF TUSTIN
GENERAL PLAN
for the City to consider utilizing skilled and trained workforce
DRAFT HOUSING ELEMENT
1-6 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 1-7 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 Comn-tission (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 1-8 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 1-9 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
0 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 11- 1
POPULATION GROWTH 2010-2018
CITY OF TUSTIN, NEARBY JURISDICTIONS AND ORANGE COUNTY
Sources: 12010 U.S. Census, 2 2014 U.S. Census
3 American Community Survey (5 -Year Estimate) 2018
Population projections are shown in Table 11-2. 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 11- 2
POPULATION PROJECTIONS IN TUSTIN, CA 2025-2045
Percent Growth
jurisdiction
20101
2014 2
20 183
2030
2035
2040
2045
2014-2018
2010-2018
Tustin
75,540
80,617
79,787
-1.0%
5.6%
Anaheim
87,932
90,576
92,564
1.5%
4.7%
336,265
346,961
352,018
Garden
-1.4%
1.0%
Grove
170,883
175,085
172,652
Irvine
212,375
248,521
282,584
1 3.7%
33.1%
Orange
324,528
139,826
139,502
-0 . 2%
2.0%
Santa Ana
-0.1%
2.2%
325,483
334,924
332,727
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 11-2. 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 11- 2
POPULATION PROJECTIONS IN TUSTIN, CA 2025-2045
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 11-2 SEPTEMBER 2022
Percent Change
2025
2030
2035
2040
2045
(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 11-2 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 11-3 shows the breakdown of employment
by occupation.
TABLE Il- 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 1 42,448 1 1000%
Source: U.S. Census: 2014-2018 American Community Survey
Table 11-4 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 11- 4
EMPLOYMENT PROIECTION IN TUSTIN. CA 2016-2040
Source: Center for Demographic Research at Cal State Fullerton - 0CF, 2018
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-3 SEPTEMBER 2022
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 - 0CF, 2018
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-3 SEPTEMBER 2022
Table 11-5 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 11- 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 Myford 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; 17452 17th 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 11-4 SEPTEMBER 2022
jurisdiction has reached an equilibrium between employment and housing
opportunities.
Table H-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 11- 6
JOBS -HOUSING BALANCE
CITY OF TUSTIN, ORANGE COUNTY, SCAG REGION, 2019
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 11-5 SEPTEMBER 2022
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 1.78
1 1.57
1 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 11-5 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 bath -room.
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 11-6 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.
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 11-7 SEPTEMBER 2022
TABLE Il- 7
HOUSEHOLD INCOME DISTRIBUTION OVERVIEW IN TUSTIN, CA 2017
Income
Owner
Owner
Renter
Renter
Total
(0/0)
(0/0)
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 11-7 SEPTEMBER 2022
TABLE Il- 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 = 21870 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 11125 1,120 190 125 2,420 3,060
100% AMI
Household Income
>100% AMI 2,325 1,355 365 110 10,665 10,625
Total 12,175 11,375 5,424 4,840 24,715 26,185
Source: Comprehensive Housing Affordability Strategy (CHAS), 2008-2012 estimates and 2013-2017 estimates
As exhibited in Table H-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 11- 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 11-8 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:
• Integration and segregation;
• Racially or ethnically concentrated areas of poverty;
• Disparities in access to opportunity, including for persons with
disabilities; and
• 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 refired 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 11-9 SEPTEMBER 2022
Table 11-10 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 11- 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 II -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 Il- 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 11-12
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 11- 12
Race/Ethnicity
SENIOR HOUSEHOLDS BY TENURE IN TUSTIN, CA 2018
Percent
White, Non -Hispanic
Owner costs
Grossrent
Black, Non -Hispanic
as a
as a
Total Elderly Senior-
percentage
percentage
jurisdiction Headed Owner
Renter Of
of
Population
Households
household
household
Two+ Races, Non -Hispanic
income
income
Other, Non -Hispanic
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 11-13. 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 11-13
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. Demograpl-dcs by disability and age cohort are
identified in Table 11-14. 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 11-14
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
difficulty
2,125
6.7%
1,147
11.8%
Total Disability
5,238
6.6%
2,291
28.4%
Total Population
79,667
8,057
Race/Ethnicity
White alone
Black or African American
alone
3,294
138
8.5%
6.5%
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-12 SEPTEMBER 2022
TABLE 11-14
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 11-17. 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 envirom-nent. 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 11-13 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 corm-nunity; 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 11-15
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 11-14 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 11-15 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 11-16 SEPTEMBER 2022
TABLE 11-16
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 11-17 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 11-18 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 11-17 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 11-18 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 11-17
AT -RISK UNITS, TUSTIN, CA
Very- Low-
Moderate-
Expiration
At -
Project Name Low Income
Income
Total Units
Date
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 11-19 SEPTEMBER 2022
TABLE 11-18
ASSISTED HOUSING INVENTORY, TUSTIN, CA
Type/ Length
Tenant
Project Name
Owner:
Federal,
of
Earliest
Type
Date
Address
Name,
State, or
Type(s) of Gov 't
Affordability
Potential
# of
(i.e.,
Bedroom
Built
Condition
Address,
Local
Assistance
Controls
Conversion
Units
Elderly,
Mix
(if
(if known)
Tel. #
(including
Date(s)
Family)
known)
Sec. 8)
Tustin
Goldrich & Kest
Fed.
HUD
---
July/2014
99
Elderly
100 1-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 11-20 SEPTEMBER 2022
TABLE 11-18
ASSISTED HOUSING INVENTORY, TUSTIN, CA
Type/ Length
Tenant
Project Name
Owner:
Federal,
of
Earliest
Type
Date
Address
Name,
State, or
Type(s) of Gov't
Affordability
Potential
# of
(i.e.
Bedroom
Built
Condition
Address,
Local
Assistance
Controls
Conversion
Units
Elderiy,
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
DDAI
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
Local
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 11-21 SEPTEMBER 2022
TABLE 11-18
ASSISTED HOUSING INVENTORY, TUSTIN, CA
Type/ Length
Tenant
Project Name
Owner:
Federal,
of
Earliest
Type
Date
Address
Name,
State, or
Type(s) of Gov't
Affordability
Potential
# of
(i.e.
Bedroom
Built
Condition
Address,
Local
Assistance
Controls
Conversion
Units
Elderiy,
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
I DDA - Disposition and Development Agreement
Source: Comprehensive Housing Affordability Strategy 2008 -2018, City of Tustin
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-22 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 11-19
ORANGE COUNTY FAIR MARKET RENT, 2020-2021
Year Efficiency One- Two- Three- Four -
Bedroom Bedroom Bedroom Bedroom
FY 2021 $1,678 $1,888 $2,331 $3,227 $3,716
FY 2020 $1,563 $1,785 $2,216 $3,098 $3,578
Source: HUD User FY 2021 Fair Market Rent Documentation System
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-23 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 11-20 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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-24 SEPTEMBER 2022
TABLE 11- 20
COST OF PRESERVATION
Project Units
Chatham
Westchester
Flanders
Total
Village
Park
Pointe
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
$438,354
$374,732
$126,231
$939,317
by Fair Market
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 11-24 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
Services of Orange County Inc.
• Century Housing Corporation
• Civic Center Barrio Housing
Corp.
• Long Beach Affordable
Housing Coalition, Inc
• Housing Corporation of
America
• Nexus for Affordable Housing
• Orange Housing Development
Corporation
• Riverside Chartable
Corporation
• Hart Community Homes
• Keller & Company
• Poker Flats LLC
• Coalition for Economic
Survival
• A Community of Friends
• CSI Support & Development
Services
• ROEM Development
Corporation
• City of Newport Beach
• Abbey Road Inc.
• Jamboree Housing
Corporation
• Innovative Housing
Opportunities, Inc.
• L + M Fund Management LLC
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:
0 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 11-25 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 11-17 includes at -risk units within the city for the 6th planning cycle (2021-2029).
Table 11-18 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 11-26 SEPTEMBER 2022
TABLE Il- 21
COST OF REPLACEMENT
Year
Project 1
Project 2
Project 3 Average
10861 Acacia
16790S Harbor
Address
*
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
7ource: Jamboree Housing, 2022; Orange County Register, 2020; Multi -Housing News, 2019.
As shown above in Table 11-21, 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 11-27 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 11-28 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, goverrunental, 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 11-29 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 pandernic 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 11-30 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 11-22 and 11-23).
TABLE 11- 22
NEW AND RESALE PRICE OF HOMES AND CONDOMINIUMS
TUSTIN AND NEIGHBORING JURISDICTIONS 2020
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-31 SEPTEMBER 2022
Median Home
Median Home
Change from
City
Zip Code
Price- Q2 2020'
Price- Q2 2019'
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%
92843
$431,000
$560,000
-22.9%
Grove
92844
$425,000
$485,000
-12.4%
92845
$749,000
$659,000
+13.7%
92602
$1,300,000
$1,243,500
+4.5%
92603
$970,000
$1,087,500
-10.8%
92604
$811,500
$750,000
+8.2%
92606
$815,000
$799,500
+1.9%
Irvine
92612
$686,500
$663,500
+3.5%
92614
$820,500
$730,000
+12.4%
92618
$920,000
$966,750
-4.8%
92620
$954,500
$1,030,000
-7.3%
92865
$755,000
$640,000
+18.0%
92866
$735,000
$738,500
-0.5%
Orange
92867
$737,500
$737,000
+0.1%
92868
$550,000
$472,500
+16.4%
92869
$655,250
$670,000
-2.2%
92701
$300,000
$380,000
-21.1%
92703
$575,000
$493,000
+16.6%
92704
$550,000
$510,000
+7.8%
Santa Ana
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 11-31 SEPTEMBER 2022
TABLE 11- 22
NEW AND RESALE PRICE OF HOMES AND CONDOMINIUMS
TUSTIN AND NEIGHBORING JURISDICTIONS 2020
Median Home Median Home Change from
Citv Zip Code Price- 02 20201 Price- 02 20191 2019
I Data include all home sales, new and resale, and condon-dniums.
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 person's debt -to -
income ratio, cash available for down payment, and credit history, when determining
a maximum loan amount. Many financial institutions are willing to significantly
decrease down payment requirements and increase loan amounts to persons with
good credit rating.
TABLE 11- 23
AVERAGE RENTAL RATES 2021 - 1ST QUARTER
CITY OF TUSTIN
Number of Bedrooms
Number of
Units
Average Square
Footage
Average
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
Caf6 (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 11-32 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 11-24).
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 11-33 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 11-34 SEPTEMBER 2022
TABLE 11-24
SUMMARY OF RESIDENTIAL ZONING REGULATIONS
CITY OF TUSTIN
Zoning
Minimum
Density
Lot
Building
Front
Interior
Corner
Rear
Parking
Lot Area
Max.
Coverage
Height
Yard
Side Yard
Side Yard
Yard
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 11-35 SEPTEMBER 2022
TABLE 11-24
SUMMARY OF RESIDENTIAL ZONING REGULATIONS
CITY OF TUSTIN
Zoning
Minimum
Density
Lot
Building
Front
Interior
Corner
Rear
Parking
Lot Area
Max.
Coverage
Height
Yard
Side Yard
Side Yard
Yard
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 11-36 SEPTEMBER 2022
TABLE 11-24
SUMMARY OF RESIDENTIAL ZONING REGULATIONS
CITY OF TUSTIN
Zoning
Minimum
Lot Area
Density
Max.
du/ac
Lot
Coverage
Building
Height
Front
Yard
Interior
Side Yard
Corner
Side Yard
Rear
Yard
Parking
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
spacesin
mobile
home
P -D Planned
10,000
Range
To be
To be
To be
To be
To be
2 assigned
Development
Incl.
detern-dne
determine
determine
determined
detern-dne
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
(med)
District
District
District
District
4 units
17.39
1 (high)
I
I
I
I
I
I
I
Source: City of Tustin, Zordng Code, 2021
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-37 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 11-38 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 Prelin-tinary RAR process, which shall provide a prelin-dnary 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 11-39 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.
Prelin-tinary 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 11-40 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 Corranunity 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 11-41 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 Lfgacy Speciflc Plan (formally 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 11-42 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 11-21
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 11-43 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 11-44 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 11-45 SEPTEMBER 2022
in -lieu fee would be $4.41 per square foot, which is much lower than other cities in
Orange County.
TABLE 11-25
INCLUSIONARY HOUSING OPTIONS FOR RESIDENTIAL PROJECTS WITH
FEWER THAN 20 UNITS
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 11-46 SEPTEMBER 2022
OpLions for.w0j:Cts Ith 20 of MO(k VWdanlial units
E.ainptt for calculati6os
114 'Base Units' plu 2aD11SlVBOmwS links m 1-37 Total Unks
AJJ ne. shall hiclo* offordole Vnem
R""', merit
on the iimbff of units is based on the nuntber I
1...ihin
far O-Sh.
in -lieu fee
'twe VK16"Propowfor the pe0jecr.
Affovdable
Units
on.lite
599Z3
IS% afthe *bm unlW SkAtL BE AFFOFaDPA"
If
.114-35%
17
WMApplicable
op tic" (@)(I)
6" .1 J SN �h.?) ft vffi,,dbbk w ry ( hhd�
=114* 6%
7
4 5% Qf 2�% sw be oft,404-k [a �OOww hovsehi*05
=114* 4.5%
51
45% 0i5%5W6, oflaroirm
=114- 4.5%
5
OR
0" "t,
111HIZ3
2"% of the 'ban units' SMALL BE Af FORDABLE
=214 - 12.5%
14
NICE Appik"
p
TS".,
9
j2 5
V 4
OR
Dow off.
-option
5% of the 'ban units" SMALL BE AFFORDABLE to�arylo.
n114 - 5Y.
sile.
Income hiocs1holds plus paynnent of an In -lieu feelseebelow)
OR
0. or Off-
10% of the " base units" SHALL BE AFFORDABLE to lo
' _ntoffie
*Dpiian
10%
11
site
(aX3)Ib)
housihields plus payment OF an In -lieu F" 1we bel—,
,options ja)J3112) and requi fe PayffiLnit Of
999230411)
an In lieu fee calcolatcd by
n $136,801 X Half the number at base units
57
7",657
NOW' Per TO:
9"", 1. CmIpwrin, the total U.1be, of �Jwniary woMarve hfts�g iiaenti� program unks r"u'red in a rt�ldeiviml pmjea, fractions stioll h,,
-Med cis to,he
,..t �bot,
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 11-46 SEPTEMBER 2022
TABLE 11-26
FEE OPTIONS FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS
It should be noted, that the in -lieu fee for projects under 20 units is reduced as the
project size becomes smaller.
TABLE 11-27
FEE PER UNIT FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS
2022 Tustin
In -Lieu Fee Per Unit
For project with fewer than 20 Uni
for
In -lieu per unit reduced
smaller projects
1-4 units
$9,200
Options for Residential Projecu with fewer than 20 units
$10,350
10-14 units
The primary nivans of complying shall be the provision of on-site units.
15-19 units
$12,651
"o-Zer' a 7'elopee may only satisfy the requirements by means of an
on-site
89925(a)
alternative to on-site oluntary workforce housing incenti" program
units in accordance with the require ments and procedures of this
section B9923.
Requirement nvy be satisfied, in whole or in part, by the construction
off-site
89925(b)
ofnew units, orthe conversion of existing market rate units tu voluntary
workforce housing incentive program uniLs, offsite within the city's
jurisdictional boundary.
in -lieu
B9925 (c
Requirement mkay be satisfied in whole or in part, by payment to the $12,651 x 19 S 240,369
payment
CiWs established in -lieu fee.
1.9nd
Requirement may be satisfied, in whole or in part, by an alternative
B9925(d)
option aoceptable to the City, wtil(;h may include without limitation the
acdication
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 11-27
FEE PER UNIT FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS
2022 Tustin
In -Lieu Fee Per Unit
For project with fewer than 20 Uni
for
In -lieu per unit reduced
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 11-47 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 11-48 SEPTEMBER 2022
TABLE 11-28
INCLUSIONARY HOUSING FEE COMPARISON
city
USIO
1.1 In IV
H—lo:
Ordin.n.
Applicabi
lrh,.ih. : III.
Affordable
Units
equarements
In -Lieu Fee Allowed?
l"M Fats
ReStunege Lb*
.a H.b,.
Nlaho.Wry
Poja uuth
15%oltotal
W;fawment ofper orroost not
L�
�71
units
7ovided on-sita (ta sed on t he
units
valuation of per unit)
E"unple
A—ed .1—i- pe, .1 it Is $200,DDO
30 tofts ,op—d
'SK requed 1. he affoolble C5 -hih)
5200,000. 5 = $1 nullb.
Hundn on
a'
Mantatory
10
Y.f., ft].rts with 9 or
rhree Un,ts $9,4401unit
n 1�9�0 r cl,eg[st- lewa
Me�i&GU-"Q F3A37144 S- W4CD1 A'EIXC
8—h
P=Ith
3
un , % saftt.1
(Finusl or
fewer unios
Fmu Utts $10,611)(Ijunit
SF0129DOWG��
..as
For Wel
Five Units $11,7801,,it
Fee Is Wied on slidlu, Kale
St, r[i, $12,960JU,1t
Sevin Units $14.1401unit
p
Eight Unit, 515,330iumt
,��d',wnapk.tse,.��—
'g
N1.sU.r. �16,5001.mt
lowee,
Mandatory
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S 17,0D) or 0 mics, to 2007,
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CHWTER2.3 -AFFORDABLE HOUSING
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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 11-49 SEPTEMBER 2022
Housing for Persons with Disabilities/Reasonable Accommodation
As discussed in previously and shown in Table 11-14, 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, ethnicifies, 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 11-50 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 11-51 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 11-52 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 11-53 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 11-54 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 11-55 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 11-28). 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 11-29 summarizes zoning regulations for homeless accommodation.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-56 SEPTEMBER 2022
TABLE 11-29
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
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 properties
(6) or fewer'
'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
realigm-nent/ conveyance process with Tustin as the Local Redevelopment Authority.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-57 SEPTEMBER 2022
0 Six (6) units at Columbus Grove operated by Orange Coast Interfaith Shelter.
0 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 11-30 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 11-58 SEPTEMBER 2022
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 11-31 provides monthly vacancy rate for TTES.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-59 SEPTEMBER 2022
TABLE 11-30
MONTHLY VACANCY RATE VILLAGE OF HOPE (2021)
Month
Average
Monthly
Bed
Occupancy
Total
Available
Beds'
Remaining Vacancy Rate
Beds
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 11-31 provides monthly vacancy rate for TTES.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-59 SEPTEMBER 2022
TABLE 11-31
MONTHLY VACANCY RATE TUSTIN TEMPORARY EMERGENCY SHELTER (2021)
Average Total
Month Monthly Available Remaining Vacancy Rate
— Bed Beds* Beds
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 11-60 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 11-32, 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 11-32
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
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 suvvlv.
Tustin Presbyterian
CITY OF TUSTIN
GENERAL PLAN
Collects food supplies and distributes the
food to various organizations involved in
providing homeless services.
DRAFT HOUSING ELEMENT
11-61 SEPTEMBER 2022
TABLE 11-32
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
Families Forward Grove operated by Families Forward,
formerly Irvine Temporary Housing in
Irvine.
Source: City of Tustin
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-62 SEPTEMBER 2022
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 11-62 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 fan-dly 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 11-63 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 11-33a, II -33b, and Figure 11-2. 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 11-32a and 11 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 11-2) 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 11-64 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 un Uts
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 11-65 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 11-66 SEPTEMBER 2022
TABLE 11-33A
DEVELOPMENT FEES
FEE TYPE LAND USE FEE RATE
Residential Single Fandly 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
I area upon orwithin a building designed for
Park Fees
Hotel or motel rental
unit without a kitchen
When a public park or public recreational facility
is not provided within a proposed residential
subdivision, the subdivision is less than fifty (50)
parcels, or the project is a conversion of an
existing apartment complex to a multi -owner
occupancy not exempted in the Subdivision
Code, a park fee will be required.
$100.00 per unit
The fee is calculated on a per unit basis for each
project, reflecting the fair market value of land
required for park purposes. The value shall be
determined by a Master Appraisal Institute
(MAI) appraiser acceptable to the City and the
ext)ense of the subdivider.
DCCSP: The fee shall be based upon the fair
market value of the amount of land which would
otherwise be required for dedication.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-67 SEPTEMBER 2022
A park fee is also required for non- subdivisions
within the Downtown CommercialCore Specific
Plan (DCCSP) and the Red Hill Avenue Specific
Plan (RHASP).
RHASP: Calculate the amount of land which
would otherwise be required for dedication:
(# of Dwellings) x (0.003 Acre/Person) x
(2.24 Person/ Dwelling Unit)
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-68 SEPTEMBER 2022
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 11-68 SEPTEMBER 2022
Affordable HousingFeej
(Only applicable to
RHASP and DCCSP)
Any residential project
providing voluntary workforce
housing incentive units
pursuant to Subsection (a)(3) of
Tustin City Code B9923 must
also pay the City a voluntary
workforce housing incentive
program in -lieu fee calculated
by either:
Effective January 2022 -
January 2023 Fee = $13,801
per unit
1. Multiplying the voluntary workforce housing incentive
program in -lieu fee by one-half (1/2) the number of base
unitsprovided on-site
(In -Lieu Fee) x (Base Units Provided On-site)
2
2. Multiplying the voluntary workforce housing incentive
program in -lieu fee by one-half (1/2) the residential project's
totalsquare feet of residential area
(In -Lieu Fee) x (Residential Proect's Total Sq. Ft. of Residential
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 11-69 SEPTEMBER 2022
TABLE 11-33B
IMPACT FEES
FEE TYPE
LAND USE
IMPACT FEE RATE
Single Family
$6,056 per unit
Transportation
Zone A Multi -Family
$3,536 per unit
Corridor Fees
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 Is'
Non-
$4.88 per sq. ft. of building area
Residential
Affordable HousingFeej
(Only applicable to
RHASP and DCCSP)
Any residential project
providing voluntary workforce
housing incentive units
pursuant to Subsection (a)(3) of
Tustin City Code B9923 must
also pay the City a voluntary
workforce housing incentive
program in -lieu fee calculated
by either:
Effective January 2022 -
January 2023 Fee = $13,801
per unit
1. Multiplying the voluntary workforce housing incentive
program in -lieu fee by one-half (1/2) the number of base
unitsprovided on-site
(In -Lieu Fee) x (Base Units Provided On-site)
2
2. Multiplying the voluntary workforce housing incentive
program in -lieu fee by one-half (1/2) the residential project's
totalsquare feet of residential area
(In -Lieu Fee) x (Residential Proect's Total Sq. Ft. of Residential
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 11-69 SEPTEMBER 2022
Figure 11-1. Impact Fee Zones
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-70 SEPTEMBER 2022
Figure 11-2. Planning Fees
NO I CASE I YPI FEE
NO. CASE WIFE I FEE
NO. CASE TYPE FEE
Cori ... I Us. permits and Annimicinni
ZsmingAdminut-ttir Rai
Signi
Adm inis"'a"ive
I
Major
$5,000 Deposit
24
Aljuslm ent/Mi no r
�500 D.p-it
46
Ter porary Sign Permit $110 Fee
Amendment
2
Minn,
$2,500 Deposit
General Plan Arnimidminot,
47
Mastic, Sign Program $500 Dsp,cm
3
ABC
$1,000 Deposit
25
Major G ... -
$ 10,00 0
48
Sign Cdo E-cpt- $500 F -
Plan Am on dm ant
Dop-it
4
Sel Rem adii
$1,000 Deposit
26
Minor ne a
$1,000 Depoialt
Varlanzesanc!Am richments., Use De erminsitims,
Plan Am':ndman,
lopmen:Agireem miss . ndtAppeals
5
Am and= t 0
�1,000 Deposit
27
Land U,a Map
$5,000 Deposit
49
M aj a r Van an ce
�5,000 Deposit
C, n tit i f Approval
Logal Rovii- and
6
Adni I' P
$500 Deposit
28
Outside
Actual Costs
so
Minoi-Variance
$1,000 Deposit
Am and on ant
Con,, I
7
Tim s suit cn,i.n,
$250 Fee
Specific Fla. Amendment,
51
Am andments to
$1,000 Deposit
Condition, ofApprov.1
6
a �. Am ndm act
$10,006 Deposit
29
Major P'Cifi
Sp"Ifi
$5,600 Deposit
52
Tir a Extensions
$250 Fee
PI-Annandmient
D-ign Rai and Amendments
30
Minor SP-Ifla
$2,500 Deposit
53
Ennis Change
$10,000 Dspo,it
P1 an Am andment
9
Major
$5,000 Deposit
SubdiA,i.ns andA.endm.nts
54
Uso Distorrininnumn
$S00 DFpoc,t
10
Minor No.
$2,500 Deposit
31
Tentativ, Tract /
$5,000 Deposit
55
Dovel.p.ont
$5,000 Deposit
P arce Map
Agreem ants
ii
Mi no r Rem odpl
$1,000 Deposit
32
Final Tract M so
$2,500 Deposit
56
Appeals
$i,000 Deposit
12
Amand.antt.
�500 Deposit
33
Final Parical Map
52,500 Deposit
PlanninglReview ciflEtuildinglitian Check Submittals
Cond,tion-cAppmval
13
Timro Ents-imn,
$250 Fee
34
Let Line
$2,500 Deposit
57
No. C-Ar-fion
20% Form it Fee
Adjustment
R-dol/Tionant
14
Concept Plan Rev-
$5,000 Deposit
35
Lot Merger
$2,500 Dep -it
58
20% Perm it Fee
Improvements
j$Hl] Par Shapt,
15
Prislimmmor, 1 -is-
-.. $2,000
36
R vprsion to
5500 Epposit
59
Landscape Plan Rpvipw
20% Perm it Fee
Deposit
I
Aer-go
En%4ronmental
37
Ce rtil
$1,000 Depicait
OtherFees
Co in p c:f
A.cndmcnt,t.
Writton 7oning
16
FIR
$20,000 D.po,m
38
Conditions of
$1,000 Deposit
60
Conf,m.t,.n/N.n
$200 P -sl
Approval
Conforming Status Lttur
17
Sups a. ent.1
$10,006 Deposit
39
Tim a Extension
$250Faa
6 1
Annual Parking
'71/Parking
Addendum FIR
Excaption Fsa
E x -ption so. -
Nogat- Dod-timn
Matter
18
Mi t gated Negative
$2,500 Deposit
4 0
Association
$3,000 Deposit
62
Annexation
$10,000 Deposit
Declaration
Dec- ants, CC&,
to
Initial Study
$1,000 Deposit
T.mpmr.myU
63
No., Ra,k Pon. it
$500 DFpoct
Notica of Completion
Tom p.r.ry J-
Planning Servi- -Hourly
20
Dei ination
Actual C.,t,
41
Par. it
$2501's.
64
Rato
Actual C,,t
E- ption
Dia-mient Feias
42
Large Gathpring
51,000 Deposit
65
pse Not Listed
Fair D rect '�o
p arm it
D ster ' nat
21 Black and White Copy �O 10 Pot Pago
43
Ti or P Ext or si on
$12 0 F as
City Counciii Re5olution No. 21-54
22 Cc In - C. py $0 30 Per Pago
44
Film Permit
$5001'so
Adopted July 20, 2021
Fffecti October 1, 2021
23 Othor Plans and Maps Actual Cost
4'
Reasonable
A-m-mr.d.tion
$500 Foa
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-71 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 11-72 SEPTEMBER 2022
TABLE 11-34
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
Residential
Duplexes or two
structure)
PD -
Planned Not Applicable
Development
Apartment
Homes, Bungalow
Courts, Discretionary
Condominiums, (Planning
Community Commission)
District was specifically created to authorize
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
structure)
'Discretionary
District
detached single-
(Planning
Program 1.5, City will amend Zoning Code to
family dwellings
Comn-dssion)
allow triplexes by Right
R3 - Multiple
*Single-family,
**Triplexes (single
Zoning district includes objective design and
Family
ADUs, JADUs;
structure);
Administrative
development standards
Residential
Duplexes or two
Boarding houses;
(Director Review)
District
detached single-
Condominiums
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-73 SEPTEMBER 2022
*Administrative
TABLE 11-34
Specific Plan includes objective design and
See Program 1.2 which commits to the
HOUSING TYPES AND PERMIT PROCESSING REQUIREMENTS
Zone
By Right CUP
Design Review
Notes
Planned
family dwellings;
Condominium
Program 1.5, City will amend Zoning Code to
Multiple family
allow triplexes by Right
(Director Review)
dwellings, apartment
District
Apartment
houses.
allow residential uses by Right
MHP -
projects
'Discretionary
Mobile
Not applicable Mobile home
(Planning
Zoning district includes objective design and
Home Park
parks;
Commission)
development standards
District
See Program 1.2 which commits to the
Agricultural
ADUs, JADUs;
*Administrative
Apartment houses
Specific Plan includes objective design and
See Program 1.2 which commits to the
PD -
Specific Plan Residential Unit
Bungalow courts
Allocation from 500
development of Objective Design Standards
Planned
Not applicable
Condominium
Administrative
Development
Community
(Director Review)
Program 1.5, City will amend Zoning Code to
District
Apartment
allow residential uses by Right
projects
RA -
Residential
*Single-family,
Not Required
*Administrative
See Program 1.2 which commits to the
Agricultural
ADUs, JADUs;
(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 11-74 SEPTEMBER 2022
Planned
TABLE 11-34
Community
Administrative
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
Community
Site #1. Specific Plan will be amended to
See Program 1.2 which commits to the
affordable housing,
allow for additional units per Program 1.1.
Source: City of Tustin
as well as mixed-use
DCCSP -
*Adrrdnistrative
Specific Plan includes objective design and
Downtown
(Director Review)
development standards. The DCCSP Land
Commercial
Mixed -Use, Live- Not Required
with concurrent
Use Plan allows for a total of 887 residential
Core Specific
Work
Residential Unit
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
Adn-dnistrative
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 11-75 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 11-3, Residential Building Permit Process.
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 11-76 SEPTEMBER 2022
Figure 11-3. Residential Building Permit Process
Submit Plans to First review - 10
CU
r. U Send Applicant
CU R
City with payment days
U Z Corrections or
Q.,M
(online or in- Subsequent
".4 Issue Permit
person) Reviews - 5 days
u 0
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 11-76 SEPTEMBER 2022
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 11-77 SEPTEMBER 2022
TABLE 11-35
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
"The
September
submitted for plan check
approval; no permits as
Area -
2021
or obtained permits
of March 2022
Hill"
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 11-77 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 11-4, 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 H-4. - Conditional Use Permit CUP Process and Timelines
pplic tion
P'�Imwrwyik-i—
i Joptiao.i) i su mittal Applicant mod ifies
ita Appl
a p p I i c -a Udonlp I a n s
. pi
and resubmits plans
Application Review for completeness
and CEUA requiremtents (301 -day review)
(3
Application
a �clr'u'cd
Application Complete and project isscheduled incomocte
to da
rpublic hearing within thirty 130) days
Public Notice is mailed, published and posted at least
ten (10� calendar days before public hearing
Raid public hearing; Project is presented to the
Zen Ing Administrator or Pla n rung Com mission
Project Project
Denied I I Approved
1"y
Appeal Period
Decis4on to "OT Decism appealed.* I Decision to Approve NCT
Appeafec[.Applmp��.m,nul Appealed. Applicant may
proceed with the project, proceed with the project.
Streamlined reviewsfor 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 11-78 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 11-79 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 strean-dined, 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 11-80 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 11-5. - Streamlined Administrative Review Process
Prel i m! nary Revi ev., Formal Application
(optional) submittal
Project Project
Denied � Approved
10 -day
Appeal Period
Deasio n to Deny NOT I I Dedsionappealed.* Decision to Approve NOT
appeaf�-d. Applicant may n t appealed. Applicant may
proceed with the projecto I I 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 11-81 SEPTEMBER 2022
Applica,nt,modifies
t
plication p
app"_Ii )n'plans and
P1
Application Review for
es
resubmrt5 plans
.2 s
completeness and CEQA
iw)
requirements (30 -day review)
Application
Incomplete
Application deemed Complete
Project Project
Denied � Approved
10 -day
Appeal Period
Deasio n to Deny NOT I I Dedsionappealed.* Decision to Approve NOT
appeaf�-d. Applicant may n t appealed. Applicant may
proceed with the projecto I I 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 11-81 SEPTEMBER 2022
In 2020, City staff developed a streamlined application and implemented a
complimentary strean-dined 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 11-82 SEPTEMBER 2022
0 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 11-83 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 11-22 (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 11-84 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 11-85 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 11-36
QUANTIFIED OBJECTIVES
Income New Construction Rehabilitation ConservatiorV
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), City's 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 comn-dts 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 11-86 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 13: 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 111-2 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 111-3 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 111-4 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 6th cycle Housing Element
update. A review of the City's past performance on housing element implementation programs
is contained in Appendix A of the Housing Element.
The following table (Table 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- I 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 111. Those programs are only listed once to avoid
duplication.
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source I Quantified Objective Timeframe
Agenci I
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
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
As requested between
the By -Right Approval of Projects with 20 Percent
"Reuse"
Development
housing related entitlements
2021 - 2029, Report
Affordable Units on Sites in compliance with
Department
for TLSP by assigning a
annually in April
Government Code Government Code 65583.2(h) and (i).
designated project manager
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:
• Allow 100 percent residential use, and
• 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
0 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
1 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
0 374 housing units by
Core area.
Development
October 2025
Department
0 373 housing units by
Economic
October 2029
Development
Department
Housing
(New) Red Hill Avenue Specific Plan (RHSP)
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 1-5 freeway
Development
assigning a designated project
Department
manager.
0 258 housing units by
October 2025
0 105 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.
General Fund
of 30 du/acre.
(New) By -Right Residential Development to Meet
Community
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
h. Facilitate affordable housing development including
Authority,
Housing Authority
inventory by 50 units over
housing for extremely low income and very low-income
Community
Fund
eight years (10 extremely low;
households, and households with special needs (such as
Development
20 very low; 20 low income
persons with disabilities and farmworkers).
Department
CDBG Fund
units).
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 explais
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.
Economic
new housing developments to
Development
ensure compliance with SLA
Department
and affordable housing
provisions.
1.2 (New) Objective Design Standards lip
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
the construction of affordable housing, including extremely
Community
Development
General Fund
Encourage the use of density
bonus incentives by
Advertise on City
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
r
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
By December 2024
Workforce
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
Program
1.5 (New) Zoning Code Streamlining Program
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Responsible Funding Source
Agenc
a. Implement zoning code amendments to facilitate � Community
application and project review streamlining and compliance Development
with State law to meet housing needs.
General Fund
Quantified Objective
ambiguities and discretionary
action(s)-
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.
Annually review
zoning code and
identify potential
improvements to
strean-dine
development and
permit Amend zoning
code as appropriate
Timeframe
By December 2025
By December 2025
Annually
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
each year.
Home Assistance Program that provides financial and
Development
website for potential funding
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
Update website with ADU
By June 2022
awareness.
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
pertaining to the new
By January 2025
tracking (refer to Program 1.1h), and technical assistance. This
accelerator program for ADUs
program will also create a one -stop -shop comprehensive
and SB 9 developments,
resource for homeowners interested in developing an ADU
specifically to high opportunity
and/or S139 developments. This program will complement
revised Program 1.1(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
0
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 Economic
units for applicable housing
any public funds, as may be legally required. Development
development projects.
Department
1.10 (Modified) Development and Permit
ip
Streamlining
I
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
Community
General Fund
Review number of days to
Bi -annual reviews in June
Department as a central clearinghouse with individuals
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
bi-annually 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 envirom-nental
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 A
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 Abu
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 1 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
PEM "MEN
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
Housing
subject only to those zoning regulations that apply to other
Authority,
residential dwellings of the same type in the same zone.
Community
Transitional and supportive housing meeting certain
Development
criteria will be allowed by -right in zones where residential
Department,
uses are pern-titted, including mixed-use and nonresidential
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 pern-dtting 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
CDBG funds
b. Facilitate continued operation of Sheepfold homes and
Community
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
Authority
Allocate CDBG funds to non -
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
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
State and Federal
outreach program with
program by June 2022
(i.e. brochures, pamphlets, informational flyers, etc. that can
Department
programs; City's
information posted on the
Develop outreach
be shared and posted on the City's website) that informs
General Fund
City's website along with
materials by September
families within the City of affordable housing and services
social media usage.
2022
available for persons with developmental disabilities.
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
Agenci
Quantified Objective
Timeframe
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
identified in Program 2.4d.
nonconformities to property.
(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.
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;
Update website and provide
Community
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
IF
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
0 937 referrals annually
information to the public at all times.
Recreation;
Department;
a 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
TGoal 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 W
a. Facilitate the process of homeownership, especially first-
Housing
State and Federal
Provide educational resources
Annually, start by
time homebuyers, by providing a virtual one stop shop
Authority;
sources
on city website and social
December 2024
clearinghouse through a non-profit organization (i.e.
Community
Development
media.
Affordable Housing Clearinghouse) and explore
participation in the Orange County Mortgage Assistance
Conduct review and analysis
Program (MAP)
for MAP participation.
By October 2023
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
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 Lk
I
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
Agenci
a. Provide rental assistance, through the County Section 8 County of Orange,
program, to extremely low and very low income Housing
households. Authority,
Community
Development
Department
3.6 Affordable Senior Housing Project and Senior
Board and Care Facility
a. Continue to provide opportunities to provide a range of Community
housing options to address the diverse needs of Tustin's Development
senior population. Department
HUD
Through the Orange County
Report annually in April,
Housing Authority, the City
during planning period.
will continue to provide
Section 8 rental assistance to
Publish locations on City
extremely low to very low-
website and verify
income residents with
annually in April
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.
None necessary
Provide at a variety of
Annual report in April.
affordable housing options for
seniors located at:
16000 Cambridge
Publish locations on City
Street (Coventry
website and verify
Court - 153 units)
annually in April
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -34 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible
Agency
3.7 (Modified) Preservation of Assisted Housing
a. Preserve units at -risk of conversion to market -rate housing Community
Development
Department,
Housing
Authority
3.8 (New) Middle Income Housing Opportunities
Community
a. Complete a cost -benefit analysis of obtaining membership Development
with the CaICHA - through its Essential Middle -Income Department,
Rental Housing Program ("Program"). Housing
Authority
Funding Source I Quantified Objective I Timeframe
311 Sycamore Avenue
(Heritage Place - 54
units)
a 275 E. 6th Street
(Tustin Gardens - 99
units)
0 17432-17442 Mitchell
Avenue (Tustin
Terrace - 20 units)
State and Federal
Establish annual monitoring
Develop monitoring
Funds
procedures for rent restricted
procedures by December
units provided through City
2023 and begin
incentives and/or financial
implementing
assistance. Contact property
procedures by January
owners within at least one year
2024.
of potential affordability
expiration to initiate
preservation discussions.
General Fund
Review and analyze benefits
By December 2025
from potential participation in
CaICHA program.
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
3.11 (New) Quality Rental Housing Inspection Program
a. Establish a multi -family quality rental housing inspection
program.
Responsible Funding Source Quantified Objective
Agenc
Timeframe
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.
Community CDBG,Home Elevate the quality of housing
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.
By July 2025
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 ChildreWs 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
Community
greater needs for daycare,
low-income families for child care services. The City will
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
Agenci
b. Amend the zoning code to require all new multi -family Community General Fund
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
and increasing the large units into the local housing
inventory.
Goal 4: SUSTAINABLE HOUSING
4.1 (Modified) Code Enforcement Program
a. Encourage property maintenance and enforce building Community City General Fund
codes to address and prevent substandard housing Development
conditions, removal of graffiti and other deferred Department
maintenance issues on public property.
Quantified Objective
Amend the code.
Facilitate the creation of four
(4) large family units will be
generated annually, and 32
total by 2029.
hivestigate substandard
housing an on-going basis;
approximately 25 cases per
year.
Remove approximately 4,000
cases of graffiti annually.
Conduct approximately 100
Water Quality inspections, in
conjunction with the Water
Quality Control Ordinance and
the National Pollutant
Discharge Elimination System
(NPDES) permit process to
protect neighborhoods from
pollution.
Timeframe
By December 2024
Annually, start January
2025 through 2029
Report annually in April
Report annually in April
Report annually in April.
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
Agenci
b. Develop educational and trainings materials, to promote Community General Fund
water efficiency. Development
Department
Quantified Objective
approximately 100 total per
year.
Educate via City's website,
Design Review process and
counter consultations;
approximately 100 total per
year.
Timeframe
Report annually in April
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -43 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
This page has been intentionally left blank.
DRAFT HOUSING ELEMENT
IV -44 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
APPENDIX A
REVIEW OF PAST PERFORMANCE
A-1
HOUSING ELEMENT
SEPTEMBER 2022
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
0 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
GENERALPLAN 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
GENERALPLAN 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.
Disable& 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
GENERALPLAN 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
GENERALPLAN 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
GENERALPLAN 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 BrowW 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
GENERALPLAN 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
'Numbers include total, actual number of units with permits issued and completed.
2 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
GENERALPLAN
ME
HOUSING ELEMENT
SEPTEMBER 2022
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
1 1
Total
1,227
1 1,549
-H
1 100 1 100
'Numbers include total, actual number of units with permits issued and completed.
2 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
GENERALPLAN
ME
HOUSING ELEMENT
SEPTEMBER 2022
APPENDIX A -
ATTACHMENTS
REVIEW OF PAST PERFORMANCE
CITY OF TUSTIN
GENERALPLAN
me
HOUSING ELEMENT
SEPTEMBER 2022
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
GENERALPLAN
A-10
HOUSING ELEMENT
SEPTEMBER 2022
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
I 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
surnmary 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
GENERALPLAN
A-11
HOUSING ELEMENT
SEPTEMBER 2022
New Construction
Rehab/Preservation
Housing
Assistance
Income Group
Goal
Actual
Goal' Actual
Goal'
Actual
Very -Low
283
94
171 253
242
243
Low
195
74
49 132
74
74
Moderate
224
114
Above Moderate
525
1,240
Total
1,227
1,522
220 385
316
317
I 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
surnmary 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
GENERALPLAN
A-11
HOUSING ELEMENT
SEPTEMBER 2022
Program
Goal 1: Adequate Housing
Supply
1.1 Available Sites Continue
to utilize Planned Community
Districts and Specific Plans to
authorize and encourage mixed-
use developments. (See Zoning
Studies Program).
Housing Element Policies: 1.1, 1.5,
1.9
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
Community
Development
Department,
Successor Agency,
City Council
Funding
Source
City General
Fund; City and
Agency staff time
involved
2013-2021
Quantified
Objective
Assist in the
development of new
affordable owner and
rental housing through
development in MCAS
- Tustin and infill areas.
The City supports
applications for the
creation of new mixed-
use developments
particularly when the
projects involve
affordable housing
A-12
Units
Tustin Legacy
(previously referred
to as MCAS):
Amalfi:
Completed 2015
37 Moderate
496 Upper Income
Anton
Com
,pleted 2015
88 Very Low
73 Low
64 Moderate
Other City Areas
Habitaffor
Humanity Veteran
Housiyg_[140 S. A
Street adjacent to
Old Town]:
Completed 2018
1 Low
1 Moderate
Results
Effectiveness
Positive
Tustin Legacy
The City entered into
agreements with
several developers at
the Tustin Legacy for
implementing the
affordable housing
component of the
Specific Plan and
secured units for
housing, including low
income households.
I PTOW] �
Specific Plan approved
in 2018 which added
into this area of the
City the opportunity
for 887 residential
units to be developed.
To date, 140 upper
income units have
been built with a
workforce housing in -
Timeframe
Continue/Modify/
Delete
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
SEPTEMBER 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding Quantified
Agency Source Objective
1.2 Mobile Homes Community City General The City will continue
Continue to maintain the City's Development Fund; processing to maintain the existing
mobile home i)ark zone and fees (recoverable) mobile home park zone.
City of Tustin
Draft Housing Element
A-13
Units
Between 2013-2021,
no applications for
mobile homes or
Results
Effectiveness
lieu fee provided. All
future development
will require
participation in
workforce housing
options contributing to
affordable housing
mostly through mixed
use.
DT -J A C!D
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.
Positive
Timeframe
Continue/Modify/
Delete
On-going
Continue
Appendix A
SEPTEMBER 2022
Program
process conditional use permit
applications as received for manu-
factured homes.
Housing Element Policies: 1.1, 1.4
1.3 Second Residential Units
Continue to provide opportunities
for affordable second residential
dwelling units on Single-family
Residential District lots where
feasible through existing Zoning
Ordinance provisions.
Housing Element Policies: 1.1, 1.8
1.4 Deed Restrictions
Require appropriate deed restric-
tions to ensure continued afforda-
bility for low- or moderate -
income housing constructed or
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
Department, City
Council
Community
Development
Department, City
Council
Community
Development
Department,
Successor Agency,
City Council
Funding
Source
City processing
fees (recoverable)
Tax -Exempt
Mortgage
Revenue
Bonds
2013-2021
Quantified
Objective
The City has updated
its Zoning Code to
allow second units to be
developed within Single
Family zoned
properties without the
need for any
discretionary actions.
During the planning
period, five (5) second
units are anticipated.
All affordable housing
created during the
planning period will be
required to record deed
restriction to ensure
continued affordability
A-14
Units
manufactured homes
were received
Between 2013- and
spring 2021:
15 ADUs were
constructed
4 ADUs are under
construction and
have not yet received
a final
8 ADUs are in the
plan check process
2 ADUs were
withdrawn
2016-2019: 2
affordable
condominium units
for a 60 -year period;
Habitat for Humanity
of Orange County
Results
Effectiveness
Existing mobile home
parks continue to be
maintained.
Positive
On April 4, 2017, the
City Council adopted
Ordinance 1479 related
to accessory dwelling
units (ADUs), formerly
known as second
residential units, in
compliance with new
state regulations.
Positive
Timeframe
Continue/Modify/
Delete
This program will be
included in the 2021-
2029 Housing
Element and future
applications will be
processed as
received in a timely
manner.
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element with
exploration of
additional
programs; future
applications will be
processed as
received in a timely
manner.
On-going
Continue
This program will be
included in the 2021 -
Appendix A
SEPTEMBER 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding Quantified
Agency Source Objective
Units
Results
Effectiveness
Timeframe
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
For affordable units,
Housing Element Policies: 1.1
the City requiring
that the property
projects will
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
densitv bonus units)
1.5 Pre -application
Conferences
Continue to utilize procedures for
pre -application conferences and
City of Tustin
Draft Housing Element
Community City General Continue Positive On-going
Development Fund; City Continued to utilize Continue
Department processing fees pre -application
(recoverable) This program will be
included in the 2021 -
Appendix A
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
Low- and Moderate -Income
Development
Fund; City
Housing
processing fees
(recoverable)
Ensure that processing of permits
for low- and moderate -income
housing are fast -tracked with low -
and moderate -income housing
permits being given priority over
other permit applications.
Housing Element Policies: 1.12
City of Tustin
Draft Housing Element
A-16
Positive
All affordable housing
projects were
recipients of such
streamlined
processin& including
three in the Tustin
Legacy; Amalfi, Anton
projects and Village of
Hope veterans housing
and homeless facility.
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Continue to process
applications in a
timely manner
Appendix A
SEPTEMBER 2022
1.7 Permit Coordination
Community
City General
Continue
Between 2013-2020
Positive
On-going.
Continue the services of the City's
Development
Fund; City
processing fees
1,562 New residential
Continue
Community Development
(recoverable)
projects processed
This program will be
Department as a central
2013: 758
included in the 2021 -
clearinghouse with individuals
2029 Housing
assigned the responsibility of
2014: 46
Element.
expediting development permits
2015: 241
required from various
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
Work with the Regional Center of
Department
website and social
media.
of the Citys website
This program will be
Orange County to implement an
was updated to
included in the 2021 -
outreach program that informs
include affordable
families within the City of
rental opportunities
City of Tustin
Draft Housing Element
WON
Appendix A
SEPTEMBER 2022
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
available for persons with
developmental disabilities.
Housing Element Policies: 1.11,
1.13,1.15
1.9 Housing for the Disabled
Community
State and Federal
Refer individuals to
Development
programs; City's
agencies providing
Require new multi -family
Department
General Fund.
supportive housing that
housing units and apartment
accommodates
conversions to condominiums to
independent living.
comply with State specifications
Add procedures and/or
pursuant to SB 520 for
undertake appropriate
accommodation of the disabled.
amendments to existing
The City will conduct analysis,
standards to ensure
add procedures, and/or
compliance with SB 520.
undertake annronriate
City of Tustin
Draft Housing Element
"M
including a map of all 2029 Housing
affordable rental Element.
opportunities in the
city.
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.
Positive I On-going
Objectives met and Continue
continues. This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
SEPTEMBER 2022
Program
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
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
F.", 6 UJ
Units
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
1.10 Transitional Housing
Encourage the continuation of the
Sheepfold homes and Laurel
House in Tustin, which provide
housing facilities for battered
homeless women and children.
These homes are located in single-
family neighborhoods and
provide a much-needed service
for homeless women and
children. In addition, explore
additional program options to
assist in the provision and
funding for other programs such
as transitional housing and single
room occupancy housing.
Housing Element Policies: 1.11,
1.14
City of Tustin
Draft Housing Element
Various Non -
Profit
Organizations,
Successor Agency,
Community
Development
Department
Variety of
private funds;
CDBG funds
Promote, assist, and
facilitate the
development of
emergency and
transients' shelters
through continued
support of the
County Homeless
Assistance Program
Support local
agencies that provide
homeless services by
providing financial
assistance of
approximately
$5,000410,000
annually.
Consider the
adoption of a Single
Room Occupancy
Ordinance to
facilitate the
development of SRO
units.
A-20
2014: Laurel House
transitional housing
was transferred to the
Orange County
Rescue Mission for
continued assistance
to the homeless,
women, and teens.
2015: The City
conveyed two (2)
four-plexes to the
Orange County
Rescue Mission
(OCRM) in order to
provide transitional
housing to homeless
veterans.
2016: Tustin Veterans
Outpost was
completed in June
2016, with the
capacity to house 26
homeless veterans
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.
Positive
On-going assistance;
during the planning
period, $33,000 of
CDBG funds were
distributed to
organizations that
provide services to
homeless individuals.
Ongoing
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
SEPTEMBER 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible Funding
Agenci Source
2013-2021
Quantified Units
Objective
A-21
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.
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
Program
1.11 Temporary Housing for
Homeless
The City will also support
countywide efforts to assist
approved homeless providers as
part of the MCAS Tustin Reuse
effort.
Housing Element Policies: 1.11,
1.14
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
County of Orange,
Community
Development
Department
2013-2021
Funding Quantified
Source Objective
CDBG funds, Continue to
HUD SHP funds participate on the
Orange County City
Managers/Plannmig
Directors SB 2 Task
Force
Continue to support
192 emergency
housing units to
single men and
women at Tustin
Legacy (Orange
County Rescue
Mission).
The City plans to
assist 200 individuals
by means of
integrating
counseling,
education, job -
training and other
techniques to stop
the cycle of
homelessness.
Continue to support
24 units of
transitional housing
for families
A-22
Units
At Tustin Legacy:
o Construction of a
192 -bed facility at
the Village of
Hope operated by
Orange County
Rescue Mission
completed and
City conveyed the
approximate 5 -acre
property to the OC
Rescue Mission at
no cost.
o Expansion plans of
the existing above -
referenced Village
of Hope facility
capacity from 192
beds to 387 beds,
construction of a
new parking lot,
and establishment
of an ancillary
church use. A
0.57 -acre parcel
was conveyed to
the Orange County
Rescue Mission in
November 2016 to
Results
Effectiveness
Positive
The MCAS Tustin
Specific Plan (now
Tustin Legacy Specific
Plan) provided sites
and designated land
uses to accommodate
the identified homeless
needs.
Timeframe
Continue/Modify/
Delete
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
SEPTEMBER 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
(operated by
Salvation Army)
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,
A-23
Units
construct the
parking lot and
construction is
complete.
o 6 new units at
Tustin Field I to
Salvation Army
provided at no
cost.
o Acquisition
contribution of 16
units in Buena
Park for the
Salvation Army
was completed.
The City assisted
in acquisition and
contributed grant
funds to acquire
the units at no
cost to Salvation
Army.
o 14 new units, in
coordination with
the City of Irvine,
obtained by Tustin
and conveyed to
Irvine Temporary
Housine at the
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible Funding
Agenci Source
2013-2021
Quantified Units
Objective
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)
o 6 new units at
Columbus Grove
to Human Options
at no cost;
complete.
o 6 new units at
Columbus Grove
to Orange Coast
Interfaith Shelter at
no cost; complete.
A-24
o In 2014, the City
Council
authorized the
conveyance of
two (2) fourplexes
to Orange County
Rescue Mission in
order to provide
transitional
housing for
homeless
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible Funding
Agenci Source
2013-2021
Quantified Units
Objective
FWA041
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
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
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
Department;
Municipal
Bonds; Private
available programs on
as needed basis.
No tax-exempt bonds
On-going
financing resources and Low-
Housing
Activity
were issued between
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
This program will be
Planning Commission and the En-
coordination between
included in the 2021-
vironmental Management Agency
the County and the
2029 Housing
(EMA) notice the City of Tustin of
City within the
Element.
any roposed development
City of Tustin
Draft Housing Element
A-26
Appendix A
SEPTEMBER 2022
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
Continue to preserve existing sites
Community
Development
Income Housing
Tax Credits;
risk units at Tustin
Gardens, and
Gardens
The City monitors the
Modify
and identify new sites that are
Department
Private Activity
identification of new
project and its
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
Develop a comprehensive
Recreation
Department
Funds
annually
17,198 of our elderly
population utilized
The City far exceeded
Continue
transportation program, case
the transportation
the objective by
City of Tustin
Draft Housing Element
EWA
Appendix A
SEPTEMBER 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding Quantified
Agency Source Objective
management, information and
referral, and shared housing
program.
Housing Element Policies: 1.15,
2.3
1.17 Recycling Single -Family
Uses in R-3 Zones into
Multiple -Family Units
Continue to encourage developers
to consolidate individual lots into
City of Tustin
Draft Housing Element
Units
system services
provided through the
City.
2013: 1,336 persons
assisted
2014: 1,448 persons
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
Community City General Eight (8) housing units Undeterminable
Development Fund; Staff time are anticipated
Department
M
Results
Effectiveness
assisting an average of
2,150 elderly annually.
See also shared
housing for the
objective results which
too were positive.
Timeframe
Continue/Modify/
Delete
This program will be
included in the 2021-
2029 Housing
Element.
Positive On-going
Continue support of Continue
applications as This program will be
received.
included in the 2021 -
Appendix A
SEPTEMBER 2022
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.
Density bonuses, parking
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
Housing Element Programs
Development
Fund; Staff time
to the Planning
Department
Commission and the
From the date of adoption of the
Element.
City Council annually.
Housing element, prepare an
annual report to the Planning
Commission assessing previous
years' accomplishments toward
meeting Housing Element
objectives. Submit the Annual
Report to the State HCD.
Housing Element Policies: all
policies
City of Tustin
Draft Housing Element
FEW
2029 Housing
Element.
The City submitted
On-going
annual reports to HCD
Continue
on or before the April
1st deadlines.
This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
SEPTEMBER 2022
Program
1.19 Consolidated Plan
The City of Tustin shall prepare
an update of the Consolidated
Plan that provides a comprehen-
sive assessment of housing needs,
a housing development plan
incorporating Federal, State and
local public and private resources,
and a one-year implementation
plan.
Housing Element Policies: 1.12,
1.16,1.18,2.1,4.1, 4.2,4.3,4.4,5.1,
5.2,5.3,5.4,5.5
1.20 Zoning Studies
To facilitate the new construction
goals of the 2012 Regional Housing
Needs Assessment, the City
intends to undertake zoning
studies to consider new programs
to encourage and promote
affordable housing and
recommend appropriate
amendments for actions by the
Planning Commission and the City
Council. These studies include:
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
Community
Development
Department
Successor Agency
and Community
Development
Department
Funding
Source
Variety of local,
State, and
Federal funding;
City General
Fund Staff time
City General
Fund,
2013-2021
Quantified
Objective
Prepare Consolidated
Plan in 2014
Prepare Action Plan
annually
Initiate Zoning Studies
by 2015 and complete
any proposed
amendments by 2021.
A-30
Results
Units Effectiveness
Positive
DCCSP area 140 new
units constructed to
date (all within the
Vintage
Development). Of
note, this development
participated in the in -
lieu fee option
regarding affordable
housing provisions.
All units were market
rate.
The City prepared and
the City Council
adopted the 2015-2020
Consolidated Plan on
April 21, 2015.
The City prepared and
the City Council
adopted, the 2020-2025
Consolidated Plan on
April 21, 2020.
Action Plans continue
to be prepared and
adopted annually.
Positive
In 2018, the Tustin City
Council adopted a new
specific plan document,
the Downtown
Conunercial Core
Specific Plan (DCCSP).
This plan introduced
mixed-use and infused
the potential for 887
units into the area
through a Residential
Allocation Reservation
Timeframe
Continue/Modify/
Delete
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Opportunities will
continue to be
explored relative to
this these and
potentially other
zonine related
Appendix A
SEPTEMBER 2022
Program
(1) Creation of zoning provisions
which will accommodate
mixed uses in portions of the
City, particularly in the Old
Town Commercial Area;
(2) Provide relaxation of certain
development standards and
incentives for projects which
include affordable housing
units particularly housing
units for the extremely -low
income upon City Council's
approval;
Housing Element Policies: 1.1, 1.12
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
FlAwl
Units
Results
Effectiveness
(RAR) review process.
Said plan was an
Orange County
American Planning
Association award
winner.
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
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
Timeframe
Continue/Modify/
Delete
studies.
Appendix A
SEPTEMBER 2022
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.
1.21 Private Streets
The City of Tustin has adopted
standards for private streets in
new residential developments. To
reduce construction costs,
developers may be permitted to
install private rather than public
streets, wherever feasible.
Housing Element Policies: 1.17
City of Tustin
Draft Housing Element
City of Tustin � None necessary
Currently in process,
City staff is working on
citywide ADU design
guidelines with
examples as well as an
ADU zoning update.
A-32
Appendix A
SEPTEMBER 2022
Additionally staff is
working on residential
related mixed-use
parking strategies for
the DCCSP area.
Continue
Positive
On-going
Private street
Continue
standards were
This program will be
implemented in most
included in the 2021 -
Tustin Legacy area
2029 Housing
residential
Element.
developments that
occurred during this
time period.
A-32
Appendix A
SEPTEMBER 2022
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,
The State of California has
Community
Development
determined that the over-riding
Department
value is the protection of the
health and safety of residential
Continue
occupants. Continue to adopt the
California Building Code
adopted the 2013, then
pursuant to the state directives
and where local amendments are
proposed to reflect local climatic,
This program will be
geologic or topographic
conditions, and minimize,
California Building
wherever possible, impacts on
provision of housing.
Housing Element Policies: 5.4
2029 Housing
City of Tustin
Draft Housing Element
City General
On-going
During this reporting
On-going
Fund; Staff time
period, the City
Continue
adopted the 2013, then
2016, and now the 2019
This program will be
California Building
included in the 2021 -
Codes.
2029 Housing
Element.
A-33
Appendix A
SEPTEMBER 2022
1.23 Site Improvements
Community
Developer
Evaluate the use of
Positive
On-going.
The requirement for the developer
Development
Department,
funded
special assessment
district funding at
Assessments were
Continue
to construct site improvements
Tustin Legacy and its
issued for a
This program will be
often results in passing these costs
use in other developing
Community Facilities
included in the 2021 -
on the housing consumer. These
areas.
District Annexation
2029 Housing
costs are reflected in the cost of
Area at Tustin Legacy
Element.
housing that eliminates an even
in 2014 (CFD 14-01) for
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 for a new
facility district on a per parcel
Community Facilities
benefit basis may enable a greater
District 2018-1
proportion of the market to
Improvement Area 1
qualify for housing. Assessment
(CFD 18-01 IA 1) at
district financing has been
Tustin Legacy in 2018
implemented in the East Tustin
for the Lermar Homes
and Tustin Legacy areas and is
of Southern California
being used to pay for public
(formerly CalAtlantic
improvements. The City will
Homes) development
assess opportunities to continue to
of 218 townhomes,
utilize these public improvement
flats, and single-family
financing techniques in newly
homes and for
developing areas such as Tustin
Brookfield Homes of
Legacy and determine whether
Southern California, a
they are financially feasible. In
future development of
creating any new assessment
400 townhomes, flats,
districts, an evaluation should be
and single-family
completed of the developer's
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
Legacy, the City will
City of Tustin
Draft Housing Element
FEW
Appendix A
SEPTEMBER 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
A-35
Units
Results
Effectiveness
continue to evaluate
financing mechanisms
to fund infrastructure
improvements.
Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding
Agency Source
1.24 Fees, Exactions, and Community
Permit Procedures Development
Consider waiving or modifying Department,
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.
Housing Element Policies: 1.12
City of Tustin
Draft Housing Element
City General
Fund;
Quantified
Objective
Defer development
impact fees during
economic downturns.
A-36
Results
Units Effectiveness
Neutral
Adoption of a new
policy has been
evaluated and
considered on an
annual basis. No
changes to date
though continually
being monitored and
considered.
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.
Timeframe
Continue/Modify/
Delete
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
SEPTEMBER 2022
1.25 Environmental
Community
General Fund;
On-going
Effective
On-going
Constraints
Development
Private
During the Housing
Continue
Continue to alleviate the necessity
Department,
developer cost
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
2029 Housing
into the development plans by re-
Specific Plan included
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 E1R 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 a large
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
Department
density bonuses.
In 2015, two apartment
Continue
facilitate the construction of
developments that
This program will be
affordable housing. Under State
were granted density
included in the 2021 -
City of Tustin
Draft Housing Element
A-37
Appendix A
SEPTEMBER 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding Quantified Units
Agency Source Objective I
Results
Effectiveness
Timeframe
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
Implementation
Implementation of the Specific
Plan for MCAS -Tustin site
Housing Element Policies: 1.1, 1.3,
1.5
City of Tustin
Draft Housing Element
Successor Agency General Fund Process entitlements for See Program 1.1
MCAS Tustir
no
Positive On-going
Achieved Continue
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
SEPTEMBER 2022
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
Department,
400 Tustin residents
annually, 3,000
Fair Housing
Continue
housing counseling services to
City's contractor
residents by 2021.
Foundation estimated
This program will be
assure equal housing
that the number of
included in the 2021 -
opportunities within the City.
Tustin residents
2029 Housing
The City allocates approximately
provided with direct
Element
$15,000 annually for handling
client assistance
tenant/landlord disputes,
during this planning
housing discrimination cases,
period was 1,333.
counseling, tenant rights, fair
Yearly educational and
housing education, and education
outreach activities
within the City. The City will
occurred including
continue to promote the fair
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
Continue to provide coordination
Recreation
Services
The City provided
Continue
and support to a home sharing
coordination and
City of Tustin
Draft Housing Element
A-39
Appendix A
SEPTEMBER 2022
Program
program funded in part by the
Community SeniorServ, formerly
known as Feedback Foundation,
Inc., as part of TLC
(Transportation Lunch and
Counseling) and the Orange
County Housing Authority.
Housing Element Policies: 2.3
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agency Source Objective
Department, and
Community
Development
Department
FWAX1111
Results
Units Effectiveness
support through the
referenced program
and providers. In
2020, the Community
SeniorSery (formerly
known as Feedback
Foundation) changed
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 pandernic
had an effect on this
program and the
ability to service
seniors at the facility.
See also Senior
Services Program.
Timeframe
Continue/Modify/
Delete
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
SEPTEMBER 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
WAVE I I
Units
Results
Effectiveness
For senior housing
requests, seniors are
referred to the Office
on Aging Orange
County, which
provides resources for
senior housing and
case management.
Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
2.3 Housing Referral Program
Police
City General
* 7,500 referrals to
Effective
On-going
Continue to provide housing
Department;
Fund, CDBG
Funds
social agencies by
The Economic
Continue
referral services to families in
Parks and
2021
Development
This program will be
need of housing assistance and
Recreation
* 50 referrals for
Department and
included in the 2021 -
information. This program
Department;
shared housing by
Tustin Housing
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
homeless people to different
To assist referrals, the
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
Draft Housing Element
A-42
Appendix A
SEPTEMBER 2022
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 Citizens
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 Progaml.18
Element Programs
Consolidated Plan
See Program 1.19
Goal 3: Ownership
Housing
City of Tustin
Draft Housing Element
A-43
Appendix A
SEPTEMBER 2022
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
Modify - The
The Housing Authority applies
eliminated low- and
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
made it more difficult
MCC and continue
State and Federal 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 Programl.13
City of Tustin
Draft Housing Element
E W, fle
Appendix A
SEPTEMBER 2022
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 Programl.18
Element Programs
Consolidated Plan
See Programl.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
Authority,
Continue
Housing Authority, where
This program will be
necessary, for the development
included in the 2021 -
and operation of federally assisted
2029 Housing
low- and moderate -income
Element
housing programs.
Housing Element Policies: 1.3,1.7,
1.14
City of Tustin
Draft Housing Element
A-45
Appendix A
SEPTEMBER 2022
4.2 Rental Assistance
County of Orange
HUD
Issue 200
Effective
On-going
Encourage the availability of
Housing
Authority
certificates/ vouchers
annually- 1,600 by 2021.
The Orange County
Continue
Section 8 rental assistance
Housing Authority
This program will be
certificates and voucher certificate
issued the following
mcluded in the 2021 -
program assistance funds through
annual voucher counts
2029 Housing
the Orange County Housing
for Tustin residents:
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 be
To maintain 74 units of affordable
included in the 2021 -
housing for Seniors located at
2029 Housing
17432-17442 Mitchell Avenue (20
Element
City of Tustin
Draft Housing Element
A-46
Appendix A
SEPTEMBER 2022
Program
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
Housing
Tustin has four (4) low-income
housing project with a total of 517
units "at -risk" of conversion to
market rate during the planning
period. If project owners choose
to convert the projects to market
rate housing, the City will
coordinate the provision of
financial and administrative
resources to preserve these units
as affordable housing.
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
Community
Development
Department,
Housing
Authority
Housing
Authority
working with a
non-profit
affordable
housing developer
a) Monitor Units at Risk:
Maintain contact with owners
of at -risk units as potential
conversion dates approach to
Community
determine whether Section 8
Development
contracts or affordability
Department,
covenants have been renewed
Housing
or are planned to be renewed.
Authority
Discuss with the owner of the
City of Tustin
Draft Housing Element
Funding
Source
State and Federal
Funds
4% Tax Credit
and Bond
Financing, other
funding sources
State grants and
HUD funds
2013-2021
Quantified
Objective
Pursuant to
Government Code
Section 65583.1 (c),
preserve at minimum
100units currently
identified as "at- risk"
at Tustin Gardens for
the time frames
required by applicable
Government Code
Section
65583.1.(c)(2)(C)(i) or
Health and Safety Code
section
Preserve 100 units at
Tustin Gardens
FEW I YA
Units
The 100 at -risk units
(Tustin Gardens)
were maintained.
Also, despite the
elimination of a major
funding source, the
Housing Authority
was also able to
preserve a total of
two low- income
units and one very
low-income unit in
foreclosure by
purchasing them and
selling them to other
families.
Results
Effectiveness
Effective
The City maintains
contact with Tustin
Gardens and has been
monitoring their
annual renewal option.
Annual Monitoring:
The Housing
Authority annually
mails letters to
homeowners
requesting
documentation
verifying continuing
compliance with the
affordability covenants
they entered into with
the City when they
purchased their
affordable unit.
Timeframe
Continue/Modify/
Delete
On-going and
modify as additional
housing projects will
fall within this
program category
over the next
planning period
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
SEPTEMBER 2022
Program
I at -risk" projects the City's
desire to preserve the units as
affordable.
b) Work with a nonprofit
affordable housing developer
to apply for 4% Tax
Credit/ Bond Financing for the
acquisition and rehabilitation
of Tustin Gardens, preserving
100 at -risk units.
c) Tenant Education. Work with
tenants of at -risk units in
danger of converting. Provide
tenants with information
regarding potential tenant
purchase of buildings
including written information
and any related workshops.
Act as a liaison between
tenants and nonprofits
potentially involved in
constructing or acquiring
replacement housing. If
existing staff is not able to
provide adequate staffing for
this program, provide outside
consultants to support the
program.
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
WIT100
Units
Results
Effectiveness
Affordable Units at
Risk of Foreclosure:
The Successor Agency,
now Housing
Authority, prepared
monthly foreclosure
reports to all City
operating departments
in order to monitor
and keep City
sensitive to the
implications on
property conditions
and blight as a result
of the foreclosure
activity associated
with periods of
economic downturn in
the residential and
commercial markets,
The Housing
Authority (created in
2011) was created by
the City Council to
assist the City in
increasing, improving
and preserving its
supply of affordable
housing.
Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
Program
d) Reserve Fund. Continue to
monitor other potential
funding sources, such as State
grants and HUD funds.
Housing Element Policies: 4.1, 4.2,
4.3,4.4
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
FWAIWVJ
Units
Results
Effectiveness
In 2014, as a result of
increased foreclosure
activity, the City
Council approved an
Affordable Housing
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
Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding Quantified
Agency Source Objective
4.5 Temporary Housing
Housing
HUD Section 8
Promote, assist, and
Assistance for Extremely Low-
Authority and
Program, CDBG
facilitate programs to
Income Households
Community
prevent extremely low -
Assist in the provision of
Development
income households to
temporary and emergency
Department
become homeless by
housing assistance to prevent
providing links and
homelessness for the extremely
program information on
low-income households as well as
City's website and at
coordination with regional, state
the Tustin Library,
and federal assistance programs
Senior Center, and
for assisting these households in
City of Tustin
Draft Housing Element
Wme"111
Results
Units Effectiveness
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.
Effective
In accordance with
AB 987, the Housing
Authority maintains
a list on the City's
website of all
affordable ownership
units and affordable
rental units in the
City of Tustin. In
addition. links to
Timeframe
Continue/Modify/
Delete
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
SEPTEMBER 2022
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
residential units in target areas
resources
(2) four-plexes by
This program will be
conveying 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
Draft Housing Element
A-51
Appendix A
SEPTEMBER 2022
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
Continue to enforce building and
Department
cases annually and
240cases by 2021.
are not kept by the
This program will be
housing codes to ensure health
City, the City's Code
Included in the 2021 -
and safety, rectify Code violations
Enforcement Staff
2029 Housing
and thereby improve the overall
estimated that over
Element
character of the community.
2,300 property
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
are generally received
owner to allow City to recover
by Code Enforcement
enforcement cost.
are very minor
City of Tustin
Draft Housing Element
A-52
Appendix A
SEPTEMBER 2022
Program
Housing Element Policies: 5.3, 5.4
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
A-53
Units
Results
Effectiveness
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.
Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
5.2 Cultural Resources
Community
CDBG, City
Rate historic structures
Effective
On-going
District
Development
General Fund,
where applicable and
Process Certificates of
Continue
There are a large number of struc-
Department
State grants
process certificates of
Appropriateness as
tures in the City that were
appropriateness as
received.
received.
This program will be
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-
improvements to
guard the heritage of the City by
properties located
preserving neighborhoods and
within the Cultural
structures that reflect the City's
Resources District by
heritage and past. Through the
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
Draft Housing Element
FEW
Appendix A
SEPTEMBER 2022
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
Require all new construction to be
Development
Department
within planning period.
In force. See Program
Continue
subject to State energy conserva-
1.7, Permit
This program will be
tion requirements (Title 24) as a
Coordination, for
included in the 2021 -
condition for the issuance of a
statistics.
2029 Housing
building permit.
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
California HERO
2029 Housing
may be explored. Examples
Program to finance
Element
include installation of
distributed generation
photovoltaic systems, tank -less
renewable energy
City of Tustin
Draft Housing Element
A-55
Appendix A
SEPTEMBER 2022
Program
water heater, natural gas recharge
connection, electric vehicle
recharge connection, wind power
generator, etc.
Housing Element Policies: 6.6
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
A-56
Units
Results
Effectiveness
sources, energy and
water efficiency
improvements and
electric vehicle charging
infrastructure.
Availability of grants
Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
6.3 Solar Energy and
Conservation
Require that environmental
analysis and subdivision plans
address energy conservation
measures and solar access. With
the passage of AB 32, the City in
anticipation with the State
mandates will set thresholds
within its CEQA checklist and
require developers to address
energy conservation measures
applicable to their proposed
development proposals.
Housing Element Policies: 6.2,63
City of Tustin
Draft Housing Element
Community None necessary On-going
Development
Department
NAVIN
Effective
CEQA checklist
updated to include
greenhouse gas
emissions.
Supported solar panels
installation in
residential and
commercial buildings.
During the planning
period, the City issued
the following number
of residential and non-
residential solar panel
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
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
SEPTEMBER 2022
Program
6.4 Building Orientation
Promote energy efficiency by
orienting homes to maximize
natural day lighting. The City
will work with potential
developers during the conceptual
review level (Design Review) by
promoting building siting that
maximizes natural day lighting.
Housing Element Policies: 6.2, 6.3
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified Units
Agenci Source Objective
Results
Effectiveness
industrial property
owners for water
conservation and
energy efficiency
improvements.
Timeframe
Continue/Modify/
Delete
Community None necessary On-going Effective On-going
Development On-going Continue/Modify
Department
This program will be
included in the 2021-
2029 Housing
Element
Wme"s]
Appendix A
SEPTEMBER 2022
6.5 Water Efficiency
Promote water -efficient
landscapes, efficient irrigation,
and use of permeable paving
materials. Through educational
materials and trainings, the City
will promote water efficiency
methods to its residents.
Landscape beautification which
results in water conservation
could be encouraged through
planting of drought tolerant
plants, installation of drip
irrigation, installation of rain
detector/sensor irrigation, etc.
Incentives such as over the
counter permit plan check,
discounted fee, or waiver of
pern-dt fee could be considered.
Housing Element Policies: 6.4
City of Tustin
Draft Housing Element
Community None necessary
Development
Department
Promote water efficient
programs by
conducting workshops
and providing
education materials on
the City Website, public
counter and at schools.
A-59
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 also 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 Browr�s
Executive Order. An
annual report
summarizing activities
between January 1st
and December 31st of
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
SEPTEMBER 2022
City of Tustin
Draft Housing Element
ME
Appendix A
SEPTEMBER 2022
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
Draft Housing Element
ME
Appendix A
SEPTEMBER 2022
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
Streamline processing for
Development
Department
green building and
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
Draft Housing Element
EVIN
Appendix A
SEPTEMBER 2022
TABLE A-3
PROGRESS TOWARDS OBJECTIVES 2013-2021
CITY OF TUSTIN
I Quantified I Extremely Very
Unit Type/Description I Objectives I 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
Undefined
Undeterminable
Units (Tustin Legacy)
Neighborhood D
1,048
533
37
496
Neighborhood G
1,247
818
88
73
64
593
Units Approved/Under
12 ADU's
Construction (2020
Undefined
(undefined income)
Annual Progre s Report))
Undefined
Undeterminable
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 MID
8
Undeterminable
in R-3 district
Subtotal
3,000
514
303
348
1,835
RHNA
1 1,2271
1
283
1951
2241
525
Difference
1 1,7731
1
231
1081
1241
1,310
1,534
(includes 1,522 ur-dts +
12 ADLYs approved
and under
ACTUAL TOTAL UNITS
RHNA
Required
construction)
19-1
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
CITY OF TUSTIN
GENERALPLAN
A-62
APPENDIX A
HOUSING ELEMENT
SEPTEMBER 2022
TABLE A-3
PROGRESS TOWARDS OBJECTIVES 2013-2021
CITY OF TUSTIN
PRESERVATION
Tustin Gardens 1 -100 1001 loo
Total Preservation 1 100 1001 too
OTHER FOCUSED
AFFORDABLE
HOUSING PROGRAMS
Homeless Assistance &
Quantified
A variety of support
Extremely
Very
Unit Type/Description
Objectives
Accomplishments I
Low
Low
Low
Moderate
Upper
Tustin Legacy New
Of Note - 5,3U7
8
Construction Inclusionary
452
residential additions
Total Rehabilitation
Undefined
and alterations
Other Admirdstrative
realized during the
Support (Housing
planning period
PRESERVATION
Tustin Gardens 1 -100 1001 loo
Total Preservation 1 100 1001 too
OTHER FOCUSED
AFFORDABLE
HOUSING PROGRAMS
Homeless Assistance &
Variety of
A variety of support
Supportive Services
Programs -
Undefined
services provided
Tustin Legacy New
Construction Inclusionary
452
230
Housing Requirement
Other Admirdstrative
Support (Housing
Authority; Density
Variety of
Bonus'; Affordable
Programs -
A variety of support
Housing Assistance
Undefined
services provided
Programs (associated
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)
CITY OF TUSTIN
GENERALPLAN
A-63
APPENDIX A
HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
APPENDIX B
SITES INVENTORY
B-1
HOUSING ELEMENT
SEPTEMBER 2022
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
Income Group
RHNA
Units
Approved
ADUs
Permitted
Net RHNA
Need
Very Low
862
6
1
855
Extremely Lowl
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.
AD UsIJAD Us - 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
corranunity to accomrnodate 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 manner. 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 - (RHA5P) 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 (Demy'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 Cen Uer
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 improvernent-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 Plan's 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 - (DCCSL?) 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 BanWs 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 comer 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
Fnd.er7p Cpnfpr
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
Property
TLSP -
Neighborhood D
North (includes
Specific Plan
Vacant
296
555
230
66
72
187
amendment) (Site
1A)
TLSP -
Neighborhood D -
South (includes
Specific Plan
Vacant
532
1,396
314
218
244
620
amendment) (Site
1B) (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
Property
3 Non -
Vacant
Site 3 (Approved
Vacantl
Entitlements)
Non-
Vacant-
Approved
6
137
6
0
0
131
Housing
Project
Site 4
Non -vacant
0
226
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
Property
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
Place
Non -vacant
0
900
225
141
150
384
Projected ADU &
35
9
6
6
14
JADUs
Entitled Units
(Transitional
Vacant -
Approved
Homes) - 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.
Zon "n
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
Zoning
Site Size
(Acres)
Lot
Consolidation
Potential
Availa le
Infrastructure
Tust'n Legacy Specific P an Area
1
Vacant,
Yes*
Varies
Yes
Planned as
Neighborhood
part of
D North and
Master
South.
Planned
CITY OF TUSTIN
GENERAL PLAN
M. me
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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
Red Hill Avenue Specifi 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. Shoppin
Center)
Downtown Commercial Core Specific P an 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
Apartm nts
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
GENERAL PLAN
1:B
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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 1-5
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
Zoning
Site Size
(Acres)
Lot
Consolidation
Potential
Available
Infrastructure
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 Capaci!y
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 Development 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-fan-dly
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 Ana2
MEMU Overlay Zone Recent
-
45-90
Developments
Sources:
'City of Irvine Second Draft 2021-2029 Cycle Housing Element Update, November 19, 2021
2City 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):
0 The TLSP area is anticipated to provide capacity of
o 555 units over approximately 40 acres in Neighborhood D North (40
du/ac minimum);
o 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).' 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:
• 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.
• 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 envirom-nental 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
GENERAL PLAN
B-22
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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.
0 The RHASP area is anticipated to provide capacity of
o 395 units over approximately 10 acres north of 1-5 (40 du/ac) and
o 105 units over approximately 6 acres south of 1-5 (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.
0 The DCCSP area is anticipated to provide capacity of
* 45 units over approximately 1 acre in DA1 (41 du/ac minimum);
* 92 units over approximately 2 acres in DA2 (48 du/ac minimum);
* 200 units over approximately 17 acres in DA3 (12 du/ac minimum);
* 150 units over approximately 4 acres in DA4 (38 du/ac minimum);
and
* 260 units over approximately 11 acres in DA6 (27 du/ac minimum).
* 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.
0 Enderle Center and Tustin Market Place
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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.
C"'Onprnl
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. h -i
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 Preferen
The COVID-19 Pandernic 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
GENERAL PLAN
B-26
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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
Proposed Zone:
Allow mixed-use development with
minimum 30/du acre (Refer to Program
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
During Planning Period:
Rezone properties to allow mixed-use,
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 1-5 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
GENERAL PLAN
B-28
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
TABLE B-5
The Market Place
Existing Zone:
PCMU - SP 8 (East Tustin Specific Plan)
Proposed Zone:
Allow mixed-use development with
minimum 30/du acre (Refer to Program
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
During Planning Period:
Rezone properties to allow mixed-use,
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
GENERAL PLAN
B-30
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
ATTACHMENTS
ASSOCIATED WITH APPENDIX B
SITE INVENTORY ASSESSMENT
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-31 SEPTEMBER 2022
Attachment B-1
Sites 1dentification to Meet RHNA*
Site
#
Site Reference
Vacant or
Non-
Vacant
Identified in
Previous 4 th
&/Or 5 1h
Cycles / Was
Counted
Towards
RHNA
Site
Size
(Acres)
APNs
Ownership
Zoning
General
Plan
Capacity
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
1B
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
GENERAL PLAN
B-32
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-33 SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
Vacant
Counted
(Acres)
Towards
RHNA
2
Neighborhood G PA 15
Vacant
Yes(both)/
50.321
City of Tustin
SID I
TLSP
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 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 (5" only)
LLC, a Delaware
Not for RHNA
Limited Liability
Company
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-33 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
111111011
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
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 El 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
GENERAL PLAN
111111011
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-35 SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
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 Area 2 92 units
8
Bel Air M tor Hotel at 140 W. First
Non-
No/No
1.0
401-571-14
GLIVI Ventures LLC
SP 12
DCCSP
Street
Vacant
DA -2
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-35 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
111M
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
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 El
Vacant
DA -2
Camino Real
150 E. First Street (Tustin War Mem)
0.43
401-583-01
City of Tustin
105 El 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 11 Larwin Sq SC
13421 Newport Avenue Tustin
0.32
401-601-05
PK 11 Larwin Sq. SC
13451 Newport Avenue
0.38
401-601-06
PK 11 Lawrin Sq. SC
13471 Newport Avenue
0.39
401-601-07
PK 11 Larwin
550 E First St
1.00
401-601-08
Haggen Property
South LLC
CITY OF TUSTIN
GENERAL PLAN
111M
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-37 SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
General
Capacity
#
Plan
Vacant
Counted
(Acres)
Towards
RHNA
275 Centennial Way
0.46
401-601-09
PK 11 Larwin Square
662 E First Street
0.91
401-601-10
PK 11 Larwin Square
Development Area 4 150 units
11
Farmer's Market Related Properties
Vacant
Yes(both)/
1.02
SP 12
DCCSP
at 225-255 El 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 El Camino Real
0.17
401-584-06
Mary M. Prescott
245 El Camino Real
0.17
401-584-07
Mary M. Prescott
235 El Camino Real
0.17
401-584-08
Mary M. Prescott
225 El Camino Real
0.17
401-584-09
Mary M. Prescott
12
NEC of El Camino Real & Sixth Street
Vacant
Yes(both)/
2.29
SP 12
DCCSP
at generally 542 El Camino Real
No
DA -4
520 El 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. 6 1h 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
Pacific
SP 12
DCCSP
Arvida Book Store, previously Mrs.
Maintenance &
DA -4
B's)
Repair Inc.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-37 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
1XIM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
Vacant
Counted
(Acres)
Towards
RHNA
14
420 El Camino Real
Vacant
No/No
0.44
401-622-18
Radon Davor
SP 12
DCCSP
I
DA -4
Development Area 6 260 units
15
Vacant Lot Adjacent to 1-5 Freeway
Vacant
Yes (5" cycle)
2.73
SP 12
DCCSP
& east of Jack in the Box Restaurant
/No
DA -6
at 14042 Newport & El 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
El Camino Plaza at SWC of El Camino
Non-
No/No
7.81
SP 12
DCCSP
Real & 6 th Street
Vacant
DA -6
620 El Camino Real
3.5
401-631-01
ECP Investors LLC
634 El 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 17 th St, 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
GENERAL PLAN
1XIM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Note: Unit capacity incorporates anticipated TLSP rezone (Neighborhood D — North)
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-39 SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
Vacant
Counted
(Acres)
Towards
RHNA
18
The Market Place, near Interstate -5
Non-
No/No
76.93
500-291-25
Tustin Market
SP 8
PCC13
900
and Jamboree Rd, near the City of
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 El Camino Real
(Entitled,
No
Plan
check and
permits
currently
underway)
Other
ADUs&JDUs
Non-
No/No
NA
NA
NA
Varies
Varies
35
Vacant
I
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 13-1A
Sites Identification to Meet RHNA - Realistic Capacity Estimates
CITY OF TUSTIN
GENERAL PLAN
B-40
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Site
Density (Gross Land Area)
REALISTIC CAPACITY
Density (Net Land Area)*
# 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
113
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
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
GENERAL PLAN
B-40
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
/
Suitable Sites for Additional o
Residential Development
I##, do
I _j
LK
40
Suitable Site Locations
Downtown Commercial Core Specift Plan
Red Hill Avenue Specific Plan
Tustin Legacy Specific Plan
Enderle Center
Tustin Marketplace
Municipal Boundaries
N
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
1 -4,
H, "Ph
2021-2029
Housing rjemwnt
FF Site 1A
TLSP NEIGHBORHOOD D NORTH C
Area does not have residential
SpdAc: Pl— 8—d.ry
Site 2
TLSP NEIGHBORHOOD G
2,029 remaining units in this area
Amend TLSP to accommodate a
minimum of 200 additional housing
units to meet RHNA
50.321 acres (VACANT)
units planned
Amend TLSP to accommodate D North
a minimum of 555 additional
units to meet RHNA
39.873 acres (VACANT)
D SITE 113
South TLSP NEIGHBORHOOD D SOUTH
1,296 remaining units in this area (includes 400
-field)
approved units — Brook
Amend TLSP to accommodate a minimum of 100
additional housing units to meet RHNA
45 acres (VACANT)
T--wo ..MOW
The sites in TLSP are vacant. Development is under the control of the City since the City owns the land.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN SEPTEMBER 2022
B-42
SITE IA: NEIGHBORHOOD D North (Rezone)
39.873 A.rres Zoning: SP 1
General Plan. TLSP 555 Units
Address
APN
Acre
Tutal
Acreage
Tu5tin
Legacy
Specific
430-381-38,
0-002
Plan
39.873
North
430-381-41
2.466
430-381-91
1,235
1
1430-381-95,
36.17
Sou rce: Ora nge Cou r ty Asse-5�o r Parc e�
Map
Awl w mvaow
m
.0,
WA! X VU A M 5k.' Z
Awm mhff-�
oo-38
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-43 SEPTEMBER 2022
Site 113 NEIGHBORHOOD D SOUTH
* 45 Acres 1396 Units
* Zoning: SP 1 General Plan: TLSP
Includes 13fookfield Development (400 units)
,208 Future Units— Multiple Family
Address
is
South
Brookfield
Tract
18197
APN Acre
Total
Acreage
44�86
Lot 2 -S-289
Lot 5 2.778
Lot 6 2-639
Lot 7 2.572
Lot 8 4.012
Lot 9 3.984
Lot 10 4.163
Lot 11 7.039
Lot 12 6.934
Lot 13 5.451
Source: Orange County Assessor Map
CITY OF TUSTIN
GENERAL PLAN
B-44
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
NEIGHBORHOOD G
Addres
APN
Acre
Tota I
s
Acreage
430-3al-
Ne4hbor
27
0�665
430-381-
hoW ri
3.573
1.559
"28
430-381-
29
1 QAQ
1.
Sou rm Ora nge Cou nty Assesso r Pa rcel M a p ""
Ow - Ast""'I KOO a 4m
NPM AMEN mm 4" rw 31
W. & CrAVI ow" 0 A&W
op -38
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-45 SEPTEMBER 2022
Continued
IPAR
NEIGHBORHOOD
G
AW M W=71
fw Sot.
oo,-39
Address
APN
Acre
Total
Acreag
TJV
430-3�1-
03
430-391-
27
4.946
CA 20
430-39L-
29
9.096
45
p
430-391-
56
3.396
46.748
4aO-agl-
Heighborho
59
0.107
%I
AmW
od G
430-391-
w
430-391-
fil
5
430-391-
62
3316
iww
4aO-891-
(D
— .--
61
7.212
IV
64
1 3.536
Pa rce 1
fW6
44
lw�'s &� a
Sou rm 0 ra
nge Cou nty Assessor
Map
47
F%Ka MAGEW ON 4M WE 10
A"- 0 COW$ MWF Of MAW
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN SEPTEMBER 2022
B-46
Tustin
2021-2029
H�Sirkg llem�d
RED HILL
AVENUE
SPECIFIC PLAN
AREA
Attachment B-2
Red Hill Avenue Specific Plan
Site Aerials / Individual Site APN Maps
Site 3
13751 - 13 941 RED HILL AVENUE
(2 Parcels) Entitled Project in 2021
137 housing units ap,proved
3.37 acres
IF -
71
AP
Ske 6'
14081— 14231 RED HILL AVENUE
Shopping Center— 1105 housing units
5.95 acres
CITY OF TUSTIN
GENERAL PLAN B-47
Site 4
1382 2 — 1385 2 RE D H I LL AVENU E
Red Hill Plaza - 226 housing units
A�Cres
5" 5
71 E L CAMi NO REAL — 32 housing units
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
FUM
SITE 3: 13751 - 13841 RED
17 ��
HILL AVENUE
J2 Parcels) Pen�ding Project
3.37 Acres Zoning: SP 13
General Plan: RHASP
Address
APN
Acre
Total
Acreage
13751 Red
Hill
500-141-
WADI fW ILIC r -m
ffiff AlOwl OLM, A 1111�15 w
Averlue
09
0.46
3.37
13841 Red
Hill
500 -141 -
Avenue
10
2.91
Source: RealQuest
CITY OF TUSTIN
GENERAL PLAN
L77-a;,�
W.. rim
40
so -14
B-48
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
WADI fW ILIC r -m
ffiff AlOwl OLM, A 1111�15 w
L M-Fl.m
xr. mr-m '. a �rl
RUM murps
Pm W CIMES ft w =AW,
B-48
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 4: 13822 - 13852 RED HILL
AVENUE
Red Hill Plaza
7.08 Acres - RHASP Zoning: SP 13 General Plan;
Address APN
Acre
Total -M
Acreage
13822 Red 500-022-
HillAvenue 12
4.9
7.08
No Address
500-022-
Listed
09
0,28
13852 Red
MO-022-
lHill enuel
04
1 1.9
1
Source: RealCLuest
CITY OF TUSTIN
GENERAL PLAN
LLJ L
7
0
, 05 J
wom Wf W.W as ma r�
rv4V 4 w ILA I" -WL -Ahll am
ft" -9 mp p a 4-1% 313-f iv M,,Wu
DRAFT HOUSING ELEMENT
B-49 SEPTEMBER 2022
SITE 5: 1571 EL CAMINO REAL
Denny's Restaurant
D.90 Acres Zoning: SP 13 General Plan
RHASP
APN Acre Total
Acre
age
1571 El 500-022-02 a9 J.9
Larn no Real
Sourm RealQuest
14
8
SWO2
mo W) arm m AA J -m WY - h OW S 6, k, —r,5w 5.:
pwr a xf ILA V-6 wy; ex. 5w
PAZ w At 4F-PJ6 J64 — -1 01z,f: � �m E]
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN SEPTEMBER 2022
B-50
SITE6; 140AI— 14231 RED HILL AVENUE
5,towill"Alwm sh.ppingConte,
5,9S A�s Zvninjg, SP I a -C;on*ral Plan: RHAW
Addresses
APN
ACRES
Total Acreage
14081 Red Hill
432-041-04
0.53
Avenue
14231 Red Hill
412-041-14
0,33
Avenuo
5.95
14131 Recl Hill
432-041-17
0.115
Avenue
14171 Red HIM
432-042-19
0.83
Avenue
14171 Red Hill
432-041-20
2.60
Avenue
14213 Recl Hill
432-04 -21
1150
Avenue
WCONO:
R�Iqwsl Wap
QCPW Wp�
05
L
7
a,
It
thrim to. ALW. �-m a Aft W-UM'f &M A AfSESSMI W
FWAO. r 1. A. 44 PA94a PIPWJM mm 4R � 00
mCr AM Wr AV. 2M-,'[ � M WMAX4 —,,,Y duw
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-51 SEPTEMBER 2022
Tustin
2021 2029
Housing rjenwnt
Attachment B-2
Downtown Commercial Core Specific Plan
Site Aerials / Individual Site APN Maps
SITE 7
365 W. FIRST ST. & VACANT LAND ADJACENTTO
VIENTO APTS. -45 unfts
SITES
-.I:
4
SITE 9
15G E. FIRST STREET & 105 EL CAMINO
TUSTIN WAR MEMORIAL AND
WIENERSCHNITZEL
0.88 ACRES
SITE
-W
DOWNTOWN
4
711 ;�i
COMMERCIAL CORE 7,
carricir pi A ADCA
CITY OF TUSTIN
GENERAL PLAN
MWE
SITE 8
140 W. FIRST STREET
BEL AIR MOTOR HOTEL - I ACRE
L
SITE
Sites 8 & 9 — 92
I
I
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 7: 3 65 W., F I RST 51 &
VACANT LAND ADJACENT TO
VILLA VIENTO APARTMENTS
Approx.l.lAcres Zoning.SP12
General Plan: DCCSP
Address
AM
Acre
Total
Acreage
165 W FIrst
401-523-1.0
0.6
L ------ 9L ------
St
1.1
Vacant
401-52�45
0.5
Frontag.eof
portion)
Apartments
Source: CitV GIS
L . I -L
Z— '\ -(�pw m
.iw,; mw AiwAr
ws ov lofor , 5_ .,I
Ae? 14. �i. " ",J�
WA -M 191f lw,r LA M-1
L
Er A
AWL jw &A 411
—0
L ------ 9L ------
6) 1
1 n. ax jit r.
L . I -L
Z— '\ -(�pw m
.iw,; mw AiwAr
ws ov lofor , 5_ .,I
Ae? 14. �i. " ",J�
WA -M 191f lw,r LA M-1
L
Er A
AWL jw &A 411
far
cAlf, tft� ff dha L]
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-53 SEPTEMBER 2022
—0
L
far
cAlf, tft� ff dha L]
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-53 SEPTEMBER 2022
SITE 8: 140 W. F1 RST STR E ET
Bel Air Motor iHotel
I Acre Zoning: SP 12 Gem�ral Plan: DCCSP
Address APN � Acre Total.
Acreag
140 401 -
West 571-14 1 acre 1 acre
First
Street
Source: RealQUe5t
CITY OF TUSTIN
GENERAL PLAN
B-54
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
(D
NX 7
t
7
0,
LA f -J? �g:w�w
pff AvA WTI UFM iw Np � w
W. . elw"$ =-21 M.1
[7
B-54
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 9: 150 E. FIRST STREET &
105 EL CAMINO REAL
Tustin War Memorial and Wiene rsch nitzel
0.88 Acres Zoning: SP 12 Generai
Plan: DCCSP
Address
APN Acre
Total
Acreage
150 E- First
401-583-4DI 0.43
strept
0.8-a
twr
105 El
401-58S-15 0.45
Camino Real
�
Source: RealQuest
a-59
dAH-7Z Wh.7T 6
9--" Ep dw, w I I *I; -
FW mtr±
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-55 SEPTEMBER 2022
twr
OV, A
Q
a
42
1 -
Corr
L
t Amer
7
—L
ID
(D
@
0
q)
I
d
W A
Pa
0
a
FY
L
V4
-1
r
wM IM rff-ry c r ri
J..L 1-w
Arf - AMIAN-4 &dn I AWSWS W
W a I
AN_ 9-4
N=4 wmlw� 4%* 0 ftd 4
W C w
At 21 -?5
AM m C."Uff, rmf,z WAW
W4 jMr
Kme.W.V ro Iii w
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-55 SEPTEMBER 2022
Tustin
2021-2029
Housing rjem
DOWNTOWN
COMMERCIAL
CORE
SPECIFIC
PLAN AREA
CITY OF TUSTIN
GENERAL PLAN
SITE 10
LARWIN SQUARE
SWC OF NEWPORT AVE & FIRST STREET— 200 units
16.47 Acres
k
SITE
7
Am%
B-56
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 10: LARWIN SQUARE
16.47 acres Zoning: SP 12 General Plan: DCCSP
Address
F APN
Acre TatalAcreage
630 E 15T ST
402-60 1-01
12�20
13341
4()1-601,04
0181
NEWRORT AVE
13421
0.32
NEWPIORT AVE
401-601-05
13451
NEWPORT AVE
401-601-06
0138
16,47
1S471 Newport
Aw
401-601-07
0.39
550 E IST ST
401-601-08
1.00
275
0.46
CENTENNIAL
401-601-09
WAY
662 E IST ST
0.91
401-601-10
Source: RealQuest
7
&rig 8
. .........
--------------- ------ ..................
I= =W= "I
ME 1�ff
Am. 84"
wr 14TRWI
k " Im —a
flKs, 1w. � — ID
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-57 SEPTEMBER 2022
Tustin
2021-2029
Housing rjem
DOWNTOWN
COMMERCIAL
CORE
SPECIFIC
PLAN AREA
Sites:
11, 12, 13, 14 —
150 units
CITY OF TUSTIN
GENERAL PLAN
SITE 11
225 — 255 EL CAMINO REAL
& 250 PROSPECTAVE.
VACANT
1.02ACRES
SITE
how
SITE 13
125W. MAIN STREET— ADJACENTTO ARVIDA
BOOKSTORE; VACANT
0.25 acres
SITE
Az
st cl
SITE 12
NEC of El CAMINO REAL& SIXTH STREET
542 EL CAMINO REAL; VACANT
2.28 Acres
wt
Val,
SITE
—ww� S -N
m SITE 14
420 EL CAMINO REAL; VACANI
0.44 Acres
SITE
FT
mm
A;=
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 11: 225 — 255 EL CAMINO REAL
& 2 50 PR OSP ECT AVE.
Farmer's Market Temporary Use
1.02 Acres Zoning: SP 12 General
Plan. DCCSP
Addre55
APN
Acres
Tota
F
AID
Acreage
250
C'
Prospect
Avenue
401-5,84-04
U, 17
No address
listed
401 -584 -OS
0,17
255 El
Camino
Real
401-584-06
0,17
1.02
245 El
Camino
Real
401-584-07
0.17
235 El
Camino
Real
401-584-08
0.17
225 El
Camino
Real
401-584-09
0.17
Sou rce: Rea I CLuest and 0 range County Pu bl Ic Works
.W& MVWJ av
,t,nrxo -r, -d Q* -U 41.7
apw R-LTT
Ar A
591
j d
02
10, 0
I PNWCT '
_d d JP
oxv
PiTUM wF hr. N-3ri 31pt
IWO
L -.1"
MR -C,
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moll - dMIX's ALYN i
.AXEL W"ffi 2 a FM
sh" IV r"AA0 mmrr J fiPmU
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-59 SEPTEMBER 2022
W I IF 2
F
AID
00
C'
0
L 'VOL i
moll - dMIX's ALYN i
.AXEL W"ffi 2 a FM
sh" IV r"AA0 mmrr J fiPmU
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-59 SEPTEMBER 2022
W I IF 2
SITE 12: NEC of El CAMINO
REAL & SIXTH STREET
542 EL CAMINO REAL
2.29 Acres Zonin � SP 12 General
Plan: 6CCSP
dress
APN
Ac re
Acreage
7:1;1
5 , 20 Ell
7 -
Camino Real
401-623-14
0.50
2,29
No Listed
Address
401-623-15
1.1
135 W 6th
401-623-16
0.69
Source: RealQuest
CITY OF TUSTIN
GENERAL PLAN
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- -------------
336
L
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?w w NJ am 41�41 �ffi a", 431 62
ZA w p.m rjHt, F44. J041 Ncr�u MAr, or PIOX
MM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
r-1
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0
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MM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 13: 125 W. MAIN
STREET - ADJACENT TO
ARVIDA BOOK STORE
0.25 Acres Zoning: SP 12
General Plan: DCCSP
Address
APN
Acre
Total
I
4!0.
I
Acrea
�1
125 W,
-
401 -573 -
Main St
13
L 0.2
Source: RealQuest
mo
401-57
V. L
7
&X. 7
4wW5 p'm 4 gwi�'s W
AW 19 4'0"4011 'AXEL AbWRS � qvi .� V E7
S,vw N fl -M (AW, # ~
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-61 SEPTEMBER 2022
4!0.
1(p
401-57
V. L
7
&X. 7
4wW5 p'm 4 gwi�'s W
AW 19 4'0"4011 'AXEL AbWRS � qvi .� V E7
S,vw N fl -M (AW, # ~
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-61 SEPTEMBER 2022
SITE 14: 420 El Camino Real
0.44 Arres Zoning: SP 13 General Plan � DCCSP
Address
APN
Acre
Total
Acreage
420 E�
401-522-
044
01"
Camino
Real
CITY OF TUSTIN
GENERAL PLAN
iv -62
57
N "O—M.-
ra ww T 7
ra juj
C
Pif
L w7m
B-62
_L
At, A
MCI
go
114, kRl
FA PH
wrg 0 LA 05.R �ig.w.j
rtKr4 W�p LA M13 wi � 4cm z 2
RRM W FA N%4N of". pw WCIME5 'Wrl, � E
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Tustin
SITE 16
EL CAMINO PLAZA
Swc OF SIXTH STREET & EL CAMINO REAL
4m
7.81 Acres
SITE 15
14042 NEWPORTAVE. & EL CAMINO REAL
VACANT, 2.73 Acres
SITE
moil -1-04.
lip
SITE
PIY
Oil
DOWNTOWN
COMMERCIAL
CORE
SPECIFIC PLAN
AREA
Sites 15 & 16 —
260 housing
units
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-63 SEPTEMBER 2022
SITE 15, 14042 NEWPORT
AVE. & EL CAM I NO REAL
2.73 Acres Zoning: SP 12 General
Plan: DCCSP
Address
APN
Acre
Total
Acreage
14042
Newport
432 -074 -
Avenue
02
0.77
14042
Newport
432 -074 -
Avenue
07
0.67.5
14042
Newport
432 -074 -
Avenue
08
0.378
14042
Newport
432 -074 -
Avenue
09
0.906
173
1�oume: RealQuest and "ngQ County Public Works
CITY OF TUSTIN
GENERAL PLAN
LW
farAl N, AL r p�ff j Rjyr PC, J LA, J4$
maka �qw rw-y Rd. ?"I am juv wrt - �"155m, awl 4 1195W,�
pmm W RJE fjqL X -Y. M". M-4 �M � . 'm X 6,
'. �AIO �W-Twow
432-0
-1 7
B-64
le
L
OWN
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
14
SITE 16: EL CAMINO PLAZA
7.81 Acres Zoning; SP 12 General Plan� K49
DCCSP
ce Total
Acreage
00
1,211
Car no
Rea, 401-631-01 15
634 El
Carnino 7.81
Real 401-631-15 4.2
No Listed t r
I Address 1401-631-13 0.11
L
NUAW� AM LA. MV
So u rce Rea I Qu est an d C ity of Tust I n G IS Data base 19v 4f-sw mwft A'a NO �."
I#X? AV M 'y ;m -m
\jj / 401-63
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-65 SEPTEMBER 2022
X-
AmW5 &W a
jllw� mW9
i" Ak VY -113
go
�r,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-65 SEPTEMBER 2022
Tustin
2021-21029
Housing flement
CITY OF TUSTIN
GENERAL PLAN
SITE 17
ENDERLE CENTER — 413 housing units
Total: 11.62 Acres
(Acr2pge suitable for redevelopment 7 acres)
'Aff
SITE
MM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE #17: ENDERLE CENTER
11.62 acres Zon�ng: PCC
General Plan: PCCB
- t I .
14081 Yorba St
401-251-04
1.05
17240 17th St
401-251-06
0.54
17280 17th St
401-252-05
0.52
17300 17th St
401-252-06
3.53
401-252-08
1.05
17490 17th St
401-252-09
0.3
17440 17th St
401-252-10
3.32
14032 Enderle,
Center Dr
401-253-03
D.5
401-253-04
0.81
Tcytal Site "cr age
11.62
Total AcreageSu ita ble for
lIffidential Development
7
Partially or wholly suitable for
residential development
Enderle Center
401-25
.OLW 0173
;Wlf =;ZT k.1 J.,
--;rlsm S &-X. a -55E5z,5,-
11AQrj-4 .YW05 Soo. 'a 25
Vq— X. Cw4r. rb—F, ff mAwx
h"K I
q ap
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-67 SEPTEMBER 2022
Tustin
20k21-2029
Housing Dement
CITY OF TUSTIN
GENERAL PLAN
lip SITE 18
THE MARKETPLACE — 900 housing units
Tota 1: 76.937 Acres
(Acreage suitable for redevelopment 18 acres)
11�9 *
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE #18: THE MARKETPLACE
76.937 acres Zoning: SP -8 General Plan: PCCB
E--]
2870 El Camino Real
500-291-02
5464
2982 El Camino Real
500-291-04
5.1s
2992 El Cam i n D Rea 1
500-291-06
0.5
3002 El Cam [no Real
500�291-07
0.41
3010 El Camino Real
50D-291-08
031
2996 El Camino Real
500�291-11
059
50D-291-12
012
500-291-21
025
3020 El Camino Real
500-291-23
0.5
3040 El Cam i n a Rea 1
50&-291-24
078
3030 El Camino Real
500-291-25
3.9.226
2762 El] Camino Real
50D.-291-26
1562
2762 El Camino Real
500�291-27
6.&45
2741 El Camino Real
500�-312-02
3.214
50G-312-03
611
2851 El Camino Real
50D-312-04
4
2961 El, Camino Real
500-312-06
2.88
3025 El Camino Real
500-3112-08
0226
3015 El Camino Real
500�-312-09
500-312-10
_315
18655
Tota I Site Acreage
76.937
Total Acreage Suitable for
Residential Developinient
18
Partia I ly or wholly suitable for
remdential development
Market Place
P aWPAO
WM AM
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-69 SEPTEMBER 2022
Tustin
2021-2029
Housing Dement
CITY OF TUSTIN
GENERAL PLAN
Transitional Housing
B-70
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Tustin
2021-2029
Housing flentent
ADUs/JADUs — 35 housing units
Citywide: ADUs/JADUs
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 4 th
Size
Plan
Vacant
&/Or 5"
(Acres)
Cycles / Was
Counted
Towards
RHNA
Tustin Legacy Specific Plan Area
1
Neighborhood D PA 8, 13 & 14
Vacant
Yes(both)/
City of Tustin
SID 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
SID I
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
GENERAL PLAN
B-72
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Attachment B-3
Buffer
Site
Site Reference
Vacant or
Identified in
Site
APNs
Ownership
Zoning
General
Capacity
#
Non-
Previous 4 th
Size
Plan
Vacant
&/Or 5"
(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
CITY OF TUSTIN
GENERAL PLAN
Attachment B-4
HCD Required Site Inventory Form
To Be Submitted Following Housing Element Adoption - As Allowed
B-74
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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.
0 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
GENERAL PLAN
C-2
HOUSING ELEMENT
SEPTEMBER 2022
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.
0 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
GENERAL PLAN
C-3
HOUSING ELEMENT
SEPTEMBER 2022
costs for navigation centers and emergency shelters, and the new
construction, rehabilitation, and preservation of permanent and transitional
housing.
0 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.
0 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.
0 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.
0 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
GENERAL PLAN
C-4
HOUSING ELEMENT
SEPTEMBER 2022
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.
0 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.
0 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 strean-dining 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
GENERAL PLAN
C-5
HOUSING ELEMENT
SEPTEMBER 2022
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
GENERAL PLAN
C-6
HOUSING ELEMENT
SEPTEMBER 2022
This page intentionally left blank.
CITY OF TUSTIN
GENERAL PLAN
C-7
HOUSING ELEMENT
SEPTEMBER 2022
APPENDIX D
AFFIRMATIVELY FURTHERING FAIR HOUSING
CITY OF TUSTIN
GENERAL PLAN
D-1
HOUSING ELEMENT
SEPTEMBER 2022
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
jurisdiction!s fair housing enforcement and outreach capacity; and
An analysis and summary of fair housing issues and identification of trends and
patterns within the City of Tustin in comparison to surrounding cities and the larger
Orange County region, including the topics of:
o Integration and segregation;
o Racially or ethnically concentrated areas of poverty;
o Disparities in access to opportunity, including for persons with disabilities; and
o Disproportionate housing needs (such as overpayment, overcrowding, housing
conditions disproportionately affecting protected classes), and displacement risk.
This analysis utilized available federal, state, and local data and knowledge to identify trends
and patterns in fair housing issues and identification of trends and patterns within the City of
Tustin. Orange County's Analysis of Impediments to Fair Housing Choice (AI) was prepared in
May 2020 and contains a thorough examination of structural barriers to fair housing choice and
access to opportunity for members of historically marginalized groups protected from
discrimination by the federal Fair Housing Act (FHA) within Orange County. The Al also
outlines fair housing priorities and goals to overcome fair housing issues. In addition, the AI
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
0 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
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
D-4 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 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.
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
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/V\Thite 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 AB 686
In 2018, the California State Legislature passed AB 686 to expand upon the fair housing
requirements and protections outlined in the Fair Employment and Housing Act (FEHA). The
law:
• requires all state and local public agencies to facilitate deliberate action to explicitly
address, combat, and relieve disparities resulting from past patterns of segregation to
foster more inclusive communities; and
• creates new requirements that apply to all housing elements due for revision on or after
January 1, 2021.
The passage of AB 686 protects the requirement to affirmatively further fair housing within
California state law, regardless of future federal actions. It also preserves the strong policy in
the U.S. Department of Housing and Community Development's (HUD) Affirmatively
Furthering Fair Housing (AFFH) Rule as published in the Federal Register in 2015.
As of January 1, 2019, AB 686 proactively applies the obligation to affirmatively further fair
housing to all public agencies in California. Public agencies must now examine existing and
future policies, plans, programs, rules, practices, and related activities and make proactive
changes to promote more inclusive communities.
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:
0 524.19 (overlaps North Tustin)
0 525.02
0 525.24
0 744.07 (overlaps Santa Ana)
0 744.08
0 755.04 (overlaps Santa Ana)
0 755.05
0 755.06 (overlaps Santa Ana)
0 755.07
CITY OF TUSTIN
GENERAL PLAN
0 755.12
0 755.13
0 755.14
0 755.15 (overlaps a small portion of
Santa Ana and a large portion of
Irvine)
0 756.06 (overlaps North Tustin)
0 756.07
0 757.01 (overlaps North Tustin)
DRAFT HOUSING ELEMENT
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:
0 754.03
0 756.03
0 757.02
0 744.06
0 756.05
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
0 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
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
D- 12 SEPTEMBER 2022
(Tustin, CA CDBG)
(Los Angeles - Long Beach -
jurisdiction
Anaheim, CA) Region
Race/ Ethnicity
Count
Percent
Count
Percent
White, Non-
24,289
30.36%
4,056,820
31.62%
Hispanic
Black, Non-
1,926
2.41%
859,086
6.70%
Hispanic
Hispanic
32,982
41.22%
5,700,860
4C44%
Asian/Pacific
Island, Non-
17,542
21.93%
1,888,969
14.72%
Hispanic
Native American,
418
0.52%
25,102
0.20%
Non -Hispanic
Two+ Races,
1,949
2.62%
267,038
2.08%
Non -Hispanic
Other, Non-
169
0.23%
30,960
0.24%
Hispanic
#1 country of
Mexico
11,270
14.09%
Mexico
1,735,902
14.34%
origin
#2 country of
Vietnam
2,115
2.64%
Philippines
288,529
2.38%
origin
#3 country of
India
2,048
2.56%
El Salvador
279,381
2.31%
origin
#4 country of
Philippines
1,677
2.10%
Vietnam
234,251
1.93%
origin
#5 country of
Korea
1,446
1.81%
Korea
224,370
1.85%
origin
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
D- 12 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
D- 13 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
174,424
1.44%
Kong &
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
0
#10 LEP
Arabic
165
0.23%
Arabic
23,275
0.19%
Language
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
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% 1,388,564 47.84%
children
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
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-15 SEPTEMBER 2022
Figure 2:2020 TCAC/HCD Opportunity Areas (Tustin)
Oi-ange
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-16 SEPTEMBER 2022
Figure 3:2021 HCD/rCAC Opportunity Areas (County)
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CITY OF TUSTIN
GENERAL PLAN
D- 17
C..P P.,
0 - C"
Garm�n, USGS, N(;A, EPA, USDA,
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Figure 4: Areas of Minority Concentration in Tustin
Regional
Pack
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Source: AFFH Data Vie— Fmnch HO
CITY OF TUSTIN
GENERAL PLAN
D-18
DRAFT HOUSING ELEMENT
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
Table 4: Dissimilarity Index Scores
Racial/ Ethnic Dissimilarity Index
Value
Level of Segregation
Dissimilarity Index Value (0-
100)
0-40
Low
Non-V\Thite/White
41-54
Medium
32.93
55-100
High
Table 4: Dissimilarity Index Scores
Racial/ Ethnic Dissimilarity Index
1990
Trend
2000
Trend
2010
Trend
2020
Tustin
Non-V\Thite/White
26.33
36.73
32.93
F48.19
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/V\rhite
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
Isolation Index
1980
1990
2000
2010
2020
2020
(Orange
County)
White/White
83.7
66.3
54.3
43.2
52.44
55.16
Black/Black
6.1
9.9
3.6
2.7
4.84
3.32
Hispanic/ Hispanic
10.2
27
51.3
51.9
56.10
52.81
,Asian/Asian
4.4
12.1
19.6
26.7
19.86
31.84
Source: County of Orange, Analysis of Impediments, 2020
As shown in Figure 2, the city's highest resource areas are to the northeast and the low resource
areas are to the south and southwest. The city did not include any areas categorized as high
segregation and poverty (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 (1-5) (see Figure 3). Areas that were indicated as
rapidly changing were located along the perimeter between low resource and high resource
areas, particularly on the southern coastal side. The City of Tustin is not classified as a rapidly
changing area. This pattern indicates a rapidly expanding trend of high resources from the
coast, inward towards central Orange County located near 1-5.
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
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
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
IHCV 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
Mr., Lorna
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N 0 2.5 5 Miles
k I I I I
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Esri, HERE, Garmin, USGS, INGA, EPA, USDA, NRS
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-23 SEPTEMBER 2022
Figure 6: Percent Population with Disabilities in Tustin
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-24 SEPTEMBER 2022
Figure 7: Percent Population of Adults Living Alone - Tustin
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-25 SEPTEMBER 2022
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-25 SEPTEMBER 2022
Figure 8: Percent Population of Adults Living with their Spouse - Tustin
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Garmlin, INCREMENT P, USGS, METI/NASA, NGA, EPA USDA
Source: AFFEI Data Viewer C7h
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-26 SEPTEMBER 2022
Figure 9: Percent of Children in Married Couple Households - Tustin
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-27 SEPTEMBER 2022
Figure 10: Percent of Children in Single Female -Headed Households - Tustin
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-28 SEPTEMBER 2022
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0 0.5 1 Miles
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County of Los Angeles, Bureau Wonaqemert Esrl HERE
Garmin, INCREMENT P, J S,7'N/NASA,'EPA
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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 1-5 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
RaciallylEthnically 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
P Mr. Lrn.
Eastvale Jurupa Vail,
k%IhIttler
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75%-100%
County Boundary
N 0 25 5 Miles
Source: AFFH Data Viewer
I E rSCAL vALLE,
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Esri, HERE, Carnnin, USGS, NGA, EPA, USDA,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-30 SEPTEMBER 2022
Figure 12: Low and Moderate Income (LMI) areas in Tustin
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N 28-
0 0.5 1 Miles Irvine, County of Los Angeles, Bureau A�ofLau Wonaqemert Esrl HERE
Garmin, INCREMENT P, U Sr7N/NASA�'EPA USDA
Sour— AFFH Data Viewer
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-31 SEPTEMBER 2022
Figure 13: Racially Concentrated Areas of Poverty (RECAPs) in Orange County
55 1. IIIAL VALLEY
Orange County
Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs)
0 - IN t a R/ECAP
I - R/ECAP Area
Poverty Status (Tract) - ACS (2015-2019)
C0 J NTY
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140'/
C—ty 3—d.'y
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-32 SEPTEMBER 2022
MI. L...
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0 - IN t a R/ECAP
I - R/ECAP Area
Poverty Status (Tract) - ACS (2015-2019)
C0 J NTY
, 10%
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30%-40%
140'/
C—ty 3—d.'y
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Source AFHH Data Viewer
S,
SANTA Wi.
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Isirl, HERE, Garmin, USGS, INGA, EPA, USDA,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-32 SEPTEMBER 2022
Figure 14: Racially Concentrated Areas of Poverty (RECAPs) in Tustin
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City Boundary 'Pap Onlywo "1 133
N 0 0.5 1 Miles ity of irvire, County of Los Angeles, Bureau of Lan Wpn2gernent, F/
1j, HERE,
Garmin, INCREMENT P, USGS, M-a-1014"IAAA, USDA
Source: A�FH Data Viewer Fmnch Hj#
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: VVhite Household Income and Percent Population (2019)
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
Tustin
Orange (city)
Santa Ana
Irvine
Orange
County
Median
Household
84,697
91,793
66,145
105,126
90,234
Income
All
Households
93,304
95,827
70,084
111,574
95,934
White alone,
101,658
95,702
79,000
113,779
100,723
White
59.01%
74.03%
28.87%
47.80%
59.25%
Population
Notes:
1.VVhite 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
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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.
TCACIHCD 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
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
D-37 SEPTEMBER 2022
Economic
Environment
Educational
Low
al
Transportati
Tustin
Opportunity
Opportunity
Transit Index
Index
Opportunity
Index
on Cost
Index
Index
Tustin total Population
White, Non-
77.38
5 5. 5 3
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
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
Islander, Non -
49.36
46.78
52.50
37.48
36.11
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
Islander, Non -
38.94
46.38
4. S. 3 2
41.97
39.51
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
D-38 SEPTEMBER 2022
Table 9: Opportunity Map Scores - Census Tracts
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
D-39 SEPTEMBER 2022
Economic
Environmental
Education
Composite
Final
Census tract
Domain
Domain
Domain
Index Score
Category
Scores
Scores
Score
Highest
0524.19
0.962
0.574
0.863
0.638
Resource
Moderate
0525.02
0.896
0.166
0.199
-0.217
Resource
High
0525.24
0.912
0.376
0.541
0.272
Resource
Low
0744.07
0.12
0.024
0.055
-0.94
Resource
Low
0744.08
0.179
0.047
0.054
-0.839
Resource
Moderate
0755.04
0.702
0.199
0.35
-0.136
Resource
Low
0755.05
0.622
0.22
0.068
-0.462
Resource
Moderate
0755.06
0.614
0.619
0.529
0.189
Resource
Moderate
0755.07
0.626
0.27
0.208
-0.269
Resource
Low
0755.12
0.27
0.218
0.106
-0.575
Resource
Low
0755.13
0.386
0.185
0.199
-0.426
Resource
Low
0755.14
0.187
0.092
0.078
-0.753
Resource
Low
0755.15
0.452
0.005
0.236
-0.839
Resource
Highest
0756.06
0.986
0.534
0.927
0.766
Resource
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
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: Califorr-da 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, 74�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 econon-dc 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 C
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. hi 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
.
0.0%
0.0%
0.0%
0.0%
0.0%
0.3%
0.3%
0.0%
22.2%
20.3%
Alaska N ative
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%
0.0%
0.0%
0.0%
0.0%
0.0%
2.4%
0.0%
40.0%
34.1%
Other Pacific
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)
I I
CITY OF TUSTIN DRAFT HOUSING ELEIVIEN I
GENERAL PLAN D-43 SEPTEMBER 2022
School Proficiency
Total Title 1
Schools
1
1
2
10
135
Total Schools
1
1
2
19
607
Percent of
Schools
-
100
-
100
-
100
-
-
52.6
22.2
Unemployment
4.2%
1.7%
3.8%
4.3%
3.3%
1.8%
1.4%
2.4%
2.80%
3.00%
Rate (2019)
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%
8.1%
6.8%
9.7%
more
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)
I
I
I
I
I
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
Census Tracts
Of
Indicators
Tustin
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
.
0.0%
0.0%
0.4%
0.0%
0.0%
0.0%
0.0%
1�4%
0.1%
0.2%
Alaska N ative
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%
0.0%
0.0%
0.0%
0.5%
0.0%
0.0%
0. 0 'Yo
0.1%
0.3%
Other Pacific
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
Schools
2
1
-
-
3
-
-
-
10
135
Total Schools
5
1
4
3
1
19
607
Percent of
Schools
40
100
-
-
75
0
0
-
52.6
22.2
Unemployment
4.1%
4.3%
5.6%
4.4%
1.3%
1.1%
2.
2. 0
2.80%
3.00%
Rate (2019)
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
f 0, 1
6.8%
9.7%
more
Transit Metrics
All Transit
Performance
5.7
5.9
5.1
5.4
6.4
1.2
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
6-51
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
2-5-),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 M
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
169
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
01 le on
na eim
a en o e
San
ou tain
alle
untin on
eac.
sa IF
e 0
-gu-- _00
Orange County
CalEnviroScreen Percentiles
1 - 10% (Lowest Score)
11-20%
21-30%
31-40%
41-50%
51-60%
61-70%
71-80%
81-90%
91 - 1D0% (Highest Score)
County Boundary
N 0 3 6 Miles
A I I I I
Source: calEnviroscmer 4,0 - Feb. 2021 Update
CITY OF TUSTIN
GENERAL PLAN
Ill=
1%, S CAL VALF V
Lall,
E"
�les,
-RE,
Vs
DRAFT HOUSING ELEMENT
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
housing problems
# with problems
# households
% with
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-
Hispanic
2,644
6,089
43.42%
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
Severe Housing Problems
# with severe
problems
# households
% with severe
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-
Hispanic
1,519
6,089
24.95%
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
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
housing problems
# with problems
# households
% with problems
Race/Ethnicity
White, Non -Hispanic
206,658
540,773
38.22%
Black, Non -Hispanic
8,074
16,719
48.29%
Hispanic
152,740
241,84
63.16%
Asian or Pacific Islander, Non-
Hispanic
84,193
186,038
45.26%
Native American, Non -Hispanic
.78 "/o
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
Severe Housing Problems
# with severe
problems
# households
% with severe
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-
Hispanic
50,205
186,038
26.99%
ative merican, on -Hispanic
44
0
Total
267,641
987,550
27. 10 %
Source: County of Orange, Analysis of Impediments, 2020
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
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 fan-dlies, 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
Orange& E Cha pman A.- Orange E Chapman A,,e
"��cks Ca.
orth Vi.t
Can)0
I rvine
01-9. C 101-9. C
IN -
IMM
City of Tustin City of Tustin
Overpayment by Renters Overpayment by Home Owners
20'A 20%-40%
20% - 40% 40% - 6U%
40% - STA 60% - SCI%
80%
City Boundary City R.unda ry
N D 0.5 1 md- CIty 0 11irl., COL.ty of L- Arig.l-, Bun—, f L -d S! 5 City cif i-, C—ty of L., Angel-, of L -d
I I I I Management Isri, HLR[r Garmin, USGS, NGA, LPA,
gerrientil, Esri, HERE, Garrhin, INCRLM,LNT R, A
USGS, MET]INASA, EPA! USDA USDA,NPS
7 �fr- ft A-0 —4 wt.j— 20191 1 �15c) rtl%�'—
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
CHIN. -It s
PI I
E,1111
Fullemon orpna—
.j -MM " 1 —1 -
Orange County
Overcrowded Households
= 158.2 (Statewide Average)
F—] f 12
:520
1570
County Boundary
N 0 3 6 Miles
Source: CHHS Data - Tract
--- T5*
Wire—
ffi M
ffl,
[S=an CIZM�—We �M
M10
CIty of I rvine, County of Les Angeles,
Bureau of Land Management, Esn, HERE,
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
$14,999
2.5%
3.8%
3.2%
2.6%
$15,000 to
$24,999
2.6%
1.3%
3.3%
2.2%
$25,000 to
$34,999
2.2%
1.8%
3.7%
2.7%
$35,000 to
$49,999
2.1%
1.9%
3.8%
2.5%
$50,000 to
$74,999
2.5%
1.9%
3.7%
2.9%
$75,000 to
$99,999
2.6%
2.2%
3.6%
2.7%
$100,000 to
$149,999
2.7%
1.5%
4.1%
2.8%
$150,000 to
$199,999
2.1%
1.5%
3.6%
2.8%
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-59 SEPTEMBER 2022
$200,000 or more
5.4%
4.3%
7.2%
5.8%
Medianm'come
90,939
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 Corrummity 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 hic.
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)
Source: County of Orange, Analysis of Impediments, 2020
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-61 SEPTEMBER 2022
Race by Housing Sites (percent)
Race by Census Tract
Low
Total
Census
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
Park
LIHTC
149
150
13.1
3.4
75.4
7.2
755.13
14.4
3.6
57.9
20.5
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 11 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
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
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
Veterans outpost
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
Tustin Temporary Emergency Shelter
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
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 predon-dnately 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
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
City of Tustin
Orange County
Tenure
Estimate
Percentage
Estimate
Percentage
2010
Owner-
occupied
13,109
52.8
599,032
60.8
Renter -occupied
11,730
47.2
385,471
39.2
Total
24,839
984,503
2019
Owner-
occupied
12,759
49.7
595,272
57.4
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)
Source: Federal Financial Institutions Exammation Council (FFIEC) Home Mortgage Disclosure Act (HMDA) Dataset, 2019
Notes: Other includes Free Form Text and Joint applicants
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-66 SEPTEMBER 2022
Preapproval
App-
Race and
Loan
approved
App.
App.
File closed for
Purchased
request
Grand
withdrawn
approved
Ethnicity
originated
but not
Denied
incompleteness
loan
Total
by applicant
but not
accepted
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
Other Pacific
5
1
1
7
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
Latinc,
Source: Federal Financial Institutions Exammation Council (FFIEC) Home Mortgage Disclosure Act (HMDA) 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
American alone
1,508
1.9
0.8
1.4
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/eflu-tic 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 Comn-tission 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
an
Figure 19: Distribution of Predominantly White and Predominantly Hispanic Population
L Chapman Av, 0i ange E Chapman Ave
I I J n e
1M
ks
Ilk
0 1 evc,
lot
N-rlh Tcr I
LZINIM
UL4'ii�oa
Cks
City of Tustin City of Tustin
White Majority Hispanic Majority
Slim (gap< 10%) Slim (gap < 10%)
Sizeable (gap 10% – 50%) =1 Sizeable (gap 10% – 50%)
Predominant (gap> 50%) �M Predominant (gap > 50%)
City Boundary City Boundary
N 0 O�5 1 M11- Oily a[ FIV,11c, C.,,, -t,, W L., Arg,t,�. ot L,, 0 05 1 Mil- cty �1 C—ty f L., A,gel�,, B.— f L -d
Ci
An d, 4FRE, G—i�, LISGS, NGAI, IN, 1r) M.n.g., ent, Fsri, HFRF, Ga–in, INCRFMFNT P
LISGS, MET^ASA, Elf USDA
56 ft
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 11-
16 in Section 11 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 1-5 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 1-5 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
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Downtown Commercial Core Specific Plan
Red Hill Averue Specific Plan
Tustin Legacy Specift Plan
Enderle Center
Tustin Marketplace
Municipal Boondaries
N
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-77 SEPTEMBER 2022
Figure 21: Focused Locations of Sites to Meet RHNA
Enderle Center (Site #19)
Tustin Marketplace
(Site #20)
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-78 SEPTEMBER 2022
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-78 SEPTEMBER 2022
Figure 22: Location of Sites in Opportunity Zones
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-79 SEPTEMBER 2022
Table 23. Sites Demographics
Area
Non -White Population
(Percent)
Low to Moderate Income
(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
GENERAL PLAN
DRAFT HOUSING ELEMENT
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
• Heritage Elementary School
• Legacy Magnet Academy (Grades 6-12)
• 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
• 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)
• Head Start preschool
• Rancho Santiago sheriffs training facility
• Orange County Animal Shelter
o Fire Station
• Army Reserve Center
• Village of Hope transitional homes for individuals and families with children
Employment
• Flight at Tustin Legacy office complex
• Hoag medical center and Health South acute care facility
• Stater Bros. grocery store and other retail and neighborhood services at the
Village at Tustin Legacy
• 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:
• Columbus Square (1,075 residential units consisting of single-family homes,
duplexes and multi -family homes)
• Columbus Grove (465 detached homes)
• Field 1 (376 attached units)
• Field 11 (189 detached units)
• Amalfi Apartments (533 apartment units)
• Greenwood (375 detached single-family units)
• Anton Legacy (225 affordable housing units)
• Levity (218 attached units)
• 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 dor�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:
0 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
AFTH Fair
Contributing Factor
Strategies to Address AFFH Issue
Supporting Programs
Housing Issue
Housing Mobility
1. Lack of affordable housing opportunities for
Housing Mobility Strategies consist of removing barriers to
PUBLIC OUTREACH - ENGAGE LIGUISTICALLY ISOLATED
Hispanic residents
housing in areas of opportunity and strategically enhancing
Revised Program 2.5 (b): By 2023, translate official City announcements (i.e. community meeting, hearings, etc.) to Spanish
2. High segregation for Hispanic/White and
Black/White populations (as defined by
access.
and disseminate printed copies of information to renters, property owners, and via social media, in order to expand
Dissimilarity Index values which indicate
Opportunity areas are rated "high" or "low" resource based on
knowledge of affordable housing options in High Opportunity Areas.
geographical segregation patterns)
education, employment, economic development, safe and decent
Community Development Department
housing, low rates of violent crime, transportation, and other
opportunities, including recreation, food and healthy
Action Outcomes:
enviromnent (air, water, safe neighborhood, safety from
environmental hazards, social services, and cultural institutions).
The City's goal is to increase attendance, representation, understanding by linguistically isolated residents, at community
meeting, public hearings and City Council meetings. By engaging Hispanic populations in the decision-making process,
they are better able to advocate for their needs and concerns regarding affordable housing and access to opportunities. 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.
QUALITY RENTAL HOUSING INSPECTION PROGRAM
New Program 3.11: By 2025 through 2029, establish a multi -family quality rental housing inspection program.
Community Development Department
Action Outcomes:
City's goal is to elevate the quality of housing in segregated areas in order to transform the area into a desirable housing
location by all socio-economic groups and to protect existing tenants from displacement and to provide occupants the
opportunity to live in suitable housing conditions that are not characterized with substandard conditions such as lack of
plumbing or overcrowding.
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
_L_
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.
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.
New Housing
1. Disparity in access to opportunity between
New Housing Choices and Affordability in Areas of
ADU/SB 9 ACCELERATOR PROGRAM
Choices and
Affordability in
the northeast (higher resources), where there
are predominate populations of White
Opportunity means promoting housing supply, choices and
affordability in areas of high opport�mi and outside of areas of
Revised Program 1.7b: The City will create an ADU/SB 9 accelerator program and focus in High Opportunity Areas
Areas of Opportunity
residents, and southwest (lower resources) of
concentrated poverty.
within the northeast portion of the City where there are predominately single-family residences in order to expand
the city, where there are predominate
housing choices. This program could include a permit fee waiver for affordable housing units, permit fast tracking (refer
populations of Hispanic residents
to Program 1.1h), and technical assistance. This program will complement revised Program 1.1(h) Streamlining and
2. Lack of affordable housing opportunities for
Permit Fast Tracking for new ADU/SB9 development proposals.
Hispanic residents
Community Development Department
Action Outcome:
By 2025, the City will adopt a program and mail out information pertaining to the new accelerator program for ADUs
and SB 9 developments, specifically to high opportunity areas.
STREAMLINING AND PERMIT FAST TRACKING
CITY OF TUSTIN
GENERAL PLAN
WMIM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
AFTH Fair
Contributing Factor
Strategies to Address AFFH Issue
Supporting Programs
Housing Issue
Revised Program 1.1 (h): By 2023, provide technical 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.
Community Development Department
Action Outcome:
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 timefrarnes and for all affordable housing projects by assigning a designated "streamlining staff
liaison" to the project.
PUBLIC OUTREACH - DISSEMINATE HOUSING AND ANCILLARY RESOURCE INFORMATION & ENGAGE
LIGUISTICALLY ISOLOATED
New Program 2.5 (c): Annually, starting in 2023 through 2029, translate the City's Tustin Housing Authority website and
factsheets promoting affordable housing opportunities and ancillary support services, such as transit and child care, into
Spanish, and distribute to low resources areas.
Community Development Department
Action Outcomes: Increase the distribution of translated materials to low resources areas located in the southwest of the
City by mailing out postcards to each household in select census tracts, containing information related to housing
choices, transit, child care, and education resources.
Place -Based
1. Disparity in access to opportunity between
Place -based Strategies to Encourage Community Conservation
HOUSING REHABILITATION TO IMPROVE HOUSING CONDITIONS, INCLUDING OVERCROWDING
Strategies to
the northeast (higher resources), where there
and Revitalization Involves approaches that are focused on
New/Revised Program 3.10: By July 2024, the City will partner with a non-profit to develop and launch a CDBG funded
Encourage
Community
are predominate populations of White
conserving and improving assets in areas of lower opportunity
Housing Rehabilitation Program to facilitate the repair of dilapidated housing to address lack of plumbing, kitchen
investment in
Revitalization
residents, and southwest (lower resources) of
the city, where there are predominate
and concentrated poverty such as targeted
neighborhood revitalization, preserving or rehabilitating existing
facilities and repairs to provide relief of overcrowding. Program participants will be provided grants and/or loans to
populations of Hispanic residents
affordable housing, improving infrastructure, schools,
conduct necessary housing updates.
2. Disproportionate housing problems for the
employment, parks, transportation and other community
The City's goal is to protect existing tenants from displacement and to provide occupants the opportunity to live in suitable
city's Hispanic and Black residents (problems
amenities.
housing conditions that are not characterized with substandard conditions such as lack of plumbing or overcrowding. The
include 1) housing unit lacks complete
program will focus on improving housing conditions in tracts 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15-(qreas
kitchen facilities; 2) housing unit lacks
with high segiegation index as defined by Dissimilarity Index values which indicate geogaphical segregation patterns in
census tracts).
complete plumbing facilities; 3) household is
overcrowded; and 4) household is cost
Action Outcomes:
burdened)
3. Disproportionate housing problems faced by
The program will facilitate four (4) rehabilitation projects to assist with reducing overcrowding per year and another four
large family households
(4) 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 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 in the
City's CDBG Annual Report.
Community Development Department
IN CREASE HOUSIN G SUPPLY FOR LARGE HOUSEHOLDS
New Program 3.13: By January 2024, the City will amend the zoning code to require all new multi -family projects to
provide at least five (5) percent large family units (3+ bedrooms) which will prevent overcrowding and further cost
burden, by addressing demand for such units and increasing the large units into the local housing inventory.
Community Development Department
Action Outcomes: Four (4) large family units will be generated annually, and 32 total by 2029.
CITY OF TUSTIN
GENERAL PLAN
KM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
AFTH Fair
Strategies to Address AFFH Issue
Contributing Factor
Supporting Programs
Housing Issue
QUALITY RENTAL HOUSING INSPECTION PROGRAM
New Program 3.11: By 2025, Establish a multi-fan-dly quality rental housing inspection program.
Community Development Department
Action Outcomes:
City's goal is to elevate the quality of housing in segregated areas in order to transform the area into a desirable housing
location by all socio-economic groups and to protect existing tenants from displacement and to provide occupants the
opportunity to live in suitable housing conditions that are not characterized with substandard conditions such as lack of
plumbing or overcrowding.
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 Dissimilari!y Index values which indicate geogjaphical segregati
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.
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.
TUSTIN LEGACY SPECIFIC PLAN IMPROVEMENT PROGRAM:
New Program 2.8: 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. The area comprises 1,500 acres, of which 800 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:
• Brookfield at Tustin Legacy and Levity: residential projects with development of open space, park areas, and
community amenities
• Tustin Legacy Linear Park Between Armstrong Avenue and Warner Avenue
• Alley Grove Community Plaza
• Neighborhood D South Infrastructure Construction - Phase 2
• Tustin Ranch Road Pedestrian Bridge
• South Hangar Renovation - Phase 1 (for future reuse of site)
• Armstrong Avenue Pedestrian Bridge
• Warner Avenue Pedestrian Bridge
Community Development Department
Action Outcomes:
The City will facilitate development of infrastructure, housing, and community amenities within the TLSP area.
Improvements will provide increased access to safe and decent housing, transportation, recreation, and a healthy
enviromnent. By 2029, the City anticipates the Tustin Legacy (Tract 744.15) to be identified as a "high resource" area
according to TCAC/HCD Opportunity Map criteria.
Protecting Existing
1. Disproportionate housing problems for the
Protecting Existing Residents from Displacement comprises
QUALITY RENTAL HOUSING INSPECTION PROGRAM
Residents from
city's Hispanic and Black residents (problems
strategies that protect residents in areas of lower or moderate
New Program 3.11: By 2025, Establish a multi -family quality rental housing inspection program.
Displacement
include 1) housing unit lacks complete
opportunity and concentrated poverty and preserve housing
kitchen facilities; 2) housing unit lacks
choices and affordability.
Community Development Department
complete plumbing facilities; 3) household is
CITY OF TUSTIN
GENERAL PLAN
D-91
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
AFTH Fair
Housing Issue
Contributing Factor
Strategies to Address AFFH Issue
Supporting Programs
overcrowded; and 4) household is cost
Action Outcomes:
burdened) - Specifically, Hispanic
households were identified as having
City's goal is to elevate the quality of housing in segregated areas in order to transform the area into a desirable housing
substantial overcrowding
location by all socio-economic groups and to protect existing tenants from displacement and to provide occupants the
2. Concentrated female -headed households and
opportunity to live in suitable housing conditions that are not characterized with substandard conditions such as lack of
LMI population within Census tract 755.14
plumbing or overcrowding.
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 DissimilarLty Index values which indicate geogjaphical segregatio
patterns in census tracts).
The City will receive at least one monthly referral from the City's Neighborhood Improvement Task Force (NlTF) (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.
The City will conduct at least five multi -family quality rental housing inspections in the programs first year, and will
increase the number of annual inspections by 2, each year thereafter until 2029. CHILD-CARE RESOURCES
New Program 3.12: By December 2022, the City will create a "Financial Assistance for Child Care" webpage with
information and links to Childrer�s Home Society of California (CHS) and the Orange County Department of Education
(OCDE). These programs provide funding to low-income families for child care services. The City will work with Tustin
Preschool, Kiddie Academy of Tustin, or other local preschool programs within Census tract 755.14 to advertise and
promote financial assistance through pamphlets, e -blasts, and other applicable online community forums (such as
Facebook and NextDoor).
Economic Development DepartmentlCommunity Development Department
Action Outcome: Single -parent households require special consideration and assistance because of their greater needs
for daycare, healthcare, and other facilities. According to HCD, female -headed households with children tend to have
lower incomes, thus limiting housing 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.
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
APPENDIX E
PUBLIC PARTICIPATION
E-1
HOUSING ELEMENT
SEPTEMBER 2022
APPENDIX E
PUBLIC PARTICIPATION (COMMUNITY ENGAGEMENT)
CITY OF TUSTIN
GENERAL PLAN
E-1
HOUSING ELEMENT
SEPTEMBER 2022
Axe,
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City of Tustin
202 7 — 2029 Housing Element Update
Community Engagement Plan
Y 01-i
lu I
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 Pa ge 12
Purpose
This COMMUNITY ENGAGEMENT PLAN is for the City of Tustin's 61h Cycle Housing Element (2021-2029). This Plan describes
strategies for engaging with residents and stakeholders through an online survey, education and awareness campaigns, and
public meetings. Due to COVID- 19 restrictions on in-person meetings, this outreach plan focused on alternatives such as virtual
meetings, targeted email blasts, mailings to stakeholders, unpaid and paid social media postings, posters at community
facilities, distribution of flyers, dedicated project website, and newspaper advertisements.
Background
The City of Tustin is preparing the 2021 — 2029 HOUSING ELEMENT UPDATE to evaluate current and
future housing conditions, and identify housing sites and programs to meet the community's needs. While
updating the housing element is a State requirement, it is also an opportunity to assess its accomplishments
and progress toward meeting housing goals put forth in the previous Housing Element in 2013. The 2021 -
2029 Housing Element will outline the goals, policies and programs needed to promote the development
and preservation of safe, accessible, and diverse housing in the City.
Goals and Objectives
The GOAL of the COMMUNITY ENGAGEMENT PLAN for the 2021 — 2029 Housing Element Update is to
guide the City's community and stakeholder engagement efforts and to provide information about the
importance in participating in the Housing Element Update. The OBJECTIVES of the Community
Engagement Plan include:
Building public awareness of the Housing Element Update, its requirements, and the City's vision
and goals to adequately plan to meet housing needs to all of its residents;
Educating the Tustin community on the requirements of the Housing Element Update, and progress
since the previous Housing Element;
Engaging community members and key stakeholder groups to provide input on potential policies
and programs that will align with Tustin resident's housing needs;
Facilitating discussions with community members and decision makers to identify how and where
additional housing could be located within the City; and,
Providing a concise document to the Tustin City Council and Planning Commission for adoption, with
input and updates from public outreach and engagement activities during the Housing Element
Update.
City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 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. 104016�
Affordable Housing Advocates ( ff*41
Alwalk
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
- Jamboree Housing - OC Community
Corp. Housing Corp.
- Tustin Planning - Habitat for Humanity
Partnership
- Linc Housing
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 und er-rep resented community
members as well as youth and seniors. This includes but is not limited to:
- St. Joseph Hospital
- Meals on Wheels
OC
- Alzheimer's of OC
-Neighborworks OC
Disability Advocates
-Community Health
Initiative of OC
- Tustin Community
Foundation
- Lestonnac Free Clinic
- Tustin Public Schools
Foundation
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
Tustin
- moms OC
- Veterans Legal
Institute
- Orange County
Finance Trust
- Big Brothers and Big
Sisters of OC
- OC Food Access
Coalition
- YMCA of OC
- Goodwill of OC
- Patriots & Paws
- Community Action
Partnership of OC
People Experiencing Homelessness
- Legal Aid Society of
OC
- Second Harvest Food
Bank of OC
- Public Law Center
Organizations, groups, or agencies that provide services to people experiencing homelessness in Tustin. This
includes but is not limited to:
- Housing and Homeless
Prevention Unit
- Human Options
- The Eli Home
-Orange County
Housing Finance Trust
- City Net
- Olive Crest
- American Family
Housing
Real Estate Affiliated
- Families Forward
- OC Gateway to
Housing
- OC Social Services
Tustin Family Campus
- Family Promise of OC
- Second Chance OC
- OC Rescue Mission
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 Pa ge 15
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
- Century Housing
- Lennar Corp.
-City Ventures
- Civic Center Barrio
Housing Corp.
- Taylor Morrison
-Greystar
- William Lyon Homes,
Inc.
- Brookfield Residential
Southern CA
Senior Housing and Advocates
-Curt Pringle & Assoc.
-HomeAid Orange County
- Shea Homes
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
-Community Action
Partnership of
Orange County
- OC Office on
Aging
-Orange County
Health Care Agency
Religious Institutions
Justin Housing
Authority
-County of Orange
Senior Services
-Senior Rental
Properties in Tustin
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 underrep resented 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
Foundation Foundation OC
- Tustin Unified
School District
City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan Pa ge 16
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
Do- Housing Element Update Community 10� Joint Community Workshop with
Workshop with the Planning Commission the City Council and Planning
Commission
November Jan/Feb May 20,21
2020 > 2021 >
llll� Community Survey open
for 30 days
Online Community Survey
No- Draft Document - Public Hearing with the
Planning Commission
September October
2021 > 2021
Do- June 30 - Reopened the
Community Survey for 30 days
Do- Draft Housing Element
Document available for public
review (30 days) and HCD
review (60 days)
00- Finalize Document -
Public Hearing with the
City Council
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:
• Survey results
• Reviewed existing housing policies
• Potential new housing programs
• Opportunity sites for meeting housing requirements
• Project timeline
City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan Pa ge 17
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
posted as a spotlight feature on the City's website and sent to the web's
subscriber list in English and in Spanish
-POSTED FLYERS - Notifications in English and in Spanish were posted on the
City's e -notice board, Library, Senior Center, Tustin Family Youth Center (TFYC),
and Boys & Girls Club. Additional bundles of flyers were distributed at the
Senior Center (200 flyers), TFYC (200 flyers), and Boys & Girls Club (100
flyers). Additional flyer distribution was offered to individual apartment
locations part of the TEAM (Tustin Effective Apartment Managers) group
-CITY CALENDAR - Meeting information was posted on the City's Calendar
-TUSTIN CHAMBER - Tustin Chamber of Commerce advertised meeting dates on
their website. Flyer graphics shared were in English and in Spanish.
-EMAIL BLASTS - Multiple email notifications were sent to 268 stakeholders and
interested parties. The City Manager's Office utilized their Community Outreach
ListSery to e-mail notifications to over 10,000 subsribers. Graphics included and
attached to email blasts were in English and in Spanish.
-POSTCARD MAILINGS - Postcards containing workshop and public participation
information in English and in Spanish were mailed to 396 interested parties
including residents, businesses, property managers, housing advocacy groups,
non -profits, religious institutions and others. Information regarding workshop
participation was included within the City of Tustin's Strategic Plan postcards
which were distributed to 29,885 Tustin residents and 3,457 Tustin businesses.
I— —
WEBSITE- City developed a
dedicated Housing Element Update)
webpage, hosted on the City's
website
*Website includes a project
overview, schedule of activities,
and information on how the public
can get involved
*Website updated regularly with
timeline, meeting updates and
survey information
Project
Webpage
-SOCIAL MEDIA POSTS - UNPAID
AND PAID - Social media posts
were made containing information
on public participation
opportunities regarding the
Housing Element Update survey,
and multiple workshops/meetings,
on all of the City's social meda
platforms
-PRESS RELEASE - A press release
was distributed in English and
Spanish, inviting the public to
review the Draft Housing Element
Update (97 subscribers)
-VIDEO OUTREACH - Mayor
Clark's Corner video advertised
review of the Draft HEU. Video
was posted on all Social Media
outlets including YouTube
*The Tustin Chamber of Commerce
shared workshop/meeting
information on each of their social
media platforms
Media Fostsi'M
0
(.-NEWSPAPER ADVERTISEMENTS - To build widespread awareness of the
Housing Element Update, the City has made publications in local and regional
news resources in both printed and digital formats
-Tustin News - distributed to over 7,000 Tustin residents
,Irvine Weekly - distributed to over 8,200 Tustin residents, including a digital
distribution, reaching over 33,000 individuals
-PAID SOCIA MEDIA ADS - Paid advertisements on the City's social media
platfroms which enabled notification to a larger population than traditional
nnqtinci-
City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 9
Appendix B
Index of Interested Parties
Index of Interested Parties
Housing Element Survey Respondents
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Outside Agencies and Developers List
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Adjacent Jurisdictions, Utilities, and College Districts List
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CITY OF TUSTIN
GENERAL PLAN
APPENDIX F
REFERENCES
F-1
HOUSING ELEMENT
SEPTEMBER 2022
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
GENERAL PLAN
F-2
HOUSING ELEMENT
SEPTEMBER 2022
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
GENERAL PLAN
F-3
HOUSING ELEMENT
SEPTEMBER 2022
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.
https:/ /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
GENERAL PLAN
F-4
HOUSING ELEMENT
SEPTEMBER 2022
ATTACHMENT F
PLANNING COMMISSION DRAFT MINUTES
SEPTEMBER 13, 2022
MINUTES
COUNCIL CHAMBER & VIDEO CONFERENCE
TUSTIN PLANNING COMMISSION
MEETING
SEPTEMBER 13,2022
7:00 p.m. CALL TO ORDER
Given. INVOCATION: Pastor Dane Counts, King's Way Foursquare Church
Given. PLEDGE OF ALLEGIANCE: Commissioner Mason
All present. ROLL CALL: Chair Mello
Chair Pro Tern Kozak
Commissioners Chu, Higuchi, Mason
None. PUBLIC INPUT:
Approved CONSENT CALENDAR:
the Consent
Calendar, as
presented.
1. APPROVAL OF MINUTES —AUGUST 23,2022
RECOMMENDATION:
That the Planning Commission approve the Minutes of the August 23,
2022 Planning Commission meeting, as provided.
2. FINDINGS REQUIRED BY AB 361 FOR THE CONTINUED USE OF
TELECONFERENCE FOR MEETINGS
In order for the Planning Commission to continue to have the option to
meet via teleconference during the pandemic, AB 361 requires the
Commission to make specific findings at least every thirty (30) days.
RECOMMENDATION:
Make the following findings by a majority vote of the Planning
Commission:
a. A state of emergency has been proclaimed by California's Governor
due to the COVID-19 pandemic, and continues to be in effect;
b. The Commission has reconsidered the circumstances of the state of
emergency; and
Minutes — Planning Commission September 13, 2022 — Page 1 of 3
c. State and local officials continue to recommend measures to promote
social distancing to slow the spread of COVID-1 9.
Motion: It was moved by Mason, seconded by Higuchi, to approve the Consent Calendar,
as presented. Motion carried 5-0.
PUBLIC HEARING:
Adopted 3. GENERAL PLAN AMENDMENT (GPA) 2022-0002 - (HOUSING
Reso. No. ELEMENT UPDATE REVISIONS)
4457, as
presented. GPA 2022-0002 is an update to the adopted Housing Element (GPA
2021-0002) in response to the State Department of Housing and
Community Development (HCD) review to comply with State Housing
Element law. The recommendation provided by the Planning
Commission at its September 13, 2022 meeting, will be forwarded to the
City Council for consideration during its October 4, 2022 meeting. City
staff will subsequently transmit the revised adopted Housing Element to
HCD by October 15, 2022.
RECOMMENDATION:
That the Planning Commission adopt Resolution No. 4457,
recommending that the City Council approve GPA 2022-0002, updating
the Housing Element to comply with State Housing Element law.
Huitron Presentation given.
Opening Commission discussion generally included favorable comments to staff, along
commentsl with general questions/comments related to the Housing Element revisions. Staff
questions. and the City Attorney provided additional feedback to the Commission including
Huitron, who referred to various sections of the Housing Element document to
further answer the Commission's questions.
7:28 p.m. Public Hearing opened.
Public Input:
1. Andrew Meling, Southwest Carpenters
7:29 p.m. Public Hearing closed.
Closing The Commission collectively commended staff for their hard work with the
comments. Housing Element revisions. Staff provided additional responses and information
to the Commission's questions regarding the Housing Element.
Minutes — Planning Commission September 13, 2022 — Page 2 of 3
Motion: It was moved by Higuchi, seconded by Chu, to adopt Resolution No. 4457, as
presented. Motion carried 5-0.
None. REGULAR BUSINESS
STAFF CONCERNS:
Barragan Barragan introduced Community Development's newest Assistant Planner, Jose
Jara, to the Commission. Welcome Jose!
COMMISSION CONCERNS:
Chu Chu had no concerns. She made favorable comments to City staff for tonight's
Public Hearing item.
Mason Mason's comments generally included: de -mystifying the process of
development; she would love to see more outreach in the community; and she
suggested staff try to rally residents in to City Hall via Tustin Tiller Days along
with educating people (i.e. NextDoor to direct residents on the process).
Kozak Kozak concurred with his fellow Commissioners regarding the Housing Element
project. 1111ft",
Higuchi Higuchi had no concerns.
Mello Mello made favorable comments to staff. He stated more public involvement
needed (i.e. social media) with regard to City projects.
7:55 p.m. ADJOURNMENT:
The next regular meeting of the Planning Commission is scheduled for
Tuesday, September 27, 2022.
Minutes — Planning Commission September 13, 2022 — Page 3 of 3
ATTACHMENT G
CITY COUNCIL RESOLUTION NO. 21-8§
CERTIFYING THE NEGATIVE DECLARATION FOR THE 6TH
CYCLE HOUSING ELEMENT UPDATE
DocuSign Envelope ID: OE07E7DE-3638-4988-8507-EB263ED01 D05
RESOLUTION NO. 21-86
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF TUSTIN,
CALIFORNIA, ADOPTING A NEGATIVE DECLARATION PURSUANT TO
THE CALIFORNIA ENVIRONMENTAL QUALITY ACT FOR GENERAL
PLAN AMENDMENT 2021-0002 (HOUSING ELEMENT UPDATE 2021-
2029)
The City Council of the City of Tustin does hereby resolve as follows:
The City Council finds and determines as follows:
A. That the California Government Code requires that cities review and
update their housing elements every eight (8) years, according to a
schedule set forth by the State Department of Housing and
Community Development-,
B. That housing is an important issue with the State of California and as
such, each city and county must identify and analyze existing and
projected housing needs within their jurisdiction and prepare goals,
policies, programs, and quantified objectives to further the
development, improvement, and preservation of housing-,
C. That in accordance with State Law, the City of Tustin has prepared a
Draft Housing Element for the 2021-2029 period in accordance with
California Government Code Sections 65580-65589.11 -1
D. That the proposed project General Plan Amendment (GPA) 2021-
0002 is considered a "project" subject to the terms of the California
Environmental Quality Act (CEQA). Pursuant to the CEQA
Guidelines Section 15063, the City has completed an Initial Study
and prepared a Negative Declaration for the draft Housing Element.
E. That implementation of the Housing Element Update's goals includes
proposed housing development within the Tustin Legacy Specific Plan
area, Red Hill Avenue Specific Plan (RHASP) area, Downtown
Commercial Core Specific Plan (DCCSP) area, The Market Place,
Ederle Center and construction of Accessory Dwelling Units (ADUs)
and transitional housing units within and/or outside of these areas.
F. That in preparation of the 2021-2029 Housing Element, City staff held
two (2) public workshops-, the first was held on November 10, 2020
and the second was held on May 11, 2021. The City also developed a
robust Community Engagement Plan which included a community
Resolution 21-86
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online survey, and social media posts, social media paid ads,
newspaper advertisements, mailings to all City residents and
stakeholders. Additional public meetings were held on August 17,
2021 and September 7, 2021 which provided additional opportunities
to gather additional public input-,
G. That on August 17, 2021 the City Council held a public hearing and an
amendment was made to the Housing Element which included the
addition of two (2) new potential housing sites and a subsequent
revision to the City's Sites Inventory based upon public comments-,
H. 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.
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 2021-0002, at
which hearing, members of the public were afforded an opportunity to
comment upon the project. At the conclusion of the public hearing,
the Planning Commission adopted Resolution No. 4439
recommending that the City Council adopt a Negative Declaration for
General Plan Amendment 2021-0002.
J. On January 16, 2001, the City of Tustin certified the Program Final
Environmental Impact Statement/Envi ron mental Impact Report
(FEIS/EIR) for the reuse and disposal of MCAS Tustin. On December
6, 2004, the City Council adopted Resolution No. 04-76 approving a
Supplement to the FEIS/EIR for the extension of Tustin Ranch Road
between Walnut Avenue and the future alignment of Valencia North
Loop Road. On April 3, 2006, the City Council adopted Resolution No.
06-43 approving an Addendum to the FEIS/EIR. And, on May, 13,
2013, the City Council adopted Resolution No. 13-32 approving a
second Addendum to the FEIS/EIR. On July 5, 2017, the City
Council adopted Resolution No. 17-23 approving a second
Supplement to the FEIS/EIR. The FEIS/EIR along with its Addenda
and Supplements is a program EIR under the California Environmental
Quality Act (CEQA). The FEIS/EIR, Addenda and Supplements
considered the potential environmental impacts associated with
development on the former MCAS, Tustin.
K. That on November 6, 2018, the City of Tustin certified the Final
Program Environmental Impact Report (EIR) for the RHASP and
Resolution 21-86
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considered the potential environmental impacts associated with
development.
L. That on July 3, 2018, the City of Tustin certified the Final Program
Environmental Impact Report (EIR) for the DCCSP and considered
the potential environmental impacts associated with development.
M. That the proper amendments to the Zoning Map and Specific Plan
would be required following adoption of the Housing Element Update
to include a zoning overlay over The Market Place and Enderle
Center RHNA housing sites, which would allow for residential
development in these areas. Potential impacts that could result from
proposed amendments would be evaluated under a separate CEQA
review process.
N. That any development proposed as a result of the Housing Element
Update would also be required to obtain City approval on a project -
by -project basis for any discretionary action and undergo a separate
environmental process to assess potential environmental impacts.
0. That mitigation measures that are required by underlying Program
EIR's for the Tustin Legacy, RHASP and DCCSP areas would be
implemented as development is proposed.
P. That a Notice of Intent to Adopt a Negative Declaration was filed with
the Clerk of the County of Orange for posting, and provided to
members of the public using a method permitted under CEQA
Guidelines Section 15072(b). The Initial Study and Draft Negative
Declaration were made available for a 30 -day public review and
comment period from August 24, through September 23, 2021, in
compliance with Sections 15072 and 15105 of the State CEQA
Guidelines.
Q. That the City Council conducted a duly noticed public hearing on
October 5, 2021, to consider Resolution No. 21-86 for the Negative
Declaration prepared for GPA 2021-0002 at which hearing, members
of the public were afforded an opportunity to comment upon the
project.
R. That the City Council considered the Initial Study and the Negative
Declaration (Exhibit A) and finds it to be adequate for General Plan
Amendment 2021-0002.
11. The City Council does hereby find that the proposed project is within the
scope of the Final EIS/EIR for the Disposal and Reuse of MCAS Tustin
Resolution 21-86
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(Program EIS/EIR for MCAS -Tustin), the RHASP area and the DCCSP area
which are previously approved and certified EIRs within the City. Each
respective EIR adequately describes the general environmental setting of
where additional residential units can be placed which, in turn, coincides with
the City's distribution of units and specific allocation.
111. The City Council hereby adopts the Negative Declaration attached hereto
as Exhibit A, incorporating herein by reference all of the applicable mitigation
measures identified in the Program EIS/EIR for MCAS -Tustin, the RHASP
area and that DCCSP area.
PASSED AND ADOPTED at a regular meeting of the Tustin City Council held on
the 5 th day of October, 2021.
e—DocuSigned by:
L E T IW'44LARK1,
Mayor
ATTEST:
,DocuSigned by:
f,vi(A dmu-JA
E R I S -r",- 1) N � 6 Y5A&U DA,
City Clerk
Resolution 21-86
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STATE OF CALIFORNIA
COUNTY OF ORANGE SS
CITY OF TUSTIN
1, Erica N. Yasuda, City Clerk and ex -officio Clerk of the City Council of the City of Tustin,
California, do hereby certify that the whole number of the members of the City Council of
the City of Tustin is five-, that the above and foregoing Resolution No. 21-86 was duly
passed and adopted at a regular meeting of the Tustin City Council, held on the 5 th day of
October, 2021, by the following vote:
COUNCILMEMBER AYES: Clark, Lumbard, Gallaciher, Gomez (4)
COUNCILMEMBER NOES: (0)
COUNCILMEMBER ABSTAINED: (0)
COUNCILMEMBER ABSENT: Cooper (1)
DocuSigned by:
E R I 63A -A, m 4,As Ui D A,
City Clerk
Attachment'.
1. Exhibit A- Initial Study/Negative Declaration for Housing Element 2021-2029
Update
Resolution 21-86
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T u S- T I N
CITY OF TUSTIN
COMMUNITY DEVELOPMENT DEPARTMENT
300 Centennial Way, Tustin, CA 92780
(714) 573-3100
EU I WING OUR FUTIUKI INITIAL STUDY / NEGATIVE DECLARATION
HONORING OUR PAST CITY OF TUSTIN GENERAL PLAN
DRAFT HOUSING ELEMENT 2021-2029
GENERAL PLAN UPDATE
July 2021
A. BACKGROUND
Project Title:
Lead Agency:
Contact Person and phone number:
Project Location:
Project Sponsor's Name and Address
General Plan Land Use Designation
Zoning Designation:
Page 11
Housing Element Update 2021-2029
City of Tustin, 300 Centennial Way, Tustin,
California 92780
Erica H. Demkowicz, AICP, Senior Planner
(714) 573-3127
EDemkowicz@tustinca.org
City of Tustin
City of Tustin, 300 Centennial Way, Tustin,
California 92780
The City supports a variety of land uses as included
in the City's General Plan Land Use Map (2018).
Housing sites identified to support the 2021
Regional Housing Needs Allocation (RHNA) are
designated with the following land uses:
TLSP — Tustin Legacy Specific Plan
RHASP — Red Hill Avenue Specific Plan
DCCSP — Downtown Commercial Core Specific
Plan
PCCB - Planned Community Commercial/Business
The City supports a variety of zone designations as
included in the City's City Zoning Map (2018). RHNA
housing sites are within the following zoning
designations:
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INITIAL STUDY
City of Tustin
SP 1 —Tustin Legacy
SP 8 — East Tustin
SP 13 — Red Hill Avenue
SP 12 — Downtown Commercial Core
DA -2 — Development Area 2
DA -3 — Development Area 3
DA -4 — Development Area 4
DA -6 — Development Area 6
PC COM - Planned Community Commercial
Project Description: The project is a General Plan Update (GPU) to
the City of Tustin (City) Housing Element for the
Sixth Cycle planning period from October 15,
2021 to October 15, 2029. The Housing
Element, which is part of the City's General Plan
is a policy document designed to provide the
City a coordinated and comprehensive strategy
for promoting the production of housing to meet
existing and future housing needs.
Surrounding Land Uses and Setting
Tustin is surrounded by the cities of Santa Ana
to the west, Irvine to the east and south, and the
City of Orange and unincorporated County of
Orange area (i.e. North Tustin) to the north. The
jurisdictions are highly developed and mostly
residential in nature. The City of Irvine contains
an abundance of commercial and business
uses, as well as John Wayne Airport.
Other public agencies whose approval is required:
The City of Tustin. No other agency is required to approve the Housing Element update,
but it will be reviewed by the HCD for the purpose of determining whether it complies
with the requirements of the Housing Element Law.
Att.qrhmpnts-
Figure 1 : Regional Location Map
Figure 2: Suitable Sites for Additional Residential Development
Figure 3a- Site Identification to Meet RHNA
Figure 3b- Site Identification to Meet RHNA (continued)
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INITIAL STUDY City of Tustin
1 INTRODUCTION
1.1 PURPOSE OF THE INITIAL STUDY
This Initial Study has been prepared in accordance with the following:
• California Environmental Quality Act (CEQA) of 1970 (Public Resources Code
Sections 21000 et seq.); and
• California Code of Regulations, Title 14, Division 6, Chapter 3 (State CEQA
Guidelines, Sections 15000 et seq.) as amended and approved on December 28,
2018.
Pursuant to CEQA, this Initial Study has been prepared to analyze the potential for
significant impacts on the environment resulting from implementation of the 2021-2029
Tustin General Plan Housing Element Update. described in greater detail in Section 3.0
below. As required by State CEQA Guidelines ("Guidelines") Section 15063, this Initial
Study is a preliminary analysis prepared by the Lead Agency, the City of Tustin, in
consultation with other jurisdictional agencies, to determine if a Negative Declaration or
an Environmental Impact Report is required for the project.
This Initial Study informs City of Tustin decision -makers, affected agencies, and the public
of potentially significant environmental impacts associated with the implementation of the
project. A "significant effect" or "significant impact" on the environment means "a
substantial, or potentially substantial, adverse change in any of the physical conditions
within the area affected by the project" (Guidelines Section 15382).
Given the project's broad scope and level of detail, combined with previous analyses and
current information about the site and environs, the State's intent is to adhere to the
following CEQA principles:
• Provide meaningful early evaluation of site planning constraints, service and
infrastructure requirements, and other local and regional environmental
considerations. (Public Resources Code Section 21003.1)
• Encourage the incorporation of environmental considerations into project
conceptual ization, design, and planning at the earliest feasible time. (Guidelines
Section 15004[b][3])
• Specify mitigation measures for reasonably foreseeable significant environmental
effects and commit the City and applicant to future measures containing
performance standards to ensure their adequacy when detailed development
plans and applications are submitted. (Guidelines Section 15126.4)
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INITIAL STUDY City of Tustin
1.2 DOCUMENT ORGANIZATION
This Initial Study includes the following sections:
Section 1. Introduction
Provides information about CEQA and its requirements for environmental review and
explains that an Initial Study was prepared by the State of California to evaluate the
proposed project's potential impact to the physical environment, and to determine if a
Negative Declaration or an Environmental Impact Report (EIR) is required.
Section 2. Environmental Setting
Provides information about the proposed project's location.
Section 3. Project Description
Includes a description of the proposed project's physical features and characteristics.
Section 4. Environmental Checklist
Includes the Environmental Checklist from the CEQA Guidelines and evaluates the
proposed project's potential to result in significant adverse effects to the physical
environment and identifies if an EIR is required, and if one is, what environmental topics
need to be analyzed in the EIR.
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INITIAL STUDY City of Tustin
2 ENVIRONMENTAL SETTING
2.1 PROJECT LOCATION
The project site is located in central Orange County, within the City of Tustin (see Figure
1). The City of Tustin is surrounded by the Cities of Orange to the north, Santa Ana to the
west, Irvine to the south, and the Santa Ana Mountains to the east. Tustin is approximately
30 miles southeast of downtown Los Angeles and 40 miles southwest of downtown San
Bernardino. Regional access to the city is provided via Interstate 5 (1-5) and State Route
55 (SR -55). The City has identified 20 sites for RHNA allocation. Sites are located within
the Tustin Legacy Specific Plan, Red Hill Avenue Specific Plan, Downtown Commercial
Core Specific Plan, Enderle Center, and The Market Place.
2.2 EXISTING LAND USES
The City of Tustin encompasses approximately 11.12 square miles. The Land Use
Element provides for seven major land use groupings divided into 15 land use categories
or designations. Four of these designations are established for residential development,
ranging from low-density single family to high-density multiple family development. Three
commercial designations, one industrial, and one public/ institutional, are included. A
planned community designation, which includes residential, commercial/business, and
public institutional components, is also provided. The City also includes several specific
plan areas that include their additional land use designations and specification criteria.
2.3 SURROUNDING LAND USES
Tustin is surrounded by the cities of Santa Ana to the west, Irvine to the east and south,
and unincorporated County of Orange area (i.e. North Tustin) and Orange to the north.
The jurisdictions are highly developed and mostly residential in nature. The City of Irvine
contains an abundance of commercial and business uses, as well as John Wayne Airport.
2.4 EXISTING LAND USE AND ZONING
The City supports a variety of land uses as included in the City's General Plan Land Use
Map (2018). Housing sites identified to support the 2021 Regional Housing Needs
Allocation (RHNA) are designated with the following land uses:
• TLSP — Tustin Legacy Specific Plan
• RHASP — Red Hill Avenue Specific Plan
• DCCSP — Downtown Commercial Core Specific Plan
• PCCB — Planned Community Commercial/Business
Additionally, the City's Zoning Map (2018) includes the following zones underlying
identified housing sites:
• SP 1 — Tustin Legacy
• SP 8 — East Tustin
• SP 13 — Red Hill Avenue
• SP 12 — Downtown Commercial Core
o DA -2 — Development Area 2
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INITIAL STUDY City of Tustin
• DA -3 — Development Area 3
• DA -4 — Development Area 4
• DA -6 — Development Area 6
PC COM — Planned Community Commercial
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SANT
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INITIAL STUDY City of Tustin
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Figure 2
Suitable Sites for Additional,,*
Residential Development
.1* it
Suitable Site Locations
Downtown Commercial Core Specific Plan
Red Hill Avenue Specific Plan
122z] Tustin Legacy Specific Plan
V7,-, Enderle Center
Tustin Marketplace
Municipal Boundaries
N
= Mile
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INITIAL STUDY City of Tustin
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Downtown Commercial 'n � n
SITE IDENTIFICATION Core Specific Plan Figure )U
TO MEET RHNA
8 9 0 F1 FLO
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AL 01 r
12
6
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Tusfin Legacy, Specific Plan Red Hill Avenue
18 Specific Plan
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17
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INITIAL STUDY City of Tustin
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SITE IDENTIFICATION
TO MEET RHNA
of
N
igure 3b
Enderle Center (Site #19)
The Market Place
(Site #20)
�A
�A
N
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INITIAL STUDY City of Tustin
3 PROJECT DESCRIPTION
3.1 PROJECT OVERVIEW
In accordance with State Government Code Section 65580, the legislature has declared
that the attainment of decent housing and the provision of a suitable living environment
to meet the needs of all economic segments of the population are of the highest priority.
The legislature also recognizes that to meet the statewide goal, cooperation between
government and the private sector is necessary, and that local and State governments
have a responsibility to utilize the powers vested in them to facilitate the development and
improvement of housing.
The Housing Element is one of the seven mandatory elements of the General Plan. State
law requires inclusion of a Housing Element in the General Plan in recognition of the role
that land use planning plays in the production of affordable housing. Tustin's General
Plan consists of the following six Elements:
• Conservation/Open Space/Recreation
• Growth Management
• Housing
• Land Use
• Noise/Circulation
• Public Safety
Specific requirements for data collection and analysis necessary to prepare the Housing
Element are set forth in Government Code Section 65583. The Government Code also
requires that each draft of the Housing Element be reviewed by the California Department
of Housing and Community Development (HCD) and that the Department's findings be
incorporated prior to adoption, or that specified findings be made in response to the
Department's comments.
The 2021-2029 Tustin General Plan Housing Element Update (HEU, Draft HEU) was
available for public review and comment from June 30, 2021 to July 30, 2021. The
document was also submitted to the HCD on June 30th and discussed preliminary
comments with the HCD on a call on August 12 th . The Draft HEU continues to be revised
to address public and HCD comment. The latest HEU document and information is
available on the City's website at https://www.tustinca.orq/Housing Element.
3.2 PROJECT DESCRIPTION
The proposed project is the 2021-2029 HEU. The purpose of the project is to ensure the
City establishes policies, procedures and incentives in its land use planning and
redevelopment activities that will result in the maintenance and expansion of the housing
supply to adequately accommodate households currently living and expected to live in
Tustin. It institutes policies that will guide City decision-making and establishes an action
program to implement housing goals through 2029. Sections included in the HEU are
summarized in Table 3-1, Summary of 2021-2029 Housing Element.
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INITIAL STUDY City of Tustin
Table 3-1: Summary of 2021-2029 Housing Element
Section
Summary
1. Introduction to
A background and introduction to contents included in the HEU for the
the Housing
2021-2029 planning period.
Element:
11. Summary of
An analysis of identified housing needs within the city, which includes
Issues, Needs,
a breakdown by special needs groups and other demographics, as
Constraints
well as an examination of the constraints that could hinder the City's
and
achievement of its objectives and the resources that are available to
Opportunities
assist in the provision of housing.
111. Housing
City goals, policies, and actions related to housing being adopted into
Element Goals
the City's General Plan for implementation during the planning period.
and Policies
IV. Housing
Existing and new housing programs to be implemented during the
Implementation
planning period in execution of identified housing goals and policies.
Programs
Appendix A — Review
A review of the continued progress in implementation, the
of Past Performance
effectiveness of the Housing Element, and the appropriateness of the
City's housing goals adopted in the HEU.
Appendix B — Housing
Identification of sites that, in total, can achieve Tustin's assigned 2021
Sites Inventory
RHNA by income level for the planning period (2021 — 2029).
Assessment
Appendix C —
Funding sources for a wide variety of major housing assistance
Affordable Housing
programs available that can assist in meeting the City's housing
Resources
needs.
Appendix D —
A summary of fair housing issues in the City of Tustin and an
Affirmatively
assessment of the jurisdiction's fair housing enforcement, outreach,
Furthering Fair
potential impediments, and commitments.
Housing
Appendix E — Public
A summary of community engagement and outreach conducted as
Participation
part of the entire HEU process.
(Community
Engagement Plan)
Appendix F —
Studies, plans, and documents referenced in development of the
References
HEU.
State Housing Law requires that each jurisdiction establish the maximum number of
housing units that will be constructed, rehabilitated, and preserved over the planning
period, or the quantified objective. Consistent with state law, the Tustin HEU provides a
plan to accommodate the City's fair share of affordable housing known as the Regional
Housing Needs Allocation, or RHNA. The RHNA is allocated to each region of the state
by HCD in consultation with regional council of governments, which is the Southern
California Association of Governments (SCAG) for the Southern California region.
RHNA allocated to the City of Tustin includes a total of 6,782 housing units with the
following breakdown by income category:
0 1,724 very low-income units-,
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INITIAL STUDY City of Tustin
0 1,046 low-income units-,
0 1,132 moderate -income units-, and
0 2,880 above moderate -income housing units.
As conveyed in Table 3-2, Sites to Meet RHNA Estimated Income Distribution, there are
a total of 658 housing units that are captured from approved/entitled, pending and
permitted (projects under construction). There are 532 units in three projects with a total
of 132 extremely very -low-income transitional housing units (7 units proposed at the
House of Ruth and 125 units proposed at the Village of Hope transitional housing
facilities) and 400 above -moderate income housing units that were approved/entitled at
the time of the preparation of the HEU (located within TLSP Neighborhood D South).
Additionally, there is one pending mixed-use project proposed with a total of 137 housing
units (6 very -low-income and 131 above -moderate -income). This project is currently
under review and anticipates a second reading to City Council in Fall 2021. In addition,
35 ADUs or JADUs are projected to be constructed during the 2021-2029 planning period.
Among other things, the Housing Element establishes the City's strategy to plan for and
facilitate the development of housing over the eight-year planning period. It is required
by Housing Element Law. Expectations are to provide an inventory of land adequately
zoned or planned to be zoned for housing and programs to implement the strategy. The
City analyzed and assessed a number of sites and areas throughout the community
based on these above-mentioned parameters as well as other considerations. While
many sites were considered, 20 sites, two facilities, and one site category have been
identified for Tustin's qualifying sites to accommodate RHNA. The City Zoning Code and
map would be amended to accommodate two of the sites proposed, Enderle Center and
The Market Place, to provide a housing overlay for the provision of residential
development. Zoning would be updated following adoption of the HEU.
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I 101111 FWA 11110"1111,1111 IN
Table 3-2: Sites to Meet RHNA Estimated Income Distribution
City of Tustin
Note: Percentage of total Very Low- and Low -Income units on vacant land is 75 percent.
Source: 2021 RHNA, SCAG
Page 117
Vacantor
Units Very
Units Low
Units
Units Above
Site Reference
Non -Vacant
Capacity
Low Income
Income
Moderate
Moderate
Income
Income
TLSP - Neighborhood D
North (includes rezone)
Vacant
1,461
105
66
72
187
(Site 1A)
TLSP - Neighborhood D
Vacant
1,296
314
218
244
620
- South (Site 1 B)
TLSP - Neighborhood G
Vacant
2,029
526
352
383
968
(Site 2)
RHASP (Sites 3 - 6)
1 Vacant
500
124
79
83
214
3 Non -Vacant
DCCSP (Sites 7 - 16)
4 Vacant
747
187
117
125
318
5 Non -Vacant
Enderle Center (Site 19)
Non -Vacant
413
102
67
69
175
The Market Place (Site
Non -Vacant
900
225
141
150
384
20)
Projected ADU & JADUs
35
9
6
6
14
Entitled
132
132
0
0
0
-Transitional -
Preservation of At -Risk of
Existing
-
-
-
-
-
Market Rate
RHNA
6,782
1,724
1,046
1,132
2,880
Assigned Distributions
6,782
1,724
1,046
1,132
3,280
Achieved
Assigned Distributions
Achieved with 20% Buffer
8.138
-
-
-
-
(within TLSP
Neighborhood G)
Note: Percentage of total Very Low- and Low -Income units on vacant land is 75 percent.
Source: 2021 RHNA, SCAG
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INITIAL STUDY City of Tustin
Future residential development in the City of Tustin will take place primarily in five distinct
parts of the city and within three Specific Plan areas-, Tustin Legacy Specific Plan (TLSP)
(formerly the MCAS Tustin Reuse Specific Plan), Downtown Commercial Core Specific
Plan (DCCSP),Red Hill Avenue Specific Plan (RHASP), Enderle Center and The Market
Place. These five areas are located in different areas of the City and are described below:
Tustin Leciacy Specific Plan (TILSP) Area
Tustin Legacy contains two neighborhoods where residential housing sites will be
concentrated for this planning period- Neighborhood D and Neighborhood G. The land is
vacant. The zoning for Tustin Legacy is SP 1 and the General Plan designation is TLSP.
Neighborhood D has a total of 84.73 acres and is divided into two areas- South (44.86
acres) and North (39.87 acres). Sites within Tustin Legacy do not have a density
prescribed to the planning area per the TLSP-1 however, there is a development cap
placed on several of the planning areas. Therefore, a default density of 30 units per acre
was applied for areas within the cap limit. A total of 4,786 units have been allocated to
this area.
Red Hill Avenue Specific Plan (RHASP) Area
The RHASP was adopted in 2018. The RHASP area consists of approximately 52 acres
centrally located within the city. It is primarily a commercial and retail corridor that is prime
for revitalization. With the Specific Plan, mixed-use residential is permitted. The RHASP
provides a unique Residential Allocation Reservation (RAR) which is approved either by
the Community Development Director or the Planning Commission/City Council, as
applicable. The RAR is the mechanism with an associated process and timeline that
allocates units to a requested development. The units are drawn from a residential
allocation bank which assigns units by area and allows for transferability between areas.
The maximum density on an individual parcel may exceed 25 dwelling units per acre (the
General Plan's maximum density) as long as the total dwelling units allocated to the
Specific Planning Area is not exceeded. Therefore, a default density of 30 units per acre
is achievable in the RHASP area. The Zoning is SP 13 and the General Plan designation
is RHASP. The maximum allowable building height for residential mixed-use development
in the RHASP is 4 stories/50 feet. Four sites within the RHASP area have been identified
as relevant sites to meet RHNA. A total of 500 residential units have been allocated to
this area.
This site also has a pending mixed-use project which was approved on August 18, 2021
by the Tustin City Council. The pending project includes 137 units (114 base density units
plus 20% density bonus), of which 131 are market -rate and six are designated affordable
to very low-income households.
Downtown Commercial Core Specific Plan (DCCSP) Area
The Downtown Commercial Core Specific Plan was adopted in 2018 and is centered
around the intersection of Main Street and El Camino Real in Old Town. The DCCSP
consists of approximately 220 acres located in the northern and western portion of the
City.
This area was not previously zoned to accommodate residential development. With the
adoption of the DCCSP, the area now allows residential development (primarily mixed -
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use residential). Since Specific Plan adoption, 140 residential units have been developed,
and 747 allocated units remain. The DCCSP also provides the RAR which is approved
either by the Current housing bank allocations which include 45 units to Development
Area 1, 92 units to Development Area 2, 200 units to Development Area 3, 150 -units to
Development Area 4 and, 260 units to Development Area 6.
The maximum density on an individual parcel may exceed 25 dwelling units per acre (the
General Plan's maximum density) as long as the total dwelling units allocated to the
Specific Plan area is not exceeded. Therefore, a default density of 30 units per acre is
achievable in the DCCSP area. The Zoning is SP 12 and the General Plan designation is
DCCSP. The maximum allowable building height ranges from two to five stories,
depending on Development Area and adjacent land uses.
None of the DCCSP sites were identified in either of the past two planning cycles as
vacant land available for housing to meet RHNA. A total of 747 residential units have
been allocated to this area.
Enderle Center
The Enderle Center is a commercial center located to the east of State Route (SR) 55
and south of 17 1h Street. The site includes existing commercial uses and could be
developed to include mixed use development in the future that would support residential
uses. The site is zoned as PC COM (Planned Community Commercial) and designated
as PCCB (Planned Community Commercial/Business) land use. Zoning would be
amended to include a housing overlay on the site in order to allow for future residential
development. Density has not been established for this area and would be established
with the adoption of the planned community. A total of 413 residential units have been
allocated to this area.
The Market Place/East Tustin Specific Plan (ETSP)
The Market Place is a commercial center located north of the 1-5 freeway at Jamboree
Road and is divided between the City of Irvine and the City of Tustin. The Tustin portion
of the commercial center is located on the west side of Jamboree Road between Bryan
Avenue and the 1-5 freeway and the City of Irvine portion is located on the east side of
Jamboree Road. The site includes existing commercial uses and could be developed to
include mixed use development in the future that would support residential uses. The site
is in the East Tustin Specific Plan Area (SP -8) and zoned as PC COM (Planned
Community Commercial) and designated as PCCB (Planned Community
Commercial/Business) land use. According to the ETSP, the allowable uses for this area
include business and employment. Zoning would be amended to include a housing
overlay on the site in order to allow for future residential development. Density has not
been established for this area and would be established with the adoption of the planned
community. A total of 900 residential units have been allocated to this area.
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3.3 DISCRETIONARY ACTION REQUESTED
The City of Tustin are expected to use the information contained in this Initial Study for
consideration of approvals related to and involved in the implementation of this project.
These include, but may not be limited to, the permits and approvals described below.
As part of the proposed project, the following discretionary actions are required:
• Adoption of Negative Declaration (City of Tustin City Council)
• Adoption of Housing Element
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4 ENVIRONMENTAL CHECKLIST
4.1 BACKGROUND
Project Title:
City of Tustin General Plan 2021-2029 Housing Element
Lead Agency:
City of Tustin
300 Centennial Way
Tustin, CA 92780
Lead Agency Contact:
Erica H. Demkowicz, Senior Planner
(714) 573-3127
Project Location:
The project site is located in Tustin, California.
Project Sponsor Contact:
City of Tustin; Erica H. Demkowicz, Senior Planner
(714) 573-3127
General Plan and Zoning Designation: Tustin supports a variety of land use and
zoning designations, including residential, commercial, industrial, and public/
institutional.
Project Description: The City of Tustin proposes to update the General Plan Housing
Element to include plans and policies that will cover the timeframe of 2021-2029 Plan,
in compliance with California Government Code Section 65580 et. seq..
Surrounding Land Uses and Setting:
Tustin is surrounded by the cities of Santa Ana to the west, Irvine to the east and south,
and unincorporated County of Orange area (i.e. North Tustin) and Orange to the north.
The jurisdictions are highly developed and mostly residential in nature. The City of
Irvine contains an abundance of commercial and business uses, as well as John
Wayne Airport.
Other Public Agencies Whose Approval is Required:
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No other agency is required to approve the HEU, but it will be reviewed by the HCD for
the purpose of determining whether it complies with the requirements of the Housing
Element Law.
4.2 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The subject areas checked below were determined to be new significant environmental
effects or to be previously identified effects that have a substantial increase in severity
either due to a change in project, change in circumstances or new information of
substantial importance, as indicated by the checklist and discussion on the following
pages.
F-1
Aesthetics
E]
Agriculture & Forest
E]
Air Quality
Resources
F-1
Biological Resources
Cultural Resources
E]
Energy
F-1
Geology /Soils
El
Greenhouse Gas
El
Hazards &
Emissions
Hazardous Materials
E]
Hydrology / Water
El
Land Use / Planning
E]
Mineral Resources
Quality
F-1
Noise
Population
El
Public Services
Housing
F-1
Recreation
Transportation
El
Tribal Cultural
Resources
F-1
Utilities / Service
El
Wildfire
E]
Mandatory Findings
Systems
of Significances
4.3 DETERMINATION:
On the basis of this initial evaluation
I find that the proposed project COULD NOT have a significant effect on the
environment, and a NEGATIVE DECLARATION will be prepared.
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El I find that although the proposed project could have a significant effect on the
environment, there will not be a significant effect in this case because revisions
in the project have been made by or agreed to by the project proponent. A
MITIGATED NEGATIVE DECLARACTION will be prepared.
F-1 I find that the proposed project MAY have a significant effect on the environment,
and an ENVIRONMENTAL IMPACT REPORT is required.
F-1 I find that the proposed project MAY have a "potentially significant" or "potentially
significant unless mitigated" impact on the environment, but at least one effect
1) has been adequately analyzed in an earlier analysis pursuant to applicable
legal standards, and 2) has been addressed by mitigation measures based on
the earlier analysis as described on attached sheets. An ENVIRONMENTAL
IMPACT REPORT is required, but it must analyze only the effects that remain
to be addressed.
F-1 I find that although the proposed project could have a significant effect on the
environment, because all potentially significant effects (a) have been analyzed
adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to
applicable standards, and (b) have been avoided or mitigated pursuant to that
earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation
measures that are imposed upon the proposed project, nothing further is
req u i red.
Signature Date
Name and Title Lead Agency
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4.4 EVALUATION OF ENVIRONMENTAL IMPACTS
1 A brief explanation is required for all answers except "No Impact" answers that are adequately
supported by the information sources a lead agency cites in the parentheses following each
question. A "No Impact" answer is adequately supported if the referenced information sources show
that the impact simply does not apply to projects like the one involved (e.g., the project falls outside
a fault rupture zone). A "No Impact" answer should be explained where it is based on project -
specific factors as well as general standards (e.g., the project will not expose sensitive receptors
to pollutants, based on a project -specific screening analysis).
2) All answers must take account of the whole action involved, including offsite as well as on-site,
cumulative as well as project -level, indirect as well as direct, and construction as well as operational
impacts.
3) Once the lead agency has determined that a particular physical impact may occur, then the
checklist answers must indicate whether the impact is potentially significant, less than significant
with mitigation, or less than significant. "Potentially Significant Impact" is appropriate if there is
substantial evidence that an effect may be significant. If there are one or more "Potentially
Significant Impact" entries when the determination is made, an EIR is required.
4) "Negative Declaration: Potentially Significant Unless Mitigation Incorporated" applies where the
incorporation of mitigation measures has reduced an effect from "Potentially Significant Impact" to
a "Less Significant Impact." The lead agency must describe the mitigation measures, and briefly
explain how they reduce the effect to a less than significant level (mitigation measures from "Earlier
Analysis," as described in (5) below, may be cross-referenced).
5) Earlier analysis may be used where, pursuant to the tiering, program EIR, or other CEQA process,
an effect has been adequately analyzed in an earlier EIR or negative declaration. Guidelines
Section 15063 (c)(3)(d). In this case, a brief discussion should identify the following:
(a) Earlier Analysis Used. Identify and state where they are available for review.
(b) Impacts Adequately Addressed. Identify which effects from the above checklist were within
the scope of and adequately analyzed in an earlier document pursuant to applicable legal
standards, and state whether such effects were addressed by mitigation measures based
on the earlier analysis.
(c) Mitigation Measures. For effects that are "Less than Significant with Mitigation Measures
Incorporated," describe the mitigation measures which were incorporated or refined from
the earlier document and the extent to which they address site-specific conditions for the
project.
6) Lead agencies are encouraged to incorporate into the checklist references to information sources
for potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared
or outside document should, where appropriate, include a reference to the page or pages where
the statement is substantiated.
7) Supporting Information Sources: A source list should be attached, and other sources used, or
individuals contacted should be cited in the discussion.
8) This is only a suggested form, and lead agencies are free to use different formats; however, lead
agencies should normally address the questions from this checklist that are relevant to a project's
environmental effects in whatever format is selected.
9) The analysis of each issue should identify: (a) the significance criteria or threshold used to evaluate
each question; and (b) the mitigation measure identified, if any, to reduce the impact to less than
significance.
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5 ENVIRONMENTAL ANALYSIS
This section provides evidence to substantiate the conclusions in the environmental checklist.
4.5 AESTHETICS
Would the project: Potentially Less Than Less Than No Impact
Significant Significant Significant
Impact with Impact
Mitigation
Incorporat
ed
a) Have a substantial adverse effect on a scenic E] El El
Vista?
b) Substantially damage scenic resources, E] El El
including, but not limited to, trees, rock
outcroppings, and historic buildings within a state
scenic highway?
c) In nonurbanized areas, substantially degrade the E] El El H
existing visual character or quality of public views of
the site and its surroundings? (Public views are
those that are experienced from publicly accessible
vantage point). If the project is in an urbanized area,
would the project conflict with applicable zoning and
other regulations governing scenic quality?
d) Create a new source of substantial light or glare El El El
which would adversely affect day or nighttime views
in the area?
a. Have a substantial adverse effect on a scenic vista?
No Impact. Scenic vistas consist of expansive, panoramic views of important, unique, or
highly valued visual features that are seen from public viewing areas. This definition
combines visual quality with information about view exposure to describe the level of
interest or concern that viewers may have for the quality of a particular view or visual
setting. A scenic vista can be impacted in two ways- a development project can have
visual impacts by either directly diminishing the scenic quality of the vista or by blocking
the view corridors or "vista" of the scenic resource. Important factors in determining
whether a proposed project would block scenic vistas include the project's proposed
height, mass, and location relative to surrounding land uses and travel corridors.
The City's General Plan identifies scenic resource areas in the Conservation/Open
Space/Recreation Element. As new development is considered by City decision makers,
public views should be preserved as much as possible. Consideration will be given to
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protecting public views along the ridge lines, views toward the inland mountains (Santa
Ana Mountains), and along scenic transportation corridors. Figure COSR-4 of the General
Plan Conservation/Open Space/Recreation Element conceptually identifies significant
public scenic resources in Tustin. Many of the City's major arterial roadways and freeway
buffers have been identified as existing landscape corridor or proposed landscape
corridor strengthen ing/freeway edge landscape buffering, including roadways adjacent to
proposed RHNA sites, such as the 1-5 corridor, Jamboree Road, and Newport Avenue.
Several policies and programs have been established through the General Plan to protect
views of scenic resources within the city. Program 35, Protect Scenic Views and
Resources establishes that "Through the Hillside Review process, monitor and limit
development of Peters Canyon Ridgeline consistent with the requirements of the East
Tustin Specific Plan, Grading and Excavation Code and Grading Manual."' Additionally,
Policy 1.14 of the General Plan Conservation/Open Space/Recreation Element
specifically instructs the City to "Enhance the important role that streetscapes play in
defining the character of the City by expanding street planning and design procedure to
include aesthetic and environmental concerns, as well as traffic considerations. Develop
a circulation system which highlights environmental amenities and scenic areas.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential scenic resource impacts would be
evaluated on a site -by -site basis and mitigation measures, if necessary, would be
implemented to reduce significant impacts. Additionally, all future projects would be
required to comply with applicable Federal, State, and local policies and regulations
established to protect scenic resources. Where applicable, existing zoning regulations
require development setbacks that would ensure that new development would not
encroach into roadway corridors. The RHASP and DCCSP both provide a unique
Residential Allocation Reservation (RAR) which is approved either by the Community
Development Director or the Planning Commission/City Council, as applicable. The RAR
is the mechanism with an associated process and timeline that allocates units to a
requested development. Development would be reviewed as consistent with City
objectives during the RAR review process for Specific Plan areas that do not have existing
development standards (DCCSP and RHASP). Generally, all development within the
RHNA designated sites (outside of designated SP areas) would be reviewed to ensure
compliance with applicable Federal, State and local policies and regulations established
to protect scenic resources. Therefore, the project would result in no impact.
b. Substantially damage scenic resources, including, but not limited to, trees,
rock outcroppings, and historic buildings within a state scenic highway?
1 City of Tustin Grading Manual (1990) available at-
https://www.tustinca.org/DocumentCenter/View/5029/Grading-Manual-June-1 990
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No Impact. There are no officially designated State scenic highways within the City. The
closest Eligible State Scenic Highway according to the California Department of
Transportation (Caltrans) is a portion of SR -91, located approximately six miles north of
the city. Tustin is not visible from the highway. Therefore, the project would result in no
impacts on a scenic resource within a state scenic highway.
c. In nonurbanized areas, substantially degrade the existing visual character
or quality of public views of the site and its surroundings? (Public views are
those that are experienced from publicly accessible vantage point). If the
project is in an urbanized area, would the project conflict with applicable
zoning and other regulations governing scenic quality?
No Impact. The city is generally a developed urbanized area. The City supports a variety
of land uses as included in the City's General Plan Land Use Map (2018). Housing sites
identified to support the 2021 RHNA are designated with the following land uses:
• TLSP — Tustin Legacy Specific Plan
• RHASP — Red Hill Avenue Specific Plan
• DCCSP — Downtown Commercial Core Specific Plan
• PCCB — Planned Community Commercial/Business
Additionally, the City's Zoning Map (2018) includes the following zones underlying
identified housing sites:
• SP 1 —
Tustin Legacy
• SP 8 —
East Tustin
• SP 13
— Red Hill Avenue
• SP 12
— Downtown Commercial Core
• DA -2 — Development Area 2
• DA -3 — Development Area 3
• DA -4 — Development Area 4
• DA -6 — Development Area 6
PC COM — Planned Community Commercial
All zoning designations, with the exception of PC COM (Planned Community Commercial)
and SP 8 (East Tustin), encourage mixed-use development and allow for residential uses.
The RHASP and DCCSP both provide a unique RAR which is approved either by the
Community Development Director or the Planning Commission/City Council, as
applicable. The RAR is the mechanism with an associated process and timeline that
allocates units to a requested development. The units are drawn from a residential
allocation bank which assigns units by area and allows for transferability between areas.
Sites within TLSP do not have a density prescribed to the entire specific plan area-,
however, there is a development cap placed on several of the planning areas.
Development would be reviewed as consistent with City objectives during the RAR review
process for Specific Plan areas that do not have existing development standards.
The HEU would not directly result in changes to land use or zoning designations. The
City's Zoning Code would be updated following adoption of the HEU to include a housing
overlay over The Market Place and Enderle Center RHNA housing sites, which would
allow for the development of residential in these areas. Proposed RHNA sites designated
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as PC COM (Planned Community Commercial) and SP 8 (East Tustin) are in existing
developed areas. Potential impacts that could result from proposed Zoning Code changes
would be evaluated under a separate CEQA review process.
The HEU is a policy document, consisting of a housing program, and its adoption would
not, in itself, produce environmental impacts. Development proposed as a result of the
HEU would be required to obtain City approval on a project -by -project basis for any
discretionary action, such as approval of a grading permit, and undergo a separate
environmental process to assess potential air quality impacts. Therefore, the HEU would
result in no impact.
d. Create a new source of substantial light or glare which would adversely
affect day or nighttime views in the area?
No Impact. The HEU does not directly propose any development. However,
implementation of the programs contained in the HEU would accommodate development
required to meet the City's RHNA. Any new development proposed on the 20 sites, which
include vacant and nonvacant areas, would introduce new sources of light from new
building security lighting, streetlights, interior lights shining through building windows, and
headlights from nighttime vehicular trips generated from new development. As discussed
above, although some of the RHNA sites are vacant, they are surrounded by urban uses
and major thoroughfares.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential light or glare impacts would be evaluated
on a site -by -site basis and mitigation measures, if necessary, would be implemented to
reduce significant impacts. Additionally, all future projects would be required to comply
with applicable local policies and regulations and would be reviewed by the City to ensure
that light and glare would not impact day or nighttime views. Therefore, the project would
result in no impact.
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4.6 AGRICULTURE AND FOREST RESOURCES
City of Tustin
In determining whether impacts to agricultural Potentially
Less Than Less Than No Impact
resources are significant environmental effects, lead Significant
Significant Significant
agencies may refer to the California Agricultural Impact
with Impact
Land Evaluation and Site Assessment Model (1997)
Mitigation
prepared by the California Dept. of Conservation as
Incorporate
an optional model to use in assessing impacts on
d
agriculture and farmland. In determining whether
impacts to forest resources, including timberland,
are significant environmental effects, lead agencies
may refer to information compiled by the California
Department of Forestry and Fire Protection
regarding the state's inventory of forest land,
including the Forest and Range Assessment Project
and the Forest Legacy Assessment Project; and the
forest carbon measurement methodology provided
in Forest Protocols adopted by the California Air
Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or 0 El El H
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the
California Resources Agency, to non-agricultural
use?
b) Conflict with existing zoning for agricultural use, 0 El El
or a Williamson Act contract?
c) Conflict with existing zoning for, or cause rezoning 0 El El
of, forest land (as defined in Public Resources Code
section 12220(g)), timberland (as defined by Public
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g))?
d) Result in the loss of forest land or conversion of 0 El El H
forest land to non -forest use?
e) Involve other changes in the existing environment 0 El El
which, due to their location or nature, could result in
conversion of Farmland, to non-agricultural use or
conversion of forest land to non -forest use?
a. Convert Prime Farmland, Unique Farmland, or Farmland of Statewide
Importance, as shown on the maps prepared pursuant to the Farmland
Mapping and Monitoring Program of the California Resources Agency, to
non-agricultural use?
No Impact. The State of California Department of Conservation's (CDOC) Farmland
Mapping and Monitoring Program is charged with producing maps for analyzing impacts
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on the state's agricultural resources. California's agricultural lands are rated based on soil
quality and irrigation status. For CEQA purposes, the following categories qualify as
"agricultural land"- Prime Farmland, Farmland of Statewide Importance, Unique
Farmland, Farmland of Local Importance, and Grazing Land.
The City does not currently include any commercial agricultural land uses. Existing zoning
in the City of Tustin does not currently allow for commercial agricultural uses. The
Residential Agricultural District (RA) allows for light agricultural uses incidental to single-
family residential use. Additionally, land within the city is almost entirely designated as
Urban and Built -Up Land and a portion of the TLSP area is designated as Other Land per
the CDOC Farmland Mapping and Monitoring Program.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential farmland impacts would be evaluated
on a site -by -site basis and mitigation measures, if necessary, would be implemented to
reduce significant impacts. Additionally, all future projects would be required to comply
with applicable local policies and regulations and would be reviewed by the City to ensure
that farmland impacts would not occur. Therefore, the project would result in no impact.
b. Conflict with existing zoning for agricultural use, or a Williamson Act
contract?
No Impact. The Williamson Act (California Land Conservation Act of 1965) restricts the
use of agricultural and open space lands to farming and ranching by enabling local
governments to contract with private landowners for indefinite terms in exchange for
reduced property tax assessments.
Tustin does not include any land that is currently under an active Williamson Act contract.
Therefore, development of the project would not result in the cancellation of the contract,
and impacts related to a Williamson Act contract would not occur and this topic will not
be evaluated in the EIR. Additionally, the HEU does not include goals, programs, or
policies that would directly conflict with existing zoning for agricultural use, or any potential
future Williamson Act contracts. Therefore, the project would result in no impact.
c. Conflict with existing zoning for, or cause rezoning of, forest land (as
defined in Public Resources Code section 12220(g)), timberland (as defined
by Public Resources Code section 4526), or timberland zoned Timberland
Production (as defined by Government Code section 51104(g))?
No Impact. "Forest land" is defined as "land that can support 10 percent native tree cover
of any species, including hardwoods, under natural conditions, and that allows for
management of one or more forest resources, including timber, aesthetics, fish and
wildlife, biodiversity, water quality, recreation, and other public benefits."2 "Timberland" is
defined as "land, other than land owned by the federal government and land designated
, California Public Resources Code Section 12220(g)
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by the board as experimental forest land, which is available for, and capable of, growing
a crop of trees of a commercial species used to produce lumber and other forest products,
including Christmas trees."3 "Timberland Production Zone" (TPZ) is defined as "an area
which has been zoned pursuant to Section 51112 or 51113 and is devoted to and used
for growing and harvesting timber, or for growing and harvesting timber and compatible
uses, as defined in subdivision (h)." The City of Tustin includes eucalyptus groves within
the hillside areas of the ETSP area.
Sites identified to accommodate RHNA housing development includes one site that falls
within the ETSP area-, however, the area where future housing is proposed is within a
completely developed area, The Market Place, that does not include forest land or
timberland land uses and would not directly or indirectly impact the existing eucalyptus
groves.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential forest land impacts would be evaluated
on a site -by -site basis and mitigation measures, if necessary, would be implemented to
reduce significant impacts. Additionally, all future projects would be required to comply
with applicable local policies and regulations and would be reviewed by the City to ensure
that forest land impacts would not occur. Therefore, the project would result in no impact.
d. Result in the loss of forest land or conversion of forest land to non -forest
use?
No Impact. As discussed above, the project does not propose development within an
area containing forest land. Therefore, the proposed project would not result in the loss
or conversion of forest land to non -forest use.
e. Involve other changes in the existing environment which, due to their
location or nature, could result in conversion of Farmland to non-
agricultural use or conversion of forest land to non -forest use?
No Impact. The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential farmland or forest land impacts would
be evaluated on a site -by -site basis and mitigation measures, if necessary, would be
implemented to reduce significant impacts. Additionally, all future projects would be
required to comply with applicable local policies and regulations and would be reviewed
by the City to ensure that farmland or forest land impacts would not occur. Therefore, the
project would result in no impact.
3 California Public Resources Code Section 4526
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4.7 AIR QUALITY
Where available, the significance criteria Potentially Less Than Less Than No Impact
established by the applicable air quality Significant Significant Significant
management or air pollution control district may be Impact with Impact
relied upon to make the following determinations. Mitigation
Would the project: Incorporat
ed
a) Conflict with or obstruct implementation of the El El El
applicable air quality plan?
b) Result in a cumulatively considerable net E] El El
increase of any criteria pollutant for which the project
region is non- attainment under an applicable
federal or state ambient air quality standard?
c) Expose sensitive receptors to substantial 0 F-1 F-1
pollutant concentrations?
d) Result in other emissions (such as those leading
to odors) adversely affecting a substantial number of
people?
a. Conflict with or obstruct implementation of the applicable air quality plan?
No Impact. The City of Tustin is located within the South Coast Air Basin (Basin). The
Basin includes all of Orange County and portions of Los Angeles, Riverside, and San
Bernardino Counties. Air quality within the Basin is under the jurisdiction of the South
Coast Air Quality Management District (SCAQMD) and the California Air Resources
Board (CARB). Standards for air quality within the Basin are documented in the
SCAQMD's Air Quality Management Plan (AQMP). The main purpose of an AQMP is to
describe air pollution control strategies to be taken by a city, county, or region classified
as a nonattainment area in order to bring the area into compliance with federal and State
air quality standards. SCAQMD's 2016 AQMP is based on regional growth forecasts for
the Southern California Association of Governments region. Whether the project would
exceed the growth assumptions in the AQMP is, in part, based on projections from local
general plans.
A project is consistent with the regional AQMP if it does not create new violations of clean
air standards, exacerbate any existing violations, or delay a timely attainment of such
standards. The HEU would not directly result in changes to land use or zoning
designations. The City's Zoning Code would be updated following adoption of the HEU to
include a housing overlay over The Market Place and Enderle Center RHNA housing
sites, which would allow for the development of residential in these areas. Potential
impacts that could result from proposed Zoning Code changes would be evaluated under
a separate CEQA review process. The HEU is a policy document, consisting of a housing
program, and its adoption would not, in itself, produce environmental impacts.
Development proposed as a result of the HEU would be required to obtain City approval
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on a project -by -project basis for any discretionary action, such as approval of a grading
permit, and undergo a separate environmental process to assess potential air quality
impacts. Therefore, the HEU would result in no impact.
b. Result in a cumulatively considerable net increase of any criteria pollutant
for which the project region is non -attainment under an applicable federal
or state ambient air quality standard (including releasing emissions which
exceed quantitative thresholds for ozone precursors)?
No Impact. The Basin is designated underthe California and National Ambient Air Quality
Standards (NAAQS) as nonattainment for ozone (03), coarse inhalable particulate matter
(PMlo), fine inhalable particulate matter (PM2.5), nitrogen oxides (NOx) (California
standard only), and lead (Los Angeles County only).
As discussed above, the HEU is a policy document, consisting of a housing program, and
its adoption would not, in itself, produce environmental impacts. However, implementation
of the programs contained in the HEU would accommodate development required to meet
the City's RHNA. The volume of air quality emissions generated by the new development
would depend on the specifics of the units constructed and the types of construction that
would occur. Development proposed as a result of the HEU would be required to obtain
City approval on a project -by -project basis for any discretionary action, such as approval
of a grading permit, and undergo a separate environmental process to assess potential
air quality impacts. For specific development projects, issues related to potential long -
and short-term emissions and impacts to air quality would be assessed at the time the
projects are proposed. Measures that are required by underlying Specific Plan EIRs, as
well as new measures specific to the development and reduce emissions would then be
adopted, as necessary. Therefore, the HEU would result in no impact.
c. Expose sensitive receptors to substantial pollutant concentrations?
No Impact. An impact is potentially significant if emission levels exceed the State or
Federal ambient air quality standards, thereby exposing sensitive receptors to substantial
pollutant concentrations. Sensitive receptors are locations where uses or activities result
in increased exposure of persons more sensitive to the unhealthful effects of emissions
(such as children and the elderly). City supports residential, school, park and other land
uses that include sensitive receptor populations. There is a school located within a RHNA
site identified within the TLSP area and several schools surrounding the other RHNA
housing sites.
The HEU consists of housing policies and programs designed to facilitate provision of
housing to meet State requirements. The HEU is a policy document that does not propose
site specific development and adoption of the HEU would not result in physical effects to
the environment. Future housing development implementing the HEU would be required
to obtain City approval on a project -by -project basis and would still be subject to all
existing City and State standards, including the development standards contained in the
Zoning Code. Furthermore, discretionary actions, such as approval of a development
permit or grading permit, would be subject to environmental review that would evaluate
the specific development proposal and the related air quality emission to ensure that the
project would not exceed SCAQMD thresholds. Measures that are required by underlying
Specific Plan EIRs, as well as new measures specific to the development would be
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adopted to reduce emissions that could expose sensitive receptors to substantial pollutant
concentrations as necessary. Therefore, the project would result in no impact.
d. Result in other emissions (such as those leading to odors) adversely
affecting a substantial number of people?
No Impact. The proposed project would not emit other emissions, such as those
generating objectionable odors, that would affect a substantial number of people. The
threshold for odor is identified by SCAQMD Rule 402, Nuisance, which states:
A person shall not discharge from any source whatsoever such quantities of air
contaminants or other material which cause injury, detriment, nuisance, or
annoyance to any considerable number of persons or to the public, or which
endanger the comfort, repose, health or safety of any such persons or the public,
or which cause, or have a natural tendency to cause, injury or damage to business
or property. The provisions of this rule shall not apply to odors emanating from
agricultural operations necessary for the growing of crops or the raising of fowl or
animals.
The HEU provides guidance for the future development of residential uses and does not
involve land uses that are typically associated with the creation of objectionable odors
(such as rendering plants, landfills, treatment plants, etc.). The HEU is a policy document,
and its adoption would not, in itself, produce environmental impacts. Future residential
project proposed to achieve the City's RHNA goals would be located on developed,
underutilized sites or on vacant parcels proposed and zoned for mixed use development.
Potential emission impacts would be evaluated on a site -by -site basis and mitigation
measures, if necessary, would be implemented to reduce significant impacts. Additionally,
all future projects would be required to comply with applicable local policies and
regulations and would be reviewed by the City to ensure that emission impacts would not
occur. Therefore, the project would result in no impact.
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4.8 BIOLOGICAL RESOURCES
City of Tustin
Would the project: Potentially Less Than Less Than No Impact
Significant Significant Significant
Impact with Impact
Mitigation
Incorporat
ed
a) Have a substantial adverse effect, either directly E] El El H
or through habitat modifications, on any species
identified as a candidate, sensitive, or special status
species in local or regional plans, policies, or
regulations, or by the California Department of Fish
and Game or U.S. Fish and Wildlife Service?
b) Have a substantial adverse effect on any riparian El El El
habitat or other sensitive natural community
identified in local or regional plans, policies,
regulations or by the California Department of Fish
and Game or US Fish and Wildlife Service?
c) Have a substantial adverse effect on state or E] El El
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.) through
direct removal, filling, hydrological interruption, or
other means?
d) Interfere substantially with the movement of any E] El El
native resident or migratory fish or wildlife species or
with established native resident or migratory wildlife
corridors, or impede the use of native wildlife
nursery sites?
e) Conflict with any local policies or ordinances E] El El
protecting biological resources, such as a tree
preservation policy or ordinance?
0 Conflict with the provisions of an adopted Habitat E] El El H
Conservation Plan, Natural Community
Conservation Plan, or other approved local,
regional, or state habitat conservation plan?
a — f. No Impact.
The City's Conservation/Open Space/Recreation Element of the General Plan Identifies
areas as "important natural resources" within Figure COSR-2. Since the natural resources
areas have been designated, new development has occurred throughout the city. Areas
identified as important natural resources are located at the northern and southern ends
of the city. Natural resources to the north include open space areas, Lower Peters Canyon
Retarding Basin, Eucalyptus Windrow, and Redwood Grove. This area also includes
Coastal Sage Scrub habitat. The natural habitats to the north support sensitive or
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endangered species such as the California Black -tailed Gnatcatcher, the San Diego
Cactus Wren, and the San Diego Coast Horned Lizard. Within southern Tustin,
agricultural land is identified as an important natural resource based on the CDOC's
previous designation of the land as important farmland. However, the area has since been
adopted into a specific plan (TLSP) and is no longer utilized for agricultural purposes.
Additionally, Peters Canyon is a predominant riparian feature within the city. Several
mitigation measures were adopted for Peters Canyon as part of the ETSP. These
mitigation measures continue to reflect City policy. For several years, the Lower Peters
4
Canyon Retarding Basin contained a small riparian habitat. This habitat has severely
deteriorated in recent years. The City works with the County of Orange, which recently
constructed a replacement dam, to preserve the riparian area and implement active
measures to increase water supply to restore the habitat area.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. One RHNA site is located in the ETSP-1 however,
the site is currently developed and is outside of areas containing sensitive biological
habitat. Potential biological resource impacts would be evaluated on a site -by -site basis
and mitigation measures, if necessary, would be implemented to reduce significant
impacts. Additionally, all future projects would be required to comply with applicable
Federal, State, and local policies and regulations established to protect biological species.
Therefore, the project would result in no impact.
4 City of Tustin General Plan Conservation/Open Space/Recreation Element, available at
https://www.tustinca.org/DocumentCenter/View/713/City-of-Tustin-General-Plan-
PnF?hiri1ri=
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4.9 CULTURAL RESOURCES
Would the project:
Potentially
Less Than
Less Than
No Impact
Significant
Significant
Significant
Impact
with
Impact
Mitigation
Incorporat
ed
a) Cause a substantial adverse change in the
E]
El
El
H
significance of a historical resource pursuant to
§15064.5?
b) Cause a substantial adverse change in the
E]
El
El
H
significance of an archaeological resource pursuant
to § 15064.5?
c) Disturb any human remains, including those El El El
interred outside of formal cemeteries?
a — c No Impact.
The City of Tustin contains several designated historic resources and resources of historic
age that could be eligible for designation. Tustin's historic preservation program was
established by Tustin City Code Section 9252 "Cultural Resources District," and is
supported by Residential Design Guidelines and Commercial Design Guidelines
established by the City. It is also supported by the Secretary of Interior's Standards for
5
the Treatment of Historical Properties. Together, these documents establish criteria and
procedures for the designation, preservation and maintenance of cultural resources
throughout the City of Tustin.
The City's Conservation/Open Space/Recreation Element of the General Plan Figure
COSR-2 identifies areas sensitive to cultural resources. The City has very detailed
standards and requirements for grading that are designed to protect sensitive
topographic, soil, paleontologic, and archaeologic resources. The Tustin Grading Manual
prescribes appropriate measures to protect the earth by controlling erosion,
sedimentation, and storm damage. Proper grading, soil management, and open space
standards will work to preserve these areas sensitive to cultural resources. Sensitive
locations are identified, and their preservation is a high priority for the City during any
project review. As new resources are identified in the City, they will be documented as
features or resources the City desires to preserve. As per the City's General Plan, a
records search will be performed prior to any development. If no record of resources
exists, a field survey will be performed. Any proposed project which is located within a
5 Tustin Residential Design Guidelines and Commercial Design Guidelines available at
https://www.tustinca.org/l 039/Resources
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sensitive area as defined by Figure COSR-2, or is identified through a subsequent study,
will require a licensed paleontologist or archaeologist to be present on the site to observe
grading or other earthwork per the City's General Plan.
California Health and Safety Code Section 7050.5, CIEQA Section 15064.5, and Public
Resources Code Section 5097.98 mandate a process to be followed in the event of an
accidental discovery of any human remains in a location other than a dedicated cemetery.
Specifically, California Health and Safety Code Section 7050.5 requires that if human
remains are discovered within the project site, disturbance of the site shall remain halted
until the coroner has conducted an investigation into the circumstances, manner, and
cause of death, and made recommendations concerning the treatment and disposition of
the human remains to the person responsible for the excavation, or to his or her
authorized representative, in the manner provided in Section 5097.98 of the Public
Resources Code. If the coroner determines that the remains are not subject to his or her
authority and if the coroner has reason to believe the human remains to be those of a
Native American, he or she shall contact, by telephone within 24 hours, the Native
American Heritage Commission.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Measures that are required by underlying Specific
Plan EIRs will be implemented. Potential cultural resource impacts would be evaluated
on a site -by -site basis and mitigation measures, if necessary, would be implemented to
reduce significant impacts. Additionally, all future projects would be required to comply
with applicable Federal, State, and local policies and regulations established to protect
cultural resources. Therefore, the project would result in no impact.
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4.10 ENERGY
Would the project: Potentially Less Than Less Than No Impact
Significant Significant Significant
Impact with Impact
Mitigation
Incorporat
ed
a) Result in potentially significant environmental E] El El
impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
b) Conflict with or obstruct a state or local plan for E] El El H
renewable energy or energy efficiency?
a and b. No Impact.
No Impact. Implementation of the programs contained in the HEU would accommodate
development required to meet the City's RHNA. The new residential units developed
through the HEU would generate demand for electricity, natural gas, as well as gasoline
for motor vehicle trips. Operational use of energy includes the heating, cooling, and
lighting of the residences, water heating, operation of electrical systems and plug-in
appliances, and outdoor lighting, and the transport of electricity, natural gas, and water to
the residences where they would be consumed. This use of energy is typical for
residential development, no additional energy infrastructure would be required to be built
to support the HEU, and no operational activities would occur that would result in
extraordinary energy consumption.
Construction of future development would be required to comply with CARB's regulations
established in 2014 to restrict the idling of heavy-duty diesel motor vehicles and govern
the accelerated turnover of oldest and dirtiest equipment to newer, cleaner models and
prevent fleets from adding older, dirtier equipment. All residential projects would be
required to meet the current Title 24 energy efficiency standards. The City's
administration of the Title 24 requirements includes review of design components and
energy conservation measures that occurs during the permitting process, which ensures
that all requirements are met. Typical Title 24 measures include insulation-, use of energy-
efficient heating, ventilation, and air conditioning equipment (HVAC) -1 solar -reflective
roofing materials-, solar panels. energy-efficient indoor and outdoor lighting systems-,
reclamation of heat rejection from refrigeration equipment to generate hot water-, and
incorporation of skylights, etc. In addition to requiring compliance with Title 24, the City
maintains several policies and requirements for development under Goal 6,
Environmental Sensitivity, that promote energy-efficient design in new development and
the use of solar energy.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
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and zoned for mixed use development. Potential energy resource impacts would be
evaluated on a site -by -site basis and mitigation measures, if necessary, would be
implemented to reduce significant impacts. Measures that are required by underlying
Specific Plan EIRs will be implemented. Additionally, all future projects would be required
to comply with applicable Federal, State, and local policies and regulations established
to promote energy efficiency and the use of renewable energy. Therefore, the project
would result in no impact.
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4.11 GEOLOGY AND SOILS
City of Tustin
Would the project:
Potentially
Less Than
Less Than No Impact
Significant
Significant
Significant
El
Impact
with
Impact
Mitigation
iv) Landslides?
El
El
Incorporat
b) Result in substantial soil erosion or the loss of
0
ed
El
a) Directly or indirectly cause potential substantial
topsoil?
adverse effects, including the risk of loss, injury, or
c) Be located on a geologic unit or soil that is
0
death involving:
El
unstable, or that would become unstable as a result
i) Rupture of a known earthquake fault, as
El
El
El
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the State
landslide, lateral spreading, subsidence,
Geologist for the area or based on other substantial
liquefaction or collapse?
evidence of a known fault? Refer to Division of
d) Be located on expansive soil, as defined in Table
Mines and Geology Special Publication 42?
El
El
ii) Strong seismic ground shaking?
El
El
El
iii) Seismic -related ground failure, including
0
El
El
liquefaction?
iv) Landslides?
El
El
El
b) Result in substantial soil erosion or the loss of
0
El
El
topsoil?
c) Be located on a geologic unit or soil that is
0
El
El
unstable, or that would become unstable as a result
of the project, and potentially result in on- or offsite
landslide, lateral spreading, subsidence,
liquefaction or collapse?
d) Be located on expansive soil, as defined in Table
0
El
El
18-1-B of the Uniform Building Code (1994),
creating substantial direct or indirect risks to life or
property?
e) Have soils incapable of adequately supporting the
0
El
El
use of septic tanks or alternative wastewater
disposal systems where sewers are not available for
the disposal of wastewater?
0 Directly or indirectly destroy a unique
0
El
El
paleontological resource or site or unique geologic
feature?
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a. i — iv and c. No Impact.
The City of Tustin General Plan Conservation/Open Space/Recreation Element identifies
several geologic hazards that could impact the community. Figure COSR-1 of the
Conservation/Open Space/Recreation Element depicts the areas in the community which
require special planning considerations to avoid potential hazards. Three geologic
hazards identified are seismic hazards, soil liquefaction, and landslides. As none of the
geologic fault systems within Tustin are known to be active, they are not identified on
Figure COSR-1 -1 however, the El Modena Fault is an inactive fault within the city. The city
is not located within an Alquist-Priolo Earthquake Fault Zone. Much of the southern
portion of Tustin, surrounding the TLSP area, is identified as high liquefaction potential.
Areas to the southeast along Peters Canyon Wash/Channel are identified as being in a
100 -year flood plain. The western portion of Tustin, surrounding the DCCSP area, is
identified as 500 -year flood plain and high liquefaction potential to the north. Several of
the proposed RHNA housing sites overlap identified hazard areas.
Structures built in the City are required to be built in compliance with the California
Building Code (CBC) (California Code of Regulations, Title 24, Part 2) that provides
provisions for earthquake safety based on factors including building occupancy type, the
types of soils onsite, and the probable strength of ground motion. Compliance with the
CBC would require the incorporation of 1) seismic safety features to minimize the
potential for significant effects as a result of earthquakes-, 2) proper building footings and
foundations-, and 3) construction of the building structure so that it would withstand the
effects of strong ground shaking.
All of the proposed RHNA housing sites are located within a specific plan area or part of
a planned development area that has undergone previous environmental review. Each of
the specific plan areas include policies and measures to be implemented by future
development that would reduce potential geologic hazards to less than significant levels.
Additionally, the General Plan includes several requirements for future development that
would further reduce the risk of loss, injury, or death, such as
Policy 8.5 of the Conservation/Open Space/Recreation Element- Review
applications for building and grading permits, and applications for subdivision for
adjacency to, threats from, and impacts on geological hazards arising from seismic
events, landslides, or other geologic hazards such as expansive soils and
subsidence areas, and
Policy 8.8 of the Conservation/Open Space/Recreation Element- Require
geotechnical studies for developments that are proposed for steep slopes and
where geological instability may be suspected. Where a precise location of the El
Modena fault is determined, appropriate building setbacks shall be established per
State law.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. The HEU would not directly result in changes to
land use or zoning designations that would place housing within an area of geologic
hazard. The City's Zoning Code would be updated following adoption of the HEU to
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include a housing overlay over The Market Place and Enderle Center RHNA housing
sites, which would allow for the development of residential in these areas. Potential
impacts that could result from proposed Zoning Code changes would be evaluated under
a separate CEQA review process. Potential risk of loss, injury, or death impacts due to
geologic hazard would be evaluated on a site -by -site basis and mitigation measures, if
necessary, would be implemented to reduce significant impacts. Additionally, all future
projects would be required to comply with applicable Federal, State, and local policies
and regulations established to prevent or reduce impacts due to geologic hazard and
measures that are required by underlying Specific Plan EIRs will be implemented.
Therefore, the project would result in no impact.
b. Result in soil erosion or the loss of topsoil?
No Impact. Although the majority of the proposed RHNA sites are currently developed,
future development would result in ground disturbing activity associated with construction
activities and there would be an increased potential for soil erosion of excavated and
loosened soils.
All proposed development construction would be required to comply with the California
Regional Water Quality Control Board (RWQCB) Order No. R8-2010-0033, National
Pollutant Discharge Elimination System (NPDES) Permit No. CAS618033 — Construction
General Permit requirements. Requirements include installation of Best Management
Practices (BMPs), which establishes minimum stormwater management requirements
and controls. To reduce the potential for soil erosion and the loss of topsoil, a Stormwater
Pollution Prevention Plan (SWPPP) is required by the RWQCB regulations to be
developed by a QSD (Qualified SWPPP Developer). The SWPPP is required to address
site-specific conditions related to specific grading and construction activities. The SWPPP
would identify potential sources of erosion and sedimentation to prevent loss of topsoil
during construction, and to identify erosion control BMPs to reduce or eliminate the
erosion and loss of topsoil, such as use of silt fencing, fiber rolls, or gravel bags-, stabilized
construction entrances/exits-, hydroseeding, and similar measures. In addition to RWQCB
requirements, proposed development would need to comply with the City of Tustin
Grading Manual procedures.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential erosion impacts would be evaluated on
a site -by -site basis and mitigation measures, if necessary, would be implemented to
reduce significant impacts. Measures that are required by underlying Specific Plan EIRs
will be implemented. Additionally, all future projects would be required to comply with
applicable Federal, State, and local policies and regulations established to reduce soil
erosion and the loss of topsoil. Therefore, the project would result in no impact.
d. Be located on expansive soil, as defined in in Table 18-1-B of the Uniform
Building Code (1994), creating substantial direct or indirect risks to life or
property?
No Impact. Expansive soils contain certain types of clay minerals that shrink or swell as
the moisture content changes-, the shrinking or swelling can shift, crack, or break
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structures built on such soils. Arid or semiarid areas with seasonal changes of soil
moisture experience, such as southern California, have a higher potential of expansive
soils than areas with higher rainfall and more constant soil moisture.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. The HEU would not directly result in changes to
land use or zoning designations that would place housing within an area of geologic
hazard. The City's Zoning Code would be updated following adoption of the HEU to
include a housing overlay over The Market Place and Enderle Center RHNA housing
sites, which would allow for the development of residential in these areas. Potential
impacts that could result from proposed Zoning Code changes would be evaluated under
a separate CEQA review process. Potential risks to life or property due to expansive soil
would be evaluated on a site -by -site basis and mitigation measures, if necessary, would
be implemented to reduce significant impacts. Additionally, all future projects would be
required to comply with applicable Federal, State, and local policies and regulations
established to prevent or reduce impacts due to expansive soil, including Policy 8.5 of the
Conservation/Open Space/Recreation Element mentioned above, which requires City
review of threats from expansive soils during the development review process. Therefore,
the project would result in no impact.
e. Have soils incapable of adequately supporting the use of septic tanks or
alternative wastewater disposal systems where sewers are not available for
the disposal of wastewater?
No Impact. Proposed RHNA sites would be served by the City sewer utilities and would
not include the use of septic tanks or alternative wastewater disposal systems. Therefore,
the project would result in no impact.
f. Directly or indirectly destroy a unique paleontological resource or site or
unique geologic feature?
No Impact. The City's Conservation/Open Space/Recreation Element of the General
Plan Figure COSR-2 identifies areas sensitive to cultural resources. None of the proposed
RHNA sites are located in an area identified by the General Plan a sensitive to
paleontological resources. The City has very detailed standards and requirements for
grading that are designed to protect sensitive topographic, soil, paleontologic, and
archaeologic resources. The Tustin Grading Manual prescribes appropriate measures to
protect the earth by controlling erosion, sedimentation, and storm damage. Proper
grading, soil management, and open space standards will work to preserve potential
paleontological resources. Sensitive locations are identified, and their preservation is a
high priority for the City during any project review. As new resources are identified in the
City, they will be documented as features or resources the City desires to preserve. Per
the City's General Plan, a records search will be performed prior to any development. If
no record of resources exists, a field survey will be performed. Any proposed project
which is located within a sensitive area, as defined by Figure COSR-2, or is identified
through a subsequent study, will require a licensed paleontologist or archaeologist to be
present on the site to observe grading or other earthwork.
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The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential paleontological resource impacts would
be evaluated on a site -by -site basis and mitigation measures, if necessary, would be
implemented to reduce significant impacts. Additionally, all future projects would be
required to comply with applicable Federal, State, and local policies and regulations
established to protect paleontological resources. Therefore, the project would result in no
impact.
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4.12 GREENHOUSE GAS EMISSIONS
Would the project: Potentially Less Than Less Than No Impact
Significant Significant Significant
Impact with I m pact
Mitigation
Incorporat
ed
a ) Generate greenhouse gas E] El El
emissions, either directly or indirectly,
that may have a significant impact on
the environment?
b) Conflict with an applicable plan, E] El El
policy or regulation adopted for the
purpose of reducing the emissions of
greenhouse gases?
a. and b. No Impact.
Implementation of the programs contained in the HEU would accommodate development
required to meet the City's RHNA allocation of 6,782 housing units within the 2021 to
2029 planning period. This additional housing would result in direct and indirect GHG
emissions, the volume of which would depend on the specifics of the units constructed.
Direct emissions include consumption of natural gas, heating and cooling of buildings,
landscaping activities and other equipment used directly by land uses. Indirect emissions
include the consumption of fossil fuels for vehicle trips, electricity generation, water
usage, and solid waste disposal.
Future development would be required to comply with Clean Energy and Pollution
Reduction Act of 2015 (SB 350), AB 1007 (Pavley 2007), Title 24 Energy Efficiency
Standards, and the California Green Building Standards, and the City would enforce local
energy policies to encourage energy-efficient design through the development permitting
process as specific above under Section 4.10, Energy.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential GHG impacts would be evaluated on a
project -by -project basis and mitigation measures, if necessary, would be implemented to
reduce significant impacts. Additionally, all future projects would be required to comply
with applicable Federal, State, and local policies and regulations established to minimize
GHG impacts. Therefore, the project would result in no impact.
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4.13 HAZARDS AND HAZARDOUS MATERIALS
Would the project:
Potentially Less Than
Significant Significant
I m pact with
Mitigation
Incorporat
ed
a) Create a significant hazard to E]
the public or the environment
through the routine transport, use,
or disposal of hazardous
materials?
b) Create a significant hazard to E]
the public or the environment
through reasonably foreseeable
upset and accident conditions
involving the release of hazardous
materials into the environment?
c) Emit hazardous emissions or E]
handle hazardous or acutely
hazardous materials, substances,
or waste within one-quarter mile of
an existing or proposed school?
d) Be located on a site which is
included on a list of hazardous
materials sites compiled pursuant
to Government Code Section
65962.5 and, as a result, would it
create a significant hazard to the
public or the environment?
e) For a project located within an
airport land use plan or, where
such a plan has not been adopted,
within two miles of a public airport
or public use airport, would the
project result in a safety hazard or
excessive noise for people
residing or working in the project
area?
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_0
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City of Tustin
Less Than No Impact
Significant
Impact
X
0
0
0
701
Wall
0111
1 Fall
NO]
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INITIAL STUDY City of Tustin
f) Impair implementation of or E] El El
physically interfere with an
adopted emergency response
plan or emergency evacuation
plan?
g) Expose people or structures, E] El El
either directly or indirectly, to a
significant risk of loss, injury or
death involving wildland fires?
a — c. No Impact.
A hazardous material is defined as any material that, due to its quantity, concentration,
or physical or chemical characteristics, poses a significant present or potential hazard to
human health and safety or to the environment if released into the workplace or
environment. Hazardous materials include, but are not limited to, hazardous substances,
hazardous wastes, and any material that a business or the local implementing agency
has a reasonable basis for believing would be injurious to the health and safety of persons
or harmful to the environment if released into the workplace or the environment.
Hazardous materials are transported through the city via highway, rail, and pipeline.
Public facilities and numerous businesses located in the city store and use varying types
and quantities of hazardous materials, as disclosed in the City's Emergency Operations
Plan.6 The haulers and users of hazardous materials are listed with the Orange County
Fire Authority and are regulated and monitored under the auspices of the County. There
are no production facilities for the manufacture of hazardous materials in the City. The
planning basis for response to a hazardous material incident in Tustin is the Orange
County Hazardous Materials Area Plan. The plan is executed within the contract services
of the Orange County Fire Authority under the Orange County -City Hazardous Material
Emergency Response Authority, a joint powers agency.
Adoption of the HEU would not result in a significant hazard to the public or the
environment through routine transport, use, or disposal of hazardous material, nor create
a significant hazard to the public or the environment through reasonably foreseeable
upset and accident conditions involving the release of hazardous materials into the
environment. The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. The HEU would not directly result in changes to
land use or zoning designations that would place housing within an area of potential
6 City of Tustin Emergency Operations Plan (2019) available at-
https://www.tustinca.org/DocumentCenter/View/570/Emergency-Operations-Plan-PDF.
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exposure to hazardous materials. The City's Zoning Code would be updated following
adoption of the HEU to include a housing overlay over The Market Place and Enderle
Center RH NA housing sites, which would allow for the development of residential in these
areas. Potential impacts that could result from proposed Zoning Code changes would be
evaluated under a separate CEQA review process. Potential risks due to hazardous
materials would be evaluated on a site -by -site basis and mitigation measures, if
necessary, would be implemented to reduce significant impacts. Additionally, all future
projects would be required to comply with applicable Federal, State, and local policies
and regulations established to prevent or reduce impacts due to hazardous materials.
Therefore, the project would result in no impact.
d. Be located on a site which is included on a list of hazardous materials sites
compiled pursuant to Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or the environment?
No Impact. There are no sites on a list of hazardous materials sites compiled pursuant
to Government Code Section 65962.5 (Cortese List) that are currently identified within
Tustin. The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential hazardous impacts would be evaluated
on a site -by -site basis and mitigation measures, if necessary, would be implemented to
reduce significant impacts. Additionally, all future projects would be required to comply
with applicable Federal, State, and local policies and regulations established to minimize
hazardous materials impacts. Therefore, the project would result in no impact.
e. For a project within an airport land use plan, or where such a plan has not
been adopted, within two miles of a public airport or public use airport,
would the project result in a safety hazard or excessive noise for people
residing or working in the project area?
No Impact. The Airport Land Use Commission (ALUC) for Orange County has
responsibility under state law for formulating a comprehensive airport land use plan
(ALUP) for the anticipated growth of each public use airport and its surrounding vicinity.
General Plans for cities affected by an ALUP must be consistent with that plan. The
purpose of the ALUP is to safeguard the general welfare of the inhabitants within the
vicinity of airports and to ensure the continued operation of the airports. The ALUC for
Orange County has adopted the Airport Environs Land Use Plan (AELUP) governing John
Wayne Airport, AFRC Los Alamitos Fullerton Airport, and Heliports. Proposed RH NA sites
identified within the TLSP area are approximately two miles northeast of John Wayne
Airport and within the AELUP planning area. The HEU will be submitted to ALUC for a
consistency determination, per ALUC requirement, during the review process since the
proposed RHNA sites fall within the John Wayne ALUP planning area.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential impacts due to proximity of John Wayne
Airport would be evaluated on a site -by -site basis and mitigation measures, if necessary,
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INITIAL STUDY City of Tustin
would be implemented to reduce significant impacts. Additionally, all future projects would
be required to comply with applicable Federal, State, and local policies and regulations
established to minimize safety hazard or excessive noise for people residing or working
in an airport land use plan area. Therefore, the project would result in no impact.
f. Impair implementation of an adopted emergency response plan or
emergency evacuation plan?
No Impact. As previously mentioned, the City adopted an Emergency Operations Plan.
The plan outlines operational duties and procedures for various positions. Additionally,
the City's Safety Element, as contained within the City of Tustin General Plan, includes
policies and procedures to be administered in the event of a disaster.7 The Safety Plan
seeks interdepartmental and inter -jurisdictional coordination and collaboration to be
prepared for, respond to and recover from every day and disaster emergencies.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential impacts due to conflict with an adopted
emergency response plan, such as emergency response times, would be evaluated on a
site -by -site basis and mitigation measures, if necessary, would be implemented to reduce
significant impacts. Additionally, all future projects would be required to comply with
applicable Federal, State, and local policies and regulations established to minimize
impacts to emergency response. Therefore, the project would result in no impact.
g. Expose people or structures, either directly or indirectly, to a significant
risk of loss, injury or death involving wildland fires?
No Impact. According to the CalFire Fire Hazard Severity Zone Map, the City of Tustin
contains very high fire severity zones in the northeast portion of the City8. The 20
proposed RHNA sites are not located within a fire hazard zone.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential impacts due to wildfire would be
evaluated on a site -by -site basis and mitigation measures, if necessary, would be
implemented to reduce significant impacts. Additionally, all future projects would be
required to comply with applicable Federal, State, and local policies and regulations
established to minimize impacts due to wildfire. Therefore, the project would result in no
impact.
7 General Plan Safety Element (2017) available at:
https://www.tustinca.org/DocumentCenter/View/713/City-of-Tustin-General-Plan-
PDF?bidld=
8 Cal Fire Hazard Severity Zone Viewer https://egis.fire.ca.gov/FHSZ/
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4.14 HYDROLOGY AND WATER QUALITY
City of Tustin
Would the project: Potentially Less Than Less Than No Impact
Significant Significant Significant
Impact with I m pact
Mitigation
Incorporate
d
a) Violate any water quality E]
standards or waste discharge
requirements or otherwise
substantially degrade surface
or ground water quality?
b) Substantially decrease E]
groundwater supplies or
interfere substantially with
groundwater recharge such
that the project may impede
sustainable groundwater
management of the basin?
c) Substantially alter the E]
existing drainage pattern of the
site or area, including through
the alteration of the course of a
stream or river or through the
addition of impervious
surfaces, in a manner which
would:
i) result in a substantial E]
erosion or siltation on- or off-
site-,
ii) substantially increase E]
the rate or amount of surface
runoff in a manner which would
result in flooding on- or offsite -1
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10-1
10-1
101
10-1
a
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a
_0
ON
SAN
MAN
ON
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iii) create or contribute E]
runoff water which would
exceed the capacity of existing
or planned stormwater
drainage systems or provide
substantial additional sources
of polluted runoff-, or
iv) impede or redirect flood E:]
flows?
d) In flood hazard, tsunami, or E]
seiche zones, risk release of
pollutants due to project
inundation?
e) Conflict with or obstruct El
implementation of a water
quality control plan or
sustainable groundwater
management plan?
a. and c. (i — iv). No Impact
INITIAL STUDY City of Tustin
El El H
El
El
Z
El
El
Z
El El Z
The HEU is a policy document that identifies strategies and programs to meet the existing
and future housing demands within the city. Future development, that has not been
proposed at this time or has been/is currently being evaluated through a separate
environmental review process, would add new uses and increase housing density within
the City. The addition of new housing units could increase pollutant loads being
discharged to local surface or ground water resources, degrading overall water quality of
the resources.
All existing and future development would be required to comply with RWQCB Order No.
R8-2010-0033, National Pollutant Discharge Elimination System (NPDES) Permit No.
CAS618033 — Construction General Permit requirements. Requirements include
installation of BMPs, which establishes minimum stormwater management requirements
and controls. To reduce the potential for soil erosion and the loss of topsoil, a SWPPP is
required by the RWQCB regulations to be developed by a QSD. The SWPPP is required
to address site-specific conditions related to specific grading and construction activities.
The SWPPP would identify potential sources of erosion and sedimentation to prevent loss
of topsoil during construction, and to identify erosion control BMPs to reduce or eliminate
the erosion and loss of topsoil, such as use of silt fencing, fiber rolls, or gravel bags-,
stabilized construction entrances/exits; hydroseeding, and similar measures. In addition
to RWQCB requirements, proposed development would need to comply with the City of
Tustin Grading Manual procedures.
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New development would also be required to be undertaken in accordance with Orange
County Drainage Area Management Plan (DAMP), per Tustin City Code, Section 4902,
Control of Urban Runoff.9 The County DAMP is the Permittees' primary policy, planning,
and implementation document for municipal NPDIES Stormwater Permit compliance,
which the City is permitted under.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential impacts due to water quality would be
evaluated on a site -by -site basis and mitigation measures, if necessary, would be
implemented to reduce significant impacts. Additionally, all future projects would be
required to comply with applicable Federal, State, and local policies and regulations
established to minimize impacts due to water quality. Therefore, the project would result
in no impact.
b. and e. No Impact.
Tustin Water Services utilizes groundwater and imported water to supply domestic water
to more than 14,100 service connections through approximately 172 miles of water
mains.10 The groundwater is pumped from the City's 14 groundwater wells. Imported
water from the Colorado River is provided by the Metropolitan Water District of Southern
California. Little to no water is provided by way of the State Water Project. Tustin Water
Services customers receive a blend of surface and groundwater from these sources. In
2013, Tustin Water Services supplied over 3.98 billion gallons of water to its customers.
The City has multiple storage reservoirs located throughout the service area that allows
for the storage of water during low demand periods for use during peak demand periods
by Tustin Water Services customers. Implementation of the programs contained in the
HEU would accommodate development required to meet the City's RHNA allocation of
6,782 housing units within the 2021 to 2029 planning period. The development of new
housing would place additional demand on existing water resources.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential impacts due to groundwater supply and
management would be evaluated on a site -by -site basis and mitigation measures, if
necessary, would be implemented to reduce significant impacts. Additionally, all future
projects would be required to comply with applicable Federal, State, and local policies
9 Orange County, 2003 Drainage Area Management Plan (DAMP), available at-
https://cms.ocqov.com/gov/pw/watersheds/documents/damP/mapplan.asp
10 City of Tustin, Water Supply & Quality, available at https://www.tustinca.org/227/Water-.
Supply -Quality
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INITIAL STUDY City of Tustin
and regulations established to minimize impacts due to groundwater supply and quality.
Therefore, the project would result in no impact.
b. In flood hazard, tsunami, or seiche zones, risk release of pollutants due to
project inundation?
No Impact. The City of Tustin General Plan Conservation/Open Space/Recreation
Element identifies several geologic hazards that could impact the community. Figure
COSR-1 of the Conservation/Open Space/Recreation Element depicts the areas in the
community which require special planning considerations to avoid potential hazards.
Areas in southeast Tustin along Peters Canyon Wash/Channel are identified as being in
a 100 -year flood plain. The western portion of Tustin, surrounding the DCCSP area, is
identified as 500 -year flood plain. Several of the proposed RHNA housing sites overlap
identified hazard areas. Current Federal Emergency Management Agency (FEMA)
Federal Insurance Rate Maps (FIRM) maps that cover the city (panel 06059CO164J and
06059CO277J) identify majority of the city as within Zone X, areas of 0.2 percent annual
chance flood-, areas of 1 percent chance flood with average depths of less than 1 foot or
with drainage areas less than 1 square mile, and areas protected by levees from 1 percent
annual chance flood." The city is eight miles inland of the Pacific Ocean and is not subject
to impacts due to tsunami. Additionally, the city and surrounding areas do not contain
nearby bodies that would subject future development to risk of seiche.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential impacts due to inundation would be
evaluated on a site -by -site basis and mitigation measures, if necessary, would be
implemented to reduce significant impacts. Additionally, all future projects would be
required to comply with applicable Federal, State, and local policies and regulations
established to minimize impacts due to project inundation. Therefore, the project would
result in no impact.
11 Federal Emergency Management Agency (2009), Federal Insurance Rate Maps
(Panels 06059CO164J and 06059CO277J ), available at:
https://msc.fema.gov/portal/home
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4.15 LAND USE AND PLANNING
City of Tustin
Would the project:
Potentiall
Less Than
Less
No
y
Significan
Than
Impact
Significan
t with
Signific
t Impact
Mitigation
ant
Incorporat
Impact
ed
a) Physically divide an established
E]
El
El
0
community?
b) Cause a significant environmental
E]
El
El
N
impact due to a conflict with any land use
plan, policy, or regulation adopted for the
purpose of avoiding or mitigating an
environmental effect?
a — b. No Impact.
The Land Use Element of the General Plan contains a Land Use Plan which indicates
the types and intensities of land use permitted throughout the City. The Land Use
Element also establishes goals and policies that provide the framework for land use
planning and decision-making in the City.
The physical division of an established community could occur if a major road
(expressway or freeway, for example) were built through an existing community or
neighborhood, or if a major development was built which was inconsistent with the land
uses in the community such that it divided the community. The environmental effects
caused by such a facility or land use could include lack of, or disruption of, access to
services, schools, or shopping areas.
The HEU would not directly result in changes to land use or zoning designations. To
accommodate RHNA, the City has identified 20 sites that could be developed with
residential housing upon future project approvals. Development proposed as a result
of the HEU would be required to obtain City approval on a project -by -project basis for
any discretionary action. In addition, the City Zoning Code and map would be amended
to accommodate two of the sites proposed, Enderle Center and The Market Place, to
provide a housing overlay for the provision of residential development. Zoning would
be updated following adoption of the HEU. Potential impacts that could result from
proposed Zoning Code changes would be evaluated under a separate CEQA review
process.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels
proposed and zoned for mixed use development. Potential land use impacts would be
evaluated on a site -by -site basis and mitigation measures, if necessary, would be
implemented to reduce significant impacts. Measures that are required by underlying
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Specific Plan EIRs will be implemented. Additionally, all future projects would be
required to comply with applicable Federal, State, and local policies and regulations
established to reduce impacts to land use. Therefore, the project would result in no
impact.
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4.16 MINERAL RESOURCES
Would the project:
INITIAL STUDY City of Tustin
Potentially Less Than
Significant Significant
Impact with
Mitigation
Incorporat
ed
a) Result in the loss of availability of E:]
a known mineral resource that
would be of value to the region and
the residents of the state?
b) Result in the loss of availability of E]
a local ly-im portant mineral
resource recovery site delineated
on a local general plan, specific
plan or other land use plan?
a — b. No Impact.
Less Than No Impact
Significant
Impact
El
El
El
El
VON
VAN
The Conservation/Open Space/Recreation Element identifies one mineral resource within
the Tustin Planning Area known as Mercury -Barite in Red Hill. However, this resource is
not utilized. In addition, the 20 sites are not located within the mineral resource area and
future development would not affect the availability of Mercury -Barite. Future
development within the RHASP area could be located along Red Hill..
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential mineral resource impacts would be
evaluated on a site -by -site basis and mitigation measures, if necessary, would be
implemented to reduce significant impacts. Additionally, all future projects would be
required to comply with applicable Federal, State, and local policies and regulations
established to reduce impacts to mineral resources. Therefore, the project would result in
no impact
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4.17 NOISE
Would the project: Potentially
Significant
Impact
a) Generation of a substantial E]
temporary or permanent increase in
ambient noise levels in the vicinity of
the project in excess of standards
established in the local general plan
or noise ordinance, or applicable
standards of other agencies?
b) Generation of excessive ground E]
borne vibration or ground borne
noise levels?
c) For a project located within the E:]
vicinity of a private airstrip or an
airport land use plan or, where such
a plan has not been adopted, within
two miles of a public airport or public
use airport, would the project
expose people residing or working in
the project area to excessive noise
levels?
a — c. No Impact.
Less Than Less Than No Impact
Significant Significant
with Impact
Mitigation
Incorporat
ed
El El E
a
:01
El
E
El
E
The City's Noise Ordinance (Ord No. 828) contained in Chapter 6 of the Tustin City Code
establishes exterior and interior noise standards that apply to all properties within
specified zones. The Noise Element of the General Plan outlines goals and policies to
reduce excessive noise in the City resulting from mobile sources and stationary sources.
The construction and operation of future development under the HEU would increase
noise levels in the City. Construction associated with future development would result in
the potential for temporary or periodic increases in noise levels and/or ground -borne
noise and vibration on or adjacent to the 20 RHNA sites. Future residential development
would also have the potential to increase noise levels long-term through increased
vehicular traffic or new stationary sources of noise. Future development would adhere to
the City's Noise Ordinance and General Plan Noise Element. In addition, future
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INITIAL STUDY City of Tustin
development within the 20 RHNA sites would undergo noise assessments that would be
analyzed on a project -by -project basis.
As discussed in Section 4.13, ALUC for Orange County has responsibility under state law
for formulating a comprehensive ALUP for the anticipated growth of each public use
airport and its surrounding vicinity. General Plans for cities affected by an ALUP must be
consistent with that plan. The purpose of the ALUP is to safeguard the general welfare of
the inhabitants within the vicinity of airports and to ensure the continued operation of the
airports. The ALUC for Orange County has adopted the AELUP governing John Wayne
Airport, AFRC Los Alamitos Fullerton Airport, and Heliports. Proposed RHNA sites
identified within the TLSP area are within the AELUP planning area and approximately
two miles northeast of John Wayne Airport.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential noise impacts would be evaluated on a
site -by -site basis and mitigation measures, if necessary, would be implemented to reduce
significant impacts. Measures that are required by underlying Specific Plan EIRs will be
implemented. Additionally, all future projects would be required to comply with applicable
Federal, State, and local policies and regulations established to reduce impacts to noise
levels. Therefore, the project would result in no impact.
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4.18 POPULATION AND HOUSING
Would the project: Potentially
Significant
Impact
a) Induce substantial unplanned E]
population growth in an area, either
directly (for example, by proposing
new homes and businesses) or
indirectly (for example, through
extension of roads or other
infrastructure)?
b) Displace substantial numbers of E]
existing people or housing,
necessitating the construction of
replacement housing elsewhere?
a — b. No Impact.
Less Than Less Than No Impact
Significant Significant
with Impact
Mitigation
Incorporat
ed
El El M
El El F1
RHNA is mandated by State Housing Law as part of the periodic process of updating local
housing elements of the General Plan. RHNA quantifies the need for housing within each
jurisdiction during specified planning periods. SCAG is in the process of developing the
6th cycle RHNA allocation plan which will cover the planning period October 2021 through
October 2029. RHNA does not necessarily encourage or promote growth, but rather
allows communities to anticipate growth, so that collectively the region and subregion can
grow in ways that enhance quality of life, improve access to jobs, promotes transportation
mobility, and addresses social equity and fair share housing needs. Future development
that occurs upon implementation of the HEU would increase the population in the City.
However, the 20 designated sites are on underutilized parcels in an urban area that would
not necessitate the need for extension of roads or other infrastructure. In addition, future
development would be analyzed on a project -by -project basis.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential recreation impacts would be evaluated
on a site -by -site basis and mitigation measures, if necessary, would be implemented to
reduce significant impacts. Additionally, all future projects would be required to comply
with applicable Federal, State, and local policies and regulations established to reduce
impacts to public services. Therefore, the project would result in no impact.
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4.19 PUBLIC SERVICES
a) Would the project result in
Potentially
Less Than
Less Than
No Impact
substantial adverse physical
Significant
Significant
Significant
impacts associated with the
Impact
with
Impact
provision of new or physically
Mitigation
altered governmental facilities, need
Incorporat
for new or physically altered
ed
governmental facilities, the
construction of which could cause
significant environmental impacts, in
order to maintain acceptable service
ratios, response times or other
performance objectives for any of
the public services:
i. Fire protection?
El
El
El
ii. Police protection?
El
El
El
iii. Schools?
El
El
El
Z
iv. Parks?
El
El
El
Z
v. Other public facilities?
El
El
El
Z
a (ii -v). No Impact.
The Tustin HEU provides a plan to accommodate the City's fair share of affordable
housing and identify and improve existing affordable housing. To accommodate the
RHNA allocation, the HEU proposes 20 sites to accommodate RHNA. The City Zoning
Code and map would be amended to accommodate two of the sites proposed, Enderle
Center and The Market Place, to provide a housing overlay for the provision of residential
development. Future development within the 20 designated RHNA sites would add new
housing in the City which would increase the demand on the City's public services
including fire and police protection, schools, parks, and libraries. However, potential
impacts to public services would be assessed on a project -by -project basis at the time
development was proposed and all development fees required by Section 9331 of the
Tustin City Code would ensure that public services would increase at the same rate as
development.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential public service impacts would be
evaluated on a site -by -site basis and mitigation measures, if necessary, would be
implemented to reduce significant impacts. Measures that are required by underlying
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Specific Plan EIRs will be implemented. Additionally, all future projects would be required
to comply with applicable Federal, State, and local policies and regulations established
to reduce impacts to public services. Therefore, the project would result in no impact.
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4.20 RECREATION
City of Tustin
Would the project: Potentially Less Than Less Than No Impact
Significant Significant Significant
Impact with Impact
Mitigation
Incorporat
ed
a) Would the project increase the E] El El
use of existing neighborhood and
regional parks or other
recreational facilities such that
substantial physical deterioration
of the facility would occur or be
accelerated?
b) Does the project include E] El El
recreational facilities or require the
construction or expansion of
recreational facilities which might
have an adverse physical effect on
the environment?
a — b. No Impact.
In 2011, the City had 113 acres of existing local and community parks, but needed an
additional 114 acres to serve its population based on a standard of three acres per
1,000 persons based on January 2011 City population of 75,781. 12 As discussed
previously, the project would not directly result in development-, however,
implementation of the housing programs could facilitate additional housing
development in fulfillment of the City's RHNA allocation. Typically, residential
development increases the need for new parks and increases the use of existing
citywide park facilities. Potential impacts on the availability of open space land and
park and recreational facilities and recreation impacts would be evaluated through a
project -by -project basis and developers would be required to pay applicable
development fees required by Section 9331 of the Tustin City Code, which would
ensure a balanced system of public and private parks, recreation facilities, and open
spaces that serves the needs of existing and future residents.
12 City of Tustin General Plan Conservation/Open Space/Recreation Element, available
at https://www.tustinca.org/DocumentCenter/View/713/City-of-Tustin-General-Plan-
PnF?hiH1H=
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The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's
RHNA goals would be located on developed, underutilized sites or on vacant parcels
proposed and zoned for mixed use development. Potential recreation impacts would
be evaluated on a site -by -site basis and mitigation measures, if necessary, would be
implemented to reduce significant impacts. Additionally, all future projects would be
required to comply with applicable Federal, State, and local policies and regulations.
Therefore, the project would result in no impact.
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4.21 TRANSPORTATION
Would the project:
INITIAL STUDY City of Tustin
Potentially Less Than
Significant Significant
Impact with
Mitigation
Incorporat
ed
Less Than
Significant
Impact
a) Conflict with a program, plan, E] El El
ordinance, or policy addressing the
circulation system, including transit,
roadway, bicycle, and pedestrian
facilities?
b) Conflict or be inconsistent with E] 1:1 El
CEQA Guidelines § 15064.3,
subdivision (b)?
c) Substantially increase hazards El 1:1
due to a geometric design feature
(e.g., sharp curves or dangerous
intersections) or incompatible uses
(e.g., farm equipment)?
d) Result in inadequate emergency E] 1:1 El
access?
a — d. No Impact.
No Impact
The Circulation Element of the City's General Plan identifies goals and policies intended
to improve overall circulation in the City and address circulation issues. New residential
development would be expected to result in vehicular trips that would increase use of
streets for transportation purposes. Future development within the RHNA sites would
occur on underutilized properties within an urbanized area and would be consistent with
the City's Circulation Element. Potential traffic impacts related to increased transportation
associated with the HEU would be analyzed through a project -by -project basis. The City's
Traffic Engineer would require project -specific transportation analysis, if required. In
addition, the Orange County Fire Authority would ensure adequate emergency access is
provided during plan checks for future development within the 20 sites.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential project proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. The City's Zoning Code would be updated
following adoption of the HEU to include a housing overlay over The Market Place and
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Enderle Center RHNA housing sites, which would allow for the development of residential
in these areas. Potential impacts that could result from proposed Zoning Code changes
would be evaluated under a separate CEQA review process. The HEU would not directly
result in changes to land use or zoning designations that would generate additional
demand on the regional and local circulation systems-, conflict with a program, plan,
ordinance, or policy addressing the circulation system-, conflict with CEQA Guidelines
section 15064.3-1 increase hazards-, or result in inadequate emergency access.
Potential transportation impacts under future development within proposed RHNA sites
would be evaluated on a site -by -site basis and mitigation measures, if necessary, would
be implemented to reduce significant impacts. Measures that are required by underlying
Specific Plan EIRs will be implemented. Additionally, all future projects would be required
to comply with applicable Federal, State, and local policies and regulations established
to reduce transportation impacts. Therefore, the project would result in no impact.
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4.22 TRIBAL CULTURAL RESOURCES
a) Would the project cause a substantial
adverse change in the significance of a
tribal cultural resource, defined in Public
Resources Code Section 21074 as either a
site, feature, place, cultural landscape that
is geographically defined in terms of the
size and scope of the landscape, sacred
place, or object with cultural value to a
California Native American tribe, and that
is..
Potentiall Less Than
y Significant
Significa with
nt Impact Mitigation
Incorporat
ed
i) Listed or eligible for listing in the E]
California Register of Historical Resources,
or in a local register of historical resources
as defined in Public Resources Code
section 5020.1(k)?
ii) A resource determined by the lead E]
agency, in its discretion and supported by
substantial evidence, to be significant
pursuant to criteria set forth in subdivision
(c) of Public Resources Code Section
5024.1. In applying the criteria set forth in
subdivision (c) of Public Resource Code
Section 5024.1, the lead agency shall
consider the significance of the resource to
a California Native American tribe?
a (kiii). No Impact.
FEW
FEW
City of Tustin
Less
Than
Signific
ant
Impact
X
—0
No
Impact
SIR,
SIR,
The City currently has a local register of historic resources included in the Tustin Historic
Resources Survey which identifies over 400 sites of possible distinction and notable
recognition. 13 The RHNA sites identified do not include sites listed in the Tustin Historic
Resources Survey. In addition, potential significant historic and cultural properties that
could be historic as defined in Public Resources Code section 5020.1 (k) would be
evaluated on a project -by -project basis. However, there is potential for resources to be
unearthed or discovered that are eligible for listing. Development proposed as a result of
the HEU would be required to obtain City approval on a project -by -project basis for any
13 Tustin Historic Resources Survey available at:
https://www.tustinca.org/l 039/Resources
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discretionary action, such as approval of a grading permit, and undergo a separate CEQA
review process to assess potential environmental impacts. Under CEQA, consultation
with tribes would be conducted under AB 52. Additionally, a Sacred Lands search request
would be obtained from the Native American Heritage Commission (NAHC) as part of the
tribal consultation process. Appropriate measures would be put in place to protect or
relocate any identified resources.
Tribal cultural resources are sites, features, places, cultural landscapes, sacred places,
and objects with cultural value to a California Native American tribe that are either eligible
or listed in the California Register of Historical Resources or local register of historical
resources (Public Resources Code § 21074). As discussed above, development
proposed as a result of the HEU would be required to obtain City approval on a project -
by -project basis for any discretionary action, such as approval of a grading permit, and
undergo a separate CIEQA review process to assess potential environmental impacts. In
order to determine whether any tribal cultural resources could be impacted by the
proposed project, California Native American tribes that are traditionally and culturally
affiliated with the project area would be contacted early in the CIEQA process (Public
Resources Code § 21080.3.1), and consultation undertaken with those Native American
tribes that express an interest in engaging in consultation for this project. Appropriate
measures would be identified during consultation and put in place to protect or relocate
any identified resources.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential tribal cultural resource impacts would
be evaluated on a site -by -site basis and mitigation measures, if necessary, would be
implemented to reduce significant impacts. Measures that are required by underlying
Specific Plan EIRs will be implemented. Additionally, all future projects would be required
to comply with applicable Federal, State, and local policies and regulations established
to protect tribal cultural resources. Therefore, the project would result in no impact.
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4.23 UTILITIES AND SERVICE SYSTEMS
Would the project: Potentially
Significant
Impact
a) Require or result in the relocation or E]
construction of new or expanded
water, wastewater treatment,
stormwater drainage, electric power,
natural gas, or telecommunications
facilities, the construction or
relocation of which could cause
significant environmental effects?
b) Have sufficient water supplies E]
available to serve the project and
reasonably foreseeable future
development during normal, dry and
multiple dry years?
c) Result in a determination by the E]
wastewater treatment provider which
serves or may serve the project that it
has adequate capacity to serve the
project's projected demand in addition
to the provider's existing
commitments?
d) Generate solid waste in excess of E]
state or local standards, or in excess
of the capacity of local infrastructure,
or otherwise impair the attainment of
solid waste reduction goals?
e) Comply with federal, state, and E]
local management and reduction
statutes and regulations related to
solid waste?
Page 169
City of Tustin
Less Than Less Than No Impact
Significant Significant
with I m pact
Mitigation
Incorporat
ed
a
_0
_0
a
101
10-1
FEW
101
10-1
a
FORM
PAN
a
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a — e. No Impact.
Implementation of the housing programs would facilitate housing development to meet
the City's RHNA allocation. The proposed RHNA sites identified for future housing
development are primarily infill locations surrounded by roadways that contain utility
infrastructure adjacent to existing development that is served by these utilities service
systems and have been planned for urban uses.
Implementation of the housing programs would facilitate housing development to meet
the City's RHNA allocation of 6,782 housing units. Development of housing would require
additional potable water resources to operate. The City of Tustin UWMP projects a
demand of 9,898 -acre feet (AF) by 2045 and a supply of 9,898 AF.14 Additionally, the
UWMP includes a contingency plan and supply assessment for dry year(s). The proposed
16 of the 20 proposed RHNA sites have been previously analyzed under adopted Specific
Plans which are included in the City's UWMP projections. The East Orange County Water
District and Irvine Ranch Water District would provide wastewater collection to the
proposed RHNA sites. The City contracts for residential refuse collection and solid waste
materials are transported to a Materials Recovery Facility where it is sorted for
recyclables. The County of Orange owns and operates the Frank R. Bowerman Sanitary
Landfill, located at 11002 Bee Canyon Access Road in Irvine, which serves Tustin.
The Resource Conservation and Recovery Act of 1976 (United States Code Title 42,
Section 6901 et seq.) governs the creation, storage, transport, and disposal of hazardous
wastes and operators of hazardous waste disposal sites.
AB 939, the Integrated Waste Management Act of 1989 (California Public Resources
Code Section 40000 et seq.) requires all local governments to develop source reduction,
reuse, recycling, and composting programs to reduce tonnage of solid waste going to
landfills. Cities must divert at least 50 percent of their solid waste generation into
recycling. Compliance with AB 939 is measured for each jurisdiction, in part, as actual
disposal amounts compared to target disposal amounts. Actual disposal amounts at or
below target amounts comply with AB 939. The City must comply with State law to reduce
solid waste generation, promote reuse and require solid waste collection for recycling and
composting.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. Potential utilities impacts would be evaluated on
a site -by -site basis and mitigation measures, if necessary, would be implemented to
reduce significant impacts. Additionally, all future projects would be required to comply
with applicable Federal, State, and local policies and regulations established related to
utilities. Therefore, the project would result in no impact.
14 Available at https://www.tustinca.org/DocumentCenter/View/5138/Tustin-2020-UWMP
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4.24 WILDFIRE
If located in or near state responsibility areas or
lands classified as very high fire hazard severity
zones, would the project:
Potentially Less Than
Significant Significant
Impact with
Mitigation
Incorporat
ed
a) Substantially impair an adopted emergency El
response plan or emergency evacuation plan?
b) Due to slope, prevailing winds, and other factors, E]
exacerbate wildfire risks, and thereby expose
project occupants to pollutant concentrations from a
wildfire or the uncontrolled spread of a wildfire?
c) Require the installation or maintenance of E]
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines or
other utilities) that may exacerbate fire risk or that
may result in temporary or ongoing impacts to the
environment?
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post -fire slope
instability, or drainage changes?
a — d. No Impact.
Less Than No Impact
Significant
Impact
El El
El El
LE
1011
0
0
Me
According to the CalFire Fire Hazard Severity Zone Map, the City of Tustin contains very
high fire severity zones in the northeast portion of the City15. The proposed RHNA sites
are not located within a fire hazard zone. In addition, the sites and areas adjacent to the
sites are urbanized and do not contain hillsides or other factors that could exacerbate
wildfire risks.
As discussed previously, the City of Tustin General Plan Conservation/Open
Space/Recreation Element identifies several geologic hazards that could impact the
community. Figure COSR-1 of the Conservation/Open Space/Recreation Element
depicts the areas in the community which require special planning considerations to avoid
potential hazards. Areas in southeast Tustin along Peters Canyon Wash/Channel are
identified as being in a 100 -year flood plain. The western portion of Tustin, surrounding
the DCCSP area, is identified as 500 -year flood plain. Several of the proposed RHNA
housing sites overlap identified hazard areas. Current Federal Emergency Management
Agency (FEMA) Federal Insurance Rate Maps (FIRM) maps that cover the city (panel
15Cal Fire Hazard Severity Zone Viewer https://egis.fire.ca.gov/FHSZ/
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06059CO164J and 06059CO277J) identify majority of the city as within Zone X, areas of
0.2 percent annual chance flood-, areas of 1 percent chance flood with average depths of
less than 1 foot or with drainage areas less than 1 square mile, and areas protected by
levees from 1 percent annual chance flood. 16
As previously mentioned, the City adopted an Emergency Operations Plan. The plan
outlines operational duties and procedures for various positions. Additionally, the City's
Safety Element, as contained within the City of Tustin General Plan, includes policies and
procedures to be administered in the event of a disaster.17 The Safety Plan seeks
interdepartmental and inter -jurisdictional coordination and collaboration to be prepared
for, respond to and recover from every day and disaster emergencies. All projects in the
city would be require to be consistent with both emergency planning documents.
Additionally, new residential uses in the city are required to include all fire related safety
features pursuant to the California Fire Code, which is included in the Tustin City Code
as Section 8104. The City's Building Department and the Fire Department would review
the building plans prior to approval to ensure that all applicable fire safety features are
included in each development project.
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA,
and associated infrastructure improvements, would be located on developed,
underutilized sites or on vacant parcels proposed and zoned for mixed use development.
Potential wildfire impacts would be evaluated on a site -by -site basis and mitigation
measures, if necessary, would be implemented to reduce significant impacts. Additionally,
all future projects would be required to comply with applicable Federal, State, and local
policies and regulations established related to wildfire hazards. Therefore, the project
would result in no impact.
16 Federal Emergency Management Agency (2009), Federal Insurance Rate Maps
(Panels 06059CO164J and 06059CO277J ), available at:
https://msc.fema.gov/portal/home
17 General Plan Safety Element (2017) available at-
https: //www. tu sti n ca. o rq/Docu m entCe nter/View/71 3/C ity-of-Tu sti n -Genera I -P Ian -
PnF?hiH1H=
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4.25 MANDATORY FINDINGS OF SIGNIFICANCE
Potentially Less Than Less Than No Impact
Significant Significant Significant
Impact with Impact
Mitigation
Incorporat
ed
a) Does the project have the potential to El El El
substantially degrade the quality of the environment,
substantially reduce the habitat of a fish or wildlife
species, cause a fish or wildlife population to drop
below self-sustaining levels, threaten to eliminate a
plant or animal community, substantially reduce the
number or restrict the range of a rare or endangered
plant or animal or eliminate important examples of
the major periods of California history or prehistory?
b) Does the project have impacts that are El El El
individually limited, but cumulatively considerable?
("Cumulatively considerable" means that the
incremental effects of a project are considerable
when viewed in connection with the effects of past
projects, the effects of other current projects, and
the effects of probable future projects)?
c) Does the project have environmental effects E] El El H
which will cause substantial adverse effects on
human beings, either directly or indirectly?
a. Does the project have the potential to substantially degrade the quality of the
environment, substantially reduce the habitat of a fish or wildlife species,
cause a fish or wildlife population to drop below self-sustaining levels,
threaten to eliminate a plant or animal community, substantially reduce the
number or restrict the range of a rare or endangered plant or animal or
eliminate important examples of the major periods of California history or
prehistory?
No Impact. As discussed in Section 4.8, the City's Conservation/Open Space/Recreation
Element of the General Plan Identifies areas as "important natural resources" within
Figure COSR-2. Since the natural resource areas have been designated, new
development has occurred throughout the city. Areas identified as important natural
resources are located at the northern and southern ends of the city. Natural resources to
the north include open space areas, Lower Peters Canyon Retarding Basin, Eucalyptus
Windrow, and Redwood Grove. This area also includes Coastal Sage Scrub habitat. The
natural habitats to the north support sensitive or endangered species such as the
California Black -tailed Gnatcatcher, the San Diego Cactus Wren, and the San Diego
Coast Horned Lizard. Within southern Tustin, agricultural land is identified as an important
natural resource based on the CDOC's previous designation of the land as important
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farmland. However, the area has since been adopted into a specific plan (TLSP) and is
no longer utilized for agricultural purposes.
Additionally, Peters Canyon is a predominant riparian feature within the city. Several
mitigation measures were adopted for Peters Canyon as part of the ETSP. These
mitigation measures continue to reflect City policy. For several years, the Lower Peters
Canyon Retarding Basin contained a small riparian habitat.18 This habitat has severely
deteriorated in recent years. The City works with the County of Orange, which recently
constructed a replacement dam, to preserve the riparian area and implement active
measures to increase water supply to restore the habitat area.
As discussed in Section 4.9, the City of Tustin contains several designated historic
resources and resources of historic age that could be eligible for designation. Tustin's
historic preservation program was established by Tustin City Code Section 9252 "Cultural
Resources District," and is supported by Residential Design Guidelines and Commercial
Design Guidelines established by the City. It is also supported by the Secretary of
Interior's Standards for the Treatment of Historical Properties.19 Together, these
documents establish criteria and procedures for the designation, preservation and
maintenance of cultural resources throughout the City of Tustin.
The City's Conservation/Open Space/Recreation Element of the General Plan Figure
COSR-2 identifies areas sensitive to cultural resources. The City has very detailed
standards and requirements for grading that are designed to protect sensitive
topographic, soil, paleontologic, and archaeologic resources. The Tustin Grading Manual
prescribes appropriate measures to protect the earth by controlling erosion,
sedimentation, and storm damage. Proper grading, soil management, and open space
standards will work to preserve these resources. Sensitive locations are identified, and
their preservation is a high priority forthe City during any project review. As new resources
are identified in the City, they will be documented as features or resources the City desires
to preserve. As per the City's General Plan, a records search will be performed prior to
any development. If no record of resources exists, a field survey will be performed. Any
proposed project which is located within a sensitive area as defined by Figure COSR-2,
The HEU is a policy document, and its adoption would not, in itself, produce
environmental impacts. Future residential projects proposed to achieve the City's RHNA
goals would be located on developed, underutilized sites or on vacant parcels proposed
and zoned for mixed use development. One RHNA site is located in the ETSP-1 however,
the site is currently developed and is outside of areas containing sensitive biological
habitat. Potential biological and cultural resource impacts would be evaluated on a site -
by -site basis and mitigation measures, if necessary, would be implemented to reduce
18 City of Tustin General Plan Conservation/Open Space/Recreation Element, available
at https: //www. tu sti nca. o rq/Docu m entCe nter/View/71 3/C ity-of-Tu sti n -Genera I- P la n-
PnP?hirllrl=
19 Tustin Residential Design Guidelines and Commercial Design Guidelines available at
https://www.tustinca.org/l 039/Resources
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significant impacts. Additionally, all future projects would be required to comply with
applicable Federal, State, and local policies and regulations established to protect
biological species and cultural resources. Therefore, the project would result in no impact.
b. Does the project have impacts that are individually limited, but cumulatively
considerable? ("Cumulatively considerable" means that the incremental
effects of a project are considerable when viewed in connection with the
effects of past projects, the effects of other current projects, and the effects
of probable future projects)?
Less Than Significant Impact. Cumulative impacts are defined as two or more individual
effects that, when considered together, are considerable or that compound or increase
other environmental impacts. The cumulative impact from several projects is the change
in the environment that results from the incremental impact of the development when
added to the impacts of other closely related past, present, and reasonably foreseeable
or probable future developments. Cumulative impacts can result from individually minor,
but collectively significant, developments taking place over a period. The CEQA
Guidelines, Section 15130 (a) and (b), states:
a. Cumulative impacts shall be discussed when the project's incremental effect is
cumulatively considerable.
b. The discussion of cumulative impacts shall reflect the severity of the impacts and
their likelihood of occurrence, but the discussion need not provide as great detail
as is provided of the effects attributable to the project. The discussion should be
guided by the standards of practicality and reasonableness.
The HEU proposes several program changes to comply with State law, as well as
proposed housing sites to accommodate RHNA's quantified objective administered to the
City for the 2021-2029 planning cycle. The HEU also provides for the continuation of the
preexisting policies and programs that were adopted in the 2014-2021 Housing Element.
The HEU would not directly result in changes to land use or zoning designations that
would place housing within an area of potential exposure to hazardous materials. The
City's Zoning Code would be updated following adoption of the HEU to include a housing
overlay over The Market Place and Enderle Center RHNA housing sites, which would
allow for the development of residential in these areas. Potential impacts that could result
from proposed Zoning Code changes would be evaluated under a separate CEQA review
process. Furthermore, mitigation measures that are required by underlying Specific Plan
EIRs would be implemented as development is proposed. Therefore, the project would
have no impact.
c. Does the project have environmental effects which will cause substantial
adverse effects on human beings, either directly or indirectly?
Less Than Significant Impact. The HEU is a policy document, and its adoption would
not, in itself, produce environmental impacts. No actual development or rezoning is
proposed as part of the HEU. The HEU would not directly result in changes to land use
or zoning designations that would place housing within an area of potential exposure to
hazardous materials. The City's Zoning Code would be updated following adoption of the
HEU to include a housing overlay over The Market Place and Enderle Center RHNA
housing sites, which would allow for the development of residential in these areas.
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Potential impacts that could result from proposed Zoning Code changes would be
evaluated under a separate CEQA review process. Development proposed as a result of
the HEU would also be required to obtain City approval on a project -by -project basis for
any discretionary action, such as approval of a grading permit, and undergo a separate
environmental process to assess potential environmental impacts. Furthermore,
mitigation measures that are required by underlying Specific Plan EIRs would be
implemented as development is proposed. Therefore, the project would have no impact.
Page 176
DocuSign Envelope ID: OE07E7DE-3638-4988-8507-EB263ED01 D05
INITIAL STUDY City of Tustin
End of document.
Page 177
ATTACHMENT H
CITY COUNCIL RESOLUTION NO. 22-47
9 EXHIBIT A: FINAL DRAFT GENERAL PLAN HOUSING
ELEMENT AND APPENDICES
I ION =01 I L11 9 IQ 0 a 0 [ON WZ1 I W
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
TUSTIN APPROVING GENERAL PLAN AMENDMENT 2022-
0002, UPDATING THE TUSTIN HOUSING ELEMENT
PURSUANT TO GOVERNMENT CODE SECTION 65588.
The City Council of the City of Tustin does hereby resolve as follows:
The City Council finds and determines as follows:
A. That California State Law Section 65588 requires each City to review as
frequently as appropriate and to revise its Housing Element as appropriate.
B. That the Housing Element is required to be updated every eight (8) years to
reflect new statutory requirements and accommodation its share of Reginal
Housing Needs Assessment Allocation.
C. That housing is an important issue with the State of California and as such,
each city and county must identify and analyze existing and projected
housing needs within their jurisdiction and prepare goals, policies,
programs, and quantified objectives to further the development,
improvement, and preservation of housing.
D. That in accordance with State Law, the City of Tustin has prepared a Draft
Housing Element for the 2021-2029 period in accordance with California
Government Code Sections 65580-65589.11.
E. That the City conducted extensive community outreach efforts through an
online community survey, social media ads and posts, newspaper
advertisements, mailings to stakeholders and memorialized all outreach
efforts in the 2021-2029 Housing Element Community Engagement Plan.
F. That on November 11, 2020, the Planning Commission held a public
meeting to review the 2021-2029 Housing Element requirements and the
City's strategy for enhancing and preserving the community's character,
and strategies for expanding housing opportunities and services for all
household types and income groups.
G. That a joint public workshop was held on May 11, 2021, to inform the
general public, the Planning Commission, and the City Council with the
purpose and intent of the Housing Element Update.
H. That the initial Draft Housing Element was circulated for public review
between June 30, 2021 and July 30, 2021 and has subsequently remained
available for on-going public review and comment thereafter.
Resolution No. 22-47
GPA 2022-0002 Housing Element Update
Page 2
1. That 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 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 6 th cycle Housing
Element update.
N. 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.
0. 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.
P. 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.
Resolution No. 22-47
GPA 2022-0002 Housing Element Update
Page 3
Q. 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/Housing Element.
R. That on September 12, 2022, the City received written correspondence
from HCD approving the revised Housing Element and determining that
the draft element, incorporating revisions submitted, meets the statutory
requirements of State Housing Element Law described in HCD's May 18,
2022 review letter.
S. That on September 13, 2022, the Planning Commission conducted a duly -
noticed public hearing to consider General Plan Amendment (GPA) 2022-
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 adopt GPA 2022-0002 updating the
Housing Element.
T. That a public hearing was duly called, noticed, and held on GPA 2022-
0002, on October 4, 2022, 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.
U. That on October 5, 2021, the City Council adopted Resolution No. 21-86,
certifying the Negative Declaration for GPA 2021-0002 and Resolution
No. 21-87, approving GPA 2021-0002, updating the Housing Element.
V. The Housing Element Update is a policy document, and its adoption
would not, in itself, produce environmental impacts. No actual
development or re -zoning is proposed as part of the Housing Element
Update. The Housing Element Update would not directly result in changes
to land use or zoning designations that would place housing within an
area of potential exposure to hazardous materials. Development proposed
as a result of the Housing Element Update would also be required to
obtain City approval on a project -by -project basis for any discretionary
action and undergo a separate environmental process to access potential
environmental impacts. Furthermore, mitigation measures that are
required by underlying EIR's would be implemented as development is
proposed. Therefore, the adopted Negative Declaration concludes that
the Housing Element would have no impact.
Resolution No. 22-47
GPA 2022-0002 Housing Element Update
Page 4
W. 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.
11. The City Council approves GPA 2022-0002, attached hereto as Exhibit A, for the
6 th Cycle Housing Element.
111. The City Council authorizes staff to submit the 6 th Cycle Housing Element Update
to HCD for certification.
IV. The Director of Community Development is authorized to make minor
modifications as may be required by HCD for Housing Element certification.
PASSED AND ADOPTED by the City Council of the City of Tustin, at a regular meeting
on the 4 th day of October, 2022.
AUSTIN LUMBARD
MAYOR
ERICA N. YASUDA
CITY CLERK
Resolution No. 22-47
GPA 2022-0002 Housing Element Update
Page 5
STATE OF CALIFORNIA
COUNTY OF ORANGE SS
CITY OF TUSTIN
1, Erica N. Yasuda, City Clerk and ex -officio Clerk of the City Council of the City of Tustin,
California, do hereby certify that the whole number of the members of the City Council of
the City of Tustin is five; that the above and foregoing Resolution No. 22-47 was duly
passed and adopted at a regular meeting of the Tustin City Council, held on the 4 th day of
October, 2022, by the following vote:
COUNCILMEMBER AYES:
COUNCILMEMBER, NOES:
COUNCILMEMBER ABSTAINED:
COUNCILMEMBER ABSENT:
ERICA N. YASUDA
CITY CLERK
Attachment:
0 Exhibit A: 2021-2029 6th Cycle Housing Element Update
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TUSTIN
GENERAL PLAN
SEPTEMBER 2022
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CITY OF TUSTIN HOUSING ELEMENT
GENERAL PLAN SEPTEMBER 2022
TABLE OF CONTENTS
Section Page
1. INTRODUCTION TO THE HOUSING ELEMENT 1-1
Purpose Of The Housing Element 1-1
Scope And Content Of Element 1-2
Consistency With State Planning Law 1-2
General Plan Consistency 1-3
Public Participation 1-4
11. SUMMARY OF ISSUES, NEEDS, CONSTRAINTS AND OPPORTUNITIES 11-1
Summary Of Housing Needs 11-1
Preservation Of Units At Risk Of Conversion 11-19
Summary Of Housing Issues 11-28
Housing Constraints 11-29Housing Opportunities 11-88
111. HOUSING ELEMENT GOALS AND POLICIES 111-1
Housing Supply/ Housing Opportunities III -1
Maintenance And Conservation 111-3
Environmental Sensitivity 111-4
Related Goals And Policies 111-4
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
LIST OF TABLES
Tables Page
TABLE II -1: POPULATION GROWTH 2010-2018
11-2
TABLE 11-2: POPULATION PROJECTIONS 2025-2045
11-2
TABLE 11-3: EMPLOYMENT BY OCCUPATION
11-3
TABLE 11-4:EMPLOYMENT PROJECTIONS
11-3
TABLE 11-5: LIST OF MAJOR EMPLOYERS
11-4
TABLE 11- 6: JOBS -HOUSING BALANCE
11-5
TABLE 11-7: HOUSEHOLD INCOME DISTRIBUTION OVERVIEW
11-7
TABLE 11-8: NUMBER OF HOUSEHOLDS WITH COST BURDEN
11-8
TABLE 11-9: NUMBER OF HOUSEHOLDS WITH COST BURDEN
11-8
TABLE 11-10: TENURE OF HOUSEHOLDS WITH HEAD OF HOUSEHOLD AGED
65 YEARS OR OLDER
II -10
TALBE 11-11: ESTIMATED HOUSEHOLD INCOME DISTRIBUTION - HOUSEHOLDS
WITH HEAD OF HOUSEHOLD AGED 65 YEARS OR OLDER
11-10
TABLE 11-12: SENIOR HOUSEHOLDS BY TENURE
11-11
TABLE 11-13 RACE AND ETHNICITY
11-11
TABLE 11-14 DISABILITY DEMOGRAPHICS
11-12
TABLE 11-15 DEVELOPMENTAL DISABILITY DEMOGRAPHICS
11-14
TABLE 11-16 TUSTIN EMPLOYMENT IN AGRICULTURE
11-17
TABLE 11-17 AT -RISK UNITS
11-19
TABLE 11-18 ASSISTED HOUSING INVENTORY
11-20
TABLE 11-19 ORANGE COUNTY FAIR MARKET RENT
11-23
TABLE 11-20 COST OF PRESERVATION
11-24
TABLE 11-21 COST OF REPLACEMENT
11-27
TABLE 11-22 NEW AND RESALE PRICE OF HOMES AND CONDOMINUMS 11-31
TABLE 11-23 AVERAGE RENTAL RATES 2021
11-32
TABLE 11-24 SUMMARY OF RESIDENTIAL ZONING REGULATIONS
11-35
TABLE 11-25 INCLUSIONARY HOUSING OPTIONS FOR RESIDENTIAL PROJECTS WITH
FEWER THAN 20 UNITS
11-46
TABLE 11-26 FEE OPTIONS FOR RESIDENTIAL PROJECTS WITH FEWER
THAN 20 UNITS
11-47
CITY OF TUSTIN
GENERAL PLAN
ill
HOUSING ELEMENT
SEPTEMBER 2022
TABLE 11-27 FEE PER UNIT FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS
LIST OF FIGURES
Figures Page
FIGURE 11-1: IMPACT FEE ZONES 11-56
FIGURE 11-2: PLANNING FEES 11-57
FIGURE 11-3: RESIDENTIAL BUILDING PERMIT PROCESS 11-62
FIGURE 11-4: CONDITIONAL USE PERMIT CUP PROCESS AND TIMELINES 11-64
FIGURE 11-5: STREAMLINED ADMINISTRATIVE REVIEW PROCESS 11-64
CITY OF TUSTIN
GENERAL PLAN
up
HOUSING ELEMENT
SEPTEMBER 2022
11-47
TABLE 11-28 INCLUSIONARY HOUSING FEE COMPARISON
11-49
TABLE 11-29 SUMMARY OF HOMELESS ACCOMODATION ZONING
REGULATIONS
11-57
TABLE 11-30 MONTHLY VACANCY RATE VILLAGE OF HOPE
11-59
TABLE 11-31 MONTHLY VACANCY TUSTIN TEMPORARY EMERGENCY
SHELTER
11-60
TABLE 11-32 EMERGENCY SHELTER/ TRANSITIONAL HOUSING FACILITIES/ HOMELESS
RESOURCES
11-61
TABLE 11-33A DEVELOPMENT FEES
11-67
TABLE II -33B DEVELOPMENT FEES
11-69
TABLE 11-34 HOUSING TYPES AND PERMIT PROCESSING REQUIREMENTS 11-73
TABLE 11-35 PROJECT BUILDING PERMIT TIMEFRAME
11-77
TABLE 11-36 QUANTIFIED OBJECTIVES
11-86
TABLE IV -1 HOUSING ELEMENTS PROGRAMS 2021-2029
IV -1
LIST OF FIGURES
Figures Page
FIGURE 11-1: IMPACT FEE ZONES 11-56
FIGURE 11-2: PLANNING FEES 11-57
FIGURE 11-3: RESIDENTIAL BUILDING PERMIT PROCESS 11-62
FIGURE 11-4: CONDITIONAL USE PERMIT CUP PROCESS AND TIMELINES 11-64
FIGURE 11-5: STREAMLINED ADMINISTRATIVE REVIEW PROCESS 11-64
CITY OF TUSTIN
GENERAL PLAN
up
HOUSING ELEMENT
SEPTEMBER 2022
INTRODUCTION TO THE HOUSING ELEMENT
The availability of decent housing and a suitable living environment for every family
has been an ongom'g 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:
0 2013-2021: The previous planning period began on October 15, 2013, and ended
on October 15, 2021
0 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 11 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 11 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 1-2 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,
envirom-nental 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:
0 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 1-3 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 1-4 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 1-5 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
policies.
CITY OF TUSTIN
GENERAL PLAN
for the City to consider utilizing skilled and trained workforce
DRAFT HOUSING ELEMENT
1-6 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 1-7 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 Comn-tission (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 1-8 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 1-9 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
0 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 11- 1
POPULATION GROWTH 2010-2018
CITY OF TUSTIN, NEARBY JURISDICTIONS AND ORANGE COUNTY
Sources: 12010 U.S. Census, 2 2014 U.S. Census
3 American Community Survey (5 -Year Estimate) 2018
Population projections are shown in Table 11-2. 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 11- 2
POPULATION PROJECTIONS IN TUSTIN, CA 2025-2045
Percent Growth
jurisdiction
20101
2014 2
20 183
2030
2035
2040
2045
2014-2018
2010-2018
Tustin
75,540
80,617
79,787
-1.0%
5.6%
Anaheim
87,932
90,576
92,564
1.5%
4.7%
336,265
346,961
352,018
Garden
-1.4%
1.0%
Grove
170,883
175,085
172,652
Irvine
212,375
248,521
282,584
1 3.7%
33.1%
Orange
324,528
139,826
139,502
-0 . 2%
2.0%
Santa Ana
-0.1%
2.2%
325,483
334,924
332,727
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 11-2. 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 11- 2
POPULATION PROJECTIONS IN TUSTIN, CA 2025-2045
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 11-2 SEPTEMBER 2022
Percent Change
2025
2030
2035
2040
2045
(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 11-2 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 11-3 shows the breakdown of employment
by occupation.
TABLE Il- 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 1 42,448 1 1000%
Source: U.S. Census: 2014-2018 American Community Survey
Table 11-4 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 11- 4
EMPLOYMENT PROIECTION IN TUSTIN. CA 2016-2040
Source: Center for Demographic Research at Cal State Fullerton - 0CF, 2018
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-3 SEPTEMBER 2022
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 - 0CF, 2018
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-3 SEPTEMBER 2022
Table 11-5 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 11- 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 Myford 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; 17452 17th 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 11-4 SEPTEMBER 2022
jurisdiction has reached an equilibrium between employment and housing
opportunities.
Table H-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 11- 6
JOBS -HOUSING BALANCE
CITY OF TUSTIN, ORANGE COUNTY, SCAG REGION, 2019
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 11-5 SEPTEMBER 2022
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 1.78
1 1.57
1 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 11-5 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 bath -room.
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 11-6 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.
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 11-7 SEPTEMBER 2022
TABLE Il- 7
HOUSEHOLD INCOME DISTRIBUTION OVERVIEW IN TUSTIN, CA 2017
Income
Owner
Owner
Renter
Renter
Total
(0/0)
(0/0)
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 11-7 SEPTEMBER 2022
TABLE Il- 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 = 21870 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 11125 1,120 190 125 2,420 3,060
100% AMI
Household Income
>100% AMI 2,325 1,355 365 110 10,665 10,625
Total 12,175 11,375 5,424 4,840 24,715 26,185
Source: Comprehensive Housing Affordability Strategy (CHAS), 2008-2012 estimates and 2013-2017 estimates
As exhibited in Table H-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 11- 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 11-8 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:
• Integration and segregation;
• Racially or ethnically concentrated areas of poverty;
• Disparities in access to opportunity, including for persons with
disabilities; and
• 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 refired 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 11-9 SEPTEMBER 2022
Table 11-10 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 11- 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 II -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 Il- 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 11-12
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 11- 12
Race/Ethnicity
SENIOR HOUSEHOLDS BY TENURE IN TUSTIN, CA 2018
Percent
White, Non -Hispanic
Owner costs
Grossrent
Black, Non -Hispanic
as a
as a
Total Elderly Senior-
percentage
percentage
jurisdiction Headed Owner
Renter Of
of
Population
Households
household
household
Two+ Races, Non -Hispanic
income
income
Other, Non -Hispanic
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 11-13. 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 11-13
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. Demograpl-dcs by disability and age cohort are
identified in Table 11-14. 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 11-14
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
difficulty
2,125
6.7%
1,147
11.8%
Total Disability
5,238
6.6%
2,291
28.4%
Total Population
79,667
8,057
Race/Ethnicity
White alone
Black or African American
alone
3,294
138
8.5%
6.5%
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-12 SEPTEMBER 2022
TABLE 11-14
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 11-17. 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 envirom-nent. 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 11-13 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 corm-nunity; 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 11-15
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 11-14 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 11-15 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 11-16 SEPTEMBER 2022
TABLE 11-16
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 11-17 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 11-18 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 11-17 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 11-18 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 11-17
AT -RISK UNITS, TUSTIN, CA
Very- Low-
Moderate-
Expiration
At -
Project Name Low Income
Income
Total Units
Date
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 11-19 SEPTEMBER 2022
TABLE 11-18
ASSISTED HOUSING INVENTORY, TUSTIN, CA
Type/ Length
Tenant
Project Name
Owner:
Federal,
of
Earliest
Type
Date
Address
Name,
State, or
Type(s) of Gov 't
Affordability
Potential
# of
(i.e.,
Bedroom
Built
Condition
Address,
Local
Assistance
Controls
Conversion
Units
Elderly,
Mix
(if
(if known)
Tel. #
(including
Date(s)
Family)
known)
Sec. 8)
Tustin
Goldrich & Kest
Fed.
HUD
---
July/2014
99
Elderly
100 1-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 11-20 SEPTEMBER 2022
TABLE 11-18
ASSISTED HOUSING INVENTORY, TUSTIN, CA
Type/ Length
Tenant
Project Name
Owner:
Federal,
of
Earliest
Type
Date
Address
Name,
State, or
Type(s) of Gov't
Affordability
Potential
# of
(i.e.
Bedroom
Built
Condition
Address,
Local
Assistance
Controls
Conversion
Units
Elderiy,
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
DDAI
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
Local
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 11-21 SEPTEMBER 2022
TABLE 11-18
ASSISTED HOUSING INVENTORY, TUSTIN, CA
Type/ Length
Tenant
Project Name
Owner:
Federal,
of
Earliest
Type
Date
Address
Name,
State, or
Type(s) of Gov't
Affordability
Potential
# of
(i.e.
Bedroom
Built
Condition
Address,
Local
Assistance
Controls
Conversion
Units
Elderiy,
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
I DDA - Disposition and Development Agreement
Source: Comprehensive Housing Affordability Strategy 2008 -2018, City of Tustin
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-22 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 11-19
ORANGE COUNTY FAIR MARKET RENT, 2020-2021
Year Efficiency One- Two- Three- Four -
Bedroom Bedroom Bedroom Bedroom
FY 2021 $1,678 $1,888 $2,331 $3,227 $3,716
FY 2020 $1,563 $1,785 $2,216 $3,098 $3,578
Source: HUD User FY 2021 Fair Market Rent Documentation System
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-23 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 11-20 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
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-24 SEPTEMBER 2022
TABLE 11- 20
COST OF PRESERVATION
Project Units
Chatham
Westchester
Flanders
Total
Village
Park
Pointe
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
$438,354
$374,732
$126,231
$939,317
by Fair Market
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 11-24 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
Services of Orange County Inc.
• Century Housing Corporation
• Civic Center Barrio Housing
Corp.
• Long Beach Affordable
Housing Coalition, Inc
• Housing Corporation of
America
• Nexus for Affordable Housing
• Orange Housing Development
Corporation
• Riverside Chartable
Corporation
• Hart Community Homes
• Keller & Company
• Poker Flats LLC
• Coalition for Economic
Survival
• A Community of Friends
• CSI Support & Development
Services
• ROEM Development
Corporation
• City of Newport Beach
• Abbey Road Inc.
• Jamboree Housing
Corporation
• Innovative Housing
Opportunities, Inc.
• L + M Fund Management LLC
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:
0 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 11-25 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 11-17 includes at -risk units within the city for the 6th planning cycle (2021-2029).
Table 11-18 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 11-26 SEPTEMBER 2022
TABLE Il- 21
COST OF REPLACEMENT
Year
Project 1
Project 2
Project 3 Average
10861 Acacia
16790S Harbor
Address
*
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
7ource: Jamboree Housing, 2022; Orange County Register, 2020; Multi -Housing News, 2019.
As shown above in Table 11-21, 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 11-27 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 11-28 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, goverrunental, 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 11-29 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 pandernic 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 11-30 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 11-22 and 11-23).
TABLE 11- 22
NEW AND RESALE PRICE OF HOMES AND CONDOMINIUMS
TUSTIN AND NEIGHBORING JURISDICTIONS 2020
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-31 SEPTEMBER 2022
Median Home
Median Home
Change from
City
Zip Code
Price- Q2 2020'
Price- Q2 2019'
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%
92843
$431,000
$560,000
-22.9%
Grove
92844
$425,000
$485,000
-12.4%
92845
$749,000
$659,000
+13.7%
92602
$1,300,000
$1,243,500
+4.5%
92603
$970,000
$1,087,500
-10.8%
92604
$811,500
$750,000
+8.2%
92606
$815,000
$799,500
+1.9%
Irvine
92612
$686,500
$663,500
+3.5%
92614
$820,500
$730,000
+12.4%
92618
$920,000
$966,750
-4.8%
92620
$954,500
$1,030,000
-7.3%
92865
$755,000
$640,000
+18.0%
92866
$735,000
$738,500
-0.5%
Orange
92867
$737,500
$737,000
+0.1%
92868
$550,000
$472,500
+16.4%
92869
$655,250
$670,000
-2.2%
92701
$300,000
$380,000
-21.1%
92703
$575,000
$493,000
+16.6%
92704
$550,000
$510,000
+7.8%
Santa Ana
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 11-31 SEPTEMBER 2022
TABLE 11- 22
NEW AND RESALE PRICE OF HOMES AND CONDOMINIUMS
TUSTIN AND NEIGHBORING JURISDICTIONS 2020
Median Home Median Home Change from
Citv Zip Code Price- 02 20201 Price- 02 20191 2019
I Data include all home sales, new and resale, and condon-dniums.
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 person's debt -to -
income ratio, cash available for down payment, and credit history, when determining
a maximum loan amount. Many financial institutions are willing to significantly
decrease down payment requirements and increase loan amounts to persons with
good credit rating.
TABLE 11- 23
AVERAGE RENTAL RATES 2021 - 1ST QUARTER
CITY OF TUSTIN
Number of Bedrooms
Number of
Units
Average Square
Footage
Average
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
Caf6 (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 11-32 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 11-24).
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 11-33 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 11-34 SEPTEMBER 2022
TABLE 11-24
SUMMARY OF RESIDENTIAL ZONING REGULATIONS
CITY OF TUSTIN
Zoning
Minimum
Density
Lot
Building
Front
Interior
Corner
Rear
Parking
Lot Area
Max.
Coverage
Height
Yard
Side Yard
Side Yard
Yard
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 11-35 SEPTEMBER 2022
TABLE 11-24
SUMMARY OF RESIDENTIAL ZONING REGULATIONS
CITY OF TUSTIN
Zoning
Minimum
Density
Lot
Building
Front
Interior
Corner
Rear
Parking
Lot Area
Max.
Coverage
Height
Yard
Side Yard
Side Yard
Yard
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 11-36 SEPTEMBER 2022
TABLE 11-24
SUMMARY OF RESIDENTIAL ZONING REGULATIONS
CITY OF TUSTIN
Zoning
Minimum
Lot Area
Density
Max.
du/ac
Lot
Coverage
Building
Height
Front
Yard
Interior
Side Yard
Corner
Side Yard
Rear
Yard
Parking
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
spacesin
mobile
home
P -D Planned
10,000
Range
To be
To be
To be
To be
To be
2 assigned
Development
Incl.
detern-dne
determine
determine
determined
detern-dne
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
(med)
District
District
District
District
4 units
17.39
1 (high)
I
I
I
I
I
I
I
Source: City of Tustin, Zordng Code, 2021
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-37 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 11-38 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 Prelin-tinary RAR process, which shall provide a prelin-dnary 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 11-39 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.
Prelin-tinary 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 11-40 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 Corranunity 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 11-41 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 Lfgacy Speciflc Plan (formally 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 11-42 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 11-21
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 11-43 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 11-44 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 11-45 SEPTEMBER 2022
in -lieu fee would be $4.41 per square foot, which is much lower than other cities in
Orange County.
TABLE 11-25
INCLUSIONARY HOUSING OPTIONS FOR RESIDENTIAL PROJECTS WITH
FEWER THAN 20 UNITS
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 11-46 SEPTEMBER 2022
OpLions for.w0j:Cts Ith 20 of MO(k VWdanlial units
E.ainptt for calculati6os
114 'Base Units' plu 2aD11SlVBOmwS links m 1-37 Total Unks
AJJ ne. shall hiclo* offordole Vnem
R""', merit
on the iimbff of units is based on the nuntber I
1...ihin
far O-Sh.
in -lieu fee
'twe VK16"Propowfor the pe0jecr.
Affovdable
Units
on.lite
599Z3
IS% afthe *bm unlW SkAtL BE AFFOFaDPA"
If
.114-35%
17
WMApplicable
op tic" (@)(I)
6" .1 J SN �h.?) ft vffi,,dbbk w ry ( hhd�
=114* 6%
7
4 5% Qf 2�% sw be oft,404-k [a �OOww hovsehi*05
=114* 4.5%
51
45% 0i5%5W6, oflaroirm
=114- 4.5%
5
OR
0" "t,
111HIZ3
2"% of the 'ban units' SMALL BE Af FORDABLE
=214 - 12.5%
14
NICE Appik"
p
TS".,
9
j2 5
V 4
OR
Dow off.
-option
5% of the 'ban units" SMALL BE AFFORDABLE to�arylo.
n114 - 5Y.
sile.
Income hiocs1holds plus paynnent of an In -lieu feelseebelow)
OR
0. or Off-
10% of the " base units" SHALL BE AFFORDABLE to lo
' _ntoffie
*Dpiian
10%
11
site
(aX3)Ib)
housihields plus payment OF an In -lieu F" 1we bel—,
,options ja)J3112) and requi fe PayffiLnit Of
999230411)
an In lieu fee calcolatcd by
n $136,801 X Half the number at base units
57
7",657
NOW' Per TO:
9"", 1. CmIpwrin, the total U.1be, of �Jwniary woMarve hfts�g iiaenti� program unks r"u'red in a rt�ldeiviml pmjea, fractions stioll h,,
-Med cis to,he
,..t �bot,
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 11-46 SEPTEMBER 2022
TABLE 11-26
FEE OPTIONS FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS
It should be noted, that the in -lieu fee for projects under 20 units is reduced as the
project size becomes smaller.
TABLE 11-27
FEE PER UNIT FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS
2022 Tustin
In -Lieu Fee Per Unit
For project with fewer than 20 Uni
for
In -lieu per unit reduced
smaller projects
1-4 units
$9,200
Options for Residential Projecu with fewer than 20 units
$10,350
10-14 units
The primary nivans of complying shall be the provision of on-site units.
15-19 units
$12,651
"o-Zer' a 7'elopee may only satisfy the requirements by means of an
on-site
89925(a)
alternative to on-site oluntary workforce housing incenti" program
units in accordance with the require ments and procedures of this
section B9923.
Requirement nvy be satisfied, in whole or in part, by the construction
off-site
89925(b)
ofnew units, orthe conversion of existing market rate units tu voluntary
workforce housing incentive program uniLs, offsite within the city's
jurisdictional boundary.
in -lieu
B9925 (c
Requirement mkay be satisfied in whole or in part, by payment to the $12,651 x 19 S 240,369
payment
CiWs established in -lieu fee.
1.9nd
Requirement may be satisfied, in whole or in part, by an alternative
B9925(d)
option aoceptable to the City, wtil(;h may include without limitation the
acdication
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 11-27
FEE PER UNIT FOR RESIDENTIAL PROJECTS WITH FEWER THAN 20 UNITS
2022 Tustin
In -Lieu Fee Per Unit
For project with fewer than 20 Uni
for
In -lieu per unit reduced
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 11-47 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 11-48 SEPTEMBER 2022
TABLE 11-28
INCLUSIONARY HOUSING FEE COMPARISON
city
USIO
1.1 In IV
H—lo:
Ordin.n.
Applicabi
lrh,.ih. : III.
Affordable
Units
equarements
In -Lieu Fee Allowed?
l"M Fats
ReStunege Lb*
.a H.b,.
Nlaho.Wry
Poja uuth
15%oltotal
W;fawment ofper orroost not
L�
�71
units
7ovided on-sita (ta sed on t he
units
valuation of per unit)
E"unple
A—ed .1—i- pe, .1 it Is $200,DDO
30 tofts ,op—d
'SK requed 1. he affoolble C5 -hih)
5200,000. 5 = $1 nullb.
Hundn on
a'
Mantatory
10
Y.f., ft].rts with 9 or
rhree Un,ts $9,4401unit
n 1�9�0 r cl,eg[st- lewa
Me�i&GU-"Q F3A37144 S- W4CD1 A'EIXC
8—h
P=Ith
3
un , % saftt.1
(Finusl or
fewer unios
Fmu Utts $10,611)(Ijunit
SF0129DOWG��
..as
For Wel
Five Units $11,7801,,it
Fee Is Wied on slidlu, Kale
St, r[i, $12,960JU,1t
Sevin Units $14.1401unit
p
Eight Unit, 515,330iumt
,��d',wnapk.tse,.��—
'g
N1.sU.r. �16,5001.mt
lowee,
Mandatory
Pujeot .0
I'll of tEuI
ys, for W.I.Et win M
S 17,0D) or 0 mics, to 2007,
% or me
rs,
less -1.
TW Ms. on finut.l..
units
Sept. A.
Mandatory
P*Iect with 5
ForSale 1D%
Yes,
Prpeons with 5 to 20 untov $S per Sr
lots/.uft—
of'o.tal uni�
ofhabita"I spane
more
lots
Proje,ts kh 20� units, $S pet SF of
UEQ&=
Into—
ha urtable spsoe
For Rea, 15%
Eff cv— 0,1obst 2, 2021 .. shall
of, ml.ru�
be.:erneoloS15persrof
habit,b]—p—
q_R
J0%V.'
Intome
W Habra
mumsaw'y
pr*�*t
25% of Mal
Y.
IVC; Payrne,t of Fit on It �t not
t�—.
f .. in"bulI&
20o,...
rth
p,mud� —du (booed - the
taths
val,awn of per unit)
E.-opl.:
�.Ineo` v.1—I. I W on it is $2oo,000
3C units Proposed
�5% nequI red 1. be affordable IS units)
� 5 � $1 r, I I1.r
Hooding—
Mandatory
P=Ith
20�% of Mal
Yes,forProjectswith9or
-520D000
Th— un," $%,130f.mt
hm.s s M�F
",.72n232&GUI113A371.-ID�.CDI--�"=
gago,
3
u Its (Pernal or
fewer unIts
Fmu Unit, $r0,5M/,it
EF012900836i
-1.
For -Sale)
"v' —ts $f'r'url—t
Fee 13 b -rad " rl'dloil Kale
51, or it, $12,9SO11 I it
U.is $24,140luffit
Eeven
ight Units $15,330/m,61
hn��, ykWoodts/h
n,,
Nine Units $16,50D/uhll
It,]..
mantatm
Prole with
15%.ft.1.1
Y. for Mitsui with 50 or
$17, ODO par on R prior to 2007.
CHWTER2.3 -AFFORDABLE HOUSING
.,11s
Its, vrill
TGID based or formula.
Santa "a
mareatory
Project with 5
ForSal, ID%
Yes;
Pro,— with 5 1. 2n umno $5 per 7
'potential
1.1sloottlo,
off Woults
of habitable sp—
more
lo—derate
ProjeUS fth 204 undo: $5 pet SF of
WA=
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M WertM to 515 per SF of
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oe
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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 11-49 SEPTEMBER 2022
Housing for Persons with Disabilities/Reasonable Accommodation
As discussed in previously and shown in Table 11-14, 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, ethnicifies, 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 11-50 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 11-51 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 11-52 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 11-53 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 11-54 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 11-55 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 11-28). 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 11-29 summarizes zoning regulations for homeless accommodation.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-56 SEPTEMBER 2022
TABLE 11-29
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
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 properties
(6) or fewer'
'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
realigm-nent/ conveyance process with Tustin as the Local Redevelopment Authority.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-57 SEPTEMBER 2022
0 Six (6) units at Columbus Grove operated by Orange Coast Interfaith Shelter.
0 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 11-30 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 11-58 SEPTEMBER 2022
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 11-31 provides monthly vacancy rate for TTES.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-59 SEPTEMBER 2022
TABLE 11-30
MONTHLY VACANCY RATE VILLAGE OF HOPE (2021)
Month
Average
Monthly
Bed
Occupancy
Total
Available
Beds'
Remaining Vacancy Rate
Beds
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 11-31 provides monthly vacancy rate for TTES.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-59 SEPTEMBER 2022
TABLE 11-31
MONTHLY VACANCY RATE TUSTIN TEMPORARY EMERGENCY SHELTER (2021)
Average Total
Month Monthly Available Remaining Vacancy Rate
— Bed Beds* Beds
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 11-60 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 11-32, 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 11-32
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
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 suvvlv.
Tustin Presbyterian
CITY OF TUSTIN
GENERAL PLAN
Collects food supplies and distributes the
food to various organizations involved in
providing homeless services.
DRAFT HOUSING ELEMENT
11-61 SEPTEMBER 2022
TABLE 11-32
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
Families Forward Grove operated by Families Forward,
formerly Irvine Temporary Housing in
Irvine.
Source: City of Tustin
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-62 SEPTEMBER 2022
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 11-62 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 fan-dly 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 11-63 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 11-33a, II -33b, and Figure 11-2. 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 11-32a and 11 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 11-2) 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 11-64 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 un Uts
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 11-65 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 11-66 SEPTEMBER 2022
TABLE 11-33A
DEVELOPMENT FEES
FEE TYPE LAND USE FEE RATE
Residential Single Fandly 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
I area upon orwithin a building designed for
Park Fees
Hotel or motel rental
unit without a kitchen
When a public park or public recreational facility
is not provided within a proposed residential
subdivision, the subdivision is less than fifty (50)
parcels, or the project is a conversion of an
existing apartment complex to a multi -owner
occupancy not exempted in the Subdivision
Code, a park fee will be required.
$100.00 per unit
The fee is calculated on a per unit basis for each
project, reflecting the fair market value of land
required for park purposes. The value shall be
determined by a Master Appraisal Institute
(MAI) appraiser acceptable to the City and the
ext)ense of the subdivider.
DCCSP: The fee shall be based upon the fair
market value of the amount of land which would
otherwise be required for dedication.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-67 SEPTEMBER 2022
A park fee is also required for non- subdivisions
within the Downtown CommercialCore Specific
Plan (DCCSP) and the Red Hill Avenue Specific
Plan (RHASP).
RHASP: Calculate the amount of land which
would otherwise be required for dedication:
(# of Dwellings) x (0.003 Acre/Person) x
(2.24 Person/ Dwelling Unit)
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-68 SEPTEMBER 2022
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 11-68 SEPTEMBER 2022
Affordable HousingFeej
(Only applicable to
RHASP and DCCSP)
Any residential project
providing voluntary workforce
housing incentive units
pursuant to Subsection (a)(3) of
Tustin City Code B9923 must
also pay the City a voluntary
workforce housing incentive
program in -lieu fee calculated
by either:
Effective January 2022 -
January 2023 Fee = $13,801
per unit
1. Multiplying the voluntary workforce housing incentive
program in -lieu fee by one-half (1/2) the number of base
unitsprovided on-site
(In -Lieu Fee) x (Base Units Provided On-site)
2
2. Multiplying the voluntary workforce housing incentive
program in -lieu fee by one-half (1/2) the residential project's
totalsquare feet of residential area
(In -Lieu Fee) x (Residential Proect's Total Sq. Ft. of Residential
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 11-69 SEPTEMBER 2022
TABLE 11-33B
IMPACT FEES
FEE TYPE
LAND USE
IMPACT FEE RATE
Single Family
$6,056 per unit
Transportation
Zone A Multi -Family
$3,536 per unit
Corridor Fees
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 Is'
Non-
$4.88 per sq. ft. of building area
Residential
Affordable HousingFeej
(Only applicable to
RHASP and DCCSP)
Any residential project
providing voluntary workforce
housing incentive units
pursuant to Subsection (a)(3) of
Tustin City Code B9923 must
also pay the City a voluntary
workforce housing incentive
program in -lieu fee calculated
by either:
Effective January 2022 -
January 2023 Fee = $13,801
per unit
1. Multiplying the voluntary workforce housing incentive
program in -lieu fee by one-half (1/2) the number of base
unitsprovided on-site
(In -Lieu Fee) x (Base Units Provided On-site)
2
2. Multiplying the voluntary workforce housing incentive
program in -lieu fee by one-half (1/2) the residential project's
totalsquare feet of residential area
(In -Lieu Fee) x (Residential Proect's Total Sq. Ft. of Residential
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 11-69 SEPTEMBER 2022
Figure 11-1. Impact Fee Zones
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-70 SEPTEMBER 2022
Figure 11-2. Planning Fees
NO I CASE I YPI FEE
NO. CASE WIFE I FEE
NO. CASE TYPE FEE
Cori ... I Us. permits and Annimicinni
ZsmingAdminut-ttir Rai
Signi
Adm inis"'a"ive
I
Major
$5,000 Deposit
24
Aljuslm ent/Mi no r
�500 D.p-it
46
Ter porary Sign Permit $110 Fee
Amendment
2
Minn,
$2,500 Deposit
General Plan Arnimidminot,
47
Mastic, Sign Program $500 Dsp,cm
3
ABC
$1,000 Deposit
25
Major G ... -
$ 10,00 0
48
Sign Cdo E-cpt- $500 F -
Plan Am on dm ant
Dop-it
4
Sel Rem adii
$1,000 Deposit
26
Minor ne a
$1,000 Depoialt
Varlanzesanc!Am richments., Use De erminsitims,
Plan Am':ndman,
lopmen:Agireem miss . ndtAppeals
5
Am and= t 0
�1,000 Deposit
27
Land U,a Map
$5,000 Deposit
49
M aj a r Van an ce
�5,000 Deposit
C, n tit i f Approval
Logal Rovii- and
6
Adni I' P
$500 Deposit
28
Outside
Actual Costs
so
Minoi-Variance
$1,000 Deposit
Am and on ant
Con,, I
7
Tim s suit cn,i.n,
$250 Fee
Specific Fla. Amendment,
51
Am andments to
$1,000 Deposit
Condition, ofApprov.1
6
a �. Am ndm act
$10,006 Deposit
29
Major P'Cifi
Sp"Ifi
$5,600 Deposit
52
Tir a Extensions
$250 Fee
PI-Annandmient
D-ign Rai and Amendments
30
Minor SP-Ifla
$2,500 Deposit
53
Ennis Change
$10,000 Dspo,it
P1 an Am andment
9
Major
$5,000 Deposit
SubdiA,i.ns andA.endm.nts
54
Uso Distorrininnumn
$S00 DFpoc,t
10
Minor No.
$2,500 Deposit
31
Tentativ, Tract /
$5,000 Deposit
55
Dovel.p.ont
$5,000 Deposit
P arce Map
Agreem ants
ii
Mi no r Rem odpl
$1,000 Deposit
32
Final Tract M so
$2,500 Deposit
56
Appeals
$i,000 Deposit
12
Amand.antt.
�500 Deposit
33
Final Parical Map
52,500 Deposit
PlanninglReview ciflEtuildinglitian Check Submittals
Cond,tion-cAppmval
13
Timro Ents-imn,
$250 Fee
34
Let Line
$2,500 Deposit
57
No. C-Ar-fion
20% Form it Fee
Adjustment
R-dol/Tionant
14
Concept Plan Rev-
$5,000 Deposit
35
Lot Merger
$2,500 Dep -it
58
20% Perm it Fee
Improvements
j$Hl] Par Shapt,
15
Prislimmmor, 1 -is-
-.. $2,000
36
R vprsion to
5500 Epposit
59
Landscape Plan Rpvipw
20% Perm it Fee
Deposit
I
Aer-go
En%4ronmental
37
Ce rtil
$1,000 Depicait
OtherFees
Co in p c:f
A.cndmcnt,t.
Writton 7oning
16
FIR
$20,000 D.po,m
38
Conditions of
$1,000 Deposit
60
Conf,m.t,.n/N.n
$200 P -sl
Approval
Conforming Status Lttur
17
Sups a. ent.1
$10,006 Deposit
39
Tim a Extension
$250Faa
6 1
Annual Parking
'71/Parking
Addendum FIR
Excaption Fsa
E x -ption so. -
Nogat- Dod-timn
Matter
18
Mi t gated Negative
$2,500 Deposit
4 0
Association
$3,000 Deposit
62
Annexation
$10,000 Deposit
Declaration
Dec- ants, CC&,
to
Initial Study
$1,000 Deposit
T.mpmr.myU
63
No., Ra,k Pon. it
$500 DFpoct
Notica of Completion
Tom p.r.ry J-
Planning Servi- -Hourly
20
Dei ination
Actual C.,t,
41
Par. it
$2501's.
64
Rato
Actual C,,t
E- ption
Dia-mient Feias
42
Large Gathpring
51,000 Deposit
65
pse Not Listed
Fair D rect '�o
p arm it
D ster ' nat
21 Black and White Copy �O 10 Pot Pago
43
Ti or P Ext or si on
$12 0 F as
City Counciii Re5olution No. 21-54
22 Cc In - C. py $0 30 Per Pago
44
Film Permit
$5001'so
Adopted July 20, 2021
Fffecti October 1, 2021
23 Othor Plans and Maps Actual Cost
4'
Reasonable
A-m-mr.d.tion
$500 Foa
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-71 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 11-72 SEPTEMBER 2022
TABLE 11-34
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
Residential
Duplexes or two
structure)
PD -
Planned Not Applicable
Development
Apartment
Homes, Bungalow
Courts, Discretionary
Condominiums, (Planning
Community Commission)
District was specifically created to authorize
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
structure)
'Discretionary
District
detached single-
(Planning
Program 1.5, City will amend Zoning Code to
family dwellings
Comn-dssion)
allow triplexes by Right
R3 - Multiple
*Single-family,
**Triplexes (single
Zoning district includes objective design and
Family
ADUs, JADUs;
structure);
Administrative
development standards
Residential
Duplexes or two
Boarding houses;
(Director Review)
District
detached single-
Condominiums
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN 11-73 SEPTEMBER 2022
*Administrative
TABLE 11-34
Specific Plan includes objective design and
See Program 1.2 which commits to the
HOUSING TYPES AND PERMIT PROCESSING REQUIREMENTS
Zone
By Right CUP
Design Review
Notes
Planned
family dwellings;
Condominium
Program 1.5, City will amend Zoning Code to
Multiple family
allow triplexes by Right
(Director Review)
dwellings, apartment
District
Apartment
houses.
allow residential uses by Right
MHP -
projects
'Discretionary
Mobile
Not applicable Mobile home
(Planning
Zoning district includes objective design and
Home Park
parks;
Commission)
development standards
District
See Program 1.2 which commits to the
Agricultural
ADUs, JADUs;
*Administrative
Apartment houses
Specific Plan includes objective design and
See Program 1.2 which commits to the
PD -
Specific Plan Residential Unit
Bungalow courts
Allocation from 500
development of Objective Design Standards
Planned
Not applicable
Condominium
Administrative
Development
Community
(Director Review)
Program 1.5, City will amend Zoning Code to
District
Apartment
allow residential uses by Right
projects
RA -
Residential
*Single-family,
Not Required
*Administrative
See Program 1.2 which commits to the
Agricultural
ADUs, JADUs;
(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 11-74 SEPTEMBER 2022
Planned
TABLE 11-34
Community
Administrative
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
Community
Site #1. Specific Plan will be amended to
See Program 1.2 which commits to the
affordable housing,
allow for additional units per Program 1.1.
Source: City of Tustin
as well as mixed-use
DCCSP -
*Adrrdnistrative
Specific Plan includes objective design and
Downtown
(Director Review)
development standards. The DCCSP Land
Commercial
Mixed -Use, Live- Not Required
with concurrent
Use Plan allows for a total of 887 residential
Core Specific
Work
Residential Unit
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
Adn-dnistrative
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 11-75 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 11-3, Residential Building Permit Process.
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 11-76 SEPTEMBER 2022
Figure 11-3. Residential Building Permit Process
Submit Plans to First review - 10
CU
r. U Send Applicant
CU R
City with payment days
U Z Corrections or
Q.,M
(online or in- Subsequent
".4 Issue Permit
person) Reviews - 5 days
u 0
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 11-76 SEPTEMBER 2022
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 11-77 SEPTEMBER 2022
TABLE 11-35
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
"The
September
submitted for plan check
approval; no permits as
Area -
2021
or obtained permits
of March 2022
Hill"
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 11-77 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 11-4, 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 H-4. - Conditional Use Permit CUP Process and Timelines
pplic tion
P'�Imwrwyik-i—
i Joptiao.i) i su mittal Applicant mod ifies
ita Appl
a p p I i c -a Udonlp I a n s
. pi
and resubmits plans
Application Review for completeness
and CEUA requiremtents (301 -day review)
(3
Application
a �clr'u'cd
Application Complete and project isscheduled incomocte
to da
rpublic hearing within thirty 130) days
Public Notice is mailed, published and posted at least
ten (10� calendar days before public hearing
Raid public hearing; Project is presented to the
Zen Ing Administrator or Pla n rung Com mission
Project Project
Denied I I Approved
1"y
Appeal Period
Decis4on to "OT Decism appealed.* I Decision to Approve NCT
Appeafec[.Applmp��.m,nul Appealed. Applicant may
proceed with the project, proceed with the project.
Streamlined reviewsfor 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 11-78 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 11-79 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 strean-dined, 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 11-80 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 11-5. - Streamlined Administrative Review Process
Prel i m! nary Revi ev., Formal Application
(optional) submittal
Project Project
Denied � Approved
10 -day
Appeal Period
Deasio n to Deny NOT I I Dedsionappealed.* Decision to Approve NOT
appeaf�-d. Applicant may n t appealed. Applicant may
proceed with the projecto I I 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 11-81 SEPTEMBER 2022
Applica,nt,modifies
t
plication p
app"_Ii )n'plans and
P1
Application Review for
es
resubmrt5 plans
.2 s
completeness and CEQA
iw)
requirements (30 -day review)
Application
Incomplete
Application deemed Complete
Project Project
Denied � Approved
10 -day
Appeal Period
Deasio n to Deny NOT I I Dedsionappealed.* Decision to Approve NOT
appeaf�-d. Applicant may n t appealed. Applicant may
proceed with the projecto I I 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 11-81 SEPTEMBER 2022
In 2020, City staff developed a streamlined application and implemented a
complimentary strean-dined 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 11-82 SEPTEMBER 2022
0 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 11-83 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 11-22 (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 11-84 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 11-85 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 11-36
QUANTIFIED OBJECTIVES
Income New Construction Rehabilitation ConservatiorV
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), City's 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 comn-dts 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 11-86 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 13: 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 111-2 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 111-3 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 111-4 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 6th cycle Housing Element
update. A review of the City's past performance on housing element implementation programs
is contained in Appendix A of the Housing Element.
The following table (Table 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- I 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 111. Those programs are only listed once to avoid
duplication.
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible Funding Source I Quantified Objective Timeframe
Agenci I
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
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
As requested between
the By -Right Approval of Projects with 20 Percent
"Reuse"
Development
housing related entitlements
2021 - 2029, Report
Affordable Units on Sites in compliance with
Department
for TLSP by assigning a
annually in April
Government Code Government Code 65583.2(h) and (i).
designated project manager
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:
• Allow 100 percent residential use, and
• 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
0 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
1 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
0 374 housing units by
Core area.
Development
October 2025
Department
0 373 housing units by
Economic
October 2029
Development
Department
Housing
(New) Red Hill Avenue Specific Plan (RHSP)
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 1-5 freeway
Development
assigning a designated project
Department
manager.
0 258 housing units by
October 2025
0 105 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.
General Fund
of 30 du/acre.
(New) By -Right Residential Development to Meet
Community
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
h. Facilitate affordable housing development including
Authority,
Housing Authority
inventory by 50 units over
housing for extremely low income and very low-income
Community
Fund
eight years (10 extremely low;
households, and households with special needs (such as
Development
20 very low; 20 low income
persons with disabilities and farmworkers).
Department
CDBG Fund
units).
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 explais
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.
Economic
new housing developments to
Development
ensure compliance with SLA
Department
and affordable housing
provisions.
1.2 (New) Objective Design Standards lip
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
the construction of affordable housing, including extremely
Community
Development
General Fund
Encourage the use of density
bonus incentives by
Advertise on City
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
r
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
By December 2024
Workforce
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
Program
1.5 (New) Zoning Code Streamlining Program
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Responsible Funding Source
Agenc
a. Implement zoning code amendments to facilitate � Community
application and project review streamlining and compliance Development
with State law to meet housing needs.
General Fund
Quantified Objective
ambiguities and discretionary
action(s)-
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.
Annually review
zoning code and
identify potential
improvements to
strean-dine
development and
permit Amend zoning
code as appropriate
Timeframe
By December 2025
By December 2025
Annually
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
each year.
Home Assistance Program that provides financial and
Development
website for potential funding
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
Update website with ADU
By June 2022
awareness.
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
pertaining to the new
By January 2025
tracking (refer to Program 1.1h), and technical assistance. This
accelerator program for ADUs
program will also create a one -stop -shop comprehensive
and SB 9 developments,
resource for homeowners interested in developing an ADU
specifically to high opportunity
and/or S139 developments. This program will complement
revised Program 1.1(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
0
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 Economic
units for applicable housing
any public funds, as may be legally required. Development
development projects.
Department
1.10 (Modified) Development and Permit
ip
Streamlining
I
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
Community
General Fund
Review number of days to
Bi -annual reviews in June
Department as a central clearinghouse with individuals
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
bi-annually 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 envirom-nental
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 A
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 Abu
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 1 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
PEM "MEN
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
Housing
subject only to those zoning regulations that apply to other
Authority,
residential dwellings of the same type in the same zone.
Community
Transitional and supportive housing meeting certain
Development
criteria will be allowed by -right in zones where residential
Department,
uses are pern-titted, including mixed-use and nonresidential
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 pern-dtting 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
CDBG funds
b. Facilitate continued operation of Sheepfold homes and
Community
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
Authority
Allocate CDBG funds to non -
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
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
State and Federal
outreach program with
program by June 2022
(i.e. brochures, pamphlets, informational flyers, etc. that can
Department
programs; City's
information posted on the
Develop outreach
be shared and posted on the City's website) that informs
General Fund
City's website along with
materials by September
families within the City of affordable housing and services
social media usage.
2022
available for persons with developmental disabilities.
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
Agenci
Quantified Objective
Timeframe
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
identified in Program 2.4d.
nonconformities to property.
(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.
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;
Update website and provide
Community
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
IF
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
0 937 referrals annually
information to the public at all times.
Recreation;
Department;
a 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
TGoal 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 W
a. Facilitate the process of homeownership, especially first-
Housing
State and Federal
Provide educational resources
Annually, start by
time homebuyers, by providing a virtual one stop shop
Authority;
sources
on city website and social
December 2024
clearinghouse through a non-profit organization (i.e.
Community
Development
media.
Affordable Housing Clearinghouse) and explore
participation in the Orange County Mortgage Assistance
Conduct review and analysis
Program (MAP)
for MAP participation.
By October 2023
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
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 Lk
I
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
Agenci
a. Provide rental assistance, through the County Section 8 County of Orange,
program, to extremely low and very low income Housing
households. Authority,
Community
Development
Department
3.6 Affordable Senior Housing Project and Senior
Board and Care Facility
a. Continue to provide opportunities to provide a range of Community
housing options to address the diverse needs of Tustin's Development
senior population. Department
HUD
Through the Orange County
Report annually in April,
Housing Authority, the City
during planning period.
will continue to provide
Section 8 rental assistance to
Publish locations on City
extremely low to very low-
website and verify
income residents with
annually in April
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.
None necessary
Provide at a variety of
Annual report in April.
affordable housing options for
seniors located at:
16000 Cambridge
Publish locations on City
Street (Coventry
website and verify
Court - 153 units)
annually in April
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -34 SEPTEMBER 2022
TABLE IV -1
HOUSING ELEMENT PROGRAMS 2021-2029
Program Responsible
Agency
3.7 (Modified) Preservation of Assisted Housing
a. Preserve units at -risk of conversion to market -rate housing Community
Development
Department,
Housing
Authority
3.8 (New) Middle Income Housing Opportunities
Community
a. Complete a cost -benefit analysis of obtaining membership Development
with the CaICHA - through its Essential Middle -Income Department,
Rental Housing Program ("Program"). Housing
Authority
Funding Source I Quantified Objective I Timeframe
311 Sycamore Avenue
(Heritage Place - 54
units)
a 275 E. 6th Street
(Tustin Gardens - 99
units)
0 17432-17442 Mitchell
Avenue (Tustin
Terrace - 20 units)
State and Federal
Establish annual monitoring
Develop monitoring
Funds
procedures for rent restricted
procedures by December
units provided through City
2023 and begin
incentives and/or financial
implementing
assistance. Contact property
procedures by January
owners within at least one year
2024.
of potential affordability
expiration to initiate
preservation discussions.
General Fund
Review and analyze benefits
By December 2025
from potential participation in
CaICHA program.
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
3.11 (New) Quality Rental Housing Inspection Program
a. Establish a multi -family quality rental housing inspection
program.
Responsible Funding Source Quantified Objective
Agenc
Timeframe
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.
Community CDBG,Home Elevate the quality of housing
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.
By July 2025
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 ChildreWs 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
Community
greater needs for daycare,
low-income families for child care services. The City will
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
Agenci
b. Amend the zoning code to require all new multi -family Community General Fund
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
and increasing the large units into the local housing
inventory.
Goal 4: SUSTAINABLE HOUSING
4.1 (Modified) Code Enforcement Program
a. Encourage property maintenance and enforce building Community City General Fund
codes to address and prevent substandard housing Development
conditions, removal of graffiti and other deferred Department
maintenance issues on public property.
Quantified Objective
Amend the code.
Facilitate the creation of four
(4) large family units will be
generated annually, and 32
total by 2029.
hivestigate substandard
housing an on-going basis;
approximately 25 cases per
year.
Remove approximately 4,000
cases of graffiti annually.
Conduct approximately 100
Water Quality inspections, in
conjunction with the Water
Quality Control Ordinance and
the National Pollutant
Discharge Elimination System
(NPDES) permit process to
protect neighborhoods from
pollution.
Timeframe
By December 2024
Annually, start January
2025 through 2029
Report annually in April
Report annually in April
Report annually in April.
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
Agenci
b. Develop educational and trainings materials, to promote Community General Fund
water efficiency. Development
Department
Quantified Objective
approximately 100 total per
year.
Educate via City's website,
Design Review process and
counter consultations;
approximately 100 total per
year.
Timeframe
Report annually in April
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN IV -43 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
This page has been intentionally left blank.
DRAFT HOUSING ELEMENT
IV -44 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
APPENDIX A
REVIEW OF PAST PERFORMANCE
A-1
HOUSING ELEMENT
SEPTEMBER 2022
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
0 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
GENERALPLAN 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
GENERALPLAN 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.
Disable& 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
GENERALPLAN 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
GENERALPLAN 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
GENERALPLAN 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 BrowW 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
GENERALPLAN 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
'Numbers include total, actual number of units with permits issued and completed.
2 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
GENERALPLAN
ME
HOUSING ELEMENT
SEPTEMBER 2022
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
1 1
Total
1,227
1 1,549
-H
1 100 1 100
'Numbers include total, actual number of units with permits issued and completed.
2 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
GENERALPLAN
ME
HOUSING ELEMENT
SEPTEMBER 2022
APPENDIX A -
ATTACHMENTS
REVIEW OF PAST PERFORMANCE
CITY OF TUSTIN
GENERALPLAN
me
HOUSING ELEMENT
SEPTEMBER 2022
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
GENERALPLAN
A-10
HOUSING ELEMENT
SEPTEMBER 2022
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
I 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
surnmary 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
GENERALPLAN
A-11
HOUSING ELEMENT
SEPTEMBER 2022
New Construction
Rehab/Preservation
Housing
Assistance
Income Group
Goal
Actual
Goal' Actual
Goal'
Actual
Very -Low
283
94
171 253
242
243
Low
195
74
49 132
74
74
Moderate
224
114
Above Moderate
525
1,240
Total
1,227
1,522
220 385
316
317
I 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
surnmary 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
GENERALPLAN
A-11
HOUSING ELEMENT
SEPTEMBER 2022
Program
Goal 1: Adequate Housing
Supply
1.1 Available Sites Continue
to utilize Planned Community
Districts and Specific Plans to
authorize and encourage mixed-
use developments. (See Zoning
Studies Program).
Housing Element Policies: 1.1, 1.5,
1.9
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
Community
Development
Department,
Successor Agency,
City Council
Funding
Source
City General
Fund; City and
Agency staff time
involved
2013-2021
Quantified
Objective
Assist in the
development of new
affordable owner and
rental housing through
development in MCAS
- Tustin and infill areas.
The City supports
applications for the
creation of new mixed-
use developments
particularly when the
projects involve
affordable housing
A-12
Units
Tustin Legacy
(previously referred
to as MCAS):
Amalfi:
Completed 2015
37 Moderate
496 Upper Income
Anton
Com
,pleted 2015
88 Very Low
73 Low
64 Moderate
Other City Areas
Habitaffor
Humanity Veteran
Housiyg_[140 S. A
Street adjacent to
Old Town]:
Completed 2018
1 Low
1 Moderate
Results
Effectiveness
Positive
Tustin Legacy
The City entered into
agreements with
several developers at
the Tustin Legacy for
implementing the
affordable housing
component of the
Specific Plan and
secured units for
housing, including low
income households.
I PTOW] �
Specific Plan approved
in 2018 which added
into this area of the
City the opportunity
for 887 residential
units to be developed.
To date, 140 upper
income units have
been built with a
workforce housing in -
Timeframe
Continue/Modify/
Delete
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
SEPTEMBER 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding Quantified
Agency Source Objective
1.2 Mobile Homes Community City General The City will continue
Continue to maintain the City's Development Fund; processing to maintain the existing
mobile home i)ark zone and fees (recoverable) mobile home park zone.
City of Tustin
Draft Housing Element
A-13
Units
Between 2013-2021,
no applications for
mobile homes or
Results
Effectiveness
lieu fee provided. All
future development
will require
participation in
workforce housing
options contributing to
affordable housing
mostly through mixed
use.
DT -J A C!D
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.
Positive
Timeframe
Continue/Modify/
Delete
On-going
Continue
Appendix A
SEPTEMBER 2022
Program
process conditional use permit
applications as received for manu-
factured homes.
Housing Element Policies: 1.1, 1.4
1.3 Second Residential Units
Continue to provide opportunities
for affordable second residential
dwelling units on Single-family
Residential District lots where
feasible through existing Zoning
Ordinance provisions.
Housing Element Policies: 1.1, 1.8
1.4 Deed Restrictions
Require appropriate deed restric-
tions to ensure continued afforda-
bility for low- or moderate -
income housing constructed or
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
Department, City
Council
Community
Development
Department, City
Council
Community
Development
Department,
Successor Agency,
City Council
Funding
Source
City processing
fees (recoverable)
Tax -Exempt
Mortgage
Revenue
Bonds
2013-2021
Quantified
Objective
The City has updated
its Zoning Code to
allow second units to be
developed within Single
Family zoned
properties without the
need for any
discretionary actions.
During the planning
period, five (5) second
units are anticipated.
All affordable housing
created during the
planning period will be
required to record deed
restriction to ensure
continued affordability
A-14
Units
manufactured homes
were received
Between 2013- and
spring 2021:
15 ADUs were
constructed
4 ADUs are under
construction and
have not yet received
a final
8 ADUs are in the
plan check process
2 ADUs were
withdrawn
2016-2019: 2
affordable
condominium units
for a 60 -year period;
Habitat for Humanity
of Orange County
Results
Effectiveness
Existing mobile home
parks continue to be
maintained.
Positive
On April 4, 2017, the
City Council adopted
Ordinance 1479 related
to accessory dwelling
units (ADUs), formerly
known as second
residential units, in
compliance with new
state regulations.
Positive
Timeframe
Continue/Modify/
Delete
This program will be
included in the 2021-
2029 Housing
Element and future
applications will be
processed as
received in a timely
manner.
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element with
exploration of
additional
programs; future
applications will be
processed as
received in a timely
manner.
On-going
Continue
This program will be
included in the 2021 -
Appendix A
SEPTEMBER 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding Quantified
Agency Source Objective
Units
Results
Effectiveness
Timeframe
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
For affordable units,
Housing Element Policies: 1.1
the City requiring
that the property
projects will
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
densitv bonus units)
1.5 Pre -application
Conferences
Continue to utilize procedures for
pre -application conferences and
City of Tustin
Draft Housing Element
Community City General Continue Positive On-going
Development Fund; City Continued to utilize Continue
Department processing fees pre -application
(recoverable) This program will be
included in the 2021 -
Appendix A
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
Low- and Moderate -Income
Development
Fund; City
Housing
processing fees
(recoverable)
Ensure that processing of permits
for low- and moderate -income
housing are fast -tracked with low -
and moderate -income housing
permits being given priority over
other permit applications.
Housing Element Policies: 1.12
City of Tustin
Draft Housing Element
A-16
Positive
All affordable housing
projects were
recipients of such
streamlined
processin& including
three in the Tustin
Legacy; Amalfi, Anton
projects and Village of
Hope veterans housing
and homeless facility.
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Continue to process
applications in a
timely manner
Appendix A
SEPTEMBER 2022
1.7 Permit Coordination
Community
City General
Continue
Between 2013-2020
Positive
On-going.
Continue the services of the City's
Development
Fund; City
processing fees
1,562 New residential
Continue
Community Development
(recoverable)
projects processed
This program will be
Department as a central
2013: 758
included in the 2021 -
clearinghouse with individuals
2029 Housing
assigned the responsibility of
2014: 46
Element.
expediting development permits
2015: 241
required from various
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
Work with the Regional Center of
Department
website and social
media.
of the Citys website
This program will be
Orange County to implement an
was updated to
included in the 2021 -
outreach program that informs
include affordable
families within the City of
rental opportunities
City of Tustin
Draft Housing Element
WON
Appendix A
SEPTEMBER 2022
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
available for persons with
developmental disabilities.
Housing Element Policies: 1.11,
1.13,1.15
1.9 Housing for the Disabled
Community
State and Federal
Refer individuals to
Development
programs; City's
agencies providing
Require new multi -family
Department
General Fund.
supportive housing that
housing units and apartment
accommodates
conversions to condominiums to
independent living.
comply with State specifications
Add procedures and/or
pursuant to SB 520 for
undertake appropriate
accommodation of the disabled.
amendments to existing
The City will conduct analysis,
standards to ensure
add procedures, and/or
compliance with SB 520.
undertake annronriate
City of Tustin
Draft Housing Element
"M
including a map of all 2029 Housing
affordable rental Element.
opportunities in the
city.
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.
Positive I On-going
Objectives met and Continue
continues. This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
SEPTEMBER 2022
Program
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
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
F.", 6 UJ
Units
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
1.10 Transitional Housing
Encourage the continuation of the
Sheepfold homes and Laurel
House in Tustin, which provide
housing facilities for battered
homeless women and children.
These homes are located in single-
family neighborhoods and
provide a much-needed service
for homeless women and
children. In addition, explore
additional program options to
assist in the provision and
funding for other programs such
as transitional housing and single
room occupancy housing.
Housing Element Policies: 1.11,
1.14
City of Tustin
Draft Housing Element
Various Non -
Profit
Organizations,
Successor Agency,
Community
Development
Department
Variety of
private funds;
CDBG funds
Promote, assist, and
facilitate the
development of
emergency and
transients' shelters
through continued
support of the
County Homeless
Assistance Program
Support local
agencies that provide
homeless services by
providing financial
assistance of
approximately
$5,000410,000
annually.
Consider the
adoption of a Single
Room Occupancy
Ordinance to
facilitate the
development of SRO
units.
A-20
2014: Laurel House
transitional housing
was transferred to the
Orange County
Rescue Mission for
continued assistance
to the homeless,
women, and teens.
2015: The City
conveyed two (2)
four-plexes to the
Orange County
Rescue Mission
(OCRM) in order to
provide transitional
housing to homeless
veterans.
2016: Tustin Veterans
Outpost was
completed in June
2016, with the
capacity to house 26
homeless veterans
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.
Positive
On-going assistance;
during the planning
period, $33,000 of
CDBG funds were
distributed to
organizations that
provide services to
homeless individuals.
Ongoing
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
SEPTEMBER 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible Funding
Agenci Source
2013-2021
Quantified Units
Objective
A-21
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.
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
Program
1.11 Temporary Housing for
Homeless
The City will also support
countywide efforts to assist
approved homeless providers as
part of the MCAS Tustin Reuse
effort.
Housing Element Policies: 1.11,
1.14
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
County of Orange,
Community
Development
Department
2013-2021
Funding Quantified
Source Objective
CDBG funds, Continue to
HUD SHP funds participate on the
Orange County City
Managers/Plannmig
Directors SB 2 Task
Force
Continue to support
192 emergency
housing units to
single men and
women at Tustin
Legacy (Orange
County Rescue
Mission).
The City plans to
assist 200 individuals
by means of
integrating
counseling,
education, job -
training and other
techniques to stop
the cycle of
homelessness.
Continue to support
24 units of
transitional housing
for families
A-22
Units
At Tustin Legacy:
o Construction of a
192 -bed facility at
the Village of
Hope operated by
Orange County
Rescue Mission
completed and
City conveyed the
approximate 5 -acre
property to the OC
Rescue Mission at
no cost.
o Expansion plans of
the existing above -
referenced Village
of Hope facility
capacity from 192
beds to 387 beds,
construction of a
new parking lot,
and establishment
of an ancillary
church use. A
0.57 -acre parcel
was conveyed to
the Orange County
Rescue Mission in
November 2016 to
Results
Effectiveness
Positive
The MCAS Tustin
Specific Plan (now
Tustin Legacy Specific
Plan) provided sites
and designated land
uses to accommodate
the identified homeless
needs.
Timeframe
Continue/Modify/
Delete
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
SEPTEMBER 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
(operated by
Salvation Army)
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,
A-23
Units
construct the
parking lot and
construction is
complete.
o 6 new units at
Tustin Field I to
Salvation Army
provided at no
cost.
o Acquisition
contribution of 16
units in Buena
Park for the
Salvation Army
was completed.
The City assisted
in acquisition and
contributed grant
funds to acquire
the units at no
cost to Salvation
Army.
o 14 new units, in
coordination with
the City of Irvine,
obtained by Tustin
and conveyed to
Irvine Temporary
Housine at the
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible Funding
Agenci Source
2013-2021
Quantified Units
Objective
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)
o 6 new units at
Columbus Grove
to Human Options
at no cost;
complete.
o 6 new units at
Columbus Grove
to Orange Coast
Interfaith Shelter at
no cost; complete.
A-24
o In 2014, the City
Council
authorized the
conveyance of
two (2) fourplexes
to Orange County
Rescue Mission in
order to provide
transitional
housing for
homeless
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible Funding
Agenci Source
2013-2021
Quantified Units
Objective
FWA041
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
Results
Effectiveness I Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
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
Department;
Municipal
Bonds; Private
available programs on
as needed basis.
No tax-exempt bonds
On-going
financing resources and Low-
Housing
Activity
were issued between
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
This program will be
Planning Commission and the En-
coordination between
included in the 2021-
vironmental Management Agency
the County and the
2029 Housing
(EMA) notice the City of Tustin of
City within the
Element.
any roposed development
City of Tustin
Draft Housing Element
A-26
Appendix A
SEPTEMBER 2022
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
Continue to preserve existing sites
Community
Development
Income Housing
Tax Credits;
risk units at Tustin
Gardens, and
Gardens
The City monitors the
Modify
and identify new sites that are
Department
Private Activity
identification of new
project and its
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
Develop a comprehensive
Recreation
Department
Funds
annually
17,198 of our elderly
population utilized
The City far exceeded
Continue
transportation program, case
the transportation
the objective by
City of Tustin
Draft Housing Element
EWA
Appendix A
SEPTEMBER 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding Quantified
Agency Source Objective
management, information and
referral, and shared housing
program.
Housing Element Policies: 1.15,
2.3
1.17 Recycling Single -Family
Uses in R-3 Zones into
Multiple -Family Units
Continue to encourage developers
to consolidate individual lots into
City of Tustin
Draft Housing Element
Units
system services
provided through the
City.
2013: 1,336 persons
assisted
2014: 1,448 persons
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
Community City General Eight (8) housing units Undeterminable
Development Fund; Staff time are anticipated
Department
M
Results
Effectiveness
assisting an average of
2,150 elderly annually.
See also shared
housing for the
objective results which
too were positive.
Timeframe
Continue/Modify/
Delete
This program will be
included in the 2021-
2029 Housing
Element.
Positive On-going
Continue support of Continue
applications as This program will be
received.
included in the 2021 -
Appendix A
SEPTEMBER 2022
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.
Density bonuses, parking
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
Housing Element Programs
Development
Fund; Staff time
to the Planning
Department
Commission and the
From the date of adoption of the
Element.
City Council annually.
Housing element, prepare an
annual report to the Planning
Commission assessing previous
years' accomplishments toward
meeting Housing Element
objectives. Submit the Annual
Report to the State HCD.
Housing Element Policies: all
policies
City of Tustin
Draft Housing Element
FEW
2029 Housing
Element.
The City submitted
On-going
annual reports to HCD
Continue
on or before the April
1st deadlines.
This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
SEPTEMBER 2022
Program
1.19 Consolidated Plan
The City of Tustin shall prepare
an update of the Consolidated
Plan that provides a comprehen-
sive assessment of housing needs,
a housing development plan
incorporating Federal, State and
local public and private resources,
and a one-year implementation
plan.
Housing Element Policies: 1.12,
1.16,1.18,2.1,4.1, 4.2,4.3,4.4,5.1,
5.2,5.3,5.4,5.5
1.20 Zoning Studies
To facilitate the new construction
goals of the 2012 Regional Housing
Needs Assessment, the City
intends to undertake zoning
studies to consider new programs
to encourage and promote
affordable housing and
recommend appropriate
amendments for actions by the
Planning Commission and the City
Council. These studies include:
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
Community
Development
Department
Successor Agency
and Community
Development
Department
Funding
Source
Variety of local,
State, and
Federal funding;
City General
Fund Staff time
City General
Fund,
2013-2021
Quantified
Objective
Prepare Consolidated
Plan in 2014
Prepare Action Plan
annually
Initiate Zoning Studies
by 2015 and complete
any proposed
amendments by 2021.
A-30
Results
Units Effectiveness
Positive
DCCSP area 140 new
units constructed to
date (all within the
Vintage
Development). Of
note, this development
participated in the in -
lieu fee option
regarding affordable
housing provisions.
All units were market
rate.
The City prepared and
the City Council
adopted the 2015-2020
Consolidated Plan on
April 21, 2015.
The City prepared and
the City Council
adopted, the 2020-2025
Consolidated Plan on
April 21, 2020.
Action Plans continue
to be prepared and
adopted annually.
Positive
In 2018, the Tustin City
Council adopted a new
specific plan document,
the Downtown
Conunercial Core
Specific Plan (DCCSP).
This plan introduced
mixed-use and infused
the potential for 887
units into the area
through a Residential
Allocation Reservation
Timeframe
Continue/Modify/
Delete
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Opportunities will
continue to be
explored relative to
this these and
potentially other
zonine related
Appendix A
SEPTEMBER 2022
Program
(1) Creation of zoning provisions
which will accommodate
mixed uses in portions of the
City, particularly in the Old
Town Commercial Area;
(2) Provide relaxation of certain
development standards and
incentives for projects which
include affordable housing
units particularly housing
units for the extremely -low
income upon City Council's
approval;
Housing Element Policies: 1.1, 1.12
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
FlAwl
Units
Results
Effectiveness
(RAR) review process.
Said plan was an
Orange County
American Planning
Association award
winner.
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
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
Timeframe
Continue/Modify/
Delete
studies.
Appendix A
SEPTEMBER 2022
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.
1.21 Private Streets
The City of Tustin has adopted
standards for private streets in
new residential developments. To
reduce construction costs,
developers may be permitted to
install private rather than public
streets, wherever feasible.
Housing Element Policies: 1.17
City of Tustin
Draft Housing Element
City of Tustin � None necessary
Currently in process,
City staff is working on
citywide ADU design
guidelines with
examples as well as an
ADU zoning update.
A-32
Appendix A
SEPTEMBER 2022
Additionally staff is
working on residential
related mixed-use
parking strategies for
the DCCSP area.
Continue
Positive
On-going
Private street
Continue
standards were
This program will be
implemented in most
included in the 2021 -
Tustin Legacy area
2029 Housing
residential
Element.
developments that
occurred during this
time period.
A-32
Appendix A
SEPTEMBER 2022
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,
The State of California has
Community
Development
determined that the over-riding
Department
value is the protection of the
health and safety of residential
Continue
occupants. Continue to adopt the
California Building Code
adopted the 2013, then
pursuant to the state directives
and where local amendments are
proposed to reflect local climatic,
This program will be
geologic or topographic
conditions, and minimize,
California Building
wherever possible, impacts on
provision of housing.
Housing Element Policies: 5.4
2029 Housing
City of Tustin
Draft Housing Element
City General
On-going
During this reporting
On-going
Fund; Staff time
period, the City
Continue
adopted the 2013, then
2016, and now the 2019
This program will be
California Building
included in the 2021 -
Codes.
2029 Housing
Element.
A-33
Appendix A
SEPTEMBER 2022
1.23 Site Improvements
Community
Developer
Evaluate the use of
Positive
On-going.
The requirement for the developer
Development
Department,
funded
special assessment
district funding at
Assessments were
Continue
to construct site improvements
Tustin Legacy and its
issued for a
This program will be
often results in passing these costs
use in other developing
Community Facilities
included in the 2021 -
on the housing consumer. These
areas.
District Annexation
2029 Housing
costs are reflected in the cost of
Area at Tustin Legacy
Element.
housing that eliminates an even
in 2014 (CFD 14-01) for
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 for a new
facility district on a per parcel
Community Facilities
benefit basis may enable a greater
District 2018-1
proportion of the market to
Improvement Area 1
qualify for housing. Assessment
(CFD 18-01 IA 1) at
district financing has been
Tustin Legacy in 2018
implemented in the East Tustin
for the Lermar Homes
and Tustin Legacy areas and is
of Southern California
being used to pay for public
(formerly CalAtlantic
improvements. The City will
Homes) development
assess opportunities to continue to
of 218 townhomes,
utilize these public improvement
flats, and single-family
financing techniques in newly
homes and for
developing areas such as Tustin
Brookfield Homes of
Legacy and determine whether
Southern California, a
they are financially feasible. In
future development of
creating any new assessment
400 townhomes, flats,
districts, an evaluation should be
and single-family
completed of the developer's
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
Legacy, the City will
City of Tustin
Draft Housing Element
FEW
Appendix A
SEPTEMBER 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
A-35
Units
Results
Effectiveness
continue to evaluate
financing mechanisms
to fund infrastructure
improvements.
Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding
Agency Source
1.24 Fees, Exactions, and Community
Permit Procedures Development
Consider waiving or modifying Department,
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.
Housing Element Policies: 1.12
City of Tustin
Draft Housing Element
City General
Fund;
Quantified
Objective
Defer development
impact fees during
economic downturns.
A-36
Results
Units Effectiveness
Neutral
Adoption of a new
policy has been
evaluated and
considered on an
annual basis. No
changes to date
though continually
being monitored and
considered.
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.
Timeframe
Continue/Modify/
Delete
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element.
Appendix A
SEPTEMBER 2022
1.25 Environmental
Community
General Fund;
On-going
Effective
On-going
Constraints
Development
Private
During the Housing
Continue
Continue to alleviate the necessity
Department,
developer cost
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
2029 Housing
into the development plans by re-
Specific Plan included
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 E1R 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 a large
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
Department
density bonuses.
In 2015, two apartment
Continue
facilitate the construction of
developments that
This program will be
affordable housing. Under State
were granted density
included in the 2021 -
City of Tustin
Draft Housing Element
A-37
Appendix A
SEPTEMBER 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding Quantified Units
Agency Source Objective I
Results
Effectiveness
Timeframe
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
Implementation
Implementation of the Specific
Plan for MCAS -Tustin site
Housing Element Policies: 1.1, 1.3,
1.5
City of Tustin
Draft Housing Element
Successor Agency General Fund Process entitlements for See Program 1.1
MCAS Tustir
no
Positive On-going
Achieved Continue
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
SEPTEMBER 2022
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
Department,
400 Tustin residents
annually, 3,000
Fair Housing
Continue
housing counseling services to
City's contractor
residents by 2021.
Foundation estimated
This program will be
assure equal housing
that the number of
included in the 2021 -
opportunities within the City.
Tustin residents
2029 Housing
The City allocates approximately
provided with direct
Element
$15,000 annually for handling
client assistance
tenant/landlord disputes,
during this planning
housing discrimination cases,
period was 1,333.
counseling, tenant rights, fair
Yearly educational and
housing education, and education
outreach activities
within the City. The City will
occurred including
continue to promote the fair
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
Continue to provide coordination
Recreation
Services
The City provided
Continue
and support to a home sharing
coordination and
City of Tustin
Draft Housing Element
A-39
Appendix A
SEPTEMBER 2022
Program
program funded in part by the
Community SeniorServ, formerly
known as Feedback Foundation,
Inc., as part of TLC
(Transportation Lunch and
Counseling) and the Orange
County Housing Authority.
Housing Element Policies: 2.3
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agency Source Objective
Department, and
Community
Development
Department
FWAX1111
Results
Units Effectiveness
support through the
referenced program
and providers. In
2020, the Community
SeniorSery (formerly
known as Feedback
Foundation) changed
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 pandernic
had an effect on this
program and the
ability to service
seniors at the facility.
See also Senior
Services Program.
Timeframe
Continue/Modify/
Delete
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
SEPTEMBER 2022
Program
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
WAVE I I
Units
Results
Effectiveness
For senior housing
requests, seniors are
referred to the Office
on Aging Orange
County, which
provides resources for
senior housing and
case management.
Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
2.3 Housing Referral Program
Police
City General
* 7,500 referrals to
Effective
On-going
Continue to provide housing
Department;
Fund, CDBG
Funds
social agencies by
The Economic
Continue
referral services to families in
Parks and
2021
Development
This program will be
need of housing assistance and
Recreation
* 50 referrals for
Department and
included in the 2021 -
information. This program
Department;
shared housing by
Tustin Housing
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
homeless people to different
To assist referrals, the
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
Draft Housing Element
A-42
Appendix A
SEPTEMBER 2022
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 Citizens
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 Progaml.18
Element Programs
Consolidated Plan
See Program 1.19
Goal 3: Ownership
Housing
City of Tustin
Draft Housing Element
A-43
Appendix A
SEPTEMBER 2022
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
Modify - The
The Housing Authority applies
eliminated low- and
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
made it more difficult
MCC and continue
State and Federal 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 Programl.13
City of Tustin
Draft Housing Element
E W, fle
Appendix A
SEPTEMBER 2022
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 Programl.18
Element Programs
Consolidated Plan
See Programl.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
Authority,
Continue
Housing Authority, where
This program will be
necessary, for the development
included in the 2021 -
and operation of federally assisted
2029 Housing
low- and moderate -income
Element
housing programs.
Housing Element Policies: 1.3,1.7,
1.14
City of Tustin
Draft Housing Element
A-45
Appendix A
SEPTEMBER 2022
4.2 Rental Assistance
County of Orange
HUD
Issue 200
Effective
On-going
Encourage the availability of
Housing
Authority
certificates/ vouchers
annually- 1,600 by 2021.
The Orange County
Continue
Section 8 rental assistance
Housing Authority
This program will be
certificates and voucher certificate
issued the following
mcluded in the 2021 -
program assistance funds through
annual voucher counts
2029 Housing
the Orange County Housing
for Tustin residents:
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 be
To maintain 74 units of affordable
included in the 2021 -
housing for Seniors located at
2029 Housing
17432-17442 Mitchell Avenue (20
Element
City of Tustin
Draft Housing Element
A-46
Appendix A
SEPTEMBER 2022
Program
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
Housing
Tustin has four (4) low-income
housing project with a total of 517
units "at -risk" of conversion to
market rate during the planning
period. If project owners choose
to convert the projects to market
rate housing, the City will
coordinate the provision of
financial and administrative
resources to preserve these units
as affordable housing.
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
Program Parameters
Responsible
Agency
Community
Development
Department,
Housing
Authority
Housing
Authority
working with a
non-profit
affordable
housing developer
a) Monitor Units at Risk:
Maintain contact with owners
of at -risk units as potential
conversion dates approach to
Community
determine whether Section 8
Development
contracts or affordability
Department,
covenants have been renewed
Housing
or are planned to be renewed.
Authority
Discuss with the owner of the
City of Tustin
Draft Housing Element
Funding
Source
State and Federal
Funds
4% Tax Credit
and Bond
Financing, other
funding sources
State grants and
HUD funds
2013-2021
Quantified
Objective
Pursuant to
Government Code
Section 65583.1 (c),
preserve at minimum
100units currently
identified as "at- risk"
at Tustin Gardens for
the time frames
required by applicable
Government Code
Section
65583.1.(c)(2)(C)(i) or
Health and Safety Code
section
Preserve 100 units at
Tustin Gardens
FEW I YA
Units
The 100 at -risk units
(Tustin Gardens)
were maintained.
Also, despite the
elimination of a major
funding source, the
Housing Authority
was also able to
preserve a total of
two low- income
units and one very
low-income unit in
foreclosure by
purchasing them and
selling them to other
families.
Results
Effectiveness
Effective
The City maintains
contact with Tustin
Gardens and has been
monitoring their
annual renewal option.
Annual Monitoring:
The Housing
Authority annually
mails letters to
homeowners
requesting
documentation
verifying continuing
compliance with the
affordability covenants
they entered into with
the City when they
purchased their
affordable unit.
Timeframe
Continue/Modify/
Delete
On-going and
modify as additional
housing projects will
fall within this
program category
over the next
planning period
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
SEPTEMBER 2022
Program
I at -risk" projects the City's
desire to preserve the units as
affordable.
b) Work with a nonprofit
affordable housing developer
to apply for 4% Tax
Credit/ Bond Financing for the
acquisition and rehabilitation
of Tustin Gardens, preserving
100 at -risk units.
c) Tenant Education. Work with
tenants of at -risk units in
danger of converting. Provide
tenants with information
regarding potential tenant
purchase of buildings
including written information
and any related workshops.
Act as a liaison between
tenants and nonprofits
potentially involved in
constructing or acquiring
replacement housing. If
existing staff is not able to
provide adequate staffing for
this program, provide outside
consultants to support the
program.
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
WIT100
Units
Results
Effectiveness
Affordable Units at
Risk of Foreclosure:
The Successor Agency,
now Housing
Authority, prepared
monthly foreclosure
reports to all City
operating departments
in order to monitor
and keep City
sensitive to the
implications on
property conditions
and blight as a result
of the foreclosure
activity associated
with periods of
economic downturn in
the residential and
commercial markets,
The Housing
Authority (created in
2011) was created by
the City Council to
assist the City in
increasing, improving
and preserving its
supply of affordable
housing.
Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
Program
d) Reserve Fund. Continue to
monitor other potential
funding sources, such as State
grants and HUD funds.
Housing Element Policies: 4.1, 4.2,
4.3,4.4
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
FWAIWVJ
Units
Results
Effectiveness
In 2014, as a result of
increased foreclosure
activity, the City
Council approved an
Affordable Housing
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
Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Program Responsible Funding Quantified
Agency Source Objective
4.5 Temporary Housing
Housing
HUD Section 8
Promote, assist, and
Assistance for Extremely Low-
Authority and
Program, CDBG
facilitate programs to
Income Households
Community
prevent extremely low -
Assist in the provision of
Development
income households to
temporary and emergency
Department
become homeless by
housing assistance to prevent
providing links and
homelessness for the extremely
program information on
low-income households as well as
City's website and at
coordination with regional, state
the Tustin Library,
and federal assistance programs
Senior Center, and
for assisting these households in
City of Tustin
Draft Housing Element
Wme"111
Results
Units Effectiveness
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.
Effective
In accordance with
AB 987, the Housing
Authority maintains
a list on the City's
website of all
affordable ownership
units and affordable
rental units in the
City of Tustin. In
addition. links to
Timeframe
Continue/Modify/
Delete
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
SEPTEMBER 2022
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
residential units in target areas
resources
(2) four-plexes by
This program will be
conveying 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
Draft Housing Element
A-51
Appendix A
SEPTEMBER 2022
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
Continue to enforce building and
Department
cases annually and
240cases by 2021.
are not kept by the
This program will be
housing codes to ensure health
City, the City's Code
Included in the 2021 -
and safety, rectify Code violations
Enforcement Staff
2029 Housing
and thereby improve the overall
estimated that over
Element
character of the community.
2,300 property
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
are generally received
owner to allow City to recover
by Code Enforcement
enforcement cost.
are very minor
City of Tustin
Draft Housing Element
A-52
Appendix A
SEPTEMBER 2022
Program
Housing Element Policies: 5.3, 5.4
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
A-53
Units
Results
Effectiveness
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.
Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
5.2 Cultural Resources
Community
CDBG, City
Rate historic structures
Effective
On-going
District
Development
General Fund,
where applicable and
Process Certificates of
Continue
There are a large number of struc-
Department
State grants
process certificates of
Appropriateness as
tures in the City that were
appropriateness as
received.
received.
This program will be
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-
improvements to
guard the heritage of the City by
properties located
preserving neighborhoods and
within the Cultural
structures that reflect the City's
Resources District by
heritage and past. Through the
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
Draft Housing Element
FEW
Appendix A
SEPTEMBER 2022
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
Require all new construction to be
Development
Department
within planning period.
In force. See Program
Continue
subject to State energy conserva-
1.7, Permit
This program will be
tion requirements (Title 24) as a
Coordination, for
included in the 2021 -
condition for the issuance of a
statistics.
2029 Housing
building permit.
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
California HERO
2029 Housing
may be explored. Examples
Program to finance
Element
include installation of
distributed generation
photovoltaic systems, tank -less
renewable energy
City of Tustin
Draft Housing Element
A-55
Appendix A
SEPTEMBER 2022
Program
water heater, natural gas recharge
connection, electric vehicle
recharge connection, wind power
generator, etc.
Housing Element Policies: 6.6
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified
Agenci Source Objective
A-56
Units
Results
Effectiveness
sources, energy and
water efficiency
improvements and
electric vehicle charging
infrastructure.
Availability of grants
Timeframe
Continue/Modify/
Delete
Appendix A
SEPTEMBER 2022
6.3 Solar Energy and
Conservation
Require that environmental
analysis and subdivision plans
address energy conservation
measures and solar access. With
the passage of AB 32, the City in
anticipation with the State
mandates will set thresholds
within its CEQA checklist and
require developers to address
energy conservation measures
applicable to their proposed
development proposals.
Housing Element Policies: 6.2,63
City of Tustin
Draft Housing Element
Community None necessary On-going
Development
Department
NAVIN
Effective
CEQA checklist
updated to include
greenhouse gas
emissions.
Supported solar panels
installation in
residential and
commercial buildings.
During the planning
period, the City issued
the following number
of residential and non-
residential solar panel
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
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
SEPTEMBER 2022
Program
6.4 Building Orientation
Promote energy efficiency by
orienting homes to maximize
natural day lighting. The City
will work with potential
developers during the conceptual
review level (Design Review) by
promoting building siting that
maximizes natural day lighting.
Housing Element Policies: 6.2, 6.3
City of Tustin
Draft Housing Element
TABLE A-2
EFFECTIVENESS OF HOUSING ELEMENT PROGRAMS
2013-2021
Program Parameters
Responsible Funding Quantified Units
Agenci Source Objective
Results
Effectiveness
industrial property
owners for water
conservation and
energy efficiency
improvements.
Timeframe
Continue/Modify/
Delete
Community None necessary On-going Effective On-going
Development On-going Continue/Modify
Department
This program will be
included in the 2021-
2029 Housing
Element
Wme"s]
Appendix A
SEPTEMBER 2022
6.5 Water Efficiency
Promote water -efficient
landscapes, efficient irrigation,
and use of permeable paving
materials. Through educational
materials and trainings, the City
will promote water efficiency
methods to its residents.
Landscape beautification which
results in water conservation
could be encouraged through
planting of drought tolerant
plants, installation of drip
irrigation, installation of rain
detector/sensor irrigation, etc.
Incentives such as over the
counter permit plan check,
discounted fee, or waiver of
pern-dt fee could be considered.
Housing Element Policies: 6.4
City of Tustin
Draft Housing Element
Community None necessary
Development
Department
Promote water efficient
programs by
conducting workshops
and providing
education materials on
the City Website, public
counter and at schools.
A-59
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 also 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 Browr�s
Executive Order. An
annual report
summarizing activities
between January 1st
and December 31st of
On-going
Continue
This program will be
included in the 2021-
2029 Housing
Element
Appendix A
SEPTEMBER 2022
City of Tustin
Draft Housing Element
ME
Appendix A
SEPTEMBER 2022
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
Draft Housing Element
ME
Appendix A
SEPTEMBER 2022
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
Streamline processing for
Development
Department
green building and
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
Draft Housing Element
EVIN
Appendix A
SEPTEMBER 2022
TABLE A-3
PROGRESS TOWARDS OBJECTIVES 2013-2021
CITY OF TUSTIN
I Quantified I Extremely Very
Unit Type/Description I Objectives I 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
Undefined
Undeterminable
Units (Tustin Legacy)
Neighborhood D
1,048
533
37
496
Neighborhood G
1,247
818
88
73
64
593
Units Approved/Under
12 ADU's
Construction (2020
Undefined
(undefined income)
Annual Progre s Report))
Undefined
Undeterminable
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 MID
8
Undeterminable
in R-3 district
Subtotal
3,000
514
303
348
1,835
RHNA
1 1,2271
1
283
1951
2241
525
Difference
1 1,7731
1
231
1081
1241
1,310
1,534
(includes 1,522 ur-dts +
12 ADLYs approved
and under
ACTUAL TOTAL UNITS
RHNA
Required
construction)
19-1
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
CITY OF TUSTIN
GENERALPLAN
A-62
APPENDIX A
HOUSING ELEMENT
SEPTEMBER 2022
TABLE A-3
PROGRESS TOWARDS OBJECTIVES 2013-2021
CITY OF TUSTIN
PRESERVATION
Tustin Gardens 1 -100 1001 loo
Total Preservation 1 100 1001 too
OTHER FOCUSED
AFFORDABLE
HOUSING PROGRAMS
Homeless Assistance &
Quantified
A variety of support
Extremely
Very
Unit Type/Description
Objectives
Accomplishments I
Low
Low
Low
Moderate
Upper
Tustin Legacy New
Of Note - 5,3U7
8
Construction Inclusionary
452
residential additions
Total Rehabilitation
Undefined
and alterations
Other Admirdstrative
realized during the
Support (Housing
planning period
PRESERVATION
Tustin Gardens 1 -100 1001 loo
Total Preservation 1 100 1001 too
OTHER FOCUSED
AFFORDABLE
HOUSING PROGRAMS
Homeless Assistance &
Variety of
A variety of support
Supportive Services
Programs -
Undefined
services provided
Tustin Legacy New
Construction Inclusionary
452
230
Housing Requirement
Other Admirdstrative
Support (Housing
Authority; Density
Variety of
Bonus'; Affordable
Programs -
A variety of support
Housing Assistance
Undefined
services provided
Programs (associated
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)
CITY OF TUSTIN
GENERALPLAN
A-63
APPENDIX A
HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
APPENDIX B
SITES INVENTORY
B-1
HOUSING ELEMENT
SEPTEMBER 2022
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
Income Group
RHNA
Units
Approved
ADUs
Permitted
Net RHNA
Need
Very Low
862
6
1
855
Extremely Lowl
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.
AD UsIJAD Us - 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
corranunity to accomrnodate 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 manner. 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 - (RHA5P) 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 (Demy'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 Cen Uer
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 improvernent-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 Plan's 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 - (DCCSL?) 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 BanWs 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 comer 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
Fnd.er7p Cpnfpr
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
Property
TLSP -
Neighborhood D
North (includes
Specific Plan
Vacant
296
555
230
66
72
187
amendment) (Site
1A)
TLSP -
Neighborhood D -
South (includes
Specific Plan
Vacant
532
1,396
314
218
244
620
amendment) (Site
1B) (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
Property
3 Non -
Vacant
Site 3 (Approved
Vacantl
Entitlements)
Non-
Vacant-
Approved
6
137
6
0
0
131
Housing
Project
Site 4
Non -vacant
0
226
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
Property
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
Place
Non -vacant
0
900
225
141
150
384
Projected ADU &
35
9
6
6
14
JADUs
Entitled Units
(Transitional
Vacant -
Approved
Homes) - 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.
Zon "n
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
Zoning
Site Size
(Acres)
Lot
Consolidation
Potential
Availa le
Infrastructure
Tust'n Legacy Specific P an Area
1
Vacant,
Yes*
Varies
Yes
Planned as
Neighborhood
part of
D North and
Master
South.
Planned
CITY OF TUSTIN
GENERAL PLAN
M. me
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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
Red Hill Avenue Specifi 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. Shoppin
Center)
Downtown Commercial Core Specific P an 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
Apartm nts
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
GENERAL PLAN
1:B
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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 1-5
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
Zoning
Site Size
(Acres)
Lot
Consolidation
Potential
Available
Infrastructure
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 Capaci!y
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 Development 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-fan-dly
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 Ana2
MEMU Overlay Zone Recent
-
45-90
Developments
Sources:
'City of Irvine Second Draft 2021-2029 Cycle Housing Element Update, November 19, 2021
2City 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):
0 The TLSP area is anticipated to provide capacity of
o 555 units over approximately 40 acres in Neighborhood D North (40
du/ac minimum);
o 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).' 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:
• 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.
• 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 envirom-nental 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
GENERAL PLAN
B-22
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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.
0 The RHASP area is anticipated to provide capacity of
o 395 units over approximately 10 acres north of 1-5 (40 du/ac) and
o 105 units over approximately 6 acres south of 1-5 (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.
0 The DCCSP area is anticipated to provide capacity of
* 45 units over approximately 1 acre in DA1 (41 du/ac minimum);
* 92 units over approximately 2 acres in DA2 (48 du/ac minimum);
* 200 units over approximately 17 acres in DA3 (12 du/ac minimum);
* 150 units over approximately 4 acres in DA4 (38 du/ac minimum);
and
* 260 units over approximately 11 acres in DA6 (27 du/ac minimum).
* 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.
0 Enderle Center and Tustin Market Place
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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.
C"'Onprnl
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. h -i
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 Preferen
The COVID-19 Pandernic 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
GENERAL PLAN
B-26
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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
Proposed Zone:
Allow mixed-use development with
minimum 30/du acre (Refer to Program
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
During Planning Period:
Rezone properties to allow mixed-use,
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 1-5 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
GENERAL PLAN
B-28
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
TABLE B-5
The Market Place
Existing Zone:
PCMU - SP 8 (East Tustin Specific Plan)
Proposed Zone:
Allow mixed-use development with
minimum 30/du acre (Refer to Program
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
During Planning Period:
Rezone properties to allow mixed-use,
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
GENERAL PLAN
B-30
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
ATTACHMENTS
ASSOCIATED WITH APPENDIX B
SITE INVENTORY ASSESSMENT
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-31 SEPTEMBER 2022
Attachment B-1
Sites 1dentification to Meet RHNA*
Site
#
Site Reference
Vacant or
Non-
Vacant
Identified in
Previous 4 th
&/Or 5 1h
Cycles / Was
Counted
Towards
RHNA
Site
Size
(Acres)
APNs
Ownership
Zoning
General
Plan
Capacity
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
1B
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
GENERAL PLAN
B-32
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-33 SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
Vacant
Counted
(Acres)
Towards
RHNA
2
Neighborhood G PA 15
Vacant
Yes(both)/
50.321
City of Tustin
SID I
TLSP
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 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 (5" only)
LLC, a Delaware
Not for RHNA
Limited Liability
Company
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-33 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
111111011
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
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 El 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
GENERAL PLAN
111111011
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-35 SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
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 Area 2 92 units
8
Bel Air M tor Hotel at 140 W. First
Non-
No/No
1.0
401-571-14
GLIVI Ventures LLC
SP 12
DCCSP
Street
Vacant
DA -2
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-35 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
111M
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
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 El
Vacant
DA -2
Camino Real
150 E. First Street (Tustin War Mem)
0.43
401-583-01
City of Tustin
105 El 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 11 Larwin Sq SC
13421 Newport Avenue Tustin
0.32
401-601-05
PK 11 Larwin Sq. SC
13451 Newport Avenue
0.38
401-601-06
PK 11 Lawrin Sq. SC
13471 Newport Avenue
0.39
401-601-07
PK 11 Larwin
550 E First St
1.00
401-601-08
Haggen Property
South LLC
CITY OF TUSTIN
GENERAL PLAN
111M
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-37 SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
General
Capacity
#
Plan
Vacant
Counted
(Acres)
Towards
RHNA
275 Centennial Way
0.46
401-601-09
PK 11 Larwin Square
662 E First Street
0.91
401-601-10
PK 11 Larwin Square
Development Area 4 150 units
11
Farmer's Market Related Properties
Vacant
Yes(both)/
1.02
SP 12
DCCSP
at 225-255 El 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 El Camino Real
0.17
401-584-06
Mary M. Prescott
245 El Camino Real
0.17
401-584-07
Mary M. Prescott
235 El Camino Real
0.17
401-584-08
Mary M. Prescott
225 El Camino Real
0.17
401-584-09
Mary M. Prescott
12
NEC of El Camino Real & Sixth Street
Vacant
Yes(both)/
2.29
SP 12
DCCSP
at generally 542 El Camino Real
No
DA -4
520 El 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. 6 1h 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
Pacific
SP 12
DCCSP
Arvida Book Store, previously Mrs.
Maintenance &
DA -4
B's)
Repair Inc.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-37 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
1XIM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
Vacant
Counted
(Acres)
Towards
RHNA
14
420 El Camino Real
Vacant
No/No
0.44
401-622-18
Radon Davor
SP 12
DCCSP
I
DA -4
Development Area 6 260 units
15
Vacant Lot Adjacent to 1-5 Freeway
Vacant
Yes (5" cycle)
2.73
SP 12
DCCSP
& east of Jack in the Box Restaurant
/No
DA -6
at 14042 Newport & El 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
El Camino Plaza at SWC of El Camino
Non-
No/No
7.81
SP 12
DCCSP
Real & 6 th Street
Vacant
DA -6
620 El Camino Real
3.5
401-631-01
ECP Investors LLC
634 El 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 17 th St, 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
GENERAL PLAN
1XIM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Note: Unit capacity incorporates anticipated TLSP rezone (Neighborhood D — North)
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-39 SEPTEMBER 2022
Identified in
Previous 4 th
Vacant or
&/Or 5 1h
Site
Site
General
Site Reference
Non-
Cycles / Was
Size
APNs
Ownership
Zoning
Capacity
#
Plan
Vacant
Counted
(Acres)
Towards
RHNA
18
The Market Place, near Interstate -5
Non-
No/No
76.93
500-291-25
Tustin Market
SP 8
PCC13
900
and Jamboree Rd, near the City of
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 El Camino Real
(Entitled,
No
Plan
check and
permits
currently
underway)
Other
ADUs&JDUs
Non-
No/No
NA
NA
NA
Varies
Varies
35
Vacant
I
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 13-1A
Sites Identification to Meet RHNA - Realistic Capacity Estimates
CITY OF TUSTIN
GENERAL PLAN
B-40
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Site
Density (Gross Land Area)
REALISTIC CAPACITY
Density (Net Land Area)*
# 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
113
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
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
GENERAL PLAN
B-40
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
/
Suitable Sites for Additional o
Residential Development
I##, do
I _j
LK
40
Suitable Site Locations
Downtown Commercial Core Specift Plan
Red Hill Avenue Specific Plan
Tustin Legacy Specific Plan
Enderle Center
Tustin Marketplace
Municipal Boundaries
N
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
1 -4,
H, "Ph
2021-2029
Housing rjemwnt
FF Site 1A
TLSP NEIGHBORHOOD D NORTH C
Area does not have residential
SpdAc: Pl— 8—d.ry
Site 2
TLSP NEIGHBORHOOD G
2,029 remaining units in this area
Amend TLSP to accommodate a
minimum of 200 additional housing
units to meet RHNA
50.321 acres (VACANT)
units planned
Amend TLSP to accommodate D North
a minimum of 555 additional
units to meet RHNA
39.873 acres (VACANT)
D SITE 113
South TLSP NEIGHBORHOOD D SOUTH
1,296 remaining units in this area (includes 400
-field)
approved units — Brook
Amend TLSP to accommodate a minimum of 100
additional housing units to meet RHNA
45 acres (VACANT)
T--wo ..MOW
The sites in TLSP are vacant. Development is under the control of the City since the City owns the land.
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN SEPTEMBER 2022
B-42
SITE IA: NEIGHBORHOOD D North (Rezone)
39.873 A.rres Zoning: SP 1
General Plan. TLSP 555 Units
Address
APN
Acre
Tutal
Acreage
Tu5tin
Legacy
Specific
430-381-38,
0-002
Plan
39.873
North
430-381-41
2.466
430-381-91
1,235
1
1430-381-95,
36.17
Sou rce: Ora nge Cou r ty Asse-5�o r Parc e�
Map
Awl w mvaow
m
.0,
WA! X VU A M 5k.' Z
Awm mhff-�
oo-38
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-43 SEPTEMBER 2022
Site 113 NEIGHBORHOOD D SOUTH
* 45 Acres 1396 Units
* Zoning: SP 1 General Plan: TLSP
Includes 13fookfield Development (400 units)
,208 Future Units— Multiple Family
Address
is
South
Brookfield
Tract
18197
APN Acre
Total
Acreage
44�86
Lot 2 -S-289
Lot 5 2.778
Lot 6 2-639
Lot 7 2.572
Lot 8 4.012
Lot 9 3.984
Lot 10 4.163
Lot 11 7.039
Lot 12 6.934
Lot 13 5.451
Source: Orange County Assessor Map
CITY OF TUSTIN
GENERAL PLAN
B-44
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
NEIGHBORHOOD G
Addres
APN
Acre
Tota I
s
Acreage
430-3al-
Ne4hbor
27
0�665
430-381-
hoW ri
3.573
1.559
"28
430-381-
29
1 QAQ
1.
Sou rm Ora nge Cou nty Assesso r Pa rcel M a p ""
Ow - Ast""'I KOO a 4m
NPM AMEN mm 4" rw 31
W. & CrAVI ow" 0 A&W
op -38
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-45 SEPTEMBER 2022
Continued
IPAR
NEIGHBORHOOD
G
AW M W=71
fw Sot.
oo,-39
Address
APN
Acre
Total
Acreag
TJV
430-3�1-
03
430-391-
27
4.946
CA 20
430-39L-
29
9.096
45
p
430-391-
56
3.396
46.748
4aO-agl-
Heighborho
59
0.107
%I
AmW
od G
430-391-
w
430-391-
fil
5
430-391-
62
3316
iww
4aO-891-
(D
— .--
61
7.212
IV
64
1 3.536
Pa rce 1
fW6
44
lw�'s &� a
Sou rm 0 ra
nge Cou nty Assessor
Map
47
F%Ka MAGEW ON 4M WE 10
A"- 0 COW$ MWF Of MAW
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN SEPTEMBER 2022
B-46
Tustin
2021-2029
H�Sirkg llem�d
RED HILL
AVENUE
SPECIFIC PLAN
AREA
Attachment B-2
Red Hill Avenue Specific Plan
Site Aerials / Individual Site APN Maps
Site 3
13751 - 13 941 RED HILL AVENUE
(2 Parcels) Entitled Project in 2021
137 housing units ap,proved
3.37 acres
IF -
71
AP
Ske 6'
14081— 14231 RED HILL AVENUE
Shopping Center— 1105 housing units
5.95 acres
CITY OF TUSTIN
GENERAL PLAN B-47
Site 4
1382 2 — 1385 2 RE D H I LL AVENU E
Red Hill Plaza - 226 housing units
A�Cres
5" 5
71 E L CAMi NO REAL — 32 housing units
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
FUM
SITE 3: 13751 - 13841 RED
17 ��
HILL AVENUE
J2 Parcels) Pen�ding Project
3.37 Acres Zoning: SP 13
General Plan: RHASP
Address
APN
Acre
Total
Acreage
13751 Red
Hill
500-141-
WADI fW ILIC r -m
ffiff AlOwl OLM, A 1111�15 w
Averlue
09
0.46
3.37
13841 Red
Hill
500 -141 -
Avenue
10
2.91
Source: RealQuest
CITY OF TUSTIN
GENERAL PLAN
L77-a;,�
W.. rim
40
so -14
B-48
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
WADI fW ILIC r -m
ffiff AlOwl OLM, A 1111�15 w
L M-Fl.m
xr. mr-m '. a �rl
RUM murps
Pm W CIMES ft w =AW,
B-48
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 4: 13822 - 13852 RED HILL
AVENUE
Red Hill Plaza
7.08 Acres - RHASP Zoning: SP 13 General Plan;
Address APN
Acre
Total -M
Acreage
13822 Red 500-022-
HillAvenue 12
4.9
7.08
No Address
500-022-
Listed
09
0,28
13852 Red
MO-022-
lHill enuel
04
1 1.9
1
Source: RealCLuest
CITY OF TUSTIN
GENERAL PLAN
LLJ L
7
0
, 05 J
wom Wf W.W as ma r�
rv4V 4 w ILA I" -WL -Ahll am
ft" -9 mp p a 4-1% 313-f iv M,,Wu
DRAFT HOUSING ELEMENT
B-49 SEPTEMBER 2022
SITE 5: 1571 EL CAMINO REAL
Denny's Restaurant
D.90 Acres Zoning: SP 13 General Plan
RHASP
APN Acre Total
Acre
age
1571 El 500-022-02 a9 J.9
Larn no Real
Sourm RealQuest
14
8
SWO2
mo W) arm m AA J -m WY - h OW S 6, k, —r,5w 5.:
pwr a xf ILA V-6 wy; ex. 5w
PAZ w At 4F-PJ6 J64 — -1 01z,f: � �m E]
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN SEPTEMBER 2022
B-50
SITE6; 140AI— 14231 RED HILL AVENUE
5,towill"Alwm sh.ppingConte,
5,9S A�s Zvninjg, SP I a -C;on*ral Plan: RHAW
Addresses
APN
ACRES
Total Acreage
14081 Red Hill
432-041-04
0.53
Avenue
14231 Red Hill
412-041-14
0,33
Avenuo
5.95
14131 Recl Hill
432-041-17
0.115
Avenue
14171 Red HIM
432-042-19
0.83
Avenue
14171 Red Hill
432-041-20
2.60
Avenue
14213 Recl Hill
432-04 -21
1150
Avenue
WCONO:
R�Iqwsl Wap
QCPW Wp�
05
L
7
a,
It
thrim to. ALW. �-m a Aft W-UM'f &M A AfSESSMI W
FWAO. r 1. A. 44 PA94a PIPWJM mm 4R � 00
mCr AM Wr AV. 2M-,'[ � M WMAX4 —,,,Y duw
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-51 SEPTEMBER 2022
Tustin
2021 2029
Housing rjenwnt
Attachment B-2
Downtown Commercial Core Specific Plan
Site Aerials / Individual Site APN Maps
SITE 7
365 W. FIRST ST. & VACANT LAND ADJACENTTO
VIENTO APTS. -45 unfts
SITES
-.I:
4
SITE 9
15G E. FIRST STREET & 105 EL CAMINO
TUSTIN WAR MEMORIAL AND
WIENERSCHNITZEL
0.88 ACRES
SITE
-W
DOWNTOWN
4
711 ;�i
COMMERCIAL CORE 7,
carricir pi A ADCA
CITY OF TUSTIN
GENERAL PLAN
MWE
SITE 8
140 W. FIRST STREET
BEL AIR MOTOR HOTEL - I ACRE
L
SITE
Sites 8 & 9 — 92
I
I
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 7: 3 65 W., F I RST 51 &
VACANT LAND ADJACENT TO
VILLA VIENTO APARTMENTS
Approx.l.lAcres Zoning.SP12
General Plan: DCCSP
Address
AM
Acre
Total
Acreage
165 W FIrst
401-523-1.0
0.6
L ------ 9L ------
St
1.1
Vacant
401-52�45
0.5
Frontag.eof
portion)
Apartments
Source: CitV GIS
L . I -L
Z— '\ -(�pw m
.iw,; mw AiwAr
ws ov lofor , 5_ .,I
Ae? 14. �i. " ",J�
WA -M 191f lw,r LA M-1
L
Er A
AWL jw &A 411
—0
L ------ 9L ------
6) 1
1 n. ax jit r.
L . I -L
Z— '\ -(�pw m
.iw,; mw AiwAr
ws ov lofor , 5_ .,I
Ae? 14. �i. " ",J�
WA -M 191f lw,r LA M-1
L
Er A
AWL jw &A 411
far
cAlf, tft� ff dha L]
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-53 SEPTEMBER 2022
—0
L
far
cAlf, tft� ff dha L]
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-53 SEPTEMBER 2022
SITE 8: 140 W. F1 RST STR E ET
Bel Air Motor iHotel
I Acre Zoning: SP 12 Gem�ral Plan: DCCSP
Address APN � Acre Total.
Acreag
140 401 -
West 571-14 1 acre 1 acre
First
Street
Source: RealQUe5t
CITY OF TUSTIN
GENERAL PLAN
B-54
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
(D
NX 7
t
7
0,
LA f -J? �g:w�w
pff AvA WTI UFM iw Np � w
W. . elw"$ =-21 M.1
[7
B-54
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 9: 150 E. FIRST STREET &
105 EL CAMINO REAL
Tustin War Memorial and Wiene rsch nitzel
0.88 Acres Zoning: SP 12 Generai
Plan: DCCSP
Address
APN Acre
Total
Acreage
150 E- First
401-583-4DI 0.43
strept
0.8-a
twr
105 El
401-58S-15 0.45
Camino Real
�
Source: RealQuest
a-59
dAH-7Z Wh.7T 6
9--" Ep dw, w I I *I; -
FW mtr±
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-55 SEPTEMBER 2022
twr
OV, A
Q
a
42
1 -
Corr
L
t Amer
7
—L
ID
(D
@
0
q)
I
d
W A
Pa
0
a
FY
L
V4
-1
r
wM IM rff-ry c r ri
J..L 1-w
Arf - AMIAN-4 &dn I AWSWS W
W a I
AN_ 9-4
N=4 wmlw� 4%* 0 ftd 4
W C w
At 21 -?5
AM m C."Uff, rmf,z WAW
W4 jMr
Kme.W.V ro Iii w
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-55 SEPTEMBER 2022
Tustin
2021-2029
Housing rjem
DOWNTOWN
COMMERCIAL
CORE
SPECIFIC
PLAN AREA
CITY OF TUSTIN
GENERAL PLAN
SITE 10
LARWIN SQUARE
SWC OF NEWPORT AVE & FIRST STREET— 200 units
16.47 Acres
k
SITE
7
Am%
B-56
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 10: LARWIN SQUARE
16.47 acres Zoning: SP 12 General Plan: DCCSP
Address
F APN
Acre TatalAcreage
630 E 15T ST
402-60 1-01
12�20
13341
4()1-601,04
0181
NEWRORT AVE
13421
0.32
NEWPIORT AVE
401-601-05
13451
NEWPORT AVE
401-601-06
0138
16,47
1S471 Newport
Aw
401-601-07
0.39
550 E IST ST
401-601-08
1.00
275
0.46
CENTENNIAL
401-601-09
WAY
662 E IST ST
0.91
401-601-10
Source: RealQuest
7
&rig 8
. .........
--------------- ------ ..................
I= =W= "I
ME 1�ff
Am. 84"
wr 14TRWI
k " Im —a
flKs, 1w. � — ID
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-57 SEPTEMBER 2022
Tustin
2021-2029
Housing rjem
DOWNTOWN
COMMERCIAL
CORE
SPECIFIC
PLAN AREA
Sites:
11, 12, 13, 14 —
150 units
CITY OF TUSTIN
GENERAL PLAN
SITE 11
225 — 255 EL CAMINO REAL
& 250 PROSPECTAVE.
VACANT
1.02ACRES
SITE
how
SITE 13
125W. MAIN STREET— ADJACENTTO ARVIDA
BOOKSTORE; VACANT
0.25 acres
SITE
Az
st cl
SITE 12
NEC of El CAMINO REAL& SIXTH STREET
542 EL CAMINO REAL; VACANT
2.28 Acres
wt
Val,
SITE
—ww� S -N
m SITE 14
420 EL CAMINO REAL; VACANI
0.44 Acres
SITE
FT
mm
A;=
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 11: 225 — 255 EL CAMINO REAL
& 2 50 PR OSP ECT AVE.
Farmer's Market Temporary Use
1.02 Acres Zoning: SP 12 General
Plan. DCCSP
Addre55
APN
Acres
Tota
F
AID
Acreage
250
C'
Prospect
Avenue
401-5,84-04
U, 17
No address
listed
401 -584 -OS
0,17
255 El
Camino
Real
401-584-06
0,17
1.02
245 El
Camino
Real
401-584-07
0.17
235 El
Camino
Real
401-584-08
0.17
225 El
Camino
Real
401-584-09
0.17
Sou rce: Rea I CLuest and 0 range County Pu bl Ic Works
.W& MVWJ av
,t,nrxo -r, -d Q* -U 41.7
apw R-LTT
Ar A
591
j d
02
10, 0
I PNWCT '
_d d JP
oxv
PiTUM wF hr. N-3ri 31pt
IWO
L -.1"
MR -C,
L 'VOL i
moll - dMIX's ALYN i
.AXEL W"ffi 2 a FM
sh" IV r"AA0 mmrr J fiPmU
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-59 SEPTEMBER 2022
W I IF 2
F
AID
00
C'
0
L 'VOL i
moll - dMIX's ALYN i
.AXEL W"ffi 2 a FM
sh" IV r"AA0 mmrr J fiPmU
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-59 SEPTEMBER 2022
W I IF 2
SITE 12: NEC of El CAMINO
REAL & SIXTH STREET
542 EL CAMINO REAL
2.29 Acres Zonin � SP 12 General
Plan: 6CCSP
dress
APN
Ac re
Acreage
7:1;1
5 , 20 Ell
7 -
Camino Real
401-623-14
0.50
2,29
No Listed
Address
401-623-15
1.1
135 W 6th
401-623-16
0.69
Source: RealQuest
CITY OF TUSTIN
GENERAL PLAN
. @ " I .,;� . I
. ...........
- -------------
336
L
%via Q* LA. rA,.0
Ars m7m rwr am r4
MLYRf rm I NW� M JM" KA ri W kwHX5 AM i w W%
?w w NJ am 41�41 �ffi a", 431 62
ZA w p.m rjHt, F44. J041 Ncr�u MAr, or PIOX
MM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
r-1
7 -
0
Swig W1
0
(D
0
JY 13
ut.
I—,
+1
"
!
I
PA
0, Q
I
W-4
I , .."
"
ff
Z
I
"I
. @ " I .,;� . I
. ...........
- -------------
336
L
%via Q* LA. rA,.0
Ars m7m rwr am r4
MLYRf rm I NW� M JM" KA ri W kwHX5 AM i w W%
?w w NJ am 41�41 �ffi a", 431 62
ZA w p.m rjHt, F44. J041 Ncr�u MAr, or PIOX
MM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE 13: 125 W. MAIN
STREET - ADJACENT TO
ARVIDA BOOK STORE
0.25 Acres Zoning: SP 12
General Plan: DCCSP
Address
APN
Acre
Total
I
4!0.
I
Acrea
�1
125 W,
-
401 -573 -
Main St
13
L 0.2
Source: RealQuest
mo
401-57
V. L
7
&X. 7
4wW5 p'm 4 gwi�'s W
AW 19 4'0"4011 'AXEL AbWRS � qvi .� V E7
S,vw N fl -M (AW, # ~
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-61 SEPTEMBER 2022
4!0.
1(p
401-57
V. L
7
&X. 7
4wW5 p'm 4 gwi�'s W
AW 19 4'0"4011 'AXEL AbWRS � qvi .� V E7
S,vw N fl -M (AW, # ~
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-61 SEPTEMBER 2022
SITE 14: 420 El Camino Real
0.44 Arres Zoning: SP 13 General Plan � DCCSP
Address
APN
Acre
Total
Acreage
420 E�
401-522-
044
01"
Camino
Real
CITY OF TUSTIN
GENERAL PLAN
iv -62
57
N "O—M.-
ra ww T 7
ra juj
C
Pif
L w7m
B-62
_L
At, A
MCI
go
114, kRl
FA PH
wrg 0 LA 05.R �ig.w.j
rtKr4 W�p LA M13 wi � 4cm z 2
RRM W FA N%4N of". pw WCIME5 'Wrl, � E
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Tustin
SITE 16
EL CAMINO PLAZA
Swc OF SIXTH STREET & EL CAMINO REAL
4m
7.81 Acres
SITE 15
14042 NEWPORTAVE. & EL CAMINO REAL
VACANT, 2.73 Acres
SITE
moil -1-04.
lip
SITE
PIY
Oil
DOWNTOWN
COMMERCIAL
CORE
SPECIFIC PLAN
AREA
Sites 15 & 16 —
260 housing
units
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-63 SEPTEMBER 2022
SITE 15, 14042 NEWPORT
AVE. & EL CAM I NO REAL
2.73 Acres Zoning: SP 12 General
Plan: DCCSP
Address
APN
Acre
Total
Acreage
14042
Newport
432 -074 -
Avenue
02
0.77
14042
Newport
432 -074 -
Avenue
07
0.67.5
14042
Newport
432 -074 -
Avenue
08
0.378
14042
Newport
432 -074 -
Avenue
09
0.906
173
1�oume: RealQuest and "ngQ County Public Works
CITY OF TUSTIN
GENERAL PLAN
LW
farAl N, AL r p�ff j Rjyr PC, J LA, J4$
maka �qw rw-y Rd. ?"I am juv wrt - �"155m, awl 4 1195W,�
pmm W RJE fjqL X -Y. M". M-4 �M � . 'm X 6,
'. �AIO �W-Twow
432-0
-1 7
B-64
le
L
OWN
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
14
SITE 16: EL CAMINO PLAZA
7.81 Acres Zoning; SP 12 General Plan� K49
DCCSP
ce Total
Acreage
00
1,211
Car no
Rea, 401-631-01 15
634 El
Carnino 7.81
Real 401-631-15 4.2
No Listed t r
I Address 1401-631-13 0.11
L
NUAW� AM LA. MV
So u rce Rea I Qu est an d C ity of Tust I n G IS Data base 19v 4f-sw mwft A'a NO �."
I#X? AV M 'y ;m -m
\jj / 401-63
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-65 SEPTEMBER 2022
X-
AmW5 &W a
jllw� mW9
i" Ak VY -113
go
�r,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-65 SEPTEMBER 2022
Tustin
2021-21029
Housing flement
CITY OF TUSTIN
GENERAL PLAN
SITE 17
ENDERLE CENTER — 413 housing units
Total: 11.62 Acres
(Acr2pge suitable for redevelopment 7 acres)
'Aff
SITE
MM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE #17: ENDERLE CENTER
11.62 acres Zon�ng: PCC
General Plan: PCCB
- t I .
14081 Yorba St
401-251-04
1.05
17240 17th St
401-251-06
0.54
17280 17th St
401-252-05
0.52
17300 17th St
401-252-06
3.53
401-252-08
1.05
17490 17th St
401-252-09
0.3
17440 17th St
401-252-10
3.32
14032 Enderle,
Center Dr
401-253-03
D.5
401-253-04
0.81
Tcytal Site "cr age
11.62
Total AcreageSu ita ble for
lIffidential Development
7
Partially or wholly suitable for
residential development
Enderle Center
401-25
.OLW 0173
;Wlf =;ZT k.1 J.,
--;rlsm S &-X. a -55E5z,5,-
11AQrj-4 .YW05 Soo. 'a 25
Vq— X. Cw4r. rb—F, ff mAwx
h"K I
q ap
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-67 SEPTEMBER 2022
Tustin
20k21-2029
Housing Dement
CITY OF TUSTIN
GENERAL PLAN
lip SITE 18
THE MARKETPLACE — 900 housing units
Tota 1: 76.937 Acres
(Acreage suitable for redevelopment 18 acres)
11�9 *
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
SITE #18: THE MARKETPLACE
76.937 acres Zoning: SP -8 General Plan: PCCB
E--]
2870 El Camino Real
500-291-02
5464
2982 El Camino Real
500-291-04
5.1s
2992 El Cam i n D Rea 1
500-291-06
0.5
3002 El Cam [no Real
500�291-07
0.41
3010 El Camino Real
50D-291-08
031
2996 El Camino Real
500�291-11
059
50D-291-12
012
500-291-21
025
3020 El Camino Real
500-291-23
0.5
3040 El Cam i n a Rea 1
50&-291-24
078
3030 El Camino Real
500-291-25
3.9.226
2762 El] Camino Real
50D.-291-26
1562
2762 El Camino Real
500�291-27
6.&45
2741 El Camino Real
500�-312-02
3.214
50G-312-03
611
2851 El Camino Real
50D-312-04
4
2961 El, Camino Real
500-312-06
2.88
3025 El Camino Real
500-3112-08
0226
3015 El Camino Real
500�-312-09
500-312-10
_315
18655
Tota I Site Acreage
76.937
Total Acreage Suitable for
Residential Developinient
18
Partia I ly or wholly suitable for
remdential development
Market Place
P aWPAO
WM AM
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN B-69 SEPTEMBER 2022
Tustin
2021-2029
Housing Dement
CITY OF TUSTIN
GENERAL PLAN
Transitional Housing
B-70
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Tustin
2021-2029
Housing flentent
ADUs/JADUs — 35 housing units
Citywide: ADUs/JADUs
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 4 th
Size
Plan
Vacant
&/Or 5"
(Acres)
Cycles / Was
Counted
Towards
RHNA
Tustin Legacy Specific Plan Area
1
Neighborhood D PA 8, 13 & 14
Vacant
Yes(both)/
City of Tustin
SID 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
SID I
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
GENERAL PLAN
B-72
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Attachment B-3
Buffer
Site
Site Reference
Vacant or
Identified in
Site
APNs
Ownership
Zoning
General
Capacity
#
Non-
Previous 4 th
Size
Plan
Vacant
&/Or 5"
(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
CITY OF TUSTIN
GENERAL PLAN
Attachment B-4
HCD Required Site Inventory Form
To Be Submitted Following Housing Element Adoption - As Allowed
B-74
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
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.
0 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
GENERAL PLAN
C-2
HOUSING ELEMENT
SEPTEMBER 2022
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.
0 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
GENERAL PLAN
C-3
HOUSING ELEMENT
SEPTEMBER 2022
costs for navigation centers and emergency shelters, and the new
construction, rehabilitation, and preservation of permanent and transitional
housing.
0 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.
0 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.
0 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.
0 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
GENERAL PLAN
C-4
HOUSING ELEMENT
SEPTEMBER 2022
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.
0 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.
0 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 strean-dining 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
GENERAL PLAN
C-5
HOUSING ELEMENT
SEPTEMBER 2022
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
GENERAL PLAN
C-6
HOUSING ELEMENT
SEPTEMBER 2022
This page intentionally left blank.
CITY OF TUSTIN
GENERAL PLAN
C-7
HOUSING ELEMENT
SEPTEMBER 2022
APPENDIX D
AFFIRMATIVELY FURTHERING FAIR HOUSING
CITY OF TUSTIN
GENERAL PLAN
D-1
HOUSING ELEMENT
SEPTEMBER 2022
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
jurisdiction!s fair housing enforcement and outreach capacity; and
An analysis and summary of fair housing issues and identification of trends and
patterns within the City of Tustin in comparison to surrounding cities and the larger
Orange County region, including the topics of:
o Integration and segregation;
o Racially or ethnically concentrated areas of poverty;
o Disparities in access to opportunity, including for persons with disabilities; and
o Disproportionate housing needs (such as overpayment, overcrowding, housing
conditions disproportionately affecting protected classes), and displacement risk.
This analysis utilized available federal, state, and local data and knowledge to identify trends
and patterns in fair housing issues and identification of trends and patterns within the City of
Tustin. Orange County's Analysis of Impediments to Fair Housing Choice (AI) was prepared in
May 2020 and contains a thorough examination of structural barriers to fair housing choice and
access to opportunity for members of historically marginalized groups protected from
discrimination by the federal Fair Housing Act (FHA) within Orange County. The Al also
outlines fair housing priorities and goals to overcome fair housing issues. In addition, the AI
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
0 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
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
D-4 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 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.
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
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/V\Thite 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 AB 686
In 2018, the California State Legislature passed AB 686 to expand upon the fair housing
requirements and protections outlined in the Fair Employment and Housing Act (FEHA). The
law:
• requires all state and local public agencies to facilitate deliberate action to explicitly
address, combat, and relieve disparities resulting from past patterns of segregation to
foster more inclusive communities; and
• creates new requirements that apply to all housing elements due for revision on or after
January 1, 2021.
The passage of AB 686 protects the requirement to affirmatively further fair housing within
California state law, regardless of future federal actions. It also preserves the strong policy in
the U.S. Department of Housing and Community Development's (HUD) Affirmatively
Furthering Fair Housing (AFFH) Rule as published in the Federal Register in 2015.
As of January 1, 2019, AB 686 proactively applies the obligation to affirmatively further fair
housing to all public agencies in California. Public agencies must now examine existing and
future policies, plans, programs, rules, practices, and related activities and make proactive
changes to promote more inclusive communities.
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:
0 524.19 (overlaps North Tustin)
0 525.02
0 525.24
0 744.07 (overlaps Santa Ana)
0 744.08
0 755.04 (overlaps Santa Ana)
0 755.05
0 755.06 (overlaps Santa Ana)
0 755.07
CITY OF TUSTIN
GENERAL PLAN
0 755.12
0 755.13
0 755.14
0 755.15 (overlaps a small portion of
Santa Ana and a large portion of
Irvine)
0 756.06 (overlaps North Tustin)
0 756.07
0 757.01 (overlaps North Tustin)
DRAFT HOUSING ELEMENT
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:
0 754.03
0 756.03
0 757.02
0 744.06
0 756.05
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
0 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
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
D- 12 SEPTEMBER 2022
(Tustin, CA CDBG)
(Los Angeles - Long Beach -
jurisdiction
Anaheim, CA) Region
Race/ Ethnicity
Count
Percent
Count
Percent
White, Non-
24,289
30.36%
4,056,820
31.62%
Hispanic
Black, Non-
1,926
2.41%
859,086
6.70%
Hispanic
Hispanic
32,982
41.22%
5,700,860
4C44%
Asian/Pacific
Island, Non-
17,542
21.93%
1,888,969
14.72%
Hispanic
Native American,
418
0.52%
25,102
0.20%
Non -Hispanic
Two+ Races,
1,949
2.62%
267,038
2.08%
Non -Hispanic
Other, Non-
169
0.23%
30,960
0.24%
Hispanic
#1 country of
Mexico
11,270
14.09%
Mexico
1,735,902
14.34%
origin
#2 country of
Vietnam
2,115
2.64%
Philippines
288,529
2.38%
origin
#3 country of
India
2,048
2.56%
El Salvador
279,381
2.31%
origin
#4 country of
Philippines
1,677
2.10%
Vietnam
234,251
1.93%
origin
#5 country of
Korea
1,446
1.81%
Korea
224,370
1.85%
origin
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
D- 12 SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
D- 13 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
174,424
1.44%
Kong &
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
0
#10 LEP
Arabic
165
0.23%
Arabic
23,275
0.19%
Language
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
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% 1,388,564 47.84%
children
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
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-15 SEPTEMBER 2022
Figure 2:2020 TCAC/HCD Opportunity Areas (Tustin)
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-16 SEPTEMBER 2022
Figure 3:2021 HCD/rCAC Opportunity Areas (County)
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CITY OF TUSTIN
GENERAL PLAN
D- 17
C..P P.,
0 - C"
Garm�n, USGS, N(;A, EPA, USDA,
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
Figure 4: Areas of Minority Concentration in Tustin
Regional
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Source: AFFH Data Vie— Fmnch HO
CITY OF TUSTIN
GENERAL PLAN
D-18
DRAFT HOUSING ELEMENT
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
Table 4: Dissimilarity Index Scores
Racial/ Ethnic Dissimilarity Index
Value
Level of Segregation
Dissimilarity Index Value (0-
100)
0-40
Low
Non-V\Thite/White
41-54
Medium
32.93
55-100
High
Table 4: Dissimilarity Index Scores
Racial/ Ethnic Dissimilarity Index
1990
Trend
2000
Trend
2010
Trend
2020
Tustin
Non-V\Thite/White
26.33
36.73
32.93
F48.19
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/V\rhite
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
Isolation Index
1980
1990
2000
2010
2020
2020
(Orange
County)
White/White
83.7
66.3
54.3
43.2
52.44
55.16
Black/Black
6.1
9.9
3.6
2.7
4.84
3.32
Hispanic/ Hispanic
10.2
27
51.3
51.9
56.10
52.81
,Asian/Asian
4.4
12.1
19.6
26.7
19.86
31.84
Source: County of Orange, Analysis of Impediments, 2020
As shown in Figure 2, the city's highest resource areas are to the northeast and the low resource
areas are to the south and southwest. The city did not include any areas categorized as high
segregation and poverty (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 (1-5) (see Figure 3). Areas that were indicated as
rapidly changing were located along the perimeter between low resource and high resource
areas, particularly on the southern coastal side. The City of Tustin is not classified as a rapidly
changing area. This pattern indicates a rapidly expanding trend of high resources from the
coast, inward towards central Orange County located near 1-5.
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
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
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
IHCV 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
Mr., Lorna
111 Ittl r E.astvale Jurupa Vail
Add.
CHINIO VALLEY
A—
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ht ... III
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Orange County
Population with a Disability (Tract) - ACS (2015-2019)
< 10m
10% - 20%
F-1 2ov. - 3ov
30% - W/
� 40%
County Boundary
N 0 2.5 5 Miles
k I I I I
Source: AFFH Data Viewer
Esri, HERE, Garmin, USGS, INGA, EPA, USDA, NRS
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-23 SEPTEMBER 2022
Figure 6: Percent Population with Disabilities in Tustin
L li,
z
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L
= City Boundary GNI 133
N 28-
0 0.5 1 Miles Irvine, County of Los Angeles, Bureau �uf Lan 4priagernert, Esri HFRF
'�T
Garmir, INCREMENT P, USGSr M -I�JNASA, EPA 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
SI A ziml W&M
z
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City El—rrd�ry
IN 0 0.5 1 Miles lty ef Irvine, County of Los Angeles, llureau cf Land Vanagem�rt, Isil, HERE,
Garmin, INCREM ENT P, USGS, METI/l EPA, USDA
Source: AFTH Data Vlpwer
)licks C.n,
) 0-�9 Y1. 01
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-25 SEPTEMBER 2022
'N 1'� Chapm in Ave
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City El—rrd�ry
IN 0 0.5 1 Miles lty ef Irvine, County of Los Angeles, llureau cf Land Vanagem�rt, Isil, HERE,
Garmin, INCREM ENT P, USGS, METI/l EPA, USDA
Source: AFTH Data Vlpwer
)licks C.n,
) 0-�9 Y1. 01
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-25 SEPTEMBER 2022
Figure 8: Percent Population of Adults Living with their Spouse - Tustin
L lil
z
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\ 11, C Pm an Avp Orange —�5-111F-Chaprnan -Ave--"�' Ca n yc, n V.o
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11
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h
0
z
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City of Tustin
Percent of Population 18 Years and Over in Households Living with Spouse
a r
20% - 4V. 4�1
40% - 60%
60% - 80%
=,so%
City Boundary ;N1 tjnivei'v'\ 1133
N 0 0.5 1 Miles Irvine, County of Los Angeles, Bureau of Land Management, Esrl HERE
Garmlin, INCREMENT P, USGS, METI/NASA, NGA, EPA USDA
Source: AFFEI Data Viewer C7h
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-26 SEPTEMBER 2022
Figure 9: Percent of Children in Married Couple Households - Tustin
L Znj
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11, C Pm an Avp Orange _�5—&Chapman Av,
W Almijiul A�-t:
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ith ell
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Percent of Children in Married -Couple Households Coutee
20% - 40Y.
409/.- 605/.
60%-80%
> mv
City Boundary
IN
0 0.5 1 Miles Irvine, County of Los Angeles, Bureau A�ofLan Wnaqemert,Esrl HERE
Garmin, INCREMENT P, US`GSr 7N/NASA� EPA USDA
S.ur AFFH Wt. Vi—r
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-27 SEPTEMBER 2022
Figure 10: Percent of Children in Single Female -Headed Households - Tustin
Vil Rpm
IF Dyer Rd
L
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sp
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ith
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6
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City of Tustin
cout�
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< 20%
20%-40%
F La Veta
Ave
City Boundary
2
f WIY
133
LU
A�ofLau
IN
0 0.5 1 Miles
Irvine,
County of Los Angeles, Bureau Wonaqemert Esrl HERE
Garmin, INCREMENT P, J S,7'N/NASA,'EPA
USDA
Sour— AFFH Data Viewer
Faidia—,
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L
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a
North T
W 17th St
0 Z Z
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-28 SEPTEMBER 2022
sp
ith
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cout�
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Percent of Children in Female -Headed Households
< 20%
20%-40%
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City Boundary
133
A�ofLau
IN
0 0.5 1 Miles
Irvine,
County of Los Angeles, Bureau Wonaqemert Esrl HERE
Garmin, INCREMENT P, J S,7'N/NASA,'EPA
USDA
Sour— AFFH Data Viewer
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 1-5 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
RaciallylEthnically 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
P Mr. Lrn.
Eastvale Jurupa Vail,
k%IhIttler
p I/ I, &' CHINO VALLEY
CH!NO HOLLS
W 1 -
Ch— HAI.
N,- S.4 P.,k
Ir —(-.rrrnoa�
Ile ton
ena
na eim
en
es min e
San a na
Orange County
Low to Moderate Income PopulatIon (Tract) - (HUD)
[--7-25%
255� - 50%
SO% - 75%
75%-100%
County Boundary
N 0 25 5 Miles
Source: AFFH Data Viewer
I E rSCAL vALLE,
A,
..z 4 N TA MA R,3
G111A1
City of Irvine, County of Los Angeles, Bureau of Land Management, Esrl, 1-
Esri, HERE, Carnnin, USGS, NGA, EPA, USDA,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-30 SEPTEMBER 2022
Figure 12: Low and Moderate Income (LMI) areas in Tustin
E Znj
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50%-75%
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City Boundary 1 133
N 28-
0 0.5 1 Miles Irvine, County of Los Angeles, Bureau A�ofLau Wonaqemert Esrl HERE
Garmin, INCREMENT P, U Sr7N/NASA�'EPA USDA
Sour— AFFH Data Viewer
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-31 SEPTEMBER 2022
Figure 13: Racially Concentrated Areas of Poverty (RECAPs) in Orange County
55 1. IIIAL VALLEY
Orange County
Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs)
0 - IN t a R/ECAP
I - R/ECAP Area
Poverty Status (Tract) - ACS (2015-2019)
C0 J NTY
, 10%
10%-20,%
20%-30'/
30%-40%
140'/
C—ty 3—d.'y
N 0 2.5 5 Miles
Source AFHH Data Viewer
S,
SANTA Wi.
MOUNT-'
City of Irvine, County of Los Anqe'�Sr Bureau of Land Management, Esr�, �
Isirl, HERE, Garmin, USGS, INGA, EPA, USDA,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-32 SEPTEMBER 2022
MI. L...
VhItner
Eastvale
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ry f- r.,
CHINIO VAL V0,1110. A—
C HINO HILLS
0" L
C h I. N III.
N."
Ik
r.1
G.q a
55 1. IIIAL VALLEY
Orange County
Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs)
0 - IN t a R/ECAP
I - R/ECAP Area
Poverty Status (Tract) - ACS (2015-2019)
C0 J NTY
, 10%
10%-20,%
20%-30'/
30%-40%
140'/
C—ty 3—d.'y
N 0 2.5 5 Miles
Source AFHH Data Viewer
S,
SANTA Wi.
MOUNT-'
City of Irvine, County of Los Anqe'�Sr Bureau of Land Management, Esr�, �
Isirl, HERE, Garmin, USGS, INGA, EPA, USDA,
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-32 SEPTEMBER 2022
Figure 14: Racially Concentrated Areas of Poverty (RECAPs) in Tustin
L lil
-D z
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�V C pm an Avp Orange man-Ave-/-��;,
)5 -E -Chap on Vif�,, N
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Parlk
Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs)
Oak
0 - Not a R/ECAP Cmek Golf Jl�
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� / I - R/FCAP Area
Poverty Status (Tract) - ACS (2015-2019)
F-1 < 10%
10% - 20%
F—] 20-/ - 30%
30% - 40%
>40%
City Boundary 'Pap Onlywo "1 133
N 0 0.5 1 Miles ity of irvire, County of Los Angeles, Bureau of Lan Wpn2gernent, F/
1j, HERE,
Garmin, INCREMENT P, USGS, M-a-1014"IAAA, USDA
Source: A�FH Data Viewer Fmnch Hj#
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: VVhite Household Income and Percent Population (2019)
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
Tustin
Orange (city)
Santa Ana
Irvine
Orange
County
Median
Household
84,697
91,793
66,145
105,126
90,234
Income
All
Households
93,304
95,827
70,084
111,574
95,934
White alone,
101,658
95,702
79,000
113,779
100,723
White
59.01%
74.03%
28.87%
47.80%
59.25%
Population
Notes:
1.VVhite 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
Orange, E Cha P11.1 Orange L Chapman A;,
North T, t
ibDA
Santa Ai,.�
"'�rcks
Cks Can
%0203
I rvine I rvine
ovo C 01 -al. C
City of Tu sti n
Clity of Tustin Median Income (Block Group)
E__J � $30,00il)
White Majority ='55S'9w
Slim (gap< 10%) = < �87,00JMCD 2CZOSUte Median income)
Sizeable (gap 10% — 50%) ER , 512swo -
Greater than $125,000
city B ... d.ry :'A0
Predominant (gap> 50Y 9 Block Groop Numbev
City Boundary
N a 0.5 1 miles city of Irvine, County of Los Angeles, Bureau of Land IN 0 0,15 1 Miles I ily of Irvine. County of Los Angeles, bUl— of L d
C
Jin
Management, Esri, HERE, Garrn�n, LISGS, NGA EPA, Managemem, Esrl, HERE, Garmin, INCREMENa"P,
USDA NIPS USGS, VE.TI/NASA, E PA. USDA
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.
TCACIHCD 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
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
D-37 SEPTEMBER 2022
Economic
Environment
Educational
Low
al
Transportati
Tustin
Opportunity
Opportunity
Transit Index
Index
Opportunity
Index
on Cost
Index
Index
Tustin total Population
White, Non-
77.38
5 5. 5 3
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
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
Islander, Non -
49.36
46.78
52.50
37.48
36.11
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
Islander, Non -
38.94
46.38
4. S. 3 2
41.97
39.51
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
D-38 SEPTEMBER 2022
Table 9: Opportunity Map Scores - Census Tracts
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
D-39 SEPTEMBER 2022
Economic
Environmental
Education
Composite
Final
Census tract
Domain
Domain
Domain
Index Score
Category
Scores
Scores
Score
Highest
0524.19
0.962
0.574
0.863
0.638
Resource
Moderate
0525.02
0.896
0.166
0.199
-0.217
Resource
High
0525.24
0.912
0.376
0.541
0.272
Resource
Low
0744.07
0.12
0.024
0.055
-0.94
Resource
Low
0744.08
0.179
0.047
0.054
-0.839
Resource
Moderate
0755.04
0.702
0.199
0.35
-0.136
Resource
Low
0755.05
0.622
0.22
0.068
-0.462
Resource
Moderate
0755.06
0.614
0.619
0.529
0.189
Resource
Moderate
0755.07
0.626
0.27
0.208
-0.269
Resource
Low
0755.12
0.27
0.218
0.106
-0.575
Resource
Low
0755.13
0.386
0.185
0.199
-0.426
Resource
Low
0755.14
0.187
0.092
0.078
-0.753
Resource
Low
0755.15
0.452
0.005
0.236
-0.839
Resource
Highest
0756.06
0.986
0.534
0.927
0.766
Resource
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
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: Califorr-da 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, 74�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 econon-dc 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 C
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. hi 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
.
0.0%
0.0%
0.0%
0.0%
0.0%
0.3%
0.3%
0.0%
22.2%
20.3%
Alaska N ative
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%
0.0%
0.0%
0.0%
0.0%
0.0%
2.4%
0.0%
40.0%
34.1%
Other Pacific
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)
I I
CITY OF TUSTIN DRAFT HOUSING ELEIVIEN I
GENERAL PLAN D-43 SEPTEMBER 2022
School Proficiency
Total Title 1
Schools
1
1
2
10
135
Total Schools
1
1
2
19
607
Percent of
Schools
-
100
-
100
-
100
-
-
52.6
22.2
Unemployment
4.2%
1.7%
3.8%
4.3%
3.3%
1.8%
1.4%
2.4%
2.80%
3.00%
Rate (2019)
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%
8.1%
6.8%
9.7%
more
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)
I
I
I
I
I
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
Census Tracts
Of
Indicators
Tustin
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
.
0.0%
0.0%
0.4%
0.0%
0.0%
0.0%
0.0%
1�4%
0.1%
0.2%
Alaska N ative
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%
0.0%
0.0%
0.0%
0.5%
0.0%
0.0%
0. 0 'Yo
0.1%
0.3%
Other Pacific
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
Schools
2
1
-
-
3
-
-
-
10
135
Total Schools
5
1
4
3
1
19
607
Percent of
Schools
40
100
-
-
75
0
0
-
52.6
22.2
Unemployment
4.1%
4.3%
5.6%
4.4%
1.3%
1.1%
2.
2. 0
2.80%
3.00%
Rate (2019)
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
f 0, 1
6.8%
9.7%
more
Transit Metrics
All Transit
Performance
5.7
5.9
5.1
5.4
6.4
1.2
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
6-51
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
2-5-),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 M
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
169
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
01 le on
na eim
a en o e
San
ou tain
alle
untin on
eac.
sa IF
e 0
-gu-- _00
Orange County
CalEnviroScreen Percentiles
1 - 10% (Lowest Score)
11-20%
21-30%
31-40%
41-50%
51-60%
61-70%
71-80%
81-90%
91 - 1D0% (Highest Score)
County Boundary
N 0 3 6 Miles
A I I I I
Source: calEnviroscmer 4,0 - Feb. 2021 Update
CITY OF TUSTIN
GENERAL PLAN
Ill=
1%, S CAL VALF V
Lall,
E"
�les,
-RE,
Vs
DRAFT HOUSING ELEMENT
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
housing problems
# with problems
# households
% with
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-
Hispanic
2,644
6,089
43.42%
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
Severe Housing Problems
# with severe
problems
# households
% with severe
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-
Hispanic
1,519
6,089
24.95%
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
GENERAL PLAN
DRAFT HOUSING ELEMENT
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
housing problems
# with problems
# households
% with problems
Race/Ethnicity
White, Non -Hispanic
206,658
540,773
38.22%
Black, Non -Hispanic
8,074
16,719
48.29%
Hispanic
152,740
241,84
63.16%
Asian or Pacific Islander, Non-
Hispanic
84,193
186,038
45.26%
Native American, Non -Hispanic
.78 "/o
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
Severe Housing Problems
# with severe
problems
# households
% with severe
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-
Hispanic
50,205
186,038
26.99%
ative merican, on -Hispanic
44
0
Total
267,641
987,550
27. 10 %
Source: County of Orange, Analysis of Impediments, 2020
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
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 fan-dlies, 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
Orange& E Cha pman A.- Orange E Chapman A,,e
"��cks Ca.
orth Vi.t
Can)0
I rvine
01-9. C 101-9. C
IN -
IMM
City of Tustin City of Tustin
Overpayment by Renters Overpayment by Home Owners
20'A 20%-40%
20% - 40% 40% - 6U%
40% - STA 60% - SCI%
80%
City Boundary City R.unda ry
N D 0.5 1 md- CIty 0 11irl., COL.ty of L- Arig.l-, Bun—, f L -d S! 5 City cif i-, C—ty of L., Angel-, of L -d
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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
CHIN. -It s
PI I
E,1111
Fullemon orpna—
.j -MM " 1 —1 -
Orange County
Overcrowded Households
= 158.2 (Statewide Average)
F—] f 12
:520
1570
County Boundary
N 0 3 6 Miles
Source: CHHS Data - Tract
--- T5*
Wire—
ffi M
ffl,
[S=an CIZM�—We �M
M10
CIty of I rvine, County of Les Angeles,
Bureau of Land Management, Esn, HERE,
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
$14,999
2.5%
3.8%
3.2%
2.6%
$15,000 to
$24,999
2.6%
1.3%
3.3%
2.2%
$25,000 to
$34,999
2.2%
1.8%
3.7%
2.7%
$35,000 to
$49,999
2.1%
1.9%
3.8%
2.5%
$50,000 to
$74,999
2.5%
1.9%
3.7%
2.9%
$75,000 to
$99,999
2.6%
2.2%
3.6%
2.7%
$100,000 to
$149,999
2.7%
1.5%
4.1%
2.8%
$150,000 to
$199,999
2.1%
1.5%
3.6%
2.8%
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-59 SEPTEMBER 2022
$200,000 or more
5.4%
4.3%
7.2%
5.8%
Medianm'come
90,939
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 Corrummity 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 hic.
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)
Source: County of Orange, Analysis of Impediments, 2020
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-61 SEPTEMBER 2022
Race by Housing Sites (percent)
Race by Census Tract
Low
Total
Census
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
Park
LIHTC
149
150
13.1
3.4
75.4
7.2
755.13
14.4
3.6
57.9
20.5
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 11 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
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
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
Veterans outpost
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
Tustin Temporary Emergency Shelter
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
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 predon-dnately 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
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
City of Tustin
Orange County
Tenure
Estimate
Percentage
Estimate
Percentage
2010
Owner-
occupied
13,109
52.8
599,032
60.8
Renter -occupied
11,730
47.2
385,471
39.2
Total
24,839
984,503
2019
Owner-
occupied
12,759
49.7
595,272
57.4
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)
Source: Federal Financial Institutions Exammation Council (FFIEC) Home Mortgage Disclosure Act (HMDA) Dataset, 2019
Notes: Other includes Free Form Text and Joint applicants
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-66 SEPTEMBER 2022
Preapproval
App-
Race and
Loan
approved
App.
App.
File closed for
Purchased
request
Grand
withdrawn
approved
Ethnicity
originated
but not
Denied
incompleteness
loan
Total
by applicant
but not
accepted
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
Other Pacific
5
1
1
7
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
Latinc,
Source: Federal Financial Institutions Exammation Council (FFIEC) Home Mortgage Disclosure Act (HMDA) 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
American alone
1,508
1.9
0.8
1.4
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/eflu-tic 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 Comn-tission 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
an
Figure 19: Distribution of Predominantly White and Predominantly Hispanic Population
L Chapman Av, 0i ange E Chapman Ave
I I J n e
1M
ks
Ilk
0 1 evc,
lot
N-rlh Tcr I
LZINIM
UL4'ii�oa
Cks
City of Tustin City of Tustin
White Majority Hispanic Majority
Slim (gap< 10%) Slim (gap < 10%)
Sizeable (gap 10% – 50%) =1 Sizeable (gap 10% – 50%)
Predominant (gap> 50%) �M Predominant (gap > 50%)
City Boundary City Boundary
N 0 O�5 1 M11- Oily a[ FIV,11c, C.,,, -t,, W L., Arg,t,�. ot L,, 0 05 1 Mil- cty �1 C—ty f L., A,gel�,, B.— f L -d
Ci
An d, 4FRE, G—i�, LISGS, NGAI, IN, 1r) M.n.g., ent, Fsri, HFRF, Ga–in, INCRFMFNT P
LISGS, MET^ASA, Elf USDA
56 ft
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 11-
16 in Section 11 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 1-5 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 1-5 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
6-Lik
I ji, ;
P71M
Suitable Site Locations
Downtown Commercial Core Specific Plan
Red Hill Averue Specific Plan
Tustin Legacy Specift Plan
Enderle Center
Tustin Marketplace
Municipal Boondaries
N
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-77 SEPTEMBER 2022
Figure 21: Focused Locations of Sites to Meet RHNA
Enderle Center (Site #19)
Tustin Marketplace
(Site #20)
CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-78 SEPTEMBER 2022
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-78 SEPTEMBER 2022
Figure 22: Location of Sites in Opportunity Zones
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CITY OF TUSTIN DRAFT HOUSING ELEMENT
GENERAL PLAN D-79 SEPTEMBER 2022
Table 23. Sites Demographics
Area
Non -White Population
(Percent)
Low to Moderate Income
(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
GENERAL PLAN
DRAFT HOUSING ELEMENT
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
• Heritage Elementary School
• Legacy Magnet Academy (Grades 6-12)
• 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
• 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)
• Head Start preschool
• Rancho Santiago sheriffs training facility
• Orange County Animal Shelter
o Fire Station
• Army Reserve Center
• Village of Hope transitional homes for individuals and families with children
Employment
• Flight at Tustin Legacy office complex
• Hoag medical center and Health South acute care facility
• Stater Bros. grocery store and other retail and neighborhood services at the
Village at Tustin Legacy
• 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:
• Columbus Square (1,075 residential units consisting of single-family homes,
duplexes and multi -family homes)
• Columbus Grove (465 detached homes)
• Field 1 (376 attached units)
• Field 11 (189 detached units)
• Amalfi Apartments (533 apartment units)
• Greenwood (375 detached single-family units)
• Anton Legacy (225 affordable housing units)
• Levity (218 attached units)
• 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 dor�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:
0 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
AFTH Fair
Contributing Factor
Strategies to Address AFFH Issue
Supporting Programs
Housing Issue
Housing Mobility
1. Lack of affordable housing opportunities for
Housing Mobility Strategies consist of removing barriers to
PUBLIC OUTREACH - ENGAGE LIGUISTICALLY ISOLATED
Hispanic residents
housing in areas of opportunity and strategically enhancing
Revised Program 2.5 (b): By 2023, translate official City announcements (i.e. community meeting, hearings, etc.) to Spanish
2. High segregation for Hispanic/White and
Black/White populations (as defined by
access.
and disseminate printed copies of information to renters, property owners, and via social media, in order to expand
Dissimilarity Index values which indicate
Opportunity areas are rated "high" or "low" resource based on
knowledge of affordable housing options in High Opportunity Areas.
geographical segregation patterns)
education, employment, economic development, safe and decent
Community Development Department
housing, low rates of violent crime, transportation, and other
opportunities, including recreation, food and healthy
Action Outcomes:
enviromnent (air, water, safe neighborhood, safety from
environmental hazards, social services, and cultural institutions).
The City's goal is to increase attendance, representation, understanding by linguistically isolated residents, at community
meeting, public hearings and City Council meetings. By engaging Hispanic populations in the decision-making process,
they are better able to advocate for their needs and concerns regarding affordable housing and access to opportunities. 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.
QUALITY RENTAL HOUSING INSPECTION PROGRAM
New Program 3.11: By 2025 through 2029, establish a multi -family quality rental housing inspection program.
Community Development Department
Action Outcomes:
City's goal is to elevate the quality of housing in segregated areas in order to transform the area into a desirable housing
location by all socio-economic groups and to protect existing tenants from displacement and to provide occupants the
opportunity to live in suitable housing conditions that are not characterized with substandard conditions such as lack of
plumbing or overcrowding.
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
_L_
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.
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.
New Housing
1. Disparity in access to opportunity between
New Housing Choices and Affordability in Areas of
ADU/SB 9 ACCELERATOR PROGRAM
Choices and
Affordability in
the northeast (higher resources), where there
are predominate populations of White
Opportunity means promoting housing supply, choices and
affordability in areas of high opport�mi and outside of areas of
Revised Program 1.7b: The City will create an ADU/SB 9 accelerator program and focus in High Opportunity Areas
Areas of Opportunity
residents, and southwest (lower resources) of
concentrated poverty.
within the northeast portion of the City where there are predominately single-family residences in order to expand
the city, where there are predominate
housing choices. This program could include a permit fee waiver for affordable housing units, permit fast tracking (refer
populations of Hispanic residents
to Program 1.1h), and technical assistance. This program will complement revised Program 1.1(h) Streamlining and
2. Lack of affordable housing opportunities for
Permit Fast Tracking for new ADU/SB9 development proposals.
Hispanic residents
Community Development Department
Action Outcome:
By 2025, the City will adopt a program and mail out information pertaining to the new accelerator program for ADUs
and SB 9 developments, specifically to high opportunity areas.
STREAMLINING AND PERMIT FAST TRACKING
CITY OF TUSTIN
GENERAL PLAN
WMIM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
AFTH Fair
Contributing Factor
Strategies to Address AFFH Issue
Supporting Programs
Housing Issue
Revised Program 1.1 (h): By 2023, provide technical 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.
Community Development Department
Action Outcome:
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 timefrarnes and for all affordable housing projects by assigning a designated "streamlining staff
liaison" to the project.
PUBLIC OUTREACH - DISSEMINATE HOUSING AND ANCILLARY RESOURCE INFORMATION & ENGAGE
LIGUISTICALLY ISOLOATED
New Program 2.5 (c): Annually, starting in 2023 through 2029, translate the City's Tustin Housing Authority website and
factsheets promoting affordable housing opportunities and ancillary support services, such as transit and child care, into
Spanish, and distribute to low resources areas.
Community Development Department
Action Outcomes: Increase the distribution of translated materials to low resources areas located in the southwest of the
City by mailing out postcards to each household in select census tracts, containing information related to housing
choices, transit, child care, and education resources.
Place -Based
1. Disparity in access to opportunity between
Place -based Strategies to Encourage Community Conservation
HOUSING REHABILITATION TO IMPROVE HOUSING CONDITIONS, INCLUDING OVERCROWDING
Strategies to
the northeast (higher resources), where there
and Revitalization Involves approaches that are focused on
New/Revised Program 3.10: By July 2024, the City will partner with a non-profit to develop and launch a CDBG funded
Encourage
Community
are predominate populations of White
conserving and improving assets in areas of lower opportunity
Housing Rehabilitation Program to facilitate the repair of dilapidated housing to address lack of plumbing, kitchen
investment in
Revitalization
residents, and southwest (lower resources) of
the city, where there are predominate
and concentrated poverty such as targeted
neighborhood revitalization, preserving or rehabilitating existing
facilities and repairs to provide relief of overcrowding. Program participants will be provided grants and/or loans to
populations of Hispanic residents
affordable housing, improving infrastructure, schools,
conduct necessary housing updates.
2. Disproportionate housing problems for the
employment, parks, transportation and other community
The City's goal is to protect existing tenants from displacement and to provide occupants the opportunity to live in suitable
city's Hispanic and Black residents (problems
amenities.
housing conditions that are not characterized with substandard conditions such as lack of plumbing or overcrowding. The
include 1) housing unit lacks complete
program will focus on improving housing conditions in tracts 744.06, 744.07, 744.08, 755.12, 755.13, 755.14, 755.15-(qreas
kitchen facilities; 2) housing unit lacks
with high segiegation index as defined by Dissimilarity Index values which indicate geogaphical segregation patterns in
census tracts).
complete plumbing facilities; 3) household is
overcrowded; and 4) household is cost
Action Outcomes:
burdened)
3. Disproportionate housing problems faced by
The program will facilitate four (4) rehabilitation projects to assist with reducing overcrowding per year and another four
large family households
(4) 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 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 in the
City's CDBG Annual Report.
Community Development Department
IN CREASE HOUSIN G SUPPLY FOR LARGE HOUSEHOLDS
New Program 3.13: By January 2024, the City will amend the zoning code to require all new multi -family projects to
provide at least five (5) percent large family units (3+ bedrooms) which will prevent overcrowding and further cost
burden, by addressing demand for such units and increasing the large units into the local housing inventory.
Community Development Department
Action Outcomes: Four (4) large family units will be generated annually, and 32 total by 2029.
CITY OF TUSTIN
GENERAL PLAN
KM
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
AFTH Fair
Strategies to Address AFFH Issue
Contributing Factor
Supporting Programs
Housing Issue
QUALITY RENTAL HOUSING INSPECTION PROGRAM
New Program 3.11: By 2025, Establish a multi-fan-dly quality rental housing inspection program.
Community Development Department
Action Outcomes:
City's goal is to elevate the quality of housing in segregated areas in order to transform the area into a desirable housing
location by all socio-economic groups and to protect existing tenants from displacement and to provide occupants the
opportunity to live in suitable housing conditions that are not characterized with substandard conditions such as lack of
plumbing or overcrowding.
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 Dissimilari!y Index values which indicate geogjaphical segregati
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.
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.
TUSTIN LEGACY SPECIFIC PLAN IMPROVEMENT PROGRAM:
New Program 2.8: 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. The area comprises 1,500 acres, of which 800 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:
• Brookfield at Tustin Legacy and Levity: residential projects with development of open space, park areas, and
community amenities
• Tustin Legacy Linear Park Between Armstrong Avenue and Warner Avenue
• Alley Grove Community Plaza
• Neighborhood D South Infrastructure Construction - Phase 2
• Tustin Ranch Road Pedestrian Bridge
• South Hangar Renovation - Phase 1 (for future reuse of site)
• Armstrong Avenue Pedestrian Bridge
• Warner Avenue Pedestrian Bridge
Community Development Department
Action Outcomes:
The City will facilitate development of infrastructure, housing, and community amenities within the TLSP area.
Improvements will provide increased access to safe and decent housing, transportation, recreation, and a healthy
enviromnent. By 2029, the City anticipates the Tustin Legacy (Tract 744.15) to be identified as a "high resource" area
according to TCAC/HCD Opportunity Map criteria.
Protecting Existing
1. Disproportionate housing problems for the
Protecting Existing Residents from Displacement comprises
QUALITY RENTAL HOUSING INSPECTION PROGRAM
Residents from
city's Hispanic and Black residents (problems
strategies that protect residents in areas of lower or moderate
New Program 3.11: By 2025, Establish a multi -family quality rental housing inspection program.
Displacement
include 1) housing unit lacks complete
opportunity and concentrated poverty and preserve housing
kitchen facilities; 2) housing unit lacks
choices and affordability.
Community Development Department
complete plumbing facilities; 3) household is
CITY OF TUSTIN
GENERAL PLAN
D-91
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
AFTH Fair
Housing Issue
Contributing Factor
Strategies to Address AFFH Issue
Supporting Programs
overcrowded; and 4) household is cost
Action Outcomes:
burdened) - Specifically, Hispanic
households were identified as having
City's goal is to elevate the quality of housing in segregated areas in order to transform the area into a desirable housing
substantial overcrowding
location by all socio-economic groups and to protect existing tenants from displacement and to provide occupants the
2. Concentrated female -headed households and
opportunity to live in suitable housing conditions that are not characterized with substandard conditions such as lack of
LMI population within Census tract 755.14
plumbing or overcrowding.
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 DissimilarLty Index values which indicate geogjaphical segregatio
patterns in census tracts).
The City will receive at least one monthly referral from the City's Neighborhood Improvement Task Force (NlTF) (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.
The City will conduct at least five multi -family quality rental housing inspections in the programs first year, and will
increase the number of annual inspections by 2, each year thereafter until 2029. CHILD-CARE RESOURCES
New Program 3.12: By December 2022, the City will create a "Financial Assistance for Child Care" webpage with
information and links to Childrer�s Home Society of California (CHS) and the Orange County Department of Education
(OCDE). These programs provide funding to low-income families for child care services. The City will work with Tustin
Preschool, Kiddie Academy of Tustin, or other local preschool programs within Census tract 755.14 to advertise and
promote financial assistance through pamphlets, e -blasts, and other applicable online community forums (such as
Facebook and NextDoor).
Economic Development DepartmentlCommunity Development Department
Action Outcome: Single -parent households require special consideration and assistance because of their greater needs
for daycare, healthcare, and other facilities. According to HCD, female -headed households with children tend to have
lower incomes, thus limiting housing 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.
CITY OF TUSTIN
GENERAL PLAN
DRAFT HOUSING ELEMENT
SEPTEMBER 2022
CITY OF TUSTIN
GENERAL PLAN
APPENDIX E
PUBLIC PARTICIPATION
E-1
HOUSING ELEMENT
SEPTEMBER 2022
APPENDIX E
PUBLIC PARTICIPATION (COMMUNITY ENGAGEMENT)
CITY OF TUSTIN
GENERAL PLAN
E-1
HOUSING ELEMENT
SEPTEMBER 2022
Axe,
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City of Tustin
202 7 — 2029 Housing Element Update
Community Engagement Plan
Y 01-i
lu I
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 Pa ge 12
Purpose
This COMMUNITY ENGAGEMENT PLAN is for the City of Tustin's 61h Cycle Housing Element (2021-2029). This Plan describes
strategies for engaging with residents and stakeholders through an online survey, education and awareness campaigns, and
public meetings. Due to COVID- 19 restrictions on in-person meetings, this outreach plan focused on alternatives such as virtual
meetings, targeted email blasts, mailings to stakeholders, unpaid and paid social media postings, posters at community
facilities, distribution of flyers, dedicated project website, and newspaper advertisements.
Background
The City of Tustin is preparing the 2021 — 2029 HOUSING ELEMENT UPDATE to evaluate current and
future housing conditions, and identify housing sites and programs to meet the community's needs. While
updating the housing element is a State requirement, it is also an opportunity to assess its accomplishments
and progress toward meeting housing goals put forth in the previous Housing Element in 2013. The 2021 -
2029 Housing Element will outline the goals, policies and programs needed to promote the development
and preservation of safe, accessible, and diverse housing in the City.
Goals and Objectives
The GOAL of the COMMUNITY ENGAGEMENT PLAN for the 2021 — 2029 Housing Element Update is to
guide the City's community and stakeholder engagement efforts and to provide information about the
importance in participating in the Housing Element Update. The OBJECTIVES of the Community
Engagement Plan include:
Building public awareness of the Housing Element Update, its requirements, and the City's vision
and goals to adequately plan to meet housing needs to all of its residents;
Educating the Tustin community on the requirements of the Housing Element Update, and progress
since the previous Housing Element;
Engaging community members and key stakeholder groups to provide input on potential policies
and programs that will align with Tustin resident's housing needs;
Facilitating discussions with community members and decision makers to identify how and where
additional housing could be located within the City; and,
Providing a concise document to the Tustin City Council and Planning Commission for adoption, with
input and updates from public outreach and engagement activities during the Housing Element
Update.
City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 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. 104016�
Affordable Housing Advocates ( ff*41
Alwalk
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
- Jamboree Housing - OC Community
Corp. Housing Corp.
- Tustin Planning - Habitat for Humanity
Partnership
- Linc Housing
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 und er-rep resented community
members as well as youth and seniors. This includes but is not limited to:
- St. Joseph Hospital
- Meals on Wheels
OC
- Alzheimer's of OC
-Neighborworks OC
Disability Advocates
-Community Health
Initiative of OC
- Tustin Community
Foundation
- Lestonnac Free Clinic
- Tustin Public Schools
Foundation
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
Tustin
- moms OC
- Veterans Legal
Institute
- Orange County
Finance Trust
- Big Brothers and Big
Sisters of OC
- OC Food Access
Coalition
- YMCA of OC
- Goodwill of OC
- Patriots & Paws
- Community Action
Partnership of OC
People Experiencing Homelessness
- Legal Aid Society of
OC
- Second Harvest Food
Bank of OC
- Public Law Center
Organizations, groups, or agencies that provide services to people experiencing homelessness in Tustin. This
includes but is not limited to:
- Housing and Homeless
Prevention Unit
- Human Options
- The Eli Home
-Orange County
Housing Finance Trust
- City Net
- Olive Crest
- American Family
Housing
Real Estate Affiliated
- Families Forward
- OC Gateway to
Housing
- OC Social Services
Tustin Family Campus
- Family Promise of OC
- Second Chance OC
- OC Rescue Mission
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 Pa ge 15
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
- Century Housing
- Lennar Corp.
-City Ventures
- Civic Center Barrio
Housing Corp.
- Taylor Morrison
-Greystar
- William Lyon Homes,
Inc.
- Brookfield Residential
Southern CA
Senior Housing and Advocates
-Curt Pringle & Assoc.
-HomeAid Orange County
- Shea Homes
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
-Community Action
Partnership of
Orange County
- OC Office on
Aging
-Orange County
Health Care Agency
Religious Institutions
Justin Housing
Authority
-County of Orange
Senior Services
-Senior Rental
Properties in Tustin
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 underrep resented 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
Foundation Foundation OC
- Tustin Unified
School District
City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan Pa ge 16
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
Do- Housing Element Update Community 10� Joint Community Workshop with
Workshop with the Planning Commission the City Council and Planning
Commission
November Jan/Feb May 20,21
2020 > 2021 >
llll� Community Survey open
for 30 days
Online Community Survey
No- Draft Document - Public Hearing with the
Planning Commission
September October
2021 > 2021
Do- June 30 - Reopened the
Community Survey for 30 days
Do- Draft Housing Element
Document available for public
review (30 days) and HCD
review (60 days)
00- Finalize Document -
Public Hearing with the
City Council
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:
• Survey results
• Reviewed existing housing policies
• Potential new housing programs
• Opportunity sites for meeting housing requirements
• Project timeline
City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan Pa ge 17
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
posted as a spotlight feature on the City's website and sent to the web's
subscriber list in English and in Spanish
-POSTED FLYERS - Notifications in English and in Spanish were posted on the
City's e -notice board, Library, Senior Center, Tustin Family Youth Center (TFYC),
and Boys & Girls Club. Additional bundles of flyers were distributed at the
Senior Center (200 flyers), TFYC (200 flyers), and Boys & Girls Club (100
flyers). Additional flyer distribution was offered to individual apartment
locations part of the TEAM (Tustin Effective Apartment Managers) group
-CITY CALENDAR - Meeting information was posted on the City's Calendar
-TUSTIN CHAMBER - Tustin Chamber of Commerce advertised meeting dates on
their website. Flyer graphics shared were in English and in Spanish.
-EMAIL BLASTS - Multiple email notifications were sent to 268 stakeholders and
interested parties. The City Manager's Office utilized their Community Outreach
ListSery to e-mail notifications to over 10,000 subsribers. Graphics included and
attached to email blasts were in English and in Spanish.
-POSTCARD MAILINGS - Postcards containing workshop and public participation
information in English and in Spanish were mailed to 396 interested parties
including residents, businesses, property managers, housing advocacy groups,
non -profits, religious institutions and others. Information regarding workshop
participation was included within the City of Tustin's Strategic Plan postcards
which were distributed to 29,885 Tustin residents and 3,457 Tustin businesses.
I— —
WEBSITE- City developed a
dedicated Housing Element Update)
webpage, hosted on the City's
website
*Website includes a project
overview, schedule of activities,
and information on how the public
can get involved
*Website updated regularly with
timeline, meeting updates and
survey information
Project
Webpage
-SOCIAL MEDIA POSTS - UNPAID
AND PAID - Social media posts
were made containing information
on public participation
opportunities regarding the
Housing Element Update survey,
and multiple workshops/meetings,
on all of the City's social meda
platforms
-PRESS RELEASE - A press release
was distributed in English and
Spanish, inviting the public to
review the Draft Housing Element
Update (97 subscribers)
-VIDEO OUTREACH - Mayor
Clark's Corner video advertised
review of the Draft HEU. Video
was posted on all Social Media
outlets including YouTube
*The Tustin Chamber of Commerce
shared workshop/meeting
information on each of their social
media platforms
Media Fostsi'M
0
(.-NEWSPAPER ADVERTISEMENTS - To build widespread awareness of the
Housing Element Update, the City has made publications in local and regional
news resources in both printed and digital formats
-Tustin News - distributed to over 7,000 Tustin residents
,Irvine Weekly - distributed to over 8,200 Tustin residents, including a digital
distribution, reaching over 33,000 individuals
-PAID SOCIA MEDIA ADS - Paid advertisements on the City's social media
platfroms which enabled notification to a larger population than traditional
nnqtinci-
City of Tustin 1 2021 — 2029 Housing Element Update I Community Engagement Plan P a g e 1 9
Appendix B
Index of Interested Parties
Index of Interested Parties
Housing Element Survey Respondents
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Orange County Housing Developers List
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CITY OF TUSTIN
GENERAL PLAN
APPENDIX F
REFERENCES
F-1
HOUSING ELEMENT
SEPTEMBER 2022
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
GENERAL PLAN
F-2
HOUSING ELEMENT
SEPTEMBER 2022
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
GENERAL PLAN
F-3
HOUSING ELEMENT
SEPTEMBER 2022
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.
https:/ /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
GENERAL PLAN
F-4
HOUSING ELEMENT
SEPTEMBER 2022