Item 08b - Arcadia Housing Element Update — Arcadia City Council, February 15, 2022 (part 3 of 5)

Calling Potential Police Cadets
Are you interested in pursuing a career in law
enforcement? Join the Arcadia Police Department as a
Police Cadet. Police Cadets must be between 18 to 21
years of age. To obtain more information, call
574-5172 or email [email protected].

ArcadiaCA.gov
SEPTEMBER 2021
Can you find the hidden x3 ?
Save by Joining the Paramedic
Membership Program
A 9-1-1 call for emergency ambulance service can cost
thousands of dollars. For $51 per year, the Paramedic
Membership Program (PMP) provides savings with
benefits that you do not want to miss:
• Covers ALL permanent household members who
reside at the same address.
• Covers ALL out-of-pocket expenses for emergency
ambulance services.
• Reduces rates for those who live in retirement
facilities and qualifying low-
income residents.

For more information, or to ob-
tain an application packet,
please contact the Arcadia Fire
Department at 574-5126 or visit
ArcadiaCA.gov/Paramedic.

Bear Safety Tips
Often bears emerge in
residential neighbor-
hoods in search of food
and water. Bears have
keen noses and can
smell from miles away.

To protect your family
and property, follow
these simple tips:
• Purchase and
properly use a bear-proof garbage container. The
City of Arcadia offers 95-gallon bear resistant carts
to residents. For more information, visit
ArcadiaCA.gov/TrashandRecycling.
• Keep barbeque grills clean and stored in a garage
or shed when not in use.
• Only provide bird feeders during November
through March.
• Don’t leave any scented products outside, even
non-food items such as suntan lotion, insect
repellent, soap, or candles.
• Harvest fruit off trees as soon as the fruit is ripe, and promptly collect fruit that has fallen.
• Securely block access to potential hibernation sites
such as crawl spaces under decks and buildings.

This can be done by sealing all openings with
caulking, foam insulation, or wood. Make sure to
continuously monitor the exterior of your home for
new possible points of entry.

In the event of immediate danger from any type of
wildlife, please do not hesitate to call the Arcadia
Police Department at 792-7151 or 9-1-1 in an
emergency. For more bear safety tips and
Information, visit ArcadiaCA.gov/Wildlife.

Arcadia Police Department Explorer
Program
The Arcadia Police Department is
seeking Explorers. An Explorer is
a volunteer scout that assists
with searches for evidence, report
writing, desk officer duties,
command post operations, crime
prevention surveillance, disaster
assistance, crowd and traffic
control, and more. It’s an excellent way to start
pursuing a career in law enforcement.

The Arcadia Police Department Explorer Program is
designed for youth between 14 to 18 years of age.

After graduating from the San Gabriel Valley Law
Enforcement Explorer Academy, Explorers are
assigned to Explorer Post 101. Police Officers then
work with Explorers in an effort to provide community
service. For more information, call 574-5172 or email
[email protected].

The Arcadia Library
Offers Wonderful Books About the
Moon Festival
The Moon Festival is a traditional Chinese celebration
observed when the moon is full and at its brightest. Visit the Arcadia Library and check out books with information on the unique cultural traditions of the Moon Festival.

For more information, visit ArcadiaCA.gov/Library.

The First Flush– Protect Water Quality
In the summer, pollutants from pet waste, cigarette
butts, oil, grease, and pesticides accumulate on the
street. In the rainy season, the first storm, known as the first flush, is dangerous because it carries these toxic pollutants in high concentrations into the ocean. By being mindful, we can help protect public health, the beaches, and aquatic life. Help prevent pollution by:
• Picking up pet waste and placing it into the
appropriate trash container.
• Properly disposing of leaves. Do not blow, sweep,
hose, or rake leaves into the street, gutter, or storm
drains.
• Avoid applying fertilizer or any other chemical on
lawns and gardens before watering or predicted rain
event.
• Properly disposing of trash; throw litter into trash
cans, not into the streets.
• Reporting illegal dumping by calling the Public Works Service Department at 254-2720.

Appendix B: Community Engagement Summary B-9

667. Public Comments
One inquiry regarding the housing element was received during the planning period. The City also posted the Public Review Draft on the City’s website for comment from September 30 through November 1, 2021.

The Draft was advertised through various outlets such as Public comments were solicited through various outlets such as Twitter, Facebook, WeChat, and Nextdoor. The City provided multiple outlets for public comments, however, noNoDespite outreach efforts, no comments were received during the Public Review Period.
-----Original Message-----
From: Richard Sun <[email protected]>
Sent: Saturday, October 2, 2021 3:09 PM
To: Lisa Flores <[email protected]>
Cc: Lorraine Sun <[email protected]>; Michael Sun <[email protected]> Subject: Re: Draft Housing Element - Public Review
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

Hi Lisa:

First, I want to thank you for replying to my request for the Draft Housing Element. As you know, we already had several meetings with you discussing our feasibility study of the development of 30-60 E Live Oak. With the Draft Housing Element in process, we will consider including affordable housing units in our development to help the City fulfil some of its affordable housing needs. To do an analysis of including affordable housing units, we need to know the affordable sales price for very low, low, and moderate income, we just wonder if the City has such data/formula available. Please advise. Thanks.

Regards
Richard Sun
________________________________
From: Lisa Flores <[email protected]>
Sent: Thursday, September 30, 2021 4:12 PM
Subject: Draft Housing Element - Public Review
Good afternoon,

Section 1: Introduction 1
TTechnical Background Report
AAppendix C
Glossary of Terms

Appendix C: Glossary of Terms C-1

Appendix C: Glossary of Terms
Above Moderate Income Household. A household with an annual income usually greater than 120% of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available legibility limits established by the U.S. Department of housing and Urban Development (HUD) for the Section 8 housing program.

Affirmatively Furthering Fair Housing (AFFH). Affirmatively Furthering Fair Housing (AFFH) is a legal requirement that federal agencies and federal grantees further the purposes of the Fair Housing Act. AFFH means "taking meaningful actions, in addition to co mbating discri mination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws.

Apartment. An apartment is one (1) or more rooms in an apartment house or dwelling occupied or intended or designated for occupancy by one (1) family for sleeping or living purposes and containing one (1) kitchen.

Assisted Housing. Generally multi-family rental housing, but sometimes single-family ownership units, whose construction, financing, sales prices, or rents have been subsidized by federal, state, or local housing programs including, but not limited to Federal state, or local housing programs including, but not limited to Federal Section 8 (new construction, substantial rehabilitation, and loan management set-asides), Federal Sections 213, 236, and 202, Federal Sections 221 (d) (3) (below-market interest rate program), Federal Sections 101 (rent supplement assistance), CDBG, FmHA Sections 515, multi-family mortgage revenue bond programs, local redevelopment and in lieu fee programs, and units developed pursuant to local inclusionary housing and density bonus programs.

Below-Market-Rate (BMR). Any housing unit specifically priced to be sold or rented to low or moderate income households for an amount less than the fair-market value of the unit. Both the State of California and the U.S. Department of Housing and Urban Development set standards for determining which households qualify as “low income” or “moderate income.” (2) The financing of housing at less than prevailing interest rates.

Build-Out. That level of urban development characterized by full occupancy of all developable sites in accordance with the General Plan; the maximum level of development envisioned by the General Plan.

Build-out does not assume that each parcel is developed to include all floor area or housing units possible under zoning regulations.

Community Development Block Grant (CDBG). A grant program administered by the U.S. Department of Housing and Urban Development (HUD) on a formula basis for entitled communities and administered by the State Department of Housing and Community Development (HCD) for non-entitled jurisdictions. This grant allots money to cities and counties for housing rehabilitation and community development, including public facilities and economic development.

Appendix C: Glossary of Terms C-2

Condominium. A structure of two or more units, the interior spaces of which are individually owned; the balance of the property (both land and building) is owned in common by the owners of the individual units. (See “Townhouse.”)
Covenants, Conditions, and Restrictions (CC&Rs). A term used to describe restrictive limitations that may be placed on property and its use, and which usually are made a condition of holding title or lease.

Deed. A legal document which affects the transfer of ownership of real estate from the seller to the buyer.

Density Bonus. The allocation of development rights that allow a parcel to accommodate additional square footage or additional residential units beyond the maximum for which the parcel is zoned, usually in exchange for the provision or preservation of an amenity at the same site or at another location.

Density, Residential. The number of permanent residential dwelling units per acre of land. Densities specified in the General Plan may be expressed in units per gross acre or per net developable acre.

Developable Land. Land that is suitable as a location for structures and that can be developed free of hazards to, and without disruption of, or significant impact on, natural resource areas.

Down Payment. Money paid by a buyer from his own funds, as opposed to that portion of the purchase price which is financed.

Duplex. A detached building under single ownership that is designed for occupation as the residence of two families living independently of each other.

Dwelling Unit (DU). A building or portion of a building containing one or more rooms, designed for or used by one family for living or sleeping purposes, and having a separate bathroom and only one kitchen or kitchenette. See Housing Unit.

Elderly Housing. Typically, one- and two-bedroom apartments or condominiums designed to meet the needs of persons 62 years of age and older or, if more than 150 units, persons 55 years of age and older, and restricted to occupancy by them.

Emergency Shelter. A facility that provides immediate and short-term housing and supplemental services for the homeless. Shelters come in many sizes, but an optimum size is considered to be 20 to 40 beds.

Supplemental services may include food, counseling, and access to other social programs. (See “Homeless” and “Transitional Housing.”)
Extremely Low Income Household. A household with an annual income equal to or less than 30% of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available eligibility limits established by the U.S. Department of Housing and Urban Development (HUD) for the Section 8 housing program.

Fair Market Rent. The rent, including utility allowances, determined by the United States Department of Housing and Urban Development for purposed of administering the Section 8 Program.

Family. (1) Two or more persons related by birth, marriage, or adoption [U.S. Bureau of the Census]. (2) An Individual or a group of persons living together who constitute a bona fide single-family housekeeping unit in a dwelling unit, not including a fraternity, sorority, club, or other group of persons occupying a hotel,

Appendix C: Glossary of Terms C-3

lodging house or institution of any kind [Governor’s Office of Planning and Research, General Plan Guidelines].

General Plan. A comprehensive, long-term plan mandated by State Planning Law for the physical development of a city or county and any land outside its boundaries which, in its judgment, bears relation to its planning. The plan shall consist of seven required elements: land use, circulation, open space, conservation, housing, safety, and noise. The plan must include a statement of development policies and a diagram or diagrams illustrating the policies.

Goal. A general, overall, and ultimate purpose, aim, or end toward which the City will direct effort.

Green Building. Green or sustainable building is the practice of creating healthier and more resource- efficient models of construction, renovation, operation, maintenance, and demolition. (US Environmental Protection Agency)
Historic Preservation. The preservation of historically significant structures and neighborhoods until such time as, and in order to facilitate, restoration and rehabilitation of the building(s) to a former condition.

Historic Property. A historic property is a structure or site that has significant historic, architectural, or cultural value.

Household. All those persons—related or unrelated—who occupy a single housing unit. (See “Family.”) Housing and Community Development Department (HCD). The State agency that has principal responsibility for assessing, planning for, and assisting communities to meet the needs of low and moderate income households.

Housing Element. One of the seven State-mandated elements of a local general plan, it assesses the existing and projected housing needs of all economic segments of the community, identifies potential sites adequate to provide the amount and kind of housing needed, and contains adopted goals, policies, and implementation programs for the preservation, improvement, and development of housing. Under State law, Housing Elements must be updated every five years.

Housing Payment. For ownership housing, this is defined as the mortgage payment, property taxes, insurance and utilities. For rental housing this is defined as rent and utilities.

Housing Ratio. The ratio of the monthly housing payment to total gross monthly income; also called Payment-to-income Ratio or Front-End Ratio.

Housing Unit. The place of permanent or customary abode of a person or family. A housing unit may be a single-family dwelling, a multi-family dwelling, a condominium, a modular home, a mobile home, a cooperative, or any other residential unit considered real property under State law.

Housing and Urban Development, U.S. Department of (HUD). A cabinet-level department of the federal government that administers housing and community development programs.

Implementing Policies. The City’s statements of its commitments to consistent actions.

Implementation. Actions, procedures, programs, or techniques that carry out policies.

Appendix C: Glossary of Terms C-4

Infill Development. The development of new housing or other buildings on scattered vacant lots in a built- up area or on new building parcels created by permitted lot splits.

Jobs-Housing Balance. A ratio used to describe the adequacy of the housing supply within a defined area to meet the needs of persons working within the same area. The General Plan uses SCAG’s definition which is a job total equal to 1.2 times the number of housing units within the area under consideration.

Land Use Classification. A system for classifying and designating the appropriate use of properties.

Live-Work Units. Buildings or spaces within buildings that are used jointly for commercial and residential purposes where the residential use of the space is secondary or accessory to the primary use as a place of work.

Low Income Household. A household with an annual income usually no greater than51%-80% of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available eligibility limits established by the U.S. Department of Housing and Urban Development (HUD) for the Section 8 housing program.

Low Income Housing Tax Credits. Tax reductions provided by the federal and State governments for investors in housing for low income households.

Manufactured Housing. Residential structures that are constructed entirely in the factory, and which since June 15, 1976, have been regulated by the federal Manufactured Home Construction and Safety Standards Act of 1974 under the administration of the U.S. Department of Housing and Urban Development (HUD). (See “Mobile home” and “Modular Unit.”)
Mixed-Use. Properties on which various uses, such as office, commercial, institutional, and residential, are combined in a single building or on a single site in an integrated development project with significant functional interrelationships and a coherent physical design. A “single site” may i nclude contiguous properties.

Moderate Income Household. A household with an annual income usually no greater than 81%-120% of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available eligibility limits established by the U.S. Department of Housing and Urban Development (HUD) for the Section 8 housing program.

Monthly Housing Expense. Total principal, interest, taxes, and insurance paid by the borrower on a monthly basis. Used with gross income to determine affordability.

Multiple Family Building. A detached building designed and used exclusively as a dwelling by three or more families occupying separate suites.

Ordinance. A law or regulation set forth and adopted by a governmental authority, usually a city or county.

Overcrowded Housing Unit. A housing unit in which the members of the household, or group are prevented from the enjoyment of privacy because of small room size and housing size. The U.S. Bureau of Census defines an overcrowded housing unit as one which is occupied by more than one person per room.

Parcel. A lot or tract of land.

Appendix C: Glossary of Terms C-5

Planning Area. The area directly addressed by the general plan. A city’s planning a rea typically encompasses the city limits and potentially annexable land within its sphere of influence.

Policy. A specific statement of principle or of guiding actions that implies clear commitment but is not mandatory. A general direction that a governmental agency sets to follow, in order to meet its objectives before undertaking an action program. (See “Program.”)
Poverty Level. As used by the U.S. Census, families and unrelated individuals are classified as being above or below the poverty level based on a poverty index that provides a range of income cutoffs or “poverty thresholds” varying by size of family, number of children, and age of householder. The income cutoffs are updated each year to reflect the change in the Consumer Price Index.

Program. An action, activity, or strategy carried out in response to adopted policy to achieve a specific goal or objective. Policies and programs establish the “who,” “how” and “when” for carrying out the “what” and “where” of goals and objectives.

Redevelop. To demolish existing buildings; or to increase the overall floor area existing on a property; or both; irrespective of whether a change occurs in land use.

Regional. Pertaining to activities or economies at a scale greater than that of a single jurisdiction and affecting a broad geographic area.

Regional Housing Needs Assessment. A quantification by the local council of governments of existing and projected housing need, by household income group, for all localities within a region.

Rehabilitation. The repair, preservation, and/or improvement of substandard housing.

Residential. Land designated in the General Plan and zoning ordinance for building consisting of dwelling units. May be improved, vacant, or unimproved. (See “Dwelling Unit.”) Residential Care Facility. A facility that provides 24-hour care and supervision to its residents.

Residential, Multiple Family. Usually three or more dwelling units on a single site, which may be in the same or separate buildings.

Residential, Single-Family. A single dwelling unit on a building site.

Retrofit. To add materials and/or devices to an existing building or system to improve its operation, safety, or efficiency. Buildings have been retrofitted to use solar energy and to strengthen their ability to withstand earthquakes, for example.

Rezoning. An amendment to the map to effect a change in the nature, density, or intensity of uses allowed in a zoning district and/or on a designated parcel or land area.

Second Unit. A self-contained living unit, either attached to or detached from, and in addition to, the primary residential unit on a single lot. “Granny Flat” is one type of second unit.

Section 8 Rental Assistance Program. A federal (HUD) rent-subsidy program that is one of the main sources of federal housing assistance for low income households. The program operates by providing “housing assistance payments” to owners, developers, and public housing agencies to make up the difference between the “Fair Market Rent” of a unit (set by HUD) and the household’s contribution toward

Appendix C: Glossary of Terms C-6

the rent, which is calculated at 30% of the household’s adjusted gross monthly income (GMI). “Section 8” includes programs for new construction, existing housing, and substantial or moderate housing rehabilitation.

Shared Living Facility. The occupancy of a dwelling unit by persons of more than one family in order to reduce housing expenses and provide social contact, mutual support, and assistance. Shared living facilities serving six or fewer persons are permitted in all residential districts by Section 1566.3 of the California Health and Safety Code.

Single-Family Dwelling, Attached. A dwelling unit occupied or intended for occupancy by only one household that is structurally connected with at least one other such dwelling unit. (See “Townhouse.”) Single-Family Dwelling, Detached. A dwelling unit occupied or intended for occupancy by only one household that is structurally independent from any other such dwelling unit or structure intended for residential or other use. (See “Family.”)
Single Room Occupancy (SRO). A single room, typically 80-250 square feet, with a sink and closet, but which requires the occupant to share a communal bathroom, shower, and kitchen.

Subsidize. To assist by payment of a sum of money or by the granting to terms or favors that reduces the need for monetary expenditures. Housing subsidies may take the forms or mortgage interest deductions or tax credits from federal and/or state income taxes, sale or lease at less than market value of land to be used for the construction of housing, payments to supplement a minimum affordable rent, and the like.

Substandard Housing. Residential dwellings that, because of their physical condition, do not provide safe and sanitary housing.

Supportive Housing. Housing with no limit on length of stay, that is occupied by the target population as defined in California Health and Safety Code Section 53260(d), and that is linked to onsite or offsite services that assist the supportive housing resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community. “Target population" means adults with low incomes having one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health conditions, or individuals eligible for services provided under the Lanterman Developmental Disabilities Services Act and may, among other populations, include families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, or homeless people. [California Health and Safety Code Sections 50675.14(b) and 53260(d)]
Target Areas. Specifically, designated sections of the community where loans and grants are made to bring about a specific outcome, such as the rehabilitation of housing affordable by Very Low and Low income households.

Tax Increment. Additional tax revenues that result from increases in property values within a redevelopment area. State law permits the tax increment to be earmarked for redevelopment purposes but requires at least 20 percent to be used to increase and improve the community’s supply of very low and low income housing. Arcadia currently allocates 30 percent of its tax increment to increase and improve the community’s supply of very low and low income housing.

Tenure. A housing unit is owner-occupied if the owner or co-owner lives in the unit, even if it is mortgaged or not fully paid for. A cooperative or condominium unit is owner-occupied only if the owner or co-owner

Appendix C: Glossary of Terms C-7

lives in it. All other occupied units are classified as renter-occupied including units rented for cash rent and those occupied without payment of cash rent.

Townhouse. A townhouse is a dwelling unit located in a group of three (3) or more attached dwelling units with no dwelling unit located above or below another and with each dwelling unit having its own exterior entrance.

Transitional Housing. Shelter provided to the homeless for an extended period, often as long as 18 months, and generally integrated with other social services and counseling programs to assist in the transition to self-sufficiency through the acquisition of a stable income and permanent housing. (See “Homeless” and “Emergency Shelter.”)
Undevelopable. Specific areas where topographic, geologic, and/or superficial soil conditions indicate a significant danger to future occupants and a liability to the City.

ACRONYMS USED
ACS: American Community Survey
BMPs: Best Management Practices
CALTRANS: California Department of Transportation
CEQA: California Environmental Quality Act
CHAS: Comprehensive Housing Affordability Strategy
CIP: Capital Improvement Program
DDS: Department of Developmental Services
DIF: Development Impact Fee
DU/AC: Dwelling Units Per Acre
EDD: California Employment Development Department
FAR: Floor Area Ratio
FEMA: Federal Emergency Management Agency
HCD: Department of Housing and Community Development
HOA: Homeowners Association
HUD: Department of Housing and Urban Development
LAFCO: Local Agency Formation Commission
MFI: Median Family Income

Appendix C: Glossary of Terms C-8

NPDES: National Pollutant Discharge Elimination System
RTFH: Regional Task Force on the Homeless
RTP: Regional Transportation Plan
SCAG: Southern California Association of Governments
SPA: Sectional Planning Area
STF: Summary Tape File (U.S. Census)
TOD: Transit-Oriented Development
TDM: Transportation Demand Management
TSM: Transportation Systems Management
WCP: Water Conservation Plan

Attachment No. 3

Attachment No.3
Comment letter from HCD and Matrix with
all the proposed changes
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. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
Jason Kruckeberg, Director
Department of Development Services
City of Arcadia
240 West Huntington Dr.

P.O. Box 60021
Arcadia, CA 91066
Dear Jason Kruckeberg:

RE: City of Arcadia’s 6
th Cycle (2021-2029) Draft Housing Element
Thank you for submitting the City of Arcadia’s (City) draft housing element received for review on October 1, 2021, along with revisions received on November 15, 2021. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation on November 4, 2021 with you, Stephanie Ellsworth, Lisa Flores, Dave Barquist, Matt Horton and Molly Mendoza.

The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code).

The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

As a reminder, the City’s 6th cycle housing element was due October 15, 2021. As of today, the City has not completed the housing element process for the 6th cycle. The City’s 5th cycle housing element no longer satisfies statutory requirements. HCD encourages the City to revise the element as described above, adopt, and submit to HCD to regain housing element compliance.

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).

November 29, 2021
Jason Kruckeberg, Director

Page 2 ends

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:
http://opr.ca.gov/docs/OPR_Appendix_C_final.pdf and
http://opr.ca.gov/docs/Final_6.26.15.pdf.

HCD appreciates your diligent efforts and responsiveness provided during the review.

We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Jamillah Williams, of our staff, at [email protected].

Sincerely,
Paul McDougall
Enclosure
Senior Program Manager

City of Arcadia’s 6th Cycle Draft Housing Element Page 3 November 29, 2021

APPENDIX

CITY OF ARCADIA

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. Review and Revision

Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)

As part of the evaluation of programs in the past cycle, the element must provide an explanation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers, and persons experiencing homelessness).

B. Housing Needs, Resources, and Constraints

The element includes the Assessment of Fair Housing (AFH); however, additional information is necessary to address the requisite affirmatively furthering fair housing (AFFH) analysis requirement, including local contributing factors to the fair housing issues and develop strong programs and strategies to address the identified fair housing issues. Specifically, the element provides data regarding the patterns of various socio-economic characteristics across components of the required analysis (e.g., segregation and integration, racially and ethnically concentrated areas of poverty and affluence, access to opportunity, displacement); however, the element should also analyze trends for potential fair housing problems specific to Arcadia. In addition, the following analysis is required:

Fair Housing Enforcement and Outreach: The element must address the ability to provide enforcement and outreach capacity which can consist of actions such as ability to investigate complaints, obtain remedies, or the ability to engage in fair housing testing. The analysis must also describe compliance with existing fair housing laws and

City of Arcadia’s 6th Cycle Draft Housing Element Page 4 November 29, 2021
regulations and include information on fair housing outreach capacity. Furthermore, the revisions should address:

• Degree of outreach to all sectors of the community.
• Ongoing outreach and public participation throughout the planning period. • Indicate any findings, lawsuits or enforcement actions taken. • Describe how many fair housing complaints the City has received over the past few years.

Integration and Segregation: While the element includes some data on integration and segregation (p. 3-46), the element must include a local and regional analysis of patterns and trends. While the element utilizes the dissimilarity index to describe integration and segregation on race, the element should include local knowledge regarding racial segregation. Local knowledge or additional data sources are important because while the dissimilarity index measures integration in comparison to white residents, the majority of the City’s population are Asian. Furthermore, the element should describe any local knowledge, a comparison of northern and southern blocks groups that demonstrated income disparities, and a regional analysis for income describing similar concentrations and trends of poverty in surrounding areas. The element must also analyze local and regional patterns and trends of segregation and integration based on familial status and persons with disabilities and conclude with a summary of issues.

Racial/Ethnic Concentrated Areas of Affluence (RCAA): While the element includes data relative to RCAA, it should also include an analysis of local and regional patterns and trends. Because the City as a whole is considered a “highest resource area” (p. 3-58), the analysis should emphasize the regional perspective, evaluating the patterns and changes over time and considering other relevant factors, such as public participation, past policies, practices, and investments and demographic trends.

Disparities in Access to Opportunity: The element provides some information on the access to opportunity (Table 3-13 on page 3-56) but it must also provide a complete local and regional analysis of patterns and trends for all components. A comprehensive analysis should include the local and regional disparities of the educational, environmental, and economic scores through local, federal, and/or state data; and provide a description of education, environment, and employment. It should also include analyses for persons with disabilities as well as access to transit. Please refer to page 35 of the AFFH guidebook (link: https://www.hcd.ca.gov/community-development/affh/index.shtml#guidance) for specific factors that should be considered when analyzing access to opportunities as it pertains to educational, employment, environmental, transportation, and any factors that are unique to Arcadia.

Disproportionate Housing Needs including Displacement Risk: While the element includes some data on overcrowded households, cost burden, and displacement, it must also include data and analysis of substandard housing conditions and homelessness. Additionally, the element must provide a local and regional analysis for

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all disproportionate housing needs and analyze the data including looking at patterns, trends, other local knowledge, and conclude with a summary of fair housing issues.

Contributing Factors: While the element lists two contributing factors (p. 3-43), it must prioritize contributing factors to fair housing issues based on the analysis.

Goals, Priorities, Metrics, and Milestones: Goals and actions must significantly seek to overcome contributing factors to fair housing issues. Currently, the element identifies Programs 5-25 (Fair Housing) and 5-26 (Fair Housing Assistance) to encourage and promote affordable housing; however, most of these programs do not appear to facilitate any meaningful change nor address AFFH requirements. Given that most of the City is considered a high resource community, the element could focus on programs that enhance housing mobility and encourage development of more housing choices and affordable housing. Programs also should be based on identified contributing factors, be significant and meaningful. The element must add, and revise programs based on a complete analysis and listing and prioritization of contributing factors to fair housing issues. Furthermore, the element must include metrics and milestones for evaluating progress on programs, actions, and fair housing results. For more information, please see HCD’s guidance at https://www.hcd.ca.gov/community- development/affh/index.shtm.

2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)

While the element quantifies the existing housing needs of extremely low-income (ELI) households, it must still quantify projected ELI housing needs. The projected housing need for ELI households can be calculated by using available census data to determine the number of very low-income households that qualify as ELI households or presume that 50 percent of very low-income households qualify as ELI households.

3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)

The City has a regional housing need allocation (RHNA) of 3,214 housing units, of which 1,672 are for lower-income households. To address this need, the element relies on vacant and nonvacant sites, including sites in Specific Plan Areas and within the Mixed-Use Overlay areas. To demonstrate the adequacy of these sites and strategies to accommodate the City’s RHNA, the element must include complete analyses:

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the development of affordable housing on the site. The element must address current and potential general plan designations, allowable densities, support for residential capacity assumptions, existing uses and any known conditions that preclude development in the planning period and the potential schedule for development. As the zoning does not currently allow residential uses at appropriate densities, then the element must include programs to rezone sites pursuant to Government Code section 65583.2, subdivisions (h) and (i). In addition, the element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.

Realistic Capacity: The element states that it assumes an 80 percent buildout to determine capacity based on buildable acreage. However, the analysis must also support this estimate based on typical densities of existing or approved residential developments at a similar affordability level. In addition, while the element provided some overlay and mixed-use development examples to support the 80 percent buildout assumption, the element must indicate whether the calculations included density bonus units.

The element must also consider the calculation for sites that allow nonresidential uses (e.g., mixed-use) based on the likelihood of nonresidential development, performance standards, development trends supporting residential development, and any existing or planned policies, programs, or local guidance or efforts promoting residential development in nonresidential zones. The element must clarify whether 100 percent residential is allowed in commercial and mixed-use zones as well as whether residential uses are allowed by-right in the Downtown Mixed-Use expansion and overlay; the Mixed-Use upzone; and the CG overlay. In addition, on page A-17, the element indicated that with the implementation of the overlay, 100 percent residential would be allowed by-right in the Live Oak Corridor except in Las Tunas. The element should analyze the impact of this standard on the City’s realistic capacity and revise the calculation as necessary.

Suitability of Nonvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. To address this requirement, the element describes in general the existing use of each nonvacant site for example “multifamily housing” or religious structure”. In addition, small nonvacant sites descriptions are limited to “Small Sites Strategy,” which is not adequate to demonstrate the potential for redevelopment in the planning period. The element should describe the existing use and the existing units on all sites in the inventory. The description of existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period. In addition, the element should analyze the extent that existing uses may impede additional residential development. For example, the element can summarize past experiences converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. The element could

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also consider indicators such as age and condition of the existing structure, expressed developer interest, low improvement to land value ratio, and other factors. Many identified sites have existing multifamily housing or townhouses, given the fact that the element estimates a low number of units needing substantial rehabilitation, the element must identify the likelihood that the existing use will be terminated during the planning period.

Small Sites: The inventory lists 441 lower-income units on smaller sites. Sites smaller than a half-acre in size are deemed inadequate to accommodate housing for lower- income housing unless it is demonstrated that sites of equivalent size and affordability were successfully developed during the prior planning period or unless the element describes other evidence to HCD that the site is adequate to accommodate lower- income housing. (Gov. Code, § 65583.2, subd. (c)(2)(A).) While the element includes examples of small site development; it does not relate these examples to the affordability of these projects. To strengthen the existing analysis, the history of small site development example should describe trends specific to the development of housing affordable to lower-income households.

Previously Identified Nonvacant and Vacant Sites: While the sites inventory identifies whether most sites were identified in the previous housing element cycle, sites 451, 456-457, 462, 466-467, did not indicate if they were identified in the 5th cycle. For any vacant sites, the element should also indicate if sites were identified in the 4 th cycle.

Accessory Dwelling Units (ADU): The element assumes an ADU build out of 26 ADU and/or junior accessory dwelling unit (JADU) per year based upon doubling the average assumption over the past few years. Given that the City has only produced an average of 12 units per year since 2018, it is not clear if this production level will be achievable in the planning period. As a result, the element should be updated to include a realistic estimate of the potential for ADUs and include policies and programs that incentivize the production of ADUs. Depending on the analysis, the element must commit to monitor ADU production throughout the course of the planning period and implement additional actions if not meeting target numbers anticipated in the housing element. In addition to monitoring production, this program should also monitor affordability. Additional actions, if necessary, should be taken in a timely manner (e.g., within six months). Finally, if necessary, the degree of additional actions should be in stride with the degree of the gap in production and affordability.

For example, if actual production and affordability of ADUs is far from anticipated trends, then rezoning or something similar would be an appropriate action. If actual production and affordability is near anticipated trends, then measures like outreach and marketing might be more appropriate.

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Environmental Constraints: While the element describes environmental conditions within the City (p. 3-40), it must describe any mitigation measures being taken to address those constraints within the City that could impact housing development in the planning period. (Gov. Code, § 65583.2, subd. (b).)

Zoning for a Variety of Housing Types:

•• Emergency Shelters: While the element states that emergency shelters are permitted in the M-1 industrial zone, it must clarify whether emergency shelters are allowed as a permitted use without a conditional use or other discretionary permit. The identified zone(s) must demonstrate the M-1 zone has sufficient capacity to accommodate the identified need for shelters or for at least one emergency shelter, whichever is greater. (Gov. Code, § 65583, subd. (a)(4).) The housing element must also demonstrate the permit processing, development, and management standards for emergency shelters are objective and encourage and facilitate the development of, or conversion to, emergency shelters. In addition, emergency shelters must only be subject to the same development and management standards applicable to residential or commercial development within the same zone except for those standards prescribed by statute.

• Transitional and Supportive Housing: Transitional and supportive housing require a use permit in zones where single family homes are permitted by right.

Transitional housing and supportive housing must be permitted as a residential use in all zones allowing residential uses and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd. (a)(5).) The element must describe and analyze the City’s transitional and supportive housing standards and codes and demonstrate consistency with Gov. Code Section 65583(a)(5) or add or revise programs which comply with the statutory requirements. Finally, the City’s definition of supportive housing should be analyzed for consistency with state law and revised as necessary.

• Single Room Occupancy (SRO): Page 3-27 provides the definition of an SRO but does not state where they are allowed. The element must describe where SROs are allowed or add a program as appropriate to update the zoning code and permit to allow the development of SROs.

• Employee Housing: The element states that employee housing is permitted in the special use zone. In addition, the element must demonstrate zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.), specifically, sections 17021.5 and 17021.6. Section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone. Section 17021.6 requires employee housing consisting of no more than 12 units or 36 beds to be permitted in the same manner as other agricultural uses in the same zone.

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•• Mobilehomes: Page 3-27 states that mobilehomes are not permitted as long- term housing. The housing element must demonstrate the jurisdiction's zoning code allows and permits manufactured housing in the same manner and in the same zone as a conventional or stick-built structures are permitted (Gov. Code Section 65852.3). Specifically, manufactured homes should only be subject to the same development standards that a conventional single-family residential dwelling on the same lot would be subject to, with the exception of, architectural requirements for roof overhang, roofing material, and siding material. (Gov.

Code Section 65852.3(a).)

4. 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.

Land Use Controls: The element must identify and analyze all relevant land-use controls impacts as potential constraints on a variety of housing types (e.g., multifamily rental housing, mobilehomes, transitional housing). The analysis must also evaluate the cumulative impacts of land use controls on the cost and supply of housing, including the ability to achieve maximum densities and cost and supply of housing. The analysis should also describe past or current efforts to remove identified governmental constraints. The element must address the following:

• Pages 3-10 and 3-11 describe the same minimum and maximum densities in the CBD, MU, and DMU zones, for example the CBD lists a minimum density of 80 dwelling units and acre and a maximum of 80 dwelling units an acre. Although the City indicated that the intent of this was to create diversity in building appearance (made possible by differing height regulations per zone), having the same minimum and maximum density in a zone is a constraint because it provides no flexibility in development. The element must analyze this as a constraint and add a program to address the density requirement.
• As part of HCD’s call with the City, staff indi cated that three stories were allowed in the R3 zone despite a maximum building height of 30 feet, but Table 3-2 (p. 3-12 and 3-13) does not provide information beyond two stories. The element should clarify if three stories are allowed in the R3 zone without a use permit. If not, the City must add a program to amend its development standards to be consistent with state law.
• The element should list and analyze minimum unit sizes.

Parking Requirements: The element must analyze the requirement of two covered parking spaces per multifamily dwelling unit for its impact as a potential constraint on housing development (p. 3-14). Should the analysis determine the parking standards or permit procedures are a constraint on residential development, it must include a program to address or remove any identified constraints.

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Fees and Exaction: While the element lists development fees on (p. 3-33), it must indicate if all fees are the same for single and multifamily. The element must also analyze their impact as potential constraints on housing supply and affordability and describe the City’s efforts to mitigate the constraint. For example, the analysis could identify the total amount of fees and their proportion to the development costs for both single family and multifamily housing. Page 3-33 of the element indicated that the City would explore opportunities to lower development fees for affordable developments but did not describe how it would do this, the element should be revised to include a program to address fees.

Processing and Permit Procedures: While the element describes the use permit procedure for mixed-use housing, it must describe and analyze the City’s permit processing and approval procedures by zone and housing type (e.g., multifamily rental housing, mobilehomes, housing for agricultural employees, supportive housing). The analysis must evaluate the processing and permit procedures’ impacts as potential constraints on housing supply and affordability. For example, the analysis should consider processing and approval procedures and time for typical single- and multi- family developments, including type of permit, level of review, approval findings and any discretionary approval procedures. The element states that a minor use permit is required for multifamily developments in mixed-use and CBD zones. The element should describe any impacts on sites in the inventory. If so, this should be analyzed as a constraint and addressed in a program.

For example, the analysis could describe required findings and discuss whether objective standards and guidelines improve development certainty and mitigate cost impacts. The element must demonstrate this process is not a constraint or it must include a program to address this permitting requirement, as appropriate.

Local Ordinances: The element must specifically analyze locally adopted ordinances such as inclusionary ordinance or short-term rental ordinance that directly impact the cost and supply of residential development. The analysis should demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters.

On/Off-Site Improvements: The element must identify subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width) and analyze their impact as potential constraints on housing supply and affordability.

Codes and Enforcement: The element must describe the City’s building and zoning code enforcement processes and procedures, including any local amendments to the building code, and analyze their impact as potential constraints on housing supply and affordability.

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Constraints on Housing for Persons with Disabilities: While the element describes the City’s Reasonable Accommodation procedure on page 3-27, it must analyze the findings as a constraint for persons with disabilities including the associated fees, the application process, and findings. In addition, the element lists the U.S. Census Bureau and California’s Office of Planning and Research definition of family, but the element must include the City’s definition of family.

In addition, the element currently details that residential care facilities serving six or fewer persons are permitted in all residential zones. However, residential care facilities serving seven or more persons are limited to two zones with the approval of a conditional use permit (CUP). The element should analyze the process and exclusion from residential zones as a potential constraint on housing for persons with disabilities and add or modify programs as appropriate to ensure zoning permits group homes objectively with approval certainty.

5. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584. The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing. (Gov. Code, § 65583, subd. (a)(6).)

Developed Densities and Permit Times: The element must be revised to include analysis of requests to develop housing at densities below those anticipated in the sites inventory and the length of time between receiving approval for a housing development and submittal of an application for building permits. The analysis should address any potential hinderances on the construction of a locality’s share of the regional housing need. The element must also describe any efforts to mitigate non- governmental constraints that create a gap in the jurisdictions ability to meet RHNA by income category.

C. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. The program shall include an

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identification of the agencies and officials responsible for the implementation of the various actions. (Gov. Code, § 65583, subd. (c).)

To address the program requirements of Government Code section 65583, subdivision (c)(1-6), and to facilitate implementation, programs should include: (1) a description of the City’s specific role in implementation; (2) all programs must be revised with discrete timelines (i.e. month and year); (3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials. Programs to be revised include the following:

• Program 5-1 (Home Rehabilitation) should describe how information will be distributed and how often, as well as proactive outreach. • Program 5-2 (Code Enforcement) should describe how often the City will provide proactive outreach to the surrounding community.
• Program 5-3 (Residential Design Guidelines) should describe the requirements for exemption from discretionary reviews for affordable housing projects. • Program 5-5 (Preservation of Middle-Income Housing through New Housing Authorities) should indicate the program’s implementation status. It is currently unclear if the new housing authorities have been established. • Program 5-11 (Housing Density Bonus) should specify when the ordinance will be updated.
• Program 5-15 (Lot Consolidation Incentives) should include a timeframe for when the City will update their fee schedule and identify additional incentives, as well as the method and frequency of advertisement to developers. • Program 5-17 (Public Information About Affordable Housing) should provide information regarding how often outreach will occur and how often the brochure will be updated.
• Program 5-23 (Homeless Program Assistance) should include implementation timeframe and frequency.
• Numerous programs continue to indicate an “ongoing” implementation status.

While this may be appropriate for some programs, programs with quantified objectives or specific implementation actions must include completion or initiation dates (including month and year) resulting in beneficial impacts within the planning period. Programs needing revision include Programs 5.1, 5.2, 5.10, 5.11, 5.15,

5.16, 5.17. 5.19, and 5.21 through 5.24.

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).)

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As noted in Finding B3, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

Rezone Program for Adequate Sites: Currently the element demonstrates a shortfall of adequate sites with zoning currently in place to accommodate the RHNA within the planning period. In order to provide sufficient sites to accommodate the RHNA, programs including but not limited to 5-7 (Establish an Overlay to Permit Residential Uses in the Commercial General Zone), 5-8 (Expansion of the Downtown Mixed-Use Area to Permit Residential Uses), and 5-9 (Expand and Update the Residential Flex Mixed-Use overlay in the Live Oak Corridor) commit to, among other things, amend the zoning to increase densities and allow residential units in areas that previously did not allow residential development. However, in order to accommodate the lower-income need, programs must demonstrate compliance with Government Code section 65583.2, subdivisions (h) and (i).

Specifically, programs must commit to:

• permit owner-occupied and rental multifamily uses by-right for developments in which 20 percent or more of the units are affordable to lower-income households.

By-right means local government review must not require a CUP, planned unit development permit, or other discretionary review or approval. • accommodate a minimum of 16 units per site;
• require a minimum density of 20 units per acre; and
• 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.

Replacement Housing Requirements: While Program 5-16 (Preservation of Rental Opportunities) provides replacement housing in the City, the program must be revised to meet all statutory requirements. Nonvacant sites identified in the sites inventory with existing, vacated, or demolished residential uses and occupied by, or subject to an affordability requirement for, lower-income households within the last five years, require a replacement housing program for units affordable to lower-income households. (Gov. Code, § 65583.2, subd. (g)(3).) Absent a compliant replacement housing program, these sites are not adequate sites to accommodate lower-income households. The replacement housing program must adhere to the same requirements as set forth in Government Code section 65915, subdivision (c)(3).

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).)

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Program 5-22 (Affordable Housing for Families and Persons with Special Needs) should describe what land use policies will be adopted for extremely low-income households and offer specific commitments towards implementation other than “exploring” regulatory incentives. The program should include specific timeframes for implementing the incentives and revising the zoning code.

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 Finding(s) B4 and B5, the element requires a complete analysis of potential governmental and non-governmental 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.

5. P romote 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).) Program 5-25 (Fair Housing, 3rd bullet point): The percentage is missing for both.

Program to AFFH: While the element includes Program 5-25 (Fair Housing) which describes how the City responds to fair housing complaints, it must include more than collaboration for discrimination complaints, include specific timeframes for outreach and how often workshops will occur throughout the planning period, and include outreach. The element must also include actions that promote AFFH opportunities as stated in Finding B1. For example, the element could include a program committing to implement Government Code section 8899.50, subdivision (b) which requires the City to administer its programs and activities relating to housing and community development in a manner to AFFH and take no action that is materially inconsistent with its obligation to AFFH. Programs should address enhancing housing mobility strategies; encouraging development of new affordable housing in high resource areas; improving place-based strategies to encourage community conservation and revitalization, including preservation of existing affordable housing; and protecting existing residents from displacement. The programs should also include metrics and milestones for evaluating progress on programs, actions, and fair housing results.

6. The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other

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urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (Gov.

Code, § 65583, subd. (c)(6).)

Program 5-4 (Preservation of At-Risk Units) should incorporate state preservation notice law (Gov. Code § 65863.10, 65863.11, and 65863.13) as well as should commit to proactive outreach to property owners regarding interest in renewing affordability restrictions and inform them about the notice requirements.

7. Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate-income households. For purposes of this paragraph, “accessory dwelling units” has the same meaning as “accessory dwelling unit” as defined in paragraph (4) of subdivision (i) of Section 65852.2. (Gov. Code, § 65583, subd. (c)(7).)

The element is required to include a program that incentivizes or promotes ADU development for very low-, low-, and moderate-income households. This can take the form of flexible zoning requirements, development standards, or processing and fee incentives that facilitate the creation of ADUs, such as reduced parking requirements, fee waivers and more. Other strategies could include developing information packets to market ADU construction, targeted advertising of ADU development opportunities or establishing an ADU specialist within the planning department. Program 5-12 (ADU and JADU Incentive and Monitoring Program) should be revised to include specific incentives to encourage ADU production in the City during the planning period.

D. Public Participation

While the element includes a general summary of the public participation process (p. 13 and 1-4), it must also demonstrate diligent efforts were made to involve all economic segments of the community in the development of the housing element. The element could describe the efforts to circulate the housing element among low- and moderate- income households and organizations that represent them and to involve such groups and persons in the element throughout the process. In addition, the element should also summarize the public comments and describe how they were considered and incorporated into the element.

In addition, HCD understands the City made the element available to the public concurrent with its submittal to HCD. By not providing an opportunity for the public to review and comment on a draft of the element in advance of submission, the City has not yet complied with statutory mandates to make a diligent effort to encourage the public participation in the development of the element and it reduces HCD’s ability to consider public comments in its review. The availability of the document to the public and opportunity for public comment prior to submittal to HCD is essential to the public process

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and HCD’s review. The City must proactively make future revisions available to the public, including any commenters, prior to submitting any revisions to HCD and diligently consider and address comments, including revising the document where appropriate.

HCD’s future review will consider the extent to which the revised element documents how the City solicited, considered, and addressed public comments in the element. The City’s consideration of public comments must not be limited by HCD’s findings in this review letter.

City of Arcadia HCD Review Matrix Page 1
HCD Comments Notes
Revised Document
Section Reference
A. Review and Revision
Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).) As part of the evaluation of programs in the past cycle, the element must provide an explanation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations
(e.g., elderly, persons with disabilities, large households, female headed households, farmworkers, and persons experiencing homelessness).

Pg. 4-4 to 4-5

B. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] 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).) The element includes the Assessment of Fair Housing (AFH); however, additional information is necessary to address the requisite affirmatively furthering fair housing (AFFH) analysis requirement, including local contributing factors to the fair housing issues and develop strong programs and strategies to address the identified fair housing issues. Specifically, the element provides data regarding the patterns of various socio-economic characteristics across components of the required analysis (e.g., segregation and integration, racially and ethnically concentrated areas of poverty and affluence, access to opportunity, displacement); however, the element should also analyze trends for potential fair housing problems specific to Arcadia. In addition, the following analysis is required:

Table 3-12 - Compliance with
Fair Housing Laws
Pg. 3-49 to 3-51:

City of Arcadia HCD Review Matrix Page 2
HCD Comments Notes
Revised Document
Section Reference
should address:
• Degree of outreach to all sectors of the community.
• Ongoing outreach and public participation throughout the planning period.
• Indicate any findings, lawsuits or enforcement actions taken. • Describe how many fair housing complaints the City has received over the past few years.

Enforcement & Outreach; Fair
housing inquires and cases

Pg. 3-54: Countywide AFH
Outreach
2021-2029 Housing Element
Outreach added;
Refer to Appendix B:

Community Engagement
Summary for full outreach
efforts

Integration and Segregation: While the element includes some data on integration and segregation (p. 3-46), the element must include a local and regional analysis of patterns and trends. While the element utilizes the dissimilarity index to describe integr
ation and segregation on race,
the element should include local knowledge regarding racial segregation. Local knowledge or additional data sources are important because while the dissimilarity index measures integration in comparison to white residents, th
e majority of the City’s population are
Asian. Furthermore, the element should describe any local knowledge, a comparison of northern and southern blocks groups that demonstrated income disparities, and a regional analysis for income describing similar concentrations and trends of poverty in surrounding areas. The element must also analyze local and regional patterns and trends of segregation and integration based on familial status and persons with disabilities and conclude with a summary of issues.

Pg. 3-54 to 3-60
Added:

Predominant Racial and Ethnic
Groups

Low Income Community
Segregation
Familial Status
Disability Distribution
Summary of Segregation and
Integration Factors

Regional Analysis
Racial/Ethnic Concentrated Areas of Affluence (RCAA): While the element includes data relative to RCAA, it should also include an analysis Pg. 3-60 – 3-65
City of Arcadia HCD Review Matrix Page 3
HCD Comments Notes
Revised Document
Section Reference
of local and regional patterns and trends. Because the City as a whole is considered a “highest resource area” (p. 3-58), the analysis should emphasize the regional perspective, evaluating the patterns and changes over time and considering other relevant factors, such as public participation, past policies, practices, and investments and demographic trends.

Regional Analysis & RECAPS
over time added

Please refer to page 35 of the AFFH guidebook (link:
https://www.hcd.ca.gov/community-
development/affh/index.shtml#guidance) for specific factors that should be considered when analyzing access to opportunities as it pertains to educational, employment, environmental, transportation, and any factors that are unique to Arcadia.

Pg. 3-66 – 3-85
Added:

Table 3-14: Updated with
County Level Data
Access to Education
Opportunities
Employment Opportunities
Summary of Disparate Access
to Opportunity
Disproportionate Housing Needs including Displacement Risk: While the element includes some data on overcrowded households, cost burden, and displacement, it must also include data and analysis of substandard housing conditions and homelessness. Additionally, the element must provide a local and regional analysis for all disproportionate housing needs and analyze the data including looking at patterns, trends, other local knowledge, and conclude with a summary of fair housing issues.

Pg. 3-85 – 3-95
Table 3-26 & Table 3-27:

Extremely Low-Income Data
Table 3-20: Homelessness Data
Table 3-30: Substandard
Housing
City of Arcadia HCD Review Matrix Page 4
HCD Comments Notes
Revised Document
Section Reference
Goals, Priorities, Metrics, and Milestones: Goals and actions must significantly seek to overcome contributing factors to fair housing issues.

Currently, the element identifies Programs 5-25 (Fair Housing) and 5-26 (Fair Housing Assistance) to encourage and promote affordable housing; however, most of these programs do not appear to facilitate any meaningful change nor address AFFH requirements. Given that most of the City is considered a high resource community, the element could focus on programs that enhance housing mobility and encourage development of more housing choices and affordable housing. Programs also should be based on identified contributing factors, be significant and meaningful. The element must add, and revise programs based on a complete analysis and listing and prioritization of contributing factors to fair housing issues.

Furthermore, the element must include metrics and milestones for evaluating progress on programs, actions, and fair housing results. For more information, please see HCD’s guidance at
https://www.hcd.ca.gov/community
- development/affh/index.shtm.

Pg. 3-110 -- 3-111
List of programs pertaining to
each AFFH subtopic
Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).) While the element quantifies the existing housing needs of extremely low- income (ELI) households, it must still quantify projected ELI housing needs.

The projected housing need for ELI households can be calculated by using available census data to determine the number of very low-income households that qualify as ELI households or presume that 50 percent of very low-income households qualify as ELI households.

Pg. 3-90 to 3-91
Tables 3-26 and 3-27

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 City of Arcadia HCD Review Matrix Page 5
need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
The City has a regional housing need allocation (RHNA) of 3,214 housing units, of which 1,672 are for lower-income households. To address this need, the element relies on vacant and nonvacant sites, including sites in Specific Plan Areas and within the Mixed-Use Overlay areas. To demonstrate the adequacy of these sites and strategies to accommodate the City’s RHNA, the element must include complete analyses:

Arcadia Golf Course: On page A-25, the element indicated that the City owns the Arcadia Par 3 Golf Course and is currently exploring potential future sale of the property and/or redevelopment of the site and has spoken with developers regarding the development of affordable housing on the site. The element must address current and potential general plan designations,
allowable densities,
support for residential capacity assumptions, existing uses and any known conditions that preclude development in the planning period and the potential schedule for development. As the zoning does not currently allow residential uses at appropriate densities, then the element must include programs to rezone sites pursuant to Government Code section 65583.2, subdivisions (h) and (i). In addition, the element must include a description of whether there are any plans to sell the property d
uring the planning period and
how the jurisdiction will comply with the Surplus Land Act Article 8 (commencing with Section 54220) of Chapter 5 of Part 1 of Division 2 of Title 5.

Pg. A-29
Realistic Capacity: The element states that it assumes an 80 percent buildout to determine capacity based on buildable acreage. However, the analysis must also support this estimate based on typical densities of existing or approved residential developments at a similar affordability level. In addition, while the element provided some overlay and mixed-use development examples to support the 80 percent buildout assumption, the Pg. A-35: Capacity
Calculations
Pg. A-12: Downtown
Mixed-Use
Pg. A-16: Mixed Use
City of Arcadia HCD Review Matrix Page 6
element must indicate whether the calculations included density bonus units.

The element must also consider the calculation for sites that allow nonresidential uses (e.g., mixed-use) based on the likelihood of nonresidential development, performance standards, development trends supporting residential development, and any existing or planned policies, programs, or local guidance or efforts promoting residential development in nonresidential zones. The element must clarify whether 100 percent residential is allowed in commercial and mixed-use zones as well as whether residential uses are allowed by- right in the Downtown Mixed-Use expansion and overlay; the Mixed- Use upzone; and the CG overlay. In addition, on page A-17, the element indicated that with the implementation of the overlay, 100 percent residential would be allowed by-right in the Live Oak Corridor except in Las Tunas. The element should analyze the impact of this standard on the City’s realistic capacity and revise the calculation as necessary.

Suitability of Nonvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites.

To address this requirement, the element describes in general the existing use of each nonvacant site for example “multifamily housing” or religious structure”. In addition, small
nonvacant sites
descriptions are limited to “Small Sites Strategy,” which is not adequate to demonstrate the potential for redevelopment in the planning period. The element should describe the existing use and the existing units on all sites in the invento
ry. The description of
existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period. In addition, the element should analyze the extent that existing uses may impede a
dditional residential development.

For example, the element can summarize past experiences Pg. A-5 – A-9
Table A-3: Example
Development of
Non-Vacant Sites for
Residential Uses
City of Arcadia HCD Review Matrix Page 7
converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. The element could also conside
r indicators such as age and condition of the existing
structure, expressed developer interest, low improvement to land value ratio, and other factors. Many identified sites have existing multifamily housing or townhouses, given the fact that the element e
stimates a low number of units needing substantial rehabilitation, the element must identify the likelihood that the existing use will be terminated during the planning period.

In addition, if the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households, the housing element must demonstrate that the existing use is not an impediment to additional residential development in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) This can be demonstrated by providing substantial evidence that the existing use is likely to be discontinued during the planning period. (Gov. Code, § 65583.2, subd. (g)(2).)
Small Sites: The inventory lists 441 lower-income units on smaller sites. Sites smaller than a half-acre in size are deemed inadequate to accommodate housing for lower- income housing unless it is demonstrated that sites of equivalent size and affordability were successfully developed during the prior planning period or unless the element describes other evidence to HCD that the site is adequate to accommodate lower- income housing. (Gov. Code, § 65583.2, subd. (c)(2)(A).) While the element includes examples of small site development; it does not relate these examples to the affordability Pg. A-31 – A-34
Tables A-18 through
A-20
City of Arcadia HCD Review Matrix Page 8
of these projects. To strengthen the existing analysis, the history of small site development example should describe trends specific to the development of housing affordable to lower-income households.

Addressed in overall
sites inventory
Accessory Dwelling Units (ADU): The element assumes an ADU build out of 26 ADU and/or junior accessory dwelling unit (JADU) per year based upon doubling the average assumption over the past few years. Given that the City has only produced an average of 12 units per year since 2018, it is not clear if this production level will be achievable in the planning period. As a result, the element should be updated to include a realistic estimate of the potential for ADUs and include policies and programs that incentivize the production of ADUs. Depending on the analysis, the element must commit to monitor ADU production throughout the course of the planning period and implement additional actions if not meeting target numbers anticipated in the housing element. In addition to monitoring production, this program should also monitor affordability. Additional actions, if necessary, should be taken in a timely manner (e.g., within six months). Finally, if necessary, the degree of additional actions should be in stride with the degree of the gap in production and affordability.

Pg. A-9 – A-11
Tables A-4 through
A-6
City of Arcadia HCD Review Matrix Page 9
Environmental Constraints: While the element describes
environmental conditions within the City (p. 3-40), it must describe any mitigation measures being taken to address those constraints within the City that could impact housing development in the planning period. (Gov. Code, § 65583.2, subd. (b).)
Pg. 3-46
Mitigating
Environmental
Constraints Section
added

Zoning for a Variety of Housing Types:
• Emergency Shelters: While the element states that emergency shelters are permitted in the M-1 industrial zone, it must clarify whether emergency shelters are allowed as a
permitted use without a conditional use or other
discretionary permit. The identified zone(s) must demonstrate the M-1 zone has sufficient capacity to accommodate the identified need for shelters or for at least one emergency shelter, whichever is greater. (Gov. Code, § 65583, subd. (a)(4).) The housing element must also demonstrate the
permit processing, development, and management standards for emergency shelters are objective and encourage and
facilitate the development of, or conversion to, emergency shelters. In addition, emergency shelters must only be subject to the same development and management standards
applicable to residential or commercial development within the same zone except for those standards prescribed by
statute.
• Transitional and Supportive Housing: Transitional and supportive housing require a use permit in zones where single family homes are permitted by right. Transitional housing and supportive housing must be permitted as a residential use in all zones allowing residential uses and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd.

Pg. 3-28
Emergency Housing
SROs
Employee Housing
Manufactured
Homes
Pg. 3-29
Transitional and
Supportive Housing
Program 5-24 Added
to address above
Program 5-36 added
to address
manufactured
homes and
mobilehomes

City of Arcadia HCD Review Matrix Page 10
(a)(5).) The element must describe and analyze the City’s transitional and supportive housing standards and codes and demonstrate consistency with Gov. Code Section 65583(a)(5) or add or revise programs which comply with the statutory requirements. Finally, the City’s definition of supportive housing should be analyzed for consistency with state law and revised as necessary.
• Single Room Occupancy (SRO): Page 3-27 provides the
definition of an SRO but does not state where they are
allowed. The element must describe where SROs are allowed or add a program as appropriate to update the zoning code and permit to allow the development of SROs.
• Employee Housing: The element states that employee housing is permitted in the special use zone. In addition, the element must demonstrate zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.),
specifically, sections 17021.5 and 17021.6. Section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone.

Section 17021.6 requires employee housing consisting of no more than 12 units or 36 beds to be permitted in the same manner as other agricultural uses in the same zone.
• Mobilehomes: Page 3-27 states that mobilehomes are not permitted as long- term housing. The housing element must demonstrate the jurisdiction's zoning code allows and permits manufactured housing in the same manner and in the same zone as a conventional or stick-built structures are permitted (Gov. Code Section 65852.3). Specifically, manufactured homes should only be subject to the same development
City of Arcadia HCD Review Matrix Page 11
standards that a conventional single-family residential dwelling on the same lot would be subject to, with the
exception of, architectural requirements for roof overhang, roofing material, and siding material. (Gov. Code Section 65852.3(a).)
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 ide ntified 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.

Land Use Controls: The element must identify and analyze all relevant land-use controls impacts as potential constraints on a variety of housing types (e.g., multifamily rental housing, mobilehomes, transitional housing). The analysis must also evaluate the cumulative impacts of land use controls on the cost and supply of housing, including the ability to achieve maximum densities and cost and supply of housing. The
analysis should also describe past or current efforts to remove identified governmental constraints. The element must address the following:

•• Pages 3-10 and 3-11 describe the same minimum and
maximum densities in the CBD, MU, and DMU zones, for
example the CBD lists a minimum density of 80 dwelling
units and acre and a maximum of 80 dwelling units an acre.

Although the City indicated that the intent of this was to create diversity in building appearance (made possible by differing height regulations per zone), having the same minimum and maximum density in a zone is a constraint
because it provides no flexibility in development. The
element must analyze this as a constraint and add a
program to address the density requirement.

Table 3-2: There are
no minimum
densities in the CBD,
MU and DMU zones
allowing for
flexibility in
development.

Pg. 3-12: See *Note.

Three stories are
allowed in the R-3
Zone without a use
permit

Pg. 3-13: No
minimum
requirement on unit
sizes, document
updated

City of Arcadia HCD Review Matrix Page 12
•• As part of HCD’s call with the City, staff indicated that three stories were allowed in the R3 zone despite a maximum
building height of 30 feet, but Table 3-2 (p. 3-12 and 3-13) does not provide information beyond two stories. The
element should clarify if three stories are allowed in the R3 zone without a use permit. If not, the City must add a
program to amend its development standards to be
consistent with state law.
•• The element should list and analyze minimum unit sizes.

Parking Requirements: The element must analyze the
requirement of two covered parking spaces per multifamily dwelling unit for its impact as a potential constraint on housing development (p. 3-14). Should the analysis determine the parking standards or permit procedures are a constraint on residential development, it must include a program to address or remove any identified constraints.

Pg. 3-15
Constraint Identified
Program 5-35
Program to address
parking standard
constraint
Fees and Exaction: While the element lists development fees on (p. 3-33), it must indicate if all fees are the same for single and multifamily. The element must also analyze their impact as potential constraints on housing supply and affordability and describe the City’s efforts to mitigate the constraint. For example, the analysis could identify the total amount of fees and their proportion to the development costs for both single family and multifamily housing. Page 3-33 of the element indicated that the City would explore opportunities to lower development fees for affordable developments but did not describe how it would do this, the element should be revised to include a program to address fees.

Table 3-9:

Development
Impact Fees
Specification of
multi vs single family
Program 5-35
Fees were not
established as a
constraint, however
the City will commit
to monitoring fees
over time to ensure
they do not become
a constraint.

City of Arcadia HCD Review Matrix Page 13
Processing and Permit Procedures: While the element
describes the use permit procedure for mixed-use housing, it must describe and analyze the City’s permit processing and approval procedures by zone and housing type (e.g.,
multifamily rental housing, mobilehomes, housing for agricultural employees, supportive housing). The analysis must evaluate the processing and permit procedures’ impacts as potential constraints on housing supply and affordability. For example, the analysis should consider processing and approval
procedures and time for typical single- and multi- family developments, including type of permit, level of review, approval findings and any discretionary approval procedures.

The element states that a minor use permit is required for multifamily developments in mixed-use and CBD zones. The element should describe any impacts on sites in the inventory.

If so, this should be analyzed as a constraint and addressed in a program.

Pg. 3-39: Language
added to narrative.

Not identified as
constraint.

Design Review: The element must describe and analyze the site plan and design review guidelines and processes,
including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and
guidelines improve development certainty and mitigate cost impacts. The element must demonstrate this process is not a constraint or it must include a program to address this permitting requirement, as appropriate.

Pg. 3-40: Language
added to narrative.

Not identified as
constraint.

Local Ordinances: The element must specifically analyze locally adopted ordinances such as inclusionary ordinance or short-term rental ordinance that directly impact the cost and supply of residential development. The analysis should
demonstrate local efforts to remove governmental constraints Pg. 3-29
Short Term Rental
Ordinance
City of Arcadia HCD Review Matrix Page 14
that hinder the locality from meeting its share of the regional housing need and from meeting the need for housing for
persons with disabilities, supportive housing, transitional housing, and emergency shelters.

Pg. 3-37: Additional
Building Codes
No other local
ordinances

On/Off-Site Improvements: The element must identify
subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width) and analyze their impact as potential constraints on housing supply and affordability.

Pg. 3-36: language
added, not
identified as
constraint

Codes and Enforcement: The element must describe the City’s building and zoning code enforcement processes and
procedures, including any local amendments to the building code, and analyze their impact as potential constraints on housing supply and affordability.

Pg. 3-37: language
added, not
identified as
constraint

Constraints on Housing for Persons with Disabilities: While the element describes the City’s Reasonable Accommodation
procedure on page 3-27, it must analyze the findings as a constraint for persons with disabilities including the associated fees, the application process, and findings. In addition, the element lists the U.S. Census Bureau and California’s Office of Planning and Research definition of family, but the element must include the City’s definition of family.

In addition, the element currently details that residential care facilities serving six or fewer persons are permitted in all residential zones. However, residential care facilities serving seven or more persons are limited to two zones with the approval of a conditional use permit (CUP). The element should analyze the process and exclusion from residential zones as a potential constraint on housing for persons with disabilities and add or modify programs as appropriate to ensure zoning
Pg. 3-29 – 3-30
Program 5-34 to
address constraint
City of Arcadia HCD Review Matrix Page 15
permits group homes objectively with approval certainty.

An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584. The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing. (Gov. Code, § 65583, subd. (a)(6).) Developed Densities and Permit Times: The element must be revised to include analysis of requests to develop housing at densities below those anticipated in the sites inventory and the length of time between receiving approval for a housing development and submittal of an application for building permits. The analysis should address any potential hinderances on the construction of a locality’s share of the regional housing need. The element must also describe any efforts to mitigate non- governmental constraints that create a gap in the jurisdictions ability to meet RHNA by income category.

Pg. 3-38: Permit
times
Pg. 3-39 to 3-40
Design Review
Process Added;
From development
history, very few
developments come
in below max.
densities. See
development history
of nonvacant sites in
Appendix A

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 state financing and subsidy programs when available. The program shall include an identification of the agencies and officials responsible for the implementation of the various actions. (Gov. Code, § 65583, subd. (c).) To address the program requirements of Government Code section 65583, subdivision (c)(1-6), and to facilitate implementation, programs should include: (1) a description of the City’s specific role in implementation; (2) all programs must be revised with discrete timelines (i.e.

City of Arcadia HCD Review Matrix Page 16
month and year); (3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials. Programs to be revised include the following:

Program 5-1 (Home Rehabilitation) should describe how
information will be distributed and how often, as well as proactive outreach.

Pg. 10-1
Program 5-2 (Code Enforcement) should describe how often the City will provide proactive outreach to the surrounding community.

Pg. 10-2
Program 5-3 (Residential Design Guidelines) should describe the requirements for exemption from discretionary reviews for affordable housing projects.

Pg. 10-2 – 10-3
Program 5-5 (Preservation of Middle-Income Housing through New Housing Authorities) should indicate the program’s implementation status. It is currently unclear if the new housing authorities have been established.

Pg. 10-3 – 10-4
Program 5-11 (Housing Density Bonus) should specify when the ordinance will be updated.

Pg. 10-11 – 10-12
Program 5-16
Program 5-15 (Lot Consolidation Incentives) should include a timeframe for when the City will update their fee schedule and identify additional incentives, as well as the method and frequency of advertisement to developers.

Pg. 10-14 – 10-15
Program 5-20
Program 5-17 (Public Information About Affordable Housing) should provide information regarding how often outreach will occur and how often the brochure will be updated.

Pg. 10-16
Program 5-23
Program 5-23 (Homeless Program Assistance) should include implementation timeframe and frequency.

Pg. 10-20
Program 5-29
Numerous programs continue to indicate an “ongoing”
implementation status. While this may be appropriate for some programs, programs with quantified objectives or specific All Chapter 10
City of Arcadia HCD Review Matrix Page 17
implementation actions must include completion or initiation dates (including month and year) resulting in beneficial impacts within the planning period. Programs needing revision include Programs 5.1,

5.2, 5.10, 5.11, 5.15, 5.16, 5.17. 5.19, and 5.21 through 5.24.

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 B3, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

Rezone Program for Adequate Sites: Currently the element demonstrates a shortfall of adequate sites with zoning currently in place to accommodate the RHNA within the planning period. In order to provide sufficient sites to accommodate the RHNA, programs including but not limited to 5-7 (Establish an Overlay to Permit Residential Uses in the Commercial General Zone), 5-8 (Expansion of the Downtown Mixed-Use Area to Permit
Residential Uses), and 5-9 (Expand and Update the Residential Flex Mixed-Use overlay in the Live Oak Corridor) commit to, among other things, amend the zoning to increase densities and allow residential units in areas that previously did not allow residential development. However, in order to accommodate the lower-income need, programs must demonstrate compliance with Government Code section 65583.2, subdivisions (h) and (i).

Specifically, programs must commit to:
• permit owner-occupied and rental multifamily uses by-right for developments in which 20 percent or more of the units are Pg. 10-4 – 10-10
Program 5-7 through
5-13
City of Arcadia HCD Review Matrix Page 18
affordable to lower-income households. By-right means local government review must not require a CUP, planned unit
development permit, or other discretionary review or approval. • accommodate a minimum of 16 units per site;
• require a minimum density of 20 units per acre; and
• 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.

Replacement Housing Requirements: While Program 5-16
(Preservation of Rental Opportunities) provides replacement housing in the City, the program must be revised to meet all statutory requirements. Nonvacant sites identified in the sites inventory with existing, vacated, or demolished residential uses and occupied by, or subject to an affordability requirement for, lower-income households within the last five years, require a replacement housing program for units affordable to lower-income households. (Gov. Code, § 65583.2, subd. (g)(3).) Absent a compliant replacement housing program, these sites are not adequate sites to accommodate lower-income households. The replacement housing program must adhere to the same requirements as set forth in Government Code section 65915, subdivision (c)(3).

Pg. 10-15
Program 5-21
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).) Program 5-22 (Affordable Housing for Families and Persons with Special Needs) should describe what land use policies will be adopted for extremely low-income households and offer specific Pg. 10-18
Program 5-28
City of Arcadia HCD Review Matrix Page 19
commitments towards implementation other than “exploring” regulatory incentives. The program should include specific timeframes for implementing the incentives and revising the zoning code.

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 Finding(s) B4 and B5, the element requires a complete analysis of potential governmental and non-
governmental 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.

Pg. 10-24
Program 5-35
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).) Program 5-25 (Fair Housing, 3rd bullet point): The percentage is missing for both.

Pg. 10-20 – 10-22
Program 5-31
City of Arcadia HCD Review Matrix Page 20
Programs should address enhancing housing mobility strategies; encouraging development of new affordable housing in high resource areas; improving place-based strategies to encourage community conservation and revitalization, including preservation of existing affordable housing; and protecting existing residents from displacement. The programs should also include metrics and milestones for evaluating progress on programs, actions, and fair housing results.

The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (Gov. Code, § 65583, subd. (c)(6).)
Program 5-4 (Preservation of At-Risk Units) should incorporate state preservation notice law (Gov. Code § 65863.10, 65863.11, and 65863.13) as well as should commit to proactive outreach to property owners regarding interest in renewing affordability restrictions and inform them about the notice requirements.

Pg. 10-3
Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate-income households. For purposes of this paragraph, “accessory dwelling units” has the same meaning as “accessory dwelling unit” as defined in paragraph (4) of subdivision (i) of Section 65852.2. (Gov. Code, § 65583, subd. (c)(7).)
The element is required to include a program that incentivizes or promotes ADU development for very low-, low-, and moderate- income households. This can take the form of flexible zoning requirements, development standards, or processing and fee incentives that facilitate the creation of ADUs, such as reduced parking requirements, fee waivers and more. Other strategies could include developing information packets to market ADU construction, targeted advertising of ADU development opportunities or Pg. 10-12 – 10-13
Program 5-17
City of Arcadia HCD Review Matrix Page 21
establishing an ADU specialist within the planning department.

Program 5-12 (ADU and JADU Incentive and Monitoring Program) should be revised to include specific incentives to encourage ADU production in the City during the planning period.

Public Participation

Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the housing element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(8).) While the element includes a general summary of the public participation process (p. 13 and 1-4), it must also demonstrate diligent efforts were made to involve all economic segments of the community in the development of the housing element. The element could describ
e the efforts to circulate the housing element among
low- and moderate- income households and organizations that represent them and to involve such groups and persons in the element throughout the process. In addition, the element should also summarize the
public comments and describe how they were
considered and incorporated into the element.

Appendix B:

Community
Engagement
Summary

City of Arcadia HCD Review Matrix Page 22
including revising the document where appropriate. HCD’s future review will consider the extent to which the revised element documents how the City solicited, considered, and addressed public comments in the element. The City’s consideration of public comments must not be limited by HCD’s findings in this review letter.

Attachment No. 4

Attachment No.4
Comment letters from the public
From: Mike Veerman
To: Mailbox - Planning
Subject: Arcadia Housing Element - Written comment - from Mike Veerman Date: Monday, January 24, 2022 8:22:43 PM
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

To the Arcadia Planning Commission:

My wife and 3 children have been living in Arcadia for 20 years. Our kids have grown up in Arcadia, and benefitted greatly here, from community actives, and very much from attending Arcadia High School. We are grateful.

We bought our house here in Arcadia when it was relatively affordable. It was still on the high side of the market bar in 2001. However, "affordable" is no longer how to describe homes in Arcadia. Our kids cannot afford it. I would be surprised if many of very our city workers from all sides of the city can afford living here in Arcadia.

Wouldn't that be great to live and work in the same city? That reduces traffic, and climate change as well. There are so many benefits of affordable housing
I very glad to hear the city has targeted some areas of our city for growth and increased density: around the Gold Line station, First Avenue north of Durate, and down here by Live Oak, near my home. I'm also glad to hear that the city wants an aggressive plan to reach our RHNA quota, especially on the very low, and low income levels. We currently are at 26 affordable units in our residential development pipeline. That good, but nowhere near our combined 1,672 quota for Very Low and Low income. We have to find ways to get those units built, and at a faster rate. I urge the city to be aggressive.

The city can do something to make this change. I suggest we create an Inclusionary Zoning Ordinance to direct developers on what the city requires. If you are not already aware, Pasadena has a 20% inclusionary zoning ordinance. That means, 20% of all dwelling units in residential developers need to be for these Very Low, Low and Moderate income levels. This has helped Pasadena increase their RHNA counts dramatically. Pasadena does not need to do this development itself. Development has not stopped, but continues. Pasadena has reached this 20% inclusionary zoning ordinance level over time. I suggest Arcadia do the same: phase in these changes over time.

Again, "aggressive" characterizes the rate of change here.

I suggest the city adopt this aggressive inclusionary ordinance. This way developers can plan, and decide to move forward when it makes sense for them.
a) In Year 2023, the Arcadia Inclusionary zoning ordinance is 10% Affordable Housing of all units build, or pay $X in lieu fee.
b) In Year 2024, the Arcadia Inclusionary zoning ordinance is 15% Affordable Housing of all units build. or pay $X multiplied by 1.5 in lieu fee.
c) In Year 2026, the Arcadia Inclusionary zoning ordinance is 20% Affordable Housing of all units build. Or pay $X multiplied by 2 in lieu fee.

The in lieu fee is calculated using the fee schedule set by City Council. If developers do not create affordable housing the in lieu fee creates funds for Arcadia to build them.

We want to have our Housing Element be certified the the California Department of Housing and Community Development (HCD), showing we have made a realistic, good faith effort to reach our RHNA quotas. I think this aggressive inclusionary zoning ordinance to end at 20% at Year 2026 will help.

Thank you for your work, and your consideration of this proposal.

Respectfully,
--Mike Veerman
2533 South Second Avenue
5HFHLYHG
Arcadia, CA 91006
P: (626) 381-9248
F: (626) 389-5414
E: [email protected]
Mitchell M. Tsai
Attorney At Law
139 South Hudson Avenue
Suite 200
Pasadena, California 91101

VIA E-MAIL
January 25, 2022
Development Services Department
City of Arcadia
240 West Huntington Dr.

Arcadia, CA 91066
Em: [email protected]
Rachelle Arellano, Deputy City Clerk
City of Arcadia
240 West Huntington Dr.

Arcadia, CA 91066
Em: [email protected]
RE: City of Arcadia’s 6th Cycle Housing Element Update.

Dear Rachelle Arellano,
On behalf of the Southwest Regional Council of Carpenters (“Southwest Carpenter” or “SWRCC”), my Office is submitting these comments for the City of Arcadia’s (“City”) January 25th, 2022 Planning Commission Meeting for its draft 2021-2029 update to the City’s General Plan Housing Element (“Project”).

The Southwest Carpenters is a labor union representing 50,000 union carpenters in six states, including California, and has a strong interest in well ordered land use planning and addressing the environmental impacts of development projects.

Individual members of the Southwest Carpenters live, work and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts.

SWRCC expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearings and proceedings related to this Project. Cal. Gov. Code § 65009(b); Cal. Pub. Res. Code § 21177(a); Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121. 5HFHLYHG
City of Arcadia – 6th Cycle Housing Element Update
January 25, 2022

Page 2 of 5 ends

SWRCC incorporates by reference all comments raising issues regarding the EIR submitted prior to certification of the EIR for the Project. Citizens for Clean Energy v City of Woodland (2014) 225 Cal. App. 4th 173, 191 (finding that any party who has objected to the Project’s environmental documentation may assert any issue timely raised by other parties).

Moreover, SWRCC requests that the City provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (“CEQA”), Cal Public Resources Code (“PRC”) § 21000 et seq, and the California Planning and Zoning Law (“Planning and Zoning Law”), Cal. Gov’t Code §§ 65000–65010. California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body.

The City should require the use of a local skilled and trained workforce to benefit the community’s economic development and environment. The City should require the use of workers who have graduated from a Joint Labor Management apprenticeship training program approved by the State of California, or have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a state approved apprenticeship training program or who are registered apprentices in an apprenticeship training program approved by the State of California.

Community benefits such as local hire and skilled and trained workforce requirements can also be helpful to reduce environmental impacts and improve the positive economic impact of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing localized economic benefits. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:
[A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

City of Arcadia – 6th Cycle Housing Element Update
January 25, 2022

Page 3 of 5 ends

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling.

Skilled and trained workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the UC Berkeley Center for Labor Research and Education concluded:
. . . labor should be considered an investment rather than a cost – and investments in growing, diversifying, and upskilling California’s workforce can positively affect returns on climate mitigation efforts. In other words, well trained workers are key to de livering emissions reductions and moving California closer to its climate targets.
1 Local skilled and trained workforce requirements and policies have significant environmental benefits since they improve an area’s jobs-housing balance, decreasing the amount of and length of job commutes and their associated greenhouse gas emissions. Recently, on May 7, 2021, the South Coast Air Quality Management District found that that the “[u]se of a local state-certified apprenticeship program or a skilled and trained workforce with a local hire component” can result in air pollutant reductions.
2 Cities are increasingly adopting local skilled and trained workforce policies and requirements into general plans and municipal codes. For example, the City of Hayward 2040 General Plan requires the City to “promote local hiring . . . to help achieve a more positive jobs-housing balance, and reduce regional commuting, gas consumption, and greenhouse gas emissions.”3

1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https://laborcenter.berkeley.edu/ wp-content/uploads/2020/09/Putting-California-on-the-High-Road.pdf. 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http://www.aqmd.gov/docs/default- source/Agendas/Governing-Board/2021/2021-May7-027.pdf?sfvrsn=10 3 City of Hayward (2014) Hayward 2040 General Plan Policy Document at p. 3-99, available at https://www.hayward-ca.gov/sites/default/files/documents/General_Plan_FINAL.pdf.

City of Arcadia – 6th Cycle Housing Element Update
January 25, 2022

Page 4 of 5 ends

In fact, the City of Hayward has gone as far as to adopt a Skilled Labor Force policy into its Downtown Specific Plan and municipal code, requiring developments in its Downtown area to requiring that the City “[c]ontribute to the stabilization of regional construction markets by spurring applicants of housing and nonresidential developments to require contractors to utilize apprentices from state-approved, joint labor-management training programs, . . .”4 In addition, the City of Hayward requires all projects 30,000 square feet or larger to “utilize apprentices from state-approved, joint labor-management training programs.”5
Locating jobs closer to residential areas can have significant environmental benefits. .

As the California Planning Roundtable noted in 2008:

People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.6
In addition, local hire mandates as well as skill training are critical facets of a strategy to reduce vehicle miles traveled. As planning experts Robert Cervero and Michael Duncan noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions since the skill requirements of available local jobs must be matched to those held by local residents.7 Some municipalities have tied local hire and skilled and trained workforce policies to local development permits to address transportation issues. As Cervero and Duncan note:

In nearly built-out Berkeley, CA, th e approach to balancing jobs and housing is to create local jobs rather than to develop new housing.” The city’s First Source program encourages businesses to hire local residents,

4 City of Hayward (2019) Hayward Downtown Specific Plan at p. 5-24, available at https://www.hayward-ca.gov/sites/default/files/Hayward%20Downtown% 20Specific%20Plan.pdf.
5 City of Hayward Municipal Code, Chapter 10, § 28.5.3.020(C). 6 California Planning Roundtable (2008) Deconstructing Jobs-Housing Balance at p. 6, available at https://cproundtable.org/static/media/uploads/publications/cpr-jobs- housing.pdf
7 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: Jobs- Housing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT- 825.pdf.

City of Arcadia – 6th Cycle Housing Element Update
January 25, 2022

Page 5 of 5 ends

especially for entry- and intermediat e-level jobs, and sponsors vocational training to ensure residents are em ployment-ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs si nce it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.

The City should consider utilizing skilled and trained workforce policies and requirements to benefit the local area economically and mitigate greenhouse gas, air quality and transportation impacts.

Sincerely,
______________________
Mitchell M. Tsai
Attorneys for Southwest Regional
Council of Carpenters
Attached:

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); and Air Quality and GHG Expert Matt Hagemann CV (Exhibit C). y,
_______________________
tchell M. Tsai
torneys for Southwest Region
uncil of Carpenters

EXHIBIT A

1 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
March 8, 2021

Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101

Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling Dear Mr. Tsai,
Soil Water Air Protection Enterprise (“SWAPE”) is pleased to provide the following draft technical report explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of greenhouse gas (“GHG”) emissions. The report will also discuss the potential for local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.

The California Emissions Estimator Model (“CalEEMod”) is a “statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects.”1 CalEEMod quantifies construction-related emissions associated with land use projects resulting from off-road construction equipment; on-road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on-road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving.2
The number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.3

1 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 2 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 3 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34.

2 Specifically, the number and length of vehicle trips is utilized to estimate the vehicle miles travelled (“VMT”) associated with construction. Then, utilizing vehicle-class specific EMFAC 2014 emission factors, CalEEMod calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction-related VMT, including personal vehicles for worker commuting.4
Specifically, in order to calculate VMT, CalEEMod multiplies the average daily trip rate by the average overall trip length (see excerpt below):
“VMTd = Σ(Average Daily Trip Rate i * Average Overall Trip Length i) n Where:
n = Number of land uses being modeled.”5
Furthermore, to calculate the on-road emissions associated with worker trips, CalEEMod utilizes the following equation (see excerpt below):
“Emissionspollutant = VMT * EFrunning,pollutant
Where:

Emissionspollutant = emissions from vehicle running for each pollutant VMT = vehicle miles traveled
EFrunning,pollutant = emission factor for running emissions.”6 Thus, there is a direct relationship between trip length and VMT, as well as a direct relationship between VMT and vehicle running emissions. In other words, when the trip length is increased, the VMT and vehicle running emissions increase as a result. Thus, vehicle running emissions can be reduced by decreasing the average overall trip length, by way of a local hire requirement or otherwise.

As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.7 In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CalEEMod default worker trip parameters. CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project- specific values, but the California Environmental Quality Act (“CEQA”) requires that such changes be justified by substantial evidence.8 The default number of construction-related worker trips is calculated by multiplying the

4 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14-15. 5 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 23. 6 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 7 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 8 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 1, 9.

3 number of pieces of equipment for all phases by 1.25, with the exception of worker trips required for the building construction and architectural coating phases.9 Furthermore, the worker trip vehicle class is a 50/25/25 percent mix of light duty autos, light duty truck class 1 and light duty truck class 2, respectively.”10 Finally, the default worker trip length is consistent with the length of the operational home-to-work vehicle trips.11 The operational home-to-work vehicle trip lengths are:
“[B]ased on the location and urbanization selected on the project characteristic screen. These values were supplied by the air districts or use a default average for the state. Each district (or county) also assigns trip lengths for urban and rural settings” (emphasis added). 12 Thus, the default worker trip length is based on the location and urbanization level selected by the User when modeling emissions. The below table shows the CalEEMod default rural and urban worker trip lengths by air basin (see excerpt below and Attachment A).13
Worker Trip Length by Air Basin
Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Minimum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90

9 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 10 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 11 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14. 12 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 21. 13 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-84 – D-86.

4 As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8- to 19.8- miles, with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8- to 14.7- miles, with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban worker trip lengths tend to be shorter in length. Based on these trends evident in the CalEEMod default worker trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent upon the urbanization of the project site, as well as the project location.

To provide an example of the potential impact of a local hire provision on construction-related GHG emissions, we estimated the significance of a local hire provision for the Village South Specific Plan (“Project”) located in the City of Claremont (“City”). The Project proposed to construct 1,000 residential units, 100,000-SF of retail space, 45,000-SF of office space, as well as a 50-room hotel, on the 24-acre site. The Project location is classified as Urban and lies within the Los Angeles-South Coast County. As a result, the Project has a default worker trip length of 14.7 miles.
14 In an effort to evaluate the potential for a local hire provision to reduce the Project’s construction-related GHG emissions, we prepared an updated model, reducing all worker trip lengths to 10 miles (see Attachment B). Our analysis estimates that if a local hire provision with a 10-mile radius were to be implemented, the GHG emissions associated with Project construction would decrease by approximately 17% (see table below and Attachment C).

Local Hire Provision Net Change
Without Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,623
Amortized Construction GHG Emissions (MT CO2e/year) 120.77 With Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,024
Amortized Construction GHG Emissions (MT CO2e/year) 100.80 % Decrease in Construction-related GHG Emissions 17%
As demonstrated above, by implementing a local hire provision requiring 10 mile worker trip lengths, the Project could reduce potential GHG emissions associated with construction worker trips. More broadly, any local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

This serves as an example of the potential impacts of local hire requirements on estimated project-level GHG emissions, though it does not indicate that local hire requirements would result in reduced construction-related GHG emission for all projects. As previously described, the significance of a local hire requirement depends on the worker trip length enforced and the default worker trip length for the project’s urbanization level and location.

14 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85.

5

SWAPE has received limited discovery. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,

Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.

Location Type Location Name Rural H-W
(miles)
Urban H-W
(miles)
Air Basin Great Basin 16.8 10.8
Air Basin Lake County 16.8 10.8
Air Basin Lake Tahoe 16.8 10.8
Air Basin Mojave Desert 16.8 10.8
Air Basin Mountain 16.8 10.8
Air Basin North Central 17.1 12.3
Air Basin North Coast 16.8 10.8
Air Basin Northeast 16.8 10.8
Air Basin Sacramento 16.8 10.8
Air Basin Salton Sea 14.6 11
Air Basin San Diego 16.8 10.8
Air Basin San Francisco 10.8 10.8
Air Basin San Joaquin 16.8 10.8
Air Basin South Central 16.8 10.8
Air Basin South Coast 19.8 14.7
Air District Amador County 16.8 10.8
Air District Antelope Valley 16.8 10.8
Air District Bay Area AQMD 10.8 10.8
Air District Butte County 12.54 12.54
Air District Calaveras 16.8 10.8
Air District Colusa County 16.8 10.8
Air District El Dorado 16.8 10.8
Air District Feather River 16.8 10.8
Air District Glenn County 16.8 10.8
Air District Great Basin 16.8 10.8
Air District Imperial County 10.2 7.3
Air District Kern County 16.8 10.8
Air District Lake County 16.8 10.8
Air District Lassen County 16.8 10.8
Air District Mariposa 16.8 10.8
Air District Mendocino 16.8 10.8
Air District Modoc County 16.8 10.8
Air District Mojave Desert 16.8 10.8
Air District Monterey Bay 16.8 10.8
Air District North Coast 16.8 10.8
Air District Northern Sierra 16.8 10.8
Air District Northern 16.8 10.8
Air District Placer County 16.8 10.8
Air District Sacramento 15 10
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Air District San Diego 16.8 10.8
Air District San Joaquin 16.8 10.8
Air District San Luis Obispo 13 13
Air District Santa Barbara 8.3 8.3
Air District Shasta County 16.8 10.8
Air District Siskiyou County 16.8 10.8
Air District South Coast 19.8 14.7
Air District Tehama County 16.8 10.8
Air District Tuolumne 16.8 10.8
Air District Ventura County 16.8 10.8
Air District Yolo/Solano 15 10
County Alameda 10.8 10.8
County Alpine 16.8 10.8
County Amador 16.8 10.8
County Butte 12.54 12.54
County Calaveras 16.8 10.8
County Colusa 16.8 10.8
County Contra Costa 10.8 10.8
County Del Norte 16.8 10.8
County El Dorado-Lake 16.8 10.8
County El Dorado- 16.8 10.8
County Fresno 16.8 10.8
County Glenn 16.8 10.8
County Humboldt 16.8 10.8
County Imperial 10.2 7.3
County Inyo 16.8 10.8
County Kern-Mojave 16.8 10.8
County Kern-San 16.8 10.8
County Kings 16.8 10.8
County Lake 16.8 10.8
County Lassen 16.8 10.8
County Los Angeles- 16.8 10.8
County Los Angeles- 19.8 14.7
County Madera 16.8 10.8
County Marin 10.8 10.8
County Mariposa 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Merced 16.8 10.8
County Modoc 16.8 10.8
County Mono 16.8 10.8
County Monterey 16.8 10.8
County Napa 10.8 10.8

County Nevada 16.8 10.8
County Orange 19.8 14.7
County Placer-Lake 16.8 10.8
County Placer-Mountain 16.8 10.8
County Placer- 16.8 10.8
County Plumas 16.8 10.8
County Riverside- 16.8 10.8
County Riverside- 19.8 14.7
County Riverside-Salton 14.6 11
County Riverside-South 19.8 14.7
County Sacramento 15 10
County San Benito 16.8 10.8
County San Bernardino- 16.8 10.8
County San Bernardino- 19.8 14.7
County San Diego 16.8 10.8
County San Francisco 10.8 10.8
County San Joaquin 16.8 10.8
County San Luis Obispo 13 13
County San Mateo 10.8 10.8
County Santa Barbara- 8.3 8.3
County Santa Barbara- 8.3 8.3
County Santa Clara 10.8 10.8
County Santa Cruz 16.8 10.8
County Shasta 16.8 10.8
County Sierra 16.8 10.8
County Siskiyou 16.8 10.8
County Solano- 15 10
County Solano-San 16.8 10.8
County Sonoma-North 16.8 10.8
County Sonoma-San 10.8 10.8
County Stanislaus 16.8 10.8
County Sutter 16.8 10.8
County Tehama 16.8 10.8
County Trinity 16.8 10.8
County Tulare 16.8 10.8
County Tuolumne 16.8 10.8
County Ventura 16.8 10.8
County Yolo 15 10
County Yuba 16.8 10.8
Statewide Statewide 16.8 10.8

Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Mininum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
Worker Trip Length by Air Basin

1.1 Land Usage
Land Uses Size Metric Lot Acreage Floor Surface Area Population General Office Building 45.00 1000sqft 1.03 45,000.00 0 High Turnover (Sit Down Restaurant) 36.00 1000sqft 0.83 36,000.00 0 Hotel 50.00 Room 1.67 72,600.00 0
Quality Restaurant 8.00 1000sqft 0.18 8,000.00 0
Apartments Low Rise 25.00 Dwelling Unit 1.56 25,000.00 72 Apartments Mid Rise 975.00 Dwelling Unit 25.66 975,000.00 2789 Regional Shopping Center 56.00 1000sqft 1.29 56,000.00 0

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
9 Wind Speed (m/s) Precipitation Freq (Days)2.2 33

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2028Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)

0.006N2O Intensity
(lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles-South Coast County, Annual
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 1 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual Attachment B
Project Characteristics - Consistent with the DEIR's model.

Land Use - See SWAPE comment regarding residential and retail land uses.

Construction Phase - See SWAPE comment regarding individual construction phase lengths.

Demolition - Consistent with the DEIR's model. See SWAPE comment regarding demolition.

Vehicle Trips - Saturday trips consistent with the DEIR's model. See SWAPE comment regarding weekday and Sunday trips.

Woodstoves - Woodstoves and wood-burning fireplaces consistent with the DEIR's model. See SWAPE comment regarding gas fireplaces.

Energy Use -
Construction Off-road Equipment Mitigation - See SWAPE comment on construction-related mitigation.

Area Mitigation - See SWAPE comment regarding operational mitigation measures.

Water Mitigation - See SWAPE comment regarding operational mitigation measures.

Table Name Column Name Default Value New Value
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces FireplaceWoodMass 1,019.20 0.00
tblFireplaces NumberWood 1.25 0.00
tblFireplaces NumberWood 48.75 0.00
tblVehicleTrips ST_TR 7.16 6.17
tblVehicleTrips ST_TR 6.39 3.87
tblVehicleTrips ST_TR 2.46 1.39
tblVehicleTrips ST_TR 158.37 79.82
tblVehicleTrips ST_TR 8.19 3.75
tblVehicleTrips ST_TR 94.36 63.99
tblVehicleTrips ST_TR 49.97 10.74
tblVehicleTrips SU_TR 6.07 6.16
tblVehicleTrips SU_TR 5.86 4.18
tblVehicleTrips SU_TR 1.05 0.69
tblVehicleTrips SU_TR 131.84 78.27
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 2 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

2.0 Emissions Summary
tblVehicleTrips SU_TR 5.95 3.20
tblVehicleTrips SU_TR 72.16 57.65
tblVehicleTrips SU_TR 25.24 6.39
tblVehicleTrips WD_TR 6.59 5.83
tblVehicleTrips WD_TR 6.65 4.13
tblVehicleTrips WD_TR 11.03 6.41
tblVehicleTrips WD_TR 127.15 65.80
tblVehicleTrips WD_TR 8.17 3.84
tblVehicleTrips WD_TR 89.95 62.64
tblVehicleTrips WD_TR 42.70 9.43
tblWoodstoves NumberCatalytic 1.25 0.00
tblWoodstoves NumberCatalytic 48.75 0.00
tblWoodstoves NumberNoncatalytic 1.25 0.00
tblWoodstoves NumberNoncatalytic 48.75 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveDayYear 25.00 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
tblWoodstoves WoodstoveWoodMass 999.60 0.00
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 3 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

2.1 Overall Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Year tons/yr MT/yr
2021 0.1713 1.8242 1.1662 2.4000e-
003

0.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213.1969 213.1969 0.0601 0.0000 214.6993 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 6 1,721.682
6 0.1294 0.0000 1,724.918
7 2023 0.6148 3.3649 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627.529 5 1,627.529
5 0.1185 0.0000 1,630.492
5 2024 4.1619 0.1335 0.2810 5.9000e-
004

0.0325 6.4700e-
003

0.0390 8.6300e-
003

6.0400e-
003

0.0147 0.0000 52.9078 52.9078 8.0200e-
003

0.0000 53.1082
Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 6 1,721.682
6 0.1294 0.0000 1,724.918
7 Unmitigated Construction
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 4 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

0.4169 0.0817 0.4986 0.1795 0.0754 0.2549 0.0000 213.1967 213.1967 0.0601 0.0000 214.6991 2022 0.6904 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 3 1,721.682
3 0.1294 0.0000 1,724.918
3 2023 0.6148 3.3648 5.6747 0.0178 1.1963 0.0996 1.2959 0.3203 0.0935 0.4138 0.0000 1,627.529 1 1,627.529
1 0.1185 0.0000 1,630.492
1 2024 4.1619 0.1335 0.2810 5.9000e-
004

0.0325 6.4700e-
003

0.0390 8.6300e-
003

6.0400e-
003

0.0147 0.0000 52.9077 52.9077 8.0200e-
003

0.0000 53.1082
Maximum 4.1619 4.1142 6.1625 0.0189 1.3058 0.1201 1.4259 0.3460 0.1128 0.4588 0.0000 1,721.682 3 1,721.682
3 0.1294 0.0000 1,724.918
3 Mitigated Construction
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 Quarter Start Date End Date Maximum Unmitigated ROG + NOX (tons/quarter) Maximum Mitigated ROG + NOX (tons/quarter) 1 9-1-2021 11-30-2021 1.4103 1.4103
2 12-1-2021 2-28-2022 1.3613 1.3613
3 3-1-2022 5-31-2022 1.1985 1.1985
4 6-1-2022 8-31-2022 1.1921 1.1921
5 9-1-2022 11-30-2022 1.1918 1.1918
6 12-1-2022 2-28-2023 1.0774 1.0774
7 3-1-2023 5-31-2023 1.0320 1.0320
8 6-1-2023 8-31-2023 1.0260 1.0260
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 5 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

2.2 Overall Operational
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Area 5.1437 0.2950 10.3804 1.6700e-
003

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835
Energy 0.1398 1.2312 0.7770 7.6200e-
003

0.0966 0.0966 0.0966 0.0966 0.0000 3,896.073
2 3,896.073
2 0.1303 0.0468 3,913.283
3 Mobile 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 Waste 0.0000 0.0000 0.0000 0.0000 207.8079 0.0000 207.8079 12.2811 0.0000 514.8354 Water 0.0000 0.0000 0.0000 0.0000 29.1632 556.6420 585.8052 3.0183 0.0755 683.7567 Total 6.8692 9.5223 30.3407 0.0914 7.7979 0.2260 8.0240 2.0895 0.2219 2.3114 236.9712 12,294.18 07 12,531.15
19 15.7904 0.1260 12,963.47
51 Unmitigated Operational
9 9-1-2023 11-30-2023 1.0265 1.0265
10 12-1-2023 2-29-2024 2.8857 2.8857
11 3-1-2024 5-31-2024 1.6207 1.6207
Highest 2.8857 2.8857
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 6 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835
Energy 0.1398 1.2312 0.7770 7.6200e-
003

3.0 Construction Detail
Construction Phase
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio-CO2 Total CO2 CH4 N20 CO2e
Percent
Reduction

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 7 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual Phase
Number
Phase Name Phase Type Start Date End Date Num Days
Week
Num Days Phase Description
1 Demolition Demolition 9/1/2021 10/12/2021 5 30
2 Site Preparation Site Preparation 10/13/2021 11/9/2021 5 20 3 Grading Grading 11/10/2021 1/11/2022 5 45
4 Building Construction Building Construction 1/12/2022 12/12/2023 5 500 5 Paving Paving 12/13/2023 1/30/2024 5 35
6 Architectural Coating Architectural Coating 1/31/2024 3/19/2024 5 35 OffRoad Equipment
Residential Indoor: 2,025,000; Residential Outdoor: 675,000; Non-Residential Indoor: 326,400; Non-Residential Outdoor: 108,800; Striped Parking Area: 0 (Architectural Coating – sqft)
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 112.5
Acres of Paving: 0
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 8 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual Phase Name Offroad Equipment Type Amount Usage Hours Horse Power Load Factor Demolition Concrete/Industrial Saws 1 8.00 81 0.73
Demolition Excavators 3 8.00 158 0.38
Demolition Rubber Tired Dozers 2 8.00 247 0.40
Site Preparation Rubber Tired Dozers 3 8.00 247 0.40
Site Preparation Tractors/Loaders/Backhoes 4 8.00 97 0.37 Grading Excavators 2 8.00 158 0.38
Grading Graders 1 8.00 187 0.41
Grading Rubber Tired Dozers 1 8.00 247 0.40
Grading Scrapers 2 8.00 367 0.48
Grading Tractors/Loaders/Backhoes 2 8.00 97 0.37
Building Construction Cranes 1 7.00 231 0.29
Building Construction Forklifts 3 8.00 89 0.20
Building Construction Generator Sets 1 8.00 84 0.74
Building Construction Tractors/Loaders/Backhoes 3 7.00 97 0.37 Building Construction Welders 1 8.00 46 0.45
Paving Pavers 2 8.00 130 0.42
Paving Paving Equipment 2 8.00 132 0.36
Paving Rollers 2 8.00 80 0.38
Architectural Coating
Air Compressors 1 6.00 78 0.48
Trips and VMT
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 9 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e-
003

0.0000 7.5100e-
003

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0475 0.4716 0.3235 5.8000e-
004

0.0233 0.0233 0.0216 0.0216 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 Total 0.0475 0.4716 0.3235 5.8000e-
004

0.0496 0.0233 0.0729 7.5100e-
003

0.0216 0.0291 0.0000 51.0012 51.0012 0.0144 0.0000 51.3601 Unmitigated Construction On-Site

3.1 Mitigation Measures Construction
Phase Name Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6 15.00 0.00 458.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Site Preparation 7 18.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Grading 8 20.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Building Construction 9 801.00 143.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Paving 6 15.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT Architectural Coating 1 160.00 0.00 0.00 14.70 6.90 20.00 LD_Mix HDT_Mix HHDT CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 10 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

3.2 Demolition - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 1.9300e-
003

0.0634 0.0148 1.8000e-
004

3.9400e-
003

1.9000e-
004

4.1300e-
003

1.0800e-
003

1.8000e-
004

1.2600e-
003

0.0000 17.4566 17.4566 1.2100e-
003

0.0000 17.4869
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 9.7000e-
004

7.5000e-
004

8.5100e-
003

2.0000e-
005

2.4700e-
003

2.0000e-
005

2.4900e-
003

6.5000e-
004

2.0000e-
005

6.7000e-
004

0.0000 2.2251 2.2251 7.0000e-
005

0.0000 2.2267
Total 2.9000e-
003

0.0641 0.0233 2.0000e-
004

6.4100e-
003

2.1000e-
004

6.6200e-
003

1.7300e-
003

2.0000e-
004

1.9300e-
003

0.0000 19.6816 19.6816 1.2800e-
003

0.0000 19.7136
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0496 0.0000 0.0496 7.5100e-
003

0.0000 7.5100e-
003

0.0000 0.0000 0.0000 0.0000 0.0000 0.0000
Off-Road 0.0475 0.4716 0.3235 5.8000e-
004

0.0233 0.0233 0.0216 0.0216 0.0000 51.0011 51.0011 0.0144 0.0000 51.3600 Total 0.0475 0.4716 0.3235 5.8000e-
004

0.0496 0.0233 0.0729 7.5100e-
003

0.0216 0.0291 0.0000 51.0011 51.0011 0.0144 0.0000 51.3600 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 11 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

0.0634 0.0148 1.8000e-
004

3.9400e-
003

1.9000e-
004

4.1300e-
003

1.0800e-
003

1.8000e-
004

1.2600e-
003

0.0000 17.4566 17.4566 1.2100e-
003

0.0000 17.4869
Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 9.7000e-
004

7.5000e-
004

8.5100e-
003

2.0000e-
005

2.4700e-
003

2.0000e-
005

2.4900e-
003

6.5000e-
004

2.0000e-
005

6.7000e-
004

0.0000 2.2251 2.2251 7.0000e-
005

0.0000 2.2267
Total 2.9000e-
003

0.0641 0.0233 2.0000e-
004

6.4100e-
003

2.1000e-
004

6.6200e-
003

1.7300e-
003

2.0000e-
004

1.9300e-
003

0.0000 19.6816 19.6816 1.2800e-
003

0.0000 19.7136
Mitigated Construction Off-Site

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1807 0.0000 0.1807 0.0993 0.0000 0.0993 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0389 0.4050 0.2115 3.8000e-
004

0.0204 0.0204 0.0188 0.0188 0.0000 33.4357 33.4357 0.0108 0.0000 33.7061 Total 0.0389 0.4050 0.2115 3.8000e-
004

0.1807 0.0204 0.2011 0.0993 0.0188 0.1181 0.0000 33.4357 33.4357 0.0108 0.0000 33.7061 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 12 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 7.7000e-
004

6.0000e-
004

6.8100e-
003

2.0000e-
005

1.9700e-
003

2.0000e-
005

1.9900e-
003

5.2000e-
004

1.0000e-
005

5.4000e-
004

0.0000 1.7801 1.7801 5.0000e-
005

0.0000 1.7814
Total 7.7000e-
004

6.0000e-
004

6.8100e-
003

2.0000e-
005

1.9700e-
003

2.0000e-
005

1.9900e-
003

5.2000e-
004

1.0000e-
005

5.4000e-
004

0.0000 1.7801 1.7801 5.0000e-
005

0.0000 1.7814
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1807 0.0000 0.1807 0.0993 0.0000 0.0993 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0389 0.4050 0.2115 3.8000e-
004

0.0204 0.0204 0.0188 0.0188 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Total 0.0389 0.4050 0.2115 3.8000e-
004

0.1807 0.0204 0.2011 0.0993 0.0188 0.1181 0.0000 33.4357 33.4357 0.0108 0.0000 33.7060 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 13 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

3.3 Site Preparation - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 7.7000e-
004

6.0000e-
004

6.8100e-
003

2.0000e-
005

1.9700e-
003

2.0000e-
005

1.9900e-
003

5.2000e-
004

1.0000e-
005

5.4000e-
004

0.0000 1.7801 1.7801 5.0000e-
005

0.0000 1.7814
Total 7.7000e-
004

6.0000e-
004

6.8100e-
003

2.0000e-
005

1.9700e-
003

2.0000e-
005

1.9900e-
003

5.2000e-
004

1.0000e-
005

5.4000e-
004

0.0000 1.7801 1.7801 5.0000e-
005

0.0000 1.7814
Mitigated Construction Off-Site

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0796 0.8816 0.5867 1.1800e-
003

0.0377 0.0377 0.0347 0.0347 0.0000 103.5405 103.5405 0.0335 0.0000 104.3776 Total 0.0796 0.8816 0.5867 1.1800e-
003

0.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103.5405 103.5405 0.0335 0.0000 104.3776 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 14 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

3.4 Grading - 2021
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 1.6400e-
003

1.2700e-
003

0.0144 4.0000e-
005

4.1600e-
003

3.0000e-
005

4.2000e-
003

1.1100e-
003

3.0000e-
005

1.1400e-
003

0.0000 3.7579 3.7579 1.1000e-
004

0.0000 3.7607
Total 1.6400e-
003

1.2700e-
003

0.0144 4.0000e-
005

4.1600e-
003

3.0000e-
005

4.2000e-
003

1.1100e-
003

3.0000e-
005

1.1400e-
003

0.0000 3.7579 3.7579 1.1000e-
004

0.0000 3.7607
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.1741 0.0000 0.1741 0.0693 0.0000 0.0693 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0796 0.8816 0.5867 1.1800e-
003

0.0377 0.0377 0.0347 0.0347 0.0000 103.5403 103.5403 0.0335 0.0000 104.3775 Total 0.0796 0.8816 0.5867 1.1800e-
003

0.1741 0.0377 0.2118 0.0693 0.0347 0.1040 0.0000 103.5403 103.5403 0.0335 0.0000 104.3775 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 15 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

1.2700e-
003

0.0144 4.0000e-
005

4.1600e-
003

3.0000e-
005

4.2000e-
003

1.1100e-
003

3.0000e-
005

1.1400e-
003

0.0000 3.7579 3.7579 1.1000e-
004

0.0000 3.7607
Total 1.6400e-
003

1.2700e-
003

0.0144 4.0000e-
005

4.1600e-
003

3.0000e-
005

4.2000e-
003

1.1100e-
003

3.0000e-
005

1.1400e-
003

0.0000 3.7579 3.7579 1.1000e-
004

0.0000 3.7607
Mitigated Construction Off-Site

3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0127 0.1360 0.1017 2.2000e-
004

5.7200e-
003

5.2600e-
003

0.0000 19.0871 19.0871 6.1700e-
003

0.0000 19.2414
Total 0.0127 0.1360 0.1017 2.2000e-
004

0.0807 5.7200e-
003

0.0865 0.0180 5.2600e-
003

0.0233 0.0000 19.0871 19.0871 6.1700e-
003

0.0000 19.2414
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 16 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

3.4 Grading - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 2.8000e-
004

2.1000e-
004

2.4400e-
003

1.0000e-
005

7.7000e-
004

1.0000e-
005

7.7000e-
004

2.0000e-
004

1.0000e-
005

2.1000e-
004

0.0000 0.6679 0.6679 2.0000e-
005

0.0000 0.6684
Total 2.8000e-
004

2.1000e-
004

2.4400e-
003

1.0000e-
005

7.7000e-
004

1.0000e-
005

7.7000e-
004

2.0000e-
004

1.0000e-
005

2.1000e-
004

0.0000 0.6679 0.6679 2.0000e-
005

0.0000 0.6684
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Fugitive Dust 0.0807 0.0000 0.0807 0.0180 0.0000 0.0180 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 0.0127 0.1360 0.1017 2.2000e-
004

5.7200e-
003

5.2600e-
003

0.0000 19.0871 19.0871 6.1700e-
003

0.0000 19.2414
Total 0.0127 0.1360 0.1017 2.2000e-
004

0.0807 5.7200e-
003

0.0865 0.0180 5.2600e-
003

0.0233 0.0000 19.0871 19.0871 6.1700e-
003

0.0000 19.2414
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 17 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

2.1000e-
004

2.4400e-
003

1.0000e-
005

7.7000e-
004

1.0000e-
005

7.7000e-
004

2.0000e-
004

1.0000e-
005

2.1000e-
004

0.0000 0.6679 0.6679 2.0000e-
005

0.0000 0.6684
Total 2.8000e-
004

2.1000e-
004

2.4400e-
003

1.0000e-
005

7.7000e-
004

1.0000e-
005

7.7000e-
004

2.0000e-
004

1.0000e-
005

2.1000e-
004

0.0000 0.6679 0.6679 2.0000e-
005

0.0000 0.6684
Mitigated Construction Off-Site

0.1023 0.1023 0.0963 0.0963 0.0000 293.1324 293.1324 0.0702 0.0000 294.8881 Total 0.2158 1.9754 2.0700 3.4100e-
003

0.1023 0.1023 0.0963 0.0963 0.0000 293.1324 293.1324 0.0702 0.0000 294.8881 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 18 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

3.5 Building Construction - 2022
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0527 1.6961 0.4580 4.5500e-
003

0.1140 3.1800e-
003

0.1171 0.0329 3.0400e-
003

0.0359 0.0000 441.9835 441.9835 0.0264 0.0000 442.6435
Worker 0.4088 0.3066 3.5305 0.0107 1.1103 8.8700e-
003

1.1192 0.2949 8.1700e-
003

0.3031 0.0000 966.8117 966.8117 0.0266 0.0000 967.4773
Total 0.4616 2.0027 3.9885 0.0152 1.2243 0.0121 1.2363 0.3278 0.0112 0.3390 0.0000 1,408.795 2 1,408.795
2 0.0530 0.0000 1,410.120
8 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.2158 1.9754 2.0700 3.4100e-
003

0.1023 0.1023 0.0963 0.0963 0.0000 293.1321 293.1321 0.0702 0.0000 294.8877 Total 0.2158 1.9754 2.0700 3.4100e-
003

0.1023 0.1023 0.0963 0.0963 0.0000 293.1321 293.1321 0.0702 0.0000 294.8877 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 19 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

0.1140 3.1800e-
003

0.1171 0.0329 3.0400e-
003

0.0359 0.0000 441.9835 441.9835 0.0264 0.0000 442.6435
Worker 0.4088 0.3066 3.5305 0.0107 1.1103 8.8700e-
003

1.1192 0.2949 8.1700e-
003

0.0864 0.0864 0.0813 0.0813 0.0000 286.2789 286.2789 0.0681 0.0000 287.9814 Total 0.1942 1.7765 2.0061 3.3300e-
003

0.0864 0.0864 0.0813 0.0813 0.0000 286.2789 286.2789 0.0681 0.0000 287.9814 Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 20 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

3.5 Building Construction - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0382 1.2511 0.4011 4.3000e-
003

0.1113 1.4600e-
003

0.1127 0.0321 1.4000e-
003

0.0335 0.0000 417.9930 417.9930 0.0228 0.0000 418.5624
Worker 0.3753 0.2708 3.1696 0.0101 1.0840 8.4100e-
003

1.0924 0.2879 7.7400e-
003

0.2957 0.0000 909.3439 909.3439 0.0234 0.0000 909.9291
Total 0.4135 1.5218 3.5707 0.0144 1.1953 9.8700e-
003

1.2051 0.3200 9.1400e-
003

0.3292 0.0000 1,327.336
9 1,327.336
9 0.0462 0.0000 1,328.491
6 Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.1942 1.7765 2.0061 3.3300e-
003

0.0864 0.0864 0.0813 0.0813 0.0000 286.2785 286.2785 0.0681 0.0000 287.9811 Total 0.1942 1.7765 2.0061 3.3300e-
003

0.0864 0.0864 0.0813 0.0813 0.0000 286.2785 286.2785 0.0681 0.0000 287.9811 Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 21 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

0.1113 1.4600e-
003

0.1127 0.0321 1.4000e-
003

0.0335 0.0000 417.9930 417.9930 0.0228 0.0000 418.5624
Worker 0.3753 0.2708 3.1696 0.0101 1.0840 8.4100e-
003

1.0924 0.2879 7.7400e-
003

0.2957 0.0000 909.3439 909.3439 0.0234 0.0000 909.9291
Total 0.4135 1.5218 3.5707 0.0144 1.1953 9.8700e-
003

1.2051 0.3200 9.1400e-
003

0.3292 0.0000 1,327.336
9 1,327.336
9 0.0462 0.0000 1,328.491
6 Mitigated Construction Off-Site

3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 6.7100e-
003

0.0663 0.0948 1.5000e-
004

3.3200e-
003

3.0500e-
003

0.0000 13.0175 13.0175 4.2100e-
003

0.0000 13.1227
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e-
003

0.0663 0.0948 1.5000e-
004

3.3200e-
003

3.0500e-
003

0.0000 13.0175 13.0175 4.2100e-
003

0.0000 13.1227
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 22 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

3.6 Paving - 2023
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 3.7000e-
004

2.7000e-
004

3.1200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0800e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.8963 0.8963 2.0000e-
005

0.0000 0.8968
Total 3.7000e-
004

2.7000e-
004

3.1200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0800e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.8963 0.8963 2.0000e-
005

0.0000 0.8968
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 6.7100e-
003

0.0663 0.0948 1.5000e-
004

3.3200e-
003

3.0500e-
003

0.0000 13.0175 13.0175 4.2100e-
003

0.0000 13.1227
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 6.7100e-
003

0.0663 0.0948 1.5000e-
004

3.3200e-
003

3.0500e-
003

0.0000 13.0175 13.0175 4.2100e-
003

0.0000 13.1227
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 23 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

2.7000e-
004

3.1200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0800e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.8963 0.8963 2.0000e-
005

0.0000 0.8968
Total 3.7000e-
004

2.7000e-
004

3.1200e-
003

1.0000e-
005

1.0700e-
003

1.0000e-
005

1.0800e-
003

2.8000e-
004

1.0000e-
005

2.9000e-
004

0.0000 0.8963 0.8963 2.0000e-
005

0.0000 0.8968
Mitigated Construction Off-Site

3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0109 0.1048 0.1609 2.5000e-
004

5.1500e-
003

4.7400e-
003

0.0000 22.0292 22.0292 7.1200e-
003

0.0000 22.2073
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e-
004

5.1500e-
003

4.7400e-
003

0.0000 22.0292 22.0292 7.1200e-
003

0.0000 22.2073
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 24 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

3.6 Paving - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 5.9000e-
004

4.1000e-
004

4.9200e-
003

2.0000e-
005

1.8100e-
003

1.0000e-
005

1.8200e-
003

4.8000e-
004

1.0000e-
005

4.9000e-
004

0.0000 1.4697 1.4697 4.0000e-
005

0.0000 1.4706
Total 5.9000e-
004

4.1000e-
004

4.9200e-
003

2.0000e-
005

1.8100e-
003

1.0000e-
005

1.8200e-
003

4.8000e-
004

1.0000e-
005

4.9000e-
004

0.0000 1.4697 1.4697 4.0000e-
005

0.0000 1.4706
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Off-Road 0.0109 0.1048 0.1609 2.5000e-
004

5.1500e-
003

4.7400e-
003

0.0000 22.0292 22.0292 7.1200e-
003

0.0000 22.2073
Paving 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Total 0.0109 0.1048 0.1609 2.5000e-
004

5.1500e-
003

4.7400e-
003

0.0000 22.0292 22.0292 7.1200e-
003

0.0000 22.2073
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 25 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

4.1000e-
004

4.9200e-
003

2.0000e-
005

1.8100e-
003

1.0000e-
005

1.8200e-
003

4.8000e-
004

1.0000e-
005

4.9000e-
004

0.0000 1.4697 1.4697 4.0000e-
005

0.0000 1.4706
Total 5.9000e-
004

4.1000e-
004

4.9200e-
003

2.0000e-
005

1.8100e-
003

1.0000e-
005

1.8200e-
003

4.8000e-
004

1.0000e-
005

4.9000e-
004

0.0000 1.4697 1.4697 4.0000e-
005

0.0000 1.4706
Mitigated Construction Off-Site

0.0213 0.0317 5.0000e-
005

1.0700e-
003

0.0000 4.4682 4.4682 2.5000e-
004

0.0000 4.4745
Total 4.1404 0.0213 0.0317 5.0000e-
005

1.0700e-
003

0.0000 4.4682 4.4682 2.5000e-
004

0.0000 4.4745
Unmitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 26 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

3.7 Architectural Coating - 2024
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Hauling 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Vendor 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Worker 0.0101 6.9900e-
003

0.0835 2.8000e-
004

0.0307 2.3000e-
004

0.0309 8.1500e-
003

2.2000e-
004

8.3700e-
003

0.0000 24.9407 24.9407 6.1000e-
004

0.0000 24.9558
Total 0.0101 6.9900e-
003

0.0835 2.8000e-
004

0.0307 2.3000e-
004

0.0309 8.1500e-
003

2.2000e-
004

8.3700e-
003

0.0000 24.9407 24.9407 6.1000e-
004

0.0000 24.9558
Unmitigated Construction Off-Site
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Archit. Coating 4.1372 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Off-Road 3.1600e-
003

0.0213 0.0317 5.0000e-
005

1.0700e-
003

0.0000 4.4682 4.4682 2.5000e-
004

0.0000 4.4745
Total 4.1404 0.0213 0.0317 5.0000e-
005

1.0700e-
003

0.0000 4.4682 4.4682 2.5000e-
004

0.0000 4.4745
Mitigated Construction On-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 27 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

4.0 Operational Detail - Mobile

4.1 Mitigation Measures Mobile

0.0835 2.8000e-
004

0.0307 2.3000e-
004

0.0309 8.1500e-
003

2.2000e-
004

8.3700e-
003

0.0000 24.9407 24.9407 6.1000e-
004

0.0000 24.9558
Total 0.0101 6.9900e-
003

0.0835 2.8000e-
004

0.0307 2.3000e-
004

0.0309 8.1500e-
003

2.2000e-
004

8.3700e-
003

0.0000 24.9407 24.9407 6.1000e-
004

0.0000 24.9558
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 28 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 Unmitigated 1.5857 7.9962 19.1834 0.0821 7.7979 0.0580 7.8559 2.0895 0.0539 2.1434 0.0000 7,620.498 6 7,620.498
6 0.3407 0.0000 7,629.016
2 4.2 Trip Summary Information

4.3 Trip Type Information
Average Daily Trip Rate Unmitigated Mitigated
Land Use Weekday Saturday Sunday Annual VMT Annual VMT
Apartments Low Rise 145.75 154.25 154.00 506,227 506,227 Apartments Mid Rise 4,026.75 3,773.25 4075.50 13,660,065 13,660,065 General Office Building 288.45 62.55 31.05 706,812 706,812 High Turnover (Sit Down Restaurant) 2,368.80 2,873.52 2817.72 3,413,937 3,413,937 Hotel 192.00 187.50 160.00 445,703 445,703
Quality Restaurant 501.12 511.92 461.20 707,488 707,488 Regional Shopping Center 528.08 601.44 357.84 1,112,221 1,112,221 Total 8,050.95 8,164.43 8,057.31 20,552,452 20,552,452
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 29 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual Miles Trip % Trip Purpose %
Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW Primary Diverted Pass-by Apartments Low Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 Apartments Mid Rise 14.70 5.90 8.70 40.20 19.20 40.60 86 11 3 General Office Building 16.60 8.40 6.90 33.00 48.00 19.00 77 19 4 High Turnover (Sit Down
Rt t )

16.60 8.40 6.90 8.50 72.50 19.00 37 20 43
Hotel 16.60 8.40 6.90 19.40 61.60 19.00 58 38 4
Quality Restaurant 16.60 8.40 6.90 12.00 69.00 19.00 38 18 44 Regional Shopping Center 16.60 8.40 6.90 16.30 64.70 19.00 54 35 11

5.0 Energy Detail

5.1 Mitigation Measures Energy

4.4 Fleet Mix
Land Use LDA LDT1 LDT2 MDV LHD1 LHD2 MHD HHD OBUS UBUS MCY SBUS MH Apartments Low Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Apartments Mid Rise 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 General Office Building 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 High Turnover (Sit Down
Restaurant)

0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Hotel 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Quality Restaurant 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.000821 Regional Shopping Center 0.543088 0.044216 0.209971 0.116369 0.014033 0.006332 0.021166 0.033577 0.002613 0.001817 0.005285 0.000712 0.00082 1 Historical Energy Use: N
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 30 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Electricity
Mitigated

0.0000 0.0000 0.0000 0.0000 0.0000 2,512.646
5 2,512.646
5 0.1037 0.0215 2,521.635
6 Electricity
Unmitigated

0.0000 0.0000 0.0000 0.0000 0.0000 2,512.646
5 2,512.646
5 0.1037 0.0215 2,521.635
6 NaturalGas
Mitigated

0.1398 1.2312 0.7770 7.6200e-
003

0.0966 0.0966 0.0966 0.0966 0.0000 1,383.426
7 1,383.426
7 0.0265 0.0254 1,391.647
8 NaturalGas
Unmitigated

0.1398 1.2312 0.7770 7.6200e-
003

0.0966 0.0966 0.0966 0.0966 0.0000 1,383.426
7 1,383.426
7 0.0265 0.0254 1,391.647
8 CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 31 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

5.2 Energy by Land Use - NaturalGas
NaturalGa
s Use
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Land Use kBTU/yr tons/yr MT/yr
Apartments Low
Rise
408494 2.2000e-
003

0.0188 8.0100e-
003

1.2000e-
004

1.5200e-
003

0.0000 21.7988 21.7988 4.2000e-
004

4.0000e-
004

21.9284
Apartments Mid
Rise

1.30613e
+007

0.0704 0.6018 0.2561 3.8400e-
003

0.0487 0.0487 0.0487 0.0487 0.0000 696.9989 696.9989 0.0134 0.0128 701.1408 General Office
Building
468450 2.5300e-
003

0.0230 0.0193 1.4000e-
004

1.7500e-
003

0.0000 24.9983 24.9983 4.8000e-
004

4.6000e-
004

25.1468
High Turnover (Sit
Down Restaurant)

8.30736e
+006

0.0448 0.4072 0.3421 2.4400e-
003

0.0310 0.0310 0.0310 0.0310 0.0000 443.3124 443.3124 8.5000e- 003

8.1300e-
003
445.9468
Hotel 1.74095e
+006

9.3900e-
003

0.0853 0.0717 5.1000e-
004

6.4900e-
003

0.0000 92.9036 92.9036 1.7800e-
003

1.7000e-
003

93.4557
Quality
Restaurant

1.84608e
+006

9.9500e-
003

0.0905 0.0760 5.4000e-
004

6.8800e-
003

0.0000 98.5139 98.5139 1.8900e-
003

1.8100e-
003

99.0993
Regional
Shopping Center
91840 5.0000e-
004

4.5000e-
003

3.7800e-
003

3.0000e-
005

3.4000e-
004

0.0000 4.9009 4.9009 9.0000e-
005

9.0000e-
005

4.9301
Total 0.1398 1.2312 0.7770 7.6200e-
003

0.0966 0.0966 0.0966 0.0966 0.0000 1,383.426
8 1,383.426
8 0.0265 0.0254 1,391.647
8 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 32 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

0.0188 8.0100e-
003

1.2000e-
004

1.5200e-
003

0.0000 21.7988 21.7988 4.2000e-
004

4.0000e-
004

21.9284
Apartments Mid
Rise

1.30613e
+007

0.0704 0.6018 0.2561 3.8400e-
003

0.0487 0.0487 0.0487 0.0487 0.0000 696.9989 696.9989 0.0134 0.0128 701.1408 General Office
Building
468450 2.5300e-
003

0.0230 0.0193 1.4000e-
004

1.7500e-
003

0.0000 24.9983 24.9983 4.8000e-
004

4.6000e-
004

25.1468
High Turnover (Sit
Down Restaurant)

8.30736e
+006

0.0448 0.4072 0.3421 2.4400e-
003

0.0310 0.0310 0.0310 0.0310 0.0000 443.3124 443.3124 8.5000e- 003

8.1300e-
003
445.9468
Hotel 1.74095e
+006

9.3900e-
003

0.0853 0.0717 5.1000e-
004

6.4900e-
003

0.0000 92.9036 92.9036 1.7800e-
003

1.7000e-
003

93.4557
Quality
Restaurant

1.84608e
+006

9.9500e-
003

0.0905 0.0760 5.4000e-
004

6.8800e-
003

0.0000 98.5139 98.5139 1.8900e-
003

1.8100e-
003

99.0993
Regional
Shopping Center
91840 5.0000e-
004

4.5000e-
003

3.7800e-
003

3.0000e-
005

3.4000e-
004

0.0000 4.9009 4.9009 9.0000e-
005

9.0000e-
005

4.9301
Total 0.1398 1.2312 0.7770 7.6200e-
003

0.0966 0.0966 0.0966 0.0966 0.0000 1,383.426
8 1,383.426
8 0.0265 0.0254 1,391.647
8 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 33 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Apartments Low
Rise
106010 33.7770 1.3900e-
003

2.9000e-
004

33.8978
Apartments Mid
Rise

3.94697e
+006
1,257.587
9 0.0519 0.0107 1,262.086
9 General Office
Building
584550 186.2502 7.6900e-
003

1.5900e-
003
186.9165
High Turnover (Sit
Down Restaurant)

1.58904e
+006
506.3022 0.0209 4.3200e-
003
508.1135
Hotel 550308 175.3399 7.2400e-
003

1.5000e-
003
175.9672
Quality
Restaurant
353120 112.5116 4.6500e-
003

9.6000e-
004
112.9141
Regional
Shopping Center
756000 240.8778 9.9400e-
003

2.0600e-
003
241.7395
Total 2,512.646
5 0.1037 0.0215 2,521.635
6 Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 34 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

6.1 Mitigation Measures Area

6.0 Area Detail

5.3 Energy by Land Use - Electricity
Electricity
Use
Total CO2 CH4 N2O CO2e
Land Use kWh/yr MT/yr
Apartments Low
Rise
106010 33.7770 1.3900e-
003

2.9000e-
004

33.8978
Apartments Mid
Rise

3.94697e
+006
1,257.587
9 0.0519 0.0107 1,262.086
9 General Office
Building
584550 186.2502 7.6900e-
003

1.5900e-
003
186.9165
High Turnover (Sit
Down Restaurant)

1.58904e
+006
506.3022 0.0209 4.3200e-
003
508.1135
Hotel 550308 175.3399 7.2400e-
003

1.5000e-
003
175.9672
Quality
Restaurant
353120 112.5116 4.6500e-
003

9.6000e-
004
112.9141
Regional
Shopping Center
756000 240.8778 9.9400e-
003

2.0600e-
003
241.7395
Total 2,512.646
5 0.1037 0.0215 2,521.635
6 Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 35 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
Category tons/yr MT/yr
Mitigated 5.1437 0.2950 10.3804 1.6700e-
003

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835
Unmitigated 5.1437 0.2950 10.3804 1.6700e-
003

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835

6.2 Area by SubCategory
ROG NOx CO SO2 Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2 NBio- CO2 Total CO2 CH4 N2O CO2e
SubCategory tons/yr MT/yr
Architectural
Coating

0.4137 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

4.3998 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 0.0206 0.1763 0.0750 1.1200e-
003

0.0143 0.0143 0.0143 0.0143 0.0000 204.1166 204.1166 3.9100e- 003

3.7400e-
003
205.3295
Landscaping 0.3096 0.1187 10.3054 5.4000e-
004

0.0572 0.0572 0.0572 0.0572 0.0000 16.8504 16.8504 0.0161 0.0000 17.2540 Total 5.1437 0.2950 10.3804 1.6600e-
003

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 36 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

7.1 Mitigation Measures Water

7.0 Water Detail

0.4137 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Consumer
Products

4.3998 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 0.0000 Hearth 0.0206 0.1763 0.0750 1.1200e-
003

0.0143 0.0143 0.0143 0.0143 0.0000 204.1166 204.1166 3.9100e- 003

3.7400e-
003
205.3295
Landscaping 0.3096 0.1187 10.3054 5.4000e-
004

0.0572 0.0572 0.0572 0.0572 0.0000 16.8504 16.8504 0.0161 0.0000 17.2540 Total 5.1437 0.2950 10.3804 1.6600e-
003

0.0714 0.0714 0.0714 0.0714 0.0000 220.9670 220.9670 0.0201 3.7400e- 003
222.5835
Mitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 37 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual Total CO2 CH4 N2O CO2e
Category MT/yr
Mitigated 585.8052 3.0183 0.0755 683.7567
Unmitigated 585.8052 3.0183 0.0755 683.7567
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 38 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Apartments Low
Rise

1.62885 /

1.02688

10.9095 0.0535 1.3400e-
003

12.6471
Apartments Mid
Rise

63.5252 /

40.0485
425.4719 2.0867 0.0523 493.2363
General Office
Building

7.99802 /

4.90201

53.0719 0.2627 6.5900e-
003

61.6019
High Turnover (Sit
Down Restaurant)

10.9272 /

0.697482

51.2702 0.3580 8.8200e-
003

62.8482
Hotel 1.26834 /

0.140927

6.1633 0.0416 1.0300e-
003

7.5079
Quality
Restaurant

2.42827 /

0.154996

11.3934 0.0796 1.9600e-
003

13.9663
Regional
Shopping Center

4.14806 /

2.54236

27.5250 0.1363 3.4200e-
003

31.9490
Total 585.8052 3.0183 0.0755 683.7567
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 39 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

8.1 Mitigation Measures Waste

7.2 Water by Land Use
Indoor/Out
door Use
Total CO2 CH4 N2O CO2e
Land Use Mgal MT/yr
Apartments Low
Rise

1.62885 /

1.02688

10.9095 0.0535 1.3400e-
003

12.6471
Apartments Mid
Rise

63.5252 /

40.0485
425.4719 2.0867 0.0523 493.2363
General Office
Building

7.99802 /

4.90201

53.0719 0.2627 6.5900e-
003

61.6019
High Turnover (Sit
Down Restaurant)

10.9272 /

0.697482

51.2702 0.3580 8.8200e-
003

62.8482
Hotel 1.26834 /

0.140927

6.1633 0.0416 1.0300e-
003

7.5079
Quality
Restaurant

2.42827 /

0.154996

11.3934 0.0796 1.9600e-
003

13.9663
Regional
Shopping Center

4.14806 /

2.54236

27.5250 0.1363 3.4200e-
003

31.9490
Total 585.8052 3.0183 0.0755 683.7567
Mitigated

8.0 Waste Detail
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 40 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual Total CO2 CH4 N2O CO2e
MT/yr
Mitigated 207.8079 12.2811 0.0000 514.8354
Unmitigated 207.8079 12.2811 0.0000 514.8354
Category/Year
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 41 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Apartments Low
Rise

11.5 2.3344 0.1380 0.0000 5.7834
Apartments Mid
Rise
448.5 91.0415 5.3804 0.0000 225.5513
General Office
Building

41.85 8.4952 0.5021 0.0000 21.0464
High Turnover (Sit
Down Restaurant)
428.4 86.9613 5.1393 0.0000 215.4430
Hotel 27.38 5.5579 0.3285 0.0000 13.7694
Quality
Restaurant

7.3 1.4818 0.0876 0.0000 3.6712
Regional
Shopping Center

58.8 11.9359 0.7054 0.0000 29.5706
Total 207.8079 12.2811 0.0000 514.8354
Unmitigated
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 42 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

8.2 Waste by Land Use
Waste
Disposed
Total CO2 CH4 N2O CO2e
Land Use tons MT/yr
Apartments Low
Rise

11.5 2.3344 0.1380 0.0000 5.7834
Apartments Mid
Rise
448.5 91.0415 5.3804 0.0000 225.5513
General Office
Building

41.85 8.4952 0.5021 0.0000 21.0464
High Turnover (Sit
Down Restaurant)
428.4 86.9613 5.1393 0.0000 215.4430
Hotel 27.38 5.5579 0.3285 0.0000 13.7694
Quality
Restaurant

7.3 1.4818 0.0876 0.0000 3.6712
Regional
Shopping Center

58.8 11.9359 0.7054 0.0000 29.5706
Total 207.8079 12.2811 0.0000 514.8354
Mitigated

9.0 Operational Offroad
Equipment Type Number Hours/Day Days/Year Horse Power Load Factor Fuel Type

10.0 Stationary Equipment
Fire Pumps and Emergency Generators
Equipment Type Number Hours/Day Hours/Year Horse Power Load Factor Fuel Type CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 43 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

11.0 Vegetation
Boilers
Equipment Type Number Heat Input/Day Heat Input/Year Boiler Rating Fuel Type User Defined Equipment
Equipment Type Number
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:52 PMPage 44 of 44 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Annual

1.2 Other Project Characteristics
Urbanization
Climate Zone
Urban
9 Wind Speed (m/s) Precipitation Freq (Days)2.2 33

1.3 User Entered Comments & Non-Default Data

1.0 Project Characteristics
Utility Company Southern California Edison
2028Operational Year
CO2 Intensity
(lb/MWhr)
702.44 0.029CH4 Intensity
(lb/MWhr)

0.006N2O Intensity
(lb/MWhr)
Village South Specific Plan (Proposed)
Los Angeles-South Coast County, Summer
CalEEMod Version: CalEEMod.2016.3.2 Date: 1/6/2021 1:54 PMPage 1 of 35 Village South Specific Plan (Proposed) - Los Angeles-South Coast County, Summer Project Characteristics - Consistent with the DEIR's model.