Agenda packet — Carmel-by-the-Sea City Council, April 8, 2024 (part 1 of 5)

CITYOF CARMEL-BY-THE-SEA

CITY COUNCIL AGENDA
Mayor Dave Potter, Councilmembers Jeff Baron,
Alissandra Dramov, Karen Ferlito, and Bobby
Richards
Contact: 831.620.2000 www.ci.carmel.ca.us
All meetings are held in the City Council Chambers
East Side of Monte Verde Street
Between Ocean and 7th Avenues

CITY COUNCIL SPECIAL MEETING
Monday, April 8, 2024
4:30 PM

HYBRID MEETING ATTENDANCE OPTIONS
This meeting will be held in person and via teleconference ("hybrid"). The public is welcome to attend the meeting in person or remotely via Zoom, however, the meeting will proceed as normal even if there are technical difficulties accessing Zoom. The City will do its best to resolve any technical issues as quickly as possible. To view or listen to the meeting from home, you may also watch the live stream on the City's YouTube page at: https://www.youtube.com/@CityofCarmelbytheSea/streams. To participate in the meeting via Zoom, copy and paste the link below into your browser.
https://ci-carmel-ca-us.zoom.us/j/84625070614 Webinar ID: 846 2507 0614 Passcode:
408269 Dial in: (253) 215-8782

HOW TO OFFER PUBLIC COMMENT
The public may give public comment at this meeting in person, or using the Zoom teleconference module, provided that there is access to Zoom during the meeting. Zoom comments will be taken after the in-person comments. The public can also email comments to [email protected]. Comments must be received at least 2 hours before the meeting in order to be provided to the legislative body. Comments received after that time and up to the beginning of the meeting will be made part of the record.

Councilmember Ferlito will be attending this meeting remotely under California Gov.

Code 54953(b) at the following location: 149 Sherman Lane, New Haven, VT 05472. The agenda will be posted at the location and will be open to the public.

CALL TO ORDER AND ROLL CALL

PUBLIC HEARINGS

1. Consider the Planning Commission's recommendation on a General Plan amendment, adopting the 6
th Cycle 2023-2031 Housing Element and associated
Initial Study/Mitigated Negative Declaration
Recommendation:

1. Adopt a Resolution 2024-028 adopting a Mitigated Negative Declaration and associated Mitigation Monitoring and Reporting Program for the 2023-2031 Housing Element of the General Plan; and

2. Adopt Resolution 2024-029 approving a General Plan Amendment to repeal the 2015-2023 Housing Element and adopt the 2023-2031 Housing Element of the General Plan in compliance with State housing element law.

ORDERS OF BUSINESS
Orders of Business are agenda items that require City Council, Board or Commission discussion, debate, direction to staff, and/or action.

1. Resolution 2024-024 receiving the Annual Comprehensive Financial Report (ACFR) for the fiscal year ending June 30, 2023

ADJOURNMENT
This agenda was posted at City Hall, Monte Verde Street between OceanAvenue and 7thAvenue, Harrison Memorial Library, located on the NE corner of Ocean Avenue and Lincoln Street, the Carmel-by-the-Sea Post Office, 5th Avenue between Dolores Street and San Carlos Street, and the City's webpage http://www.ci.carmel.ca.us in accordance with applicable legal requirements.

SUPPLEMENTAL MATERIAL RECEIVED AFTER THE POSTING OF THEAGENDA Any supplemental writings or documents distributed to a majority of the City Council regarding any item on this agenda, received after the posting of the agenda will be available for public review at City Hall located on Monte Verde Street between Ocean and Seventh Avenues during regular business hours.

SPECIAL NOTICES TO PUBLIC
In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, please contact the City Clerk's Office at 831-620-2000 at least 48 hours prior to the meeting to ensure that reasonable arrangements can be made to provide accessibility to the meeting (28CFR 35.102-35.104 ADA Title II).

CITY OF CARMEL-BY-THE-SEA

CITY COUNCIL
Staff Report
April 8, 2024

PUBLIC HEARINGS
TO: Honorable Mayor and City Council Members
SUBMITTED BY: Marnie R. Waffle, AICP, Principal Planner APPROVED BY: Chip Rerig, City Administrator
SUBJECT:

Consider the Planning Commission's recommendation on a General Plan amendment, adopting the 6
th Cycle 2023-2031 Housing Element and associated
Initial Study/Mitigated Negative Declaration
Recommendation:

1. Adopt a Resolution 2024-028 adopting a Mitigated Negative Declaration and associated Mitigation Monitoring and Reporting Program for the 2023-2031 Housing Element of the General Plan; and

RECOMMENDATION:

1. Adopt a Resolution 2024-028 adopting a Mitigated Negative Declaration and associated Mitigation Monitoring and Reporting Program for the 2023-2031 Housing Element of the General Plan; and

BACKGROUND/SUMMARY:

Executive Summary
The City has prepared a draft update to the Housing Element of the General Plan (Attachment 5) to affirmatively further fair housing and accommodate the 349-unit Regional Housing Needs Allocation (RHNA) for the 2023-2031 Housing Element cycle. The content of the draft 2023-2031 Housing Element is structured for consistency with the requirements set forth in state law. In addition to responding to requirements of state law, the Housing Element also demonstrates the City’s strategy for meeting the City’s locally determined housing needs and that these needs are addressed through policies and programs outlined within the Housing Element. Public review and input have been a critical component of this 6th Cycle Housing Element Update.

This staff report provides a summary of the Housing Element requirements, an overview of the status of the City’s draft Housing Element, and the findings provided to the City by HCD on the first 90-day review and subsequent 60-day review of the draft. The City has responded to HCD’s comments and believes that the draft Housing Element substantially complies with Article 10.6.

Background
CA Government Code Title 7, Division 1, Chapter 3, Article 10.6 [65580 – 65589.11] regulates the use and requirements of housing elements in California. The state law requires jurisdictions to update their General Plan Housing Element every eight years. State law further requires the current update for jurisdictions in the Association of Monterey Bay Area Governments (AMBAG) region to comply by December 15, 2023.

The City’s 2023-2031 Draft Housing Element was prepared with the benefit of input from the community and discussion at numerous public meetings held by the City Council, the Planning Commission, and the Housing Ad Hoc Committee. Guidance was also provided by HCD throughout the process.

On August 3, 2023, January 24, 2024, and April 4, 2024 the City submitted drafts of the updated Housing Element to HCD for its review. The City received HCD’s 90-day findings letter on November 1, 2023 and HCD’s 60-day findings letter on March 20, 2024. Based on discussions with HCD, staff revised the draft Housing Element to include additional information and analysis. Prior to each resubmittal to HCD the draft Housing Element was posted for public review and comment. All public comments were considered during preparation of the subsequent draft.

On April 8, 2024, the Planning Commission held a public hearing to consider the final draft Housing Element and adopted Resolution 2024-025-PC recommending City Council adoption of the 2023-2031 Housing Element and Resolution 2024-024-PC recommending adoption of the environmental document.

The following section summarizes the required components of Housing Element Updates per State law, new requirements since the 5th Cycle Housing Element Update (2015-2023), and penalties for noncompliance with Housing Element laws. The section also includes a summary of public meetings related to the 6th Cycle Housing Element Update prior to today’s meeting.

Required Components of a Housing Element
Pursuant to Government Code Section 65583, local governments are required to include the items below as components within their Housing Elements and subsequent updates thereto. Newly required components introduced as part of the 6th Cycle are noted below and discussed in further detail within the “New Requirements for the 6th Cycle Housing Element Update” Section below.

1. Housing Needs Assessment. Examine demographic, employment, and housing trends and conditions and identify the community's existing and projected housing needs, with attention paid to special housing needs (e.g., large families, persons with disabilities). This section includes a community’s Regional Housing Needs Allocation (RHNA) as determined by the community’s regional planning body in partnership with HCD.

2. Evaluation of Past Performance. Review the prior Housing Element to measure progress in implementing policies and programs.

3. Housing Sites Inventory. Identify locations of available sites for housing development or redevelopment to demonstrate there is enough land zoned for housing to meet future needs at all income levels. New component of state law: The standards for designating adequate sites were substantially changed from the sixth cycle, particularly for non-vacant sites.

4. Community Engagement. Implement a robust community engagement program that includes reaching out to individuals and families at all economic levels of the community plus historically underrepresented groups.

5. Constraints Analysis. Analyze and recommend remedies for existing and potential governmental and nongovernmental barriers to housing development.

6. Policies and Programs. Establish policies and programs to be carried out during the 2023-2031 planning period to fulfill the identified housing needs.

7. AFFH. New component of state law: Analyze and address significant disparities in housing needs and access to opportunity by proposing housing goals, objectives, and policies that aid in 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.

New Requirements for the 6th Cycle Housing Element Update Pursuant to recent State legislation, the following items are now required as part of the Housing Element Update process:

Affirmatively Furthering Fair Housing (AFFH). Assembly Bill 686 (AB 686), passed in 2018, created new requirements for jurisdictions to affirmatively further fair housing. According to AB 686, affirmatively furthering fair housing means to take “meaningful actions, in addition to combating discrimination, which overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics” and is Federally mandated by the 1968 Fair Housing Act.

The four main goals are to:

Address significant disparities in housing needs and in access to opportunity, and Replace segregated living patterns with truly integrated and balanced living patterns, and Transform racially and ethnically concentrated areas of poverty into areas of opportunity, and Foster and maintain compliance with civil rights and fair housing laws.

Public Comment on Draft Revisions. Assembly Bill 215 (AB 215, 2021) requires local governments to make the first draft revision of their housing element update available for public comment for at least 30 days. Further, if any comments are received, a local government must take at least ten additional business days to consider and incorporate public comments into the draft revision before submitting to HCD. HCD must review the draft and report its written findings to the planning agency within 90 days of receiving the first draft submittal for each housing element revision or within 60 days of its receipt for a subsequent draft amendment or adoption.

Penalties for Non-Compliance
In the 6th Cycle, jurisdictions face a number of new consequences for not having a certified Housing Element. Under legislation enacted in recent years, if a jurisdiction does not comply with State housing law, HCD may refer the jurisdiction to the Attorney General. Significant fines may be imposed if a jurisdiction does not comply with a court order within one year. A court finding a Housing Element inadequate may limit local land use decision-making authority until the jurisdiction brings its Housing Element into compliance, or local governments may lose the right to deny certain projects, including those submitted under the “Builder’s Remedy”.

Conversely, an HCD-certified housing element makes jurisdictions eligible for, or with higher priority for, numerous sources of funding, such as Local Housing Allocations, Affordable Housing and Sustainable Communities Grants, SB 1 Planning Grants, CalHOME Program Grants, Infill Infrastructure Grants, ProHousing Design funding, Local Housing Trust Funds and Regional Transportation Funds (such as MTC’s OneBayArea Grants).

Related Elements
Safety Element. Jurisdictions must review and update their Safety Element to meet certain requirements concurrently with the Housing Element update. The Safety Element must be reviewed and updated to address wildfire, seismic, geologic and flood risks. Climate adaptation and resiliency strategies are also considered.

SB 1035 and SB 379. Require all jurisdictions to address climate change adaptation and resilience in their general plan safety element. SB 379 is triggered by the next update of a jurisdiction’s local hazard mitigation plan (updated every five years) or before 1/1/2022, whichever is first. SB 1035 built off SB 379, requiring the safety element be updated every eight years upon the next housing element update.

SB 1241. Applies to communities with very high fire hazard severity or unincorporated communities in state responsibility areas. Communities subject to SB 1241 need to ensure consistency between the housing and safety elements to address fire risk. AB 2911 strengthened the local very high fire hazard severity zone designation.

AB 2140. Authorizes local governments to adopt the LHMP with the general plan safety element.

Integration by reference or annexation is encouraged through a post-disaster financial incentive to cover local shares of the 25 percent non-federal portion of grant-funded post-disaster projects when approved by the legislature.

The update to the City’s Safety Element is underway.

Summary of Prior Meetings and Study Sessions
Since November 2022, the City has conducted a comprehensive community engagement and outreach strategy as required by the Government Code to inform the 6th Cycle Housing Element Update Process.

This strategy has included a series of community meetings and public study sessions with the Housing Ad Hoc Committee, Planning Commission, and City Council. These meetings and study sessions are summarized in Section 1.6 of the final draft Housing Element. Feedback received throughout the ongoing community engagement and outreach process has assisted staff and the consulting team in preparing the draft Housing Element Update and related items.

Housing Element Requirements
The following section summarizes the contents of the City’s Housing Element Update for the 2023-2031 Planning Period.

Housing Needs Assessment
As part of the Housing Element Update process the City is required to analyze the existing and projected housing needs of the City, including its fair share of RHNA requirements. The City’s analysis of housing needs is required to include an assessment of detailed demographic data, including population, age, size, and ethnicity; household characteristics; overpayment trends; housing stock conditions; units in need of replacement or rehabilitation; and needs of special needs populations including the elderly, persons with disabilities, unhoused persons, extremely low-income households, and farmworkers. The 6th Cycle Housing Element Update outlines the following housing needs of the City.

Regional Housing Needs Allocation (RHNA)
In August 2021, the California Department of Housing and Community Development (HCD) issued a Regional Housing Need Determination to the AMBAG region for the 6th Cycle planning period of June 30, 2023 to December 15, 2031 and determined that the region must zone to accommodate a minimum of 33,274 housing units during this period.

California housing law (Government Code § 65580 et seq.) requires AMBAG, acting in the capacity of Council of Governments (COG), to develop a Regional Housing Needs Allocation (RHNA) Plan to allocate existing and projected housing needs to local jurisdictions within Monterey and Santa Cruz Counties.

Based on the final RHNA Plan, each city and county must update its housing element to demonstrate how the jurisdiction will meet the expected growth in housing needs over this period of time. On October 12, 2022, the AMBAG Board of Directors adopted the Final 2023-2031 6th Cycle RHNA Plan.

AMBAG’s Plan distributes the RHNA across the regions counties and cities based on demographic, and population data received from the California Department of Finance (DOF). Local jurisdictions must then utilize their ascribed RHNA to update the housing elements of their general plans for the 6th Cycle planning period, inclusive of identifying eligible land resources to accommodate this RHNA. The City of Carmel-bythe-Sea’s RHNA is 349 units.

RHNA requirements are organized into four affordability categories, established according to the Area Median Income (AMI) of a geography. These categories include very low-income residential units, which are affordable to households earning less than 50% of AMI; low-income residential units, which are affordable to households earning between 50% and 80% of AMI; moderate income residential units, which are affordable to households earning between 80% and 120%; and above moderate-income residential units which are affordable to households earning upwards of 120% of AMI. The City’s RHNA breakdown is as follows:
113 very-low income units,
74 low-income units,
44 moderate-income units, and
118 above moderate-income units.

RHNA Buffer
New “no net loss” provisions of Government Code Section 65863 require the City to ensure an adequate supply of land resources to be made available for housing development throughout the 2023-2031 planning period. This means if housing sites identified within the City’s 6th Cycle housing element update are developed with non-residential uses, lower residential densities, or residential uses at affordability levels higher than anticipated by the Housing Element, the City’s Housing Element could be determined to be out of compliance. Accordingly, the City’s RHNA requirement is further buffered with 61 units or 17% to ensure compliance with “no net loss” provisions.

Constraints Analysis
In addition to analyzing the existing and projected housing needs of the City, the Housing Element Update must also identify and analyze potential and actual governmental and nongovernmental constraints to the maintenance, improvement, or development of housing for all income in the community, regardless of protected class. A summary of constraints to the development and improvement of housing in the City can be found in Appendix B of the Housing Element.

Housing Resources & Sites Inventory
As part of the 6th Cycle housing element update, the City is also required to identify resources available to the City for the preservation, rehabilitation, and production of housing throughout the community. This includes programmatic and financial resources, such as those offered locally or through State or Federal partners. These resources also include land resources within the City that were identified as eligible for accommodation of the City’s RHNA Requirements. Pursuant to Government Code Section 65583.2(a) the following land resources are eligible for accommodation of the City RHNA: vacant sites zoned for residential use; or vacant sites zoned for nonresidential use that allow residential development; or residentially zoned sites that are capable of being developed at a higher density; or sites zoned for nonresidential use that can be redeveloped for residential use, and for which the Housing Element includes a program to rezone the site. The City’s Housing Sites Inventory is summarized in Appendix C of the Housing Element.

Policies and Programs
The Housing Element Update includes a set of goals, policies, and implementing programs intended to promote the preservation, rehabilitation, and production of housing throughout the City. Goals are longrange, broad, and comprehensive targets that describe the future outcomes the City desires. A policy is a specific instructional guideline that seeks to promote goals. Together, goals and policies are implemented through a series of programs that identify specific, quantifiable actions the City will undertake during the 6th Cycle planning period. A summary of Draft Goals, Policies, and Programs can be found in Chapter 2 of the Housing Element.

AFFH
Assembly Bill 686 (AB 686), passed in 2018, created new requirements for jurisdictions to affirmatively further fair housing as part of the Housing Element Update process. These requirements found in Government Code Section 8899.50 are intended to address racial inequalities seen today throughout the region which developed through historical policies and practices enacted at federal, state, regional and local levels and across the public and private sectors. Though many of these explicit forms of historical discrimination have been outlawed, the results of these systems have left a lasting imprint on both the region and the City. Racially explicit practices (e.g., racial covenants) that excluded persons of color from predominately white neighborhoods have been replaced with race-neutral land use policies that continue to exclude these same groups. Furthermore, rapidly increasing housing costs have deepened racial and economic disparity and segregation, displacing many low-income individuals and people of color to the peripheries of the region or out of the region altogether.

Accordingly, the City must incorporate fair housing considerations into its 6th Cycle Housing Element Update to increase housing opportunities in high-resource neighborhoods and bring additional resources to traditionally under-resourced neighborhoods. A summary of the required AFFH component can be found in section 1.4 of the Housing Element.

Targeted Community Outreach
The City must demonstrate “meaningful, frequent, and ongoing community participation, consultation, and coordination” as part of the 6th Cycle Housing Element Update process. This is intended to ensure that input has been received from groups historically and presently most impacted by fair housing issues and that local knowledge is incorporated into Housing Elements. A summary of the City’s targeted community outreach efforts can be found in section 1.6 of the Housing Element. Additional information can be found in Appendices E and H.

Assessment of Fair Housing
The City must also describe and analyze the unique housing circumstances of the City. This analysis is referred to as an Assessment of Fair Housing (AFH) and analyzes circumstances within the City pertaining to Fair Housing issues including:

Fair Housing Outreach Capacity and Enforcement
The City’s AFH includes information regarding the City’s Fair Housing Outreach Capacity and Enforcement methods which can be found in Appendix A of the Housing Element.

Segregation and Integration Patterns
The City’s AFH also analyzes segregation and integration patterns within the jurisdiction as well as regionally. Segregation and integration patterns are analyzed by evaluating the concentration (or lack thereof) of protected groups within the community, relative to their distribution across a larger geography.

Disparities In Access to Opportunity
The City’s AFH also evaluates disparities in access to opportunity within the City, which are areas within the City that have substantial differences in access to education, transportation, economic and environmental outcomes than other areas as identified by the California Tax Credit Allocation Committee (TCAC).

Disproportionate Housing Needs (For Low-Income Households and Protected Classes) The City’s AFH also evaluates disproportionate housing needs among low-income households and protected classes within the City. Disproportionate housing needs are evident when members of a protected group disproportionately experience a housing need compared to other groups or the total population. Disproportionate housing needs typically refer to the risk of displacement, overcrowding, or cost-burden, among others.

Sites Inventory
State Law requires the City to evaluate whether Housing Sites identified as suitable for accommodation of the City’s RHNA requirements are identified relative to the full scope of the assessment of fair housing (e.g., segregation and integration, racially and ethnically concentrated areas of poverty and affluence, access to opportunity, etc.). A summary of how Housing Sites were identified consistent with AFFH can be found in section 1.4 of the Housing Element.

Goals, Policies, and Actions
The policies and programs responsive to State Law demonstrating the City’s commitment to affirmatively further fair housing as part of the Housing Element Update process can be found in Chapter 2 of the Housing Element.

Evaluation of Past Progress
Pursuant to State Law, the implementation status of Goals, Policies, and Programs from the City’s 5th Cycle Housing Element Update has been included in Appendix D of the Housing Element.

Community Engagement
Consistent with State Law, the City has conducted ongoing community outreach efforts throughout the 6th Cycle Housing Element Update process. These efforts, inclusive of the Housing Ac Hoc Committee, Planning Commission, and City Council meetings held prior to today, are summarized within section 1.6 of the Housing Element.

Review Process
Below is a summary of the formal review process. Numerous informal rounds of review with HCD also occurred.

On August 3, 2023, the City submitted the draft Housing Element to HCD for a mandatory 90-day review.

On November 1, 2023, the City received HCD’s findings regarding the Element’s compliance with state law included as Attachment 6.

On January 24, 2024, the City submitted a revised draft Housing Element to HCD for a mandatory 60- day review included as Attachment 7.

On March 20, 2024, the City received HCD’s findings regarding the Element’s compliance with state law included as Attachment 8.

On April 4, 2024, the City submitted a final draft Housing Element to HCD, included as Attachment

9. On April 5, 2024, the City received HCD's findings regarding the revised draft Housing Element's compliance with state law included as Attachment 10.

Environmental Review
The City has prepared the necessary environmental review, consistent with CEQA, for the Draft 2023– 2031 Housing Element Update. The City Council will be considering the adoption of an Initial Study/Mitigated Negative Declaration and associated Mitigation Monitoring and Reporting Program, consistent with CEQA, for the Draft 2023– 2031 Housing Element Update (Resolution 2024-028, Attachments 1 - 4)
Alternatives
The City Council can provide feedback to be incorporated as an amendment to the 2023-2031 Housing Element, following adoption by the City Council and certification by HCD.

The City Council could also opt not to adopt the 2023-2031 Housing Element by the April 15, 2024, deadline although that would put the City at risk of the penalties associated with AB 1398 and housing statute.

FISCAL IMPACT:

PRIOR CITY COUNCIL ACTION:

ATTACHMENTS:

Attachment 1) Resolution 2024-028 – adopting the Mitigated Negative Declaration and associated Mitigation Monitoring and Reporting Program
Attachment 2) Exhibit A: Initial Study/Mitigated Negative Declaration Attachment 3) Exhibit B: Mitigation Monitoring and Reporting Program Attachment 4) Exhibit C: Response to Comments
Attachment 5) Resolution 2024-029 - adopting the 2023-2031 Housing Element Attachment 6) Exhibit A: 2023-2031 Housing Element
Attachment 7) HCD 90-day Finding Letter, dated November 1, 2023 Attachment 8) Response to HCD Findings (Draft 2023-2031 Housing Element submitted 1.24.24) Attachment 9) HCD 60-day Finding Letter, dated March 20, 2024 Attachment 10) HCD Letter, dated April 5, 2024

CITY OF CARMEL-BY-THE-SEA

CITY COUNCIL
RESOLUTION NO. 2024-028
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARMEL BY-THE-SEA

ADOPTING A MITIGATED NEGATIVE DECLARATION AND ASSOCIATED MITIGATION MONITORING AND REPORTING PROGRAM FOR THE 2023-2031 HOUSING ELEMENT UPDATE
WHEREAS, State Housing Element Law (Government Code Sections 65580 et seq.) requires that the Carmel-by-the-Sea City Council adopt a Housing Element for the eight-year period 2023-2031 to accommodate the City of Carmel-by-the-Sea regional housing need allocation (RHNA) of 349 housing units, comprised of 113 very-low-income units, 74 low-income units, 44 moderate-income units, and 118 above moderate-income units; and WHEREAS, to comply with State Housing Element Law, the City of Carmel-by-the-Sea has prepared the 2023-2031 Housing Element in compliance with State Housing Element Law and has identified sites that can accommodate housing units meeting the City’s RHNA; and WHEREAS, as provided in Government Code Section 65350 et. seq., adoption of the Housing Element constitutes a General Plan Amendment; and WHEREAS, the California Environmental Quality Act (California Public Resources Code §§ 21000, et seq., “CEQA”), together with State Guidelines (14 California Code Regulations §§ 15000, et seq., the “CEQA Guidelines”) and City Environmental Regulations (CMC 17.60) require that certain projects be reviewed for environmental impacts and that environmental documents be prepared; and
WHEREAS, the City completed an Initial Study and prepared a draft Mitigated Negative Declaration, which was circulated for public review from February 23, 2024, to March 25, 2024, using both the State clearinghouse and the regional clearinghouse for distribution; and WHEREAS, two public comments were received from responsible agencies and responded to, included as Exhibit C; and
WHEREAS, on March 29, 2024, a notice of the public hearing scheduled for April 8, 2024, was published in the Carmel Pine Cone in compliance with State law (California Government Code 65091) indicating the date and time of the public hearing; and WHEREAS, on or before April 5, 2024, the meeting agenda was posted in three locations in compliance with State law indicating the date and time of the public hearing; and WHEREAS, on April 8, 2024, the Planning Commission adopted Resolution 2024-024-PC recommending City Council adoption of a Mitigated Negative Declaration and associated Mitigation Monitoring and Reporting Program; and
WHEREAS, on April 8, 2024, the City Council held a duly noticed public hearing to receive public testimony regarding the 6th cycle 2023-2031 Housing Element update and Initial Study/Mitigation Negative Declaration including the associated Mitigation Monitoring and Attachment 1
Resolution 2024-028

Page 2 of 2 ends

Reporting Program, including, without limitation, the information provided to the City Council by City staff and through public testimony; and
WHEREAS, this Resolution and its findings are made based upon the evidence presented to the Council at the hearing, including, without limitation, the staff report and attachments submitted by the Community Planning and Building Department; and WHEREAS, the City Council did hear and consider all said reports, attachments, recommendations, and testimony herein above set forth and used their independent judgment to evaluate the project; and
WHEREAS, the facts set forth in the recitals are true and correct and are incorporated herein by reference.

NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Carmel-bythe-Sea does hereby adopt the Mitigated Negative Declaration, included as Exhibit A, and associated Mitigation Monitoring and Reporting Program for the 2023-2031 Housing Element update, included as Exhibit B.

PASSED, APPROVED, AND ADOPTED BY THE CITY COUNCIL OF THE CITY OF CARMEL-BY-THE-SEA this 8th day of April 2024, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

APPROVED: ATTEST:
_________________________ _________________________
Dave Potter Nova Romero, MMC
Mayor City Clerk
EXHIBIT A: Initial Study/Mitigated Negative Declaration EXHIBIT B: Mitigation Monitoring and Reporting Program
EXHIBIT C: Response to Comments
Attachment 1
Mitigated Negative Declaration
City of Carmel-by-the-Sea
6th Cycle Housing Element Update
(2023-2031) and
Safety Element Update
February 20, 2024
Prepared by
EMC Planning Group
Attachment 2
Attachment 2
City of Carmel-by-the-Sea

COMMUNITY PLANNING AND BUILDING DEPARTMENT

POST OFFICE DRAWER CC
CARMEL-BY-THE-SEA, CA 93921
(831) 620-2010 OFFICE

NOTICE OF INTENT TO ADOPT A MITIGATED NEGATIVE DECLARATION In compliance with the California Environmental Quality Act (CEQA), City of Carmel-by-the-Sea has undertaken environmental review for the proposed 6th Cycle Housing Element Update (2023-2031) and Safety Element Update, and intends to adopt a Mitigated Negative Declaration. The City of Carmel-bythe-Sea invites all interested persons and agencies to comment on the proposed 6th Cycle Housing Element Update (2023-2031) and Safety Element Update.

Lead Agency: City of Carmel-by-the-Sea
Project Location: Carmel-by-the-Sea
Project Description: The project includes the update to the City’s 6th Cycle Housing Element Update (2023-2031) Housing and Community Development (HCD) Revised Draft (dated January 24, 2024) (“Housing Element Update”) and the update to the City’s Safety Element. The adoption of these two elements would be an amendment to the City’s General Plan/Coastal Land Use Program (General Plan). It is not expected that the updates to the City’s Safety Element result in any physical changes. The Housing Element Update includes 410 housing units, which is approximately 17 percent more than the RHNA of 349 units.

The City does not anticipate that future housing projects proposed on sites with existing commercial/office uses would also result in expanded building square footage for such uses. Consequently, no increase in existing commercial/office building square footage would occur with implementation of the Housing Element Update.

Public Review Period: Begins– February 23, 2024
Ends – March 25, 2024
Proposed Mitigated
Negative Declaration is
Available for Public
Review at these
Locations:

City of Carmel-by-the-Sea website: https://ci.carmel.ca.us/post/currentplanning-applications (Environmental Notices tab) City of Carmel-by-the-Sea Housing Element Update website:
https://homecarmelbythesea.com/
Hard copies will be available at the City of Carmel-by-the-Sea City Hall Address Where Written
Comments May be
Sent:

City Hall
PO Box CC
Carmel-by-the-Sea, CA 93921
Marnie Waffle, AICP, Principal Planner
[email protected]
Public Hearing: Date: April 2, 2024
Time: 4:30 pm
Location: City Hall and via Zoom
Attachment 2
Attachment 2
This document was produced on recycled paper.

MITIGATED NEGATIVE DECLARATION

CITY OF CARMEL-BY-THE-SEA
6TH CYCLE HOUSING ELEMENT UPDATE
(2023-2031) AND SAFETY ELEMENT UPDATE

PREPARED FOR
City of Carmel-by-the-Sea
Marnie R. Waffle, AICP, Principal Planner
City Hall, PO Box CC
Carmel-by-the-Sea, 93921
Tel 831.620.2057
[email protected]

PREPARED BY
EMC Planning Group Inc.
601 Abrego Street
Monterey, CA 93940
Tel 831.649.1799
Fax 831.649.8399
Teri Wissler Adam, Senior Principal
[email protected]
www.emcplanning.com
February 20, 2024
Attachment 2
Attachment 2
City of Carmel-by-the-Sea

COMMUNITY PLANNING AND BUILDING DEPARTMENT

POST OFFICE DRAWER CC
CARMEL-BY-THE-SEA, CA 93921
(831) 620-2010 OFFICE
Mitigated Negative Declaration 1 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update February 20, 2024

MITIGATED NEGATIVE DECLARATION
In Compliance with the
California Environmental Quality Act (CEQA)
Project Name City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update
Lead Agency City of Carmel-by-the-Sea
Project Proponent City of Carmel-by-the-Sea
Project Location Various locations throughout Carmel-by-the-Sea Project Description The project includes the update to the City’s 6th Cycle Housing Element Update (2023-2031) Housing and Community Development (HCD) Revised Draft (dated January 24, 2024) (“Housing Element Update”) and the update to the City’s Safety Element. The adoption of these two elements would be an amendment to the City’s General Plan/Coastal Land Use Program (General Plan).

It is not expected that the updates to the City’s Safety Element result in any physical changes. The Housing
Element Update includes 410 housing units, which is
approximately 17 percent more than the RHNA of 349
units. The City does not anticipate that future housing projects proposed on sites with existing commercial/office uses would also result in expanded building square footage for such uses. Consequently, no increase in existing
commercial/office building square footage would occur with implementation of the Housing Element Update.

Public Review Period Begins – February 23, 2024
Ends – March 25, 2024
Written Comments To
City of Carmel-by-the-Sea, City Hall
P.O. Box CC
Carmel-by-the-Sea, CA 93921
Proposed Findings The City of Carmel-by-the-Sea is the custodian of the documents and other material that constitute the record of proceedings upon which this decision is based.

Attachment 2
Mitigated Negative Declaration 2 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update February 20, 2024 The initial study indicates that the proposed project has the potential to result in significant adverse environmental impacts. However, the mitigation measures identified in the initial study would reduce the impacts to a less than
significant level. There is no substantial evidence, in light of the whole record before the lead agency, City of Carmel-bythe-Sea, that the project, with mitigation measures incorporated, may have a significant effect on the
environment. See the following project-specific mitigation measures:

Mitigation Measures
Air Quality
AQ-1 The developer shall prepare a Construction Management Plan for review and approval by the Community Development Director or his designate. The Construction Management Plan shall include the following measures to reduce TAC emissions during construction at individual project sites:
a. Heavy-duty diesel vehicles will have 2010 or newer model year engines, in compliance with the California Air Resources Board’s Truck and Bus Regulation; b. Idling of construction equipment and heavy-duty diesel trucks will be avoided where feasible, and if idling is necessary, it will not exceed three minutes; c. All construction equipment will be maintained and properly tuned in accordance with manufacturer’s specifications and will be checked by a certified visible emissions evaluator; and
d. All non-road diesel construction equipment will, at a minimum, meet Tier 3 emission standards listed in the Code of Federal Regulations Title 40, Part 89, Subpart B, §89.112. Further, where feasible, construction equipment will use alternative fuels such as compressed natural gas, propane, electricity or biodiesel.

Biological Resources
BIO-1 Worker Environmental Awareness Training. Prior to approval of a grading permit at a housing site, a qualified biologist shall conduct a training session for all construction personnel. At a minimum, the training shall include a description of special-status species potentially occurring in the housing site vicinity, including, but not limited to, monarch butterfly, obscure bumble bee, and western bumble bee. Their habitats, general measures that are being implemented to conserve species as they relate to the housing site, and the boundaries within which construction activities will occur will be explained.

Informational handouts with photographs clearly illustrating the species’ appearances Attachment 2
Mitigated Negative Declaration 3 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update February 20, 2024 shall be used in the training session. All new construction personnel shall undergo this mandatory environmental awareness training. Documentation of completion of this training shall be submitted to the City of Carmel-by-the-Sea Community Planning and Building Department prior to the start of ground disturbing activities.

BIO-2 Monarch Butterfly Survey and Avoidance. Prior to initiation of ground disturbance, a late fall/early winter monarch butterfly survey of trees on the housing site shall be conducted by a qualified biologist. Results of the survey shall be submitted to the City of Carmel-bythe-Sea Community Planning and Building Department upon completion. If the results of the survey do not identify any potential overwintering monarch butterflies on-site, not further mitigation is required. If overwintering monarchs are determined to use the site, the applicant shall avoid removal of trees used for overwintering by monarchs to the greatest extent feasible. If trees cannot be avoided, tree removal shall occur outside of the overwintering period (November through February) or until a qualified biologist has determined that overwintering monarchs are no longer using the site. Documentation of tree avoidance or absence of monarchs shall be submitted to the City of Carmel-by-theSea Community Planning and Building Department prior to tree removal.

BIO-3 Bumble Bee Survey and Avoidance. Prior to ground disturbance, a qualified biologist will conduct a pre-construction survey of small mammal burrows and thatched/bunch grasses for western bumble bee activity during the optimal flight period (April 1 – July 31). If the survey results are negative (i.e., no bumble bee activity observed), a letter report confirming absence will be prepared and submitted to the City of Carmel-by-the-Sea Community Planning and Building Department and no further mitigation is required.

If bumble bee nests are detected and the area can be avoided, a qualified biologist shall supervise the installation of protective fencing/flagging a minimum of 50 feet around the nest area prior to construction. The fencing/flagging will be checked at least once per week until construction is complete to ensure that the protective fencing/flagging remains intact. The qualified biologist can conduct the weekly checks or train a biological monitor selected from the construction crew by the construction contractor (typically the project foreman) to check the fencing/flagging and provide weekly updates.

Documentation of the fencing/flagging installation shall be provided to the City of Carmel-by-the-Sea Community Planning and Building Department prior to the start of ground disturbance activities. Documentation of the weekly checks and timely maintenance (if needed) shall be provided to the City of Carmel-by-the-Sea Community Planning and Building Department quarterly during construction.

If bumble bee nests are detected and the area cannot be avoided, the qualified biologist shall coordinate with the California Department of Fish and Wildlife to determine the appropriate method of relocation or eviction of the nests.

After it has been confirmed that the habitat area is no longer occupied, a letter report will be prepared by the qualified biologist and submitted to the City of Carmel-by-the-Sea Community Planning and Building Department.

Attachment 2
Mitigated Negative Declaration 4 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update February 20, 2024 BIO-4 Approximately 14 days prior to tree removal or construction activities, a qualified biologist shall conduct a habitat assessment for bats and potential roosting sites in trees to be removed in trees within 50 feet of the construction easement. These surveys shall include a visual inspection of potential roosting features (bats need not be present) and a search for presence of guano within the housing site, construction access routes, and 50 feet around these areas. Cavities, crevices, exfoliating bark, and bark fissures that could provide suitable potential nest or roost habitat for bats shall be surveyed. Assumptions can be made on what species is present due to observed visual characteristics along with habitat use, or the bats can be identified to the species level with the use of a bat echolocation detector such as an “Anabat” unit. Potential roosting features found during the survey shall be flagged or marked.

If no roosting sites or bats are found, a letter report confirming absence shall be prepared and submitted to the Carmel-by-the-Sea Community Planning and Building Department and no further mitigation is required. If bats or roosting sites are found, bats shall not be disturbed without specific notice to and consultation with the California Department of Fish and Wildlife.

If bats are found roosting outside of the nursery season (May 1 through October 1), the California Department of Fish and Wildlife shall be consulted prior to any eviction or other action. If avoidance or postponement is not feasible, a Bat Eviction Plan will be submitted to the California Department of Fish and Wildlife for written approval prior to project implementation. A request to evict bats from a roost includes details for excluding bats from the roost site and monitoring to ensure that all bats have exited the roost prior to the start of activity and are unable to re-enter the roost until activity is completed. Any bat eviction shall be timed to avoid lactation and young-rearing. If bats are found roosting during the nursery season, they shall be monitored to determine if the roost site is a maternal roost. This could occur by either visual inspection of the roost bat pups, if possible, or by monitoring the roost after the adults leave for the night to listen for bat pups. Because bat pups cannot leave the roost until they are mature enough, eviction of a maternal roost cannot occur during the nursery season. Therefore, if a maternal roost is present, a 50-foot buffer zone (or different size if determined in consultation with the California Department of Fish and Wildlife) shall be established around the roosting site within which no construction activities including tree removal or structure disturbance shall occur until after the nursery season. Once the absence of roosting bats has been confirmed, a letter report will be prepared and submitted to the City of Carmel-by-theSea Community Planning and Building Department.

BIO-5 To avoid impacts to nesting birds during the nesting season (February 1 through September 15), construction activities within or adjacent to any housing site that includes any vegetation removal or ground disturbance (such as grading or trenching) shall be conducted between September 16 and January 31, which is outside of the bird nesting season. If construction activities must commence during the bird nesting season, then a qualified biologist shall conduct a pre-construction survey for nesting birds to ensure that no nests would be disturbed during construction.

Attachment 2
Mitigated Negative Declaration 5 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update February 20, 2024 a. Two surveys for active nests of birds shall occur within 7 days prior to start of construction, with the second survey conducted within 48 hours prior to start of construction. Appropriate minimum survey radius surrounding the work area is typically 250 feet for passerines, 500 feet for smaller raptors, and 1,000 feet for larger raptors. Surveys shall be conducted at the appropriate times of day to observe nesting activities. Individual project developers shall submit evidence of completion of the pre-construction surveys to the City of Carmel-by-the-Sea Community Planning and Building Department prior to initiation of ground disturbing activities. b. If the qualified biologist documents active nests within individual housing site boundaries, an appropriate buffer between each nest and active construction shall be established. The buffer shall be clearly marked and maintained until the young have fledged and are foraging independently. Prior to construction, the qualified biologist shall conduct baseline monitoring of each nest to characterize “normal” bird behavior and establish a buffer distance, which allows the birds to exhibit normal behavior. The qualified biologist shall monitor the nesting birds daily during construction activities and increase the buffer if birds show signs of unusual or distressed behavior (e.g., defensive flights and vocalizations, standing up from a brooding position, and/or flying away from the nest). If buffer establishment is not possible, the qualified biologist shall have the authority to cease all construction work in the area until the young have fledged and the nest is no longer active. This measure shall be implemented by the individual project developers prior to initiation of ground disturbing activities. Once the absence of nesting birds has been confirmed, a letter report will be prepared and submitted to the City of Carmel-bythe-Sea Community Planning and Building Department prior to disturbance of the nest area.

Geology and Soils
GEO-1 The following language shall be included on all grading permits: “If paleontological resources are discovered during demolition and earthmoving activities, work shall stop within 100 feet of the find until a qualified paleontologist can assess if the find is unique and, if necessary, develop appropriate treatment measures in consultation with the City’s Community Planning and Building Department.”
Attachment 2
Mitigated Negative Declaration 6 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update February 20, 2024 This side intentionally left blank.

Attachment 2
This document was produced on recycled paper.

INITIAL STUDY

CITY OF CARMEL-BY-THE-SEA
6 TH CYCLE HOUSING ELEMENT UPDATE
(2023-2031) AND SAFETY ELEMENT UPDATE

PREPARED FOR
City of Carmel-by-the-Sea
Marnie R. Waffle, AICP, Principal Planner
City Hall, PO Box CC
Carmel-by-the-Sea, 93921
Tel 831.620.2057
[email protected]

TABLE OF CONTENTS
A. BACKGROUND..................................................................................................................... 1 B. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED............................................... 9 C. DETERMINATION.............................................................................................................. 10 D. EVALUATION OF ENVIRONMENTAL IMPACTS ............................................................. 11

1. Aesthetics.............................................................................................................................. 12

2. Agriculture and Forest Resources...................................................................................... 16

3. Air Quality............................................................................................................................. 18

4. Biological Resources ............................................................................................................ 24

5. Cultural Resources ............................................................................................................... 41

6. Energy.................................................................................................................................... 43

7. Geology and Soils ................................................................................................................ 46

8. Greenhouse Gas Emissions ............................................................................................... 50

9. Hazards and Hazardous Materials..................................................................................... 54

10. Hydrology and Water Quality ............................................................................................ 57

11. Land Use and Planning ....................................................................................................... 63

12. Mineral Resources................................................................................................................ 65

13. Noise...................................................................................................................................... 66

14. Population and Housing ..................................................................................................... 69

15. Public Services...................................................................................................................... 70

16. Recreation ............................................................................................................................. 72

17. Transportation ...................................................................................................................... 73

18. Tribal Cultural Resources ................................................................................................... 76

19. Utilities and Service Systems.............................................................................................. 77

20. Wildfire .................................................................................................................................. 80

21. Mandatory Findings of Significance .................................................................................. 82 E. SOURCES............................................................................................................................. 84 Attachment 2
EMC Planning Group Inc.

Appendices
Appendix A 6th Cycle Housing Element Update (2023-2031) Housing and Community Development Revised Draft (January 24, 2024)
Appendix B Review of Environmental Safety Element for Compliance with Recent State Legislation (August 25, 2023)
Appendix C CalEEMod Results
Appendix D Special-Status Species in the Vicinity of the Housing Sites Appendix E Monterey Peninsula Water Management District’s Technical Memorandum (June 1, 2023)
Figures
Figure 1 Location Map .................................................................................................................... 5 Figure 2 Housing Sites Inventory Locations ................................................................................ 7 Figure 3 Special-Status Plant Species with Potential to Occur in the Vicinity of a Housing Site .................................................................................................................... 27 Figure 4 Special-Status Wildlife Species with Potential to Occur in the Vicinity of a Housing Site .................................................................................................................... 29 Figure 5 National Wetlands Inventory Map ............................................................................... 37 Tables
Table 1 Regional Housing Needs Allocation .............................................................................. 2 Table 2 Project Characteristics.................................................................................................... 19 Table 3 Unmitigated Operational Criteria Air Pollutant Emissions...................................... 21 Table 4 Non-Mobile Unmitigated Operational GHG Emissions ......................................... 52 Attachment 2
Section A Background 1 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 A. BACKGROUND
Setting
The City of Carmel-by-the-Sea is located in Monterey County on the south side of the Monterey Bay. It is approximately one square mile in size and is almost entirely built out. Carmel-by-the-Sea is surrounded by the community of Pebble Beach and cities of Pacific Grove, Monterey, Sand City, and Seaside to the north, unincorporated Monterey County, State Route 1 and Jacks Peak to the east, the Pacific Ocean to the west, and unincorporated Monterey County, Point Lobos State Natural Reserve, and Big Sur to the south. Carmel-by-the-Sea’s topography ranges from sea level at the Pacific Ocean to approximately 500 feet above sea level at the city limits west of State Route 1. Key access points to Carmel-by-the-Sea include Ocean Avenue, Carpenter Street, Rio Road and the Pebble Beach Gate. State Route 1, located east of and outside of the Carmel-bythe-Sea city limits, provides the primary access to each of these key access points except for the Pebble Beach Gate. State Route 1 is the main roadway linking Carmel-by-the-Sea to Santa Cruz and the northern Monterey Bay region, as well as to Big Sur and south Monterey County.

Figure 1, Location Map, presents the relationship between the City of Carmel-by-the-Sea and nearby cities and unincorporated Monterey County, as well as the state highway system.

Project Title City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety
Element Update
Lead Agency Contact Person
and Phone Number
Marnie R. Waffle, AICP, Principal Planner
831-620-2057
Date Prepared February 20, 2024
Study Prepared by EMC Planning Group Inc.
601 Abrego Street
Monterey, CA 93940
Project Location City of Carmel-by-the-Sea
Project Sponsor Name and Address City of Carmel-by-the-Sea City Hall, PO Box CC
Carmel-by-the-Sea, 93921
General Plan Designation Various
Zoning Various
Attachment 2
Section A Background 2 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Background
Housing Element Update
The City of Carmel-by-the-Sea (City) has prepared a draft 6th Cycle Housing Element that covers the planning period 2023 through 2031 consistent with the requirements under California state law. Updating the Housing Element requires that the City identify adequate housing sites to accommodate the Regional Housing Needs Allocation (RHNA) assigned to the City by the California Department of Housing and Development (HCD) and the Association of Monterey Bay Area Governments (AMBAG). The RHNA identified for the City’s 6th Cycle Housing Element is 349 units, and is presented in Table 1 below.

Table 1 Regional Housing Needs Allocation
Income Group Percentage of Area Median Income (AMI) Share Extremely Low Income1 <30 57
Very Low Income <50 56
Low Income 51-80 74
Moderate Income 81-120 44
Above Moderate Income 121 + 118
Total 349
SOURCE: AMBAG
NOTE: Extremely low-income RHNA is found as a subset within the very low-income category for all other tables in this document.

The City’s 6th Cycle Housing Element Update (2023-2031) Housing and Community Development (HCD) Revised Draft (dated January 24, 2024) can be found in Appendix A.

Safety Element Update
The City is in the process of preparing an update to its City of Carmel-by-the-Sea General Plan/Coastal Land Use Plan - Environmental Safety Element (hereafter referred to as the City’s “Safety Element”).

Since the latest Safety Element update in 2009, several pieces of legislature have been passed.

Therefore, the Safety Element update includes, but is not limited to:
 Updates to the Geology and Seismic Hazards and Evacuation Routes;  Updates to mapping and figures;
 Updates to State Fire and Building Code language;
 Updates to fire severity zone maps reflecting the California Department of Forestry and Fire maps; and
 Updates to reflect any applicable federal, state, or local laws relating to hazardous materials since 2009.

Details about the updates required for the Safety Element can be found in the memorandum dated August 25, 2023 found in Appendix B.

Attachment 2
Section A Background 3 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Description of Project
The project includes the update to the City’s 6th Cycle Housing Element Update (2023-2031) Housing and Community Development (HCD) Revised Draft (dated January 24, 2024) (“Housing Element Update”) and the update to the City’s Safety Element (together, the “proposed project”). The proposed project requires these updates in order to comply with the state’s housing goals set forth in the Government Code as well as updated legislature associated with safety hazards. The adoption of these two element updates would be an amendment to the City’s General Plan/Coastal Land Use Program (General Plan).

It is not expected that the updates to the City’s Safety Element would result in any physical changes. Therefore, this initial study will focus primarily on the physical changes of the Housing Element Update and include analysis of the Safety Element update as appropriate.

The Housing Element Update includes 410 housing units, which is approximately 17 percent more than the RHNA of 349 units. Table C-3 within Appendix C of the Housing Element Update provides details and capacity estimates for each of the parcels that comprise the City’s housing sites inventory. Figure 2, Housing Sites Inventory Locations, shows an overview of the proposed sites inventory map. Using 1.79 persons per household, development of these housing units would result in a population increase of approximately 734 people (California Department of Finance 2023). The Housing Element Update includes goals, policies, and programs to support public and/or private development of 410 housing units.

The City does not anticipate that future housing projects proposed on sites with existing commercial/office uses would also result in expanded building square footage for such uses.

Consequently, no increase in existing commercial/office building square footage is expected to occur with implementation of the Housing Element Update.

Other Public Agencies Whose Approval May Be Required
 California Department of Fish and Wildlife
Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.?
The City sent letters to Native American tribes traditionally and culturally affiliated with the City of Carmel-by-the-Sea on March 9, 2023 asking if any request AB 52 or SB 18 consultation. The City received one response from the Esselen Tribe of Monterey County on March 12, 2023 requesting consultation and the City has met with the tribal leader in person and been in communication via email with other leaders of the Tribe. The City has continued their efforts to consult and meet with the Tribe since late May 2023, with no response back from the Tribe as of February 15, 2024 (Marnie Waffle, email message, February 15, 2024).

Attachment 2
Section A Background 4 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Note: Conducting consultation early in the CEQA process allows tribal governments, lead agencies, and project proponents to discuss the level of environmental review, identify and address potential adverse impacts to tribal cultural resources, and reduce the potential for delay and conflict in the environmental review process. (See Public Resources Code section 21080.3.2.) Information may also be available from the California Native American Heritage Commission’s Sacred Lands File per Public Resources Code section 5097.96 and the California Historical Resources Information System administered by the California Office of Historic Preservation. Please also note that Public Resources Code section 21082.3(c) contains provisions specific to confidentiality.

Attachment 2
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UV1
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Peak
Seaside
Sand
City
Source: ESRI 2023
Figure 1
Location Map
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study
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Attachment 2
Section A Background 6 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 This side intentionally left blank.

Attachment 2
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7th Ave.
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13th Ave.

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Housing Sites Inventory Locations
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study
0 1050 feet
Figure 2
Source: Monterey County GIS 2023, Google Earth 2023 Site Inventory Parcels City Limit
7 8
1 2
3 4 5
6 9
10 11
12 13 14
15 16
17 18
19 20
22 21
23 24
25 Attachment 2
Section A Background 8 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 This side intentionally left blank.

Attachment 2
Section B Environmental Factors Potentially Affected 9 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 B. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following pages.
☐ Aesthetics ☐ Greenhouse Gas Emissions ☐ Public Services ☐ Agriculture and Forestry
Resources
☐ Hazards & Hazardous
Materials
☐ Recreation
☐ Air Quality ☐ Hydrology/Water Quality ☐ Transportation ☐ Biological Resources ☐ Land Use/Planning ☐ Tribal Cultural Resources ☐ Cultural Resources ☐ Mineral Resources ☐ Utilities/Service Systems ☐ Energy ☐ Noise ☐ Wildfire
☐ Geology/Soils ☐ Population/Housing ☐ Mandatory Findings of Significance
Attachment 2
Section C Determination 10 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 C. DETERMINATION
On the basis of this initial evaluation:
☐ I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
☒ I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
☐ I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
☐ I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.
☐ I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (1) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (2) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Marnie Waffle, AICP, Principal Planner Date
Attachment 2
Section D Evaluation of Environmental Impacts 11 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 D. EVALUATION OF ENVIRONMENTAL IMPACTS
Notes

1. All answers take account of the whole action involved, including off-site as well as onsite, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.

2. Once it has been determined that a particular physical impact may occur, then the checklist answers indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that an effect may be significant. If there are one or more “Potentially Significant Impact” entries when the determination is made, an EIR is required.

3. “Negative Declaration: Less-Than-Significant Impact with Mitigation Measures Incorporated” applies where the incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less-Than-Significant Impact.” The lead agency must describe the mitigation measures and briefly explain how they reduce the effect to a less-than-significant level (mitigation measures from section XVII, “Earlier Analyses,” may be cross-referenced).

4. Earlier analyses are used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. [Section 15063(c)(3)(D)] In this case, a brief discussion would identify the following:
a. “Earlier Analysis Used” identifies and states where such document is available for review.
b. “Impact Adequately Addressed” identifies which effects from the checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and states whether such effects were addressed by mitigation measures based on the earlier analysis.
c. “Mitigation Measures”—For effects that are “Less-Than-Significant Impact with Mitigation Measures Incorporated,” mitigation measures are described which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.

5. Checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances, etc.) are incorporated. Each reference to a previously prepared or outside document, where appropriate, includes a reference to the page or pages where the statement is substantiated.

6. “Supporting Information Sources”—A source list is attached, and other sources used or individuals contacted are cited in the discussion.

7. The explanation of each issue identifies:
a. The significance criteria or threshold, if any, used to evaluate each question; and b. The mitigation measure identified, if any to reduce the impact to less than significant.

Attachment 2
Section D Evaluation of Environmental Impacts 12 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

1. AESTHETICS
Except as provided in Public Resources Code Section 21099 (Modernization of Transportation Analysis for Transit-Oriented Infill Projects), would the project:

Comments:
a. The City’s General Plan does not specifically identify a scenic vista; however, Carmel-bythe-Sea is known for its renowned scenic environment consisting of the coastline and the central ride of wooded hills. The preservation of these two features is imperative if the scenic character of the Peninsula is to be maintained (City of Carmel-by-the-Sea 2003, p. I-12).

This analysis focuses on the redevelopment of properties with new housing of greater scale and increased height that could result in potentially adverse effects on views of the ocean and wooded hillsides of Carmel-by-the-Sea. The proposed housing sites are primarily located within the developed, commercial areas of Carmel-by-the-Sea, a minimum of 1,800 feet from the ocean. Refer to Figure 2. Therefore, development of residential uses in these areas would not result in an adverse impact to the coastline.

The housing sites are scattered throughout Carmel-by-the-Sea encompassing areas zoned Single-family Residential (R-1), Multi-family Residential (R-4), Central Commercial (CC), Service Commercial (SC), and Residential and Limited Commercial (RC). City Municipal Code Section 17.14.150 states that the main building and roof form for all structures within the CC and SC districts shall be limited to a maximum of 30 feet whereas the main building and roof form for all structures within the RC and R-4 districts shall be limited to a maximum of 26 feet. Table 17.10-C of the City Municipal Code requires a 24-foot height standard for structures within the R-1 district.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Have a substantial adverse effect on a scenic vista? ☐ ☐ ☒ ☐ b. Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic
buildings within a state scenic highway?
☐ ☐ ☐ ☒
c. In non-urbanized areas, substantially degrade the
existing visual character or quality of public views of the site and its surroundings? (Public views are those
that are experienced from publicly accessible vantage
points.) If the project is in an urbanized area, would
the project conflict with applicable zoning and other
regulations governing scenic quality?
☐ ☐ ☐ ☒
d. Create a new source of substantial light or glare, which would adversely affect day or nighttime views in the
area?
☐ ☐ ☒ ☐
Attachment 2
Section D Evaluation of Environmental Impacts 13 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Section 17.10.010.D of the City Municipal Code requires that residential buildings shall not present excess visual mass or bulk to public view or to adjoining properties.

Designing buildings so that floor levels and plate heights are close to grade help reduce mass and bulk and the use of natural materials, such as wood or stone, and the creative use of landscaping can also help avoid excess mass. Section 17.10.010.E requires that buildings relate to a human scale in their forms, elements, and in the detailing of doors, windows, roofs, and walkways.

The proposed project does not include specific development; therefore, future individual development will be required to comply with the abovementioned City Municipal Code sections associated with scale and height to ensure that the proposed structures do not have a substantial adverse effect on views of the wooded hillsides of Carmel-by-the-Sea. b. According to the California Department of Transportation’s California State Scenic Highway System Map, the portion of State Route 1 east of the city limits, is officially designated as a state scenic highway (California Department of Transportation 2023).

The City’s General Plan does not specifically identify any scenic resources. However, Carmel-by-the-Sea is known for its abundance of trees, which are scattered throughout the city, as well as along the western border of State Route 1. According to Monterey County’s Carmel Area Land Use Plan, the existing forested corridor along Highway 1 shall be maintained as a scenic resource and natural screen for existing and new development (Monterey County 1983, p. 27). Further, views of the ocean and beach bluffs can be considered scenic resources of the City.

Development of the housing sites identified within the Housing Element Update are not located within State Route 1 and would not be visible to travelers on State Route 1, as the nearest housing site is located approximately 1,400 feet from the highway, and the area between the highway and the nearest housing site is developed with houses and significant tree cover. Development of the housing sites would not damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway.
c. All of the housing sites are located within the Carmel-by-the-Sea city limits and, therefore, are located within a developed area. Implementation of the Housing Element Update would include the reuse of existing development lands and infill development on vacant parcels to meet the housing needs of the growing community. New development associated with the housing sites would not substantially degrade the visual character or quality of the City by complying with existing design guidelines. The housing sites are located in both residential and commercial zoning districts within the city. Therefore, the design guidelines outlined in the Residential Design Guidelines and the Downtown Design Guidelines would apply.

The housing sites would also be required to comply with applicable General Plan policies such as Land Use Policy P1-27, which requires that development (commercial or residential) does not diminish the village character by excessively blocking important Attachment 2
Section D Evaluation of Environmental Impacts 14 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 public or private views and disturbing natural topography, mature trees, or native growth; Land Use Policy P1-37, which requires design review for new homes and second story additions in the residential district, for exterior remodeling that significantly affects the character or appearance of structures, and sites in the R-1 Zoning District; and Land Use Policy P1-39, which requires that site improvements be compatible with, and sensitive to, the natural features and built environment of the site and of the surrounding area.

Consistency of new development with the City’s design and development standards and General Plan policies would be ensured by the City as part of the development review process for individual projects proposed on the housing sites. Therefore, the project would have no impact from conflict with applicable zoning and other regulations governing scenic quality.
d. Most of the housing sites developed with uses include lighting of one or more types and intensities (e.g., building lighting, landscape lighting, safety lighting, pathway and parking lot lighting, etc.). New development at the housing sites would include lighting of similar types and intensities, and must conform to the City’s Residential Design Guidelines and the Downtown Design Guidelines associated with light and glare.

As part of the City’s development review process, each new development at the housing sites would be required to provide lighting plans. As part of that process, the City would review the plans to ensure that lighting is designed to be properly shielded, does not cause significant illumination of off-site properties, and is no more intense than needed for the specific lighting application.

Because new development would occur on some sites that are already developed with uses that include lighting, lighting for new development would be similar in character as that on existing developed sites. Residential development on vacant sites would be compatible to existing, adjacent residential development and would comply with the regulations associated with lighting in the City’s Residential Design Guidelines.

Compliance with the City’s Residential and Downtown Design Guidelines and development review process, in addition to the below standard condition of approval, would ensure that development of the housing sites would not create a significant level of new light or glare, which would adversely affect day or nighttime views in the area.

Standard Condition of Approval
The following Carmel-by-the-Sea standard conditions of approval would apply to projects that implement the Housing Element Update.

11. Prior to the issuance of a building permit, the Applicant shall include in the construction drawings the manufacturer’s specifications, including illumination information, for all exterior light fixtures. All fixtures shall be shielded and downfacing.

Attachment 2
Section D Evaluation of Environmental Impacts 15 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Exterior wall-mounted lighting shall be limited to 25 watts or less (incandescent equivalent or 375 lumens) per fixture and shall be installed no higher than 10 feet above the ground or walking surface.

Landscape lighting shall not exceed 18 inches above the ground nor more than 15 watts (incandescent equivalent or 225 lumens) per fixture and shall be spaced no closer than 10 feet apart. Landscape lighting shall not be used as accent lighting, nor shall it be used to illuminate trees, walls, or fences. The purpose of landscape lighting is to safely illuminate walkways and entrances to the subject property and outdoor living spaces.

Attachment 2
Section D Evaluation of Environmental Impacts 16 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

2. AGRICULTURE AND FOREST RESOURCES
In determining whether impacts on agricultural resources are significant environmental effects and in assessing impacts on agriculture and farmland, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:

Comments:
a. There are no agricultural lands within the city limits of Carmel-by-the-Sea (City of Carmel-by-the-Sea 2009, Open Space and Conservation Element – p. 7-24). Therefore, development on any of the housing sites on the inventory list would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) to nonagricultural use.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the
California Resources Agency, to nonagricultural use?
☐ ☐ ☐ ☒
b. Conflict with existing zoning for agricultural use, or a Williamson Act contract? ☐ ☐ ☐ ☒
c. Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
section 12220(g)), timberland (as defined by Public
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g))?
☐ ☐ ☐ ☒
d. Result in the loss of forest land or conversion of
forest land to non-forest use? ☐ ☐ ☐ ☒
e. Involve other changes in the existing environment
which, due to their location or nature, could result in conversion of Farmland to nonagricultural use or
conversion of forest land to non-forest use?
☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 17 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 b. There are no agricultural lands within the city limits of Carmel-by-the-Sea (City of Carmel-by-the-Sea 2009, Open Space and Conservation Element – p. 7-24). Therefore, development on any of the housing sites on the inventory list would not conflict with existing zoning for agricultural use, or a Williamson Act contract. c. There are no forest lands within the City of Carmel-by-the-Sea as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g). Therefore, development on any of the housing sites on the inventory list would not conflict with existing zoning, or cause rezoning of, forest land, timberland, or timberland zoned Timberland Production.
d. There are no forest lands within the City of Carmel-by-the-Sea; therefore, development on any of the housing sites on the inventory list would not result in the loss of forest land or conversion of forest land to non-forest use.
e. There are no agricultural lands within the city limits of Carmel-by-the-Sea (City of Carmel-by-the-Sea 2009, Open Space and Conservation Element – p. 7-24) and there are no forest lands within the City. Therefore, development on any of the housing sites on the inventory list would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to nonagricultural use or conversion of forest land to non-forest use.

Attachment 2
Section D Evaluation of Environmental Impacts 18 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

3. AIR QUALITY
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.

Would the project:

The City of Carmel-by-the-Sea is located in the North Central Coast Air Basin, which is under the jurisdiction of the Monterey Bay Air Resources District (“air district”), formerly known as the Monterey Bay Unified Air Pollution Control District. The air district has regulatory authority over stationary sources of air emissions, monitoring air quality within the air basin, providing guidelines for analysis of air quality impacts pursuant to CEQA, and preparing an air quality management plan to maintain or improve air quality in the air basin. The air district has developed thresholds of significance for criteria air pollutants. These are contained in the CEQA Air Quality Guidelines (“CEQA Guidelines”) (Monterey Bay Unified Air Pollution Control District 2008). The 2012-2015 Air Quality Management Plan (air quality plan) was adopted by the air district in March 2017. This remains the currently adopted plan. The discussion in this section is based primarily on the air district’s CEQA guidelines and the air quality plan, as well as the results of emissions modeling using the California Emission Estimation Model (CalEEMod) version 2022.1.

The “unmitigated” emissions scenario provides estimates of the criteria air pollutant emissions that would be generated during construction and operation of new housing development that would occur with implementing the Housing Element Update. The CalEEMod results in Appendix C are also used to inform the energy and greenhouse gas (GHG) analyses discussed in Section 6.0, Energy, and Section 8.0, Greenhouse Gas Emissions, of this report. Data inputs to the model take into account the type and density of proposed residential uses utilizing CalEEMod default land uses number of housing units accommodated by the Housing Element Update) as presented in Table 2, Project Characteristics.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Conflict with or obstruct implementation of the
applicable air quality plan? ☐ ☐ ☒ ☐
b. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is
nonattainment under an applicable federal or state
ambient air quality standard?
☐ ☐ ☒ ☐
c. Expose sensitive receptors to substantial pollutant
concentrations? ☐ ☒ ☐ ☐
d. Result in other emissions, such as those leading to
odors adversely affecting a substantial number of
people?
☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 19 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Table 2 Project Characteristics
Project Component Land Use Subtype1,2 Proposed3
Residential Units Apartments Mid Rise 410
SOURCE: CalEEMod version 2022.1, Housing and Community Development (HCD) Initial Draft 6th Cycle Housing Element Update (2023-2031) City of Carmel-by-the-Sea, August 1, 2023.

NOTES:

1. CalEEMod default land use subtype. Descriptions of the model default land use categories and subtypes are found in the User’s Guide for CalEEMod Version 2022.1 available online at: https://caleemod.com/documents/user-guide/01_User%20Guide.pdf.

2. Apartment Mid Rise CalEEMod Land use subtype default housing density is up to 38 dwelling units per acre as identified in Table 2, Default Housing Density, found in the User’s Guide for CalEEMod Version 2022.1.

3. Residential housing unit capacity identified in Table C-3, Housing Sites Inventory, of Appendix C, Housing Sites Inventory Analysis, from the Housing and Community Development (HCD) Initial Draft 6th Cycle Housing Element Update (2023-2031) City of Carmel-by-the-Sea, at an applied density of 20- 33 dwelling units per acre.

Other data inputs to CalEEMod are based on the following primary assumptions:
 Construction start date will be January 2024;
 Operational emissions are estimated for the year of 2031;  New residential development on existing developed sites will not result in a loss of existing residential or non-residential uses on such sites;
 Residential development density will range between 20-33 dwelling units per acre;  All construction related worker, vendor, and hauling travel will take place on paved roads; and
 Daily vehicle trip rates are consistent with Multifamily Housing (Mid-Rise) as described in Table 1, Trip Generation Evaluation, of the Carmel Housing Element Update VMT Analysis (Hexagon Transportation Consultants, Inc. 2023).

Comments:
a. An air quality plan consistency determination is a process by which the Lead Agency demonstrates that the population associated with new proposed housing is accommodated by the Association of Monterey Bay Area Governments (“AMBAG”) regional growth forecasts as reflected in the air quality plan. Projects related directly to population growth generate population-related emissions (e.g., motor vehicles, residential heating, and cooling emissions). Population-related emissions have been estimated in the air quality plan; population-related projects that are consistent with these forecasts are consistent with the plan. The air district uses consistency with the air quality plan to determine a project’s cumulative impact on regional air quality under CEQA. The air district has established a consistency determination procedure tied to population growth – a project that does not result in an increase in population beyond that projected by AMBAG is considered not to conflict with the air quality management plan.

Attachment 2
Section D Evaluation of Environmental Impacts 20 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 The residential sites identified for the proposed project would be developed at densities ranging between 20-44 dwelling units per acre. The proposed project would accommodate 410 residential units at a persons per household rate of approximately 1.79, for an estimated population increase of 734 people (refer also to the discussion in Section

14.0, Population and Housing). The most recent growth projections for the City of Carmel-by-the-Sea are in the 2022 Regional Growth Forecast, Attachment 2: Final Draft 2022 Subregional Growth Forecast AMBAG Region and Jurisdictions (AMBAG 2022).

The forecast shows a 2020 population of 3,949, a projected 2025 population of 3,946, and a 2030 projected population of 3,954 for the city. The population increase of 734 would exceed the population projections upon which the air quality management emissions forecasts are based. Despite this conflict with the air quality plan, the proposed project would not result in significant impacts to air quality, as further detailed in “b” through “d” below. Therefore, the conflict would not result in a significant air quality impact.
b. The six most common and widespread air pollutants of concern, or “criteria pollutants,” are ground-level ozone, nitrogen dioxide, particulate matter, carbon monoxide, sulfur dioxide, and lead. In addition, reactive organic gases, also referred to as volatile organic gases (VOC), are a key contributor to the criteria air pollutants because they react with other substances to form ground-level ozone. Health effects of from prolonged exposures to criteria air pollutants include asthma, bronchitis, chest pain, coughing, and heart diseases.

The air district has primary responsibility for assuring that national and state ambient air quality standards are attained and maintained in the air basin. The air district is responsible for monitoring air quality in the air basin, which is designated under state criteria as a nonattainment area for ozone and suspended particulate matter (PM10).

Under federal criteria, the air basin is at attainment (8-hour standard) for ozone and particulates.

State standards are promulgated by the California Air Resources Board as mandated by the California Clean Air Act. The air district has developed criteria pollutant emissions thresholds, which are used to determine whether or not a proposed project would violate an air quality standard or contribute to an existing violation during operations and/or construction. The thresholds are noted in the following discussions of operational and construction air quality effects.

Operational Emissions
The proposed project would result in new sources of operational mobile and area source emissions. Emissions modeling undertaken to quantify cumulative criteria air pollutant emissions from operating 410 residential units shows that operational criteria air pollutant emissions would not exceed air district thresholds as shown in Table 3, Unmitigated Operational Criteria Air Pollutant Emissions. Detailed emissions modeling results are presented in Appendix C.

Attachment 2
Section D Evaluation of Environmental Impacts 21 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Table 3 Unmitigated Operational Criteria Air Pollutant Emissions Emissions
Volatile Organic
Compounds
(VOC)1,2
Nitrogen
Oxides
(NOx)1,2
Suspended
Particulate
Matter
(PM10)1,2
Carbon
Monoxide
(CO)1,2
Air District Thresholds 137 137 82 550
Project Emissions 14 6 7 32
Exceeds Thresholds? NO NO NO NO
SOURCE: EMC Planning Group 2023
NOTES: The modeling was conducted using 400 residential units. Because the project emissions are significantly below the thresholds, modeling was not updated with the increase in 10 units.

1. Results may vary due to rounding.

2. Expressed in pounds per day.

Air district CEQA Guidelines Table 5-4 show representative project types and sizes at which air district thresholds could be exceeded. Screening thresholds for residential developments, such as low-rise apartments (1,080 dwelling units) and condominium/townhouse projects (1,195 dwelling units) suggest, as confirmed by the modeling results presented above, that cumulative operational air emissions impacts from 410 new residential units constructed at similar densities would not exceed the thresholds.

The proposed project would not result in significant impacts to localized air quality and the project contribution to regional air quality impacts would be less-than-significant.

Construction Emissions
Emissions from construction activities represent temporary impacts that are typically short in duration, depending on the size, phasing, and type of project. Air quality impacts can, nevertheless, be acute during construction periods, resulting in significant localized impacts to air quality. Table 5-1, Thresholds of Significance Construction Impacts, of the air district CEQA guidelines summarizes the threshold of significance for construction activities. Construction emissions have the potential to significantly impact local air quality, or pose localized health risks. Localized health risks are discussed under item “c” of this section. Construction emissions include fugitive dust emissions generated during grading.

The air district CEQA guidelines report that construction projects using typical construction equipment such as dump trucks, scrappers, bulldozers, compactors and front-end loaders that temporarily emit ozone precursors such as VOCs or oxides of nitrogen (NOx), are accommodated in the emission inventories of State- and federallyrequired air plans and would not have a significant impact on the attainment and maintenance of ozone thresholds. Air district CEQA Guidelines Table 5-2, Construction Activity with Potentially Significant Impacts, identifies the level of construction activity that could result in significant temporary fugitive dust (PM10) impacts if not mitigated.

Grading and excavation activities that disturb more than 2.2 acres per day and construction activities with minimal earthmoving that disturb more than 8.1 acres per day are assumed to be above the 82 pounds of PM10 threshold of significance.

Attachment 2
Section D Evaluation of Environmental Impacts 22 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 The housing sites inventory included as Table C-3 within Appendix C of the Housing Element Update provides details and development capacity estimates for each of the sites that comprise the City’s proposed housing sites inventory. The largest of the sites is approximately 1.84 acres. Consequently, grading and/or excavation activities on any one site would not have potential to generate construction emissions that exceed air district thresholds. Associated construction air quality impacts would be less than significant. c. The proposed project has the potential to exposure sensitive receptors to localized health risks associated with toxic air contaminant (TAC) emissions from construction equipment exhaust emitted at individual housing site locations. TACs are pollutants that may be expected to result in an increase in mortality, serious illness, or may pose a present or potential hazard to human health at elevated concentrations and durations of exposure.

Health effects include cancer, birth defects, neurological damage, damage to the body's natural defense system, and diseases that lead to death. TACs are found in ambient air, especially in urban areas, and are caused by industry, agriculture, fuels combustion, and commercial operations (e.g., dry cleaners). Diesel exhaust is the predominant TAC in urban air and is estimated to represent about two-thirds of the cancer risk from TACs.

Diesel particulate matter (DPM) is the primary TAC of concern within diesel exhaust.

The primary community risk impact issues associated with construction exhaust emissions are cancer risk (DPM exposures) and exposure to PM2.5.

According to the air district’s CEQA guidelines, a sensitive receptor is generally defined as a location where there is reasonable expectation that human populations, especially children, seniors, and sick persons, could be continuously exposed to TACs. Typical sensitive receptors include residences, hospitals, and schools.

Operations of residential uses are not generally sources of TACs that would increase health risks. However, construction activities at each housing site could generate temporary and limited localized TAC emissions from diesel construction equipment. The air district recommends using best management practices during construction to reduce related diesel emissions. Additionally, emissions from diesel engines used in construction are subject to control under regulations adopted by both the California Air Resources Board and U.S. EPA. U.S. EPA promulgated new emission standards for off-road engines in 1998, with the California Air Resources Board adopting parallel standards in 2000. In 2004, Tier 4 emission standards were adopted and were phased in for new engines between 2011 and 2014. In 2007 CARB adopted an off-road equipment regulation to accelerate reductions of NOx and diesel PM from existing off-road engines.

Beginning in 2012 and through 2023, the off-road regulation requires operators of older equipment to either install abatement devices, upgrade to Tier 3 and eventually Tier 4 engines, or to retire older equipment.

Implementation of the following mitigation measure would ensure that the health risks from potential exposures to construction TAC emissions would be less than significant by requiring that best management practices be implemented to reduce emissions and to ensure compliance with diesel engine regulations designed to reduce diesel emissions.

Attachment 2
Section D Evaluation of Environmental Impacts 23 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Mitigation Measure
AQ-1 The developer shall prepare a Construction Management Plan for review and approval by the Community Development Director or his designate. The Construction Management Plan shall include the following measures to reduce TAC emissions during construction at individual project sites:
a. Heavy-duty diesel vehicles will have 2010 or newer model year engines, in compliance with the California Air Resources Board’s Truck and Bus Regulation; b. Idling of construction equipment and heavy-duty diesel trucks will be avoided where feasible, and if idling is necessary, it will not exceed three minutes; c. All construction equipment will be maintained and properly tuned in accordance with manufacturer’s specifications and will be checked by a certified visible emissions evaluator; and
d. All non-road diesel construction equipment will, at a minimum, meet Tier 3 emission standards listed in the Code of Federal Regulations Title 40, Part 89, Subpart B, §89.112. Further, where feasible, construction equipment will use alternative fuels such as compressed natural gas, propane, electricity or biodiesel. d. The most common sources of odors identified in complaints received by local air districts are sewage treatment plants, landfills, recycling facilities, waste transfer stations, petroleum refineries, biomass operations, autobody shops, coating operations, fiberglass manufacturing, foundries, rendering plants, and livestock operations. The proposed project would not produce these types or other significant objectionable odors that would adversely affect a substantial number of people (Monterey Bay Unified Air Pollution Control District Air Quality Guidelines, page 3-5). Therefore, there would be no impacts associated with odor.

Attachment 2
Section D Evaluation of Environmental Impacts 24 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

4. BIOLOGICAL RESOURCES
Would the project:

Comments:

This section evaluates the potential effects of the Housing Element Update on the biological resources present in the vicinity of the housing site locations. The Housing Element Update identifies all potential housing sites on vacant and developed lots within the city limits, away from wetlands, waterways, and open space. The Housing Element Update focuses on infill development and redevelopment in the already fully developed City of Carmel-by-the-Sea. This evaluation utilizes the federal, state, and regional/local regulatory framework pertaining to biological resources and anticipates impacts to biological resources as a result of the development Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Have a substantial adverse effect, either directly or through habitat modifications, on any species
identified as a candidate, sensitive, or special status species in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife
or US Fish and Wildlife Service?
☐ ☒ ☐ ☐
b. Have a substantial adverse effect on any riparian
habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or US
Fish and Wildlife Service?
☐ ☐ ☐ ☒
c. Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to,
marsh, vernal pool, coastal, etc.), through direct
removal, filing, hydrological interruption, or other
means?
☐ ☐ ☐ ☒
d. Interfere substantially with the movement of any
native resident or migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites?
☐ ☐ ☐ ☒
e. Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
☐ ☐ ☒ ☐
f. Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state habitat conservation plan?
☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 25 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 of the housing sites. This evaluation is a high-level analysis for the proposed Housing Element Update; specific, subsequent projects and their effects on biological resources are not fully known at this time. Accordingly, this analysis uses a high-level approach to evaluating potential impacts to sensitive biological resources that may result from implementation of the proposed project, corresponding with the conceptual level of project information available.

EMC Planning Group assessed the housing site locations shown on Figure 2, Housing Sites Inventory Locations, and reviewed biological resource database accounts, aerial photographs, technical background information, and policies applicable to projects located in Carmel-by-theSea. This included searching the U.S. Fish and Wildlife Service (USFWS) Endangered Species Database (USFWS 2023a), California Department of Fish and Wildlife (CDFW) California Natural Diversity Database (“CNDDB”, CDFW 2023a, CDFW 2023b), and California Native Plant Society (CNPS) Inventory of Rare and Endangered Plants (CNPS 2023) to identify special-status plants, wildlife, and habitats known to occur in the vicinity of the housing sites. A review of the U.S.

Fish and Wildlife Service’s National Wetlands Inventory (NWI) database was also conducted to identify jurisdictional aquatic features (wetlands, drainages, and/or riparian areas) on or adjacent to the housing sites (USFWS 2023b).

Environmental Setting. Areas surrounding the City of Carmel-by-the-Sea possess diverse natural resources that include coastal scrub and dunes along Carmel Beach, Monterey pine forest and arroyo willow riparian forest within Mission Trail Nature Preserve, and arroyo willow riparian forest along the Carmel River. A small stream in the northern portion of Carmel-by-theSea flows down Pescadero Canyon to the Pacific Ocean. Another small stream flows through Mission Trail Park before reaching the Carmel River. Carmel-by-the-Sea has nine formally designated park, open space, and recreational areas. Carmel-by-the-Sea is also within the coastal zone, the legislatively-defined area regulated under the Coastal Act, including both land and water areas along the length of the California coastline. All of the housing sites are therefore located within the coastal zone.

Environmentally Sensitive Habitat Areas (ESHAs) regulated by the Coastal Act located within Carmel-by-the-Sea include:
 The dune scrub of Carmel Beach, with a known occurrence of Tidestrom’s lupine (Lupinus tidestromii), a state- and federally-listed endangered species, and northern legless lizard (Anniella pulchra), a state species of special concern;  The Monterey pine forest and arroyo willow riparian forest in Mission Trail Nature Preserve, with known occurrences of special-status plant and wildlife species including Hickman’s onion (Allium hickmanii) and Monterey dusky-footed woodrat (Neotoma fuscipes luciana); and  The wildlife corridor, Monterey pine, arroyo willow riparian forest, and wet meadow habitat of Pescadero Canyon.

Plant and Wildlife Habitat. The City of Carmel-by-the-Sea is committed to conserving the biodiversity of all its native species. City plant and wildlife habitats within Carmel-by-the-Sea are diverse and include parks, vacant lots, streams, gardens, yards, and an abundance of deciduous and coniferous trees. City landscapes are inherently characterized by extreme habitat fragmentation. Habitat patches in the city core are isolated from each other by a matrix of built Attachment 2
Section D Evaluation of Environmental Impacts 26 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 environment making dispersal difficult, at least for poorly dispersing wildlife. Potential habitat on or adjacent to housing sites include gardens with a diverse variety of shrubs and trees. Vacant lots have disturbed, weedy vegetation. Carmel-by-the-Sea also has numerous street trees with Monterey pine (Pinus radiata), Monterey cypress (Hesperocyparis macrocarpa), and coast live oak (Quercus agrifolia) being the most common species. City-adapted wildlife found throughout Carmel-by-the-Sea include the California mule (blacktail) deer (Odocoileus hemionus californicus), coyote (Canis latrans), raccoon (Procyon lotor), Virginia opossum (Didelphis virginiana), striped skunk (Mephitis mephitis), and western gray squirrel (Sciurus griseus). Common bird species in Carmel-bythe-Sea include the western gull (Larus occidentalis), acorn woodpecker (Melanerpes formicivorus), chestnut-backed chickadee (Poecile rufescens), California scrub-jay (Aphelocoma californica), California towhee (Melozone crissalis), dark-eyed junco (Junco hyemalis), Anna’s hummingbird (Calypte anna), and raptors, such a red-shouldered hawk (Buteo lineatus) and red-tailed hawk (Buteo jamaicensis). a. Special-Status Species. Special-status species are those listed as Endangered, Threatened, or Rare, or as candidates for listing by the U.S. Fish and Wildlife Service and/or California Department of Fish and Wildlife; as Species of Special Concern or Fully Protected species by the California Department of Fish and Wildlife; or as Rare Plant Rank 1B or 2B species by California Native Plant Society. Appendix D, SpecialStatus Species in the Vicinity of the Housing Sites, presents tables with database search results, and lists special-status species documented within the vicinity of the housing sites, their listing status and suitable habitat description, and their potential to occur on the housing sites. Figure 3, Special-Status Plant Species with Potential to Occur in the Vicinity of a Housing Site, and Figure 4, Special-Status Wildlife Species with Potential to Occur in the Vicinity of a Housing Site, present maps of California Natural Diversity Database results.

The housing sites provide limited habitat for the special-status species reported on the California Natural Diversity Database as known to occur in or near the City of Carmelby-the-Sea. Areas that would provide more substantial habitat for special-status species are primarily located along the western coastal edge of the city and within the open spaces on the city’s southeastern boundary. Development facilitated by the Housing Element Update could impact individual trees and pockets of vegetation in the developed areas of the city. These trees and isolated pockets could provide habitat for nesting birds, roosting bats, monarch butterfly (Danaus plexippus), obscure bumble bee (Bombus caliginosus), and western bumble bee (Bombus occidentalis), the disturbance or potential loss of which would be considered a significant, adverse impact. Additional analysis of specialstatus species in the vicinity of the housing sites is included here.

Special-Status Plant Species. Fifty-one (51) special-status plant species that occur in the vicinity of the housing sites were assessed for their potential to occur and all species are considered unlikely to occur (Appendix D). No suitable habitat for special-status plant species recorded as occurring in the vicinity is expected at any of the housing sites. The special-status plant species in the vicinity are not adapted to disturbed or developed sites. Therefore, the proposed project would have no impact on special-status plant species.

Attachment 2
Monterey
pine
Monterey pine
Monterey pine
marsh
microseris
sandmat
manzanita
Jolon clarkia
Eastwood's
goldenbush
Kellogg's
horkelia
fragrant
fritillary
marsh
microseris
Yadon's
rein orchid
Yadon's
rein orchid Yadon's
rein orchid Hooker's
manzanita
Hickman's
onion
Hooker's
manzanita
Hickman's Hickman's onion
onion
Hickman's
onion
Toro
manzanita
Tidestrom's
lupine
Yadon's rein orchid
Hickman's
onion
Source: ESRI 2023, CNDDB 2023
Figure 3
Special-Status Plant Species
with Potential to Occur in the Vicinity of a Housing Site City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study
0 2,500 feet 1 Mile Buffer
City Limits
Housing Sites Inventory Parcels
Special Status Plants
Attachment 2
Section D Evaluation of Environmental Impacts 28 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 This side intentionally left blank.

Attachment 2
Monterey
shrew
obscure
bumble bee
western
bumble bee
steelhead
Monterey
shrew
globose
dune beetle
Northern
California
legless lizard
Northern
California
legless lizard
monarch butterfly
California
red-legged frog
California
red-legged
frog
Northern
California
legless lizard
California
red-legged
frog
Special-Status Wildlife Species
with Potential to Occur in the Vicinity of a Housing Site City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study
0 2,500 feet
Figure 4
Source: ESRI 2023, CNDDB 2023
1 Mile Buffer
City Limits
Housing Sites Inventory Parcels
Special Status Wildlife
Attachment 2
Section D Evaluation of Environmental Impacts 30 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 This side intentionally left blank.

Attachment 2
Section D Evaluation of Environmental Impacts 31 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Special-Status Wildlife Species. Thirty-one (31) special-status wildlife species that occur in the vicinity of the housing sites were assessed for their potential to occur on the housing sites and three species were determined to have the potential to occur: monarch butterfly, obscure bumble bee, and western bumble bee, as well as special-status bats, and nesting birds and raptors (Appendix D).

Monarch Butterfly. The Monarch butterfly is not officially listed under the California Endangered Species Act or the federal Endangered Species Act or considered a California Department of Fish and Wildlife Species of Special Concern; however, on December 15, 2020, the U.S. Fish and Wildlife Service announced that listing the monarch as endangered or threatened under the Endangered Species Act is warranted, but precluded by higher priority listing actions. The monarch is now considered a candidate for listing under the Endangered Species Act and will be reviewed by U.S. Fish and Wildlife Service annually until a listing decision is made. The California Department of Fish and Wildlife monitors overwintering colonies of this species because monarch populations in California have severely declined since the 1980s (Jepsen et al. 2017). The cause of this decline is thought to be loss of milkweed (Asclepias spp.) and nectar plants; loss and degradation of overwintering groves; and other stressors like disease, insecticides, and impacts of climate change (Jepsen et al. 2017). The monarch overwintering season is typically October to March.

Monarchs do not favor eucalyptus trees; however, most of the overwintering locations in California are within eucalyptus groves simply because of their abundance in coastal areas in the state (Jepsen et al. 2017). Within the vicinity of the housing sites, native trees that could be used by overwintering monarchs include eucalyptus, coast live oak, and coniferous forest (Jepsen et al. 2017). Eucalyptus and other coniferous trees may potentially be removed as a result of development housing sites. Removal or disturbance of monarch overwintering habitat is considered a significant impact. Implementation of Mitigation Measures BIO-1 and BIO-2, below, would reduce potential, significant impacts to monarch butterfly to less than significant.

Mitigation Measures
BIO-1 Worker Environmental Awareness Training. Prior to approval of a grading and/or building permit at a housing site, a qualified biologist shall conduct a training session for all construction personnel. At a minimum, the training shall include a description of special-status species potentially occurring in the housing site vicinity, including, but not limited to, monarch butterfly, obscure bumble bee, and western bumble bee. Their habitats, general measures that are being implemented to conserve species as they relate to the housing site, and the boundaries within which construction activities will occur will be explained.

Informational handouts with photographs clearly illustrating the species’ appearances shall be used in the training session. All new construction personnel shall undergo this mandatory environmental awareness training. Documentation of completion of this training shall be submitted to the City of Carmel-by-theSea Community Planning and Building Department prior to the start of ground disturbing activities.

Attachment 2
Section D Evaluation of Environmental Impacts 32 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 BIO-2 Monarch Butterfly Survey and Avoidance. During the late fall/early winter prior to initiation of ground disturbance, a winter monarch butterfly survey of trees on the housing site shall be conducted by a qualified biologist. Results of the survey shall be submitted to the City of Carmel-by-the-Sea Community Planning and Building Department upon completion. If the results of the survey do not identify any potential overwintering monarch butterflies on-site, no further mitigation is required. If overwintering monarchs are determined to use the site, the applicant shall avoid removal of trees used for overwintering by monarchs to the greatest extent feasible. If trees cannot be avoided, tree removal shall occur outside of the overwintering period (November through February) or until a qualified biologist has determined that overwintering monarchs are no longer using the site. Documentation of tree avoidance or absence of monarchs shall be submitted to the City of Carmel-by-the-Sea Community Planning and Building Department prior to tree removal.

Obscure Bumble Bee. In 2019, the obscure bumble bee was identified as a candidate species for endangered species listing under California Endangered Species Act (California Fish and Game Commission 2019). Although not yet formally listed, species identified as “candidate” require consideration during CEQA analyses. This species occurs along the Pacific Coast, from southern California to southern British Columbia, with scattered records from the east side of California’s Central Valley. The Obscure bumble bee inhabits open grassy coastal prairies and Coast Range meadows. Nesting occurs underground as well as above ground in abandoned bird nests. Males patrol circuits in search of mates. Obscure bumble bees require species that bloom and provide adequate nectar and pollen throughout the colony’s flight period from as early as February to late November.

Western Bumble Bee. In 2019, the western bumble bee was identified as a candidate species for an endangered species listing under California Endangered Species Act (California Fish and Game Commission 2019). Although not yet formally listed, species identified as “candidate” require consideration during CEQA analyses. Although formerly common throughout much of its range, populations from central California to southern British Columbia and west of the Sierra-Cascade Ranges have declined sharply since the late 1990s. Western bumble bees primarily nest in underground cavities such as abandoned burrows or other animal nests on open west-southwest slopes. General habitat requirements include meadows and grasslands with flowering plants, and they may be found in some natural areas within developed environments. Western bumble bees require species that bloom and provide adequate nectar and pollen throughout the colony’s flight period from as early as February to late November.

If the western bumble bee or obscure bumble bee is present on or adjacent to a housing site, construction activities could result in the loss or disturbance of the individual animals. This would be a significant adverse environmental impact. Implementation of Mitigation Measure BIO-1 presented above, which requires a training session on specialAttachment 2 Section D Evaluation of Environmental Impacts 33 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 status species potentially present on the construction site for all personnel and Mitigation Measure BIO-3 would reduce this potential, significant impact to a less-than-significant level.

Mitigation Measure
BIO-3 Bumble Bee Survey and Avoidance. During the optimal flight period for the obscure bumble bee and western bumble bee (April 1 – July 31) and prior to ground disturbance a qualified biologist shall conduct a pre-construction survey of small mammal burrows and thatched/bunch grasses for bumble bee nesting activity. If the survey results are negative (i.e., no bumble bee nesting activity observed), a letter report confirming absence will be prepared and submitted to the City of Carmel-by-the-Sea Community Planning and Building Department and no further mitigation is required.

Documentation of the fencing/flagging installation shall be provided to the City of Carmel-by-the-Sea Community Planning and Building Department prior to the start of ground disturbance activities. Documentation of the weekly checks and timely maintenance (if needed) shall be provided to the City of Carmel-bythe-Sea Community Planning and Building Department quarterly during construction.

Bats. Trees and/or buildings or structures on or adjacent to a housing site could provide roosting habitat for bats state-listed as species of special concern, including pallid bat (Antrozous pallidus) and Townsend's big-eared bat (Corynorhinus townsendii). Pallid bat prefers roosting in open, dry habitats with rocky areas. Townsend’s big-eared bat prefers roosting and nesting found in caves, tunnels, mines, and buildings. The distribution of bat species in the Carmel area is relatively unknown, however these species have been identified as occurring within ten miles of the housing sites (CNDDB 2023). Tree removal and construction activities at a housing site could result in the disturbance of roost and natal sites occupied by special-status bats on or adjacent to the housing site, if Attachment 2
Section D Evaluation of Environmental Impacts 34 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 present. Implementation of Mitigation Measures BIO-1 presented earlier, which requires a training session on special-status species potentially present on the construction site for all personnel and Mitigation Measure BIO-4 would reduce this potential, significant impact to special-status bats to a less-than-significant level.

Mitigation Measure
BIO-4 Approximately 14 days prior to tree removal or construction activities, a qualified biologist shall conduct a habitat assessment for bats and potential roosting sites in trees to be removed in trees within 50 feet of the construction easement. These surveys shall include a visual inspection of potential roosting features (bats need not be present) and a search for presence of guano within the housing site, construction access routes, and 50 feet around these areas.

Cavities, crevices, exfoliating bark, and bark fissures that could provide suitable potential nest or roost habitat for bats shall be surveyed. Assumptions can be made on what species is present due to observed visual characteristics along with habitat use, or the bats can be identified to the species level with the use of a bat echolocation detector such as an “Anabat” unit. Potential roosting features found during the survey shall be flagged or marked.

If bats are found roosting during the nursery season, they shall be monitored to determine if the roost site is a maternal roost. This could occur by either visual inspection of the roost bat pups, if possible, or by monitoring the roost after the adults leave for the night to listen for bat pups. Because bat pups cannot leave the roost until they are mature enough, eviction of a maternal roost cannot occur during the nursery season. Therefore, if a maternal roost is present, a 50- foot buffer zone (or different size if determined in consultation with the California Department of Fish and Wildlife) shall be established around the roosting site within which no construction activities including tree removal or structure disturbance shall occur until after the nursery season. Once the Attachment 2
Section D Evaluation of Environmental Impacts 35 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 absence of roosting bats has been confirmed, a letter report will be prepared and submitted to the City of Carmel-by-the-Sea Community Planning and Building Department.

Nesting Birds and Raptors. Various bird species may nest on or adjacent to the housing sites, including on buildings, on open ground, or in any type of vegetation. If nesting birds protected by state and federal regulations are present during soil-disturbing or construction activities, including vegetation removal and site preparation on housing sites, an individual project may directly result in loss of active nests, or indirectly result in nest abandonment and thereby cause loss of fertile eggs or nestlings. These impacts to nesting birds are considered significant adverse environmental impacts. Mitigation Measure BIO-1 presented earlier, which requires a training session on special-status species potentially present on the construction site for all personnel and Mitigation Measure BIO-5 would reduce this potential, significant impact to nesting birds and raptors to a less-than-significant level.

Mitigation Measure
BIO-5 To avoid impacts to nesting birds during the nesting season (February 1 through September 15), construction activities within or adjacent to any housing site that includes any vegetation removal or ground disturbance (such as grading or trenching) shall be conducted between September 16 and January 31, which is outside of the bird nesting season. If construction activities must commence during the bird nesting season, then a qualified biologist shall conduct a preconstruction survey for nesting birds to ensure that no nests would be disturbed during construction.
a. Two surveys for active nests of birds shall occur within 7 days prior to start of construction, with the second survey conducted within 48 hours prior to start of construction. Appropriate minimum survey radius surrounding the work area is typically 250 feet for passerines, 500 feet for smaller raptors, and 1,000 feet for larger raptors. Surveys shall be conducted at the appropriate times of day to observe nesting activities. Individual project developers shall submit evidence of completion of the pre-construction surveys to the City of Carmel-by-the-Sea Community Planning and Building Department prior to initiation of ground disturbing activities. b. If the qualified biologist documents active nests within individual housing site boundaries, an appropriate buffer between each nest and active construction shall be established. The buffer shall be clearly marked and maintained until the young have fledged and are foraging independently.

Prior to construction, the qualified biologist shall conduct baseline monitoring of each nest to characterize “normal” bird behavior and establish a buffer distance, which allows the birds to exhibit normal behavior. The qualified biologist shall monitor the nesting birds daily during construction activities and increase the buffer if birds show signs of Attachment 2
Section D Evaluation of Environmental Impacts 36 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 unusual or distressed behavior (e.g., defensive flights and vocalizations, standing up from a brooding position, and/or flying away from the nest). If buffer establishment is not possible, the qualified biologist shall have the authority to cease all construction work in the area until the young have fledged and the nest is no longer active. This measure shall be implemented by the individual project developers prior to initiation of ground disturbing activities. Once the absence of nesting birds has been confirmed, a letter report will be prepared and submitted to the City of Carmel-by-the-Sea Community Planning and Building Department prior to disturbance of the nest area.
b. Riparian Habitat or Sensitive Natural Communities. No riparian habitat or sensitive natural communities were identified on or adjacent to the housing sites (USFWS 2023b).

Therefore, the proposed project would not have a substantial adverse effect on any riparian habitat or other sensitive natural community. Figure 5, National Wetlands Inventory Map, shows riparian habitat within the City of Carmel-by-the-Sea. c. State or Federally Protected Wetlands A review of the National Wetlands Inventory (NWI) online database was conducted to identify potential jurisdictional wetland features on or adjacent to the housing sites (USFWS 2023b). No state or federally protected wetlands were identified on or adjacent to the housing sites. Therefore, the proposed project would not have a substantial adverse effect on state or federally protected wetlands. Figure 5, National Wetlands Inventory Map, shows wetlands and waterways within and adjacent to the City of Carmel-by-the-Sea.
d. Wildlife Movement. No essential habitat connectivity areas or wildlife corridors were identified on or adjacent to the proposed housing sites. Therefore, development of the housing sites would not interfere with wildlife movement (CDFW 2023d). e. Local Biological Resource Policies/Ordinances.

City’s General Plan: The City’s General Plan is a comprehensive statement of the planning goals and policies for the Carmel-by-the-Sea. The City’s General Plan has been combined with its Local Coastal Land Use Plan to ensure coordination of these two policy documents. The Coastal Land Use Plan sets forth goals, objectives, and policies that govern the use of land and water in Carmel-by-the-Sea consistent with the California Coastal Act of 1976.

The Open Space and Conservation Element of the General Plan includes comprehensive goals, objectives, and policies for the long-term management and conservation of openspace land and natural resources.

Attachment 2
National Wetlands Inventory Map
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study
0 1,100 feet
Figure 5
Source: ESRI 2023, USFWS NWI 2020
City Limits
Housing Sites Inventory Parcels
Estuarine and Marine Deepwater
Estuarine and Marine Wetland
Freshwater Emergent Wetland
Freshwater Forested/Shrub Wetland
Freshwater Pond
Riverine
Attachment 2
Section D Evaluation of Environmental Impacts 38 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 This side intentionally left blank.

Attachment 2
Section D Evaluation of Environmental Impacts 39 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 The Coastal Resource Management Element of the General Plan includes comprehensive goals, objectives, and policies for the protection of the City’s coastal environmental resources including the character of its forest, beach and bluffs, water quality and Environmentally Sensitive Habitat Areas (ESHAs).

City of Carmel-by-the-Sea Municipal Code - Trees: Chapter 17.48, Trees and Shrubs, of the City’s Municipal Code contains ordinances that apply to trees within the city limits.

Where tree removal is approved at the request of a property owner, another tree should be planted in a suitable location.

Tree Removal and Pruning Permits are required for:
 Pruning of live limbs over 4 inches in diameter
 Removal of oak, pine, cypress and redwood trees over 6 inches in diameter measured at 4.5 feet above ground level (diameter at breast height – DBH), including dead trees
 Removal of other tree species (not oak, pine, cypress or redwood) over 10 inches DBH, including dead trees
 Removal of trees over 2 inches DBH on vacant lots and properties with an active building permit
Per Chapter 17.48 of the Municipal Code, the applicant will be required to obtain a Tree Removal or Pruning Permit to remove or prune protected trees and replace those trees in accordance with their value. Tree permit applications are obtained from the Community Planning and Building Department.

Best management practices for tree care and the protection of wildlife can be found in Tree Care for Wildlife Best Management Practices (Bassett et al. 2021).

No development is proposed at this time and no trees are currently proposed for removal. Future development of a proposed housing site may result in tree removal or impacts to trees adjacent to a construction area. Therefore, implementation of the following standard conditions of approval will be required by each individual, future development proposed:

Standard Condition of Approval

26. Throughout construction, the Applicant shall protect all trees identified for preservation by methods approved by the City Forester. Trees on or adjacent to the site shall only be removed upon the approval of the City Forester or Forest and Beach Commission.

27. Requirements for tree preservation shall adhere to the following tree protection measures on the construction site.
 Prior to grading, excavation, or construction, the developer shall clearly tag or mark all trees to be preserved.
 Excavation within 6 feet of a tree trunk is not permitted.

Attachment 2
Section D Evaluation of Environmental Impacts 40 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024  No attachments or wires of any kind, other than those of a protective nature, shall be attached to any tree.
 Per Municipal Code Chapter 17.48.110, no material may be stored within the dripline of a protected tree, including the drip lines of trees on neighboring parcels.
 Tree Protection Zone. The Tree Protection Zone shall be equal to dripline or 18 inches radially from the tree for every one inch of trunk diameter at 4.5 feet above the soil line, whichever is greater. A minimum of 4-foot-high transparent fencing is required unless otherwise approved by the City Forester. Tree protection shall not be resized, modified, removed, or altered in any manner without written approval. The fencing must be maintained upright and taught for the duration of the project. No more than 4 inches of wood mulch shall be installed within the Tree Protection Zone. When the Tree Protection Zone is at or within the drip line, no less than 6 inches of wood mulch shall be installed 18 inches radially from the tree for every one inch of trunk diameter at 4.5 feet above the soil line outside of the fencing.
 Structural Root Zone. The Structural Root Zone shall be 6 feet from the trunk or 6 inches radially from the tree for every one inch of trunk diameter at 4.5’ above the soil line, whichever is greater. Any excavation or changes to the grade shall be approved by the City Forester prior to work. Excavation within the Structural Root Zone shall be performed with a pneumatic excavator, hydro-vac at low pressure, or another method that does not sever roots.  If roots greater than 2 inches in diameter or larger are encountered within the approved Structural Root Zone, the City Forester shall be contacted for approval to make any root cuts or alterations to structures to prevent roots from being damaged.
 If roots larger than 2 inches in diameter are cut without prior City Forester approval or any significant tree is endangered as a result of construction activity, the building permit will be suspended, and all work stopped until an investigation by the City Forester has been completed, and mitigation measures have been put in place.

28. All foundations within 15 feet of significant trees shall be excavated by hand. If any tree roots larger than two inches (2”) are encountered during construction, the City Forester shall be contacted before cutting the roots. The City Forester may require the roots to be bridged or may authorize the roots to be cut. If roots larger than two inches (2”) in diameter are cut without prior City Forester approval or any significant tree is endangered as a result of construction activity, the building permit will be suspended and all work stopped until an investigation by the City Forester has been completed. Six inches (6”) of mulch shall be evenly spread across the inside the dripline of all trees prior to the issuance of a building permit. f. Conservation Plans. There are no critical habitat boundaries, habitat conservation plans, natural community conservation plans, or other approved local, regional, or state habitat conservation plans applicable to the proposed housing site locations and no conflict with any conservation plan is anticipated (USFWS 2023c).

Attachment 2
Section D Evaluation of Environmental Impacts 41 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

5. CULTURAL RESOURCES
Would the project:

Comments:
a. Five of the housing sites are located on the Carmel Inventory of Historic Resources Database (City of Carmel-by-the-Sea 2023); Sites #1, 2, 9, part of 11 (only APN 010-085-004), and 19). Additionally, Site #10 could be considered a candidate for inclusion as a historic property according to conversations with City staff (City of Carmel-by-the-Sea 2023).

Historic resources are an important element of Carmel-by-the-Sea’s community character.

Therefore, historic preservation efforts are integrated within the City’s permit processes such as design review and land use development approvals. Additionally, the City implements conservation of its character through its Design Guidelines for the residential district, the commercial district, and for the public rights-of-way.

Development on historic sites identified on the Carmel Inventory of Historic Resources Database are subject to additional review from a city-retained historical consultant and review by the Historic Resources Board prior to consideration by the Planning Commission. Therefore, future applicants proposing development at Housing Sites #9, 11, 19, and potentially 10, would require additional review at the application submittal stage of the permit process. These future applicants would be required to incorporate any changes to the development required by City staff during the permit process to ensure impacts associated with historic resources are not significant. If the City determines that the proposed development would result in a significant and adverse impact to a historic resource, an environmental impact report would be required, and the City could not use this initial study for the project.
b. Archaeological resources from both the prehistoric period and the early historic period can be found in Carmel (Land Use and Community Character Element, p. 1-25). General areas of archaeological significance are shown in Figure 1.4 of the General Plan Land Use and Community Character Element. Housing Site #10 falls within this general area of archaeological significance.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Cause a substantial adverse change in the significance of a historical resource pursuant to section 15064.5? ☐ ☐ ☒ ☐ b. Cause a substantial adverse change in the significance of an archaeological resource pursuant to section
15064.5?
☐ ☐ ☒ ☐
c. Disturb any human remains, including those interred
outside of dedicated cemeteries? ☐ ☐ ☒ ☐
Attachment 2
Section D Evaluation of Environmental Impacts 42 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Compliance with the following City standard condition of approval would ensure that development of the housing sites (in particular, Housing Site #10) would result in less than significant impacts on archaeological resources.

Standard Conditions of Approval

19. Prior to the issuance of a building permit, the Applicant shall submit an archaeological reconnaissance report prepared by a qualified archaeologist or another person(s) meeting the standards of the State Office of Historic Preservation. The Applicant shall adhere to any recommendations set forth in the archaeological report. All new construction involving excavation shall immediately cease if materials of archaeological significance are discovered on the site and shall not be permitted to recommence until a mitigation and monitoring plan is approved by the Planning Commission.

20. Throughout construction, all activities involving excavation shall immediately cease if cultural resources are discovered on the site, and the Applicant shall notify the Community Planning & Building Department within 24 hours. Work shall not be permitted to recommence until such resources are properly evaluated for significance by a qualified archaeologist. If the resources are determined to be significant, prior to the resumption of work, a mitigation and monitoring plan shall be prepared by a qualified archaeologist and reviewed and approved by the Community Planning and Building Director. In addition, if human remains are unearthed during the excavation, no further disturbance shall occur until the County Coroner has made the necessary findings regarding origin and distribution pursuant to California Public Resources Code (PRC) Section 5097.98.
c. The proposed project does not involve specific development and there is no known evidence of human remains within the various housing sites. However, there remains the possibility that ground disturbing activities associated with the proposed project could damage or destroy previously undiscovered Native American human remains.

Disturbance of Native American human remains would be a significant impact. The standard conditions of approval identified in checklist question “b,” above, would reduce this potential impact to a less-than-significant level.

Attachment 2
Section D Evaluation of Environmental Impacts 43 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

6. ENERGY
Would the project:

Comments:
a. Energy impacts are assessed based on the proposed project energy demand profile, its relationship to the state’s energy efficiency regulations, and the City’s land use planning regulations, as summarized below.

Regulatory Requirements
A multitude of state regulations and legislative acts are aimed at improving vehicle fuel efficiency, energy efficiency, and enhancing energy conservation. For example, the Pavley I standards focus on transportation fuel efficiency. The gradual increased use of electric cars powered with cleaner electricity will reduce consumption of fossil fuel. Vehicle miles traveled are expected to decline with the continuing implementation of Senate Bill 743, resulting in less vehicle travel and less fuel consumption. In the renewable energy use sector, representative legislation for the use of renewable energy includes, but is not limited to, Senate Bill 350 and Executive Order B-16-12. In the building energy use sector, representative legislation and standards for reducing natural gas and electricity consumption include, but are not limited to Assembly Bill 2021, the Green Building Standards Code (CALGreen), and the California Building Standards Code.

The California Energy Code (California Code of Regulations, Title 24, Part 6), which is incorporated into the California Building Standards Code, was first established in 1978 in response to a legislative mandate to reduce California's energy consumption. The California Energy Code is updated every three years by the California Energy Commission as the Building Energy Efficiency Standards to allow consideration and possible incorporation of new energy efficiency technologies and construction methods.

The energy code is specifically designed to reduce wasteful and unnecessary energy consumption in newly constructed and existing buildings, including residential buildings.

For residential uses of the type proposed, the standards require a suite of building energy efficiency requirements, combined with on-site renewable energy production, that ensure such uses have net zero electricity energy demand.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Result in a potentially significant environmental
impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
☐ ☐ ☒ ☐
b. Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency? ☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 44 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 CALGreen, which requires all new buildings in the state to be more energy efficient and environmentally responsible, was most recently updated in July 2022. Its comprehensive regulations are intended to achieve major reductions in interior and exterior building energy consumption.

A project could be considered to result in significant environmental effects due to wasteful, inefficient, or unnecessary consumption of energy if its energy demand is extraordinary relative to common land use types, its gross energy demand is excessive relative to total demand in Monterey County, and/or it fails to comply with energy efficiency/conservation regulations that are within the applicant’s control. The new housing accommodated by the Housing Element Update is a common land use type for which energy demand is not considered wasteful or unnecessary, particularly under conditions where the critical statewide housing crisis is prompting dramatic action to increase local housing production.

Projected Energy Use
Project energy demand would not be excessive relative to total demand in the county summarized below.

Electricity. According to the California Energy Commission Energy Consumption Data Management System, in 2020, total electricity consumption in Monterey County was 2,434,272,857 kilowatt-hours (kWh). Section 5.11, Operational Energy Consumption, in the CalEEMod results included in Appendix C, show that the anticipated electricity demand for development pursuant to the Housing Element Update would be 1,187,158 kWh per year, or 0.05 percent of the countywide electrical demand in the absence of state regulations designed to reduce energy demand. Electricity demand would be reduced to zero with required conformance to regulatory requirements included in the California Energy Code, Building Energy Efficiency Standards, as summarized above. The 2022 standards require that low-rise residential development has net zero electricity demand.

This is achieved through a combination of incorporating energy efficiency, energy reduction features, and renewable energy features.

Natural Gas. According to the California Energy Commission Energy Consumption Data Management System, in 2020, total natural gas consumption in Monterey County was 110,009,822 therms. Section 5.2, Energy by Land Use – Natural Gas, in the project CalEEMod results included in Appendix C shows that projected natural gas demand from projects implementing the Housing Element Update would be about 10,002,514 kBTU (British Thermal Units) per year or approximately 100,002 therms per year. This is less than one-tenth of one percent of countywide demand in 2020.

Transportation Fuel. The VMT analysis in Section 17.0, Transportation, concludes that the proposed project would have a less-than-significant VMT impact. This owes primarily to the fact that affordable housing projects are deemed to reduce the distances that residents need to travel to access employment opportunities. Affordable housing projects implemented under the Housing Element Update are expected to reduce automobile use and associated fuel usage relative to market rate housing. Additionally, based on the number of new dwelling units projected for any individual housing site, no individual Attachment 2
Section D Evaluation of Environmental Impacts 45 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 planned moderate- and/or above-moderate-income level housing projects would generate more than 110 vehicle trips per day, a traffic volume at or below which VMT impacts are considered less than significant. Since the VMT impacts would be less than significant, project transportation fuel demand would be reduced relative to projects with a significant VMT impact and the associated demand would not be wasteful or unnecessary. Further, all proposed housing would be constructed on infill sites. From a land use perspective, infill development generally results in lower VMT and lower transportation fuel demand than does development on sites at the periphery of an urban area.

Developers of future individual housing projects would be required to comply with state regulatory requirements for reducing building energy demand found in Title 24 of the current California Building Code, and with CALGreen requirements as described above.

The proposed project would consume energy, but it would not be inefficient, wasteful, or unnecessary. Therefore, the impact would be less than significant. b. There are no regulations at the local level that would mandate that the proposed project must include on-site renewable energy sources. The California Building Standards Code would require the proposed project to be built to the Building Energy Efficiency Standards in effect at the time the building permit is issued. By incorporating energy efficiency and renewable energy measures per the Building Energy Efficiency Standards and complying with CALGreen standards, as would be enforced through the City’s building permit process, the project would comply with existing state and local energy standards and would not conflict with or obstruct a state or local plan for energy efficiency.

Attachment 2
Section D Evaluation of Environmental Impacts 46 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

7. GEOLOGY AND SOILS
Would the project:

Comments:
a. Earthquake. There are no Alquist-Priolo earthquake faults near to the City of Carmelby-the-Sea (City of Carmel-by-the-Sea 2009, Figure 8.1); the nearest is the San Andreas Fault located more than 30 miles northeast of the City (California Department of Conservation 2023). Therefore, development of the proposed housing sites would not Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or death involving:
(1) Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other
substantial evidence of a known fault? Refer to
Division of Mines and Geology Special
Publication 42?
☐ ☐ ☐ ☒
(2) Strong seismic ground shaking? ☐ ☐ ☒ ☐
(3) Seismic-related ground failure, including
liquefaction?
☐ ☐ ☐ ☒
(4) Landslides? ☐ ☐ ☐ ☒
b. Result in substantial soil erosion or the loss of topsoil? ☐ ☐ ☒ ☐ c. Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the
project, and potentially result in on- or off-site
landslide, lateral spreading, subsidence, liquefaction, or collapse?
☐ ☐ ☐ ☒
d. Be located on expansive soil, creating substantial
direct or indirect risks to life or property? ☐ ☐ ☐ ☒
e. Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal
systems where sewers are not available for the disposal of wastewater?
☐ ☐ ☐ ☒
f. Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? ☐ ☒ ☐ ☐
Attachment 2
Section D Evaluation of Environmental Impacts 47 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 directly or indirectly cause substantial adverse effects, including the risk of loss, injury, or death involving the rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map.

Seismic Ground Shaking. According to the City’s General Plan Figure 8.1, there are two fault lines at the northeast corner and southwest corner of, and outside of, the City of Carmel-by-the-Sea city limits (Hatton Canyon and Cypress Point, respectively). Only Cypress is active or potentially active (City of Carmel-by-the-Sea 2009, Figure 8.1).

Therefore, seismic ground shaking is possible within the City should an earthquake occur on the Cypress Point Fault.

Future development will be required to conform to the uniform development regulations in the California Building Code that address seismic hazards, which has been adopted by the City of Carmel-by-the-Sea (City Municipal Code Chapter 15.08), to reduce geologic hazard risk potential in new development. Additionally, General Plan Environmental Safety Element Policy P8-24 requires adequate geotechnical investigations to be undertaken to provide necessary information and mitigation for any development locating substantial structures in areas subject to seismic hazards, ground failure, erosion, or landsliding. Therefore, future development of the housing sites will be required to prepare adequate geotechnical investigations for the review and approval of the City Community Planning and Building Department, and comply with the recommendations presented within the report. Compliance with the City’s Municipal Code Chapter 15.08, preparation of the geotechnical investigations and compliance with the recommendations found in the report all would ensure less than significant impacts associated with development and seismic ground shaking.

Liquefaction. The City of Carmel-by-the-Sea is within a low liquefaction hazard zone with some areas of high liquefaction around the edges of the city limits (Monterey County 2023a). All of the housing site locations are within a low liquefaction hazard zone.

Therefore, development of the housing sites would comply with the City’s General Plan Environmental Safety Element Policy P8-25, which requires that the placement of critical facilities and high occupancy structures (e.g., multi-family residential, hotels, etc.) avoid areas subject to ground failure during an earthquake. Implementation of the proposed project is not likely to result in direct or indirect substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction.

Landslide. Most of the City of Carmel-by-the-Sea is within a low landslide hazard zone, with some moderate landslide hazard zones to the southeast and northeast edges of the city limits (Monterey County 2023a). All of the housing site locations are within the low landslide hazard zone. The proposed project involves the development of new and redevelopment of existing structures for housing. Therefore, development of the housing sites is not likely to result in direct or indirect substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including landslide.

Attachment 2
Section D Evaluation of Environmental Impacts 48 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 b. The majority of the City of Carmel-by-the-Sea is within a moderate erosion hazard zone with some areas around the edges of the city limits within high erosion hazard zones (Monterey County 2023a). All of the housing sites are located within a moderate erosion hazard zone.

City General Plan Environmental Safety Element Policy P8-24 requires adequate geotechnical investigations to be undertaken to provide necessary information and mitigation for any development locating substantial structures in areas subject to seismic hazards, ground failure, erosion, or landsliding.

In addition to compliance with General Plan Policy P8-24, future development for each housing site will be required to implement the following standard condition of approval to reduce the potential for erosion or siltation impacts.

Standard Condition of Approval

32. Prior to issuance of a building permit, the Applicant shall submit for review and approval by the Community Planning & Building and Public Works Departments an erosion and sediment control plan that includes locations and installation details for erosion and sediment control BMPs, material staging areas, and stabilized access.

Preparation of a geotechnical investigation pursuant to General Plan Policy P8-24 and compliance with the above standard condition of approval would ensure that the project result in less than significant erosion impacts.
c. Based on the information available, it does not appear that the housing sites are located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse. However, should the geotechnical investigations required pursuant to General Plan Policy P8-24 (identified in checklist questions “a” and “b”) present information to the contrary, future development at the housing sites would be required to comply with the recommendations identified in the geotechnical investigations report.
d. The two main soil types at the housing site locations are Oceano loamy sand, 2 to 15 percent slopes, and Elkhorn fine sandy loam, 9 to 15 percent slopes. Neither of these two soil types have expansion properties (Monterey County 1978). Therefore, the housing sites are not located on expansive soil and implementation of the project would not create a substantial or indirect risks to life or property.
e. Each of the housing sites proposed for development connect into the City’s existing sanitary sewer system. Development at each housing site would continue to connect into the City’s sewer system and, therefore, would not use septic tanks or alternative wastewater disposal systems.
f. There are no known paleontological resources within the City of Carmel-by-the-Sea; the nearest known resource is located in the Point Lobos State Reserve approximately two miles south of the city limits (Monterey County 2023b).

Attachment 2
Section D Evaluation of Environmental Impacts 49 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 However, it is possible that paleontological resources could be accidentally discovered during construction activities associated with development of the housing sites. Directly or indirectly destroying a unique paleontological site is considered a significant, adverse environmental impact. Implementation of the following mitigation measure would ensure this potential impact would be less than significant.

Mitigation Measure
GEO-1 The following language shall be included on all grading permits: “If paleontological resources are discovered during demolition and earthmoving activities, work shall stop within 100 feet of the find until a qualified paleontologist can assess if the find is unique and, if necessary, develop appropriate treatment measures in consultation with the City’s Community Planning and Building Department.”
Attachment 2
Section D Evaluation of Environmental Impacts 50 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

8. GREENHOUSE GAS EMISSIONS
Would the project:

Comments:
a. The city adopted a Climate Action Plan (CAP) in July of 2022. It contains the requisite elements of a plan for reducing GHG emissions as outlined in CEQA Guidelines section 15183.5, including strategies to reduce GHG emissions from new and existing development as needed to meet the GHG reduction targets identified in the CAP for 2030 and 2045. The CAP assesses projected cumulative GHG impacts of activities within the City with GHG reduction measures identified to reduce cumulative impacts to the 2030 and 2045 target levels. The city has since been implementing the CAP as a means of reducing both community and municipal GHG emissions sources.

The emissions projections and reduction measures in the CAP did not, and could not have foreseen the new cumulative growth proposed in the current Housing Element Update or its associated GHG emissions. Stated in the alternative, the proposed project is not consistent with the cumulative growth assumptions in the CAP. As a result, analysis of the proposed project GHG impact, an impact which is inherently cumulative in nature, cannot be streamlined using the CAP as outlined in CEQA Guidelines section 15183.5.

GHG impacts are; therefore, assessed using a qualitative approach supported by quantified GHG modeling results as described below.

Analysis Methodology
The significance of GHG emissions from the proposed project is being evaluated based on a methodology which examines mobile source emissions separately from the balance of GHG emissions sources. This methodology looks first at mobile source emissions in the context of vehicle miles travelled (VMT) generated by the project and a quantified threshold of significance for this emissions source as recommended by the California Office of Planning and Research. GHG emissions from other project sources (e.g., electricity, area sources, water, wastewater) are quantified and qualitatively compared to values derived by modifying past quantified thresholds of significance from two adjacent air districts.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
☐ ☐ ☒ ☐
b. Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?
☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 51 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 This “bifurcated” analysis approach is supported by several published sources. These include: 1) California Office of Planning and Research’s Discussion Draft CEQA and Climate Change Advisory (December 2018), which discusses CEQA streamlining for GHG impacts by examining VMT effects (mobile source emissions) separately from energy and natural gas sources; 2) California Office of Planning and Research’s Technical Advisory on Evaluating Transportation Impacts in CEQA (December 2018), which provides guidance on evaluating VMT impacts that affect the state’s ability to meet it long-term climate goals; and 3) Association of Environmental Professionals’ Final Whitepaper - Beyond 2020 and Newhall: A Field Guide to New CEQA Greenhouse Gas Thresholds and Climate Action Plan Targets for California (October 2016), which identifies two hybrid analysis concepts using Senate Bill 375 and Senate Bill 743 that each evaluate transportation (mobile source) GHG emissions separately from non-mobile sources.

Senate Bill 375 was enacted in 2008. Its overall purpose is to reduce GHGs from passenger vehicles by setting regional emissions targets with which local communities can align their land use and transportation policies to help achieve. Senate Bill 743, enacted in 2013, is designed to help achieve state climate policy and sustainability goals. It eliminates traffic delay as an environmental impact under CEQA and instead, requires an assessment of VMT as a basis to encourage development that reduces VMT and associated mobile source GHG emissions.

VMT and Mobile Source GHG Emissions. VMT impacts of the project are discussed in Section 17.0, Transportation. The VMT Analysis for the Carmel-by-the-Sea Housing Element Update (Hexagon Transportation Consultants 2023), more fully described in that section, concludes that the VMT impact of implementing individual future housing projects per the Housing Element Update would be less than significant. This conclusion is based on guidance provided by the California Office of Planning and Research for implementing California Senate Bill 743. Refer to Section 17.0 for more information. Given that the project VMT impact is less than significant, the mobile source GHG emissions the project would generate can also be assumed to have a less-than-significant impact.

Non-Mobile Source GHG Emissions. Non-mobile source GHG emissions from construction and operation of the housing units accommodated by the Housing Element Update were estimated using CalEEMod. The detailed CalEEMod modeling results are included as Appendix C.

Construction activity would generate approximately 862.96 metric tons of carbon dioxide equivalent (MT CO2e) per year. To account for the contribution of construction emissions to the project non-mobile source annual emissions profile, construction emissions are amortized over an assumed 30-year operational timeframe; amortized annual emissions equal 28.8 MT CO2e per year.

Project operations would generate GHG emissions from energy use (electricity), natural gas use (area source), waste generation, and water use. Projected unmitigated emissions from these sources, as well as amortized construction emissions are summarized in Table 4, Non-Mobile Unmitigated Operational GHG Emissions. Refer to Section 2.5, Operations Emissions by Sector, Unmitigated, of the CalEEMod results included in Appendix C for reference to these emissions volumes.

Attachment 2
Section D Evaluation of Environmental Impacts 52 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Table 4 Non-Mobile Unmitigated Operational GHG Emissions Emissions Sources GHG Emissions (MT CO2e)
Area 6.91
Energy 643.13
Water 23.28
Waste 92.34
Refrigerants 0.46
Amortized Construction 28.80
Total 794.92
SOURCE: EMC Planning Group 2023
Lacking the option to utilize the City’s CAP to streamline the GHG impact analysis, thresholds of significance from local/regional air districts are referenced here. As previously noted, the air district has not developed GHG thresholds of significance for land use projects. In the absence of this direction, thresholds of significance that were developed by two adjacent air districts – the Bay Area Air Quality Management District (BAAQMD) and the San Luis Obispo Air Pollution Control District (SLOAPCD), are referenced for qualitatively assessing the relative magnitude of non-mobile source emissions from the proposed project.

BAAQMD provided guidance and quantified thresholds of significance for assessing GHG impacts in its 2017 California Environmental Quality Act Air Quality Guidelines, and as part of that guidance, derived a bright line threshold of 1,100 MT CO2e/year. Projects that generate a greater volume of GHG emissions per year would be considered to have a significant impact. SLOAPCD did the same in its 2012 CEQA Air Quality Handbook, and derived a bright line threshold of 1,150 MT CO2e/year. The substantial evidence used by each agency to develop their respective thresholds is included their CEQA guidance documentation. The bright line thresholds were developed to guide new development within each district with the goal of meeting the state’s Assembly Bill 32 statewide GHG emissions reduction target of 20 percent below 1990 levels by 2020.

With the subsequent passage of Senate Bill 32 in 2016, the state set a deeper GHG reduction target of 40 percent below 1990 levels by 2030. Consequently, the bright line thresholds identified above are not valid after 2020. Reducing these bright line thresholds by an additional 20 percent, to 880 MT CO2e/year and 920 MT CO2e/year, respectively, would approximate bright line values of 40 percent below 1990 levels to meet the state 2030 emissions reduction target. Neither agency has adopted these scaled down values as thresholds of significance, nor has the air district or City adopted either value as such.

Rather, as noted above, these values are being used to qualitatively assess the relative magnitude of non-mobile source emissions from the proposed project. The non-mobile source project emissions volume of 794.92 MT CO2e/year is below both values, which indicates that non-mobile source project emissions should not be considered to have a significant impact.

Attachment 2
Section D Evaluation of Environmental Impacts 53 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Given that neither the mobile source GHG emissions or the non-mobile source GHG emissions from the project would be significant, the project would have a less-thansignificant impact from generation of GHG emissions. b. As described in item “a” above, neither the city nor air district have adopted plans for reducing GHG emissions that can be used to streamline the analysis of Housing Element Update project GHG impacts. Consequently, the significance of mobile source GHG impacts is evaluated in the context of state legislation embodied in SB 743, and the nonmobile source GHGs are evaluated in the context of scaled quantified thresholds of significance that had been adopted by adjacent air districts as part of their respective plans for reducing GHG emissions. Because the project impacts are less than significant, the project would have no impact from conflict with VMT regulations designed to reduce mobile source GHG emissions or with the referenced GHG emissions reduction plans.

Attachment 2
Section D Evaluation of Environmental Impacts 54 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

9. HAZARDS AND HAZARDOUS MATERIALS
Would the project:

Comments:
a. Residential development does not commonly involve the use of acutely hazardous materials of the types that could pose a threat to public health and safety. Similarly, replacement commercial development that could occur on a number of the housing sites is not commonly a source of substantial hazardous materials risk. Therefore, the proposed project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
☐ ☐ ☐ ☒
b. Create a significant hazard to the public or the
environment through reasonably foreseeable upset
and accident conditions involving the release of
hazardous materials into the environment?
☐ ☐ ☒ ☐
c. Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
☐ ☐ ☐ ☒
d. Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code section 65962.5 and, as a result,
create a significant hazard to the public or the
environment?
☐ ☐ ☐ ☒
e. For a project located within an airport land-use plan or, where such a plan has not been adopted, within
two miles of a public airport or a public-use airport,
result in a safety hazard or excessive noise for people residing or working in the project area?
☐ ☐ ☐ ☒
f. Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
☐ ☐ ☐ ☒
g. Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or death involving wildland fires?
☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 55 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 b. Demolition of existing structure can be expected on some of the housing sites. It is possible that existing structures may contain hazardous substances such as asbestos and/or lead materials.

Regulation of hazardous materials and hazardous wastes occurs at the federal, state, and local levels of government. On the federal level, many hazardous materials-related regulations are promulgated by the Environmental Protection Agency. On the state level, the California Environmental Protection Agency, Department of Toxic Substances Control, and Regional Water Quality Control Board (RWQCB) are responsible for overseeing many remediation and monitoring activities performed for sites in California with hazardous materials. Carmel-by-the-Sea is located within the jurisdiction of the Central Coast RWQCB. Regulations pertaining to work place standards and for transportation of hazardous materials are enforced by the State of California Division of Occupational Safety and Health (City of Carmel-by-the-Sea 2009, Environmental Safety Element – p. 8-23). Additionally, the California Department of Industrial Relations Subchapter 4, Construction Safety Orders - Article 4 discusses the requirements for construction sites and construction workers dealing with demolishing buildings that may contain asbestos or lead-based paint.

Compliance with these uniformly applied requirements would be required by the City as part of the development review and building permit processes for individual projects on the housing sites for which demolition activities would occur. Additionally, the following standard condition of approval would be required to reduce impacts involving the potential release of hazardous materials into the environment to a less-than-significant level.

Standard Condition of Approval

18. Prior to the issuance of a demolition permit, the Applicant shall submit a hazardous materials waste survey to the Building Division in conformance with the Monterey Bay Unified Air Pollution Control District.
c. Implementation of the proposed project would not result in the development of uses that could emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste. Additionally, the following four schools are nearest to the City of Carmel-by-the-Sea: Carmel High School, Carmel Middle School, Carmel River Elementary School, and Stevenson School. None of these schools are located within onequarter mile from the housing sites (Google Earth 2023). Therefore, the proposed project would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. d. The following lists were reviewed:
 Hazardous Materials Waste and Substances Sites from the Department of Toxic Substances Control EnviroStor Database (Department of Toxic Substances Control 2023);
Attachment 2
Section D Evaluation of Environmental Impacts 56 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024  Leaking Underground Storage Tank Sites from the State Water Board’s GeoTracker Database (State Water Resources Board 2023);
 Solid Waste Disposal Sites Identified by Water Board with Waste Constituents Above Hazardous Waste Levels Outside the Waste Management Unit (California Environmental Protection Agency 2023a);
 “Active” Cease and Desist Order and Cleanup and Abatement Orders from Water Board (California Environmental Protection Agency 2023b); and  List of hazardous waste facilities subject to corrective action pursuant to Section 25187.5 of the Health and Safety Code, identified by the Department of Toxic Substances Control (California Environmental Protection Agency 2023c).

The project site is not located on any of these lists. The housing site located at the northwest corner of Dolores and Ocean Avenues is located adjacent to, but outside of, a completed and closed case of a leaking underground storage tank (State Water Resources Board 2023).

Therefore, the proposed project is not located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code section 65962.5 and, as a result, would not create a significant hazard to the public or the environment. e. The City of Carmel-by-the-Sea is located approximately 3.5 miles southwest of the nearest airport, the Monterey Regional Airport. Therefore, none of the housing sites are located within an airport land-use plan or within two miles of a public airport or a publicuse airport. Implementation of the proposed project would not result in a safety hazard or excessive noise for people residing or working in the project area. f. The housing sites are generally located throughout central Carmel-by-the-Sea on vacant or underutilized parcels. Development or redevelopment of these parcels is not expected to result in changes to the street system. The nearest emergency evacuation route from the housing sites is the primary route located on Carpenter Street, four blocks east from housing site #3 (City of Carmel-by-the-Sea 2015). Therefore, development of the housing sites would not impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan.
g. According to the California Department of Forestry and Fire Protection’s FHSZ Viewer, none of the housing sites are located within a very high fire hazard severity zone (CalFire 2023). Therefore, development of the housing sites identified within the Housing Element Update would not expose people or structures to a risk of loss, injury or death involving wildland fires.

Attachment 2
Section D Evaluation of Environmental Impacts 57 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

10. HYDROLOGY AND WATER QUALITY
Would the project:

Comments:
a. Construction Water Quality Impacts. The development and redevelopment of the proposed housing sites would involve soil disturbance associated with site preparation, grading, and in some cases potentially excavation activities. Delivery, handling and storage of construction materials and wastes; equipment refueling; and construction equipment use and maintenance could result in spills of oil, grease, or related pollutants. These activities have potential to cause water quality degradation if eroded soil or other pollutants are carried by storm water into storm water drainage systems and ultimately into downstream water bodies.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Violate any water quality standards or waste discharge requirements or otherwise substantially degrade
surface or ground water quality?
☐ ☐ ☐ ☒
b. Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such
that the project may impede sustainable groundwater
management of the basin?
☐ ☐ ☒ ☐
c. Substantially alter the existing drainage pattern of the site or area, including through the alteration of the
course of a stream or river or through the addition of
impervious surfaces, in a manner which would:
(1) Result in substantial erosion or siltation on- or offsite; ☐ ☐ ☒ ☐ (2) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding onor off-site; ☐ ☐ ☒ ☐
(3) Create or contribute runoff water that would exceed the capacity of existing or planned storm water
drainage systems or provide substantial additional
sources of polluted runoff; or
☐ ☐ ☒ ☐
(4) Impede or redirect flood flows? ☐ ☐ ☐ ☒
d. In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? ☐ ☐ ☐ ☒
e. Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 58 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 City Municipal Code Chapter 17.43, Water Quality Protection Ordinance, intends to protect and enhance the coastal waters in accordance with policies in the City’s Local Coastal Plan, the California Coastal Act, and the City’s National Pollutant Discharge Elimination System (NPDES) Phase II Permit requirements. Section 17.43.030 requires that during the construction phase of a development project, an erosion and drainage control plan shall be prepared and submitted. The plan shall include a site-specific erosion control plan that includes controls on grading, best management practice for staging, storage, and disposal of construction materials, design specification of sedimentation basins and landscaping/revegetation of graded or disturbed areas. All new development and redevelopment within the City shall comply with the requirements in Chapter 17.43.

Although no development is proposed at this time, required compliance of future development with the NPDES water quality standards identified in the City’s Municipal Code and the City’s standard conditions of approval would ensure that applicable water quality standards are met. Therefore, construction activities associated with developing the housing sites would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality.

Standard Conditions of Approval

29. Prior to the issuance of a building permit, the Applicant shall submit for review and approval by the Community Planning & Building and Public Works Departments a drainage plan that meets the requirements of the City's drainage guidance, SOG [Standard Operating Guidance] 17-07. At a minimum, new and replaced impervious area drainage must be dispersed around the site rather than focused on one corner of the property; infiltration features must be sized appropriately and located at least 6 feet from neighboring properties. The drainage plan shall include information on drainage from new impervious areas and semi-pervious areas;

37. Prior to the issuance of a building permit, the Applicant shall submit a Construction Management Plan for review and approval by the Community Planning & Building Director.

Post-Construction Water Quality Impacts.

Development is widely regarded as a leading cause of surface water pollution resulting from altering watershed hydrology and introducing urban pollutants. The proposed project could result in the change in surface conditions at one or more of the individual housing site locations from pervious to impervious features. This type of change in surface conditions could increase storm water runoff during project operations relative to existing conditions where a portion of storm water currently percolates through exposed Attachment 2
Section D Evaluation of Environmental Impacts 59 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 soil back to groundwater. Increases in the rate or volume of storm water delivered into receiving waters can cause erosion of downstream drainage courses, termed “hydromodification,” which generates additional sediment that further degrades water quality.

Chapter 17.43 of the City Municipal Code requires that all projects be designed to control post-development peak runoff rates and average volumes to maintain or reduce predevelopment downstream erosion rates. Section 17.43.030.A.2, Application Submittal Requirements, requires that the post-construction plans detailing how stormwater and polluted runoff will be managed or mitigated should be included in the design of all projects that require an erosion and drainage control plan. Project submittals shall include details regarding how the project will use appropriate site design and source control best management practices to minimize adverse effects of the project on water quality. Section

17.43.030.D requires that all projects that require an erosion and drainage control plan provide plans detailing how the project will use appropriate site design and source control best management practices to minimize adverse effects of the project on water quality.

The proposed project does not include any specific development at this time; therefore, future, individual projects will be required to comply with the post-construction-related regulations identified in City Municipal Code Chapter 17.43 to ensure that applicable water quality standards are met. Therefore, post-construction activities associated with developing the housing sites would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. b. Groundwater Supplies. According to the Groundwater Basin Boundary Assessment Tool by the Department of Water Resources, the City of Carmel-by-the-Sea is located adjacent to, but outside of, the Carmel Valley Groundwater Basin (Department of Water Resources 2023). Carmel-by-the Sea receives its water from the California-American Water Company (Cal-Am) Central Division who pumps its water from several local water sources: groundwater from the Carmel River Aquifer, Seaside Groundwater Basin, Aquifer Storage and Recovery, indirect portable reuse from Pure Water Monterey, and desalinated water from Sand City. The majority of water received in the City is from the Carmel River and the Seaside Groundwater Basin (City of Carmel-by-the-Sea 2023b).

According to the Monterey Peninsula Water Management District’s Technical Memorandum dated June 1, 2023, the City requires at least 46 acre-feet of water to meet the needs of the City’s RHNA plus the 17 percent buffer included in the Housing Element Update and evaluated in this initial study (i.e., total of 410 housing units). The memorandum is included as Appendix E.

Future development of the housing sites will be required to comply with Chapter 15.28, Water Conservation, of the City’s Municipal Code, whose intent is to control unnecessary consumption of the available water supplies on the Monterey Peninsula by requiring the use of water-saving devices in the construction of improvements. Compliance with Section 17.50.020, Water Conservation, is also required for future development as it Attachment 2
Section D Evaluation of Environmental Impacts 60 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 establishes uniform standards for water conservation (by way of pumping fixtures and landscape standards) and provides guidance on the manner in which conserved water is to be used within the City’s total water management program.

Many of the housing sites are developed with existing businesses or residences that currently use water. It would be speculative at this time to document the existing water use at each site and whether future redevelopment of those sites would result in the need for more or less water supply, as there are currently no development plans to evaluate.

Therefore, as development applications are received on the housing sites, City staff will evaluate the application to determine if additional water supply is required, and if it is available to the project.

Implementation of the following standard condition of approval would be required by future applicants requesting to develop the housing sites to ensure that the proposed project would not decrease groundwater supplies such that the project would impede sustainable groundwater management of the basin. Refer to Section 19.0, Utilities and Service Systems, checklist question “b” for a more detailed discussion on water supplies.

Standard Condition of Approval

4. Approval of this application does not permit an increase in water use on the project site without adequate supply. Should the Monterey Peninsula Water Management District determine that adequate water is unavailable for this site, this permit will be scheduled for reconsideration, and appropriate findings will be prepared for review and adoption by the Planning Commission
Groundwater Recharge. Development at the housing sites could result in changes to surface conditions reducing the amount of pervious area and thereby interfering with groundwater recharge. However, as discussed in checklist question “a” above, project submittals are required to include details regarding how the project will use appropriate site design and source control best management practices to minimize adverse effects of the project on water quality. There are several types of treatment control best management practices that encourage groundwater recharge for new development such as infiltration basins and trenches, bioretention cells, landscape, etc. Implementation of such practices would reduce the project’s potential impacts on interfering with groundwater recharge to a less-than-significant level.
c. Erosion. Refer to Section 7.0, Geology and Soils, checklist question “b.” Flooding and Runoff. As previously discussed in checklist question “a” above, the proposed project could result in the change in surface conditions at one or more of the individual housing site locations from pervious to impervious features. This type of change in surface conditions could increase storm water runoff relative to existing conditions where a portion of storm water currently percolates through exposed soil back to groundwater. Increases in the rate or volume of storm water runoff could contribute to localized flooding if stormwater infrastructure is not designed or sized to accommodate the increased flows. Section 17.43.030.B of the City Municipal Code requires that all Attachment 2
Section D Evaluation of Environmental Impacts 61 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 development that requires an erosion and drainage control plan (such as the future development proposals for the housing sites) shall implement appropriate site design and source control best management practices to minimize post-construction polluted runoff.

Additionally, Section 17.43.080 of the City’s Municipal Code states that in order to mitigate the increased runoff rates from single-family residences due to new impervious surfaces, new and remodel projects which need an erosion and drainage control plan (such as the future development proposals for the housing sites) shall include design elements which accommodate on-site percolation, retention or collection of stormwater runoff such that the peak runoff rate after development either meets the 85th percentile storm event criterion or does not exceed predevelopment runoff levels to the maximum extent practicable. Runoff that will come from the project site must meet the applicable requirements contained in the City’s Low Impact Design Guidelines Manual.

Compliance with the regulations provided in the City’s Municipal Code and implementation of the below standard condition of approval would ensure that flooding and runoff impacts that could occur from future development altering existing drainage patterns of the site or area would be less than significant.

Standard Condition of Approval

07. At a minimum, new and replaced impervious area drainage must be dispersed around the site rather than focused on one corner of the property; infiltration features must be sized appropriately and located at least 6 feet from neighboring properties. The drainage plan shall include information on drainage from new impervious areas and semi-pervious areas.

Flood Flows. None of the housing sites are located within a flood hazard zone (FEMA 2023); therefore, the impediment or redirecting of flood flows would not be of concern in relation to development of the housing sites.
d. None of the housing sites are located within a flood hazard zone (FEMA 2023), within a tsunami hazard area (California Department of Conservation 2023), nor a seiche zone.

Therefore, development of the housing sites would not risk release of pollutants due to project inundation.
e. The City of Carmel-by-the-Sea is not located within a groundwater basin (Department of Water Resources 2023) and receives the majority of its water from the Carmel River and the Seaside Groundwater Basin (City of Carmel-by-the-Sea 2023b), neither of which has a groundwater sustainability plan. Therefore, development of the housing sites would not conflict with or obstruct implementation of a sustainable groundwater management plan.

The Water Quality Control Plan for the Central Coastal Basin June 2019 Edition (Basin Plan) is the Central Coast Regional Water Quality Control Board's master water quality control planning document. The Basin Plan describes how the quality of surface water and Attachment 2
Section D Evaluation of Environmental Impacts 62 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 groundwater in the Central Coast Region should be managed to provide the highest water quality reasonably possible. The Central Coast Regional Water Quality Control Board implements the Basin Plan by issuing and enforcing waste discharge requirements to individuals, communities, or businesses whose waste discharges can affect water quality.

These requirements can be either State Waste Discharge Requirements for discharges to land, or federally delegated NPDES permits for discharges to surface water.

City Municipal Code Chapter 17.42, Stormwater Quality and Utility, requires that new development and redevelopment projects comply with the City’s low impact development requirements, which is in conformance with the NPDES Phase II permit, to control the volume, rate, and potential pollutant load of stormwater runoff to minimize generation, transport, and discharge of pollutants. Therefore, future development associated with the proposed project must be designed consistent with regulations promulgated by the Central Coast Regional Water Quality Control Board to protect water quality consistent with the goals of the Basin Plan. Therefore, the proposed project would not conflict with or obstruct implementation of the water quality control plan.

Attachment 2
Section D Evaluation of Environmental Impacts 63 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

11. LAND USE AND PLANNING
Would the project:

Comments:
a. The proposed project plan for development of future residential units throughout the City of Carmel-by-the-Sea and updates to the City’s Safety Element based on various legislative updates associated with safety hazards. As discussed in the project description, updates to the Safety Element are not expected to involve any physical changes.

Therefore, neither of these two components of the project would result in physically dividing an established community.
b. Section 3.0, Air Quality, states that the project’s population increase would exceed the population projections upon which the air quality management emissions forecasts are based. However, despite this conflict with the air quality plan, the project would not result in significant impacts to air quality and, therefore, would not result in a significant air quality impact.

As discussed in Section 4.0, Biological Resources, there are no critical habitat boundaries, habitat conservation plans, natural community conservation plans, or other approved local, regional, or state habitat conservation plans applicable to the proposed project site.

The project, as mitigated, would reduce the potential adverse impact on the Monarch butterfly, Obscure and Western bumble bees, bats, nesting birds and raptors during construction of the proposed project.

Section 8.0, Greenhouse Gas Emissions, concludes that the project would have no impact from conflict with VMT regulations designed to reduce mobile source GHG emissions or with the referenced GHG emissions reduction plans.

As concluded in Section 10.0, Hydrology and Water Quality, the proposed project would not conflict with an adopted groundwater sustainability plan or groundwater basin plan.

As discussed in Section 13.0, Noise, compliance with the applicable General Plan policies and County Code requirements would ensure less than significant impacts associated with reducing exposures to unacceptable noise due to project construction.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Physically divide an established community? ☐ ☐ ☐ ☒
b. Cause any significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?
☐ ☐ ☒ ☐
Attachment 2
Section D Evaluation of Environmental Impacts 64 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Section 17.0, Transportation, concludes that compliance with the applicable General Plan policies related to the City’s circulation system and the future applicant’s payment of the regional traffic impact fee would offset any potential impacts the project could have to the circulation system and, therefore, would not conflict with a program, plan, ordinance, or policy addressing the circulation system.

Attachment 2
Section D Evaluation of Environmental Impacts 65 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

12. MINERAL RESOURCES
Would the project:

Comments:
a, b. According to the U.S. Geological Survey’s Mineral Resources Online Spatial Data, there are no mineral resources within the City of Carmel-by-the-Sea (U.S. Geological Survey 2023). Therefore, implementation of the proposed project would not result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state nor would it result in the loss of availability of locally important mineral resource recovery site delineated in a local general plan, specific plan, or other land-use plan.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Result in loss of availability of a known mineral
resource that would be of value to the region and the
residents of the state?
☐ ☐ ☐ ☒
b. Result in the loss of availability of a locally important mineral resource recovery site delineated in a local
general plan, specific plan, or other land-use plan?
☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 66 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

13. NOISE
Would the project result in:

Comments:
a. Temporary – Construction Noise. Future development at each of the housing sites would result in a temporary increase in ambient noise levels in the vicinity of the project.

However, because there are no specific development plans included as part of the project, it would be speculative to predict noise levels, locations, or time periods for construction of such projects, or construction noise at adjacent properties. Nonetheless, at the time future development is proposed at any of the housing sites, the regulations identified within Chapter 8.56, Noise Regulation, of the City Municipal Code shall be followed.

According to Chapter 8.56, Noise Regulation, of the City Municipal Code, construction noises (also known as Class B Noise) are not allowed between the hours of 6:30pm and 8am.

Future development will also be required to comply with General Plan Noise Element Policies P9-4 ensuring that construction activities are managed to minimize overall noise impacts on surrounding land uses and Policy P9-17, which states the enforcement of state laws regarding un-muffled or improperly muffled motor vehicles.

Compliance with the City’s Municipal Code and General Plan policies would ensure that development at the housing sites would result in less than significant temporary noise increases.

Permanent – Operational Noise. Exiting sensitive noise receptors could be affected by buildout of operational noise occurring onsite at properties developed or redeveloped under the proposed project. Noise generated by onsite activities for the new residential Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or in applicable
standards of other agencies?
☐ ☐ ☒ ☐
b. Generation of excessive ground-borne vibration or
ground borne noise levels? ☐ ☐ ☒ ☐
c. For a project located within the vicinity of a private airstrip or an airport land-use plan or, where such a
plan has not been adopted, within two miles of a
public airport or public-use airport, expose people
residing or working in the project area to excessive
noise levels?
☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 67 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 development would be subject to the City’s noise regulations contained in Chapter 8.56 of the Municipal Code. Additionally, future development at the housing sites would be required to comply with General Plan Noise Element Policy P9-8, which requires that all new residential, commercial, and mixed-use proposals, including condominium conversions, apply the noise and land use compatibility standards shown in Table 9.2 of the Noise Element. Compliance with these regulations would reduce potential onsite noise impacts to a less-than-significant level.

Development facilitated by the proposed project would also result in increased offsite operational noise levels such as the potential for additional vehicle trips on roadways within the City. However, future development at the housing sites would each be required to comply with the City’s General Plan Noise Element Policy P9-9, which requires acoustical reports and evaluation of noise mitigation measures for projects that would substantially increase noise.

Compliance with the above-mentioned regulations and policies, as well as implementation of the noise mitigation in the acoustical report, would ensure that development at the housing sites would result in less than significant permanent noise increases. b. The dominant sources of man‐made vibration are sonic booms, blasting, pile driving, pavement breaking, demolition, diesel locomotives, and rail‐car coupling. None of these activities are anticipated to occur with construction or operation of the proposed Housing Element Update, with the exception of pavement breaking and demolition of on-site structures, as well as possible pile driving. Vibration from construction activities could be detected at the closest sensitive land uses, some of which are located adjacent to housing site locations, especially during movements by heavy equipment or loaded trucks and during some paving activities.

As discussed in checklist question “a” above, construction noises (which includes vibration-related activities) are not allowed between the hours of 6:30pm and 8am pursuant to Chapter 8.56, Noise Regulation, of the City Municipal Code. Vibrationrelated activities associated with development of the proposed project would be required to remain within the abovementioned time period. In addition, future development at the housing sites would each be required to comply with the City’s General Plan Noise Element Policy P9-9, which requires acoustical reports and evaluation of noise mitigation measures for projects that would substantially increase noise. Acoustical reports typically evaluate vibration impacts for proposed projects and, therefore, would provide mitigation measures to reduce significant impacts associated with potential vibration activities.

Compliance with the City’s Municipal Code Chapter 8.56 and General Plan Policy P9-9, as well as implementation of the vibration mitigation impacts in the acoustical report, would ensure that the impacts associated with the generation of excessive ground-borne vibration or ground borne noise levels during implementation of the project would be less than significant.

Attachment 2
Section D Evaluation of Environmental Impacts 68 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 c. The nearest airport to the proposed housing sites is the Monterey Regional Airport, which is located approximately 3.5 miles northeast. Therefore, the project is not located within the vicinity of a private airstrip, an airport land-use plan, or within two miles of a public airport or public-use airport and would not expose people residing or working in the project area to excessive noise levels.

Attachment 2
Section D Evaluation of Environmental Impacts 69 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

14. POPULATION AND HOUSING
Would the project:

Comments:
a. The proposed project would result in new residential development and an increase in population in Carmel-by-the-Sea; the project anticipates an increase in approximately 734 residents. This growth is being planned for as part of this environmental analysis.

Therefore, the environmental impacts associated with this growth is evaluated throughout this initial study.
b. Only one of the housing site locations currently includes residential uses (Site #18) and the proposed project plans for 410 new housing units. Therefore, implementation of the Housing Element Update would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Induce substantial unplanned population growth in an area, either directly (e.g., by proposing new homes and businesses) or indirectly (e.g., through extension of
roads or other infrastructure)?
☐ ☐ ☐ ☒
b. Displace substantial numbers of existing people or
housing, necessitating the construction of replacement
housing elsewhere?
☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 70 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

15. PUBLIC SERVICES
Would the project result in substantial adverse physical impacts associated with the provision of or need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the following public services:

Comments:
a. The Monterey Fire Department staffs the Carmel Fire Department to protect the lives and property of residents, businesses, and visitors for the City of Carmel-by-the-Sea (City of Carmel-by-the-Sea 2023) through a contractual agreement to provide mutual and automatic aid to each other on an as-needed basis (City of Carmel-by-the-Sea 2009). The Carmel Fire Department (Station #15) is located on 6th Avenue between Mission Street and San Carlos Street.

The proposed project would result in the increase in population, which would increase the demand on fire services and could result in the need for new or physically altered facilities, the construction of which could cause significant environmental impacts.

However, the Monterey Fire Chief indicates that based on the current capacity of the crew stationed in Carmel-by-the-Sea, there will not be a need to increase staffing or add to the facilities to handle this increase in population (Gaudenz Panholzer, email message, August 4, 2023).
b. The City Police Department is responsible for law enforcement and crime prevention within the City of Carmel-by-the-Sea. The City Police Department is located on southeast corner of Junipero Street and 4th Avenue.

The proposed project would result in the increase in population, which would increase the demand on police protection services and could result in the need for new or physically altered facilities, the construction of which could cause significant environmental impacts. However, according to the Police Chief, the City Police Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Fire protection? ☐ ☐ ☐ ☒
b. Police protection? ☐ ☐ ☒ ☐
c. Schools? ☐ ☐ ☒ ☐
d. Parks? ☐ ☐ ☒ ☐
e. Other public facilities? ☐ ☐ ☒ ☐
Attachment 2
Section D Evaluation of Environmental Impacts 71 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Department is currently exploring a building renovation to meet these exact needs and allow the City Police Department to meet future standards (Jeff Watkins, email message, July 31, 2023).

Building renovations and small building expansions are generally exempt from CEQA due to their minimal environmental impacts. Therefore, the environmental effects from physical impacts to the City Police Department facilities resulting from the proposed project would be less than significant.
c. The students generated by the proposed project would be served by the schools within the Carmel Unified School District. This increase in students would increase the demand on the Carmel Unified School District and could result in the need for new or physically altered facilities, the construction of which could cause significant environmental impacts.

Discussions with the Carmel Unified School District staff members indicated that they don’t have a recent student generation rate that can be used to estimate the number of students that could be generated by the proposed project. Children living in Carmel-bythe-Sea would attend Carmel River Elementary School, Carmel Middle School, and Carmel High School.

Buildout of the Housing Element Update is anticipated within eight years. Therefore, it is conservatively assumed that implementation of the proposed project would result in the need for new or physically altered facilities, the construction of which could cause significant environmental impacts (Sharon Ofek, zoom meeting, August 8, 2023).

In accordance with Senate Bill 50, the project developers for the housing sites would be required to pay development impact fees to the school district at the time of the building permit issuance for each individual housing site. The school district would use collected funds towards new facilities to offset any impacts associated with new development.

Pursuant to California Government Code Section 65996, payment of these fees is deemed to fully mitigate cumulative CEQA impacts of new development on school facilities. Therefore, payment of state-mandated impact fees would reduce potential impacts on school facilities to a less-than-significant level. d, e. Due to the proposed project’s increase in population, an increase in the use of nearby parks and other facilities may occur. The General Plan does not include a policy requiring a minimum amount of park acreage per resident. Other cities have an adopted standard of providing 3-5 acres of neighborhood and community parks for every 1,000 residents.

By this standard, Carmel-by-the-Sea exceeds the acreage for meeting the parkland needs of its residents due to its approximately 138 acres of parks and open space. Additionally, as stated within the General Plan Public Facilities and Services Element, public recreational facilities include the beach (City of Carmel-by-the-Sea 2009). Therefore, the proposed project would not result in significant impacts associated with requiring physical changes to existing, or requiring new, parkland areas.

Attachment 2
Section D Evaluation of Environmental Impacts 72 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

16. RECREATION
Comments:
a, b. The proposed project is the implementation of the City’s 6th Cycle 2023-2031 Housing Element, which would result in an increase in population and could also result in the increased use of existing parks or other recreational facilities within the City of Carmelby-the-Sea.

A variety of different parklands and recreational facilities are provided by the City of Carmel-by-the-Sea to serve the needs of the community. Parks include community parks, beach parks, and small mini-parks. Refer back to Section 15.0, Public Services, checklist question “d, e” for more information on potential impacts the proposed project could have on the City’s parks and recreational facilities.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Would the project increase the use of existing
neighborhood and regional parks or other recreational
facilities such that substantial physical deterioration of the facility would occur or be accelerated?
☐ ☐ ☒ ☐
b. Does the project include recreational facilities or
require the construction or expansion of recreational
facilities, which might have an adverse physical effect on the environment?
☐ ☐ ☒ ☐
Attachment 2
Section D Evaluation of Environmental Impacts 73 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

17. TRANSPORTATION
Would the project:

Comments:
a. Some of the housing sites are located within the Single-Family (R-1) Zoning District and the General Plan Circulation Element Policy P2-3 prohibits the construction of formal sidewalks and concrete curbs in the R-1 district. Therefore, these housing sites do not have pedestrian facilities present. According to Figure 2-2 of the General Plan Circulation Element and the location of the housing sites, bike routes are only located on the streets fronting some of the sites (e.g., bike routes are present on San Carlos Avenue and 8th Avenue but not in other locations where housing sites are located). Bus routes are located throughout the City and are within walking distance to all housing sites proposed.

According to the General Plan Circulation Element, many of the downtown streets and intersections in the commercial district carry traffic volumes that exceed their design capacity as a result of externally-generated traffic associated with visitors and tourists. For this reason, and for the growing population of the City, General Plan Circulation Element Policy P2-16 requires the limitation of distribution, character and intensity of land uses that generate increased levels of traffic beyond the capacity of the existing street system.

The City also established a regional development impact fee for the purpose of paying for regional transportation improvement projects needed to meet increased demand created by traffic resulting from new development. This payment is required by the applicant prior to issuance of a building permit.

Implementation of the proposed project would be subject to and implement General Plan policies applicable to transit, bicycle, and pedestrian facilities. Additionally, future development projects under the proposed project would be subject to all applicable City guidelines, standards, and specifications related to transit, bicycle, or pedestrian facilities.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Conflict with a program, plan, ordinance, or policy
addressing the circulation system, including transit,
roadway, bicycle and pedestrian facilities?
☐ ☐ ☐ ☒
b. Conflict or be inconsistent with CEQA guidelines
section 15064.3, subdivision (b)? ☐ ☐ ☒ ☐
c. Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
☐ ☐ ☐ ☒
d. Result in inadequate emergency access? ☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 74 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Any modifications or new transit, bicycle, and pedestrian facilities would be subject to and designed in accordance with all applicable General Plan policies. In particular, Circulation Element Policies P2-3 and P2-16 identified previously as well as Policy P2-14, which states to design and construct, where appropriate, roadway improvements which eliminate adverse impacts of high volume through traffic, and Objective O2-5, which requires that all new developments provide sufficient off-street parking facilities.

Because implementation of the proposed project would be subject to all applicable City guidelines, standards, and specifications, as well as pay the regional impact fee, the proposed project would not conflict with adopted policies, plans, or programs for transit, bicycle, or pedestrian facilities.
b. Hexagon Transportation Consultants prepared a memorandum (VMT Analysis for the Carmel-by-the-Sea Housing Element Update (“VMT analysis”), dated August 28, 2023 for the proposed project to determine whether the project would result in a significant vehicle miles traveled (VMT) impact.

The City of Carmel-by-the-Sea has not adopted a VMT policy and, therefore, the general practice is to follow the Governor’s Office of Planning and Research (OPR)’s Technical Advisory on Evaluating Transportation Impacts in CEQA. Per these guidelines, there are several categories of projects that could be presumed to have a less than significant VMT impact, or be screened out of a VMT analysis.

Screening Threshold for Small Projects (projects that generate or attract fewer than 110 trips per day generally may be assumed to cause a less than significant transportation impact) - The VMT analysis states that the housing sites proposed included moderate- or above moderate-income levels that would generally have residential capacities that are below 12 units per site. Hexagon Transportation Consultants tested the daily project trip generation for various potentially applicable land use categories and determined that each individual housing site with moderate- and above moderate-income level housing would not generate more than 110 trips per day. Therefore, all of these housing sites are presumed to generate a less than significant VMT impact.

Presumption of Less Than Significant Impact for Affordable Residential Development (100 percent affordable residential development in infill locations may be presumed to cause a less-than-significant transportation impact) - As stated in the VMT analysis, most of the remaining housing sites include exclusively affordable housing residential capacity.

The residential capacity for hospitality employee housing would also be categorized as very low- and low-income level housing. Per OPR guidelines, all of these sites would thus be presumed to cause a less than significant transportation impact.

Map-Based Screening for Residential Projects (residential projects that are located in areas with low VMT, and that incorporate similar features (i.e., density, mix of uses, transit accessibility), will tend to exhibit similar low VMT, and may be screened out of needing to prepare a detailed VMT analysis) - The VMT analysis concludes that because all areas of the City are located in low VMT areas, per the OPR guidelines, all housing sites can be presumed to generate less than significant VMT.

Attachment 2
Section D Evaluation of Environmental Impacts 75 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 The VMT analysis states that while all housing sites can be presumed to have a less than significant VMT impact, a quantitative VMT analysis is also required to determine the VMT effects of the proposed project as a whole, assuming buildout of all housing sites.

Based on the quantitative analysis prepared, the VMT analysis concluded that the VMT threshold for the proposed residential developments would be 9.6 daily miles traveled, which is less than the County average daily residential VMT per capita of 11.3. Therefore, the proposed project at a plan level would generate a less than significant VMT impact. c. Subsequent projects under the proposed project, including any new roadway, bicycle, or pedestrian infrastructure improvements would be subject to, and designed in accordance with, City standards and specifications that address potential design hazards including sight distance, driveway placement, and signage. Additionally, any new transportation facilities, or improvements to such facilities associated with subsequent projects, would be constructed based on industry design standards and best practices consistent with the City’s zoning code, building design, and inspection requirements. Therefore, the proposed project would not result in a design feature that would increase hazards. d. There are no development projects proposed at this time; therefore, specific housing sites developed under the proposed project cannot be analyzed for adequacy of emergency access. However, the City maintains the roadway network that provides access to new development sites in accordance with industry design standards, which ensures that the physical network would be free of obstructions to emergency responders. Emergency access to new development sites proposed under the project would be subject to review by the City and responsible emergency service agencies, thus ensuring the projects would be designed to meet all emergency access and design standards. General Plan Circulation Element Policy P2-1, in part, requires that changes to street configurations do not conflict with emergency vehicle access requirements and/or the requirements of the Emergency Operations Plan (most current version adopted in 2021).

Based on the above considerations, adequate emergency access would be provided to the housing sites.

Attachment 2
Section D Evaluation of Environmental Impacts 76 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

18. TRIBAL CULTURAL RESOURCES
Would the project:

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
Comments:
a. The City sent out letters to Native American tribes traditionally and culturally affiliated with the City of Carmel-by-the-Sea on March 9, 2023 asking if any request AB 52 consultation. The City received one response from the Esselen Tribe of Monterey County on March 12, 2023 requesting consultation and the City has met with the tribal leader in person and been in communication via email with other leaders of the Tribe. The City has continued their efforts to consult and meet with the Tribe since late May 2023, with no response back from the Tribe as of October 2, 2023 (Marnie Waffle, email message, October 2, 2023).
a. Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public
Resources Code section 21074 as either a site, feature, place, or cultural landscape that is geographically
defined in terms of the size and scope of the
landscape, sacred place, or object with cultural value
to a California Native American tribe, and that is:
(1) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of
historical resources as defined in Public Resources
code section 5020.1(k), or
☐ ☐ ☐ ☒
(2) A resource determined by the lead agency, in its
discretion and supported by substantial evidence, to
be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code Section
5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead
agency shall consider the significance of the resource
to a California Native American tribe.
☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 77 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

19. UTILITIES AND SERVICE SYSTEMS
Would the project:

Comments:
a. Carmel-by-the-Sea is served by existing water, wastewater, storm water drainage, electric power, natural gas, and telecommunications facilities. Reasonably foreseeable development resulting from implementation of the proposed project would increase demand and may require new or expanded facilities.

It would be speculative at this time to determine the impacts related to the construction of new, or expansion of existing, such facilities. Impacts from any infrastructure improvements required by new development associated with the project would be further analyzed under separate CEQA review when determinations are made on the type, scope, and location of the infrastructure improvements. If required, utilities would be installed during each individual project construction and would not result in significant environmental effects beyond those identified throughout this initial study.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Require or result in the relocation or construction of new or expanded water, wastewater treatment, storm
water drainage, electric power, natural gas, or
telecommunications facilities, the construction or
relocation of which could cause significant
environmental effects?
☐ ☐ ☒ ☐
b. Have sufficient water supplies available to serve the project and reasonably foreseeable future
development during normal, single-dry and multipledry years? ☐ ☐ ☒ ☐
c. Result in a determination by the wastewater treatment provider, which serves or may serve the project that it has inadequate capacity to serve the project’s
projected demand in addition to the provider’s
existing commitments?
☐ ☐ ☐ ☒
d. Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals?
☐ ☐ ☐ ☒
e. Comply with federal, state, and local management and reduction statutes and regulations related to solid
waste?
☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 78 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Therefore, the proposed project would not require or result in the relocation or construction of new or expanded water facilities, the construction or relocation of which could cause significant environmental effects beyond those already identified throughout this EIR.
b. Carmel-by-the Sea receives its water from the California-American Water Company (CalAm) Central Division who pumps its water from several local water sources: groundwater from the Carmel River Aquifer, Seaside Groundwater Basin, Aquifer Storage and Recovery, indirect portable reuse from Pure Water Monterey, and desalinated water from Sand City. The majority of water received in the City is from the Carmel River and the Seaside Groundwater Basin (City of Carmel-by-the-Sea 2023b).

Cal-Am’s Final Urban Water Management Plan (UWMP) (June 2021) provides several tables illustrating normal, single- and five consecutive-dry year water supply and demands to determine the total available supply. The supply from the Carmel River Aquifer, Seaside Groundwater Basin, Sand City Desalination Plant, and Monterey Peninsula Water Supply Project (MPWSP) Desalination Plant (anticipated to be operational by 2030) are all anticipated to be reliable and provide their contractual or design supply in all year types.

Until the MPWSP Desalination Plant is online, it is expected that demands will need to be constrained through the enaction of the Water Shortage Contingency Plan (CaliforniaAmerican Water Company 2021, p. E-4). As described in the UWMP, the Water Shortage Contingency Plan is used to provide guidance to the Monterey County District’s governing body, staff, and the public by identifying response actions to allow for efficient management of any water shortage with predictability and accountability. It provides the tools to maintain reliable supplies and reduce the impacts of supply interruptions due to extended drought or catastrophic supply interruptions.

The water demand for the UWMP was calculated based on regional population growth projections available prior to the release of AMBAG’s current RHNA. The RHNA would result in more residential units within Cal-Am’s service area than what was considered in the UWMP. According to the Monterey Peninsula Water Management District’s Technical Memorandum dated June 1, 2023, the City requires at least 46 acre-feet of water to meet the needs of the City’s RHNA plus the 17 percent buffer included in the Housing Element Update and evaluated in this initial study (i.e., total of 410 housing units).

The Housing Element Update indicates that almost half of the housing anticipated would be moderate, low-, or very low-income housing. Section 17.50.040.A of the City Attachment 2
Section D Evaluation of Environmental Impacts 79 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Municipal Code states that projects involving no net increase in water use or that will create new housing affordable to moderate, low-or very low-income households may be accepted and processed without regard to water allocations.

Implementation of the following standard condition of approval would be required by future applicants requesting to develop the housing sites to ensure that there would be sufficient water supplies available to serve each individual project and reasonably foreseeable future development during normal, single-, and multiple-dry years.

Standard Condition of Approval

The Carmel Area Wastewater District uses a wastewater generation rate of 100 gallons per day (GPD) per residential unit. Therefore, the Housing Element Update is projected to generate 40,000 GPD of wastewater. The wastewater treatment plant currently has the capacity and ability to take on the project’s generation of wastewater (Barbara Buikema, email message, September 13, 2023). Therefore, the proposed project would not result in a determination by the wastewater treatment provider that it has inadequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments. d, e. The solid waste needs of the City of Carmel-by-the-Sea are served by ReGen Monterey, formerly the Monterey Regional Waste Management District, located at 14201 Del Monte Boulevard in Marina. The ReGen Monterey property includes the Monterey Peninsula Landfill, which collects the solid waste (ReGen Monterey 2023). The Monterey Peninsula Landfill has a maximum permitted capacity of 49.7 million cubic yards (CalRecycle 2023a).

The proposed project would generate approximately 11,670 pounds of solid waste per day (734 residents x 15.9 pounds of solid waste per person per day) (CalRecycle 2023b), or approximately 6.9 cubic yards of solid waste per day. Many of the housing sites are proposed on currently developed properties, whose solid waste needs are already served by the landfill. The housing sites proposed on vacant properties would be new solid waste being served by the landfill. Nonetheless, the Monterey Peninsula Landfill has sufficient capacity to serve the solid waste needs of the proposed project and would comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

Attachment 2
Section D Evaluation of Environmental Impacts 80 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

20. WILDFIRE
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

Comments:

According to the California Department of Forestry and Fire Protection’s FHSZ Viewer, none of the housing sites are located within a state responsibility area or within a very high fire hazard severity zone (CalFire 2023); however, the sites are located near state responsibility areas, which border the city. Housing sites #3, #4, and #11 are located nearest to the city border, and therefore are located nearest to the state responsibility area. a. The proposed project involves the development of housing sites generally throughout central Carmel-by-the-Sea on vacant or underutilized parcels. The nearest emergency evacuation route from the housing sites is the primary route located on Carpenter Street, four blocks east from housing site #3 (City of Carmel-by-the-Sea 2015). Therefore, the City’s emergency evacuation routes would not be impaired by implementation of the proposed project.
b. Housing sites #3, #4, and #11 each slope southwest towards the ocean. These slopes could increase the speed and intensity of wildfires exacerbating wildfire risks. However, development of housing sites #3, #4, #11, or any of the housing sites identified in the Housing Element Update, would not exacerbate wildfire risks and thereby expose people to pollutant concentrations from a wildfire or the uncontrolled spread of wildfires.

Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Substantially impair an adopted emergency response
plan or emergency evacuation plan? ☐ ☐ ☐ ☒
b. Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to pollutant concentrations from a wildfire
or the uncontrolled spread of wildfire?
☐ ☐ ☐ ☒
c. Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency
water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
☐ ☐ ☐ ☒
d. Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
☐ ☐ ☐ ☒
Attachment 2
Section D Evaluation of Environmental Impacts 81 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 c. The Housing Element Update involves the development of housing on vacant and underutilized parcels within the developed City of Carmel-by-the-Sea. Each of the housing sites have the ability to connect into the City’s existing water and wastewater lines and have access to existing overhead electricity power lines. Therefore, implementation of the Housing Element Update would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.
d. The City’s Environmental Safety Element Figure 8.2, Areas Prone to Landslide, illustrates the locations within Carmel-by-the-Sea that are susceptible to landslide hazards. None of the housing sites are located within the areas identified on Figure 8.2. Development of the housing sites identified in the Housing Element Update would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

Attachment 2
Section D Evaluation of Environmental Impacts 82 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024

21. MANDATORY FINDINGS OF SIGNIFICANCE
Comments:
a. As discussed in Section 4.0, Biological Resources, Mitigation Measures BIO-1 through BIO-5 would reduce the potential adverse impact on the Monarch Butterfly, Obscure and Western Bumble Bees, bats, and nesting birds and raptors during construction of the proposed project to a less-than-significant level.

As described in Section 5.0, Cultural Resources, some of the housing sites are listed on the Carmel Inventory of Historic Resources Database. Future applications for development on these sites would require additional review at the application submittal stage of the permit process and the applicants would be required to incorporate any changes to the development required by City staff to ensure impacts associated with historic resources are not significant. Additionally, archaeological resources from both the prehistoric period and the early historic period can be found in Carmel-by-the-Sea; therefore, implementation of the standard conditions of approval identified in Section 5.0, Cultural Resources, checklist question “b” would ensure that the potential impacts to these resources would not be significant.
b. Proposed project impacts that contribute to cumulative project impacts are required to be lessened per the mitigation measures presented in this initial study. With implementation Potentially
Significant
Impact
Less-than-Significant
Impact with Mitigation
Measures Incorporated
Less-ThanSignificant
Impact
No
Impact
a. Does the project have the potential to substantially degrade the quality of the environment; substantially
reduce the habitat of a fish or wildlife species; cause a fish or wildlife population to drop below selfsustaining levels; threaten to eliminate a plant or animal community; substantially reduce the number or
restrict the range of an endangered, rare, or threatened species; or eliminate important examples of the major
periods of California history or prehistory?
☐ ☒ ☐ ☐
b. Does the project have impacts that are individually
limited, but cumulatively considerable? (“Cumulatively
considerable” means that the incremental effects of a
project are considerable when viewed in connection
with the effects of past projects, the effects of other current projects, and the effects of probable future
projects)
☐ ☐ ☒ ☐
c. Does the project have environmental effects, which
will cause substantial adverse effects on human beings, either directly or indirectly?
☐ ☐ ☒ ☐
Attachment 2
Section D Evaluation of Environmental Impacts 83 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 of the mitigation measures, standard conditions of approval, and policies identified herein, the project’s contribution to cumulative project impacts would not be considerable.
c. Based on the analysis provided in this initial study, the proposed project could indirectly cause substantial adverse effects to human beings through soil erosion and seismic ground-shaking. However, as discussed throughout this initial study, the impacts would not be significant. Therefore, the proposed project would not result in significant environmental effects that would cause substantial adverse effects on human beings, either directly or indirectly.

Attachment 2
Section E Sources 84 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 E. SOURCES
Setting and Background
City of Carmel-by-the-Sea. August 2023. 6th Cycle Housing Element Update (2023-2031) Housing and Community Development (HCD) Initial Draft.

EMC Planning Group. August 2023. Review of Environmental Safety Element for Compliance with Recent State Legislation. Monterey, CA.

Google Earth. 2023.

Project Description
California Department of Finance. May 2023 “E-5 Population and Housing Estimates for Cities, Counties, and the State, January 2021-2023, with 2020 Benchmark.” https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housingestimates-for-cities-counties-and-the-state-2020-2023/ City of Carmel-by-the-Sea. August 2023. 6th Cycle Housing Element Update (2023-2031) Housing and Community Development (HCD) Initial Draft.

Aesthetics
California Department of Transportation. “California State Scenic Highway System Map.” Accessed on July 13, 2023.
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46 cc8e8057116f1aacaa
Monterey County. April 1983. Carmel Area Land Use Plan. chromeextension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.co.monterey.ca.us/home /showpublisheddocument/37889/636371078026230000
Agriculture
City of Carmel-by-the-Sea. September 2009. General Plan/Coastal Land Use Program.

Carmel-by-the-Sea, CA.

Air Quality
Association of Monterey Bay Area Governments. 2022. Regional Growth Forecast. June 2022. https://www.ambag.org/sites/default/files/2022-12/REVISED_PDFAAppendix %20A_2022%20RGF.pdf.

Accessed September 14, 2023
Attachment 2
Section E Sources 85 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 California Air Resources Board. “Summary: Diesel Particulate Matter Health Impacts.” https://ww2.arb.ca.gov/resources/summary-diesel-particulate-matter-health-impacts EMC Planning Group. September 22, 2023. CalEEMod Results, Apple Ave Subdivision Proposed Emissions. Monterey, CA.

Hexagon Transportation Consultants, Inc. 2023. Carmel Housing Element Update VMT Analysis.

August 28, 2023
Monterey Bay Air Resources District. 2017. Air Quality Management Plan. Monterey, CA. https://www.mbard.org/air-quality-plans
Monterey Bay Unified Air Pollution Control District. 2008. CEQA Air Quality Guidelines.

February 2008. https://www.co.monterey.ca.us/home/showdocument?id=22559.

Accessed September 20, 2023
Biological Resources
Bassett, Corinne G., Ryan Gilpin, and Kara Donohue. 2021. Tree Care for Wildlife Best Management Practices. Western Chapter of the International Society of Arboriculture.

California Native Plant Society (CNPS). 2023. Inventory of Rare and Endangered Plants of California online database. Sacramento, California. Accessed September 2023. http://www.rareplants.cnps.org
California Fish and Game Commission. 2019. Notice of Findings for Crotch Bumble Bee (Bombus crotchii), Franklin’s Bumble Bee (Bombus franklini), Suckley Cuckoo Bumble Bee (Bombus suckleyi), and Western Bumble Bee (Bombus occidentalis occidentalis).

California Department of Fish and Wildlife (CDFW). 2023a. California Natural Diversity Database (CNDDB) online database. Sacramento, California. Accessed September 2023. https://wildlife.ca.gov/data/cnddb
CDFW. 2023b. Biogeographic Information and Observation System (BIOS) online database.

Sacramento, California. Accessed September 2023.
http://bios.dfg.ca.gov
CDFW. 2023c. California Natural Community List. Sacramento, California.

Accessed September 2023.

CDFW. 2023d. California Essential Habitat Connectivity Project. Sacramento, California.

Accessed September 2023.
https://wildlife.ca.gov/Conservation/Planning/Connectivity/CEHC City of Carmel-by-the-Sea. 2009. General Plan/Coastal Land Use Program. Carmel-by-the-Sea, CA.

City of Carmel Forestry Department. 2001. City of Carmel-by-the-Sea Forest Management Plan.

Carmel-by-the-Sea, CA.

Attachment 2
Section E Sources 86 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 EMC Planning Group, Inc. 2023. City of Carmel’s’ 6th Cycle 2023-2031 Housing Element (2023-2031) Housing and Community Development (HCD).

Jepsen, S., E. Pelton, S. H. Black, C. Fallon, C. Voight, and S. Weiss. 2017. Protecting California’s butterfly groves: management guidelines for monarch butterfly over- wintering habitat. Xerces Society for Invertebrate Conservation and Creekside Center for Earth Observation, Portland, OR and Meno Park, CA, USA.

Jones & Stokes Associates, Inc. 1995. Final Results of the Environmentally Sensitive Habitat Area Study Conducted for the City of Carmel-by-the-Sea. Carmel-by-the-Sea, CA.

U.S. Fish and Wildlife Service (USFWS). 2023a. Endangered Species Program online database. Species list for Monterey County. Washington, D.C. Accessed September 2023. http://www.fws.gov/endangered/
USFWS. 2023b. National Wetlands Inventory online database. Washington, D.C.

Accessed September 2023.
http://www.fws.gov/wetlands/
USFWS. 2023c. Critical Habitat for Threatened and Endangered Species online mapper.

Accessed September 2023.
https://fws.maps.arcgis.com/home/webmap/viewer.html?webmap=9d8de5e265ad4fe 09893cf75b8dbfb77
Cultural Resources
City of Carmel-by-the-Sea. August 2023. 6th Cycle Housing Element Update (2023-2031) Housing and Community Development (HCD) Initial Draft.

City of Carmel-by-the-Sea. June 2022. “Carmel Inventory of Historic Resources Database.” https://ci.carmel.ca.us/sites/main/files/carmel_inventory_of_historic_resources_ v2022.pdf
City of Carmel-by-the-Sea. September 2009. General Plan/Coastal Land Use Program.

Carmel-by-the-Sea, CA.

Energy
California Energy Commission. 2022. Building Energy Efficiency Standards. https://www.energy.ca.gov/programs-and-topics/programs/building-energy-efficiencystandards/2022-building-energy-efficiency. Accessed September 21, 2023 California Energy Commission. Energy Consumption Data Management System. http://www.ecdms.energy.ca.gov. Accessed September 20, 2022 Hexagon Transportation Consultants, Inc. 2023. Carmel Housing Element Update VMT Analysis.

August 28, 2023
Attachment 2
Section E Sources 87 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Geology and Soils
California Department of Conservation. “Earthquake Zones of Required Investigation.” Accessed on September 18, 2023.
https://maps.conservation.ca.gov/cgs/EQZApp/app/
City of Carmel-by-the-Sea. September 2009. General Plan/Coastal Land Use Program.

Carmel-by-the-Sea, CA.

City of Carmel-by-the-Sea. Municipal Code. Updated through July 2023. https://www.codepublishing.com/CA/CarmelbytheSea/#!/CarmelNT.html Monterey County. 1978. Soil Survey of Monterey County, California.

Monterey County. “Parcel Report Web App.” Accessed on September 18, 2023a. https://maps.co.monterey.ca.us/wab/parcelreportwebapp/
Monterey County. “Paleontology.” Accessed on September 19, 2023b. https://montereycountyopendata-12017-01-13t232948815zmontereyco.opendata.arcgis.com/datasets/MontereyCo::paleontology/explore?location =36.506399%2C-121.834082%2C12.00
Greenhouse Gas Emissions
Association of Environmental Professionals. 2016. Final Whitepaper - Beyond 2020 and Newhall:

A Field Guide to New CEQA Greenhouse Gas Thresholds and Climate Action Plan Targets for California. https://califaep.org/docs/AEP-2016_Final_White_Paper.pdf.

Accessed September 22, 2023
Association of Monterey Bay Area Governments. 2022. Regional Growth Forecast. June 2022. https://www.ambag.org/sites/default/files/2022-12/REVISED_PDFAAppendix %20A_2022%20RGF.pdf. Accessed September 14, 2023
Bay Area Air Quality Management District. 2022. CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans. https://www.baaqmd.gov/plans-andclimate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines.

Accessed September 22, 2023
California Office of Planning and Research. 2018. Discussion Draft, CEQA and Climate Change Advisory. https://opr.ca.gov/docs/20181228-Discussion_Draft_Climate_Change_ Adivsory.pdf . Accessed September 22, 2023
California Office of Planning and Research. 2018. Accessed on August 11, 2022. Technical Advisory on Evaluating Transportation Impacts in CEQA. http://opr.ca.gov/docs/20190122- 743_Technical_Advisory.pdf. Accessed September 22, 2023 Attachment 2
Section E Sources 88 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 City of Carmel-by-the-Sea. 2022. Climate Action Plan. July 2022. https://ci.carmel.ca.us/sites/main/files/file-attachments/climate_adaptation_plan_ appendixa_climate_action_plan_prefinal_042822.pdf?1656630014#:~:text=In%20the% 20City%20of%20Carmel,to%20meet%20the%20State%20target.

Accessed September 21, 2023
San Luis Obispo County Air Pollution Control District. 2012. CEQA Air Quality Handbook. https://storage.googleapis.com/slocleanair-org/images/cms/upload/files/CEQA_ Handbook_2012_v2%20%28Updated%20MemoTable1-1_July2021%29_Linkedwith Memo.pdf. Accessed September 22, 2023
Hazards and Hazardous Materials
California Department of Industrial Relations. Subchapter 4, Construction Safety Orders – Article 4 - Dusts, Fumes, Mists, Vapors, and Gases. Accessed on July 27, 2023. https://www.dir.ca.gov/title8/sb4a4.html
California Department of Toxic Substances Control. “Envirostor – Hazardous Waste and Substances Site List (Cortese).” Accessed on July 28, 2023. https://www.envirostor.dtsc.ca.gov/public/search.asp?page=1&cmd=search&business _name=&main_street_name=&city=&zip=&county=&status=ACT%2CBKLG%2CC OM&branch=&site_type=CSITES%2CFUDS&npl=&funding=&reporttitle=HAZAR DOUS+WASTE+AND+SUBSTANCES+SITE+LIST+%28CORTESE%29&reportt ype=CORTESE&federal_superfund=&state_response=&voluntary_cleanup=&school _cleanup=&operating=&post_closure=&non_operating=&corrective_action=&tiered_ permit=&evaluation=&spec_prog=&national_priority_list=&senate=&congress=&ass embly=&critical_pol=&business_type=&case_type=&searchtype=&hwmp_site_type= &cleanup_type=&ocieerp=&hwmp=False&permitted=&pc_permitted=&inspections= &inspectionsother=&complaints=&censustract=&cesdecile=&school_district=&order by=county
California Environmental Protection Agency. “List of solid waste disposal sites identified by Water Board with waste constituents above hazardous waste levels outside the waste management unit (PDF).” Accessed on July 28, 2023a. chromeextension://efaidnbmnnnibpcajpcglclefindmkaj/https://calepa.ca.gov/wpcontent/uploads/sites/6/2016/10/SiteCleanup-CorteseList-CurrentList.pdf California Environmental Protection Agency. “List of “active” CDO and CAO from Water Board (MS Excel, 1,453 KB).” Accessed on July 28, 2023b. https://calepa.ca.gov/sitecleanup/corteselist/
California Environmental Protection Agency. “List of hazardous waste facilities subject to corrective action pursuant to Section 25187.5 of the Health and Safety Code, identified by DTSC.” Accessed on July 28, 2023c.
https://calepa.ca.gov/sitecleanup/corteselist/section-65962-5a/?emrc=63f01af3d8806 Attachment 2
Section E Sources 89 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 California Department of Forestry and Fire Protection. “FHSZ Viewer.” Accessed on July 21, 2023. https://egis.fire.ca.gov/FHSZ/ City of Carmel-by-the-Sea. September 2009. General Plan/Coastal Land Use Program.

Carmel-by-the-Sea, CA.

Google Earth. 2023.

State Water Resources Control Board. “GeoTracker.” Accessed on July 28, 2023. https://geotracker.waterboards.ca.gov/map/?myaddress=California&from=header&cq id=9235730826
Hydrology and Water Quality
California Department of Conservation. “Monterey County Tsunami Hazard Areas.” Accessed on September 18, 2023.
https://www.conservation.ca.gov/cgs/tsunami/maps/monterey City of Carmel-by-the-Sea. Municipal Code. Updated through July 2023a. https://www.codepublishing.com/CA/CarmelbytheSea/#!/CarmelNT.html City of Carmel-by-the-Sea. “Water Conservation.” Accessed on September 18, 2023b. https://ci.carmel.ca.us/post/waterconservation#:~:text=The%20majority%20of%20the%20water,River%20or%20the%2 0Seaside%20Basin
Department of Water Resources. “Groundwater Basin Boundary Assessment Tool.” Accessed on September 14, 2023. https://gis.water.ca.gov/app/bbat/ Federal Emergency Management Agency (FEMA). “FEMA Flood Map Service Center:

Search By Address.” Accessed on September 15, 2023.
https://msc.fema.gov/portal/search#searchresultsanchor
Monterey County. “Parcel Report Web App.” Accessed on September 18, 2023. https://maps.co.monterey.ca.us/wab/parcelreportwebapp/
Land Use and Planning
City of Carmel-by-the-Sea. August 2023. 6th Cycle Housing Element Update (2023-2031) Housing and Community Development (HCD) Initial Draft.

Mineral Resources
U.S. Geological Survey. “Mineral Resources Online Spatial Data.” Accessed on July 18, 2023. https://mrdata.usgs.gov/general/map-us.html
Attachment 2
Section E Sources 90 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 Noise
City of Carmel-by-the-Sea. Municipal Code. Updated through July 2023. https://www.codepublishing.com/CA/CarmelbytheSea/#!/CarmelNT.html Population and Housing
City of Carmel-by-the-Sea. August 2023. 6th Cycle Housing Element Update (2023-2031) Housing and Community Development (HCD) Initial Draft.

Public Services
City of Carmel-by-the-Sea. September 2009. General Plan/Coastal Land Use Program.

Carmel-by-the-Sea.

City of Carmel-by-the-Sea. “Police and Fire.” Accessed on July 18, 2023. https://ci.carmel.ca.us/police-fire
Ofek, Sharon, Deputy Superintendent – Educational Services, Carmel Unified School District.

Zoom meeting with consultant, 8 August 2023.

Recreation
City of Carmel-by-the-Sea. August 2023. 6th Cycle Housing Element Update (2023-2031) Housing and Community Development (HCD) Initial Draft.

Transportation
City of Carmel-by-the-Sea. September 2009. General Plan/Coastal Land Use Program.

Carmel-by-the-Sea, CA.

Hexagon Transportation Consultants. August 2023. VMT Analysis for the Carmel-by-the-Sea Housing Element Update. San Jose, CA.

Tribal Cultural Resources
Waffle, Marnie, AICP, Principal Planner, City of Carmel-by-the-Sea Community Planning and Building Department. Email message to consultant, 13 July 2023 and 2 October 2023.

Utilities and Service Systems
Buikema, Barbara, General Manager, Carmel Area Wastewater District. Email correspondence with consultant, 13 September 2023.

Attachment 2
Section E Sources 91 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 California-American Water Company. June 2021. Final Urban Water Management Plan. https://wuedata.water.ca.gov/getfile?filename=/public%2Fuwmp_attachments%2F359 6173942%2FFinal_Monterey_UWMP_compiled.pdf
CalRecycle. “SWIS Facility/Site Activity Details - Monterey Peninsula Landfill (27-AA-0010).” Accessed on September 13, 2023a.
https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/2642?siteID=1976 CalRecycle. “Disposal Rate Calculator – Carmel-by-the-Sea – 2022.” Accessed on September 13, 2023b.
https://www2.calrecycle.ca.gov/LGCentral/AnnualReporting/DisposalRateCalculator City of Carmel-by-the-Sea. Municipal Code. Updated through July 2023a. https://www.codepublishing.com/CA/CarmelbytheSea/#!/CarmelNT.html City of Carmel-by-the-Sea. “Water Conservation.” Accessed on September 18, 2023b. https://ci.carmel.ca.us/post/waterconservation#:~:text=The%20majority%20of%20the%20water,River%20or%20the%2 0Seaside%20Basin
Monterey Peninsula Water Management District. June 2023. Technical Memorandum - Summary of Water Supply Requirements for Housing. Monterey, CA.

ReGen Monterey. “About Us.” Accessed on September 13, 2023. https://regenmonterey.org/about/#1488961033450-0782f568-b1863b55-93c5 Wildfire
California Department of Forestry and Fire Protection. “FHSZ Viewer.” Accessed on July 21, 2023. https://egis.fire.ca.gov/FHSZ/ City of Carmel-by-the-Sea. November 2015. Carmel-by-the-Sea Emergency Evacuation Route. chromeextension://efaidnbmnnnibpcajpcglclefindmkaj/https://ci.carmel.ca.us/sites/main/file s/file-attachments/cityofcarmel_emergencyroutes_final_- _nov_6_2015_1_0.pdf?1570563179
Attachment 2
Section E Sources 92 EMC Planning Group
City of Carmel-by-the-Sea 6th Cycle Housing Element Update (2023-2031) and Safety Element Update Initial Study February 20, 2024 This side intentionally left blank.

Attachment 2
6 th Cycle Housing Element Update (2023-2031) Housing and Community Development Revised Draft (January 24, 2024) A

APPENDIX
Attachment 2
Attachment 2
Housing and Community Development (HCD) Revised Draft
6th Cycle Housing Element Update
(2023-2031)

CITY OF CARMEL-BY-THE-SEA
January 24, 2024
Prepared by
EMC Planning Group
Attachment 2
Attachment 2

HOUSING AND COMMUNITY DEVELOPMENT (HCD) REVISED DRAFT
6 TH CYCLE HOUSING ELEMENT UPDATE
(2023-2031)

CI TY OF CARMEL-BY-THE -SEA

PREPARED FOR
City of Carmel-by-the-Sea
Marnie Waffle, AICP, Principal Planner
City of Carmel-by-the-Sea
P.O. Box CC
Carmel-by-the-Sea, CA 93921
Tel 831.620.2000

PREPARED BY
EMC Planning Group Inc.
601 Abrego Street
Monterey, CA 93940
Tel 831.649.1799
Fax 831.649.8399
Anastazia Aziz, AICP, Principal
[email protected]
www.emcplanning.com
January 24, 2024
This document was produced on recycled paper.

Attachment 2
Attachment 2
EMC Planning Group
Table of Contents

1.0 INTRODUCTION.................................................................................................... 1-1

1.1 Introduction ...................................................................................................................... 1-1

1.2 California’s Housing Crisis.............................................................................................. 1-2

1.3 Regional Housing Needs Allocation .............................................................................. 1-3

1.4 Affirmatively Furthering Fair Housing.......................................................................... 1-4

1.5 Overview of Planning Efforts ........................................................................................ 1-7

1.6 Public Participation ........................................................................................................ 1-11

2.0 GOALS, POLICIES, AND PROGRAMS ................................................................... 2-1

2.1 Introduction ...................................................................................................................... 2-1

2.2 What’s New....................................................................................................................... 2-1

2.3 Program Overview and Quantified Objectives............................................................ 2-2

2.4 Goals, Policies and Programs ......................................................................................... 2-3 Appendices
Appendix A Housing Needs & Fair Housing Report
Appendix B Housing Constraints
Appendix C Vacant and Available Sites
Appendix D Review of Previous Housing Element
Appendix E List of Contacted Organizations
Appendix F ECONorthwest Feasibility Study
Appendix G Energy Conservation and Reduction of Greenhouse Gas Emissions Appendix H Stakeholder Survey
Tables
Table 1-1 Regional Housing Needs Allocation .......................................................................... 1-4 Table 2-1 Quantified Objectives Summary................................................................................. 2-3 Attachment 2
Attachment 2
Chapter 1.0 – Introduction 1-1 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024

1.0 Introduction

1.1 Introduction
Carmel-by-the-Sea is a community with a high quality of life, a healthy environment, and renowned architecture. The long-term vitality of Carmel-by-the-Sea and the local economy depend upon the availability of various types of housing to satisfy the community’s local housing needs while continuing to be a vacation destination for all. As Carmel-by-the-Sea looks towards the future, increasing the range and diversity of housing options is integral to the City’s success. This Housing Element serves as a continuation of the City’s commitment to ensuring new opportunities for residential development, as well as preserving and enhancing existing neighborhoods, and continuing to protect the natural environment.

Located on the Monterey Peninsula and incorporated in 1916, Carmel-by-the-Sea is a bijou coastal community boasting sweeping views of the Pacific Ocean, acclaimed architecture, and a strong residential character. The City has nearly 50 historic properties within the centralized commercial district, primarily dating to the turn of the 20th century and the 1920-1930s period. Residences throughout the one-square-mile village span a range of construction eras but are collectively appreciated for their architectural aesthetic. As a result of its beauty, the City is a popular tourism and second-home destination. Approximately 51 percent of housing units are for seasonal, recreational, or occasional use, creating high barriers of entry to the housing market for local renters.

This 2023-2031 Housing Element represents the City of Carmel-by-the-Sea’s intent to plan for the housing needs of the community while meeting the State's housing goals as set forth in Article 10.6 of the California Government Code (Section 65580-65589.11). The California State Legislature has identified the attainment of a decent home and a suitable living environment for every Californian as the State's major housing goal. The Carmel-by-the-Sea 6th Cycle Housing Element represents a sincere and creative effort to meet State housing mandates within the constraints of an established and nearly built-out community with limited land availability, coastal hazards, and extraordinarily high costs of land and housing.

Pursuant to state law, the Housing Element must be updated periodically according to statutory deadlines. This 6th Cycle Housing Element covers the planning period 2023 through 2031 and replaces the City's 5th Cycle Housing Element that covered the period 2015 through 2023.

Attachment 2
Chapter 1.0 – Introduction 1-2 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Per State Housing Element law, the document must be periodically updated to:
 Outline the community’s housing production objectives consistent with State and regional growth projections;
 Describe goals, policies and implementation strategies to achieve local housing objectives;  Examine the local need for housing with a focus on special needs populations;  Identify adequate sites for the production of housing serving various income levels;  Analyze potential constraints to new housing production;  Evaluate the Housing Element for consistency with other General Plan elements; and  Evaluate Affirmatively Furthering Fair Housing.

1.2 California’s Housing Crisis
The 6th Cycle Housing Element update comes at a critical time because California is experiencing a housing crisis, and as is the case for all jurisdictions in California, Carmel-by-the-Sea is committed to playing its part in meeting the growing demand for housing. In the period 2020 through 2045, the AMBAG region is projected to add 36,544 jobs,1 which represents a nine (9) percent increase. These changes will increase demand for housing across all income levels, and if the region can’t identify ways to significantly increase housing production, it risks worsening the burden for existing lowerincome households, many of whom do not have the luxury or skill set to move to a new job center but that are nonetheless faced with unsustainable increases in housing cost.

If the region becomes less competitive in attracting workers and increasingly unaffordable to lower-income workers and seniors, then social and economic segregation will worsen, only exacerbating historic patterns of housing discrimination, racial bias, and segregation. This potentiality has become so acute in recent years that the California Legislature addressed the issue with new legislation in 2018. Assembly Bill (AB) 686 requires all state and local agencies to explicitly address, combat, and relieve disparities resulting from past patterns of housing segregation to foster more inclusive communities.

This is commonly referred to as Affirmative Furthering Fair Housing, or AFFH (more on this below).
1 Source: AMBAG, November 18, 2022. “Final 2022 Regional Growth Forecast” “There's a movement in
California now called 'Yes, In
My Backyard,' and I'd love to
see us join that.”
May 24, 2023 Housing Ad Hoc
Committee Community Meeting
Attendee
Attachment 2
Chapter 1.0 – Introduction 1-3 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Carmel-by-the-Sea has had moderate success in meeting its housing needs. In the last Housing Element cycle (2015 to 2022 – 2023 pending2), for example, 18 housing units were constructed in the City, which represented 58 percent of its Regional Housing Needs Allocation (RHNA) of 31 new housing units. Of the units built, none were affordable to lower- and moderate-income households,3 and 100 percent were affordable to above moderate-income households.

1.3 Regional Housing Needs Allocation
For the eight-year time frame covered by this Housing Element Update (2023-2031), the Department of Housing and Community Development (HCD) has identified the region’s housing need as 33,274 units. The total number of housing units assigned by HCD is separated into four income categories that cover housing types for all income levels, from very low-income households to market rate housing.4 This calculation is based on population projections produced by the California Department of Finance as well as adjustments that incorporate the region’s existing housing need. Per Government Code Section 65583(a), the Housing Element must also provide quantification and analysis of projected housing needs for extremely low-income households. The number of units for the extremely low-income level is not assigned by HCD, but is left for quantification by the local jurisdiction. This calculation is based on the HCD approved methodology5, assuming that 50 percent of very low-income households qualify as extremely lowincome households.

Almost all jurisdictions in the Monterey Bay Area received a larger RHNA this cycle compared to the last cycle, primarily due to changes in state law that led to a considerably higher Regional Housing Needs Determination (RHND) compared to previous cycles.

On November 8, 2022, AMBAG’s adopted RHNA Methodology was approved by HCD. For Carmel-by-the-Sea, the RHNA to be planned for this cycle is 349 units, a substantial increase from the last cycle. Table 1-1 Regional Housing Needs Allocation shows the RHNA for Carmel-by-theSea for the period 2023 through 2031. 2 Source: November 8, 2022 HCD letter to AMBAG. Local governments may credit new units approved, permitted, and/or built beginning from the start date of the RHNA projection period, June 30, 2023, towards their RHNA 3 Source: City of Carmel-by-the-Sea HCD Annual Reports and City staff. 4 HCD divides the RHND into the following four income categories:

Very Low income: 0-50% of Area Median Income
Low income: 50-80% of Area Median Income
Moderate income: 80-120% of Area Median Income
Above Moderate income: 120% or more of Area Median Income 5 https://www.hcd.ca.gov/planning-and-community-development/housing-elements/building-blocks/extremely-lowincome-housing-needs Attachment 2
Chapter 1.0 – Introduction 1-4 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table 1-1 Regional Housing Needs Allocation
Income Group Percentage of Area Median Income (AMI) Share Extremely Low Income6 <30 57
Very Low Income <50 56
Low Income 51-80 74
Moderate Income 81-120 44
Above Moderate Income 121 + 118
Total 349
SOURCE: AMBAG

1.4 Affirmatively Furthering Fair Housing
In 2018, Assembly Bill (AB) 686, established an independent state mandate to affirmatively further fair housing (AFFH). Assembly Bill (AB) 686 extends requirements for federal grantees and contractors to “affirmatively further fair housing,” including requirements in the Federal Fair Housing Act, to public agencies in California. Affirmatively furthering fair housing is defined specifically as taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity by 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.

Assembly Bill (AB) 686 requires public agencies to:
 Administer their programs and activities relating to housing and community development in a manner to affirmatively further fair housing;
 Not take any action that is materially inconsistent with the obligation to affirmatively further fair housing;
 Ensure that the program and actions to achieve the goals and objectives of the Housing Element affirmatively further fair housing; and
 Include an assessment of fair housing in the Housing Element.

The requirement to Affirmatively Further Fair Housing (AFFH) is derived from The Fair Housing Act of 1968, which prohibited discrimination concerning the sale, rental, and financing of housing based on race, color, religion, national origin, or sex—and was later amended to include familial status and disability. The 2015 U.S. Department of Housing and Urban Development (HUD) Rule 6 Extremely low-income RHNA is found as a subset within the very low-income category for all other tables in this document
Attachment 2
Chapter 1.0 – Introduction 1-5 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 to Affirmatively Further Fair Housing and California Assembly Bill (AB)686 (2018) mandate that each jurisdiction takes meaningful action to address significant disparities in housing needs and access to opportunity. AB 686 requires that jurisdictions incorporate AFFH into their Housing Elements, which includes inclusive community participation, an assessment of fair housing, a site inventory reflective of AFFH, and the development of goals, policies, and programs to meaningfully address local fair housing issues.

An AFFH analysis was prepared and is included as an Appendix to this Housing Element (see Appendix A).

Defining Segregation
Segregation is the separation of different demographic groups into different geographic locations or communities, meaning that groups are unevenly distributed across geographic space. This report examines two spatial forms of segregation: neighborhood-level segregation within a local jurisdiction and city-level segregation between jurisdictions in the Monterey Bay Area.

Neighborhood-level segregation (within a jurisdiction, or intra-city): Segregation of race and income groups can occur from neighborhood to neighborhood within a city. For example, if a local jurisdiction has a population that is 20 percent Latinx, but some neighborhoods are 80 percent Latinx while others have nearly no Latinx residents, that jurisdiction would have segregated neighborhoods.

City-level segregation (between jurisdictions in a region, or inter-city): Race and income divides also occur between jurisdictions in a region. A region could be very diverse with equal numbers of White, Asian, Black, and Latinx residents, but the region could also be highly segregated with each city comprised solely of one racial group.

There are many factors that have contributed to the generation and maintenance of segregation.

Historically, racial segregation stemmed from explicit discrimination against people of color, such as restrictive covenants, redlining, and discrimination in mortgage lending. This history includes many overtly discriminatory policies made by federal, state, and local governments (Rothstein 2017).

Segregation patterns are also affected by policies that appear race-neutral, such as land use decisions and the regulation of housing development.

Segregation has resulted in vastly unequal access to public goods such as quality schools, neighborhood services and amenities, parks and playgrounds, clean air and water, and public safety (Trounstine 2015). This generational lack of access for many communities, particularly people of color and lower income residents, has often resulted in poor life outcomes, including lower educational attainment, higher morbidity rates, and higher mortality rates (Chetty and Hendren 2018, Ananat 2011, Burch 2014, Cutler and Glaeser 1997, Sampson 2012, Sharkey 2013).

Attachment 2
Chapter 1.0 – Introduction 1-6 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Segregation Patterns in the Monterey Bay Area
Across the Monterey Bay Area, Hispanic and Black residents are significantly more segregated from other racial and income groups. The highest levels of racial segregation occur between the Hispanic and Black populations. The analysis completed for this report indicates that the amount of racial segregation both within Monterey Bay Area cities and across jurisdictions in the region has slightly increased since the year 2010.

Segregation and Land Use
It is difficult to address segregation patterns without an analysis of both historical and existing land use policies that impact segregation patterns. Land use regulations influence what kind of housing is built in a city or neighborhood (Lens and Monkkonen 2016, Pendall 2000). These land use regulations in turn impact demographics: they can be used to affect the number of houses in a community, the number of people who live in the community, the wealth of the people who live in the community, and where within the community they reside (Trounstine 2018). Given disparities in wealth by race and ethnicity, the ability to afford housing in different neighborhoods, as influenced by land use regulations, is highly differentiated across racial and ethnic groups (Bayer, McMillan, and Reuben 2004).7
Segregation in the Carmel-by-the-Sea
The following are highlights of demographics as they apply to Carmel-by-the-Sea. For further information regarding the history of racial segregation, please refer to Appendix A.  As of 2019, White residents are the most segregated compared to other racial groups as measured by the isolation index. White residents live in neighborhoods where they are less likely to come into contact with other racial groups;
 As of 2019, Non-Hispanic White individuals comprise 87 percent of Carmel-by-the-Sea’s population followed by Hispanic or Latino (8 percent) and Asian populations (5 percent);  The City has no populations identifying as American Indian, Alaska Native, Native Hawaiian or Other Pacific Islander; and
 Black or African American non-Hispanic individuals represent less than 1 percent of the City’s population.
7For the source data, see U.S. Census Bureau, American Community Survey 5-Year Data (2015-2019), Table B19013B, Table B19013D, B19013H, and B19013I.

Attachment 2
Chapter 1.0 – Introduction 1-7 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Carmel-by-the-Sea’s General Plan and Municipal Code
historically emphasized single-family residential
development patterns and consequently, the City offers a limited variety of housing types with 87 percent single family detached units. Historically, this type of
development contributed to segregation patterns,
including in Carmel-by-the-Sea, due to, among other
factors, the higher purchase costs that accompany singlefamily homes. Financing for single-family properties favored educated higher income earners and as a result
purchasing property in the City remained out of reach for many lower income households and led to the
demographics seen in the City today. While Carmel-bythe-Sea’s population demographics are not as diverse as other jurisdictions within Monterey County and restrictive covenants were not enacted specifically in the City,
enacting policies and programs that promote AFFH and highlight the community’s assets could attract individuals to the area, encourage those that work in the City to live there as well, and assist lower-income households that are currently living in the community. Currently, 28 percent of households within Carmel-by-the-Sea are considered lower-income.

Regional Segregation
The following are highlights of regional segregation metrics as they apply to Carmel-by-the-Sea:
 The City has a higher share of White residents than other jurisdictions in the Monterey Bay Area as a whole, a lower share of Latinx residents, a lower share of Black residents, and a lower share of Asian/Pacific Islander residents; and
 Regarding income groups, the City has a lower share of very low-income residents than other jurisdictions in the Monterey Bay Area as a whole, a lower share of low-income residents, a lower share of moderate-income residents, and a higher share of above moderate-income residents.

1.5 Overview of Planning Efforts
This section provides an overview of planning and legislative efforts that provide the context for development of the 6th Cycle Housing Element.
"I urge you to enthusiastically
embrace this opportunity to
do exactly what you've come
up with because Carmel really
needs it, and it didn't happen
that Carmel turned out to be
a wealthy white exclusive
community by accident. It was
purposeful. “
May 24, 2023 Housing Ad Hoc
Committee Community
Meeting Attendee
Attachment 2
Chapter 1.0 – Introduction 1-8 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Effectiveness of Previous Housing Element
The 2015 Housing Element identified a Regional Housing Needs Allocation of 31 housing units in Carmel-by-the-Sea between 2015 and 2023. The RHNA was divided into the following income categories:
 7 units affordable to extremely low- and very low-income households;  5 units affordable to low-income households;
 6 units affordable to moderate-income households; and  13 units affordable to above moderate-income households.

During the 2015–2023 planning period, 18 new above moderate-income units were added to the City’s housing stock, and no units were added in the moderate, low or very low-income categories8 .

This indicates that residential growth for extremely and very low-income households was slower than anticipated, which may be in part due to a lack of water resources, the COVID pandemic, the cost of land and construction, and the overall lack of interest to develop affordable housing in the community. As a result, housing costs continued to increase substantially due to low supply, and affordability became more elusive.

The goals, objectives, policies, and actions in the 2015 Housing Element complied with State Housing Law and provided proper guidance for housing development in the City. In the 2023 Housing Element update, objectives for each of the goals will be modified as appropriate to more specifically respond to the housing environment in Carmel-by-the-Sea from 2023-2031. Policies will also be modified as needed to respond to current Housing Element Law and existing and anticipated residential development conditions. See Appendix E for a complete review and analysis of Carmelby-the-Sea’s 5th Cycle Housing Element (2015-2023).

New State Laws Affecting Housing
While the City has taken steps throughout the 5th Cycle to increase housing production locally, the State passed numerous laws to address California’s housing crisis during the same period. As the State passes new legislation in the remainder of the 5th Cycle and during the 6th Cycle, the City will continue to amend the Municipal Code; to monitor and evaluate policies and programs designed to meet State requirements; and to proactively implement new policies and programs to help increase housing production citywide.

In 2019, several bills were signed into law that include requirements for local density bonus programs, the Housing Element, surplus lands, accessory dwelling unit (ADU) streamlining, and removing local barriers to housing production. The City implemented changes required by state law, through amendments to the Municipal Code. The following is a summary of recent legislation and 8 RHNA Progress Report - 5th Cycle RHNA Progress Report - California Open Data Attachment 2
Chapter 1.0 – Introduction 1-9 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 proposed City activities that will further the City’s efforts to increase housing production during the 6th Cycle. Please see the section above for a discussion of Assembly Bill (AB) 686 (Affirmatively Furthering Fair Housing).

Climate Change and RHNA Methodology
Per statute, Assembly Bill (AB) 1445 (2023) amends California Government Code Section 65584.04 and would require Councils of Governments to consider including the impacts of climate change as a factor when developing the methodology for allocating regional housing need. Regions would specifically need to consider emergency evacuation route capacity, wildfire risk, and sea level rise, but could also consider any other climate change-related factor. Although this does not apply to the current RHNA, it could affect the 7th Cycle allocation.

Incentives for Accessory Dwelling Units
In 2020, AB 686, AB 587, AB 671, AB 881, and SB 13
further incentivize the development of accessory dwelling units (ADUs) through streamlined permits, reduced
setback requirements, increased allowable square footage, reduced parking requirements, and reduced fees. The City last amended the Municipal Code in 2017 to address ADUs and is currently following state law while preparing
additional amendments to the Municipal Code.

In 2023, the City intends to further amend the standards for ADUs and JADUs, consistent with state Law, to encourage conversion of guest houses to ADUs and promote construction of new units. Further the City will develop pre-approved, standardized ADU plans to make construction more affordable and will continue to include the HD ADU handbook on the City’s website.

Low-Barrier Navigation Centers
AB 101 (2019) requires jurisdictions to allow “low-barrier navigation centers” ByRight in areas zoned for mixed uses and in nonresidential zones permitting multifamily uses, if the center meets specified requirements. A low-barrier navigation center is a service-enriched shelter focused on moving unhoused people into permanent housing. The center provides temporary living facilities while case-managers connect individuals to public benefits, health services, and housing. The City’s Municipal Code will be amended to comply with state law.

Surplus Public Land
AB 1255 and AB 1486 (2020) seek to identify and prioritize state and local surplus lands available for housing development affordable to lower-income households. City-owned land was considered through preparation of the adequate sites inventory of the 6th Cycle Housing Element. These sites may be developed over time or possibly leased for development.

ADUs and JADUs make
economic sense for many of us
and could account for scores of
new units in the next 8 years.

November 17, 2022 Housing Ad Hoc
Committee Community Meeting
Attendee
Attachment 2
Chapter 1.0 – Introduction 1-10 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 In 2019, Governor Gavin Newsom signed an executive order to identify State owned sites to help address the California housing crisis.

Accelerated Housing Production
Assembly Bill (AB) 2162 (2018) and Senate Bill (SB) 2 (2019) address various methods and funding sources that jurisdictions may use to accelerate housing production.

Priority Processing
SB 330 (2019) enacts changes to local development policies, permitting, and processes that will be in effect through January 1, 2025. SB 330 places new criteria on the application requirements and processing times for housing developments; prevents localities from decreasing the housing capacity of any site, such as through downzoning or increasing open space requirements, if such a decrease would preclude the jurisdiction from meeting its RHNA housing targets; prevents localities from establishing non-objective standards; and requires that any proposed demolition of housing units be accompanied by a project that would replace or exceed the total number of units demolished.

Additionally, any demolished units that were occupied by lower-income households must be replaced with new units affordable to households with those same income levels.

Housing and Public Safety
In response to SB 379 (2015) and other recent state legislation, local jurisdictions must update their safety element to comprehensively address climate adaptation and resilience (SB 379 and SB 1035, 2018) and identify evacuation routes (SB 99 and AB 747, both 2019). These updates are triggered by the 6th Cycle Housing Element update. This Housing Element will contain an evaluation of the existing safety element and programming actions to update the safety element to satisfy the new state requirements. Also, as sites are identified and analyzed for inclusion in the City’s housing site inventory, special attention will be paid to the risk of wildfire and the need for evacuation routes. In this way, the City will coordinate updates between the elements, so that future development is directed into areas that avoid or reduce unreasonable risks while also providing needed housing and maintaining other community planning goals.

Disadvantaged Communities
In 2011, the Governor signed SB 244 which requires local governments to make determinations regarding “disadvantaged unincorporated communities,” defined as a community with an annual median income that is less than 80 percent of the statewide annual median household income. The City has determined that there are no unincorporated islands or fringe or legacy communities that qualify as disadvantaged communities inside or near its boundaries.

Consistency with General Plan
The City of Carmel-by-the-Sea adopted a comprehensive update to its General Plan in 2003 in conjunction with the adoption of their Local Coastal Plan. Additional, element-specific, updates Attachment 2
Chapter 1.0 – Introduction 1-11 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 were completed in 2009 and 2015. The General Plan is a long-range planning document that serves as the “blueprint” for development for local jurisdictions in California. All development-related decisions in the City must be consistent with the General Plan, and if a development proposal is not consistent with the plan, then it must be revised or the plan itself must be amended.

State law requires a community’s General Plan to be internally consistent. This means that the Housing Element, although subject to special requirements and a different schedule of updates, must function as an integral part of the overall General Plan, with consistency between it and the other General Plan elements. From an overall standpoint, the development projected under this Housing Element is consistent with the other elements in the City’s current General Plan.

Many housing needs can only be addressed on a comprehensive basis in concert with other community concerns such as infill development or mixed-use incentives, for example, which must consider land use, traffic, parking, design, and other concerns as well.

The City’s Housing Element is being updated at this time in conformance with the 2023-2031 6th Cycle update for jurisdictions in the Association of Monterey Bay Area Governments (AMBAG) region. The Housing Element builds upon the other General Plan elements and contains policies to ensure that it is consistent with other elements of the General Plan. As portions of the General Plan are amended in the future, the plan (including the Housing Element) will be reviewed to ensure that internal consistency is maintained.

1.6 Public Participation
The primary purpose of this chapter is to describe the
effort made by the City of Carmel-by-the Sea to engage
all economic segments of the community (including
residents and/or their representatives) in the
development and update of the Housing Element. This
public participation effort also includes formal
consultation, pursuant to Government Code §65352.3,
with representatives from the Tribal Nations that are
present and active in Monterey County. It is also
responsive to AB 686 (2018, Affirmatively Furthering
Fair Housing), which requires local jurisdictions, as they update their Housing Elements, to conduct public
outreach to equitably include all stakeholders in the
Housing Element public participation program.

The mission of the Housing Ad Hoc
Committee is to provide guidance as
the City updates the Housing Element
of its General Plan. The Committee will
participate in public outreach and
education; consider opportunities and
incentives for the development of
affordable housing; and explore
creative, tailored solutions to meet
the City’s workforce and range of
other housing needs while preserving
the character of Carmel by-the-Sea.

Karen Ferlito and Bobby Richards,
Housing Ad Hoc Committee
Councilmembers
Attachment 2
Chapter 1.0 – Introduction 1-12 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 The 6th Cycle RHNA numbers are a monumental change for all California communities, and the success of the update process hinges in part on a community outreach and engagement program that was robust, inclusive, and meaningful. The City’s community engagement program has included an initial presentation to the City Council, a series of Housing Ad Hoc Committee community meetings, stakeholder outreach, direct contact with interested residents and property owners, and online/virtual participation. Key components of the interactive engagement plan include: Housing Element website, http://www.HOMECarmelbytheSea.com where all updates are provided as well as community engagement opportunities.

H.O.M.E. Carmel-by-the-Sea website
Housing Opportunities Made Easier (HOME) at HOMECarmel (homecarmelbythesea.com) is a dedicated website that provides a portal to all of the housing -element-related public engagement activities that are available to members of the public. This includes information on housing element basics, community ideas board, property owner interest forms, site surveys, site selection details, and materials from community workshops.
 Q&A. Received questions in a managed space that accommodated messages throughout the iterative brainstorming process.
 Ideas Board. Promoted brainstorming among community members to suggest creative ways to achieve our RHNA goals.
 Interactive Site Inventory Mapping. Allowed community members an opportunity to examine proposed housing sites and suggest alternative solutions via an interactive online mapping tool. The site inventory mapping tool was advertised on the H.O.M.E. Carmel-by-theSea website in addition to other City communication outlets and made available through engage.emcplanning.com/homecarmelpotentialsitesinventory.  Surveys. Encouraged community-members to voice their opinions in a convenient way that also helped City staff understand what areas of the City need more encouragement to participate.

Aggregate data also helped the City understand generally who is participating with the outreach tools. All surveys were advertised on the H.O.M.E. Carmel-by-the-Sea website in addition to other City communication outlets. City staff also walked the City and handed out flyers to hospitality workers in an effort to increase the demographics of community members taking the Stakeholder Survey. The Stakeholder Survey was available in both English and Spanish. • Stakeholder Survey. Released for public engagement on May 24, 2023 to solicit input from Carmel-by-the-Sea residents, property owners, business owners, employees, community activists, and visitors. The stakeholder survey closed July 6. The Housing Element will contain updated policies and programs as guided by the public’s perspective.

Attachment 2
Chapter 1.0 – Introduction 1-13 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024  Property Owner Interest Form. Released for public engagement on April 6, 2023 to develop a list of property owners interested in building an accessory dwelling unit (ADU) or junior accessory dwelling unit (JADU). A list of interested property owners will be added to Appendix C – Sites Inventory when the survey is closed July 6.

Community Meetings
The City hosted a series of community meetings to inform and educate the public on the 2023-2031 6th Cycle Housing Element Update planning process and collect community feedback. These meetings are ongoing and continue to guide the policies and programs to ensure Carmel-by-theSea’s character and values are upheld.  November 17, 2022 Housing Ad Hoc Committee
Community Meeting. Hosted to introduce the 2023-2031
6th Cycle Housing Element Update to community residents.  February 7, 2023 City Council Meeting. Presentation on preliminary housing feasibility report and Housing Element update status.
 February 28, 2023 Housing Ad Hoc Committee
Community Meeting. Hosted to discuss development
constraints and potential incentives.
 April 6, 2023 Housing Ad Hoc Committee Community
Meeting. Hosted to discuss current 5th Cycle Housing
Element policies and programs, HOMECarmel unveiling
and walk through, and introduction to AFFH.
 May 24, 2023 Housing Ad Hoc Committee Community
Meeting. Hosted to discuss housing needs, fair housing, sites inventory, and policies and programs to address the needs.
 June 15, 2023 Joint City Council/Planning Commission/Housing Ad Hoc Community Meeting. Hosted to discuss the Public Draft Housing Element, the 30-day Public Comment Period, and next steps in the planning process.
 July 11, 2023 City Council Meeting. Update on the Housing Element Public Review Draft and discuss revision to the document after the 30-day comment period and review the City’s response to public comments on the Public Draft.
 August 1, 2023 City Council Meeting. Update on the Housing Element planning process and review of full Initial Draft Housing Element prior to submittal to HCD for 90-day review.

If you rewind the clock 30
years, we did have 4,000 or
more full-time residents in
this town so it’s not like that’s
impossible. But the world is
different now, the number of
cars has increased, etc., so
there will be interesting
balances and challenges as we
add people to our community,
which is going to be a great
thing.

November 17, 2022
Housing Ad Hoc Committee
Community Meeting
Attendee
Attachment 2
Chapter 1.0 – Introduction 1-14 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024  November 13, 2023 Housing Ad Hoc Community Meeting. Hosted to review the comment letter from HCD.
 January 9, 2023 City Council Meeting. Update on revisions to the Housing Element in response to the comment letter from HCD, and next steps in the certification process.

Public Participation to Affirmatively Furthering Fair Housing The Carmel-by-the-Sea public participation program was also responsive to AFFH, which requires local jurisdictions to conduct public outreach to equitably include all stakeholders in the Housing Element public participation program (see the discussion above for more complete information on AFFH).

The organizations listed in Appendix E were contacted initially with an invitation to further connect.

There were more opportunities for deeper connection with some of the Community Based Organizations (CBOs) included with the list.

The City emphasized the power of public participation during the public draft 30-day review period.

Community members were informed that their comments would be included in the public record that will be read by decision-makers and reviewed by HCD, with transparent obligation to be responsive to comments as part of the preliminary draft submittal to HCD.

Tribal Consultation
This public participation effort also includes formal consultation, pursuant to Government Code §65352.3, with representatives from the Esselen Nation that is present and active in Monterey County. Consultation is in process.

Public Review of Draft and Final Housing Element
Public Comment Review Period
As required by HCD, the Draft Housing Element was available for 30-days of public review from June 5, 2023 to July 6, 2023. The Draft Housing Element was posted on the City of Carmel website and the dedicated Housing Element website (homecarmelbythesea.com) and a number of public comments were received. Additionally, a joint City Council and Planning Commission Committee meeting was held on June 15, 2023 where verbal public comments were accepted on the Draft Housing Element.

Public comments received during the 30-day public review period can be found in the Public Comment Report, along with responses. The HCD Initial Draft has been updated as needed to reflect the comments received by the public.

Stakeholder Survey
The City of Carmel published a Stakeholder Survey to gather input from community members. The goal of the survey was to inform the City of Carmel-by-the-Sea what housing needs exist and to Attachment 2
Chapter 1.0 – Introduction 1-15 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 solicit community members input on how to achieve the RHNA. The survey was made available in English and Spanish and was posted on the dedicated Housing Element website (homecarmelbythesea.com). The Stakeholder survey was available from May 24, 2023 to July 6, 2023. 156 responses were received in English and 1 response was received in Spanish. See Appendix H for an in-depth discussion of the Stakeholder Survey results.

Overall, survey respondents indicated a need for more diverse housing types within the City (apartments, condominiums, ADUs and senior housing). Survey respondents encourage the use of second story buildings for housing within the Commercial District, especially for affordable units, and indicate a need for expanded City services to distribute information about affordable units.

When asked if property owners would consider adding an ADU to their property, many responded that lots are too small, however, a number of property owners did indicate interest if the permitting was streamlined, fees were lowered, or financial assistance was provided.

Attachment 2
Chapter 1.0 – Introduction 1-16 EMC Planning Group
Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 This side intentionally left blank.

Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-1 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024

2.0 Goals, Policies, and Programs

2.1 Introduction
The City is responsible for enabling the production of housing by reducing regulatory barriers, providing incentives, and supporting programs that create or preserve housing, especially for vulnerable populations. To enable the construction of quality housing, the City has identified the following goals:

Goal HE-1 Facilitate Housing Construction
Goal HE-2 Protect Affordable Housing and Improve the Housing Stock Goal HE-3 Provide Opportunities for New Affordable and Other Special Needs Housing Goal HE-4 Exemplify Sustainable Development and Energy Conservation Goal HE-5 Publicize Housing Needs and Resources
The City’s demographic and housing needs assessment, including contributing factors to housing disparities, formed an integral part of program development. Highlights include: the predominant age group in 2019 was between 65 to 74 years of age; the population was comprised of over 85% White individuals; the unemployment rate was 0.1 percent; above-moderate households made up the majority of households at 62 percent; and 57 percent of total households were owner occupied and 43 percent renter occupied. Of note, 23 percent of household are cost burdened and 23 percent are severely cost burdened. Detailed information is provided in Appendix A.

Additionally, the majority of the sites identified in the Site Inventory were not identified in the 5th Cycle Housing Element. The Policies and Programs below are intended to reduce the regulatory barriers to redevelop of these sites and to demonstrate the City is taking measures to ensure construction of more units, in the 6th cycle.

2.2 What’s New
This section provides an overview of significant new policy and program directions being taken by the City of Carmel-by-the-Sea to address housing issues in the community and the larger Monterey Bay Area.

Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-2 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Affirmatively Furthering Fair Housing
The new policy direction that the City will undergo during the 6th Cycle Housing Element Update involves addressing historic economic and racial segregation patterns. In 2018, the California Legislature established an independent state mandate to affirmatively further fair housing (AFFH).

Affirmatively furthering fair housing is defined specifically as taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity by 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.

Contributing Factors
The following contributing factors that impact fair housing and affirmatively furthering fair housing (AFFH) within the City were identified and prioritized as follows:

High Priority
 Lack of affordable housing;
 Lack of adequate housing stock that meets the needs of residents;  Jobs-worker imbalance;
 Lack of accessible units for individuals with disabilities;  Lack of Transitional and Supportive Housing/Emergency Shelters;  There is a lack of developable land, and the City is subject to additional coastal zone regulations;  Lack of racial and ethnic diversity within the City; and  Cost of land, materials, and labor which limit profitability of affordable housing.

Medium Priority
 Lack of access to information about fair housing rights; and  Limited knowledge of fair housing by residents.

More detailed AFFH information is located in Appendix A. The City of Carmel-by-the-Sea is adopting new policies and programs through the update of this 6th Cycle Housing Element, to align with the state’s new AFFH mandate. Policies and programs that support this alignment are identified with the letters “AFFH.”

2.3 Program Overview and Quantified Objectives
Quantified Objectives estimate the number of units likely to be constructed, rehabilitated, or conserved/preserved by income level during the planning period. The Quantified Objectives do not represent a ceiling on development, but rather set a target goal for the jurisdiction to achieve, based Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-3 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 on needs, resources, and constraints. These objectives will focus communication between the City and HCD with future Annual Progress Reports (APRs). HCD does not require that all objectives must be met, rather, it is a goal that enables objective assessments about program effectiveness so the City can make informed determinations to continue, modify, or delete programs with the next Housing Element update Cycle. Table 2-1, Quantified Objectives, provides an estimate of the number of units likely to be constructed, rehabilitated or conserved/preserved in Carmel-by-the-Sea in the 6th Cycle.

Table 2-1 Quantified Objectives Summary
Income Category New Construction Rehabilitation* Conservation/ Preservation**
Extremely Low 61 - -
Very Low 60 5 -
Low 93 5 50
Moderate 61 6 -
Above Moderate 135 400 -
Total 410 416 50
SOURCE: City of Carmel-by-the-Sea 2023
NOTES: *The City has approximately 3,800 residential units, 60 (or about one percent) of which are affordable units. Each year the City processes approximately 100 building permits for remodels, additions, and other construction, which rehabilitates the existing housing stock. For the lower-income categories rehabilitation goals, the City assumes that one percent of the total permits processed will be for affordable units. Under these assumptions, the City would rehabilitate two units of affordable housing a year or approximately 16 units throughout the 2023-2031 planning cycle. This represents approximately 30 percent of the City’s existing affordable housing inventory. **The City has no units at risk of converting to market rate during this planning cycle.

2.4 Goals, Policies and Programs
Community input has been and continues
to be an integral part of the development of
policies and programs for the 6th Cycle
Housing Element. The purpose of this
section is to set forth goals, policies, and
programs to further the development of
housing for all income levels in the
community. The Implementation Programs
listed below provide a workplan for
programs to ensure timely implementation
and tracking. The following programs are
will be implemented city-wide, unless
otherwise specified below.
"... The land as it exists now, the way
it's zoned, could support the 349 units,
plus the buffer. So, the question then is
how do we get people excited about
developing some of those units?
That's where these programs and
processes come into play and that's
why we need to amend the Municipal
Code, to codify those things..."
May 24, 2023 Housing Ad Hoc Committee
Community Meeting Attendee
Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-4 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 GOAL H1 FACILITATE HOUSING CONSTRUCTION
Policy 1.1: Ensure adequate sites are available to meet the City’s projected housing growth needs.

Program 1.1.A: Adequate Sites
The City has a RHNA or growth need of 113 units affordable to Extremely Low- and Very LowIncome households. The City’s General Plan and Municipal Code provide for housing types at appropriate densities to accommodate the RHNA. The City will encourage and facilitate the development of new units consistent with the RHNA by continuing to work with housing providers such as the Carmel Foundation and will actively find new organizations to partner with. The City also offers incentives and concessions outlined in Programs listed below.

The Planning Division shall annually evaluate and report to the City Council on the City’s progress in meeting its Housing Element objectives, as well as remain in compliance with the no-net loss requirements of Government Code Section 65863.

Quantified Objective: 61 Extremely Low, 60 Very Low, 93 Low, 61 Moderate and 135 Above Moderate-Income housing units
Timeframe: Maintain adequate sites to meet RHNA through June 2031 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-3.1.a: Adequate Sites)

Program 1.1.B: City-Owned Sites - AFFH
The City will maintain compliance with the Surplus Land Act throughout the 2023-2031 Housing Element period. The City will assess the appropriateness of and consider implementing the following: outreach opportunities with housing developers, requests for proposals, development incentives, fee waivers, priority process, and financial assistance (when available) to facilitate and incentivize developers to develop housing units on City-owned sites.

The City plans to make three (3) sites (#1, #2, and #3 in the Sites Inventory) available through the Surplus Land Act process over the next five years for the potential development of 122 units (105 affordable to lower-income households and 17 for moderate-income households). These sites are planned to remain in City ownership and are anticipated to be made available for development through long-term leases. These sites will be made available for affordable housing consistent with the requirements of the Surplus Land Act. Please note there are no State-owned or Federally-owned sites within Carmel-by-the-Sea.

The City has an existing long-term lease with the Carmel Foundation, which manages 50 affordable apartment units for seniors (55+). The lease has benefitted the community, and the City would like Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-5 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 to expand the number of affordable housing in the City through the use of the three identified sites.

Specific planned actions by the City include the establishment of development standards (for the Sunset Center sites, specifically), development of a project description, publication of an RFP within six months, selection of a development partner, two years to enter into an Exclusive Negotiation Agreement, two years for land use entitlements and development agreements, 6-12 months for building permit issuance, and 2-3 years for construction. Council approval is required for each step in this process.

Specific actions the City is committed to:
 Maintain compliance with the Surplus Land Act throughout the 2023-2031 Housing Element period;
 Establish and implement development standards for Sunset Center (Sites #1 and #2);  Make properties available through the Surplus Land Act process;  Develop project description and establish an RFP process and solicit developers by Fall 2024;  Target Exclusive Negotiating Agreement by Fall 2025; and  Target land use entitlements issuance by Winter 2026.

Quantified Objective: 39 Extremely Low, 39 Very Low, 46 Low, 25 Moderate Income units Timeframe: Complete investigations and potential partnerships by December 2026
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly 3-3.1.b: Surplus Sites)
Program 1.1.C: Development on Small Sites
Small sites can be difficult to develop particularly when development standards don’t adequately take into account small lot dimensions. The City will continue to offer incentives and concessions that facilitate development on small sites in the commercial and multi-family districts, including density bonuses that allow for development up to 88 du/ac. Presently, Carmel Municipal Code Section

17.14.060 (Central Commercial (CC) District Regulations Applicable) waives off-street parking entirely for apartments in the CC district. In the Service Commercial (SC) District, the required parking for an affordable housing unit is ½ space per unit and for senior housing it is ⅓ space per unit. Senior housing also has a guest parking requirement of 1 space per 4 housing units. The City will further evaluate the residential parking requirements in the Service Commercial (SC) and Residential & Limited Commercial (RC) zoning districts to help facilitate market rate housing.

Alternative parking programs such as bike and/or car share, or free or discounted bus passes, will be evaluated to offset reduced parking.

Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-6 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Quantified Objective: 35 Very Low-Income units with reduced parking Timeframe: Complete evaluations by December 2024
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly 3-3.1.c: Development on Small Sites)

Program 1.1.D: Allow Religious Institution Affiliated Housing Development In 2020, the California legislature passed Assembly Bill (AB) 1851 and AB 2244 in 2022, which encourage the use of religious facility sites (including parking lots) for housing developments and prohibit jurisdictions from requiring replacement parking when used for qualified development.

State law defines “religious institution affiliated housing” as housing that is on religious institution property and is eligible for a State density bonus, meaning it has elements of affordability. Consistent with AB 1851 and AB 2244, the City will amend the Zoning Ordinance to allow religious institutionaffiliated housing development projects by-right as an accessory use to a permitted religious institution use, allow these uses at densities up to 33 units per acre, and update the parking requirements consistent with State law. The City commits to modifying standards and make making other modifications as needed to achieve the maximum allowed densities.

Quantified Objective: 1 Extremely Low, 1 Very Low, 1 Low, 3 Moderate, and 3 Above Moderate Income units
Timeframe: Amend the Zoning Ordinance by December 2026.

Responsible Party: Community Planning & Building Department Funding Funding Source: General Fund
(NEW)
Policy 1.2: Continue to monitor and work cooperatively with regional agencies to augment infrastructure in a manner that provides adequate capacity for existing and new housing needs while preserving and improving the unique visual character of the City.

Program 1.2.A: Water Distribution Prioritization for Affordable Housing – AFFH Perhaps the greatest constraint to housing production in Carmel-by-the-Sea is the lack of water. The City’s Regional Housing Needs Allocation (RHNA) of 349 units for the 2023-2031 planning period is estimated to require approximately 40 acre feet of water.

Potable water is a fundamental infrastructure need for housing and is a limited resource in Carmelby-the-Sea. Water is regulated by the State Water Resources Control Board (SWRCB) and the Monterey Peninsula Water Management District (MPWMD). Few developed sites have available water credits sufficient to accommodate construction of additional residential units, and the City’s own water allocation is quite limited. Further, due to the current State imposed cease-and-desist order in Carmel, California American Water (Cal-Am) is not permitted to set new water meters at this time. In an effort to address water constraints, the City will:

Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-7 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024  Support efforts by the MPWMD to expand the water supply with new water sources that will support affordable housing development (December 2027).  Work cooperatively with MPWMD to implement water conservation methods through the building permit process (e.g., low-flow fixtures, instant hot water heaters, cisterns/rain gardens) to augment water for new development projects. The City has received many building permit applications for remodels and refurbishments of older homes, which would result in water conservation implementation, and is supportive of new water supplies. The City and MPWMD will measure the amount of water conserved on an annual and ongoing basis.  Work cooperatively with MPWMD to establish a procedure to prioritize water allocation for housing developments that include affordable units for lower-income households (December 2026).
 From its own modest water allocation of approximately 1.6 acre-feet, the City will grant water allocation priority to those projects that assist the City in meeting its share of the regional housing need for lower- and moderate-income households. A City policy to clearly reflect water allocation priority and incentives for Extremely Low, Very Low, Low and Moderate-Income households will be adopted (December 2026).

Quantified Objective: Prioritize 193 affordable units for water Timeframe: Adopt policy by June 2025
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-3.2: Address Infrastructure Constraints) Program 1.2.B: Address Infrastructure Constraints
Ensuring the City’s infrastructure is modernized and can accommodate future growth is a critical charge of local governments. Much of the City’s infrastructure is nearing the end of its lifecycle and crafting Capital Improvement Programs that effectively manage infrastructure is imperative.

Additionally, the City experienced significant power outages during the 2022-2023 winter season that negatively impacted the City at large. The City’s Public Works Department continues to improve City infrastructure including road maintenance and storm drains, through the City’s 5-Year Capital Improvement Plan process. The City will continue to work cooperatively with outside agencies, including the Pacific Gas and Electric Company (PG&E), the Carmel Area Wastewater District (CAWD), and California American Water (Cal-AM), to continue to maintain and upgrade the City’s infrastructure.

The City of Carmel proposes the following actions and timeline to address infrastructure constraints during the 6th Cycle:
 The City of Carmel will collaborate with and support the undergrounding of electrical wires by PG&E in an effort to provide consistent power. The City is working with PG&E to develop an Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-8 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 undergrounding plan estimated to be complete within 10-15 years for a small portion of the City, with the remainder of the City’s electrical wires anticipated to be undergrounded in the next 20- 30 years.
• Quantified Objective: Underground a small portion of the electrical wires by December 2034, and work with PG&E to underground the remainder over the next 20-30 years.
 The City will implement drainage and street improvements, including ADA ramps and sidewalk slope improvements through the Capital Improvement Process. • Quantified Objective: The City will invest $2.065 million in drainage improvements and $6.7 million in street improvements by December 2026.

Timeframe: City’s 5-Year Capital Improvement Process through June 2031 Responsible Party: Public Works Department
Funding Source: General Fund
(Formerly Program 3-3.2: Address Infrastructure Constraints) Policy 1.3: Reduce or eliminate governmental constraints on the provision of affordable housing. Direct public funding resources to the conservation of existing housing units in neighborhoods where continued residential use is appropriate.

Program 1.3.A: Condominium Conversions - AFFH
The City will continue to implement the condominium conversion ordinance, which restricts the conversion of apartments to condominiums to preserve the lower-cost rental housing options (i.e., apartments) within the City. Apartments cannot be converted to condominiums unless a new apartment is being created to offset the conversion.

Quantified Objective: Preserve rental units
Timeframe: Continued ordinance implementation through June 2031 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.3.a: Condominium Conversions)
Program 1.3.B: Overnight Visitor Accommodation (Conversion) Development Transfer Rights - AFFH
Pursuant to Coastal Zone requirements, the City has recognized existing overnight visitor accommodations (hotels/motels, inns, bed and breakfasts and other various lodging options) as an important coastal visitor asset and economic base in the community. There are a number of older, overnight visitor accommodations in the R-1, CC, RC, and SC zoning districts, including some that are non-conforming. Appendix C provides a list of existing eligible overnight visitor accommodation Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-9 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 locations. Property owners of these establishments are encouraged to consider rehabilitating these sites as multi-family rental residences. These properties are distributed throughout the City and this policy would diversify the housing stock through more cost-effective means of rehabilitating and refurbishing existing buildings.

The City will incentivize both the transfer of development rights of overnight visitor accommodations to other sites within commercial zoning districts and conversion of existing overnight visitor accommodation properties to multi-family residences that include 15 percent lower-income units. The same number of overnight visitor accommodation rooms to serve coastal visitor access in the City will be retained while increasing the affordable multi-family housing rental stock.

If at mid-cycle, the incentive program has not received interest, the City will consider alternative incentives and meet with property owners to discern a path toward maximizing use of the property to enable affordable housing.

Quantified Objective: 33 units converted from overnight visitor accommodation rooms to housing units
Timeframe: Program reviewed by June 2027
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-4.1.b Conversion of R-1 Motels)
Program 1.3.C: Accessory Dwelling Units - AFFH
The City’s Accessory Dwelling Units (ADUs) and Junior ADUs (JADUs) ordinance is currently being updated to reflect state law. The City’s ADU ordinance was last updated in 2017 (Ord. 2017- 10 § 1 (Exh. A), 2017). Carmel-by-the-Sea is currently following the requirements of State law in the review and approval of ADUs and JADUs. The City is in the process of updating its ADU Ordinance to incorporate state laws that have expanded since 2017, and to clarify the ADU permitting process for property owners.

The City recognizes that ADUs provide affordable housing options for family members, seniors, students, in-home health care providers, and other small household types. ADUs can also be useful to generate additional rental income for the homeowner, making homeownership more financially feasible. It’s also important to note that 80 percent of Carmel-by-the-Sea’s vacant units are for seasonal, recreational, or occasional (second home) use. ADU and JADU development on properties used for occasional use adds to the permanent rental housing stock and provides on-site oversight for second home properties. The City includes the Housing and Community Development Department ADU Handbook on the Planning Department website to offer technical assistance to interested property owners.

Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-10 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Pre-approved, standardized plans can eliminate the costs of designing a custom ADU, and assures property owners the unit type and size is already approved by the City. Pre-approved plans can also make construction more affordable if the designs are using materials that are easily sourced and standard sized.

To further promote ADU development the City will implement to the following:
 The City is on track to adopt an updated ADU Ordinance by the end of 2024. The City will also amend the Municipal Code to reflect current State ADU law in a timely manner as new relevant state laws are adopted during the planning cycle.

Timeframe: Ordinance adopted by December 2024
 Develop pre-approved, standardized ADU plans available on the City’s website to further incentive the construction of ADUs.

Quantified Objective: 5 Extremely Low, 5 Very Low, 10 Low, 10 Moderate, and 4 Above Moderate-Income units
Timeframe: December 2026
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.3.c: Subordinate Units)
Program 1.3.D – Overnight Visitor Accommodation - Employee Housing Program The City has a number of overnight visitor accommodation (motels, hotels, inns) properties that would greatly benefit from incorporating affordable on-site employee housing. Appendix C provides a list of existing overnight visitor accommodation locations. These units would alleviate the current lack of housing that many hospitality employees that work in Carmel face. As an incentive to the owners/operators of motels, hotels, and inns to provide on-site affordable employee housing, the City will offer an additional overnight accommodation room for each onsite housing unit created.

This incentive will serve to increase affordable rental housing, offset the loss of revenues for the business owners, and maintain visitor-serving coastal access. The City will amend the Municipal Code as follows:
 Allow at least one on-site affordable employee housing unit in conjunction with one new overnight visitor accommodation room.

The City will conduct outreach with overnight visitor accommodation property owners to better discern the viability of the incentive program by December 2024.

If at mid-cycle, the program does not receive interest, the City will require upon receiving building permits, that a single on-site affordable employee housing unit be developed in conjunction with one new overnight visitor accommodation room.

Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-11 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Quantified Objective: 4 Extremely Low, 4 Very Low, 12 Low, 11 Moderate-Income employee housing units by December 2031
Timeframe: Amend Municipal Code by December 2026 and re-evaluate program by December 2028
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.3.c: Subordinate Units)
Program 1.3.E: Amend the A-2 Zoning District - AFFH
The Community and Cultural Center Zoning District, A-2, allows senior housing (55+) as a permitted use in addition to uses that provide cultural and community activities associated with the arts, education and recreation; however, development standards are not specified for the A-2 district and design review is required. The lack of development and design standards adds uncertainty and can significantly lengthen the development process. Amending the A-2 zoning district with clear setbacks, height, and objective design standards will add clarity and remove a development constraint. The City will amend the Municipal Code to include clear development and design standards for the A-2 zoning district to encourage affordable senior housing.

Quantified Objective: 25 Extremely Low, 25 Very Low, 35 Low, and 8 Moderate-Income units
Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(NEW)
Program 1.3.F: Employee Housing – Farmworker Housing – AFFH In compliance with State requirements and the Employee Housing Act, the City of Carmel-by-theSea will amend the Municipal Code to include a definition for employee housing that permits employee housing for six or fewer employees to be treated as a single- family structure and permitted in the same manner as other dwellings within the R-1 zoning district.

Although the City does not have agricultural uses, and therefore, no housing designated specifically for farmworkers —the City supports the County of Monterey’s efforts to educate the public on resources that are available for agricultural workers. The City has identified the following resources that are available throughout the region for agricultural employees:
 Spanish Farmworkers Resource Line – provides information on a variety of issues such as legal help and medication services, stress, resources for farmworkers with disabilities, etc.  The Center for Community Advocacy – an organization whose mission is to support and build leadership within the community and in particular for farmworkers and their families. The Center has worked side by side with farmworkers to help improve their living conditions, advocate to have more affordable housing and access to health services and resources.

Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-12 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024  Farm and Food Worker Relief Program – Catholic Charities Diocese Monterey is providing direct financial relief to eligible farmworkers in the counties of Monterey, Santa Cruz, San Benito, and San Luis Obispo. The purpose of this program is to provide direct financial relief to eligible field workers, meatpacking workers, livestock workers, and grocery store workers.

Quantified Objective: N/A
Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(NEW)
Program 1.3.G: Manufactured Homes on a Foundation System The City currently permits manufactured homes on a foundation system on lots zoned for conventional single-family residential dwellings pursuant to state law Government Code 65852.3.

Manufactured homes represent an affordable and cost-effective form of housing. The City will amend the Municipal Code to include manufactured homes as a permitted use in the R-1 zoning district subject to the same development standards to which a conventional single-family residential dwelling on the same lot would be subject.

Quantified Objective: 8 Low Income units
Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(NEW)
Program 1.3.H: Prepare Checklist and Procedures for SB35 Government Code section 65913.4 allows qualifying development projects with a specified proportion of affordable housing units to move more quickly through the local government review process and restricts the ability of local governments to reject these proposals. SB 35 does not apply within the Coastal Zone. Carmel-by-the-Sea is entirely within the Coastal Zone. If SB-35 becomes applicable to Coastal Zone areas, the City will create a SB35 checklist and written procedures for processing SB35 applications to ensure efficient and complete application processing.

Quantified Objective: N/A
Timeframe: Within 6 months of any change to the law that would impact the City Responsible Party: Community Planning and Building Department Funding Source: General Fund
(NEW)
Program 1.3.I: Implement State Law SB 10 Opportunities to Maximize Feasibility of Development in Strategic Locations.

SB 10 encourages strategic density within neighborhoods. Three (3) underutilized sites currently zoned R-1 and located on the periphery of the commercial district are occupied by non-residential Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-13 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 uses that could accommodate multi-family housing with the implementation of SB 10. The City will work with the property owners to zone these sites for development under the provisions of SB 10, including a by right process, requiring no discretionary review. These sites include Site #5 (First Church of Christ Parking Lot), Site #6 (American Red Cross), and Site #9 (American Legion).

Quantified Objective: 4 Extremely Low, 3 Very low, 6 Low, 3 Moderate, and 3 Above Moderate-Income units
Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(NEW)
Program 1.3.J: Emergency Shelters
In compliance with AB 2339 Statutes of 2022, the City will amend Title 17 to define emergency shelters and clearly state they are a permitted use by-right, requiring no discretionary review in the CC, SC, and RC commercial districts.

Quantified Objective: N/A
Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(NEW)
Policy 1.4: Improve Development Review and Approval Processes Program 1.4.A: Eliminate Unnecessary Use Permits - AFFH Multi-family and duplex housing units constituted approximately 13 percent of Carmel’s housing stock. The use permit (UP) (or conditional use permit (CUP)) requirement is implemented as an additional regulatory tool and adds extra regulations, review, and required findings, to a variety of development standards that affect multi-family development. Municipal Code Chapter 17.64 Findings Required for Permits and Approvals includes a broad list of applicable conditional uses and incentives. There are opportunities to reduce redundancies and facilitate residential construction while still enabling development to meet City regulations. For example, a use permit is required in:
 Municipal Code Section 17.64.190 Residential Construction at Densities Between 33 and 44 Units per Acre;
 Municipal Code Section 17.64.230 Affordable Housing – Residential Construction at Densities Between 45 and 88 Units Per Acre for developments the request a bonus density or a density bonus; and
Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-14 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024  Municipal Code Section 17.14.150 Building Height requires a use permit for additional underground floors used for parking vehicles, storage and mechanical equipment. The additional use permit requirement can affect how much parking can be accommodated and limit the number of units.

The City will eliminate UP requirements to remove the constraint to the development of multifamily residential units, and licensed community care facilities of seven or more persons.

Quantified Objective: 50 Moderate-Income units
Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Development Department
Funding Source: General Fund
(Formerly Program 3-2.1.D: Multi-Family Residential Development Review) Program 1.4.B: Objective Design and Development Standards - AFFH The City currently relies upon mostly subjective design guidelines for new single-family residences.

In the commercial and multi-family districts, less detailed subjective design guidelines are in place.

The City’s residential and commercial design guidelines are being updated this year to provide clarity and more objectivity. The lack of objective design guidelines creates a higher level of subjectivity for multi-family affordable projects.

The lack of Objective Design and Development Standards poses a constraint to residential development. Guidelines that are subjective increase uncertainty and risk for housing developers.

Objective Design and Development Standards provide a measure of clarity that proposed developments will be measured against, and provide the community with assurance that developments will conform with measurable objective standards. The City will create Objective Design and Development Standards for multi-family housing projects that include at least one deedrestricted affordable housing unit.

In November 2023, the City received an $85,000 REAP 2.0 Local Suballocation Grant — which will be used to pursue the creation and adoption of Objective Design and Development Standards (ODDS) to reduce governmental constraints presently limiting the production of affordable housing. Once adopted, the City's ODDS will be used to review and approve housing projects with at least 20 percent affordable units (units for very-low, low, and moderateincome households) on sites identified within the City's draft 2023-2031 6th Cycle Housing Element. The City's expectation, and desired intent, is that having ODDS in place will incentivize and accelerate the construction of multi-family affordable housing projects in the City's downtown zones, including the Central Commercial (CC), Service Commercial (SC), Residential & Limited Commercial (RC), and Multifamily Residential (R-4), which all fall within the Potential Opportunity Area identified by Moving Forward Monterey Bay 2045.

Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-15 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Quantified Objective: N/A
Timeframe: Adoption of Objective Design Guidelines by December 2025 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(NEW)
GOAL H2 PROTECT AFFORDABLE HOUSING AND IMPROVE THE

HOUSING STOCK
Policy 2.1: Maintain and encourage expansion of permanent residential housing stock in the Residential and Commercial Districts.

Program 2.1.A: Incentives for Mixed-Use Development - AFFH Providing additional development capacity of any type increases project feasibility. In order to better incentivize affordable residential development, the City will amend the Municipal Code to increase the floor area bonuses from 15 to up to 25 percent for projects that include housing for Moderate, Low or Very-Low-income households. The City will also distribute informational materials promoting the floor area bonus and other applicable incentives.

Quantified Objective: 5 Moderate-Income units
Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-2.1.a)
Program 2.1.B: Permanent Housing - AFFH
Short-term rentals can provide valuable coastal visitor-serving access; however, units used as shortterm rentals preclude the establishment of permanent housing. The City also has a significant percentage of the housing stock that remains vacant for part of the year due to second home ownership. This creates a significant barrier for current and potential residents to enter the local housing market and further limits opportunities to correct the housing crisis, address diversity, and provide inclusive housing options.

The City’s ordinance prohibiting short-term, transient rentals and timeshares of residential dwellings in the R-1 District and allowing a limited number of short-term rentals in the commercial areas has successfully limited the proliferation of these uses. The City will continue to implement these ordinances. In an effort to address the high rate of second home ownership, the City will promote Accessory Dwelling Units and Junior Accessory Dwelling Units (see Programs 1.3.C and 1.3.D) to add affordable rental units on properties that may otherwise lie vacant, and will establish an Affordable Housing Trust Fund (see Program 2.1.D).

Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-16 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Quantified Objective: Preservation of permanent housing and affordable units Timeframe: Continued ordinance implementation through June 2031 Responsible Party: Community Planning & Building Department/City Administrator Funding Source: General Fund
(Formerly Program 3-4.1.a)
Program 2.1.C: Monitor Affordable Housing Stock - AFFH
The City will develop a City-managed Affordable Housing Oversight Program and continue to monitor affordable housing projects and work with the owners to preserve affordability through identification of funding sources and/or opportunities for partnerships with other housing providers. The program will formalize annual monitoring of the affordable housing stock throughout the city to ensure affordable housing is being protected and provided as required by Government Code Section 65590. The City will update its databases to better track data on new construction, demolition, conversion and replacement housing units for low- and moderate-income households including the following:
 The number of new housing units approved for construction;  The number of low- and moderate-income housing units required to be provided in new housing developments;
 The number of existing residential dwelling units occupied by low- and moderate-income households that have been authorized to be demolished or converted; and  The number of low- and moderate-income housing units required to be replaced (of those units being demolished or converted).

Additionally, in compliance with AB 1397, the City will adopt a policy to require replacement housing units subject to the requirements of Government Code section 65915, subdivision (c)(3) when any new housing development project occurs on a site meeting the any of the following conditions: 1) currently has residential uses or within the past five years has had residential uses that have been vacated or demolished, 2) was subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of low or very low-income, 3) subject to any other form of rent or price control through a public entity’s valid exercise of its police power, or 4) is occupied by low or very low-income households.

Quantified Objective: Monitor 50 Lower-Income housing units Timeframe: Develop program by June 2025
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.3.d: Monitor Affordable Housing Stock) Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-17 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Program 2.1.D: Establish Affordable Housing Trust Fund - AFFH The City currently relies on outside agencies and organizations to fund affordable housing projects. However, in an effort to establish a City-funded source dedicated to supporting the creation, maintenance, and rehabilitation of affordable units, the City will explore the creation of an Affordable Housing Trust Fund. Sources of funding could include increasing the existing Transit Occupancy Tax (TOT) or dedicating a portion of existing TOT to affordable housing, property transfer tax, sales tax, vacancy tax or other funding source.

Quantified Objective: $1,000,000
Timeframe: Establish Fund by June 2031
Responsible Party: City Administrator
Funding Source: General Fund
(NEW)
Policy 2.2: Preserve and protect the scale of established neighborhoods while encouraging property improvement.

Program 2.2.A: Historic Preservation Educational Programs Cities have unique characteristics that develop over time. Carmel-by-the-Sea has a distinctive building style and form that existing residents cherish and which serves to attract new residents and visitors. In an effort to continue to encourage improvements to the existing housing stock, the City will continue to promote education programs that improve public understanding of the City’s rich cultural and design heritage, and provide zoning flexibility and incentives to facilitate rehabilitation of historic resources. The City will continue to use the Historic Building Code to facilitate residential rehabilitation of historic residences.

Quantified Objective: 50 Low Income rehabilitated historic units Timeframe: Continued education and ordinance implementation through June 2031
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-4.3.a: Neighborhood Preservation Educational Programs) Policy 2.3: Preserve and expand affordable and rental housing opportunities to enable local employees to live in the community where they work.

Program 2.3.A: Preserve and Increase Upper Floor Residential Uses - AFFH The retail and office landscape is shifting and the City continues to experience retail and office vacancies. This shift represents an opportunity to increase supply of housing as a preferred development form in all Commercial Districts. The City currently prohibits the conversion of existing second-floor residential units to commercial use and requires all newly constructed second- “I believe a vacancy tax
should be proposed to the
voters, which can go toward
funding affordable housing.

The City needs to frame
affordable housing in a
positive way. I feel like
people's aversion to
affordable housing in their
communities is just a public
relations failure."
May 24, 2023 Housing Ad Hoc
Committee Community Meeting
Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-18 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 floor space to be used as residential units. Housing over first-floor commercial uses is a particularly suitable solution for underutilized second-floor space. Therefore, the City will proactively work with property owners to encourage conversion of vacant or underutilized upper floors to residential use.

Quantified Objective: 5 Moderate and 110 Above Moderate-Income units Timeframe: Proactive outreach through December 2031
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-2.1.b)
Policy 2.4: Preserve the existing housing stock
Program 2.4.A: Housing Rehabilitation and Maintenance Information - AFFH In order to stay habitable and energy efficient, all buildings need maintenance. When buildings fall into an extreme state of disrepair, a more comprehensive housing rehabilitation procedure is needed.

Over the past few years, inflation and building supply chain issues have dramatically increased the cost of building materials. Labor costs have also risen significantly due to a shortage of skilled construction workers and ongoing cost-of-living increases. This results in very costly rehabilitation projects. In order to assist Low-income property owners, the City will distribute information on Inspection Services and Housing Rehabilitation programs and alternative ways of financing home repairs.

Quantified Objective: 16 Low-Income rehabilitated units Timeframe: Proactive outreach through June 3031
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Programs 3-1.1.a and 3-1.1.c Housing Rehabilitation and Housing Maintenance) GOAL H3 PROVIDE OPPORTUNITIES FOR NEW AFFORDABLE AND

OTHER SPECIAL NEEDS HOUSING
Policy 3.1: Incentivize affordable housing development, with an emphasis on affordable housing built to accommodate Extremely-Low and Low-Income residents.

Encourage the private sector to produce affordable housing.

Program 3.1.A: Mixed Use Affordable Housing - AFFH
The retail and office landscapes are shifting and this change represents an opportunity to encourage mixed-use developments (housing over first-floor commercial uses) as a preferred development form via community outreach. The City will proactively work with property owners, property managers, and realtors to promote and incentivize upper-floor housing opportunities, including the potential of allowing a third-floor mezzanine for affordable housing. Such development would be subject to appropriate objective design standards, including the City’s 30-foot height limit.

Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-19 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Based on the feedback received by City Staff from the development community, the City will implement the following actions:
 Revise design guidelines based on community feedback
 Revise approval processes if constraints are identified during feedback gathering  Host outreach and FAQ forums for developers and community members (Annually) Quantified Objective: N/A
Timeframe: Revise guidelines and approval processes by December 2027 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly 3-2.1.c: Incentives for Mixed Use Affordable Housing) Program 3.1.B: Housing for Extremely-Low Income
Households - AFFH
Providing housing units for Extremely-Low Income (ELI)
Households earning 30 percent or less of the Area Median Income (AMI) for Monterey County has proved challenging for the City. The City will continue to place specific
emphasis on the provision of multi-family housing and nontraditional housing types such as single-room-occupancy units and transitional housing. The City will encourage development of housing for ELI households through a
variety of activities such as targeted outreach to for-profit and non-profit housing developers on at least an annual basis, providing in-kind technical assistance, fee deferrals, expedited/priority processing, identifying grant and funding opportunities, applying for or supporting applications for funding on an ongoing basis, reviewing and prioritizing local funding for developments that include housing for ELI households and/or offering additional incentives to supplement the density bonus provisions in state law.

The City also has a variety of programs to encourage the development ELI units including Accessory Dwelling Units, a portion of which are affordable by design to Extremely-Low Income Households and Employee Housing. The City has also funded a full-time permanent Associate Planner position through the General Fund to focus on long-range planning and housing needs.

Quantified Objective: 57 Extremely Low-Income units
Timeframe: Fund Associate Planner through June 2031
Responsible Party: Planning and Building Department
Funding Source: General Fund
(Formerly Program 3-5.4.b)
“I'm pretty passionate about
affordable housing and
diversity. I think that's what
makes a community, and we
do lack it. I have kids that
live in the community and
go to Carmel High School,
and I would like to see more
of a social, economic, and
age difference in our
community, personally."
May 24, 2023 Housing Ad Hoc
Committee Community Meeting
Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-20 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Program 3.1.C: Density Bonus - AFFH
Density bonuses can provide a significant incentive to build affordable housing units. By increasing the number of units permitted to be built on a property, the financial investment required to bring the development to fruition has a higher likelihood of a return. Given the high cost of materials, labor and borrowing costs, increasing the number of units can make the housing project financially feasible. The City will further review and revise applicable density bonus and bonus density ordinances to clarify the regulations and increase certainty of applicability.

Quantified Objective: 15 Low-Income units
Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.4.a: Density Bonus)
Program 3.1.D: Reduced Entitlement and Development Fees - AFFH Entitlement and development fees paid by project applicants assist in the City’s ability to recover administrative and operating costs; however, these fees may have the unintended consequence of increasing the cost of housing. To encourage the development of affordable housing, the City will waive the parking in-lieu fees for affordable housing units and reduce the planning and building permit fees by up to 25% for affordable housing units in commercial areas.

Quantified Objective: Reduced City fees by 25% for developments with affordable units Timeframe: Adopt Fee Schedule by July 2025
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.5.a: Reduced Entitlement and Development Fees) Program 3.1.E: Reduced Parking Requirements - AFFH
Parking requirements increase costs to residential development and take up valuable space that can be used for housing. The City will continue to offer reduced parking requirements for affordable housing developments. Additionally, the City will waive the parking in-lieu fees for affordable units, clarify the program requirements in the Central Commercial (CC) zoning district, and reduce parking requirements in the Multi-Family Residential (R-4), Residential & Limited Commercial (RC), and Service Commercial (SC) zoning districts.

Quantified Objective: Reduced parking for developments with affordable units Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.5.b: Reduced Parking Requirements) Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-21 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Program 3.1.F: Expedited Processing Procedures - AFFH
Faster permit processing times reduce overall project timelines and allow a project to get to the construction stage in a timely manner. Reducing overall project timelines is critical during this inflationary period where materials and labor costs continue to rise. Additionally, supply chains still have not recovered to pre-pandemic levels and delays in processing can also result in delays in placing orders and receiving materials and securing labor. The City will prioritize projects with affordable units, assign a dedicated planner to facilitate the development process, and schedule joint public hearings when multiple decision-making bodies are involved.

Quantified Objective: Shorter processing times by 50% for developments with affordable units
Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Planning and Building Department, in coordination with the Planning Commission and City Council
Funding Source: General Fund
(Formerly Program 3-5.5.c: Expedited Processing Procedures) Program 3.1.G: Establish Minimum Densities - AFFH
Establishing a minimum density can be utilized as a tool to ensure the limited available land in a City is used in an efficient manner and lower densities are avoided. The City’s intention for establishing a minimum density in the Commercial and Multi-Family Residential Districts is rooted in enabling the development of more dense housing in the City. Currently, the Commercial District (SC, RC, and CC) permits residential densities of 0-22 dwelling units per acre and the Multi-Family Residential District (R-4) permits a maximum of 33 dwelling units per acre. Effectively, establishing a minimum density in these districts will result in higher yields of residential units. Recent residential development in the City’s Commercial District have ranged in densities from 22-33 dwelling units per acre.

The City will revise the Municipal Code for commercial districts (RC, SC, and CC) and multi-family residential (R-4) district to establish a minimum density of 33 du/ac, as part of the base zoning.

Quantified Objective: 14 Extremely Low, 14 Very Low, 11 Low, 22 Moderate, and 110 Above Moderate-Income units
Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(NEW)
Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-22 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Policy 3.2: Recognize the special needs of persons with disabilities and the need to retain flexibility in the design review process to accommodate these needs.

Program 3.2.A: Reasonable Accommodation Procedures - AFFH A reasonable accommodation is any change, exception or adjustment to a rule, policy, practice or service that allows a person with a disability to have an equal opportunity to participate. Information on reasonable accommodation procedures will continue to be provided at City Hall and on the City’s website. The City will evaluate and revise Policy C11-01, which describes procedures to provide reasonable accommodation and will explore reduced or waived permit fees for persons with disabilities in compliance with the provisions of SB 520, in an effort to remove any additional barriers and encourage those with disabilities to apply.

Additionally, the City will amend the Municipal Code to remove the findings requirement for requested accommodations stating, “the requested accommodation will not result in a significant and unavoidable negative impact on adjacent uses or structures.” Quantified Objective: 8 applications
Timeframe: Adoption of revised policy by June 2031
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.1: Reasonable Accommodation Procedures) Policy 3.3: Facilitate the provision of transitional and supportive housing in appropriate districts in the community.

Program 3.3.A: Zoning for Transitional and Supportive Housing - AFFH Senate Bill (SB) 2 (2007) revised Housing Element law requiring that transitional and supportive housing be permitted as a residential use, subject only to restrictions that apply to other residential dwellings of the same type in the same zone. In compliance with SB 2, the City will continue to allow transitional/supportive housing as a residential use. The City’s Municipal Code permits transitional and supportive housing by-right in all districts that permit residential uses including the CC, SC, RC and R-4 Districts, regardless of the number of persons the facility.

Quantified Objective: N/A
Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.8: Zoning for Transitional and Supportive Housing) Program 3.3.B: Low-Barrier Navigation Centers - AFFH
Assembly Bill (AB) 101 (2019) provides a pathway to permanent housing for people experiencing homelessness. A “Low Barrier Navigation Center” is a housing first, low-barrier, service-enriched shelter focused on moving people into permanent housing. The shelter provides temporary living Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-23 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing. In order to comply with state law, the City will amend the Municipal Code to include the definition for “Low Barrier Navigation Center” and will develop By Right procedures for processing low barrier navigation centers.

Quantified Objective: N/A
Timeframe: Adoption of Municipal Code amendments by December 2024 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(NEW)
Program 3.3.C: Unlicensed Residential Care Facilities
State law requires local governments to treat licensed residential care facilities (e.g. group homes) with six or fewer residents as a residential use and subject to the same development standards as a single-family dwelling. Furthermore, no conditional use permit, variance, or other zoning clearance shall be required of a residential care facility that serves six or fewer persons that is not also required of a single-family dwelling of the same type in the same zone. The residents and operators of a residential care facility shall be considered a family for the purposes of any law or zoning ordinance that relates to the residential use of a property. However, “six or fewer persons” does not include the operator, the operator’s family, or persons employed as staff. These facilities are licensed and regulated by the State of California.

The City defines Residential Care Facilities as facilities that require or are licensed by the State of California to provide living accommodations and 24-hour, primarily nonmedical care and supervision for persons in need of personal services, supervision, protection, or assistance. Living accommodations are shared living quarters with or without separate kitchens or bathrooms for each room or unit. This classification includes facilities that are operated for profit as well as those operated by public or nonprofit institutions.

Residential Care, General. A residential care facility providing 24-hour nonmedical care for more than six persons in need of personal services, supervision, protection, or assistance. This classification includes hospices, board and care homes, and similar establishments that are licensed by the State of California. These types of facilities are conditionally permitted in the SC and RC Districts.

Residential Care, Limited. A residential care facility providing 24-hour nonmedical care for six or fewer persons in need of personal services, supervision, protection, or assistance essential for sustaining the activities of daily living. This classification includes only those facilities licensed for residential care by the State of California. These types of facilities are subject to the same regulations as apply to other family residential dwellings in the CC, SC, and RC Districts. In the R-1 District, they are permitted in single-family homes. In the R-4 District, they are permitted by-right with no restrictions.

Residential Care, Senior. A residential care facility providing 24-hour medical or nonmedical care for more than six persons 60 years of age or older in need of personal services, supervision, protection, or assistance for sustaining the Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-24 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 activities of daily living. This classification includes nursing homes for the elderly, life care or continuing care homes, and similar facilities licensed for residential care by the State of California. These types of facilities are conditionally permitted in the SC, RC, and R-4 Districts.

Recognizing that larger facilities provide necessary supportive environments for a variety of households, the City will amend the Zoning Ordinance to conditionally permit unlicensed facilities of seven or more persons in all zones that allow similar residential uses.

Quantified Objective: Amend the Zoning Ordinance to conditionally permit unlicensed residential care facilities of seven or more persons in all zones that allow similar residential uses
Timeframe: Amend the Zoning Ordinance by December 2024
Responsible Agency: Community Planning and Building Department Funding Source: General Fund
(NEW)
Program 3.3.D: Single Room Occupancy (SRO) Units
The Carmel Municipal Code will be amended to permit single-room occupancy units as a residential use subject only to those regulations that apply to other residential dwellings of the same type in the same zone. As such, City staff will complete the following schedule of actions to amend the Municipal Code:
 Draft a definition for "single room occupancy unit" to add to the zoning ordinance consistent with the Government Code (November 2024)
 Propose the zoning change amendment to the City Council for approval (December 2024) Quantified Objective: N/A
Timeframe: Adopt Ordinance by December 2024
Responsible Party: Community Planning & Building Department Funding Source: General Fund
(NEW)
GOAL H4 EXEMPLIFY SUSTAINABLE DEVELOPMENT AND ENERGY

CONSERVATION
Policy 4.1: Support energy and water conservation programs to reduce the consumption of these resources in housing and to reduce housing costs.

Program 4.1.A: Water Conservation - AFFH
Potable water remains scarce and highly regulated in the City and continues to be a major limiting constraint to new development. In order to preserve the City’s limited water allocation for new Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-25 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 residential units, the City will continue to enforce the Water Management Program through the building permit process, establish the Water Distribution Policy, and provide information to the community on water conservation retrofits and best practices. In addition, the City will provide information on and promote water conservation education through outreach and community engagement, and retrofit rebates provided by the Monterey Peninsula Water Management District.

Quantified Objective: Promote water conservation in 100 existing units Timeframe: Adoption of policy by June 2031
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly 3-5.6.b Water Conservation)
Program 4.1.B: Energy Conservation and Green Building
Conserving energy to reduce stress on the electrical grid and reduce the effects of climate change (i.e. wildfire and flooding) is increasingly critical. The City experienced significant power outages during the 2022-23 winter storms, adjacent areas were flooded, and the past few wildfire seasons have significantly impacted air quality and resulted in evacuations of neighboring communities. The City will continue to review applications for new construction and substantial alterations, taking into consideration solar orientation and access to sunlight. The City will also continue to require compliance with current state building standards for energy efficiency in all new homes. The City will further disseminate information by updating the website annually with related energy conservation and green building information. The City also participates in the Community Wildfire Protection Program and is committed to implementing Program recommendations.

Quantified Objective: Promote energy conservation in 100 existing units Timeframe: Continued education and compliance through June 2031 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.6.a: Energy Conservation and Green Building) GOAL H5 PUBLICIZE HOUSING NEEDS AND RESOURCES
Policy 5.1: Support and enforce fair housing laws. Expand fair housing choice by promoting housing opportunities and removing impediments to fair housing.

Program 5.1.A: Fair Housing Services - AFFH
The Fair Housing Act protects people from discrimination when they are renting or buying a home, getting a mortgage, seeking housing assistance, or engaging in other housing-related activities. The California Department of Fair Employment and Housing and the Conflict Resolution and Mediation Center of Monterey County provide fair housing services and information. These agencies advise persons in need of information on housing and employment, mediate Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-26 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 landlord/tenant disputes and research complaints about discriminatory housing practices. The City shall coordinate with these agencies to provide printed information about fair housing services at City Hall, on the City’s website, and in other public buildings such as the City’s two libraries. The City shall also refer inquiries related to fair housing to these agencies and provide fair housing resources at outreach events.

Quantified Objective: 25 referrals/materials distributed Timeframe: Proactive outreach through June 2031
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.7: Fair Housing Services)

Program 5.1.B: Housing Choice Voucher Program - AFFH
Created by the Housing and Community Development Act of 1978, the Housing Choice Voucher program, formerly known as Section 8, provides assistance to eligible Low- and Moderate-Income families to rent housing in the private market. Eligibility for this program is based on the family’s gross annual income and family size. The Housing Choice Voucher rental assistance program is administered by the Housing Authority of Monterey County. The City will continue to facilitate use of the Housing Choice Voucher program in the community by distributing information for the program at City Hall and the Library and making referrals to the Housing Authority.

Quantified Objective: 40 referrals/materials distributed Timeframe: Proactive outreach through June 2031
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.3.b Section 8 Rental Assistance)
Program 5.1.C: Shared Housing Information - AFFH
Shared housing is another important tool to provide affordable housing units. Shared housing is generally more affordable because a portion of a residence is rented as opposed to an entire unit.

Shared housing can also financially help low-income individuals who own their homes and alleviate loneliness. Benefits to Low-Income individuals include provision of safe and secure affordable housing in a high-cost market. The City will continue to distribute informational materials from the Monterey County Housing Authority and the Carmel Foundation, display information at City Hall and other public buildings and posted on the City’s website. The City will also seek out other Shared Housing providers and resources to expand this housing option.

Quantified Objective: 80 referrals/website visits
Timeframe: Proactive outreach through June 2031
Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-5.2: Shared Housing Information)
Attachment 2
Chapter 2.0 – Goals, Policies, and Programs 2-27 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Policy 5.2: Promote public awareness and foster pride in the history of the village.

Program 5.2.A: Support Community Organizations - AFFH
Community organizations play a pivotal role to provide outreach and services to those facing housing issues. The City will continue to support neighborhood organizations that promote neighborhood involvement, safety and improvement, including but not limited to the Carmel Residents Association, the Carmel Foundation and the Carmel Heritage Society. The City will develop partnerships with these organizations to promote neighborhood enhancement programs, conduct and improve outreach and education, and solicit community input.

Quantified Objective: N/A
Timeframe: Proactive outreach and partnerships through June 2031 Responsible Party: Community Planning and Building Department Funding Source: General Fund
(Formerly Program 3-4.2.b: Support Neighborhood Organizations)

Attachment 2
Chapter 2.0 – Goals, Policies, and Implementing Programs 2-28 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 This side intentionally left blank.

Attachment 2
Housing Needs & Fair Housing Report A

APPENDIX
Attachment 2
Attachment 2
Table of Contents
APPENDIX A HOUSING NEEDS & FAIR HOUSING REPORT........................................... A-1 A.1 Introduction ........................................................................................................................... A-1 A.2 Population, Employment, and Household Characteristics ............................................. A-8 A.3 Disproportionate Housing Needs ..................................................................................... A-34 A.4 Special Needs Groups ......................................................................................................... A-43 A.5 Access to Opportunity ........................................................................................................ A-59 A.6 Housing Stock Characteristics........................................................................................... A-68 A.7 Fair Housing Enforcement and Outreach Capacity....................................................... A-83 A.8 Fair Housing Recommendations ....................................................................................... A-89 A.9 Conclusion ............................................................................................................................ A-94 Tables
Table A-1 Population Growth Forecast by Jurisdiction, 2015-2045 ................................... A-9 Table A-2 Population Age Distribution by Jurisdiction, 2019 ............................................ A-11 Table A-3 Population by Race by Jurisdiction, 2019 ............................................................ A-13 Table A-4 Employment Growth Forecast by Jurisdiction, 2015-2045 ............................. A-21 Table A-5 Employment by Sector, Carmel-by-the-Sea, 2010 and 2019............................ A-22 Table A-6 Unemployment Rate, Carmel-by-the-Sea, 2019................................................. A-24 Table A-7 Regional Housing Needs Allocation .................................................................... A-25 Table A-8 Occupations by Mean Salary, Monterey County, 2019 ..................................... A-26 Table A-9 Housing Forecast by Jurisdiction, 2015-2045..................................................... A-26 Table A-10 Households by Income Category, Carmel-by-the-Sea, 2019............................ A-29 Table A-11 Overview of Special Needs Groups..................................................................... A-43 Table A-12 Extremely Low-Income Households, Carmel-by-the-Sea, 2015-2019 ........... A-45 Table A-13 Disability Status by Age, Carmel-by-the-Sea, 2021............................................ A-51 Attachment 2
Table A-14 Population with Developmental Disabilities by Age, Carmel-by-the-Sea, 2021........................................................................................ A-52 Table A-15 Population with Developmental Disabilities by Residence, Carmel-by-the-Sea, 2021........................................................................................ A-52 Table A-16 Homeless Population by Jurisdiction, 2017-2022.............................................. A-58 Table A-17 Homelessness by Household Type and Shelter Status, Monterey County, 2019A- ....................................................................................................... A-58 Table A-18 Housing Unit Growth Trends by Jurisdiction, 2010-2019............................... A-68 Table A-19 Housing Units by Type by Jurisdiction, 2019 ..................................................... A-69 Table A-20 Housing Units by Type and Tenure, Carmel-by-the-Sea, 2019 ....................... A-70 Table A-21 Household Size by Tenure by Jurisdiction, 2019 ............................................... A-70 Table A-22 Vacant Housing Units by Type, Carmel-by-the-Sea, 2019............................... A-73 Table A-23 Housing Permits by Income Group, Carmel-by-the-Sea, 2015-2021............. A-73 Table A-24 Inventory of Assisted Rental Housing ................................................................ A-75 Table A-25 Median Home Value by Jurisdiction, 2019-2022............................................... A-81 Table A-26 Average Rent by Number of Bedrooms, Carmel-by-the-Sea, 2023................ A-81 Table A-27 Housing Affordability, Carmel-by-the-Sea, 2022............................................... A-82 Table A-28 Fair Housing Issues, Contributing Factors, and AFFH Programmatic Actions ..................................................................................................................... A-91 Figures
Figure A-1 Major Public and Legal Actions that Influence Fair Access to Housing ..........A-3 Figure A-2 Population Growth, Carmel-by-the-Sea, 2010-2019 ............................................A-9 Figure A-3 Population Distribution by Age, Carmel-by-the-Sea, 2010-2019 .................... A-10 Figure A-4 Population by Race Compared to the County, 2019 ......................................... A-12 Figure A-5 Population by Race, Carmel-by-the-Sea, 2010-2019 ......................................... A-13 Figure A-6 Regional Non-White vs. White Population, 2010-2019.................................... A-15 Figure A-7 Diversity Index, Carmel-by-the-Sea, 2018 .......................................................... A-16 Figure A-8 R/ECAP by Census Tract, Carmel-by-the-Sea, 2009-2013 ............................. A-18 Attachment 2
Figure A-9 RCAAs by Census Tract, Carmel-by-the-Sea, 2015-2019................................. A-19 Figure A-10 Percent Non-White by Block Group, Carmel-by-the-Sea, 2018 ..................... A-20 Figure A-11 Worker Earnings by Place of Residence & Place of Work, Carmel-by-the-Sea, 2019........................................................................................ A-23 Figure A-12 Household by Type by Jurisdiction, 2019 ........................................................... A-27 Figure A-13 Changes in Household Type, Carmel-by-the-Sea, 2010-2019.......................... A-28 Figure A-14 Households by Household Size by Jurisdiction, 2019 ...................................... A-28 Figure A-15 Median Household Income by Jurisdiction, 2019 ............................................. A-30 Figure A-16 Regional Median Household Income, 2010-2019.............................................. A-31 Figure A-17 Median Income by Block Group, Carmel-by-the-Sea, 2015-2019 .................. A-32 Figure A-18 Income by Category, Carmel-by-the-Sea, 2019.................................................. A-33 Figure A-19 Housing Tenure by Jurisdiction, 2019 ................................................................. A-34 Figure A-20 Housing Problems by Tenure, Carmel-by-the-Sea, 2015-2019........................ A-35 Figure A-21 Severe Housing Problems by Tenure, Carmel-by-the-Sea, 2015-2019........... A-36 Figure A-22 Overcrowding by Severity by Jurisdiction, 2019................................................ A-37 Figure A-23 Overcrowding by Tenure and Severity, Carmel-by-the-Sea, 2019 .................. A-37 Figure A-24 Overcrowded Households, Carmel-by-the-Sea.................................................. A-38 Figure A-25 Cost Burden Severity by Jurisdiction, 2015-2019 .............................................. A-39 Figure A-26 Cost Burden by Tenure, Carmel-by-the-Sea, 2015-2019 .................................. A-40 Figure A-27 Cost Burden by Home Owners, Carmel-by-the-Sea, 2015-2019..................... A-41 Figure A-28 Cost Burden by Renter Households, Carmel-by-the-Sea, 2015-2019............. A-42 Figure A-29 Percent Living Below the Poverty Line by Race and Ethnicity, Carmel-by-the-Sea, 2019........................................................................................ A-46 Figure A-30 Senior Population by Jurisdiction, 2019 .............................................................. A-47 Figure A-31 Senior Housing by Tenure, Carmel-by-the-Sea, 2019 ....................................... A-48 Figure A-32 Senior Households by Income, Carmel-by-the-Sea, 2019 ................................ A-48 Figure A-33 Population by Disability Status by Jurisdiction, 2021 ........................................ A-50 Figure A-34 Trends in Persons with Disabilities, Carmel-by-the-Sea, 2012-2021 .............. A-50 Attachment 2
Figure A-35 Households by Size and Tenure, Carmel-by-the-Sea, 2019.............................. A-53 Figure A-36 Single-Parent Households by Jurisdiction, 2019 ................................................ A-54 Figure A-37 Trends in Single-Parent Households, Carmel-by-the-Sea, 2010-2019............ A-55 Figure A-38 Hired Farm Labor, Monterey County, 2002-2017............................................. A-56 Figure A-39 TCAC Opportunity Composite Score, Carmel-by-the-Sea, 2022 ................... A-61 Figure A-40 TCAC Opportunity Economic Score, Carmel-by-the-Sea, 2022 .................... A-62 Figure A-41 TCAC Opportunity Education Score, Carmel-by-the-Sea, 2022 .................... A-63 Figure A-42 TCAC Opportunity Environmental Score, Carmel-by-the-Sea, 2022............ A-65 Figure A-43 Social Vulnerability Index, Carmel-by-the-Sea, 2018 ........................................ A-66 Figure A-44 Housing by Type in Carmel-by-the-Sea, 2010-2019.......................................... A-69 Figure A-45 Household Tenure by Race, Carmel-by-the-Sea, 2019 ..................................... A-71 Figure A-46 Vacancy Rates by Jurisdiction, 2019 .................................................................... A-72 Figure A-47 Vacancy Trends, Carmel-by-the-Sea, 2010-2019 ............................................... A-72 Figure A-48 Displacement Risk, Carmel-by-the-Sea, 2022..................................................... A-78 Figure A-49 Housing Stock by Age, Carmel-by-the-Sea, 2019.............................................. A-79 Figure A-50 FHEO Cases Total, Monterey County, 2020 ..................................................... A-85 Figure A-51 FHEO Cases, Disability Bias, Monterey County, 2020 .................................... A-86 Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-1 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Appendix A
Housing Needs & Fair Housing Report
A.1 Introduction
The following report provides both the City of Carmel-by-the-Sea Housing Needs Assessment and Fair Housing Assessment. This analysis primarily utilizes U.S. Census Bureau American Community Survey (ACS) 5-Year Estimate data1 and California Department of Housing and Community Development (HCD) data.

Housing Needs Assessment
The Housing Needs Assessment for the City of Carmel-by-the-Sea provides an in-depth analysis of the City’s population, employment, economics, household, and housing stock conditions and characteristics. This assessment develops context for the City’s goals, programs, and policies for the 6th Cycle Housing Element.

Fair Housing Assessment
In 2018, Governor Brown signed Assembly Bill (AB 686) which requires departments and agencies to administer programs relating to housing in a way that affirmatively furthers fair housing (AFFH) 2 .

As of January 1, 2019, AB 686 extends the obligation to affirmatively further fair housing to all public agencies in the State of California. This affirmative duty is not limited to those agencies with relationships with the federal government and is to be broadly applied throughout agencies at the state and local level. Now, all public agencies must both (1) administer programs and activities relating to housing and community development in a manner that affirmatively furthers fair housing, and (2) take no action inconsistent with this obligation3. AB 686 also made changes to Housing Element Law, requiring Housing Elements and General Plans to incorporate AFFH requirements.

Such requirements include an analysis of fair housing outreach and capacity, integration and segregation, access to opportunity, disparate housing needs, and current fair housing practices. 1 The primary reason for using 2019 data is because this is the data that was primarily being used by HCD in their AFFH datasets for the majority of housing needs data, including data that is pulled from CHAS datasets which range from 2013-2019. Additionally, 2020-2021 Census data may not be representative due to the COVID-19 pandemic. Largely, the data is reported for 2019 as this aligns with the supplemental data HCD has provided and allows for consistent reporting.
2 Public agencies receiving funding from the U.S. Department of Housing and Urban Development (HUD) are also required to demonstrate their commitment to AFFH. The federal obligation stems from the fair housing component of the federal Civil Rights Act mandating federal fund recipients to take “meaningful actions” to address segregation and related barriers to fair housing choice.
3 California Department of Housing and Community Development Guidance, 2021, page 9.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-2 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Affirmatively Furthering Fair Housing
“Affirmatively furthering fair housing” means taking meaningful actions, in addition to combating discrimination, 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.

The duty to affirmatively further fair housing extends to all of a public agency’s activities and programs relating to housing and community development. (Gov. Code, § 8899.50, subd. (a)(1).)”
SOURCE: California Department of Housing and Community Development Guidance, 2021, page 14.

History of segregation in the region
The United States’ oldest cities have a history of
mandating segregated living patterns. Exclusive zoning
practices were common in the early 1900s -- courts
struck down only the most discriminatory and allowed
those that would be considered today to have a
“disparate impact” on classes protected by the Fair
Housing Act. For example, the 1926 case Village of
Euclid v. Amber Realty Co. (272 U.S. 365) supported the segregation of residential, business, and industrial uses, justifying separation by characterizing apartment
buildings as “mere parasite(s)” with the potential to
“utterly destroy” the character and desirability of
neighborhoods. At that time, multifamily apartments
were the only housing options for people of color,
including immigrants.

The Federal Fair Housing Act was not enacted until nearly 60 years after the first racial zoning ordinances appeared in U.S. cities. This coincided with a shift away from federal control over lowincome housing toward locally-tailored approaches (block grants) and market-oriented choice (Section 8 subsidies, now called Housing Choice Vouchers)—the latter of which is only effective when adequate affordable rental units are available.

Figure A-1 on the following page provides a timeline of major legal and public actions that have influenced fair access to housing beginning in 1910.

This history of segregation in the
region is important not only to
understand how residential
settlement patterns came about—
but, more importantly, to explain
differences in housing opportunity
among different residents.

In sum, not all residents had equal
ability to build housing wealth.

This historically unequal playing
field in part determines structural
inequities that persist today.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-3 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-1 Major Public and Legal Actions that Influence Fair Access to Housing SOURCE: Root Policy Research
Appendix A – Housing Needs & Fair Housing Report A-4 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Monterey County and the Monterey Bay region also have an interesting past, as far as the fight to end racial segregation is concerned. Some of the segregation in the Monterey Bay area can be attributed to historically discriminatory practices, such as racial covenants4 , redlining5, and
discriminatory mortgage approvals. While Carmel-by-the-Sea itself does not have a history of racial covenants, the City’s racial characteristics do reflect persistent “structural inequities” in society, and “self-segregation” (i.e., preferences to live near similar people).

Kent Seavey’s 2007 book Carmel: A History in Architecture details the history of Carmel-by-the-Sea, from its early settlement by Spanish explorers, to its marketing as a “seaside resort for Catholics” in the 1880s, to the development of the City’s more contemporary history and architectural design.

Similar to other jurisdictions within Monterey County, Carmel-by-the-Sea does not have a high level of diversity.

Harold and Ann Gilliam describe the history of Carmel in their 1996 book Creating Carmel, The Enduring Vision. Carmel started as an artist town, with notable writers, artists and poets Mary Austin, Sinclair Lewis, Jack London and Robinson Jeffers settling in Carmel-by the-Sea. They were drawn to Carmel-by-the-Sea for its natural beauty, a quiet town among Monterey pine forest, scenic, rocky coastline, and white sand beaches. The early small cottages of the early 1900’s reflect these humble beginnings, and the evolution of Carmel’s architecture, including, Comstock’s notable fairy-tale style buildings, mirrors the community of artists who resided in Carmel-by-the-Sea. As Carmel-by-the-Sea grew and became a globally known tourist destination land prices began to increase. Gilliam writes, "[a]s expensive homes have replaced Carmel’s traditional cottages, the town’s demographics have changed. The artists and writers who carried on the Sterling tradition… and the low-to-middleincome residents in the old redwood cottages, have been gradually replaced by upscale business people and professionals able to afford the fantastically escalating prices of land”. In addition to historical discriminatory practices that embedded segregated living patterns throughout the Monterey Bay area, it’s also necessary to recognize the historical impacts of colonization and genocide on Indigenous populations and how the effects of those atrocities are still being felt today.

Historically, the Monterey Peninsula has been home to indigenous populations for more than 10,000 years. The original inhabitants of present-day Monterey County were the Ohlone (Costanoan), Salinan, and Esselen tribes who have “…lived in communities related by language, family, and custom.”6
However, “[d]ue to the devastating policies and practices of a succession of explorers, missionaries, settlers, and various levels of government over the centuries since European expansion, these tribes have lost the vast majority of their population as well as their land.”7 4 Racial covenants are clauses that were inserted into property deeds to prevent people who were not White from buying or occupying land. 5 Redlining is the practice of denying credit to individuals based on race, ethnicity, or other discriminatory practices. 6 From Racial Beachhead: Diversity and Democracy in a Military Town, by Carol Lynn McKibben, 2012, Stanford University Press.
7 From Indigenous peoples of San Mateo County. San Mateo County Office of Education.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-5 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 The lasting influence of these policies and practices have contributed directly to the disparate housing and economic outcomes collectively experienced by Native populations today.8 The Monterey County Weekly news outlet highlights the past and present effects of restrictive covenants, along with other housing issues such as “the lack of affordable housing, generational wealth inequities and zoning issues,” as potential contributing factors to segregation within the County.9 Though restrictive racial covenants were never enacted specifically in Carmel-by-the-Sea (unlike nearby Pebble Beach and Pacific Grove), the City’s population demographics are less diverse than other jurisdictions within Monterey County. Carmel-by-the-Sea’s General Plan and Zoning Ordinance have long emphasized single-family residential patterns and consequently, the City offers a limited variety of housing types with 87 percent single family detached units. Historically, this type of development contributed to segregation patterns in part due to higher purchase costs that accompany single-family homes. Because financing for single-family properties favored educated higher income earners, purchasing property in the City remained out of reach for many lower income households and likely contributed to the demographics seen in the City today.

Enacting policies and programs that promote AFFH and highlight the community’s assets could attract a broader demographic to the area, and encourage those that work in the City to live here as well. As reflected by the 2021 Proclamation of the City Council of Carmel-by-the-Sea: Carmel-bythe-Sea has been and will continue to be enriched and enhanced in its cultural fabric, economic prosperity, and personal understanding of others by having a principled and respectful community standard towards all people.
8 From Systemic Inequality: Displacement, Exclusion, and Segregation, by Danyelle Solomon, et al., 2019, Center for American Progress.
9 From Ribakoff, S. (2022, November 24) A new group sets out to explore the history of racist housing covenants in Monterey County. Monterey County Weekly.

Carmel-by-the-Sea has been and will continue to be enriched and enhanced in its cultural fabric, economic prosperity and personal understanding of others by having a principled and respectful community standard towards all people.

July 5, 2021
Proclamation of the City Council of
Carmel-By-The-Sea
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-6 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Overview of Carmel-by-the-Sea
Over the past 10 years, Carmel-by-the-Sea has experienced growth in both population and jobs10, which means more
housing of various types and sizes is needed to ensure that residents across all income levels, ages, and abilities have a place to call home. While the number of people drawn to the City has steadily increased, housing production has not kept pace with demand, contributing to the housing shortage in the City. The following Housing Needs and Fair Housing Assessment develops context for the goals, programs, and policies that Carmel-by-the-Sea will implement to address inequities in the 6th Cycle Housing Element.

Summary of Population, Employment, Household and
Housing Stock Characteristics
The following provides a brief overview of population,
employment, household, and housing stock characteristics in Carmel-by-the-Sea. These statistics help inform the existing housing needs in Carmel-by-the-Sea, as well as highlighting past trends and future forecasts to develop proactive policies and programs to address the needs of the community.
 Between 2010-2019, Carmel-by-the-Sea’s population increased by 2.8 percent.11  According to the Association of Monterey Bay Area Governments (AMBAG) 2022 Regional Growth Forecast, Carmel-by-the-Sea, the population is forecast to grow by approximately three (3) percent between 2015 to 2045.
 In 2019, the predominant age group was individuals between 65 to 74 years of age.  In 2019, the population was comprised of the following racial and ethnic groups: non-Hispanic White individuals (86.5 percent), Hispanic or Latino (8.2 percent), Asian populations (5.2 percent), and Black or African American (0.1 percent).
 According to the AMBAG 2022 Regional Growth Forecast, Carmel-by-the-Sea is projected to experience an employment growth of 17 percent (562 new jobs) between 2015-2045.  In 2019, the unemployment rate was 0.1 percent; approximately 5 percent less than the County. 10 From AMBAG Regional Growth Forecast 2022; 2010 (population: 3,722); 2015 (population 3,854); 2020 (population: 3,949).
11 From U.S. Census Bureau, ACS 5-Year Estimate, 2010-2019 The fear factor about ‘housing
projects’ is very high in this
community. Even the process of
identifying housing sites is a red
flag for this community. However,
[more detached dwelling units and
new residential apartments above
commercial spaces] is a
continuation of a tradition that is
tried and true and proven all over
the world and also is the tradition
of this community.

February 28, 2023 Housing Ad Hoc
Committee Community Meeting
Attendee
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-7 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024  According to the AMBAG 2022 Regional Growth Forecast, Carmel-by-the-Sea is forecast to have a household growth of approximately one (1) percent by 2045 – an increase of 42 housing units.
 In 2019, the largest household type was married-couple family households (47 percent) singleperson households (40 percent), female-headed households (6 percent), Other non-family households (5 percent), and male-headed households (2 percent).  In 2019, above moderate-income households made up the majority of households in the City (62 percent) followed by lower-income households (28 percent), and moderate-income households (10 percent).
 In 2019, the housing stock was predominantly occupied by owner households (57 percent), compared to renter households (43 percent).
 In 2019, the majority of households (94 percent) do not experience overcrowding. Six (6) percent of households in Carmel-by-the-Sea are severely overcrowded and zero percent are moderately overcrowded.
 In 2019, 23 percent of households are cost burdened and 23 percent are severely cost burdened.  The 2015-2019 Comprehensive Housing Affordability Strategy (CHAS) data indicates there were approximately 310 extremely low- and very low-income households living in Carmel-by-theSea. There are approximately 140 extremely low-income households in Carmel-by-the-Sea, 100 of which are owner-occupied households and 40 extremely low-income renter-occupied households.
 In 2019, senior households makeup 43 percent of all households; 15 percent of seniors rent their homes.
 In 2019, 12 percent of people in Carmel-by-the-Sea have a disability of some kind.  In 2019, Carmel-by-the-Sea had 70 large households, of which 57 percent are renter-occupied households. Renter-occupied households makeup the majority of all 3-5+ person households.  In 2019, female-headed family households comprised 75 percent of single-parent households and male-headed households accounted for 25 percent. No single-parent households fell below the poverty level.
 The number of households experiencing homelessness has decreased between 2017 to 2022 from 16 persons to one (1), respectively.
 In 2019, Carmel-by-the-Sea had 3,832 housing units, an approximate 6 percent increase from the 3,606 units that existed in 2010.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-8 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024  Between 2015 and 2022, 18 housing units were issued permits in Carmel-by-the-Sea which represents 58 percent of the RHNA number of 31 units assigned in the 5thCycle Housing Element.
 In 2019, the housing stock included the following unit types: 87 percent of homes were singlefamily detached; 10 percent were multifamily; 2 percent were mobile homes; and 1 percent were single-family attached.
 From 2010 to 2019, the City has experienced a stable vacancy average of 51 percent as a result of tourism and second-home ownership.
 As of 2019, 80 percent of Carmel-by-the-Sea’s vacant units were for seasonal, recreational, or occasional (second home) use.
 In 2022, the median home value was estimated to be $2,070,835. Home prices increased by 59 percent from 2019 to 2022. This reflects a 20 percent higher increase than the County, which is similar to nearby cities.
12  As of 2023, the average rent for an apartment in Carmel-by-the-Sea ranged from $2,200 (studio) to $5,459 (three bedrooms).13
A.2 Population, Employment, and Household Characteristics Population characteristics impact current and future housing needs in a community. A city’s population growth, age composition, and race and ethnicity composition help to determine the type and extent of housing needed. The following section provides analysis of population characteristics and local trends that affect housing demand in Carmel-by-the-Sea.

Population Growth
Table A-1 shows population projections through 2045 according to the Association of Monterey Bay Area Governments (AMBAG) 2022 Regional Growth Forecast. In Carmel-by-the-Sea, the population is forecast to grow approximately 3 percent between 2015 to 2045. This reflects 11 percent less than the County, 1 percent more than Pacific Grove, and 56 percent less than Del Rey Oaks14. Population growth forecasts provide critical insight to the future demands of communities in terms of housing needs, employment, and more.
12 From Zillow Home Value Index, December 2019-2022 13 From Zillow Rental Price Index, March 2023 14 These two Cities have been chosen for comparison throughout the document based on having comparable population sizes to Carmel-by-the-Sea.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-9 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-1 Population Growth Forecast by Jurisdiction, 2015-2045 Jurisdictions Population Change
2015-2045
2015 2020 2025* 2030* 2035* 2040* 2045* Numeric %
Monterey County 430,310 441,143 452,761 467,068 476,028 483,884 491,443 61,133 14% Carmel-by-theSea 3,854 3,949 3,946 3,954 3,964 3,974 3,984 130 3% Del Rey Oaks 1,663 1,662 1,693 1,734 1,859 2,330 2,650 987 59% Pacific Grove 15,460 15,265 15,290 15,395 15,530 15,676 15,817 357 2% SOURCE: AMBAG Regional Growth Forecast, 2022
NOTE: *Projected growth values
Figure A-2 illustrates population growth in Carmel-by-the-Sea between 2010-2019. Carmel-by-theSea’s population increased by 2.8 percent from 2010 to 2019. The City’s population steadily increased from 2010 to 2017 before experiencing a sharp decline through 2019.

Figure A-2 Population Growth, Carmel-by-the-Sea, 2010-2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2010-2019 Age Characteristics
A community’s housing needs are partly determined by preferences of age groups and household types (age, family/non-family, female-headed, etc.). When seeking housing, households may prioritize factors such as size, accessibility, and price. For instance, younger and middle-aged households may seek homes that can accommodate a growing household size, whereas older adults may seek to downsize to an apartment with assistive care services or a smaller, more affordable single-family home. Disabled persons may seek homes that are accessible and include universal 3600
3650
3700
3750
3800
3850
3900
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Population
Year
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-10 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 design or visitability features. Overall, the life stages of a population determine the housing stock that is needed in a community.

In 2010, Carmel-by-the-Sea’s predominant age group was
individuals between 65 and 74 years of age (19 percent).

Figure A-3 shows that between 2010 and 2019, the
general age of the population has been slowly increasing, with the most populous age groups in the City being
individuals between 55 and 84 years of age. The City’s
median age has changed little since 2010, ranging from
56 in 2010, 54 in 2015, and 59 in 2019. Overall, the City’s aging trend suggests a demand for housing geared toward middle-aged to senior groups.

Figure A-3 Population Distribution by Age, Carmel-by-the-Sea, 2010-2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2010, 2015, 2019 Age 0-4 Age 5-14 Age 15-24 Age 25-34 Age 35-44 Age 45-54 Age 55-64 Age 65-74 Age 75-84 Age 85+ 2010 3% 8% 4% 8% 10% 17% 12% 19% 12% 5%
2015 6% 11% 6% 6% 11% 11% 16% 20% 8% 6%
2019 1% 10% 1% 8% 11% 11% 14% 21% 15% 7%
0%
5%
10%
15%
20%
25%
“When I grew up, this
was a town of children.

All the property owners
were parents. All the
employees in the stores
were parents. So,
everything in this town
was about children, and
we don't have children
anymore.”
May 24, 2023 Housing Ad
Hoc Committee Community
Meeting Attendee
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-11 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-2 shows population age distribution revealing that Carmel-by-the-Sea’s most populous age group in 2019 was individuals 65 to 74 years of age (21 percent). Compared to the County and nearby cities, Carmel-by-the-Sea has the largest 55 to 85+ age group (43 percent) followed by Pacific Grove (27 percent), Del Rey Oaks (23 percent), and the County (13 percent). Since 2010, Carmelby-the-Sea’s smallest age demographic are those aged 0-14.

Table A-2 Population Age Distribution by Jurisdiction, 2019 Jurisdiction Population Age
0-4 5-14 15-24 25-34 35-44 45-54 55-64 65-74 75-84 85+
Monterey County 7.3% 14.8% 14.3% 14.4% 13.0% 11.8% 11.1% 7.7% 3.6% 1.9% Carmel-by-the-Sea 1.4% 9.7% 1.4% 8.1% 10.6% 11.4% 14.3% 21.3% 14.9% 7% Del Rey Oaks 5.7% 8.3% 5.7% 12.6% 12.5% 13% 18.9% 15.9% 4.4% 2.9% Pacific Grove 3.5% 12.2% 8.5% 10.0% 10.4% 13.3% 14.7% 16.5% 6.6% 4.3% SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2019
Race and Ethnicity Characteristics
Examining the demographic, ethnic, and racial composition of a region is integral to understanding fair housing concerns including access to economic opportunity and safe and affordable housing.

Historic exclusionary governmental policies, biased mortgage lending practices, and other tactics have caused racial and ethnic segregation and spatial inequities. This section provides an overview of racial/ethnic composition and segregation patterns within Monterey County and the City of Carmelby-the-Sea.

Understanding the racial and ethnic composition of a city is vital to ensuring equal opportunity to housing for all groups, inclusive of cultural norms and preferences. An in-depth analysis of race and ethnicity is provided in the Fair Housing Report in Appendix A. Figure A-4 illustrates the racial and ethnic composition of Carmel-by-the-Sea compared to the County.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-12 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-4 Population by Race Compared to the County, 2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2019
When comparing the City and the County, non-Hispanic White and Hispanic or Latino populations are the most represented; however, the County presents more diversity than Carmel-by-the-Sea.

Non-Hispanic White individuals comprise 87 percent of Carmel-by-the-Sea’s population followed by Hispanic or Latino (8 percent) and Asian populations (5 percent). In contrast, the County’s largest population is Hispanic or Latino individuals (60 percent) followed by non-Hispanic White (31 percent). The City has no populations identifying as American Indian or Alaska Native or Native Hawaiian or Other Pacific Islander. Black or African American non-Hispanic individuals represent less than 1 percent of the City’s population.

Table A-3 provides a comparison of racial and ethnic composition by jurisdiction. In 2019, Carmelby-the-Sea (87 percent) and the neighboring City of Pacific Grove (83 percent) had the largest nonHispanic White populations compared to Del Rey Oaks (75.5 percent) and the County (30.8 percent). Compared to surrounding cities and the County, Carmel-by-the-Sea had the lowest Asian population (5 percent). Overall, Carmel-by-the-Sea is one of the least diverse when compared to the County and the nearby cities of Del Rey Oaks and Pacific Grove.

American
Indian or
Alaska
Native
Asian
Black or
African
American,
NonHispanic
White,
NonHispanic
Some
other race
Hispanic
or Latino
Native
Hawaiian
and Other
Pacific
Islander
Carmel-by-the-Sea 0.0% 5.2% 0.1% 86.5% 0.0% 8.2% 0.0%
Monterey County 0.2% 5.5% 2.5% 30.8% 0.1% 60.3% 0.5%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-13 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-3 Population by Race by Jurisdiction, 2019
Jurisdiction
American
Indian or
Alaska
Native
Asian,
alone
Black or
African
American,
NonHispanic
White, NonHispanic
Some
Other
Race
Hispanic
or Latino
Native
Hawaiian
and Other
Pacific
Islander
Monterey County 0.2% 5.5% 2.5% 30.8% 0.1% 60.3% 0.5%
Carmel-by-the-Sea 0.0% 5.2% 0.1% 86.5% 0.0% 8.2% 0.0%
Del Rey Oaks 0.0% 7.1% 2.5% 75.5% 0.0% 13% 0.3%
Pacific Grove 0.2% 5.8% 1.0% 82.8% 0.0% 10.3% 0.1%
SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2019
When analyzing race and ethnicity in a city, it’s important to understand how demographics have changed over time. Figure A-5 illustrates changes in population by race between 2010-2019 in Carmel-by-the-Sea. During this time frame, Carmel-by-the-Sea’s population composition experienced fluctuations in nearly all populations, and by 2019 saw a decline in each population except non-Hispanic White. In 2015, the non-Hispanic White population experienced a 2 percent decrease in size, while the Asian and Hispanic or Latino populations increased 2 percent and 3 percent, respectively. In 2019, Carmel-by-the-Sea experienced a 7 percent increase in the nonHispanic White population, and a decline in both the Asian and Hispanic or Latino populations by 4 percent and 3 percent, respectively. Since 2015, population levels have remained less than 1 percent for Black or African American, American Indian or Alaska Native, Native Hawaiian, and Other Pacific Islander populations in Carmel-by-the-Sea.

Figure A-5 Population by Race, Carmel-by-the-Sea, 2010-2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2010, 2015, 2019 American
Indian or
Alaska Native
Asian
Black or
African
American,
Non-Hispanic
White, NonHispanicSome other
race
Hispanic or
Latino
Native
Hawaiian
and Other
Pacific
Islander
2010 0.0% 8.6% 1.4% 81.5% 0.0% 8.5% 0.0%
2015 0.3% 9.0% 0.0% 79.6% 0.0% 11.1% 0.0%
2019 0.0% 5.2% 0.1% 86.5% 0.0% 8.2% 0.0%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-14 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Demographic characteristics such as the racial and ethnic composition of a city are necessary to inform the housing needs of a community inclusive of cultural norms and preferences.

Integration and Segregation
To inform priorities, policies, and actions, the housing element must include an analysis of integration and segregation, including patterns and trends. Integration generally means a condition in which there is not a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a particular type of disability in a specific geographic area. Segregation generally means the opposite condition, where concentrations of the characteristics described above are high in a specific geographic area.

Integration and Segregation
“Integration generally means a condition in which there is not a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a particular type of disability when compared to a broader geographic area.

Segregation generally means a condition in which there is a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a type of disability in a particular geographic area when compared to a broader geographic area.” SOURCE: California Department of Housing and Community Development Guidance, 2021, page 31.

Residential segregation and exclusion, whether by race, ethnicity, disability, or income, is a result of numerous housing policies, practices, and procedures—both public and private—that have had enduring and pervasive negative impacts. Overt and covert housing discrimination through land use policy, shifting housing markets, and patterns of investment and disinvestment, have restricted meaningful fair housing choice and equitable access to opportunity, particularly for communities of color. Historic patterns of segregation persist in California despite the long-standing federal mandate, established by the Fair Housing Act of 1968, that federal agencies and federal grantees affirmatively further the purposes of the FHA.

Past and present discriminatory policies and practices, including long-term disinvestment, have resulted in neighborhoods with concentrated poverty and poor housing stock, limited access to opportunity, unsafe environmental conditions, underfunded schools, dilapidated infrastructure, and other disproportionately experienced problems. In addition, governmental policies have subsidized the development of segregated, high-resourced suburbs in metropolitan areas by constructing new highway systems—often through lower income communities of color— to ensure access to job opportunities in urban centers. This physical and policy infrastructure supports patterns of discrimination and high levels of segregation that continue to persist in California and across the country. All of these conditions persist despite the over 50-year-old obligation to prohibit discrimination and affirmatively further fair housing.15 15 California Department of Housing and Community Development. 2021. AFFH Guidance Memo. https://www.hcd.ca.gov/communitydevelopment/affh/docs/affh_document_final_4-27-2021.pdf Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-15 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-6 shows the percentage of non-White and White populations throughout the region from 2010 to 2019.

Figure A-6 Regional Non-White vs. White Population, 2010-2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2010, 2015, 2019 As of 2019, the City of Carmel-by-the-Sea has the highest percentage (86.5 percent) of White residents and the lowest percentage of Non-White residents (13.5 percent) when compared to the County, and the cities of Del Rey Oaks and Pacific Grove. Given the City’s status as being a “Highest Resource” city (see Figure A-17), having the highest median household income (see Figure A-16), and being a majority Senior community, Carmel-by-the-Sea recognizes the need to attract a more diverse population into the City and has identified various community resources and organizations to assist individuals that may have disparities in access to opportunity, and fall into the “special needs” category. A complete breakdown of service providers and community organizations that are available to the special needs populations is available in section A.4 (“Special Needs Groups”) of this Appendix.

Diversity Index
The Diversity Index measures the degree to which the five major ethnic populations (non-Hispanic White, non-Hispanic Black, Asian and Pacific Islander, Hispanic, and Two or more races) are evenly distributed across a geographic area. The index ranges from 0 to 1 – where 0 is low diversity, meaning only one group is present and 1 is high diversity, meaning an equal proportion of all five groups is present).

Figure A-7 below depicts the level of diversity within the City. Carmel-by-the-Sea, along with neighboring jurisdictions have the lowest levels of diversity within the region. Carmel-by-the-Sea has a low level of diversity with 86.5 percent of the population identifying as non-Hispanic White.

NonWhite White NonWhite White NonWhite White
2010 2015 2019
Monterey County 67.1% 32.9% 26.7% 73.3% 69.2% 30.8%
Carmel-by-the-Sea 18.5% 81.5% 20.4% 79.6% 13.5% 86.5%
Del Rey Oaks 18.3% 81.7% 20.1% 79.9% 24.5% 75.5%
Pacific Grove 21.8% 78.2% 13.2% 86.8% 17.2% 82.8%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%
100.0%
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-16 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-7 Diversity Index, Carmel-by-the-Sea, 2018
SOURCE: California Department of Housing and Community Development, AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-17 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Racially or Ethnically Concentrated Areas of Poverty and Affluence A Racially Concentrated Area of Poverty or an Ethnically Concentrated Area of Poverty (R/ECAP) and a Racially Concentrated Area of Affluence (RCAAs) represent opposing ends of the segregation spectrum from racially or ethnically segregated areas with high poverty rates to affluent predominantly White neighborhoods. Historically, HUD has paid particular attention to R/ECAPs as a focus of policy and obligations to AFFH. Recent research out of the University of Minnesota Humphrey School of Public Affairs argues for the inclusion of RCAAs to acknowledge current and past policies that created and perpetuate these areas of high opportunity and exclusion.16 R/ECAPs
HCD and HUD’s definition of a Racially/Ethnically Concentrated Area of Poverty is:

A census tract that has a non-White population of 50 percent or more (majority-minority) or, for non-urban areas, 20 percent, AND a poverty rate of 40 percent or more; OR A census tract that has a non-White population of 50 percent or more (majority-minority) AND the poverty rate is three times the average tract poverty rate for the County, whichever is lower.

SOURCE: California Department of Housing and Community Development Guidance, 2021.

It is important to note that R/ECAPs and RCAAs are not areas of focus because of racial and ethnic concentrations alone. This study recognizes that racial and ethnic clusters can be a part of fair housing choice if they occur in a non-discriminatory market. Rather, R/ECAPs are meant to identify areas where residents may have historically faced discrimination and continue to be challenged by limited economic opportunity, and conversely, RCAAs are meant to identify areas of particular advantage and exclusion.

RCAAs
HCD and HUD’s definition of an RCAA is a census tract 1) with a percentage of its total White population that is 1.25 times higher than the average percentage of the COG region’s White population; and 2) has a median income that is 2 times higher than the COG Area Median Income (AMI). Generally, these are understood to be neighborhoods in which there are both high concentrations of non-Hispanic White households and high household income rates.

SOURCE: California Department of Housing and Community Development Guidance, 2023 As can be seen in the Figure A-8 and Figure A-9, the City of Carmel-by-the-Sea is not considered a R/ECAP; nor, is the City considered an RCAA. As highlighted previously, Carmel-by-the-Sea does not have a majority-minority population and thus cannot be labelled as a R/ECAP. Figure A-10 16 From Goetz, E. G., Damiano, A., & Williams, R. A. (2019). Racially Concentrated Areas of Affluence: A Preliminary Investigation. Cityscape: A Journal of Policy Development and Research, 21(1), 99–124 Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-18 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 shows that less than or equal to 20 percent of the City’s population is non-White. Though Carmelby-the-Sea’s percentage of exclusively White population and AMI are higher than the County-wide average, the median income in the City is not high enough for the jurisdiction to be considered an RCAA17.

Figure A-8 R/ECAP by Census Tract, Carmel-by-the-Sea, 2009-2013 SOURCE: California Department of Housing and Community Development, AFFH Data Viewer 17 To be considered an RCAA, census tracts must have a Location Quotient (LQ) of more than 1.25 and a median income 1.5 times higher than the COG AMI or 1.5 times higher than the State AMI, whichever is lower. In this case, Carmel’s median income would need to be 1.5 times greater than the State AMI of $69,021.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-19 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-9 RCAAs by Census Tract, Carmel-by-the-Sea, 2015-2019 SOURCE: California Department of Housing and Community Development, AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-20 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-10 Percent Non-White by Block Group, Carmel-by-the-Sea, 2018 SOURCE: California Department of Housing and Community Development, AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-21 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Employment
Employment characteristics can significantly impact the housing needs and trends of a community from income and wage scale to job location and industry. Employment and income are determinates of a population’s ability to purchase housing including the type of housing and size, both of which can induce negative effects such as overpayment and overcrowding. Table A-4 summarizes projected employment growth for Carmel-by-the-Sea, the County, and nearby cities from 2015- 2045.

Table A-4 Employment Growth Forecast by Jurisdiction, 2015-2045 Jurisdictions Population Change
2015 - 2045
2015 2020 2025* 2030 2035* 2040* 2045* Numeric Percent
Monterey County 225,268 243,015 245,054 249,613 253,918 258,553 263,437 38,169 17% Carmel-by-the-Sea 3,353 3,566 3,593 3,674 3,752 3,833 3,915 562 17% Del Rey Oaks 705 748 753 774 794 815 834 129 18%
Pacific Grove 7,470 8,016 8,061 8,152 8,244 8,343 8,445 975 13% SOURCE: AMBAG Regional Growth Forecast, 2022
NOTE: *Projected growth values
According to the AMBAG 2022 Regional Growth Forecast, Carmel-by-the-Sea was projected to experience an employment growth of 17 percent (562 new jobs) between 2015-2045. This projected employment growth mirrors the County (17 percent) and is 4 percent higher than Pacific Grove (13 percent), but reflects 1 percent lower than Del Rey Oaks (18 percent). This projected increase in job growth presents an opportunity for cities to construct additional housing options for the existing and future workforce.

Table A-5 shows 2010 and 2019 employment data for Carmel-by-the-Sea by sector. Key findings in employment data include the following:
 Education services, healthcare, and social assistance industries were the largest employers of Carmel-by-the-Sea (28 percent) in both 2010 and 2019, followed by arts, entertainment, recreation, accommodation, and food services (19 percent and 15 percent, respectively);  Information industries experienced the greatest increase between 2010 and 2019 (585 percent), followed by construction (276 percent);
 Five sectors experienced drastic declines in employment between 2010 and 2019 including finance and insurance, real estate, and rental leasing (137 percent), professional, scientific, management, and administrative services (61 percent), public administration (54 percent), arts, entertainment, recreation, accommodation and food services (35 percent), and education services, healthcare, and social assistance (20 percent); Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-22 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024  Wholesale trade (2 percent) and agriculture, forestry, fishing and hunting, and mining (0 percent) industries experienced the least amount of growth; and
 Overall, there was a 19 percent decrease in employment for Carmel-by-the-Sea residents between 2010 and 2019.

Table A-5 Employment by Sector, Carmel-by-the-Sea, 2010 and 2019 Industry Sector
2010 2019 Percent
Change
2010-2019 People
Employed
Percent of City
Employment
People
Employed
Percent of City
Employed
Agriculture, forestry, fishing and
hunting, and mining 0 0% 0 0% 0%
Construction 25 1% 94 7% 276%
Manufacturing 40 2% 67 5% 68%
Wholesale Trade 0 0% 26 2% 2%
Retail Trade 247 14% 213 15% 14%
Transportation and warehousing,
and utilities 63 4% 95 7% 51%
Information 14 1% 96 7% 585%
Finance and insurance, real
estate, and rental leasing 172 10% 73 5% -137%
Professional, scientific,
management, and administrative
services
273 15% 106 7% -61%
Education services, healthcare,
and social assistance 493 28% 394 28% -20%
Arts, entertainment, recreation,
accommodation, and food services 330 19% 216 15% -35%
Public Administration 112 6% 52 4% -54%
Total Employment 1,769 100% 1,432 100% -19%
SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2010, 2019 Balance of Jobs to Workers
A city houses employed residents who either work in the community where they live, or work elsewhere in the region. Conversely, a city may have job sites that employ residents from the same city but more often employ workers commuting from outside of it. One measure of local imbalance is the relationship between workers and jobs. A city with a surplus of workers, “exports” workers to other parts of the region, while a city with a surplus of jobs must conversely “import” them.

Smaller cities will typically have more employed residents than jobs and will export workers as a result, while larger cities tend to have a surplus of jobs and will import workers. To some extent, the Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-23 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 regional transportation system is set up for this flow of workers to the region’s core job centers. At the same time, as the housing affordability crisis has illustrated, local imbalances may be severe, where local jobs and worker populations are out of sync at a sub-regional scale.

A community may offer employment for relatively low-income workers but have relatively few housing options for those workers. Conversely, it may house residents who are low-wage workers but offer few employment opportunities for them. Such relationships may cast extra light on potentially pent-up demand for housing in particular price categories. A relative surplus of jobs relative to residents in a given wage category suggests the need to import those workers, while conversely, surpluses of workers mean the community will export those workers to other jurisdictions. Such flows are not inherently bad, though over time, sub-regional imbalances may appear.

Figure A-11 illustrates earnings of workers in comparison to worker place of residence and place of work in Carmel-by-the-Sea. In 2019, Carmel-by-the-Sea had more low-wage jobs than low-wage residents (where low-wage refers to jobs paying less than $25,000). At the high end of the wage spectrum (i.e., wages over $75,000 per year), the City had more high-wage jobs than high-wage residents.18 This indicates the City is a net-importer of workers for both low- and high-wage jobs. It should be noted that the minimum wage has increased since 2019, from $12 to $15.50, thus increasing the annual incomes of full-time workers as well.

Figure A-11 Worker Earnings by Place of Residence & Place of Work, Carmel-by-the-Sea, 2019
SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2019
18 The source table is top-coded at $75,000, precluding more fine-grained analysis at the higher end of the wage spectrum.
48 148
213
328
621
457
1,108
1,226
509
703
0 200
400
600
800
1,000
1,200
1,400
Less than
$9,999
$10,000 to
$24,999
$25,000 to
$49,999
$50,000 to
$74,999
$75,000 or
more
Workers
Wage Group
Place of Residence
Place of Work
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-24 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 According to U.S. Census Bureau data reported in a Housing Feasibility Study for the City of Carmel-by-the-Sea by ECONorthwest,
19 a mere 2.6 percent of workers live and work in Carmel-bythe-Sea, while approximately half of all workers live within 10 miles of the City and 26 percent commute from more than 25 miles away.
20 Concentrations in hospitality and leisure services may create obstacles for local workers that earn lower-incomes and cannot afford to live in the community. Such imbalances of jobs to housing impacts an individual’s ability to integrate into the community due to long distance travel, excessive costs of travel, and reduced personal time.

Unemployment rates21 are essential to understanding the affordability needs of a community when determining housing options. Table A-6 provides a breakdown of unemployment rates for Carmelby-the-Sea, the County, and nearby cities. Compared to the County and nearby cities, Carmel-bythe-Sea has the lowest unemployment rate with less than 1 percent of unemployed residents. This indicates an approximate 4.8 percent less than the County, 5 percent less than the Del Rey Oaks, and 3.8 percent less than Pacific Grove.

Table A-6 Unemployment Rate, Carmel-by-the-Sea, 2019
Jurisdictions Unemployment Rate
Monterey County 4.9%
Carmel-by-the-Sea 0.1%
Del Rey Oaks 5.1%
Pacific Grove 3.9%
SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2019
The Monterey Bay Area approved Regional Housing Needs Assessment (RHNA) Methodology is broken down into four income levels:
 Very Low Income (50 percent or less of the County’s median income);  Low Income (50-80 percent of the County’s median income);  Moderate Income (80-120 percent of the County’s median income); and  Above moderate Income (120 and above the County’s median income).

Carmel-by-the-Sea’s RHNA allocation is presented below in Table A-7. 19 From ECONorthwest, Housing Feasibility Study, 2023
20 From U.S. Census Bureau Longitudinal Employer-Household Dynamics Data 21 The term unemployment refers to a person who is actively searching for employment but is not able to find work.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-25 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-7 Regional Housing Needs Allocation
Income Group Percentage of AMI Share
Extremely Low-Income22 <30 57
Very Low-Income <50 56
Low-Income 50-80 74
Moderate-Income 80-120 44
Above Moderate-Income 120+ 118
Total 349
SOURCE: City of Carmel-by-the-Sea, 2023
In Monterey County, the median household income in 2019 was an estimated $71,015 compared to Carmel-by-the-Sea at $98,188. Table A-8 lists occupations by mean salary in Monterey County.

According to Table A-8, the occupations that fall below 50 percent of the median income are Food Preparation and Serving-Related Occupations; Personal Care and Services Occupations; and Farming, Fishing, and Forestry Occupations. The majority of occupations in Monterey County have an average income that is low (50-80 percent AMI) or very low (<50 percent AMI). If applied to Carmel-by-the-Sea, it should be anticipated that affordable housing is needed to accommodate potential low- and very low-income households.

Household Characteristics
Characteristics of a household include household type and size, income, affordability, and special needs groups. According to HCD, a household is defined as “All persons who occupy a housing unit. The occupants may be a single family, on person living alone, two or more families living together, or any groups of related or unrelated persons who share living arrangements.” Large families, single parent households, female-headed households, or extremely low- and low-income households may be classified as Special Needs groups. Special Needs groups are identified due to the unique nature of household characteristics and potential housing challenges faced. The following section examines household characteristics trends in Carmel-by-the-Sea and the region.

Table A-9 provides an overview of the projected housing units needed in Monterey County, Carmelby-the-Sea, and nearby cities, Del Rey Oaks and Pacific Grove.23 Carmel-by-the-Sea is forecast to have a household growth of approximately 1 percent by 2045 – an increase of 42 housing units.

Compared to the County, this reflects 18 percent less projected growth and 2 percent less growth than Pacific Grove. Of the nearby cities, the City of Del Rey Oaks has the highest projected increase in housing unit growth at 61 percent.
22 Extremely low-income RHNA is found as a subset within the very low-income category for all other tables in this document.
23From AMBAG Regional Growth Forecast, 2022
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-26 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-8 Occupations by Mean Salary, Monterey County, 2019 Occupation Salary
Management Occupations $117,738
Business and Financial Operations Occupations $78,900
Computer and Mathematical Occupations $96,980
Architecture and Engineering Occupations $92,554
Life, Physical, and Social Science Occupations $84,516
Community and Social Services Occupations $59,549
Legal Occupations $103,094
Education, Training, and Library Occupations $69,296
Arts, Design, Entertainment, Sports, and Media Occupations $56,599 Healthcare Practitioners and Technical Occupations $115,486 Healthcare Support Occupations $42,625
Protective Service Occupations $70,161
Food Preparation and Serving-Related Occupations $30,127 Building and Grounds Cleaning and Maintenance Occupations $36,330 Personal Care and Service Occupations $31,984
Sales and Related Occupations $42,099
Office and Administrative Support Occupations $44,239
Farming, Fishing, and Forestry Occupations $29,901
Construction and Extraction Occupations $60,870
Installation, Maintenance, and Repair Occupations $54,180 Production Occupations $41,905
Transportation and Material Moving Occupations $37,144
SOURCE: California Employment Development Division, Occupational Wage data, 2019 Table A-9 Housing Forecast by Jurisdiction, 2015-2045
Jurisdictions Population Change
2015 - 2045
2015 2020 2025* 2030* 2035* 2040* 2045* Numeric Percent Monterey County 139,177 141,764 146,716 153,852 159,100 162,612 165,328 26,151 19% Carmel-by-the-Sea 3,417 3,437 3,437 3,442 3,450 3,453 3,459 42 1% Del Rey Oaks 741 741 762 809 848 1,052 1,195 454 61%
Pacific Grove 8,184 8,201 8,214 8,267 8,336 8,400 8,463 279 3% SOURCE: AMBAG Regional Growth Forecast, 2022
NOTE: *Projected growth values
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-27 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Household Type and Size
Figure A-12 illustrates household characteristics by type in 2019 for Carmel-by-the-Sea, the County, and nearby cities, Del Rey Oaks and Pacific Grove. In Carmel-by-the-Sea, the largest household type was married-couple family households (47 percent) followed by single-person households (40 percent). This is consistent with the County and nearby cities. Carmel-by-the-Sea has the lowest percentage of female-headed households (6 percent) compared to the County (13 percent), Del Rey Oaks (7 percent), and Pacific Grove (9 percent).

Figure A-12 Household by Type by Jurisdiction, 2019
SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2019
Figure A-13 illustrates household changes between 2010-2019 in Carmel-by-the-Sea. Over the last decade, married-couple family households have remained the largest household type in the City followed by single-person households. Since 2015, married-couple family households have begun declining, while single-person households have increased. Female-headed households experienced the most fluctuation between 2010-2019, showing a steady increase between 2010-2013, then slowly decreasing through 2019 to 6 percent (7 percent decrease between 2013-2019). Male-headed households have slightly increased since 2010 from zero to 2 percent in 2019. These changes in household type over time indicate a need for housing options that appeal to both family-sized and smaller-sized households (keeping affordability in mind).

13.3%

5.9% 6.9% 8.8%

6.5%

2.0% 4.5% 2.8%

52.5%

46.9%

51.4% 45.9%

6.1%

5.2%

3.7%

6.4%

21.6%

40.0%

33.5% 36.0%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Monterey County Carmel-by-the-Sea Del Rey Oaks Pacific Grove Single-person Households
Other Non-Family Households
Married-couple Family Households
Male-headed Households
Female-Headed Households
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-28 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-13 Changes in Household Type, Carmel-by-the-Sea, 2010-2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2010-2019 NOTE: Non-family households include unrelated persons living in one housing unit.

Figure A-14 illustrates households by household size for Carmel-by-the-Sea, the County, and nearby cities. Carmel-by-the-Sea’s largest household type according to size is 2-person households (42 percent) followed by 1-person households (40 percent). This is consistent with findings in Figure A-13, with married-couple family households remaining the largest household type since 2010 followed by single-person households. This reflects a demand for affordable housing units appealing to married-couple and single-person households.

Figure A-14 Households by Household Size by Jurisdiction, 2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2019

8.8% 10.5% 11.9% 13.0% 11.0% 11.1% 11.0% 10.7% 6.8% 5.9%

0.0% 1.3% 1.5% 1.1% 1.1% 2.1% 1.2% 1.3%

0.9% 2.0%

43.6%

44.4% 46.4%

50.9% 50.9% 52.4% 49.3% 46.7% 49.9% 46.9%

3.6%

2.5%

3.8%

3.7% 2.6% 2.0%

2.8% 3.6% 3.8% 5.2%

44.0% 41.3% 36.4% 31.3% 34.5% 32.4% 35.7% 37.6% 38.5% 40.0% 0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Single-person Households
Other Non-Family Households
Married-couple Family Households
Male-headed Family Households
Female-Headed Family Households

40.0%

23.9%

33.5% 36.0%

41.5%

31.1%

38.2% 36.2%

14.8%

34.0%

21.4% 22.2%

3.6% 11.0% 6.9% 5.5%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Carmel-by-the-Sea Monterey County Del Rey Oaks Pacific Grove 5-Person or More Household
3-4-Person Household
2-Person Household
1-Person Household
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-29 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Household Income
Affordability is a key component in determining the housing needs of a community. Household income determines the ability of a household to purchase or rent a housing unit. However, fluctuating household incomes may result in the need to spend disproportionate amounts of income on housing costs, referred to as overpayment or cost burden. As a result, this may also lead to overcrowding and/or substandard living conditions.

The following are income categories based on area median income (AMI) according to HCD:
 Extremely low-income: households earning 0-30 percent of AMI;  Very low-income: households earning 30-50 percent of AMI;  Low-income: households earning 50-80 percent of AMI;
 Moderate-income: households earning 80-100 percent of AMI; and  Above-moderate income: households earning 100-120 percent of AMI.

Government Code Section 65583(a) defines extremely low-income households as earning 30 percent or below area median income, and considers them as a subset of the very low-income category. The extremely low-, very low-, and low-income groups are referred to as lower-income. In Carmel-bythe-Sea 28 percent of households are considered lower-income.

Table A-10 summarizes households by income category in Carmel-by-the-Sea in 2019. Above moderate-income households make up the majority of households in the City (62 percent) followed by lower-income households (28 percent). Approximately 7 percent of households in Carmel-bythe-Sea identify as extremely low-income. This reflects a need for more affordable housing in the City, and in tandem with Figure A-13 and Figure A-14 findings, it is likely the demand for singleperson households is accompanied by a need for affordable options.

Table A-10 Households by Income Category, Carmel-by-the-Sea, 2019 Income Category (% of County MFI) Households Percent
Extremely Low-Income (30% MFI or less) 140 7%
Very Low-Income (30-50% MFI) 170 9%
Low-Income (50-80% MFI) 235 12%
Moderate-Income (80-100% MFI) 185 10%
Above Moderate-Income (>100% MFI) 1,200 62%
Total 1,930 100%
SOURCE: Department of Housing and Urban Development (HUD) Comprehensive Housing Affordability Strategy (CHAS), 2015-2019 Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-30 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-15 illustrates the median household income in Carmel-by-the-Sea, the County, and nearby cities in 2019. Carmel-by-the-Sea’s median household income was $98,188 – approximately $27,173 higher than the County ($71,015). The City of Del Rey Oaks had the second highest median household income at $95,000 followed by Pacific Grove at $88,250. Understanding Carmel-by-theSea’s median household income determines what income category households identify with and what affordability levels look like for the community.

Figure A-15 Median Household Income by Jurisdiction, 2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2019
$71,015.00
$98,188.00 $95,000.00
$88,250.00
$-
$20,000.00
$40,000.00
$60,000.00
$80,000.00
$100,000.00
$120,000.00
Monterey County Carmel-by-the-Sea Del Rey Oaks Pacific Grove Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-31 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-16 highlights the median household income from 2010 to 2019, throughout the region.

Between 2010 and 2015, Carmel-by-the-Sea’s median household income remained relatively stable, and saw a 31.3 percent increase between the years of 2015 and 2019. Compared to other regional jurisdictions, Monterey County has maintained the lowest median household income, showing a slight decrease from 2010 to 2015, and a 20.8 percent increase from 2015 to 2019. The Cities of Del Rey Oaks and Pacific Grove followed similar trends to Carmel-by-the-Sea in that they increased slightly between the years of 2010 and 2015, and then increased significantly between 2015 and 2019.

Figure A-16 Regional Median Household Income, 2010-2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2010, 2015, 2019 Figure A-17 illustrates median household income across Carmel-by-the-Sea. According to the HCD AFFH Data Viewer, Carmel-by-the-Sea households experience variation in median household income based on location. Households located in the center of the City reportedly earn less than the City’s annual median income ($98,188) and households located in the north and south earn more (>$87,100 - <125,000).
2010 2015 2019
Monterey County $59,271.00 $58,783.00 $71,015.00
Carmel-by-the-Sea $74,489.00 $74,758.00 $98,188.00
Del Rey Oaks $81,154.00 $86,250.00 $95,000.00
Pacific Grove $66,730.00 $79,740.00 $88,250.00
$-
$20,000.00
$40,000.00
$60,000.00
$80,000.00
$100,000.00
$120,000.00
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-32 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-17 Median Income by Block Group, Carmel-by-the-Sea, 2015-2019 SOURCE: California Department of Housing and Community Development, AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-33 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-18 provides a breakdown of 2019 incomes by category in Carmel-by-the-Sea.

Approximately 43 percent of households are earning $100,000 or more (more than the City’s annual median income). Conversely, 26 percent households earn an annual income less than $50,000 ($48,188 less than the City’s annual median income). Approximately 41 percent of households are earning below the City’s annual median income, of which 10 percent earn less than $25,000.

Figure A-18 Income by Category, Carmel-by-the-Sea, 2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimates, 2019
The household income characteristics in Carmel-by-the-Sea reveal a demand for the development of more affordable housing options that appeal to both lower-income and above-moderate households.

Carmel-by-the-Sea is comprised primarily of above moderate-income households (62 percent), most of which identify as married-couple families (47 percent). Nonetheless, 28 percent of households are lower-income and 40 percent of households identify as single-persons. Affordable housing in Carmel-by-the-Sea must accommodate these households as well despite their non-majority makeup.

Figure A-19 illustrates housing by tenure in Carmel-by-the-Sea, the County, and nearby cities. Fiftyseven (57) percent of households in Carmel-by-the-Sea are owners and 43 percent are renters. This reflects an approximate 6 percent higher owner household population than the County (51 percent), 11 percent higher than Pacific Grove (46 percent), and 14 percent lower than Del Rey Oaks (71 percent).
10%
8%
8%
15%
11%
12%
11%
20%
Less than $25,000
$25,000 - $34,999
$35,000 - $49,999
$50,000 - $74,999
$75,000 - $99,999
$100,000 - $149,999
$150,000 - $199,999
$200,000 or more
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-34 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-19 Housing Tenure by Jurisdiction, 2019
SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
A.3 Disproportionate Housing Needs
Housing Problems and Severe Housing Problems
The following section details housing problems and severe housing problems in Carmel-by-the-Sea according to the Census Bureau Comprehensive Housing Affordability Strategy (CHAS).

Disproportionate Housing Needs
“Disproportionate housing needs generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area. For purposes of this definition, categories of housing need are based on such factors as cost burden and severe cost burden, overcrowding, homelessness, and substandard housing conditions.” SOURCE: California Department of Housing and Community Development Guidance, 2021, page 39.

The CHAS data set provides in-depth analysis on housing needs by income level according to types of households. According the CHAS, housing problems are defined as having one or more of the following variables:
 Incomplete kitchen facilities;
 Incomplete plumbing facilities;
 More than one person per room; and
 Cost burden greater than 30 percent.
57% 51%
71%
46%
43% 49%
29%
54%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Carmel-by-the-Sea Monterey County Del Rey Oaks Pacifc Groves Renter Occupied
Owner Occupied
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-35 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Severe housing problems are defined as having one or more of the following variables:
 Incomplete kitchen facilities;
 Incomplete plumbing facilities;
 More than 1.5 persons per room; and
 Cost burden greater than 50 percent.

Additionally, CHAS defines cost burden as the ratio of housing costs to household income. The following defines cost burden by renter and owner:
 Renter Cost Burden: gross rent (contract rent plus utilities); and  Owner Cost Burden: select monthly owner costs including mortgage payment, utilities, association fees, insurance, and real estate taxes.

Figure A-20 and Figure A-21 illustrate housing problems by tenure and severe housing problems by tenure in Carmel-by-the-Sea during 2019. Approximately 60 percent of renter households have at least one of four housing problems and 36 percent have at least one of four severe housing problems. In contrast, 47 percent of owner households experience at least one housing problem and 25 percent have at least one severe housing problem.

Figure A-20 Housing Problems by Tenure, Carmel-by-the-Sea, 2015-2019 SOURCE: U.S. Census Bureau, CHAS Data, 2015-2019
NOTE: The four housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1 person per room, and cost burden greater than 30%.
47%
60%
53%
40%
0% 20% 40% 60% 80% 100%
Owner %
Renter %
Household has at least 1 of 4
Housing Problems
Household has none of 4
Housing Problems OR cost
burden not available, no other
problems
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-36 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-21 Severe Housing Problems by Tenure, Carmel-by-the-Sea, 2015-2019 SOURCE: U.S. Census Bureau, CHAS Data, 2015-2019
NOTE: The four housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1.5 person per room, and cost burden greater than 50%.

Overcrowding
Understanding the prevalence of overcrowded households within a community helps determine the need for affordable and adequately sized housing units for the community. Overcrowding is defined as a household with more than one occupant per room excluding bathrooms and kitchens. Units with more than 1.5 persons per room are considered severely overcrowded. Overcrowding may occur due to a lack of available affordable and/or adequately sized housing units. Cultural norms and customs combined with low-income or lack of adequately size housing units can result in overcrowding too. For example, in Asian culture, households are often comprised of multigenerations. If this custom is also compounded by low-income or lack of adequately sized housing units overcrowding may occur.

Figure A-22 illustrates overcrowding by severity in Carmel-by-the-Sea, the County, and nearby cities in 2019. The City of Del Rey Oaks households experience the least amount of overcrowding (0.8 percent) and no severe overcrowding, compared to Carmel-by-the-Sea households that experience zero percent moderate overcrowding, but 6 percent severe overcrowding. Monterey County has a higher overall percentage of households that experience overcrowding (9 percent) and severe overcrowding (5 percent) compared to Carmel-by-the-Sea. 25%
36%
75%
64%
0% 20% 40% 60% 80% 100%
Owner %
Renter %
Household has at least 1 of 4
Housing Problems
Household has none of 4 Housing
Problems OR cost burden not
available, no other problems
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-37 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-22 Overcrowding by Severity by Jurisdiction, 2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Figure A-23 illustrates overcrowding by tenure and severity in Carmel-by-the-Sea during 2019.

Renter households in Carmel-by-the-Sea experience 8 percent more overcrowding than owner households. While renter households do not experience overcrowding (more than 1-person per room), 10 percent experience severe overcrowding (more 1.5-persons per room). Similarly, owner households in Carmel-by-the-Sea do not experience overcrowding, but 2 percent do experience severe overcrowding.

Figure A-23 Overcrowding by Tenure and Severity, Carmel-by-the-Sea, 2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
94%
86%
99%
92%
0%
9%
1%
3%
6% 5%
0%
5%
75%
80%
85%
90%
95%
100%
Carmel-by-the-Sea Monterey County Del Rey Oaks Pacific Grove More than 1.5 Occupants per Room

1.0 to 1.5 Occupants per Room

1.0 or Less Occupants per Room
98%
90%
0%
0%
2%
10%
84%
86%
88%
90%
92%
94%
96%
98%
100%
Owner Occupied Renter Occupied
More than 1.5 Occupants
per Room

1.01 to 1.5 Occupants per
Room

1.0 or Less Occupant per
Room
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-38 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-24 illustrates overcrowded households in Carmel-by-the-Sea. According to the HCD AFFH Data Viewer, Carmel-by-the-Sea households experience no variation in overcrowding based on location. In the City, overcrowding rates are less than 8.2 percent.

Figure A-24 Overcrowded Households, Carmel-by-the-Sea
SOURCE: California Department of Housing and Community Development, AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-39 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Cost Burden
According to HCD, overpayment or cost burden is measured as households spending more than 30 percent of their gross income including utilities for housing; severe overpayment or severe cost burden is measured as households spending 50 percent or more of their gross income for housing.

For the duration of this report, overpayment will be referred to as cost burden.

The cost burden rates of owners and renters in a community provide insight to housing needs such as, the affordability of the local housing market and the availability of housing units that accommodate household needs like size and housing type. Additionally, federal and state agencies examine cost burden to determine a community’s need for housing assistance.

Figure A-25 illustrates cost burden severity in Carmel-by-the-Sea, the County, and nearby cities.

Carmel-by-the-Sea household cost burden rates are similar to the County. In Carmel-by-the-Sea, 46 percent of households experience some level of cost burdened, of which 23 percent are severely cost burdened, while the County has a cost burden rate of 22 percent and a severe cost burden rate of 18 percent. The cities of Del Rey Oaks and Pacific Grove have slightly lower rates of cost burden overall with 67 percent and 61 percent of households experiencing no cost burden, respectively.

Overall, the City of Del Rey Oaks has the lowest percent of households experiencing any type of cost burden. It is important to relate Carmel-by-the-Sea’s approximate 46 percent cost burden with its 10 percent population of overcrowded renter households, as these may be indicators of an unaffordable and homogenous local housing market.

Figure A-25 Cost Burden Severity by Jurisdiction, 2015-2019 SOURCE: U.S. Census Bureau, CHAS Data, 2015-2019
54% 59%
67% 61%
23%
22%
21%
21%
23% 18%
11%
16%
0% 1% 1% 2%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Carmel-by-the-Sea Monterey County Del Rey Oaks Pacific Grove 0%-30% of Income Used for Housing 30%-50% of Income Used for Housing 50%+ of Income Used for Housing Not Computed
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-40 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-26 illustrates cost burden by tenure in Carmel-by-the-Sea. Renter and owner households experience similar levels of cost burden. Renter households experience 24 percent cost burden and 23 percent severe cost burden (47 percent total), whereas owner households experience 23 percent cost burden and 22 percent severe cost burden (45 percent total). This reflects a 1 percent difference between cost burden and severe cost burden for renter and owner households, respectively.

Figure A-26 Cost Burden by Tenure, Carmel-by-the-Sea, 2015-2019 SOURCE: U.S. Census Bureau, CHAS Data, 2015-2019
Figure A-27 illustrates cost burden of home owners in Carmel-by-the-Sea. According to the HCD AFFH Data Viewer, the highest rates of cost burden among home owners in Carmel-by-the-Sea are concentrated in the central and southern regions of the City. In these regions, 80 percent of owner households experience cost burden. In the northern region of the City, 40-60 percent of owner households experience cost burden.

Figure A-28 illustrates cost burden of renters in Carmel-by-the-Sea. When analyzing concentrations of cost burden among renter-occupied households in Carmel-by-the-Sea, there is no variation based on location. Between 40-60 percent of renter-households experience cost burden across the City. 55% 52%
23% 24%
22% 23%
0% 0%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Owner Occupied Renter Occupied
Not Computed
50%+ of Income Used for
Housing
30%-50% of Income Used for
Housing
0%-30% of Income Used for
Housing
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-41 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-27 Cost Burden by Home Owners, Carmel-by-the-Sea, 2015-2019 SOURCE: California Department of Housing and Community Development, AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-42 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-28 Cost Burden by Renter Households, Carmel-by-the-Sea, 2015-2019 SOURCE: California Department of Housing and Community Development, AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-43 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 A.4 Special Needs Groups
Special needs groups are those that may face particular challenges in obtaining adequate housing due to inherent circumstances such as age, disabilities, household size, income level, age, and occupation.

Large families, single parent households, female-headed households, or extremely low- and lowincome households, and homeless persons may be classified as Special Needs groups. Special Needs groups are identified due to the unique nature of household characteristics and potential housing challenges faced. Table A-11 provides a summary of special needs groups in Carmel-by-the-Sea.

Table A-11 Overview of Special Needs Groups
Special Needs Groups Count Percent of Total
Households
Percent of Total
Population
Total population 3,830 -- 100%
Total occupied units (households) 1,925 100% --
Extremely Low-income (0-30% of HAMFI)
households 140 households 7% --
Total Senior Population 1,657 persons -- 43%
Senior Owner-Households 763 households 40% --
Senior Renter-Households 283 households 15% --
Persons with Disabilities24 406 persons -- 12%
Persons with Developmental
Disabilities1 <70 persons -- --
Large Households 70 households 4% --
Single-Parent Households 153 households 8% --
Single-Parent, Female Headed
Households with Children (under 18)
below poverty line
0 households -- --
People Living in Poverty 111 persons -- 3%
Farmworkers2 26,929 persons -- --
Migrant Farmworkers 4,972 persons -- --
Seasonal Farmworkers 12,123 persons -- --
Permanent Farmworkers 14,806 persons -- --
Persons Experiencing Homelessness3 1 person -- --
SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019; U.S. Census Bureau CHAS 2015-2019 Data; USDA Statistics Services; California Department of Developmental Services, Consumer Count by California ZIP Code and Residence Type (2021).

NOTE: 1. Data provided by California Department of Developmental Services and taken at the ZIP code level.

2. Agriculture, forestry, fishing and hunting and mining industry. Farmworker data is taken of the population 16 years and older. Data provided by USDA Statistics Services and taken at the County level for 2017; includes permanent and seasonal farmworkers.

3. Total results from 2022 Monterey County Homeless County and Survey Comprehensive Report. 24 This estimate uses U.S. Census Bureau ACS 5-Year Estimates for 2021.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-44 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Extremely Low-Income Households and Poverty Status
Extremely low-income (ELI) households are those that earn less than 30 percent of the median family income (MFI).

Very low-income households are those that earn 50 percent of less of the MFI. Extremely low-income households
typically face a combination of housing challenges related to income status, family size/type, disability status, access to housing opportunities, and other household characteristics.

Additionally, ELI households are more likely to experience overcrowding, cost burden, and substandard housing
conditions. Extremely low-income households are typically minimum-wage workers, disabled persons, farmworkers, and seniors on fixed incomes.

Table A-12 provides a breakdown of extremely low-income households in Carmel-by-the-Sea. The 2015-2019
Comprehensive Housing Affordability Strategy (CHAS) data indicates there were approximately 140 ELI households (7 percent of total households) in Carmel-by-the-Sea. Of the extremely low-income households in Carmel-by-the-Sea, 29 percent are renter-occupied households and 71 percent are owner-occupied households, or 2 percent and 5 percent of all households, respectively.

When analyzing cost burden of ELI households, approximately 120 ELI households experience severe cost burden (paying more than 50 percent of median gross income on housing) and 140 experience moderate cost burden (paying more than 30 percent of median gross income on housing). Of the ELI households experiencing some form of cost burden, the majority are owneroccupied households.

Data for overcrowding by income level is not available for Carmel-by-the-Sea. However, because owner-occupied households represent the majority of ELI households and experience higher rates of cost burden, overcrowding, substandard housing issues it may be assumed that ELI households experience overcrowding.

The projected RHNA for ELI households was based on the assumption that 50 percent of very lowincome households qualify as extremely low-income households. The very low-income housing need is 113 housing units, of which the City estimates 57 housing units will accommodate the extremely low-income housing need.

It seemed really scary when
we first looked at the [RHNA
numbers] and the idea of
trying to squeeze more into
this beautiful place that’s so
unique [but] I really like the
idea of coming at this from a
compassionate and creative
perspective. I really resonate
with that.

November 17, 2023
Housing Ad Hoc
Committee Community
Meeting Attendee
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-45 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-12 Extremely Low-Income Households, Carmel-by-the-Sea, 2015-2019 Households Number Percentage of Total
Households
Total occupied units (households) 1,925 100%
Total Lower-income (0-80% of HAMFI) households 545 28%
Extremely Low-income (0-30% of HAMFI) households 140 7% Extremely Low-income renters 40 2%
Extremely Low-income owners 100 5%
Lower-income households paying more than 50% 270 14%
Extremely Low-income paying more than 50% 120 6%
ELI Renter HH severely cost burdened 20 1%
ELI Owner HH severely cost burdened 100 5%
Lower-income households paying more than 30% 430 22%
Extremely Low-income paying more than 30% 140 7%
ELI Renter HH moderately cost burdened 40 2%
ELI Owner HH moderately cost burdened 100 5%
Lower-income households experiencing 1 of 4 Housing Problems 450 23% Extremely Low-income households experiencing 1 of 4 Housing Problems 140 7% ELI Renter HH experiencing 1 of 4 Housing Problems 40 2% ELI Owner HH experiencing 1 of 4 Housing Problems 100 5% SOURCE: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) 2015-2019.

NOTE: MFI = HUD Median Family Income, this is the median family income calculated by HUD for each jurisdiction, to determine Fair Market Rents (FMRs) and income limits for HUD programs. MFI will not necessarily be the same as other calculations of median incomes (such as Census number), due to a series of adjustments that are made.

The four housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1 person per room, and cost burden greater than 30%. ***Cost burden is the ratio of housing costs to household income. For renters, housing cost is gross rent (contract rent plus utilities). For owners, housing cost is "select monthly owner costs", which includes mortgage payment, utilities, association fees, insurance, and real estate taxes.

In 2019, approximately 111 persons were identified as living below the poverty line.25 Figure A-29 illustrates the percent of the population in Carmel-by-the-Sea living below the poverty line in 2019 by race and ethnicity. Despite being the smallest population in the City (comprising .1 percent of the population), the Black or African American population is estimated to have the highest rate of poverty (50 percent); however, the low sample size makes it difficult to draw conclusions about this population. In contrast, the non-Hispanic White population represents 87 percent of the total population and only 2 percent is living below the poverty line. The Hispanic or Latinx population experiences the second highest rate of poverty with 13 percent living below the poverty line. 25 From U.S. Census Bureau ACS 5-Year Estimate, 2019, Table S1701 Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-46 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-29 Percent Living Below the Poverty Line by Race and Ethnicity, Carmel-by-the-Sea, 2019
SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
NOTE: Race/Ethnicity represents percentage of the total population* To address the needs of ELI households, the City will adopt housing programs to facilitate the construction of affordable and supportive housing for ELI households. Policies that will directly impact ELI households in Carmel-by-the-Sea include:
 Policy 3.1: Incentivize affordable housing development, with an emphasis on affordable housing built to accommodate Extremely Low-Income residents. Encourage the private sector to produce affordable housing;
 Policy 4.1: Support energy and water conservation programs to reduce the consumption of these resources in housing and to reduce housing costs; and  Policy 5.1: Support and enforce fair housing laws. Expand fair housing choice by promoting housing opportunities and removing impediments to fair housing.

All housing policies and programs can be found in full detail in Chapter 2 of the Housing Element.

In Carmel-by-the- Sea, housing costs may pose a challenge to residents that are from Extremely Low-Income households. With a median home value of $2,070,835 (compared to a median home value of $561,490 in Monterey County), ELI residents may find it difficult to achieve homeownership. Additionally, ELI residents normally experience limited accessibility to suitable transportation services to commute from home to work.

Hispanic or
Latinx
Other Race
or Multiple
Races
(Hispanic
and NonHispanic)
White,
NonHispanic
Asian
alone
Native
Hawaiian
and Other
Pacific
Islander
Black or
African
American
(Hispanic
and NonHispanic)
American
Indian or
Alaska
Native
(Hispanic
and NonHispanic)
Below Poverty Line 13.4% 0.0% 2.1% 0.0% 0.0% 50.0% 0.0% Race/Ethnicity* 8.2% 0.0% 86.5% 5.2% 0.0% 0.1% 0.0%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-47 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 In recognition of this issue, the City has identified the following service providers and programs to assist residents that are from an Extremely Low-Income household:
 Fair Housing Education
 Housing Choice Voucher Program
 211 Monterey/United Way
 CHISPA Housing
 Monterey-Salinas Transit
 Independent Transportation Network of Monterey (ITN Monterey)  MST Rides ADA Paratransit Agency
Seniors
Seniors are identified as individuals 65 years and older. Senior households often experience a combination of factors that can make accessing or keeping affordable housing a challenge. They often live on fixed incomes and are more likely to have disabilities, chronic health conditions, and/or reduced mobility. Seniors who rent may be at even greater risk for housing challenges than those who own, due to income differences between these groups.

Figure A-30 illustrates the senior population in Carmel-by-the-Sea, the County, and nearby cities.

Compared to the County and nearby cities, Carmel-by-the-Sea has the highest senior population (43 percent), approximately 30 percent more than the County and 16 percent more than Pacific Grove.

Figure A-30 Senior Population by Jurisdiction, 2019
SOURCE: U.S. Census Bureau, 2019
NOTE: Senior population is defined as persons 65 years and older. 43%
13%
23%
27%
0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
50%
Carmel-by-the-Sea Monterey County Del Rey Oaks Pacific Grove Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-48 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-31 illustrates senior housing by tenure in Carmel-by-the-Sea during 2019. Senior households in Carmel-by-the-Sea are primarily owners (73 percent). Similarly, the senior households of the County (73 percent) and nearby cities of Del Rey Oaks (91 percent) and Pacific Grove (68 percent) are majority owners.

Figure A-31 Senior Housing by Tenure, Carmel-by-the-Sea, 2019 SOURCE: U.S. Census Bureau, 2019
NOTE: Senior population is identified as persons 65 years and older.

Figure A-32 illustrates senior households by their income. 14 percent of Carmel-by-the-Sea’s senior households earn a yearly income of $200,000 or more). However, an estimated 61 percent of senior households earn less than the City’s median household income ($98,188).

Figure A-32 Senior Households by Income, Carmel-by-the-Sea, 2019 SOURCE: U.S. Census Bureau, 2019
NOTE: Senior population is identified as persons 65 years and older. 73% 73%
91%
68%
27% 27%
9%
32%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Carmel-by-the-Sea Monterey County Del Rey Oaks Pacific Grove Renter
Owner
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-49 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 In Carmel-by-the- Sea, housing costs does not necessarily pose a challenge to the City’s elderly residents, as over 70 percent of the City’s Senior population owns a home (see Figure A-30).

However, elderly residents may be more likely experience limited accessibility to suitable transportation services, and limited mobility.

As such, the City has identified the following service providers and programs to assist Seniors:
 The Salvation Army Good Samaritan Center
 Meals on Wheels of the Monterey Peninsula
 Seniors Helping Seniors
 Seaside Recreation Services – Senior Center Programs
 Habitat for Humanity Monterey
 Monterey-Salinas Transit
 Independent Transportation Network of Monterey (ITN Monterey)  MST Rides ADA Paratransit Agency
People with Disabilities
People with disabilities face additional housing challenges. Encompassing a broad group of individuals living with a variety of physical, cognitive and sensory impairments, many people with disabilities live on fixed incomes and are in need of specialized care, yet often rely on family members for assistance due to the high cost of care. When it comes to housing, people with disabilities are not only in need of affordable housing but accessibly designed housing, which offers greater mobility and opportunity for independence. Unfortunately, the need typically outweighs what is available, particularly in a housing market with such high demand. People with disabilities are at a high risk for housing insecurity, homelessness, and institutionalization, particularly when they lose aging caregivers.

Figure A-33 illustrates population by disability status in Carmel-by-the-Sea, the County, and nearby cities in 2021. Twelve (12) percent of the population in Carmel-by-the-Sea has some form of disability, which is on par with nearby cities. The cities of Del Rey Oaks and Pacific Grove each have a population of 13 percent and 12 percent, respectively, with a disability. The County has the lowest percentage of persons with a disability at 9 percent.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-50 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-33 Population by Disability Status by Jurisdiction, 2021 SOURCE: U.S. Census Bureau, 2021
Over the last decade, the population of persons with disabilities has increased in Carmel-by-the-Sea.

Figure A-34 illustrates trends in persons with disabilities in Carmel-by-the-Sea between 2012-2021.

In 2014, the population of persons with disabilities began to steadily increase from 12 percent to its highest point at 22 percent in 2018. In 2019, the upward trend in persons with disabilities began to decline reaching 16 percent, and eventually hitting 12 percent in 2021. Overall, the population of persons with disabilities has increased 3 percent since 2012.

Figure A-34 Trends in Persons with Disabilities, Carmel-by-the-Sea, 2012-2021 SOURCE: U.S. Census Bureau, 2012-2021
88% 91% 87% 88%
12% 9% 13% 12%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Carmel-by-the-Sea Monterey County Del Rey Oaks Pacific Grove With a disability
No disability
91% 93%
88% 86% 84% 83%
78%
84% 85% 88%
9% 7%
12% 14% 16% 17%
22%
16% 15% 12%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
No disability
Disability
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-51 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-13 provides an overview of disability by type and age in Carmel-by-the-Sea during 2021.

Hearing difficulty is the most widespread disability in Carmel-by-the-Sea (41 percent) with the highest concentration in persons 65 years of age and older. Self-care difficulty is the least common disability with 7 percent experiencing this in Carmel-by-the-Sea. Overall, seniors (persons aged 65+) makeup the largest demographic with a disability (50 percent).

Table A-13 Disability Status by Age, Carmel-by-the-Sea, 2021 Disability Type Under 18 18-64 65 and Over Total
Percent of
Population with
a Disability
Hearing Difficulty 20 0 305 325 41%
Vision Difficulty 20 0 50 70 9%
Cognitive Difficulty 0 29 46 75 9%
Ambulatory Difficulty 0 0 142 142 18%
Self-care Difficulty 0 0 56 56 7%
Independent Living Difficulty 0 0 130 130 16%
Total 40 29 729 798 100%
SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2021
NOTE: These disabilities are counted separately and are not mutually exclusive, as an individual may report more than one disability. These counts should not be summed.

State law also requires Housing Elements to examine the housing needs of people with developmental disabilities. Developmental disabilities are defined as severe, chronic, and attributed to a mental or physical impairment that begins before a person turns 18 years old. This can include Down’s Syndrome, autism, epilepsy, cerebral palsy, and mild to severe mental retardation. Some people with developmental disabilities are unable to work, rely on Supplemental Security Income, and live with family members. In addition to their specific housing needs, they are at increased risk of housing insecurity after an aging parent or family member is no longer able to care for them.

Table A-14 shows the population with developmental disabilities by age in Carmel-by-the-Sea. In Carmel-by-the-Sea, of the 798 persons with a disability, approximately less than 70 have a developmental disability. Of these, less than 31 are children/young adults (i.e., under the age of 18) and less than 36 are adults.

Table A-15 shows the population with developmental disabilities by residence in Carmel-by-the-Sea.

The most common living arrangement for individuals with developmental disabilities in Carmel-bythe-Sea is the home of parent/family/guardian.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-52 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-14 Population with Developmental Disabilities by Age, Carmel-by-the-Sea, 2021 Age Group Number
Age Under 18 <31
Age 18+ <36
SOURCE: California Department of Developmental Services, Consumer Count by California ZIP Code and Age Group (2021).

NOTE: Universe: Population with developmental disabilities. Notes: The California Department of Developmental Services is responsible for overseeing the coordination and delivery of services to more than 330,000 Californians with developmental disabilities including cerebral palsy, intellectual disability, Down syndrome, autism, epilepsy, and related conditions. The California Department of Developmental Services provides ZIP code level counts. To get jurisdiction-level estimates, ZIP code counts were crosswalked to jurisdictions using census block population counts from Census 2010 SF1 to determine the share of a ZIP code to assign to a given jurisdiction.

Table A-15 Population with Developmental Disabilities by Residence, Carmel-by-the-Sea, 2021
Residence Type Number
Home of Parent/Family/Guardian <38
Foster/Family Home 0
Independent/Supported Living <11
Other 0
Community Care Facility <11
Intermediate Care Facility 0
SOURCE: California Department of Developmental Services, Consumer Count by California ZIP Code and Residence Type (2021).

In Carmel-by-the- Sea, the majority of the residents that have disabilities are also age 65 and over.

Housing and transportation costs may pose a challenge to residents with disabilities. As such, the City has identified the following service providers and programs to assist residents that are living with disabilities:
 Monterey County Aging and Adult Services
 Paradigm Adult Services
 Special Kids Connect
 Monterey-Salinas Transit
 Independent Transportation Network of Monterey (ITN Monterey)  MST Rides ADA Paratransit Agency
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-53 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Large Households
Large households are defined as households of five or more individuals. Large households often have different housing needs than smaller households. Household income and local housing markets can greatly impact a household’s ability to afford adequately sized housing. If a city’s rental housing stock does not include larger apartments, large households who rent could end up living in overcrowded conditions. Similarly, large households may experience overpayment as a result of a high housing market and limited availability.

Figure A-35 illustrates 2019 households by size and tenure in Carmel-by-the-Sea. The City has 70 large households, of which 57 percent are renter-occupied households. Owner-occupied households makeup the majority of 1-person and 2-person households, whereas renter-occupied households makeup the majority of all 3-5 person households. This combined with a total cost burden rate of 46 percent for renter households (Figure A-25), suggests it is likely that large households in Carmel-bythe-Sea may experience overcrowding and/or overpayment.

Figure A-35 Households by Size and Tenure, Carmel-by-the-Sea, 2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
In Carmel-by-the- Sea, housing costs may pose a challenge to large households, as they are more likely to rent as opposed to purchasing a home, and experience higher cost-burden and overcrowding. With a median home value of $2,070,835 (compared to a median home value of $561,490 in Monterey County), large households may find it difficult to achieve homeownership.

Furthermore, finding suitable transportation may be a challenge, as well.

The City has identified the following service providers and programs to assist large households:
 Housing Choice Voucher Program
 Fair Housing Education
 Monterey County Down-payment Assistance Program
59% 63%
43%
28%
41% 43%
37%
57%
72%
57%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
1 Person
Household
2 Person
Household
3 Person
Household
4 Person
Household
5 Or More
Person
Household
Owner Occupied
Renter Occupied
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-54 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024  Monterey-Salinas Transit
 Independent Transportation Network of Monterey (ITN Monterey)  Monterey Dial-A-Ride Program
 Ridesharing services
Single-Parent Households
Households headed by one person are often at greater risk of housing insecurity, particularly femaleheaded households, who may be supporting children or a family with only one income.

In Carmel-by-the-Sea, the largest proportion of households are married-couple family households at 47 percent, while female-headed households make up 6 percent, and male-headed households make up 2 percent of all households (Figure A-12). Figure A-36 shows single-parent households in Carmel-by-the-Sea, the County, and nearby cities. Compared to the County and nearby cities, Carmel-by-the-Sea’s ratio of single-parent households is on par. Carmel-by-the-Sea’s single-parent households are predominantly female-headed family households (75 percent). Male-headed family households makeup 25 percent.

Figure A-36 Single-Parent Households by Jurisdiction, 2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Over the last decade, male-headed family households have slightly increased in Carmel-by-the-Sea, while female-headed family households have decreased. Figure A-37 illustrates trends in singleparent households in Carmel-by-the-Sea between 2010-2019.26 26 The data reports female- and male-headed family household as a percentage of total households in Carmel-by-the-Sea. 79% 75% 79% 73%
21% 25% 21% 27%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Monterey County Carmel-by-the-Sea Del Rey Oaks Pacific Grove Male-headed Family Households
Female-Headed Family Households
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-55 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-37 Trends in Single-Parent Households, Carmel-by-the-Sea, 2010-2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2010-2019 NOTE: This table reports female- and male-headed family households as a percentage of total households in Carmel-by-the-Sea.

During this period, male-headed households increased from zero percent in 2010 up to 2 percent by 2015. From 2016-2018, the male-headed family households remained at 1 percent until increasing to 2 percent by 2019. Comparatively, female-headed family households decreased a total of 3 percent between 2010-2019. From 2010-2013, female-headed family households steadily increased reaching its highest point at 13 percent in 2013. By 2014, the group experienced a 2 percent decrease and remained constant until 2018 when it began to decline, reaching 6 percent in 2019.

Female-headed households with children may face particular housing challenges, with pervasive gender inequality resulting in lower wages for women. Moreover, the added need for childcare can make finding a home that is affordable more challenging. In 2019, there were no single-parent households that fell in the Below Poverty Level category in Carmel-by-the-Sea.

In an effort to relieve some of the housing and transportation issues that single-parent households may face, the City has identified the following service providers and programs to assist single-parent households:
 Housing Choice Voucher Program
 Fair Housing Education
 Monterey County Down-payment Assistance Program
 Monterey-Salinas Transit
 Independent Transportation Network of Monterey (ITN Monterey)  Ridesharing services
9%
10%
12%
13%
11% 11% 11% 11%
7%
6%
0%
1% 1% 1% 1%
2%
1% 1% 1%
2%
0%
2%
4%
6%
8%
10%
12%
14%
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Female-Headed Family Households
Male-headed Family Households
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-56 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Farmworkers
Across the state, housing for farmworkers has been recognized as an important and unique concern.

Farmworkers generally receive wages that are considerably lower than other jobs and may have temporary housing needs. Finding decent and affordable housing can be challenging, particularly in the current housing market.

According to the U.S. Department of Agriculture Census of Farmworkers, the number of permanent farm workers in Monterey County has decreased since 2002, totaling 14,806 in 2017, and the number of seasonal farm workers has also decreased, totaling 12,123 in 2017. Figure A-38 shows hired farm labor in Monterey County between 2002-2017.

Figure A-38 Hired Farm Labor, Monterey County, 2002-2017 SOURCE: U.S. Department of Agriculture, Census of Farmworkers (2002, 2007, 2012, 2017), Table 7: Hired Farm Labor.

NOTES: Universe: Hired farm workers (including direct hires and agricultural service workers who are often hired through labor contractors). Farm workers are considered seasonal if they work on a farm less than 150 days in a year, while farm workers who work on a farm more than 150 days are considered to be permanent workers for that farm.

There are no agriculture uses within the City of Carmel-by-the-Sea. However, Carmel-by-the-Sea shares the responsibility for farmworker housing as farmworkers may work within 75 miles of agricultural land uses (including dairy, vineyards, and produce) and the City is within 75 miles of these uses.

Agriculture consisting of crop farming and livestock grazing is the largest industry in Monterey County and contributes a significant amount of money to the County’s economy. Out of approximately 1.3 million acres of County land dedicated to agriculture, most of this area (approximately 80%) is used for grazing. The most productive and lucrative farmlands in the County are located in the North County, Greater Salinas, and Central Salinas Valley Planning Areas. 17,538
13,564
12,306
13,875
16,159 16,713
14,806
12,123
0 2,000
4,000
6,000
8,000
10,000
12,000
14,000
16,000
18,000
20,000
Permanent Seasonal
Farm Workers
2002
2007
2012
2017
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-57 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 The County, in compliance with State legislation and the Employee Housing Act, acknowledges the division of available farmland for the creation of farmworker or employee/family housing27. In compliance with State requirements, the City of Carmel-by-the-Sea has included a new program to amend the Municipal Code’s to include a definition for employee housing, and the zone in which employee housing would be allowed (Program 1.3.F, see Chapter 2).

Although the City of Carmel-by-the-Sea does not have any agricultural employees and is therefore unable to determine housing and transportation costs for agricultural employees in Carmel-by-theSea, the City has identified the following regional service providers and programs to assist farmworker households with the greater Monterey County region:
 Spanish Farmworkers Resource Line;
 The Center for Community Advocacy;
 Farm and Food Worker Relief Program;
 Monterey-Salinas Transit;
 Independent Transportation Network of Monterey (ITN Monterey);  MST Rides ADA Paratransit Agency; and
 Rideshare services.

Persons Experiencing Homelessness
Homelessness remains an urgent challenge in many communities across the state, reflecting a range of social, economic, and psychological factors. Rising housing costs result in increased risks of community members experiencing homelessness. Addressing the specific housing needs for the unhoused population remains a priority throughout the region, particularly since homelessness is disproportionately experienced by people of color, people with disabilities, those struggling with addiction and those dealing with traumatic life circumstances.

Table A-16 show changes in the homeless population between 2017-2022 in Carmel-by-the-Sea, the County and neighboring jurisdictions. According to the 2022 Monterey Homeless Count and Survey Comprehensive Report, Carmel-by-the-Sea has seen a decrease in homeless persons since 2017, totaling one person in 2022. Similarly, the Monterey Bay Area overall has seen a decrease in homeless populations with the exception of Seaside.
27 https://www.co.monterey.ca.us/home/showpublisheddocument/45812/636389938528430000 Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-58 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-16 Homeless Population by Jurisdiction, 2017-2022 Jurisdiction
Unsheltered Sheltered Total
2019-2022 % Change 2017 2019 2022 2017 2019 2022 2017 2019 2022 Monterey (City) 292 167 74 46 37 27 338 204 101 -50%
Carmel-by-the-Sea 16 6 1 0 0 0 16 6 1 *
Del Rey Oaks 111 0 2 0 0 0 111 0 2 *
Seaside 40 126 90 58 56 62 98 182 152 -16%
Pacific Grove 35 14 29 0 0 0 35 14 29 *
Total 509 315 198 104 93 89 613 408 287 -66%
SOURCE: 2022 Monterey Homeless Count and Survey Comprehensive Report NOTE: % change was not calculated when jurisdiction was below 25 individuals.

Table A-17, shows household type and shelter status in Monterey County in 2019. In Monterey County, the most common type of household experiencing homelessness are those without children in their care. Among households experiencing homelessness that do not have children, 83 percent are unsheltered. Similarly, the majority of homeless households with children are unsheltered (45 percent).

Table A-17 Homelessness by Household Type and Shelter Status, Monterey County, 2019 Jurisdiction
People in
Households
Composed Solely of
Children Under 18
People in Households
with Adults and Children
People in Households
without Children Under
18 Total
Count Percent Count Percent Count Percent
Sheltered –
Emergency Shelter 0 0% 146 22% 218 11% 364
Sheltered –
Transitional
Housing
0 0% 218 33% 124 6% 342
Unsheltered 10 100% 303 45% 1,685 83% 2,340
Total 10 100% 667 100% 2,027 100% 2,704
SOURCE: U.S. Department of Housing and Urban Development (HUD), Continuum of Care (CoC) Homeless Populations and Subpopulations Reports (2019).

For the data table behind this figure, please refer to the Data Packet Workbook, Table HOMELS-01.

NOTES: Universe: Population experiencing homelessness. This data is based on Point-in-Time (PIT) information provided to HUD by CoCs in the application for CoC Homeless Assistance Programs. The PIT Count provides a count of sheltered and unsheltered homeless persons on a single night during the last ten days in January. Each Bay Area County is its own CoC, and so the data for this table is provided at the county-level. Per HCD’s requirements, jurisdictions will need to supplement this county-level data with local estimates of people experiencing homelessness.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-59 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Housing and transportation costs can be barriers to residents that are experiencing homelessness.

With a median home value of $2,070,835 (compared to a median home value of $561,490 in Monterey County), those experiencing homelessness would need wrap-around support, access to community services, and State/Federal assistance to end the cycle of homelessness. Many individuals thar are homeless may experience difficulties with: finding emergency shelter, having access to food and job-training resources. Lack of adequate transportation to commute to job interviews and appointments with social service providers may also be an obstacle to individuals experiencing homelessness. In an effort to break these barriers, the City has identified the following service providers and programs to assist residents experiencing homelessness:
 Community Human Services;
 Habitat for Humanity Monterey;
 Peacock Acres;
 Interfaith Outreach of Monterey;
 Monterey-Salinas Transit;
 Independent Transportation Network of Monterey (ITN Monterey);  MST Rides ADA Paratransit Agency; and
 Rideshare Services.

A.5 Access to Opportunity
This section discusses disparities in access to opportunity among protected classes including access to quality education, employment, transportation, and environment. The California Tax Credit Allocation Committee (TCAC) in collaboration with HCD developed a series of opportunity maps that help to identify areas of the community with good or poor access to opportunity for residents.

These maps were developed to align funding allocations with the goal of improving outcomes for low-income residents—particularly children.

Access to Opportunity
“Access to opportunity is a concept to approximate place-based characteristics linked to critical life outcomes. Access to opportunity oftentimes means both improving the quality of life for residents of low-income communities, as well as supporting mobility and access to ‘high resource’ neighborhoods. This encompasses education, employment, economic development, safe and decent housing, low rates of violent crime, transportation, and other opportunities, including recreation, food and healthy environment (air, water, safe neighborhood, safety from environmental hazards, social services, and cultural institutions).” SOURCE: California Department of Housing and Community Development Guidance, 2021, page 34.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-60 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 The opportunity maps highlight areas of highest resource, high resource, moderate resource, moderate resource (rapidly changing), low resource, and high segregation and poverty. TCAC provides opportunity maps for access to opportunity in quality education, employment, transportation, and environment. Opportunity scores are presented on a scale from zero to one and the higher the number, the more positive the outcomes.

Disparities in Access to Opportunity
As can be seen in Figure A-39, TCAC Opportunity Composite Score, Carmel-by-the-Sea is considered a highest resource area as is much of western Monterey County. According to the HCD AFFH Data Viewer TCAC Opportunity Map, there are no areas of variation in access to opportunity across the City.

Economic
TCAC’s economic opportunity score is comprised of poverty, adult educational attainment, employment, job proximity, and median home value. Figure A-40 shows concentrations of economic outcomes in Carmel-by-the-Sea. According the HCD AFFH Data Viewer TCAC Economic Opportunity Map, all areas of Carmel-by-the-Sea have a high economic opportunity score of 0.75-1.0. This reflects a high level of opportunity for economic advancement for residents in Carmel-by-the-Sea.

Education
TCAC’s education score is based on math proficiency, reading proficiency, high school graduation rates, and the student poverty rate. Opportunity scores are presented on a scale from zero to one and the higher the number, the more positive the outcomes.

Figure A-41 shows the level of TCAC educational opportunity across Carmel-by-the-Sea. According to TCAC’s Educational Opportunity Map, Carmel-by-the-Sea scores between 0.75-1.0 indicating a high level of positive educational outcomes for residents in Carmel-by-the-Sea.

Carmel-by-the-Sea is served by the Carmel Unified School District (CUSD), along with elementary, middle, and high schools within the City and school district. As of 2022, the State of California School Dashboard highlights a 97.9 percent graduation rate among all students enrolled in Carmel High School, which is higher than the statewide average (87.4 percent) and County average (88.5 percent).

When broken down by race/ethnicity, Hispanic and White students graduated at a high rate (97.4 percent for both groups). There is no performance data available for the graduation rates of African American, Asian, Filipino, and American Indian students at Carmel High.

Additionally, there is no performance data available for the graduation rates of students with a disability within Carmel High.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-61 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-39 TCAC Opportunity Composite Score, Carmel-by-the-Sea, 2022 SOURCE: California Department of Housing and Community Development AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-62 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-40 TCAC Opportunity Economic Score, Carmel-by-the-Sea, 2022 SOURCE: California Department of Housing and Community Development AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-63 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-41 TCAC Opportunity Education Score, Carmel-by-the-Sea, 2022 SOURCE: California Department of Housing and Community Development AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-64 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Environment
TCAC’s opportunity areas environmental scores are based on the CalEnviroScreen 4.0 indicators, which identify areas disproportionately vulnerable to pollution sources such as ozone, PM2.5, diesel PM, pesticides, toxic release, traffic, cleanup sites, groundwater threats, hazardous waste, impaired water bodies, and solid waste sites.

Figure A-42 shows TCAC environmental outcomes across Carmel-by-the-Sea. According to the HCD AFFH Data Viewer TCAC Environmental Opportunity Map, Carmel-by-the-Sea scores between 0.75-1.0 indicating a low level of environmental pollution burden and positive outcomes for residents in Carmel-by-the-Sea.

The Social Vulnerability Index (SVI) provided by the Center for Disease Control (CDC)ranks census tracts based on their ability to respond to a disaster and includes four themes of socioeconomic status, household composition, race or ethnicity, and housing and transportation.

Figure A-43 shows SVI levels across Carmel-by-the-Sea. Carmel-by-the-Sea scores low on the SVI (less than 0.25) indicating that the City is slightly vulnerable to disasters, but highly equipped to respond to them. Just outside of the City’s borders however, vulnerability levels increase to 0.25-0.5.

This is likely due to a difference in jurisdictional resources.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-65 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-42 TCAC Opportunity Environmental Score, Carmel-by-the-Sea, 2022 SOURCE: California Department of Housing and Community Development AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-66 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-43 Social Vulnerability Index, Carmel-by-the-Sea, 2018 SOURCE: California Department of Housing and Community Development AFFH Data Viewer Disparities Specific to the Population Living with a Disability In Carmel-by-the-Sea, 12.3 percent of the population is living with at least one disability, compared to 8.8 percent in Monterey County. The most common disabilities in the City are: hearing difficulty (9.9 percent), ambulatory difficulty (4.4 percent), and independent living difficulty (4.3 percent). For Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-67 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 the population 65 and over, the share of the population with hearing difficulties increases to 19.3 percent. In an effort to improve accessibility features for residents living with disabilities, the City will allocate funding from its Capital Improvement Program (CIP) to improve curb cuts, sidewalks, and slopes within Carmel-by-the-Sea.

Disparities in Access to Transportation
In the City of Carmel-by-the-Sea, public transportation is serviced by Monterey-Salinas Transit (MST). From a regional standpoint, MST services approximately 2.2 million passengers on an annual basis of which 76 percent of the passengers come from a historically underrepresented (non-White) background with an annual household income under $40,000.28 Monterey-Salinas Transit also reports that 25 percent of all trips begin in a disadvantaged community, and 20 percent of the passengers serviced by MST have a disability and are dependent on others for mobility and transport.

Compared to all other jurisdictions serviced by MST, Carmel-by-the-Sea has the 6th highest monthly ridership (Monterey-Salinas Transit, 2023). In an effort to lower the disparities in access to transit, the City has collaborated with MST to ensure that 100% of the City’s residents live within a ½ mile of transit stops. Additionally, the City coordinates with the County of Monterey to provide transportation to elderly residents (through the Senior Rideshare Program), and individuals with disabilities through the Independent Transportation Network of Monterey (ITN Monterey) and the MST Rides ADA Paratransit Agency.

Housing Mobility Enhancement
Being that the City of Carmel-by-the-Sea is the highest resource community when compared to the rest of the region, the City will promote housing mobility as a means of removing barriers to higher opportunity areas and strategically enhancing access to housing choices and affordability to provide more inclusivity in the City and region. To enhance housing mobility, the City has included the following programs in Chapter 2 of the Housing Element:
 1.1.D: Allow Religious Institution Affiliated Housing Development (site 5 has been designated for this use in the Sites Inventory);
 1.3.C: Accessory Dwelling Units;
 1.3.D: Overnight Visitor Accommodation - Employee Housing Program;  2.1.B: Permanent Housing;
 3.1.B: Housing for Extremely-Low Income Households;
28 https://carmel.novusagenda.com/agendapublic/CoverSheet.aspx?ItemID=5838&MeetingID=1350 Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-68 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024  5.1.A: Fair Housing Services; and
 5.1.B: Housing Choice Voucher Program.

For a complete list of programs. Refer to Chapter 2 of the Housing Element.

A.6 Housing Stock Characteristics
Carmel-by-the-Sea’s housing stock is defined as all housing units within its jurisdiction.

Characteristics of housing stock include housing type, age, condition, tenure, vacancy rates, costs, affordability, and growth. The following section provides an in-depth analysis of the housing stock in Carmel-by-the-Sea to determine how/if the current the housing stock meets the needs of existing and future residents.

Housing Growth
Table A-18 provides an overview of housing growth trends between 2010-2019 in Carmel-by-theSea, the County, and nearby cities. Between 2010-2019, Carmel-by-the-Sea housing unit estimates grew approximately 6 percent, more than the County and Del Rey Oaks, but 2 percent less than Pacific Grove. These estimates show the majority of housing growth in Carmel-by-the-Sea occurred between 2015-2019 (8 percent).

Table A-18 Housing Unit Growth Trends by Jurisdiction, 2010-2019 Jurisdiction 2010 2015 2019 Percent Change
2010-2015
Percent Change
2015-2019
Monterey County 138,833 139,794 141,820 1% 1%
Carmel-by-the-Sea 3,606 3,532 3,832 -2% 8%
Del Rey Oaks 752 733 745 -3% 2%
Pacific Grove 7,723 8,411 8,347 9% -1%
SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2010-2019 Housing Type
Table A-19 provides a comparison of housing unit types in Carmel-by-the-Sea, the County, and nearby cities. In Carmel-by-the-Sea, single-family detached units are the most common housing type (87 percent). This aligns with the County (63 percent), Del Rey Oaks (76 percent), and Pacific Grove (60 percent) having majority single-family detached units. Overall, Carmel-by-the-Sea has the highest percentage of single-family detached units compared to the County and nearby cities, but the lowest percentage of multifamily housing units (10 percent).

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-69 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-19 Housing Units by Type by Jurisdiction, 2019
Jurisdiction
SingleFamily
Detached
SingleFamily
Attached
Multifamily Mobile
Homes Total Units
Count Percent Count Percent Count Percent Count Percent Monterey County 88,721 63% 8,796 6% 37,734 27% 6,529 5% 141,820 Carmel-by-the-Sea 3,319 87% 54 1% 367 10% 92 2% 3,832
Del Rey Oaks 567 76% 49 7% 118 16% 11 2% 745
Pacific Grove 5,023 60% 497 6% 2,668 32% 159 2% 8,347
SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
NOTE: Table indicates total housing units.

Figure A-44 illustrates housing type trends in Carmel-by-the-Sea between 2010-2019. In 2010, the majority of housing types were single-family detached homes (82 percent); this has since increased to 87 percent in 2019. Multifamily housing (2+ units) has decreased by 3 percent since 2010 accounting for only 10 percent of housing types in 2019. In 2010, mobile homes comprised the smallest percentage of housing type in Carmel-by-the-Sea, and have since slightly increased to 2 percent in 2019.

Figure A-44 Housing by Type in Carmel-by-the-Sea, 2010-2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2010-2019 Housing Availability and Tenure
Housing tenure refers to individuals who own or rent a housing unit. The number of residents who own their homes compared to those who rent their homes can help identify the level of housing insecurity (i.e., ability for individuals to stay in their homes) in a city and region. Generally, renters Single-Family
Home:

Attached
Single-Family
Home:

Detached
Multifamily
Housing: Two
to Four Units
Multifamily
Housing: Fiveplus UnitsMobile Homes
2010 5% 82% 6% 7% 0%
2015 2% 87% 3% 7% 2%
2019 1% 87% 3% 7% 2%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-70 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 may be displaced more quickly if prices increase. Additionally, housing tenure may be an indicator of housing affordability (i.e., if the local housing market has high barriers to entry, there may be more renter households than owner households).

In Carmel-by-the-Sea, the housing stock includes 828 renter-occupied housing units and 1,099 owner-occupied housing units (Table A-20). When analyzing housing unit type in tandem with tenure, the majority of all housing units are single-family detached (87 percent), of which 17 percent are renter-occupied and 32 percent are owner-occupied (Figure A-18; Table A-20).

Table A-20 Housing Units by Type and Tenure, Carmel-by-the-Sea, 2019 Tenure
SingleFamily
Detached
SingleFamily
Attached
Multifamily Mobile
Homes Total Units
Count Percent Count Percent Count Percent Count Percent Renter-Occupied 568 69% 19 2% 221 27% 20 2% 828
Owner-Occupied 1,076 98% 0 0% 23 2% 0 0% 1,099
SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
NOTE: Table indicates total occupied housing units.

Table A-21 provides an overview of household size by tenure for Carmel-by-the-Sea, the County, and nearby cities. In Carmel-by-the-Sea, the average household size is 2.04, of which the majority of larger households are comprised of renter-occupied units (2.13 persons/unit). An average household size of 2.04 suggests a need for more small housing units. This aligns with 82 percent of Carmel-bythe-Sea’s population being comprised of 1-2 person households (Figure A-14). Compared to the County and nearby cities, Carmel-by-the-Sea has the lowest average household size (2.04 persons/unit). The County has a high average household size of 3.27 suggesting a need for large housing units and even a need for smaller independent units such as ADUs/JADUs for extended family, etc.

Table A-21 Household Size by Tenure by Jurisdiction, 2019 Jurisdiction OwnerOccupied
RenterOccupied
Average
Household
Size
Monterey County 3.13 3.41 3.27
Carmel-by-the-Sea 1.97 2.13 2.04
Del Rey Oaks 2.29 2.49 2.35
Pacific Grove 2.34 2.15 2.23
SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-71 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-45 illustrates 2019 household tenure by race in Carmel-by-the-Sea. Tenure by race varies some in Carmel-by-the-Sea as the majority of all households are non-Hispanic White (87 percent), of which 58 percent are owner-households and 42 percent are renter-households (Figure A-4; Figure A-44). Hispanic or Latino households (8 percent) makeup the second largest population in Carmelby-the-Sea, of which 72 percent are owner-households and 28 percent are renter-households. Less than 1 percent of Black or African American, Native Hawaiian or Other Pacific Islander, and American Indian or Alaska Native households are represented in the City’s housing market.

Figure A-45 Household Tenure by Race, Carmel-by-the-Sea, 2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Figure A-46 illustrates vacancy rates in Carmel-by-the-Sea, the County, and nearby cities. Carmel-bythe-Sea has a vacancy rate of 50 percent. This reflects a 40 percent higher vacancy rate than the County (10 percent) and 32 percent higher than Pacific Grove (18 percent).

American
Indian or
Alaska
Native
(Hispanic
and NonHispanic)
Asian
alone
Native
Hawaian
and Other
Pacific
Islander
Black or
African
American
(Hispanic
and NonHispanic)
Hispanic or
Latinx
Some
Other
Race/Multi
ple Races
White
(Hispanic
and NonHispanic)
White,
NonHispanic
Renter Occupied 0% 51% 0% 0% 28% 100% 42% 42%
Owner Occupied 0% 49% 0% 0% 72% 0% 58% 58%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-72 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-46 Vacancy Rates by Jurisdiction, 2019
SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Figure A-47 illustrates vacancy trends in Carmel-by-the-Sea from 2010-2019. Over the course of nearly a decade, the City has experienced a stable vacancy average of 51 percent. This is staggeringly high considering the current housing crisis. Additionally, this affects the accuracy of data reporting for the City, as the majority of homeowners do not live in Carmel-by-the-Sea full time, thus resulting in skewed data collection.

Figure A-47 Vacancy Trends, Carmel-by-the-Sea, 2010-2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Table A-22 shows vacant housing units by type, revealing 80 percent of Carmel-by-the-Sea’s vacant units are for seasonal, recreational, or occasional use, aligning with the 51 percent average vacancy trends (Figure A-46). The high percentage of vacant housing units is largely impacted by tourism 50%
10% 13%
18%
0%
10%
20%
30%
40%
50%
60%
Carmel-by-the-Sea Monterey County Del Rey Oaks Pacific Grove 46% 47% 51% 52% 51% 52% 53% 52% 52% 50%
54% 53% 49% 48% 49% 48% 47% 48% 48% 50%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2010 2011 2012 2013 2014 2015 2016 2017 2018 2019
Occupied
Vacant
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-73 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 and second-home ownership. This creates a significant barrier for current and potential residents to enter the local housing market and hinders opportunities to correct the housing crisis, address diversity, and provide inclusive housing options to promote a vibrant and active community.

Table A-22 Vacant Housing Units by Type, Carmel-by-the-Sea, 2019 Housing Unit Type Estimate Percentage
For rent 96 5%
Rented, not occupied 12 1%
For sale only 11 1%
Sold, not occupied 49 3%
For seasonal, recreational, or occasional
use
1,522 80%
For migrant workers 0 0%
Other vacant 215 11%
Total 1,905 100%
SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
Table A-23 shows housing permits issued by the City of Carmel-by-the-Sea by income group.

Between 2015 and 2021, 18 housing units were issued permits in Carmel-by-the-Sea which represents 58 percent of the RHNA number of 31 units assigned in the 5th Cycle Housing Element.

Table A-23 Housing Permits by Income Group, Carmel-by-the-Sea, 2015-2021 Income Group Number Percent
Very Low-Income Permits 0 0.0%
Low-Income Permits 0 0.0%
Moderate-Income Permits 0 0.0%
Above Moderate-Income Permits 18 58.0%
Total 18 58.0%
SOURCE: California Department of Housing and Community Development (HCD), 5th Cycle Annual Progress Report Permit Summary (2022).

NOTE: Universe: Housing permits issued between 2015 and 2021. Notes: HCD uses the following definitions for the four income categories: Very Low Income: units affordable to households making less than 50 percent of the Area Median Income for the county in which the jurisdiction is located. Low Income:
units affordable to households making between 50 percent and 80 percent of the Area Median Income for the county in which the jurisdiction is located. Moderate Income: units affordable to households making between 80 percent and 120 percent of the Area Median Income for the county in which the jurisdiction is located.

Above Moderate Income: units affordable to households making above 120 percent of the Area Median Income for the county in which the jurisdiction is located.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-74 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Assisted Housing Developments At-Risk of Conversion
While there is an immense need to produce new affordable housing units, ensuring that the existing affordable housing stock remains affordable is equally important. Additionally, it is typically faster and less expensive to preserve currently affordable units that are at risk of converting to market-rate than it is to build new affordable housing.

The California Housing Partnership Preservation Database is the state’s most comprehensive source of information on subsidized affordable housing at risk of losing its affordable status and converting to market-rate housing.29 According to the database, there are no federal or state assisted units in Carmel-by-the-Sea.

A variety of affordable housing projects provided through an assortment of local programs serves the Carmel-by-the-Sea. Each of the following projects serves as an example of the methods and incentives used by the City to achieve production of affordable housing units.

Oliver White Building and Viejo Carmel
The mixed-use Oliver White building contains four residential units, one of which is a ModerateIncome unit in perpetuity. Originally this site was developed with a single-story commercial building.

The owner and City worked together to achieve a second story of residential apartments at a density of 44 units per acre.

The Viejo Carmel project is a larger example of infill development that provides affordable housing.

The 20,000 square-foot site was occupied by semi-industrial uses and offices. The site was razed and redeveloped with ten condominiums and ten apartments at a density of 44 units per acre. Without density bonuses, the site could only achieve 15 residential units. With density bonuses, an additional two Low-Income rental apartments in perpetuity were approved. Additionally, the parking requirement for the low-income units was reduced.

Norton Court Apartments
The Norton Court Apartments for seniors is operated by the Carmel Foundation. As part of this 24- unit project, the City entered into a 50-year agreement to lease the property for one dollar per year to the Carmel Foundation. This amounts to a substantial land subsidy provided by the City that offsets a large part of the cost of developing housing. The units are restricted as Low- and Moderate-Income. Rents are maintained as affordable to lower-income seniors strictly through private donations raised by the Carmel Foundation.
29 This database does not include all deed-restricted affordable units in the state, so there may be at-risk assisted units in a jurisdiction that are not captured.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-75 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Trevvett and Haseltine Courts
Trevvett and Haseltine Courts were developed with funding from the Carmel Foundation. Rents for the combined 26 rental apartments are maintained as affordable to lower-income seniors with private donations raised by the Foundation.

San Carlos Lodge
This site was granted a major addition and allowed the conversion of some existing apartments to transient overnight visitor accommodation units. As a condition, the project retained two of the existing apartments as affordable housing for Moderate-Income households in perpetuity.

The City’s inventory of affordable units is listed below in Table A-24.

Table A-24 Inventory of Assisted Rental Housing
Development Name Total Units Household Type Provided By Expiration of Affordability
Oliver White 1 Moderate Density Bonus In perpetuity
Viejo Carmel 2 Low Density Bonus In perpetuity
Norton Court 24 Senior Low Lease Subsidy
Specific Plan Not defined
San Carlos Lodge 2 Moderate Condition of Approval In perpetuity Trevvett Court 14 Senior, Very-Low &
Low
Private non-profit
Specific Plan 30 years
Haseltine Court 12 Senior Private non-profit Not applicable Hasegawa 1 Low Inclusionary In perpetuity
Carl 1 Senior Inclusionary 2027
Mandurrago 2 Senior Inclusionary In perpetuity
Gonzales 1 Low Inclusionary In perpetuity
Ravel Corporation 1 Low Inclusionary In perpetuity
Trini Iye 1 Moderate Inclusionary In perpetuity
Total 62
SOURCE: City of Carmel-by-the-Sea Community Planning and Building Department, 2023 Potential Loss of Assisted Housing Units
Housing units developed with public subsidies are an important source of affordable housing to lower-income households. Preserving the long-term affordability of such housing units is the most cost-effective means for providing decent and affordable housing in a community. Recognizing this important resource, State Housing Element law requires that a jurisdiction examine the potential loss Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-76 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 of publicly subsidized multi-family rental housing for lower-income household due to expiration of deed restrictions, affordability covenants, and /or subsidy contracts. All of the affordable housing units in Carmel are privately funded.

Norton Court, Trevvett Court, and Haseltine Court are operated by the Carmel Foundation, a 501(c)(3) charitable organization providing affordable senior housing units. The Foundation does not accept government funding. The Foundation currently has a 5-7 year wait list on these properties and does not intend to convert any units to market rate housing within this Housing Element cycle.

Norton Court receives a subsidized property lease from the City, and is located within a Specific Plan area that requires “24 efficient and moderately priced housing units for the elderly and handicapped residents of Carmel-By-The-Sea”. Further, the Specific Plan requires 21 studio units at 500 square feet each and 3 one-bedroom units at 572 square feet each.

Trevvett Court is also located within a Specific Plan area that requires “all 14 units be reserved for senior citizens of low or very low-income status for a period of at least 30 years.” Housing units within Trevvett Court range from 400- 600 square feet in size.

Units in the Oliver White Building, Viejo Carmel, and Sand Carlos Lodge are restricted as affordable housing in perpetuity.

One unit in the Carl development is listed with an expiration date of 2027. City staff are further researching the terms of this affordable unit. To maintain the existing affordable housing stock, the City can either preserve the existing affordable units or facilitate the development of new units.

Depending on the circumstances of at-risk projects, different options may be used to preserve or replace the units. Preservation options typically include: 1) construction of replacement units; 2) provision of rental assistance to tenants; 3) transfer of the project to nonprofit ownership; and 4) purchase of affordability covenants. These options are described below and the City’s focus is on construction of replacement units and rental assistance.

Construction of Replacement Units
The construction of new affordable housing units is a means of replacing the at-risk units should they be converted to market-rate units. The cost of developing housing depends on a variety of factors, including density, size of the units (i.e. square footage and number of bedrooms), location, labor, materials and land costs, and type of construction. The City is implementing a number of programs to encourage development of new affordable units to increase the City’s affordable housing stock.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-77 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Rental Assistance
Rental subsidies using non-federal (state, local, or other) funding sources can be used to maintain affordability of at-risk units. These rent subsidies can be structured to mirror the federal Housing Choice Voucher (Section 8) program. Under Section 8, HUD pays the difference between what tenants can pay (defined as 30 percent of household income) and what HUD estimates as the fair market rent on the unit. The feasibility of this alternative is highly dependent on the availability of other funding sources necessary to make rent subsidies available and the willingness of property owners to accept rental vouchers if they can be provided. Housing Choice Vouchers are available through the Housing Authority of Monterey County.

Transfer of Ownership
Transferring ownership of an at-risk project to a nonprofit housing provider is generally one of the least costly ways to ensure that at-risk units remain affordable for the long term. By transferring property ownership to a nonprofit organization whose mission includes affordable housing, the risk of losing the low-income restrictions is minimized, and the project would become potentially eligible for a greater range of governments assistance.

Purchase of Affordability Covenants
Another option to preserve the affordability of at-risk projects is to provide an incentive package to the owners to maintain the projects as affordable housing. Incentives could include bringing down the interest rate on the remaining loan balance, providing loans for capital improvements, and/or supplementing subsidies. The feasibility of this option depends on whether the complex is too highly leveraged. By providing lump sum financial incentives or ongoing subsidies in the form of rents or reduced mortgage interest rates to the owner, the City can ensure that some of all of the units remain affordable.

Displacement
Because of increasing housing prices, displacement is a major concern in the Monterey Bay Area.

Displacement has the most severe impacts on low- and moderate-income residents. When individuals or families are forced to leave their homes and communities, they also lose their support network.

According to the California Department of Housing and Community Development (HCD) AFFH Data Viewer and the Urban Displacement Project 2022 estimates, Carmel-by-the-Sea renteroccupied households earning between 0-80 percent AMI are at low risk of potential displacement or gentrification in the northern region of the City. Mapping of the central and southern regions of the City show sufficient data was not captured to definitively report displacement risk. Figure A-48 illustrates displacement risk in Carmel-by-the-Sea.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-78 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-48 Displacement Risk, Carmel-by-the-Sea, 2022
SOURCE: California Department of Housing and Community Development AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-79 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Housing Age and Condition
Housing age and condition are factors considered in overall housing quality as they may affect the structural integrity and ability to adequately function for a household. Thus, the age and condition of a house may indicate the need for major repairs to the foundation, plumbing, or roof.

Figure A-49 illustrates housing stock by age in Carmel-by-the-Sea. In Carmel-by-the-Sea, 95 percent of the housing stock was built prior to 1999 and is over 20 years old. Thirty-seven (37) percent of the housing stock was built between 1940-1959 and 2 percent was built in 2010 or later.

Figure A-49 Housing Stock by Age, Carmel-by-the-Sea, 2019 SOURCE: U.S. Census Bureau, ACS 5-Year Estimate, 2019
According to historical data from Carmel-by-the-Sea’s Code Compliance Coordinator, the City estimates that there are approximately five-six (5-6) units in need of rehabilitation. This 6th Cycle Housing Element proposes the following policies and programs to address and facilitate the rehabilitation of these units.
 Policy 2.1: Maintain and encourage expansion of permanent residential housing stock in the Commercial, R-1, and R-4 Districts;
 Policy 2.2: Preserve and protect the scale and character of established neighborhoods while encouraging property improvement;
 Policy 2.3: Preserve and expand affordable and rental housing opportunities to enable local employees to live in the community where they work; and  Policy 2.4: Preserve the existing housing stock.

All programs and policies can be found in Chapter 2 of the Housing Element. 28%
37%
17%
13%
4%
2%
0%
5%
10%
15%
20%
25%
30%
35%
40%
Built 1939 Or
Earlier
Built 1940 To
1959
Built 1960 To
1979
Built 1980 To
1999
Built 2000 To
2009
Built 2010 Or
Later
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-80 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 The City’s Code Compliance Officer works to educate property owners about income-based financing opportunities for the rehabilitation of substandard units. Code Compliance receives a limited number of complaints related to Health and Safety and associated substandard units. Over the last four years Code Compliance has received 11 property maintenance complaints and approximately six (5-6) of these cases indicated a need for repairs related to substandard housing issues. Cases are complaint driven and the city does not reach out to property owners with methods to fund repairs. From Code Compliance records and on-site local knowledge, the complaints are spread across the city and do not appear more frequently in any particular part of the city nor are they concentrated.
3031
As indicated by the 49 building permit applications received by the City (as of October 2023), many residents in Carmel-by-the-Sea are interested in maintaining the upkeep of their residences, and fixing any structural issues that may need to be repaired — to prevent their residences from becoming “substandard”. However, to the City's knowledge, all units have a functioning kitchen, indoor plumbing, and electricity, etc., and are not “substandard”.

Housing Costs and Affordability
Identifying the cost of owning or renting a home in a city helps determine the affordability of housing at different income levels. Understanding housing affordability also informs what types and sizes of housing are needed by the community’s households.

Home Prices and Rental Costs
Table A-25 show changes in median home values between 2019-2022 in Carmel-by-the-Sea, the County and nearby cities. According to Zillow Home Value Index data, the median home value in Carmel-by-the-Sea was estimated at $1,299,387 in December 2019. By 2022, the median home value in Carmel-by-the-Sea increased approximately 59 percent due to market demand. By comparison, the median home value in the County was valued at $561,490 in December 2019 and experienced a 39 percent increase by 2022.
30 Correspondence with Code Compliance Officer December 15, 2023 31 https://carmel.novusagenda.com/agendapublic/CoverSheet.aspx?ItemID=5833&MeetingID=1505 Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-81 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-25 Median Home Value by Jurisdiction, 2019-2022 Jurisdiction
Median Home Value Percent Change
2019-2022 2019 2020 2021 2022
Monterey County $561,490 $632,834 $735,469 $778,164 39% Carmel-by-the-Sea $1,299,387 $1,450,127 $1,912,421 $2,070,835 59% Del Rey Oaks $630,204 $701,060 $779,099 $840,663 33%
Seaside $550,015 $616,786 $690,126 $729,055 33%
Pacific Grove $943,900 $1,032,675 $1,237,054 $1,294,881 37% SOURCE: Zillow Home Value Index, 2019-2022
NOTE: Housing value estimates were taken from December for years 2019-2022.

Rental Affordability
Similar to home value prices, rental prices have also increased over the last decade. This significantly affects lower-income households as they are typically majority renters. High rental prices can exacerbate housing challenges such as overcrowding and cost burden if adequate rental stock is not available to suit household needs.

Table A-26 shows average rent estimates by unit size in Carmel-by-the-Sea based on 2023 Zillow rental market data. Included in the table is Housing and Urban Development’s (HUD) Fair Market Rents (FMR) for 2023, which establishes rental subsidy limits for Section 8 housing voucher recipients.

Table A-26 Average Rent by Number of Bedrooms, Carmel-by-the-Sea, 2023 Unit Type Average Rents Fair Market Rents (HUD)
Studio $2,200 $2,112
One bedroom $2,500 $2,194
Two bedrooms $4,000 $2,675
Three bedrooms $5,459 $3,790
Four+ bedrooms n/a $4,144
SOURCE: Zillow, 2023; HUD, Fair Market Rent Documentation System, 2023 NOTES: Zillow rental value estimates were taken from March 2023. No rental units with four + bedrooms are listed as available within the Carmel-by-the-Sea City boundary. Fair Market Rent values are based on Salinas, CA MSA Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-82 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-27 reports the maximum monthly housing costs affordable to households according to income group in Monterey County. Income groups are based on the HCD 2022 State Income Limits Report, which considers housing affordable assuming a household can pay up to 30 percent of its monthly income toward housing. In Table A-27, maximum affordable sales prices are based on the following assumptions: 6.42 percent interest rate,32 30-year fixed loan, and a 5 percent down payment.

Table A-27 Housing Affordability, Carmel-by-the-Sea, 2022 Income Group HCD Income Limits
Maximum Affordable Price
Monthly Rental Ownership
Extremely Low (0-30% AMI)
One Person $23,900 $598 $100,340
Two Person $27,300 $683 $114,614
Three Person $30,700 $768 $128,889
Four Person $34,100 $853 $143,163
Very Low (30-50% AMI)
One Person $39,800 $995 $167,093
Two Person $45,500 $1,138 $191,024
Three Person $51,200 $1,280 $214,954
Four Person $56,850 $1,421 $238,675
Low (50-80% AMI)
One Person $63,700 $1,593 $267,433
Two Person $72,800 $1,820 $305,638
Three Person $81,900 $2,048 $343,843
Four Person $91,000 $2,275 $382,048
Moderate (80-120% AMI)
One Person $75,650 $1,891 $317,603
Two Person $86,500 $2,163 $363,155
Three Person $97,300 $2,433 $408,497
Four Person $108,100 $2,700 $453,839
SOURCE: California Department of Housing and Community Development, State Income Limits, 2022, Monterey County As mentioned in Table A-25, the median home price in Carmel-by-the-Sea in December 2022 was $2,070,835 which is only affordable to above moderate-income households earning approximately $495,000 or more annually (62 percent of Carmel-by-the-Sea households are categorized as above moderate-income).
32 Interest rate based on December 29, 2022 interest rate according to Freddie Mac Primary Mortgage Market Survey Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-83 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 A.7 Fair Housing Enforcement and Outreach Capacity
This section discusses fair housing legal cases and inquiries, fair housing protections and enforcement, and outreach capacity.

Fair Housing Legal Cases and Inquiries
California fair housing law extends beyond the protections in the Federal Fair Housing Act (FHA).

In addition to the FHA protected classes—race, color, ancestry/national origin, religion, disability, sex, and familial status—California law offers protections for age, sexual orientation, gender identity or expression, genetic information, marital status, military or veteran status, and source of income (including federal housing assistance vouchers).

The California Department of Fair Employment in Housing (DFEH) was established in 1980 and is now the largest civil rights agency in the United States. According to their website, the DFEH’s mission is, “to protect the people of California from unlawful discrimination in employment, housing and public accommodations (businesses), and from hate violence and human trafficking in accordance with the Fair Employment and Housing Act (FEHA), Unruh Civil Rights Act, Disabled Persons Act, and Ralph Civil Rights Act”.33
DFEH receives, evaluates, and investigates fair housing complaints. DFEH plays a particularly significant role in investigating fair housing complaints against protected classes that are not included in federal legislation and therefore not investigated by HUD. DFEH’s website provides detailed instructions for filing a complaint, the complaint process, appealing a decision, and other frequently asked questions.34 Fair housing complaints can also be submitted to HUD for investigation.

Additionally, Monterey County has a number of local resource and enforcement organizations:
 The Housing Authority of the County of Monterey: A public agency that provides rental assistance and develops and manages affordable housing throughout Monterey County, California;
 South County Housing: A non-profit community development corporation. The organization’s mission is to promote viable neighborhoods that enhance healthy, sustainable communities by collaboratively providing affordable housing and promoting neighborhood services;
33 From State of California Civil Rights Department
34 From State of California, Civil Rights Department Complaint Process Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-84 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024  Public Interest Law Project: a nonprofit support center for California legal services and other public interest law programs. The California Affordable Housing Law Project (CAHLP) is a project of the Public Interest Law Project. CAHLP concentrates primarily on the enforcement of California’s Housing Element and redevelopment statutes and of state and federal relocation assistance and fair housing laws;
 Coalition of Homeless Service Providers: Advocate on the subject of homelessness with policy makers, public funders, and those with lived experience; and  California Rural Legal Assistance (CRLA): a nonprofit legal service program created to help California’s low-income individuals and communities. CRLA provides low-income rural Californians with free legal assistance and a variety of community education and outreach programs. Half of its resources are committed to multi-client cases that grapple with the root causes of poverty, with the goal of improving conditions for farmworkers, single parents, school children, the elderly, people with disabilities, and entire communities.

Between 2012 and 2017, 53 fair housing complaints in Monterey County had been filed with the California Department of Fair Employment and Housing (DFEH). Among the complaints countywide, most were related to physical disabilities (23 instances) and familial/marital status (ten instances). Discrimination based on race was also common (seven instances). A complaint may involve multiple acts of discrimination and vice versa. A total of 57 acts of discrimination were recorded in Monterey County. Refusal to rent (17 instances), discriminatory statements (12 instances), and denial of reasonable accommodation/modifications (12 instances) were the most common discriminatory acts in the County.35
In 2020, a total of six (6) discrimination cases were found with the Office of Fair Housing and Equal Opportunity. Fifty percent of the cases were filed on the basis of disability bias. None of the complaints alleged racial bias. Figure A-50 illustrates that out of all of the FHEO cases filed in the state of California in 2020 (398), only between 1 and 2.5 percent of the cases were filed in Monterey County. None of the discrimination cases filed in Monterey County in 2020 took place in Carmelby-the-Sea. 36 A total of six discrimination complaints were filed within Monterey County during 2020. Of those cases, three of them alleged discrimination based on disability. Figure A-51 illustrates this statistic by showing that 40.01 to 65 percent of the cases filed in Monterey County during 2020 reflected disability bias. None of the FHEO complaints occurred in the City of Carmel-by-the-Sea. 35 From California Department of Fair Employment & Housing, 2018; Monterey County Regional Analysis of Impediments to Fair Housing Choice, 2019
36 City of Carmel-by-the-Sea, 2023
Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-85 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-50 FHEO Cases Total, Monterey County, 2020
SOURCE: California Department of Housing and Community Development AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-86 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Figure A-51 FHEO Cases, Disability Bias, Monterey County, 2020 SOURCE: California Department of Housing and Community Development AFFH Data Viewer Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-87 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 NFHA identifies three significant trends in 2020 that are relevant for this AFFH:
 First, fair lending cases referred to the Department of Justice from federal banking regulators has been declining, indicating that state and local government entities may want to play a larger role in examining fair lending barriers to homeownership;  Second, NFHA identified a significant increase in the number of complaints of harassment— 1,071 complaints in 2020 compared to 761 in 2019; and
 Finally, NFHA found that 73 percent of all fair housing complaints in 2020 were processed by private fair housing organizations, rather than state, local, and federal government agencies— reinforcing the need for local, active fair housing organizations and increased funding for such organizations.37
Outreach and Capacity
Currently, Carmel-by-the-Sea’s website contains information about local fair housing ordinances.

The website describes the steps residents should take if they feel they have faced discrimination and are seeking information about filing complaints (e.g., link to HUD’s and State of California fair housing pages). The site also references the organizations that provide fair housing services and assistance to City residents.

The following organizations offer fair housing services and assistance to the residents of Carmel-bythe-Sea:
 Conflict Resolution and Mediation Center;
 Legal Services for Seniors;
 California Rural Legal Assistance;
 ECHO Fair Housing Services
 HUD Housing Assistance;
 Central Coast Center for Independent Living; and
 Center for Community Advocacy.

Compliance with State Fair Housing Law
The City of Carmel-by-the-Sea complies with existing fair housing laws and regulations by ensuring all residents have equal access to housing programs, services, and resources and supporting residents in filing complains on housing discrimination. Carmel-by-the-Sea is compliant with the following State laws that promote fair and affordable housing. The City has not been alleged or found in violation of the following:
37 From Gentry, A. (2021, September 4). Annual fair housing report shows increase in housing harassment. NFHA.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-88 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024  Housing Accountability Act (Gov. Code. Section 65589.5) requiring adoption of a Housing Element and compliance with RHNA allocations – The City will comply with the Housing Accountability Act by approving any eligible housing development projects, including those with at least 20 percent affordable units to lower-income households.  No Net Loss Law (Gov. Code Section 65863) requiring that adequate sites be maintained to accommodate unmet RHNA allocations – The City complies with the No Net Loss Law by identifying sites that can accommodate the City’s RHNA. The City also maintains minimum density requirements for multi-family housing developments in the R-4 district. However, to further encourage the development of affordable housing, the City is committed to amending the Municipal Code to amend the base zoning for the SC, RC, and CC commercial districts and the R-4 multi-family residential development district to allow a minimum of 33 dwelling units per acre.
 Limits on Growth Controls Law (Gov. Code. Section 65302.8) – The City complies with the Limits on Growth Controls Law. The City is surrounded by County development and has not adopted any mandatory general plan elements which limit the number of housing units..  Housing Element Law (Gov. Code Section 65583(c)(5), (c)(10) – The City has included this analysis of fair housing and identifies strategies to increase housing opportunities for all residents, with specific actions to reduce housing disparities for lower-income households.

Housing Specific Policies Enacted Locally
The City of Carmel-by-the-Sea identified the following local policies that contribute to the regulatory environment for affordable housing development in the City:

Policy 1.1: Ensure adequate sites are available to meet the City’s projected housing growth needs.

Policy 1.3: Reduce or eliminate governmental constraints on the provision of affordable housing. Direct public funding resources to the conservation of existing housing units in neighborhoods where continued residential use is appropriate.

Policy 2.3: Preserve and expand affordable and rental housing opportunities to enable local employees to live in the community where they work.

Policy 2.4: Preserve the existing housing stock.

Policy 3.2: Recognize the special needs of persons with disabilities and the need to retain flexibility in the design review process to accommodate these needs.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-89 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 A.8 Fair Housing Recommendations
Contributing Factors and Fair Housing Action Plan
The disparities in housing choice and access to opportunity discussed above stem from historical actions, socioeconomic factors that limit employment and income growth, barriers to open housing choice, and until recently, very limited resources to respond to needs.

Local Knowledge of Contributing Factors to Fair Housing In order to better inform this Housing Element to meet the needs of residents of Carmel-by-theSea, the City solicited the input of the public with prompted questions. All responses were taken into consideration for incorporation into the Housing Element to guide policies and programs that address the housing needs of existing and future residents.

Question: How can the supply of affordable housing be increased to meet the needs of our community?
Community members offered the following solutions:
 Encourage ADUs;
 Encourage second-story additions to single-story buildings downtown specifically for affordable housing;
 Change the zoning code to allow 3-story buildings downtown specifically for affordable housing;  Set a maximum square footage limit on housing units in downtown to spur the creation of more small units rather than just a few large units;
 Create objective (yes/no checklist-style) design standards for new housing projects that include affordable units;
 Less short-term rental places, more long-term rental options;  Build housing on the outskirts and empty parking lots;  Annex land outside City for affordable housing; and
 Continue to ensure the built environment is subordinate to the natural environment.

Question: In your experience in Carmel-by-the-Sea, what has contributed to the fair housing issues? What solutions do you envision to address these issues?  Information about affordable units.
 Down payment assistance.
 Tenant assistance resources.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-90 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Priority of Contributing Factors
The City of Carmel-by-the-Sea has prioritized the following contributing factors to the Fair Housing issues mentioned above. Table A-28 presents prioritized fair housing issues and contributing factors, as well as the City’s programs to support a solution-oriented approach to affirmatively furthering fair housing.

Attachment 2
Appendix A – Housing Needs & Fair Housing Report A-91 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table A-28 Fair Housing Issues, Contributing Factors, and AFFH Programmatic Actions Fair Housing Issue Contributing Factor(s) AFFH Programmatic Action Priority Household Characteristics
Carmel-by-the-Sea has significantly lower
proportions of racial and ethnic minorities
compared to Monterey County and the
AMBAG region. Lack of inclusionary
housing may contribute to the lack of
protected classes in the community.
 Lack of racial and ethnic diversity within the City;
and
 Lack of adequate affordable housing options.

Program 1.1.B: Underutilized Sites
Program 3.1.C: Density Bonus
Program 3.1.D: Reduced Entitlement and
Development Fees
Program 1.3.D: Employee Housing Program
Program 2.1.A: Incentives for Mixed-Use
Development
High
Disproportionate Housing Needs
Forty-six (46) percent of Carmel-by-the-Sea
households are cost burdened households,
of which 24 percent are renter-occupied
households and 23 percent are owneroccupied.
 Lack of affordable housing;
 Lack of adequate housing stock that meets the
needs of residents; and
 Jobs-worker imbalance.

Program 1.1.B: Underutilized Sites
Program 1.3.D: Employee Housing Program
Program 2.4.A: Housing Rehabilitation and
Maintenance Information
Program 3.1.B: Housing for Extremely-Low
Income Households
Program 3.1.C: Density Bonus
Program 3.1.G: Affordable Housing Overlay
District
High
Special Needs Groups
In Carmel-by-the-Sea, extremely lowincome and special needs groups  Lack of affordable housing;
 Jobs-worker imbalance;
Program 1.3.E: Amend the A-2 Zoning District
Program 3.1.B: Housing for Extremely-Low
Income Households
High
Appendix A – Housing Needs & Fair Housing Report A-92 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Fair Housing Issue Contributing Factor(s) AFFH Programmatic Action Priority experience disproportionate impacts of
poverty, increasing the challenge of
obtaining adequate housing in the City.
 Lack of accessible units for individuals with
disabilities; and
 Lack of Transitional and Supportive
Housing/Emergency Shelters.

Program 3.2.A: Reasonable Accommodation
Procedures
Program 3.3.A: Zoning for Transitional and
Supportive Housing
Program 3.3.B: Low-Barrier Navigation
Centers
Housing Stock
Carmel-by-the-Sea’s lack of affordable
housing production, limited variety of
housing types, and increasing housing
costs create barriers to enter the local
housing market.
 Since 2015, there have been 18 housing permits in
the City for only above moderate-income
households; and
 Lack of developable land, and the City is subject to
coastal zone ordinances.

Program 1.3.A: Condominium Conversions
Program 1.3.B: Overnight Visitor
Accommodation (Conversion)
Development Transfer Rights
Program 1.3.C: Accessory Dwelling Units
Program 1.4.A: Remove Use Permit
Requirement for Multi-Family
Development
Program 1.4.B: Objective Design Standards
Program 2.1.B: Permanent Housing
Program 2.3.A: Preserve and Increase Upper
Floor Residential Uses
Program 3.1.E: Reduced Parking
Requirements
Program 3.1.F: Expedited Processing
Procedures
High
Access to Opportunity
Low production of affordable housing in
Carmel-by-the-Sea limits housing choices
for low-income households, and has a
disproportionate impact on Hispanic or
Latino, Asian, and Black/African American
households.
 Of the 18 housing permits issued in Carmel-by-theSea since 2015, zero were issued for lowerincome households (lack of affordable housing); and
 Costs of land, materials, and labor which limit
profitability of affordable housing.

Program 1.2.A: Water Distribution Policy
Program 1.3.A: Condominium Conversions
Program 1.3.D: Employee Housing Program
Program 2.1.D: Establish Affordable Housing
Trust Fund
Program 3.1.C: Density Bonus
Program 4.1.A: Water Conservation
High
Appendix A – Housing Needs & Fair Housing Report A-93 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Fair Housing Issue Contributing Factor(s) AFFH Programmatic Action Priority Fair Housing Enforcement
No residents filed fair housing complaints in
Carmel-by-the-Sea, indicating a lack of
cause for complaint, or, alternatively, a
potential lack of awareness about fair
housing rights.
 Lack of access to information about fair housing
rights; and
 Limited knowledge of fair housing by residents.

Program 2.1.C: Monitor Affordable Housing
Stock
Program 5.1.A: Fair Housing Services
Program 5.1.B: Housing Choice Voucher
Program
Program 5.1.C: Shared Housing Information
Program 5.2.A: Support Community
Organizations
Medium
SOURCE: City of Carmel-by-the-Sea; EMC Planning Group
Appendix A – Housing Needs & Fair Housing Report A-94 EMC Planning Group Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 A.9 Conclusion
To address the fair housing issues identified in this Housing Needs and Fair Housing report, the programs listed in the above section are included in Chapter 2 of this Housing Element.

Attachment 2
Housing Constraints

APPENDIX
B
Attachment 2
Attachment 2
Table of Contents
APPENDIX B HOUSING CONSTRAINTS ............................................................................. B-1 B.1 Introduction ........................................................................................................................... B-1 B.2 Governmental Constraints ................................................................................................... B-1 B.3 Non-Governmental Constraints ....................................................................................... B-56 Tables
Table B-1 Residential Land Use Designations ......................................................................... B-4 Table B-2 Residential Uses Permitted by Zone....................................................................... B-7 Table B-3 Residential Development Standards..................................................................... B-12 Table B-4 R-1 District Base Floor Area and Bonus Floor Area Standards for Typical Lots .............................................................................................................. B-13 Table B-5 Maximum Density Standards................................................................................. B-15 Table B-6 Maximum Height Standards ................................................................................... B-16 Table B-7 Minimum Off-Street Parking Requirements ....................................................... B-19 Table B-8 Summary of Community Planning & Building Fees (2023-2024).................... B-39 Table B-9 Jurisdictional Comparison of Average Design Review/Study Fees ................. B-42 Table B-10 Estimate of Total Development Fees Imposed.................................................. B-44 Table B-11 Review/Approval Requirements and Processing Times................................... B-48 Table B-12 Permit Streamlining Act Processing Times.......................................................... B-49 Table B-13 Summary of Governmental Constraints .............................................................. B-56 Table B-14 Summary of Non-Governmental Constraints ..................................................... B-66

Attachment 2
Attachment 2
Appendix B – Housing Constraints B-1 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Appendix B
Housing Constraints
B.1 Introduction
Housing development is affected by public regulations and other forces. This chapter discusses both governmental and non-governmental constraints that affect housing in the City of Carmel-by-theSea. Governmental constraints consist of policies, requirements, or other actions imposed by various levels of government on land, housing ownership, and development. In addition to local standards, the City follows building and design requirements put forth by state laws, the California Building Code, Subdivision Map Act, energy conservation requirements, as well as other regulatory standards.

However, Federal and State agency regulations that may constrain development are beyond the City’s control and are therefore not addressed in this document. Non-governmental constraints are other conditions that impact housing development such as market factors, environmental setting, land availability, and construction costs.

B.2 Governmental Constraints
Governmental constraints are policies, standards, requirements, or actions imposed by the various levels of government upon land, housing ownership and development. Although Federal and State agencies play a role in the imposition of governmental constraints, these agencies are beyond the influence of local government and are therefore not addressed in this document. As appropriate, the City will monitor federal and state legislation that impacts housing. The City will update its Municipal Code, as needed to comply with any new housing related planning or zoning laws enacted by the State during the 6th Cycle Planning Period (2023-2031).

Infrastructure Constraints
Water Supply
The primary infrastructure constraint to the development of housing in Carmel is the lack of potable water. The lack of a reliable available water supply continues to limit growth in Carmel and throughout the Monterey Peninsula region.

Carmel is under the jurisdiction of the Monterey Peninsula Water Management District (MPWMD) and receives its water from the California-American Water Company (Cal-Am). The MPWMD has permit authority over the production and distribution of all water supplies within the Monterey Peninsula region, and allocates water supplies to cities and unincorporated County areas within its Attachment 2
Appendix B – Housing Constraints B-2 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 jurisdiction. Water service by Cal-Am is constrained by State Water Resources Control Board (SWRCB) Order WR 95-101, which determined that in 1995 approximately 70 percent of Cal-Am supply was based on unlawful diversion from the Carmel River. Order 95-10 requires that any new water supply be used to reduce diversions from the Carmel River prior to allowing new users.

Furthermore, SWRCB issued a Cease-and-Desist order to Cal-Am in 20082 to further restrict water use which limits the placement of new water meters to service new development.

According to the MPWMD June 1, 2023 Technical
Memorandum – Summary of Water Supply Requirements
for Housing, the City requires 40 acre feet (AF) to meet the City’s RHNA (349 units). The City has approximately 2.661 acre-feet of available water3 for general distribution which represents a water deficit of approximately 37.339AF. There is also Malpaso Water Company water entitled to certain limited properties whose owners were previously able to purchase water directly from the Water Company4. The
Sites Inventory clearly identifies whether water is a
constraint for each identified property. This is the only water available to the City until the District supplies increase and new allocations are made to each city in the District.

Based on current supplies, sufficient water is not widely available to fully accommodate additional development commensurate with the City’s total RHNA.

The City will continue to work with local and regional agencies to explore options for additional water supplies during the 6th Cycle Housing Element planning period.

The 6th Cycle Housing Element includes a program (program 1.2.A) to work with local and regional agencies to pursue new water supplies and includes prioritizing allocation of the City’s 2.661 acrefeet of water for affordable housing through the development of a water distribution policy. The City is currently working with the MPWMD to utilize water-saving fixtures for every building permit 1 See Order No. WR 95-10, chromeextension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.waterboards.ca.gov/waterrights/board_decisions/adopte d_orders/orders/1995/wro95-10.pdf
2 See Order WR 2009-0060, chromeextension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.waterboards.ca.gov/waterrights/board_decisions/adopte d_orders/orders/2009/wro2009_0060.pdf
3 See June 2023 MPWMD Monthly Allocation Report chromeextension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.mpwmd.net/asd/board/boardpacket/2023/20230717/1 0/Item-10-Exh-10-A.pdf
4 See June 2023 MPWMD Monthly Allocation Report – Entitlements - chromeextension://efaidnbmnnnibpcajpcglclefindmkaj/https://www.mpwmd.net/asd/board/boardpacket/2023/20230717/1 0/Item-10-Exh-10-B.pdf
We have competing mandates.

One of the mandates we have
from the State of California is
Order 95-10, which basically
says we have no more
water…the other mandate is
the [RHNA units]…if we don’t
have water, we can’t build
them. It doesn’t matter how
you slice or dice it – no water,
no construction.

April 6, 2023 Housing Ad Hoc
Committee Community
Meeting Attendee
Attachment 2
Appendix B – Housing Constraints B-3 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 application, which helps to minimize water usage and thereby conserve water for future allocation in new developments. The City of Carmel is also supportive of Pure Water Monterey’s and Cal-Am’s efforts to provide additional water for new units, and promote desalination.

Wastewater
The Carmel Area Wastewater District (CAWD) collects and conveys wastewater from a business or residence to the wastewater treatment plant using underground pipes and lift stations. The CAWD collection system is comprised of approximately 81 miles of gravity sewers ranging in size from 6 inches to 27 inches in diameter together with nearly four (4) miles of force mains, seven (7) pump stations, and over 1,500 manholes.

Two trunk sewers serve the City of Carmel and the Hatton Fields areas. Within the City of Carmelby-the-Sea pump stations are located at (1) the westerly terminus of 8th Avenue (at Scenic Drive), (2) the intersection of Monte Verde Street and Sixteenth Avenue, (3) west side of Scenic Road approximately 200 feet south of Ocean View Avenue All pump stations have been upgraded to allow remote monitoring and have capabilities for standby power and emergency bypass.

The District’s permitted capacity is 3.0 million gallons per day (MGD) and their current average daily dry weather flow is approximately 1.2 to 1.3 MGD.

The City is required to plan for an additional 349 residential housing units in this planning cycle.

Based on capacity and communication with the District, the CAWD has adequate treatment capacity to serve these units5.

General Plan and Land Use Controls
Each city and county in California must prepare a comprehensive, long-term General Plan to guide its future. The Land Use Element of the General Plan establishes the basic land uses and density of development within each jurisdiction. Under state law, the General Plan elements must be internally consistent, and each jurisdiction’s zoning must be consistent with its General Plan. Thus, the Land Use Element must provide suitable locations and densities to implement the policies of the Housing Element.

The City’s development policies, standards and requirements were established with the intent of maintaining the long-term health, safety, and welfare of the community. To achieve this, the City has implemented a range of procedures, regulations and fees associated with all local development. Specific land use and 5 May 17, 2023 email correspondence with CAWD
We are primarily,
essentially, and
predominantly a
residential city. I want
to see us preserve our
residential character.

February 28, 2023
Housing Ad Hoc
Committee Community
Meeting Attendee
Attachment 2
Appendix B – Housing Constraints B-4 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 development constraints, such as zoning regulations, governmental fees, building code standards, design review, and processing and permitting time can greatly influence the type and cost of construction that occurs.

The City of Carmel-by-the-Sea General Plan/Coastal Land Use Plan (General Plan) was adopted in 2003 and most recently amended in 2015. The General Plan Land Use Element identifies land use designations and development intensities for all land within City boundaries. Land Use designations include Core Commercial, Residential/Commercial, Multi-Family Residential, Single Family Residential, and Open Space/Recreation/Cultural. The Residential/Commercial land use designation encourages mixed use buildings and is intended to provide for a mix of residential dwellings and a limited range of office and service uses in scale with the character of the community.

Table B-1, Residential Land Use Designations, identifies the residential land use designations and their maximum permitted densities.

Table B-1 Residential Land Use Designations
Designation Maximum Density
Single-Family Residential 11 du/acre
Multi-Family Residential 33 du/acre, 44 du/acre (with affordable housing) Commercial/Residential 33 du/acre
Core Commercial 33 du/acre
SOURCE: Carmel-by-the-Sea 2003 General Plan
The range of residential densities provided by Carmel-by-the-Sea’s General Plan is sufficient to accommodate a range of housing types and affordability levels. It does not, therefore, pose an undue governmental constraint the development of housing for the community.

Local Coastal Program and Coastal Land Use Plan
The California Coastal Act was established to balance landowners’ rights to develop and the public’s right to enjoy the coastline. This resulted in an area defined as the Coastal Zone which is regulated to ensure orderly, long-range conservation, use, and management of the natural, scenic, cultural, recreational, and manmade resources of the coast. All of the Carmel-by-the-Sea is located within the Coastal Zone, which in this area extends from the coast of Carmel Bay east to California State Highway 1.

Carmel-by-the-Sea’s Local Coastal Program (LCP) was certified by the Coastal Commission in 2004, enabling the City to issue Coastal Development Permits (CDPs). This gives the City authority over local development applications, with appeal oversight maintained by the Coastal Commission in limited areas of the City identified on the Carmel Zoning Map as the Beach & Riparian Attachment 2
Appendix B – Housing Constraints B-5 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Overlay/Coastal Commission Appeal Jurisdiction. Land uses within the appeal jurisdiction are limited to single-family residential and open space. The Commission also retains permanent coastal permit jurisdiction over development proposed on tidelands, submerged lands, and public trust lands.

The LCP includes the following General Plan Elements: Land Use, Circulation, Coastal Access and Recreation, and Coastal Resource Management; the Zoning Ordinance (Implementation Plan); and, Appendices A through I of the General Plan and Zoning Ordinance.

The presence of land use regulation via the LCP, in general, means that housing development in Carmel-by-the-Sea faces a high bar to succeed. Most of the recent remedies brought forward by the California legislature to facilitate housing development are either outright inapplicable in the Coastal Zone (SB 35) or are secondary to California Coastal Commission policies that protect habitat resources (SB 9).

Zoning Code
The City of Carmel-by-the-Sea Zoning Code (City Municipal Code Title 17, Chapter 17.08- Residential Zoning Districts) establishes regulatory standards that dictate the type, location, density, and scale of residential development within the City’s boundaries. Essentially, all zoning districts allow residential development. Below are the two primary zoning districts within the city that allow for residential uses:
 R-1 Single-Family Residential District; and
 R-4 Multifamily Residential District.

In addition, the following zoning districts provide for some residential uses above commercial uses or on ground floor after review and approval of a conditional use permit.  SC Service Commercial;
 CC Central Commercial District; and
 RC Residential and Limited Commercial.

The following public and quasi-public zoning districts also permit limited residential uses:
 P-2 Improved Parklands (Park and Recreation District);  A-2 Community and Cultural (Other Public District); and  A-3 Senior Citizen Facility (Other Public District).

The City of Carmel-by-the-Sea Municipal Code (CMC) provides zoning regulations that are more specific than the General Plan Land Use designations. The R-1 (Single-Family Residential) district provides an appropriate land area for permanent single-family residential uses and structures and to enhance and maintain the residential character of the City. The R-4 (Multifamily Residential) district Attachment 2
Appendix B – Housing Constraints B-6 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 is intended to serve two purposes: 1) to provide an appropriate location for a mix of multifamily residential dwelling units convenient to the commercial area; and 2) to serve as a buffer or transitional zone between the commercial area and the single-family residential district.

Commercial zoning districts that permit residential uses include:
 The Central Commercial (CC) District, which is intended to provide an appropriate location for a broad range of retail, residential and service uses. Uses which generate high pedestrian traffic and which do not have large space requirements are appropriate in this district. Residential uses are appropriate on the second floor of structures.
 The Service Commercial (SC) District, which is intended to provide an appropriate location for services, offices, residential and limited retail activities that primarily serve local needs. This district is intended to provide a distinct transition between the more intense activities in the CC district and the less intense activities in the districts on its periphery. Mixed uses of commercial and residential activities are appropriate throughout this district.  The Residential and Limited Commercial (RC) District seeks to provide an appropriate location for permanent and transient residential uses, service and office uses, and limited retail uses that do not adversely impact the residential neighborhood. This district is intended to provide a transition and buffer between the more intense activities in the CC and SC districts and the less intense activities in the R-1 and R-4 districts.

Certain public and quasi-public zoning districts also permit limited residential uses. The Park and Recreation (P-2) District permits single-family, senior citizen housing, and family day care uses which are limited to the use and maintenance of existing buildings for nonprofit organizations, governmental buildings and uses, and residential use. Sites located in the Community and Cultural Center (A-2) District and Senior Citizen Facility (A-3) District permit senior citizen housing outright.

Table B-2, Residential Uses Permitted by Zone, shows residential uses, the zoning districts in which they are permitted, and whether they are permitted by right (without discretionary action) or with a conditional use permit (CUP). The City’s Municipal Code is available online:
(https://www.codepublishing.com/CA/CarmelbytheSea/).

Attachment 2
Appendix B – Housing Constraints B-7 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Table B-2 Residential Uses Permitted by Zone
Residential Use
Residential Zoning
Districts Commercial Zoning Districts
Public and Quasi-Public Districts
(Park and Recreation & Other
Public Districts)
R-1 R-4 CC SC RC P-2 A-2 A-3
Single-Family P P C-L-5 C C P-L-1 - -
Accessory Dwelling Units
Accessory Dwelling Unit (Interior) P P - - - - - -
Accessory Dwelling Unit
(New Structure) P P - - - - - -
Class I Accessory Dwelling Unit P - - - - - - -
Class II Accessory Dwelling Unit P - - - - - - -
Studio P P - - - - - -
Guesthouse (Noncommercial) C - - - - - - -
Multifamily Dwellings
0-22 dwelling units/acre - P P P P - - -
22 dwelling units/acre - C - - -
23-33 dwelling units/acre - C C C C - - -
34-44 dwelling units/acre - C C C C - - -
45-88 dwelling units/acre - - C C C - - -
Senior Citizen Housing R-L-5 P P P P P-L-1 P P
Family Day Care
Small Family R-L-5 P - P P-L-1 - -
Large Family - C-4 - C C P-L-1 - -
Group Residential - C - - - - - -
Appendix B – Housing Constraints B-8 EMC Planning Group City of Carmel-by-the-Sea 6th Cycle Housing Element Update HCD Revised Draft January 2024 Residential Use
Residential Zoning
Districts Commercial Zoning Districts
Public and Quasi-Public Districts
(Park and Recreation & Other
Public Districts)
R-1 R-4 CC SC RC P-2 A-2 A-3
Transient Rental, Legal Nonconforming - R-L-6 C-L-7 C-L-7 C-L-7 - - - Transient Rental, Housing Incentive - R-L-7 C-L-8 C-L-8 C-L-8 - - - SOURCE: CMC Title 17 Zoning 2023
NOTE: Key:
(P) permitted use classifications.
(L) use classifications that are permitted, subject to certain specific limitations noted by the number designations and listed at the end of Schedule II-1 (CMC Section 17.08.040) and Schedule II-B (CMC Section 17.14.030). (C) use classifications permitted after review and approval of a conditional use permit by the Planning Commission. Conditions or standards may apply to these uses, noted by the number designations and listed at the end of Schedule II-1.
(—) prohibited
Residential Districts Specific Limitations and Conditions R-L-1. Limited to advertising, consumer credit reporting, secretarial and court reporting, equipment maintenance and repair, personnel supply services, and nonretail computer services and repair.

Carmel-by-the-Sea City CouncilApril 8, 2024

Carmel-by-the-Sea City Council
April 8, 2024