Addendum to the
Certified Final Program EIR
for the
City of Diamond Bar 2040 General Plan
July 2022
OVERVIEW
On December 17, 2019 the Diamond Bar City Council certified Final EIR No. SCH 2018051066 for the Diamond Bar 2040 General Plan. The City is now required to adopt an updated Housing Element for the 2021-2029 planning period. The purpose of this Addendum is to demonstrate that the 2021-2029 Housing Element update would not result in any of the conditions under which a subsequent environmental document would be required pursuant to CEQA Guidelines Section 15164.
PURPOSE OF AN ADDENDUM
CEQA Guidelines Section 15164(a) states: “The lead agency or responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred.”
The following analysis demonstrates that the 2021-2029 Housing Element update does not raise any new environmental issues and requires only minor technical changes or additions to the previous EIR to satisfy the requirements of CEQA for the proposed Housing Element update.
PUBLIC REVIEW PROCESS FOR AN ADDENDUM
CEQA Guidelines Section 15164(c) and 15164(d) state: “An addendum need not be circulated for public review but can be included in or attached to the final EIR or adopted negative declaration.
The decision making body shall consider the addendum with the final EIR or adopted negative declaration prior to making a decision on the project.” PROJECT DESCRIPTION: 2021-2029 HOUSING ELEMENT UPDATE
State law requires every jurisdiction within the Southern California Association of Governments (“SCAG”) region to prepare a Housing Element update for the 2021-2029 planning period.
Detailed requirements for Housing Elements are established in California Government Code Sec. 65580 et seq.
The Draft 2021-2029 Housing Element, which is posted on the City website at:
https://www.diamondbarca.gov/963/Housing-Element-Update, focuses on establishing City policies and programs to address the housing needs of current and future Diamond Bar residents.
The Draft Housing Element includes the following sections:
• An introductory overview of the Housing Element (Section 9.1) • Analysis of the City's demographic and housing characteristics and trends (Section 9.2) • Evaluation of resources and opportunities available to address housing needs (Section 9.3) Addendum to Final EIR No. SCH 2018051066
Diamond Bar 2021-2029 Housing Element
• Analysis of potential governmental and non-governmental constraints to meeting the City's housing needs (Section 9.4)
• The Housing Action Plan for the 2021-2029 planning period (Section 9.5) • Review of the City’s accomplishments during the previous planning period (Appendix A) • An inventory of sites that could accommodate the City’s new housing needs (Appendix B); • A description of opportunities for stakeholders to participate in the preparation of the Housing Element (Appendix C); and
• An assessment of fair housing issues (Appendix D).
ENVIRONMENTAL ANALYSIS
Generally, the most significant issues addressed in the Housing Element are: 1) whether City plans and regulations accommodate housing for persons with special needs in compliance with State law; and 2) how the City will accommodate its share of regional housing needs assigned through the Regional Housing Needs Assessment (“RHNA”) process.
Housing for Persons with Special Needs. State law establishes specific requirements related to City regulation of housing for persons with special needs, including the homeless and persons with disabilities. Section 9.4 of the Housing Element (Constraints) contains an analysis of City plans and regulations for a variety of housing types. The analysis concluded that while current City regulations are consistent with most laws regarding special needs housing, some recently adopted laws will require that the Municipal Code be amended in order to ensure consistency with State law. Section 9.5 (Housing Action Plan) of the Housing Element includes the following programs to comply with State requirements:
• Program H-10. Accessory Dwelling Units. State law has been amended several times over the past few years to establish mandatory local standards and procedures intended to encourage production of ADUs. This program includes a commitment to process a Development Code amendment in conformance with current State law. • Program H-11. Emergency Shelters, Low Barrier Navigation Centers and Transitional/Supportive Housing. The Development Code establishes standards and procedures for these types of housing targeted for persons who are homeless or at risk of becoming homeless. This program includes a commitment to process a Development Code amendment in conformance with recent changes to State law. These changes include allowing supportive housing meeting specified criteria in zones where multi-family and mixed uses are permitted, and allowing low barrier navigation centers meeting specified standards in areas zoned for mixed use and in non-residential zones permitting multi-family uses. Low barrier navigation centers are defined as “Housing first, low-barrier, service-enriched shelters focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing.”
• Program H-12. Affordable Housing Incentives/Density Bonus. Density bonus refers to the State law requiring cities to allow increased density and other incentives for housing developments that include long-term commitments to provide units affordable to low- and moderate-income households. Recent changes to State Density Bonus Law have increased the required amount of density bonus and other incentives for affordable housing. This program includes a commitment to amend the City’s density bonus regulations consistent with current State law.
Addendum to Final EIR No. SCH 2018051066
Diamond Bar 2021-2029 Housing Element
Regional Housing Needs Assessment. The Regional Housing Needs Assessment (“RHNA”) is the process established in State law by which housing needs are determined for each city. On March 4, 2021 SCAG adopted the final RHNA Plan, which assigns Diamond Bar the following housing needs for the 2021-2029 planning period.
2021-2029 RHNA Allocation – Diamond Bar
Extremely Low +
Very Low Low Moderate AboveModerate Total
844 434 437 806 2,521
Source: SCAG, 3/4/2021
The RHNA allocation identifies the amount of additional housing a jurisdiction would need in order to have enough housing at all price levels to fully accommodate its assigned share of the region’s housing need during the 8-year planning period. The RHNA is a planning requirement based upon existing and projected housing need, not a construction quota, mandate, or prediction of future housing development. Jurisdictions are not required to build housing or issue permits to achieve their RHNA allocations.
The Housing Element must include an evaluation of potential capacity for additional housing based on land use patterns, development regulations, other development constraints (such as infrastructure availability and environmental conditions) and real estate market trends. The analysis must be prepared at a parcel-specific level of detail and identify properties (or “sites”) where additional housing could be built consistent with City regulations. This evaluation is referred to as the “sites analysis” and State law requires the analysis to demonstrate that the city has adequate sites with appropriate zoning to fully accommodate additional housing development commensurate with its RHNA allocation in each income category. Appendix B of the Housing Element includes a parcel-level analysis of sites that could accommodate the City’s RHNA allocation. State law establishes an allowable density of 30 units/acre that is assumed to facilitate development of housing affordable to lower-income households.
Diamond Bar’s 2040 General Plan, adopted in December 2019, estimates that up to 3,750 new housing units could be built in the city by 2040, depending on market conditions. It is expected that much of this growth will occur within the Town Center Mixed Use, Neighborhood Mixed Use, Transit Oriented Development and Community Core Overlay focus areas, while most existing residential neighborhoods will experience less growth and change. The amount of additional housing development anticipated in the General Plan and analyzed in the General Plan Program EIR exceeds the RHNA allocation of 2,521 units by approximately 49%. While the total additional housing development anticipated in the Housing Element is less that the level of development assumed in the General Plan, the Housing Element sites inventory assumes an allowable density of 30 units per acre and a realistic density of 24 units per acre in the Town Center Focus Area as compared to the General Plan policy of 20 units/acre for the Town Center. It is important to note that the Housing Element is a policy document and no specific housing project would be approved and no development regulations would be changed by adoption of the Housing Element; therefore, no direct environmental impacts would be caused by adoption of the Housing Element.
Program H-8 includes a commitment to adopt revised land use regulations for the focus areas to establish detailed development standards, and the City has initiated preparation of a specific plan for the Town Center area. Once specific development standards such as height limits and allowable building floor area have been identified as part of the specific plan process, additional CEQA analysis will be conducted to evaluate whether any new environmental impacts would be expected to occur that were not analyzed in the General Plan Program EIR. A similar CEQA Addendum to Final EIR No. SCH 2018051066
Diamond Bar 2021-2029 Housing Element
review will also be conducted in connection with the preparation of new development regulations for the other focus areas.
CONCLUSION
The 2040 General Plan Program EIR evaluated potential environmental impacts that would be expected to occur as a result of future development consistent with the General Plan. Since the amount of new residential development assumed in the 2021-2029 Housing Element does not exceed General Plan assumptions, no new significant effects would occur that were not previously analyzed in the General Plan EIR. No specific development project would be approved as part of the Housing Element, and the proposed Development Code amendments related to affordable housing density bonus and housing for persons with special needs are required to conform City regulations with current State law. Therefore, these amendments would not change the type or amount of development already allowed under State law.
On the basis of the foregoing analysis the City has determined that pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15164, an addendum is the appropriate CEQA document for the 2021-2029 Housing Element update. There is no substantial evidence that the proposed Housing Element amendment will result in significant environmental impacts not previously addressed in the 2040 General Plan EIR. Consequently, no additional CEQA analysis is required at this time.