requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.
For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor's Office of Planning and Research at:
httwflopr,ca.goWdqq§/0PR Apoendix C firiM.odf and
http://oor.ca.aov/d6t� §/"""""`F�inal 6,26,15j)dE
We are committed to assist the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Colin Cross, of our staff, at colln,crossighqd&p�Mv.
Sincerely,
t-1
Paul McDougall
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The following changes are necessary to bring the City's housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.
Housing element technical assistance information is available on HCD's website at well
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1. Affirmatively furtherfing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2 ... shall include an assessment of fair housing in thejurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Lem Mr -Caw. I
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- q nutreacli is particularly important to informing Tair tiousing issues, confrIDUling Taclors and appropriate goals and actions. Outreach should consider a variety of methods to gather input on the various components of the assessment of fair housing (e.g., segregation and integration, disparities in access to opportunity, disproportionate housing needs) and may utilize information from the 2020 Analysis of Impediments to Fair Housing Choice.
Pattornsartd 17re4ids- The element reports data regarding the patterns of various socio- economic chara�teristics across all components of the required analysis (e.g., segregation and integration, access to opportunity, displacement). However, the element should also generally analyze the various socio-economic characteristics. An analysis should generally address patterns at a regional and local level and trends in patterns over time. Patterns at a regional level must compare conditions at the local level to the rest of the region. This analysis should compare the locality at a county level or other regional level such as a Council of Governments, where appropriate, for the purposes of promoting more inclusive communities. Patterns at a local level must address whether certain areas strongly differ from other areas. The analysis should also address any coincidence with other components of the assessment of fair housing and local data and knowledge and other relevant factors as described below.
City of Downey's 6 th Cycle Draft Housing Element Page 1 November 10, 2021
Disparities in Access to OpDortunity: The element reports data from the TCAC/HCD Opportunity maps at a composite level, but it should also separately report and analyze data, patterns and trends related to education, economy and transportation.
Disproportionate Housing Need,,Includin Displacement Risk: The element describes I displacement relative to tenure; however, it could also consider information from the HC lk AFFH Data Viewer and provide analysis as described above, including overlapping coincidence with other components of the assessment of fair housing. I Local Data and Knowledge: The element should incorporate local data and knowledge of thejurisdiction into the AFFH section. To assist in meet ng this requirement, t e e ement should provide local data not captured in regional, state, or federal data analysis, including information obtained through community participation or consultation.
Other Relevant Factors: The element must include other relevant factors that contribute tit fair housing issues in the jurisdiction. For instance, the element can analyze historical land use, zoning, governmental and nongovernmental spending including transportation investments, history of lending practices and demographic trends.
Sites Inventory: The element discusses identified sites relative to the TCAC/HCD Opportunity Map at a compositive level but should also address the other components of the assessment of fair housing (e.g., segregation and integration, disproportionate housing need, including displacement risk), identified sites by income group and location, magnitude of the impact and any isolation of the RHNA by income group.
Contributina Factors jpair Housing Issues: The element should re -visit and prioritize contributing factors to fair housing based on the outcomes of a complete analysis.
Contributing factors create, contribute to, perpetuate, or increase the severity of fair housing issues and are fundamental to adequate goals and actions. Examples include community opposition to affordable housing, housing discrimination, land use and zoning laws, lack of regional cooperation, location and type or lack of affordable housing and lack of public or private investment in areas of opportunity or affordable housing choices. The analysis shall result in strategic approaches to inform and connect goals and actions to gate contributing factors to affordable housing.
Strategies and AcItlions: Goals and actions must significantly seek to overcome contributing factors to fair housing issues. Current program actions include the City's already existing strategies to provide adequate sites and do not demonstrate a connection to the fair housing issues and contributing factors identified. This is not adequate to satisfy the requirement for specific and meaningful actions. Program action should be proactive, facilitate meaningful change, and respond directly to the contributil factors to fair housing issues that were identified. Furthermore, the element must includ metrics and milestones for evaluating progress on programs, actions, and fair housing results. The element must add and revise programs based on a complete analysis and connect to prioritized contributing factors to fair housing issues. I City of Downey's 61" Cycle Draft Housing Element Page 2 November 10, 2021
2. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality's housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov.
Code, § 65583, subd. (a)(3).)
Progress in Meeting the RHNA: The City's RHNA may be reduced by the number of new units built since June 30, 2021, but the element must describe the City's methodology for assigning these units to the various income groups based on actual sales price or rent level of the units and demonstrate their availability in the planning period. Specifically, the element credits 28 townhomes (12850 Woodruff Avenue), of which 2 will be affordable to very low-income households. However, it must demonstrate affordability as described above. In addition, the element lists 600 approved units, of which 300 are expected to be affordable to very low-income households, from the Rancho Los Amigos South Campus Specific Plan. The element must address the status of these proposed units, including potential availability in the planning period and demonstrate anticipated affordability as described above.
Realistic CaDatity: The methodology for calculating residential capacity on identified site must account for land use controls, site improvements and typical densities of existing or approved residential developments at a similar affordability level. While the element utilizes various potential unit yields, it must still support these assumptions. For example, for higher -density sites that do not require rezoning, the element assumes 80 percent of potential yield. The element supports this assumption by referring to two high -density developments, one of which dates back to 2014. Further support is needed tojustify this assumption. The element does not clarify what zones these two high -density projects we developed in, or whether density bonus projects such as these are typical of residential development in those zones. The element should demonstrate what specific trends, factors, and other evidence led to the assumptions, including a more holistic view of development trends.
In addition, for sites where zoning allows 100 percent nonresidential uses, this analysis must adjust for the likelihood of 100 percent nonresidential development. For example, the element could describe the underlying zoning, whether 100 percent nonresidential development is allowed in these zones, analyze all development activity in these non- residential zones, how often residential development occurs and adjust residential capacity calculation, policies and program accordingly. The element could also incorporate any relevant programs or policies the City is undertaking to facilitate residential development in zones allowing 100 percent nonresidential uses. "M
City of Downey's 61h Cycle Draft Housing Element Page 3 November 10, 2021
some existing uses, but it must include analysis to demonstrate the potential for additional development. The analysis should consider factors including the extent to which existing uses may constitute an impediment to additional residential development, the City's past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites. For example, the element could clarify what is meant by "potential for intensification" (p. 4-6) and consider additional indicators such as age and condition of the existing structure, presence of expiring leases, expressed developer interest in residential development, low improvement to land value ratio, and other factors.
In addition, because the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower -income households, it must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.
Small Sites: The element identifies many sites at less than a half -acre. These sites are not eligible absent a demonstration that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower -income housing units as projected for the site or unless other evidence is provided. If the inventory indicates some sites can be consolidated it should also provide analysis demonstrating the potential for consolidation. For example, the analysis could describe the City's role or track record in facilitating small -lot consolidation, policies or incentives offered or proposed to encourage and facilitate lot consolidation, conditions rendering parcels suitable and ready for lot consolidation, or information from the owners of each aggregated site.
Accessofy Dwelling Units (AQjjsJ* The element assumes an average of 125 ADLIs per year will be constructed during the planning period, for a total of 1,038 ADUs. The element's analysis and programs do not support this assumption. Based on HCD records and numbers reported in the element, the City is averaging about 24 ADU permits per year since 2018. To include a realistic estimate of the potential for ADUs, the element must reduce the number of ADLIs assumed per year and include analysis, policies and programs as appropriate. The element must commit to monitor ADU production and affordability throughout the course of the planning period and implement additional actions if not meeting target numbers anticipated in the housing element by a certain date.
Additional actions, if necessary, should be taken in a timely manner (e.g., within 6 months). Finally, if necessary, the degree of additional actions should be in stride with the degree of the gap in production and affordability. For example, if actual production and affordability of ADUs is far from anticipated trends, then rezoning or something similar City of Downey's 6th Cycle Draft Housing Element Page 4 November 10, 2021
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[jjFIr()[j[fj6[j •ri .31707 fit ,•I'll, 1-71 TJI d eFMTD�my d I= conditions within the City, it must describe any known environmental constraints or other conditions that could impact housing development on identified sites in the planning period.
In addition, water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower - income households. (Gov. Code, § 65589.7.) The element should discuss compliance with this requirement and if necessary, add or modify programs to establish a written procedure by a date early in the planning period.
Eloctibnit Sites lny�my: For your information, pursuant to Government Code section 65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City must utilize standards, forms, and definitions adopted by HCD.
Please see HCD's housing element webpage aov1qommynit*
development/housing-element/index.shtml#element for a cop 0 y f the form and instructions. The City can reach out to HCD at sitesinventorvghcd.ca.gov for technical assistance.
• Emergency Shelters: The element describes that emergency shelters are permitted in the H-M zone without discretionary action. The element should also describe development standards, including parking requirements, for compliance with statutory requirements. In addition, the element states that no properties are available in the areas zoned to permit emergency shelters. As a result, the element should identify another zone and area to accommodate the need for emergency shelters, including a description of capacity and add or modify Program 2.7 (Address Homelessness) to amend zoning as appropriate.
• Employee Housing: The element must demonstrate zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.) or add or modify programs. Specifically, section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone. Section 17021.6 requires employee housing consisting of no more than 12 units or 36 beds to be permitted in the same manner as other agricultural uses in the same zone.
City of Downey's 6th Cycle Draft Housing Element Page 5 November 10, 2021
3. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)
Land Use Controls: The element must identify and analyze all relevant land -use controls as potential constraints on a variety of housing types, both independently and cumulative with other land -use controls. Further analysis is needed of the City's requirements relate to heights in multifamily zones, particularly the Downtown Core, and parking requirement The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include program to address identified constraints.
Site Plan Revift: The element must analyze the City's Site Plan Review, including approval procedures and decision -making criteria, for their impact as potential constraint on housing supply, cost and approval certainty. Specifically, certain approval findings, such as that a proposed development should "integrate harmoniously", prevent "extreme of dissimilarity or monotony", and focus on the compatibility of the design, appear subjective and should be analyzed as a potential constraint. A full analysis should discus whether approval findings, standards and guidelines provide for development certainty a impact the cost and timing of approvals. The element must add or modify programs as appropriate to address identified constraints.
ZQPing�and Fees TranapgtqM: The element must clarify its compliance with new transparency requirements for posting all zoning and development standards on the City's website and include programs if appropriate.
4. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality's share of the regional housing need in accordance with Government Code section 65584... (Gov. Code, § 65583, subd. (a) (6) J
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City of Downey's 61h Cycle Draft Housing Element Page 6 November 10, 2021
5. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 6558 subd.
While the element quantifies various special needs groups, it must also analyze those housing needs. The analysis should include, but is not limited to, factors such as household income, tenure, housing types, overpayment, trends, zoning and related strategies, available resources and gaps in addressing housing needs. Local officials, special needs service providers, or City/County social and health service providers may be able to assist with information to complete the analysis. For additional information and a sample analysis, see the Building &%#I
families-female-head-household.shtml.
In addition, to supplement analysis and better formulate policies and programs, the element should also identity and analyze persons with disabilities by type (e.g., ambulatory, vision difficulty, cognitive) and permanent and seasonal farmworkers at a county level (e.g., USDA Agricultural Census).
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with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. The program shall include an identification of the agencies and officials responsible for the implementation of the various actions. (Gov.
Code, § 65583, subd.
To have a beneficial impact in the planning period and address the goals of the housinff element, programs must be revised with discrete timelines, objectives and specific and clear commitment to outcomes.
Programs to be revised with discrete timelines (e.g., annually, Spring 2022) include Programs 1.4 (Accessory Dwelling Units), 1.5 (Density Bonus), 2.1 (Special Needs Housing), 2.3 (Affordable Housing Development Incentives), 2.4 (Affordable Housing Technical Assistance), 2.6 (First -Time Home Buyer Assistance), 2.7 (Address Homelessness), 2.8 (County and Regional Partnerships) and 3.5 (Special Needs Housing Law).
City of Downey's 61" Cycle Draft Housing Element Page 7 November 10, 2021
Programs to be revised with objectives include Programs 1.5 (Density Bonus), 2.3 (Affordable Housing Development Incentives), 2.6 (First -Time Homebuyer Assistance) ?nd 3.8 (Energy Conservation).
Programs to be revised with specific and clear commitment to outcomes includ'a • Program 1.3 (Land Use Policy Changes) commits to revise residential standards, needed"; however, the program should specifically commit to making revisions consistent with the feedback of expert practitioners as noted on page 1-8. • Program 2.2 (Housing for Persons with Disabilities) should go beyond reviewing procedures and revise procedures to ensure objective procedures that promote approval certainty and address barriers to housing for persons with disabilities. • Program 3.1 (Lot Consolidation) should commit to additional actions given the lack of progress in the prior planning period (p. 5-8) and reliance on small sites. • Program 3.6 (Definition of Family) commits to evaluate and amend the definition of family if appropriate. Based on the information in the element, the definition of family is a constraint on housing for persons with disabilities and the Program should clearly commit to amend the definition.
• Program 3.9 (Water and Sewer Providers) simply commits to confirm procedures are available for the eight -year planning period. However, confirmation should occur as part of the housing element update and clear commitment should be included to establish procedures, particularly if the City plays a role in granting water and sewer service.
Identify actions that will be taken to make sites available during the planning period with 2ppropriate zoning and development standards and with services and facilities to ,?ccommodate that portion of the city's or county's share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory -built housing, mobilehomes, housing for agricultural employees, supportive housing, single -room occupancy units, emergency shelters, and transitional housing, (Gov. Code, § 65583, subd. (c)(1).) As noted in Finding A2, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition:
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City of Downey's 6th Cycle Draft Housing Element Page 8 November 10, 2021
establish incentives to encourage intended uses consistent with the overlay given allowable uses by the base zoning.
City -owned Sites: The element should consider a schedule of actions to facilitate development of City -owned site(s). Additional actions include outreach with developers, incentives, fee waivers, priority processing and financial assistance.
3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities.
The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities, (Gov. Code, § 65583, subd. (c)(3).)
As noted in Findings A3 and A4, the element requires a complete analysis of potentia' governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or gate any identified constraints.
,C Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act P. 2.8 commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).) Ia 1 0 . . a . a 9 a 0 0 0 0 6 .
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5. Develop a plan that incentivizes and promotes the creation of ADUs that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate -income households. For purposes of this paragraph, "accessory dwelling units"has the same meaning as "accessory dwelling unit"as defined in paragraph (4) of subdivision (i) of Section 65852.2. (Gov. Code, § 65583, subd.
Program 1.4 (Accessory Dwelling Units) generally includes outreach and some other actions but should consider additional commitment to incentives, particularly if the City continues to utilize ADUs toward a significant portion of the RHNA. Examples could include exploring and pursuing funding, modifying development standards and homeowner/applicant assistance tools. In addition, Program 1.4 (Accessory Dwelling Units) should monitor affordability in addition to productions and must commit to take alternative actions beyond incentives if necessary (e.g., rezoning) and by a specified date (e.g., within 6 months).
City of Downey's 6 th Cycle Draft Housing Element Page 9 November 10, 2021
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segments of the community in the development of the Housing Element, and the element shall describe this effort, (Gov. Code, § 65583, subd. (c)(8)) HCD understands the City made the element available to the public two weeks prior its submittal to HCD. By not providing ample opportunity for the public to review and comment on • draft • the element in advance of submission, the City has not yet complied with statutory mandates to make a diligent effort to encourage the public participation in the development of the element. This reduces HCD's •• to consider public • in its review. The availability • the i• to the public and •••• for public comment prior to submittal to HCD is essential to the public process and HCD's review. The City must proactively make future revisions available to the public, including • commenters, prior to submitting • revisions to HCD and diligently consider and address comments, including making revisions to the •• where appropriate. HCD's future review will consider the extent to which the revised element documents how the City solicited, considered, and addressed public comments in the element. The City's consideration • public • must not •• `'• • HCD's findings in this review letter.
City of Downey's 61h Cycle Draft Housing Element Page 10 November 10, 2021
City of Downey -Summary of City Fdita/Respolm to HCD Findings - December 2tro
7.1. Outreach: The aIamentditctrflyev, outreach efforts for the broader housingetormutt, but itshould also incorporate outreach relative to affirmatively furthering fair housing (AFFH), This outreach is particularly important to informing fair housing issues, contributing factors and appropriate goals and actions, Outreach should consider a variety of methods to gather input on the various components of the assessment of fair housing (e,g„ segregation and integration, disparities in access to opportunity, disproportionate housing needs} Chapter 1 has been edited to expand the outreach discussion related to AFFH and components of the A, I- Patterns and Trends: The ahudent reports data regarding the patterns of various socio-econosure } on a ractenstics across a I components of the required analysis (e.g tartn�nd rids :I"gJier -y j ii ce aver, the element should also generally analyze the vartout, 5 4do u^c uaratiki The AFFH analysis has been edited to add:
cllaeaGtcrds 9lrs. An aasnpysgs should generally address patterns at a regional and local level asad imaclit ur petltorne More focal and regional information related to segregation overtime.. Patterns at a regional level must compare conditions at the local level to the rest of the region... This Add information on low- and moderate -income areas of the City and surrounding region including analysis should compare the towilirs, at a county level or other regional louoi such as a Council of Governments, adding Not data to Figure 3,5 where appt¢pitf iate, for the purposes of promoting more inclusive vernmuraities. Patterns at a local level must ® gummary, of findings from local and regional dotal R r segregation and integration address whether certain areas strongly differ from other areas. The analysis should also address any A.dtfittional local and regional data and analysis for RJPCh.Pc and Racially/Ethnically Concentrated coincidence with other components of the assessment of fair housing and local data and knowledge and other Areas of Affluence zelcvato factors as described below,
The AFFH analysis has been edited to add:
A..3. Disparities in Access to Opportunity: The element reports data from the TCAC(HCD Opportunity maps at a e Opportunity access information related to education, environmental justice, transportation, and composite level, but it should also separately report and analyze data, patterns and trends related to education, employment,. tUob onwb`and trarrxpoxRakfirr5,- .The AFFH area! raa h� ,..... _.....-__, ..», _ m..... .�...�.m».o,..... —�
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+- regional data for overcrowding, displacement risk,
e Identification of overlapping coincidence with other components of the assessment A4. Disproportionate Housing Need, Including Displacement Risk: The element describes displacement relative Additional regional comparison for substandard housing to tenure; however, it could also consider information from the HCD AFFH Data Viewer and provide analysis as Summary of findings from local and regional data for segregation and integration '. described al9tPvs;„➢ntclu3in eiverilipuestcoincidence With pthet copipainents of the assessment of A• air hauls it .__ #.. ,�,�„�... .... .. ..............,.. .�_ .-.- »�. '.
A5_ total.Data'az+d Knowledge: The element should incorporate loran data and knowledge qd Itge jiAttrstttaa[p1ti i into the AFFH section, To assist in meeting this requirement, the element should provide local data not captured in regional, state, or federal data analysis, including information obtained through community The AFFH analysis has been edited to add a local knowledge section that addresses related issues ide ntified in the public out reach proca.55 $wp7l aS htsttrrica9 tpottenrt*tadaln'ea*t tsmm�.$d taMitCi}aR&at.§xtorcxSnSu tta4daan�� ....,�..,>._-,m...-.-..,.._.,...,.....�.:...�.........e-.-,.._,.._ A..6,. Other Relevant Factors: 'Ilkvtt +' lAnaatst: must include other relevant factors that contribute to fair hJuam .issues in the jurisdiction.: For instance, the element can analyze historical land use, zoning, governmennongovernmental spending including transportation investments, history of lending practices and deThe AFFH analysis has been edited to add alocal knowledge section that addresses related Issues �. p A7, sites loventory The element discusses Wouniflint.sites relative to the TCAC/HCD Opportunity Map et a coin positive level but should also address the other components of the assessment of Fair housing (eg., segregation and integration, disproportionate housing need, including displacement risk), identified sites by The sites inventory AFFH section is edited to identify areas that the AFFH analysis showed had .incomep'ltxnupand daeaEton, ptirem rxiStotfe of Ehe dtxa aGt'and ary iseaGaYio epFtpte lFvit.#8l hyincome grareap, disptcrpar#kgar'rEc!needs and is 9a.r vnitaer identification to diona d Prioritize Lion of Local Fair Housing
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A.S. Contributing Factors to Fair Housing Issues: The element should. re visit and prioritize contributing factors TEve dSFfia an:9ly'sds kegs ha8°h adtox«d 8U tiuta lden list of related an g Issues
to fair housing based on
the the tioutco es lain complete analysis,
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City fP—ey—Summasy of coy Ed;ueResponse to Hop Findings—Decerrtber2a2x Examples include community opposition to affordable housing,.housing discrimination, land use and zoning laws, lack of regional cooperation, location and type or lack of affordable housing and lack of public or private investment in areas ofopportunmy or affordable housing choices The analysis shall result in strategic sfiiaaA 9lSkrategies and Actions: Goalactions must significantly to overcomet contributing bfactors z44re.
fair
nd housing issues. Current program actions include the City's already existing strategies to provide adequate sites and do not demonstrate a connection to the fair housing issues and contributing factors identified.. This is not adequate to satisfy the requirement for specific and meaningful actions, Program actions should be proactive, :facilitate meaningful change, and respond directly to the contributing factors to fair housing issues that were identified. .Furthermore, the element must include metrics and milestones for evaluating progress on programs, The element (particularly Program 5.2 in Chapter 6) is revised and enhanced with additional program actions, and fair housing results„ The element must add and revise programs based on a complete analysis and actions based on the complete analysis and listing and prioritization of contributing factors to fair housing tt Otm_%ts acoar iwsn Ua— saes
A21 Progress in Meeting i
e RHNA. The City's RHNA maybe reduced by the number of new units built since .June 30, 2021, but the element most describe the City's methodology for assigning these units to the various income groups based on actual sales price or rent level of the units and demonstrate their availability in the Information on the affordability of the two units at 12850 Woodruff Avenue has been added under planning period: Specifically, the element credits 28 townhomes (12850 Woodruff Avenue), of which 2 will be the Approved and Proposed Projects heading in Chapter4,. affordable to very low-income households,. However, it must demonstrate affordability as described above.. In +' Residential development potential in the adopted Rancho Los Amigos South Campus Specific Plan addition, the element lists 600 approved units, of which 300 are expected to be affordable to very low-income has been moved from the Approved and Proposed Projects section to the Sites Inventory Section, households, from the Rancho Los Amigos South Campus Specific Plan:. The element must address the status of The revisions address the status of the proposed units, including potential availability in the .'these proposed units, including potential availability in the planning period and demonstrate anticipated planning period and as well as information on recent development inquiries,. atfzrrdabiNty. as described above.. ..... i s
A 2,2, Realistic Capacity: The methodology for calculating residential capacity on identified sites must account Chapter 4 is edited to add:
for land use controls, site improvements and typical densities of existing or approved residential developments w text to clarify location of two affordable projects in the Downtown Downey Specific Plan at a similar affordability level.. While the element utilizes various potential unit yields, it must still support these Development interest in the two specific, plan areas assumptions, For example, for higher -density sites that do not require rezoning, the element assumes 80 a Additional examples of multifamily development to support the use of 80%of maximum allowed percent of potential yield.. The element supports this assumption by referring to two high -density density to calculate realistic capacity,. Recent project trends show that the density assumption is developments, one of which dates back to 2014, Further support is needed to justify this assumption., The realistic„ element does not clarify what zones these two high -density, projects were developed in, or whether density bonus projects such as these are typical of residential development in those zones... The element should Also, Chapter 4 is edited to clarify that the use of densities significantly lower than what is allowed demonstrate what specific trends, factors, and other evidence led to the assumptions, including a more holistic accounts for the potential development of mixed uses. As part of the City's Housing Element view of development trends. 'implementation (Program 1..3), the City is increasing allowable density in the R-3 zone to allow up to 40 units per acre and in the process adjust development standards, accordingly,: Program 13 also includes an In addition, for sites where zoning allows 100 percent nonresidential uses, this analysis must adjust for the 'action item to review and revise residential developments standards including building height limits in the likelihood of 100 percent nonresidential development,. For example, the element could describe the underlying ,R-3 zoning district and to identify and codify incentives to encourage development of residential uses in zoning, whether 100 percent nonresidential development is allowed in these zones, analyze all development areas with the new Residential Overlay and Mixed -Use zone,. activity in these non-residential zones, how often residential development occurs and adjust residential capacity calculation, policies and program accordingly, The element could also incorporate any relevant As part of the General Plan and Zoning update, The City will also adopt additional incentives for projects programs or policies the City is undertaking to facilitate residential development in zones allowing 100 percent that include lot consolidation as away of adding more residential units to a project (Program 13),. nonresidentia l oases:. -.
...�..._...._..,.,. .....,...... ....... _ .... _ _...,,ma.....-- ........_, ..,,._.....- _..�.....,w�..._._,w_, A 2 3- Suit. bility of Noneaca nt Sitesi The ere anent mric imvlude ah analysis demonstrating the motenti.f for redevelopment of n.nv.cant sites'To address this requirement, the element states that sites were selected based on "potential capacity increase available to prayer ownerss' and on locti1 46t1 andm x�.4to e?",, )p 4 Chapter 4 is edited to'
City in HOD Findings- DeCoarbE,2021
the a lament also generally describes some existing uses, but it must retire analysis to demonstrate the Refine the site mven to ry and focus on sites that meet the existing use, land va I ue, and in lanaffiradon potential for additional development.The analysis should consider factors including the extent to which existing criteria stated in the Chapter, As part oft he revision process several sites were removed and replaced with uses may constitute an innizedimento, additional residential development, the City's past "penance with more suitable Miss
converting existing Lives to higher density residential development, the current market demand for the existing use,an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent The City will include findings in the adopting resolution for the Housing Element that indicates that redevelopment of the site for additional residential development, development trends, market conditions, and existing uses are not an impediment to additional residential development and will likely discontinue in regulatory or other incentives or standards to encourage additional residential development on these sites,. For the planning period,
example, the element could clarify what is meant by "potential for intensification" (is, 4-6) and consider additional indicators such as age and condition of the existing structure, presence of expiring leases, expressed developer interest in residential development, low improvementto land value ratio, and other factors, In addition, because the housing element relies upon nourvacent sites to accommodate more than 50 percent of the RHNA for lower -income households, it must demonstrate existing uses are not an impediment to additional residential development and will likely dincentirms, in the planning period, (Go, Code, § 65593,2, mbd (g)(2)f Absent findings (e,&, adoption resolution) based on substantial evidence, the existing uses will be presumed to ameare additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA,
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Consistent with updated Housing Element law (Assembly Bill 1397) related to the suitability ofserall and large sites, the lower -income sites inventory presented in this section is predominately limited to parcels between 0.5 and 10 acres in size, as HCD has indicated these size parameters beat accommodate lower - income housing need, In this inventory, mnly40 of the 424 parcels that make up the sites inventory are less than half an acre in size (9%) and they are included only if they are part of larger site that function as one use (for "ample, a single structure or use over more than I parcel) and/or the parcels are adjacent and under common ownership,
A2,4. Small Sites: The element identifies many sites at less than a half -acre. These sites are not eligible absent a demonstration that sites of equivalent size were successfully developed during the prior planning period for an Several sites comprising one or more parcels are less than one-half acre In size, These sites are included equivalent number of lower -income housing units as projected for the site or unless other evidence is provided, because the multiple parcels function as one site, such as a structure and its attached, surface, parking lot '..If the inventory indicates some sites can be consolidated it should also provide analysis demonstrating the or a single structure located on multiple parcels, Small sites (less than one-half acre) meeting the default potential for consolidation, For example, the analysis could describe the City's role or track record in facilitating density standard are NOT credited toward the lower -income Rl INA, Lot consolidation assumptions in the small -lint consolidation, policies or incentives offered or proposed to encourage and facilitate lot consolidation, sites inventory are hunted,
conditions rendering parcels suitable and ready for lot consolidation, or information from the owners of each -PItgregated site.
Text in Chapter 4 has been edited to clarify thesepoints, A 2,5, Accessory Dwelling Units (ADUs): The element @55Wmex an average of 125 AEgJz per year will be constructed during the planning period, for a total of 1,038 ADUC, The element's analysis and programs do not support this assumption, Based on HCD records and numbers reported in the element, the City is averaging about 24 ADU permits per year since 2018, To include a realistic estimate of the potential for AOLJc, the element must reduce the number ofADUC assumed per year and include analysis, policies and programs as The ADU portion of the sites inventory is edited to update the number of ADU permits provided in 2021 appropriate, The element must commit to monitor ADU production and affordability throughout the course of I. of October)„ The revised estimates for the planning period account for pent-up demand at the stareof the planning period and implement additional actions if not meeting target numbers anticipated in the housing the planning period and the, potential leveling off of ADU development in the later part of the planning I, aL _tL _r
.!I,M,nt actions, if necessary, shouldtimely manner. , ��hbr 6 period A very conservative estimate of development under the provisions of 513 9 is also added.:
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City of Downey-5rine oyof City EditsfResponse to HAD Findings—December202I months),, Finally, if necessary, the degree of additional actions should be in stride with the degree of the gap in production and affordability. For example, if actual production and affordability of ADUs is far from anticipated trends, then rezoning or something similar would bean appropriate action:. If actual production and affordability is near antcipated trends, the, measures like utreach and marketing might be more appropnaYe ,... ,.
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The discussion under the Site Infrastructure and Constraints include information on environmental hazards (earthquakes, liquefaction, landslides, flooding). None of the parcels identified in the residential sites inventory are constrained by sensitive habitat or (contamination that would prohibit developers from building,. The City requires engineering reports to .'establish appropriate design standards and mitigation measures taken to alleviate any identified hazards A 2,:6;:. Environmental Constraints: While the clement generally describes a few environmental conditions within kHowever, the necessity offices reports is offset by the need for public safety and welfare, and thus the the City, it most describe any known environmental constraints or other conditions that could impact housing City does not consider the reports a constraint to housing development.::
development on identified sites in the planning period. ,.,... _... _ ........®.... ...
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Additional information for water and sewer capacity is added to the element under the "Site 3' Infrastructure and Environmental Constraints" heading in Chapter 4,. To accommodate the 2021-2029 A.27,. Infrastructure: The element generally describes infrastructure,. However, it must also demonstrate RHNA of over 6,500 residential units, within three years of adopting this Housing Element, the City will sufficient total water and sewer capacity (existing and planned) to accommodate the regional housing need by undertake a series of land use actions to increase development potential,. These proposed land use actions community plan area..
will require thorough infrastructure and environmental review, and any additional constraints will be identified at the time the actions are taken, along with any necessary mitigation measures to address In addition, water and sewer service providers must establish specific procedures to grant priority water and `infrastructure system and service provision,.
sewer service to developments with units affordable to lower -income households.. (Gov.: Code, § 65589,7.r) The element should discuss compliance with this requirement and if necessary, add or modify programs to establish 'Program 3.9, included in the Draft Housing Element submitted to the Department, is already in place to a written procedure by a date early m the plamm� penod.� _ _ _ address the required actions of the C tjs water and sewer service providers,.. m.
A2;8, Electronic Sites inventory:For your to Government Code section th y 65583, 3, the City must submit an electronic sites inventory with its adopted housing element.. The City must utilize standards, forms, and definitions adopted by NICE,. Please see HCD's housing element webpage at https://www..hcd,ca.govjcommunity-development/housing-element/index,shtmiffelement for a copy of the form and tlns¢AaeSi� n5 Tite City And reach our to HCD rvt tltemfnv ptDa hctf.c a. v for technical ie, assstanc. .....�..
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_R2.9 Zoning fora Variety of Housing Types:
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® Emergency Shelters: The element describes that emergency shelters are permitted in the H-M zone without I
discretionary action.. The element should also describe development standards, including parking requirements, for compliance with statutory requirements.. In addition, the element states that no properties are available in . the areas zoned to permit emergency shelters., As a result, the element should identify another zone and area The element has been edited to describe development standards, including parking requirements, for to accommodate the need for emergency shelters, including a description of capacity and add or modify compliance with statutory requirements.. As a result of this edit, a new action item is added to Program 35 Program 2,.7 (Address Homelessness) to amend zoning as appropriate, to identify the M-2 zone for emergency shelter development and to ensure compliance with State law, including addressing the City's distancing requirements.:
Employee Housing: The element must demonstrate zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 at saiT) or add or modify programs, Specifically, section 17021.5 requires A heading for Employee Housing is added to Chapter 3 under Zoning for a Variety of Housing Types and employee housing for six or fewer employees to be treated as a single-family structure and permitted in the Program 1..3 is updated to add an action item committing to update the Zoning Code to define employee same manner as other dwellings of the same type in the same zone,. Section 17021.6 requires employee housing and to clarify that employee housing serving six or fewer employees shall be deemed a single - sing consisting of no more than 12 units or 36 beds to be permitted in the same manner as other he.`
family structure and shall be, subject to the same standards for a single-family residence in the save, zone, a;Nculhual uses in the same zone
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4 City of powney-Summary of ttt}! @dits/Res(tonse Po diCD Rndtngs - Decensber 2021 Parking: Tables 3.3, 3,5, and Mare updated to include parking standards;. Following Table 3..6 is a new heading, "Parking for I�
A3 1, Land Use Controls: The element must identify and analyze all relevant land -use controls se potential Multi -Family Developments' which addresses parking in the R-3 zone and in the Downtown Downey constraints on a variety of housing types, both independently and cumulatively with other land -use controls, Specific Plan (DDSP) area: Parking reductions for uses in the DDSP and for senior and affordable housing Further analysis is needed of the City's requirements related to heights in multifamily zones, particularly the are addressed.
Downtown Core, and parking requirements„ The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs Building Heights: Chapter 3 under the Residential Development Standards heading is updated to add to address identified constraints, p� e� mm� -.� '.
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building he hts in the R 3 zone and in the Downtown DowneySpecific is Plan area,. information on. rc.
A 3,2, Site Pfan Review: The element must ame iyze, the CiSo's Site Plan Review, including approval procedures and decision -making criteria, for their impact as potential constraints on housing supply, cost and approval (Chapter 3 under the Site Plan Review heading is updated to include more information on the site plan certainty.. Specifically, certain approval findings, such as that a proposed development should "integrate (review process and Program 1,3 is updated to add that the City will update development standards for harmoniously", prevent "extremes of dissimilarity or monotony', and focus on the compatibility of the design, '':. mu Iti-to mily projects that will not require the Site Plan Review process and allow for this review to be appear subjective and should be analyzed as a pate nheI constraint,. A full analysis should discuss whether '.':
tomplated administratively without discretionary approval,: In addition, Program 3.3 is included and approval findings, standards and guidelines provide for development certainty and impact the cost and timing indicates that the City will adopt objective design standards to ensure that the City can provide local of approvals.. The element must add or modif pro rams as appropr late to address identified constraints, ...
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A 3;3, Zoning and Fees Transparency: The element clarify its compliance with new transparency *; Information about online access to the City's development process information and resources is 'requirements for posting all zoning and development standards on the Citys website and include programs if added to Chapter 3 under the Residential Development Standards heading appro Hate
+....The loratianof th Cit 's fee is added at the end of th Fees and Exactions section in Chapter 3 A.41: The element must include analysis of requests to develop housing at densities below those anticipated in the site inventory. The element notes that the City does not discourage developers who choose to develop at The discussion under Government Code 65583(a)(6) Development Analysis is edited to add more detail lower densities, but it still roust analyze any such requests and address any hinderances on the construction of and experiences with lower density requests and Programs 1.S is edited to add additional actions to the RHNA,
ancoura a eve lopmentathigherdensities..
_
,.. While the le ement quantifies various special needs graups, it must al ASl. so analyze the,. housing needs.: The 'analysis should include, but is not limited to, factors such as household income, tenure, housing types, 'overpayment, trends, zoning and related strategies, available resources and gaps in addressing housing needs.
Chapter 2 under the Special Needs is edited to add:
Local officials, special needs service providers, or City/County social and health service providers may be able to Information on persons with disabilities by type (eg,:, ambulatory, vision difficulty, cognitive) as assist with information to complete the analysis. For additional information and a sample analysis, see the well as resources.,
Building Blocks atiyM.kG'ffy>wycf'ttdf m ty....: tr+t?'y5 +d ,. w.,'}yif1,Y8„t`¢„M f q.lujtrig hlem�stes rB 9+t+ia _s Rae, .T„. o Resources for seniors.
families-female-head-household.shtml.
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a Housing stock, income and poverty information related to large households.
The number of farmworkers at a county level
In addition, to supplement analysis and better formulate policies and programs, the element should also Issues, number of households with children, change since 2014, resources for female headed "identity and analyze persons with disabilities by type psg,.ambulatory, vision difficulty, cognitive) and households„
permanent a id seasonal farmworkers at a county level (e, USDA Agricultural Census}LLLL µ 1 .�.,._, .._ ,—. ..... .. ,._.w...
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&2.1, To have a beneficial impact in the planning period and address the goals of the housing element, -
;programs must be revised with discrete timelines, objectives and spanific and clear commitment to outcomes. + Program 13 is edited to change "Review and, if needed, revise" to "revise" as it relates to development standards (minimum lot area requirements and building height limits in the R-3 Programs to be revised with discrete timelines (e,.g„ annually, Spring 2022) include Programs 1,4 (Accessory zoning district and minimum unit sizes for all residential development),; Dwelling Units), 1.5 (Density Bonus), 2,1 (Special Needs Housing), 2.3 (Affordable Housing Development + Program 1A is edited to is edited to add more information on ADD resources such as the one -stop 'lIncentives), 2.4 (Affordable Housing Technical Assistance), 2,:6 (First -Time Home Buyer Assistance), 2.7 (Address webpage and to add that if production falls below levels anticipated in the Housing Element, the
2.8 (County and Regional Partnerships) and 3,5 (special Needs Housm Law .
Homelessness),:....,,�.,.�...�.-.�,,._�..� _. _. - ......,..: .�,.....__--..... .Gifu wI11 evaluate and ensure that adequate sites are available thraugh the adopted sites inventory, ® _�_............. __..,.,.,...... .....�....... .e.,,,...,.....®.�........
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City fQowneY—Summary of City EdtPs/Fesponse to WD11adho—Daveriss,2021
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or it will identify add rhona I sites to ensured continued provision of adequate sites, Additional Programs to be revised with objectives include Programs 1,5 (Density Ban us), 23 (Affordable Housing action items such as establishing ADU office hours are added - Development Incentives), 2,6 (First -Time Home buyer Assistance) and 3,8 (Energy Conservation), . Program 1.5 is edited to add additional action items, objectives, and timeframes . Program 2,1 is edited to add a more specific timeframe Programs to be revised with specific and clear commitment to outcomes include:
* Program 2 2 is edited to remove the "review" action and commit to specific action . Program 23 is edited to add objectives and a specific timeframe Program 1,3 (Land Use Policy Changes) commits to revise residential standards, "if needed"; however, the . program 214 is edited to add specific timeframe details program should specifically commit to making revisions consistent with the feedback of expert practitioners as , Program 2 ' 6 is edited to add objectives and a specific thunframes noted on page 1-9,
. Program 2 7 is edited to add specific timeframe, details - Program 2,2 (Housing for Persons with Disabilities) should go beyarial reviewing procedures and revise - Program 2,8 is edited to add specific timeframe details procedures to ensure objective procedures that promote approval certainty and address barriers to housing for * Program 3,1 is edited to commit to more specific action and a new timeframe is added persons with disabilities,
Program 3,5 is edited to add action items related to zoning for emergency shelter and employee - Program 3,1 (Lot Consolidation) should commit to additional actions given the lack of progress in the prior housing and specific timeframe details
planning period (p, 5-8) and reliance on small sites,
. Program 3,6 is edited to provide more definitive action related to the mod fication/replacenne at of ® Program 3,6 (Definition of Family) commits to evaluate and amend the definition of family if appropriate.the City's definition of "family',
Based on the information in the element, the definition of family is a constraint on housing for persons with . Program 3.8 is edited to add objectives and bureframes disabilities and the Program should clearly commit to amend the definition, # Program 3,9 is edited to clarify that the City (which provides water and sewer services, does net ® Program 3,9 (Water and Sewer Providers) simply commits to confirm procedures are available for the eight- have procedures in place to grant priority for the provision water and server services to year planning period. However, confirmation should occur as part of the housing element update and clear proposed developments that include units affordable to lower -income households as required by commitment should be included to establish procedures, particularly if the City plays a role in granting water law, An action item to address this is added as is a timeframe, and sewer service...
B, 12 A, noted in Finding AS, the element does not include a complete site analysis, therefore, the adequacy of ................
sites and zoning were not established, Based on the results of complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types,. In addition:
. Program 1-1 is edited to clarify by -right and minimum densities consistent with Government Code sections 65583,2 and reflects edits to the, sites inventory.
Program 1,1 (Adequate Sites) commits to rezoning and satisfies many requirements, but it should also clarify . Program 1.3 is edited to add that the City will identify and codify incentives to encourage by -right and minimum densities consistent with Government Code sections 65583.2, subdivisions (h) and (i) and development residential uses in areas with the new Residential Overlay and Mixed -Use vens and commit to establish incentives to encourage intended uses consistent with the overlay given allowable uses by to change "Review and, if needed, revise" to "revise" as it relates to development standards the base zoning,
(minimum lot area requirements and building height limits in the R-3 zoning district and minimum ® City -owned Sites: The element should consider a schedule of actions to facilitate development of City -owned unit sizes for all residential development)
shale), Additional actions include outreach with developers, incentives, fee waivers, priority processing and Program 24 is edited to add actions related to development on on City -owned sites, financial assistance
Page - 6
HCD Findings from 11J10/21 Letter!tNtlimfy
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DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
MMyjLd.ca_qov
November 10, 2021
Aldo Schindler, Director
City of Downey
11111 Brookshire Avenue
Downey, CA 90241
700-r-TRAVATOWINITATOT -
• �• - 1 1III 1 6, 1 11 1 1
Thank you for submitting the City of Downey's (City) draft housing element received for review on September 15, 2021. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation on November 8, 2021 with Senior Planner Crystal Landavazo, Associate Planner Irving Anaya, and consultant, Diana Gonzalez, of MIG. In addition, HCD considered comments from Californians for Homeownership pursuant to Government Code section 65585, subdivision (c).
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Element Law.
Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criterion. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD's Affordable Housing and Sustainable Communities programs; and HCD's Permanent . - 'I'LL ............. ........ -6 & , 0
Aldo Schindler, Director
requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.
For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor's Office of Planning and Research at:
http:gMr.ca.aov/docs/OPR Appendix C final.pdf and
httD://dDr.caAoV/d•�iha[,
We are committed to assist the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Colin Cross, of our staff, at cohmcrossQhcd,)cagov.
Sincerely,
Paul McDougall
140WA9129 0
The following changes are necessary to bring the City's housing element into compliance with.
Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.
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1. Affirmatively furtherflng] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division I of Title 2 ... shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, it
Outreach: The element describes outreach efforts for the broader housing element, but it should also incorporate outreach relative to affirmatively furthering fair housing (AFFH).
This outreach is particularly important to informing fair housing issues, contributing factors and appropriate goals and actions. Outreach should consider a variety of methods to gather input on the various components of the assessment of fair housing (e.g., segregation and integration, disparities in access to opportunity, disproportionate housing needs) and may utilize information from the 2020 Analysis of Impediments to Fair Housing Choice.
EpAgms and ILends. The element reports data regarding the patterns of various socio- economic characteristics across all components of the required analysis (e.g., segregation and integration, access to opportunity, displacement). However, the element should also generally analyze the various socio-economic characteristics. An analysis should generally address patterns at a regional and local level and trends in patterns over time. Patterns at a regional level must compare conditions at the local level to the rest of the region. This analysis should compare the locality at a county level or other regional level such as a Council of Governments, where appropriate, for the purposes of promoting more inclusive communities. Patterns at a local level must address whether certain areas strongly differ from other areas. The analysis should also address any coincidence with other components of the assessment of fair housing and local data and knowledge and other relevant factors as described below.
City of Downey's 6th Cycle Draft Housing Element Page I November 10, 2021
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Disproportionate Housing Need, Including Displacement Ri,sk- The element describes displacement relative to tenure; • it could also consider information from the HCD AFFH Data Viewer and provide analysis as described above, including overlapping coincidence with other components of the assessment of fair housing.
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,QLher Rplgvant Factors: The element must include other relevant factors that contribute to fair housing issues in the jurisdiction. For instance, the element can analyze historical land use, zoning, governmental and nongovernmental spending including transportation investments, •. of lending practices and demographic trends.
Sites lnvento!y, The element discusses identified sites relative to the TCAC/HCD Opportunity Map at a compositive level but should also address the other components of the assessment of fair housing (e.g., segregation and integration, disproportionate housing need, including displacement risk), identified sites by income group and location, magnitude of the impact and any isolation of the RHNA by income group.
ContribubngfAgLors to Fair Housing��-, The element should re -visit and prioritize contributing factors to fair housing based on the outcomes of a complete analysis.
Contributing factors create, contribute to, perpetuate, or increase the severity of fair housing issues and are fundamental to adequate goals and • Examples include community opposition to affordable housing, housing discrimination, land use and zoning laws, lack of regional cooperation, location and type or lack of affordable housing and lack • public or • investment in areas of opportunity • affordable housing choices. The analysis shall result in strategic approaches to inform and connect goals and actions to gate contributing I• to affordable housing.
Stt&gies and Actiom Goals and actions must significantly seek to overcome contributing factors to fair housing issues. Current program actions include the City's already existing strategies to provide adequate sites and do not demonstrate a connection to the fair housing issues and contributing factors identified. This is not •-i to satisfy the requirement for ♦p and •i actions. Program actions should be proactive, facilitate meaningful change, and respond directly to the contributin-g factors to fair housing issues that were identified. Furthermore, the element must include metrics • • for evaluating progress • programs, actions, and fair housing results. The element must add and revise programs based on a complete analysis and connect to prioritized contributing factors to fair housing issues.
City of Downey's 6th Cycle Draft Housing Element Page 2 November 10, 2021
inventory • land suitable and available for •' development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the • period to meet the locality's housing -• • a designated • level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov, Code, ♦ 65583, subd.
Progress in Mgq!j11g the RHNA: The City's RHNA may be reduced by the number of ne units built since June 30, 2021, but the element must describe the City's methodology assigning these units to the various income groups based on actual sales price • rent level of the units and demonstrate their availability in the planning period. Specifically, t element -•I 28 townhomes (12850 Woodruff Avenue), of which 2 will •` affordable• very low-income households. However, it must demonstrate affordability as described above. In addition, the element lists 600 approved units, of which 300 are expected to b affordable to very low-income households, from the Rancho Los Amigos South Campu Specific Plan. The element must address the status of these proposed units, including potential availability in the planning period and demonstrate anticipated affordability as described above.
Realistic Capacily- The methodology for calculating residential capacity on identified sites must • for land use controls, site improvements and typical densities • existing •. approved residential developments at a similar affordability level. While the element utilizes various potential unit yields, it must still support these assumptions. For example, for higher -density sites that do not require rezoning, the element assumes 80 percent of potential yield. The element supports this assumption by referring to two high -density developments, one of which dates back to 2014. Further support is needed to justify this assumption. The element does not clarify what zones these two high -density projects werit developed in, or whether density bonus projects such as these are typical of residential development in those • The element should demonstrate what specific trends, factors, and •. evidence led to the assumptions, including a more • view •, development trends.
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MIST aaj1FsY=hFffMffMooa OT 1 #111, peluerif Flunresidenflai aeveiopmenl. For exampleMe dlement could describe the underlying zoning, whether 100 percent nonresidential :�evelopment is allowed in these zones, analyze all development activity in these non- residential zones, how often residential development occurs and adjust residential .•. calculation, •• and program accordingly. The element could also incorporatc 2ny relevant programs or policies the City is undertaking to facilitate residential ��evelopment in zones allowing 100 percent nonresidential uses.
Suitability of L�onvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. To address this requirement, the element • I IZI I • • IS MW I I Lei I IN 11 Lip 974A big I I • M qb,1;&-MJ pim MIMI I 1ZX4 U.-d I I L-711 I W, I kaeAs [Z] 11.73 rt I I vae [.-Mel I I• City of Downey's 6th Cycle Draft Housing Element Page 3 November 10, 2021
some existing uses, but it must include analysis to demonstrate the potential for additional development. The analysis should consider factors including the extent to which existing uses may constitute an impediment to additional residential development, the City's past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites. For example, the element could clarify what is meant by "potential for intensification" (p. 4-6) and consider additional indicators such as age and condition of the existing structure, presence of expiring leases, expressed developer interest in residential development, low improvement to land value ratio, and other factors.
In addition, because the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower -income households, it must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.
Small Sites- The element identifies many sites at less than a half -acre. These sites are not eligible absent a demonstration that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower -income housing units as projected for the site or unless other evidence is provided. If the inventory indicates some sites can be consolidated it should also provide analysis demonstrating the potential for consolidation. For example, the analysis could describe the City's role or track record in facilitating small -lot consolidation, policies or incentives offered or proposed to encourage and facilitate lot consolidation, conditions rendering parcels suitable and ready for lot consolidation, or information from the owners of each aggregated site.
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since 2018. To include a realistic estimate of the poten�iallfor ADUs, the element must reduce the number of ADUs assumed per year and include analysis, policies and programs as appropriate. The element must commit to monitor ADU production and . . . . . . . . . .
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14 V4 I IL40 [MI A rA I If I IQ; M R I i ia;mpiv i w-n Lei i in i ne mi ernirdusp, 01 Op!I line - go 0 0 0 6 6 - - Environmental Constraints- While the element generally describes a few environmental conditions within the City, it must describe any known environmental constraints or other conditions that could impact housing development on identified sites in the planning period.
Infrastructure: The element generally describes infrastructure. However, it must also demonstrate sufficient total water and sewer capacity (existing and planned) to accommodate the regional housing need by community plan area.
In addition, water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower - income households. (Gov. Code, § 65589.7.) The element should discuss compliance with this requirement and if necessary, add or modify programs to establish a written procedure by a date early in the planning period.
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65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City must utilize standards, forms, and definitions adopted by HCD.
Please see HCD's housing element webpage at httr)s�,#www�hcd.ca,a�ovkommuriitv- og)lglggplgtit/hous�ino-oldmentlindex.shtthlftlemeiit for a copy of the form and instructions. The City can reach out to HCD at sitesinventory0hcdtaxiov for technical assista-tice.
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• Emergency Shelters- The element describes that emergency shelters are permitted in the H-M zone without discretionary action. The element should also describe development standards, including parking requirements, for compliance with statutory requirements. In addition, the element states that no properties are available in the areas zoned to permit emergency shelters. As a result, the element should identify another zone and area to accommodate the need for emergency shelters, including a description of capacity and add or modify Program 2.7 (Address Homelessness) to amend zoning as appropriate.
• Employee Housing.- The element must demonstrate zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.) or add or modify programs. Specifically, section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone. Section 17021.6 requires employee housing consisting of no more than 12 units or 36 beds to be permitted in the same manner as other agricultural uses in the same zone.
City of Downey's 6th Cycle Draft Housing Element Page 5 November 10, 2021
C An analysis of ••' and actual •i constraints upon the maintenance, improvement, or development of housing '• all income levels, including the types • housing identified in paragraph (1) •` subdivision (c), and for persons with disabilities identified in the analysis pursuant to paragraph (7), including land use controls, buildin codes and their enforcement, site improvements, fees and • exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, sub Land Use Controls: The element must identify and analyze all relevant land -use controls as potential constraints on a variety of housing types, both independently and cumulative t
with other land -use controls. Further analysis is needed of the City's requirements relate '.• heights in multifamily zones, particularly the Downtown •I:` and parking `•...
The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include program to address identified constraints.
Site Plan RgyjqW- The element must analyze the City's Site Plan Review, including approval procedures and decision -making criteria, for their impact as potential constraints • housing supply, cost and approval certainty. Specifically, certain approval findings, such as that a proposed development should "integrate harmoniously", prevent "extremes • • • monotonyand • on the compatibility of the design, appear subjective and should be analyzed as a potential constraint. A full analysis should discuss whethe Mroval findints standards and �yuidelines -#,rovide • develotment certainto and impact the • and timing • approvals. The element must .•• • •i programs as appropriate to address identified constraints.
Zonlha and Fees TW��Mpgy- The element must clarify its compliance with new transparency requirements for posting all zoning and development standards on ths, City's website and •'.e programs if appropriate.
4. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality's share of the regional housing need in accordance with Government Code section 65584... (Gov. Code, § 65583, subd. (a) (6).)
City of Downey's 6th Cycle Draft Housing Element Page 6 November 10, 2021
5. Analyze any •' housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads •:
households, and families and persons in need of emergency shelter. (Gov. Code, § 6558 subd.
While the element quantifies various special needs groups, it must also analyze those housing needs. The analysis should include, but is not limited to, factors such as household income, tenure, housing types, overpayment, trends, zoning and related strategies, available resources and gaps in addressing housing needs. Local officials, special needs service providers, or City/County social and health service providers may be able to assist with information to complete the analysis. For additional information and a sample analysis, see the Building raw ilies-fe-ti;ale-Wead-Wousei�old.sWt-itl.
In addition, to supplement analysis and better formulate policies and programs, the element should also identity and analyze persons with disabilities by type (e.g., ambulatory, vision difficulty, cognitive) and permanent and seasonal farmworkers at a county level (e.g., USDA Agricultural Census).
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Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy i•'. when available. The program shall include an identification of the agencies and officials responsible • the 1• • the various actions. (Gov.
Code, ♦ 65583, subd.
To have a beneficial impact in the planning period and address the goals of the housing element, programs must be revised with discrete timelines, objectives and specific and clear commitment to outcomes.
Programs to be revised with discrete timelines (e.g., annually, Spring 2022) include Programs 1.4 (Accessory Dwelling Units), 1.5 (Density Bonus), 2.1 (Special Needs Housing), 2.3 (Affordable Housing Development Incentives), 2.4 (Affordable Housi Technical Assistance), 2.6 (First -Time Home Buyer Assistance), 2.7 (Address Homelessness), 2.8 (County and Regional Partnerships) and 3.5 (Special Needs •
City of Downey's 6 th Cycle Draft Housing Element Page 7 November 10, 2021
Programs to be revised with objectives include Programs 1.5 (Density Bonus), 2.3 (Affordable Housing Development Incentives), 2.6 (First -Time Homebuyer Assistance) and 3.8 (Energy Conservation).
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• Program 1.3 (Land Use Policy Changes) commits to revise residential standards, "if needed"; however, the program should specifically commit to making revisions consistent with the feedback of expert practitioners as noted on page 1-8. • Program 2.2 (Housing for Persons with Disabilities) should go beyond reviewing procedures and revise procedures to ensure objective procedures that promote approval certainty and address barriers to housing for persons with disabilities. • Program 3. 1 (Lot Consolidation) should commit to additional actions given the lack of progress in the prior planning period (p. 5-8) and reliance on small sites. • Program 3.6 (Definition of Family) commits to evaluate and amend the definition of family if appropriate. Based on the information in the element, the definition of family is a constraint on housing for persons with disabilities and the Program should clearly commit to amend the definition.
Program 3.9 (Water and Sewer Providers) simply commits to confirm procedures are available for the eight -year planning period. However, confirmation should occur as part of the housing element update and clear commitment should be included to establish procedures, particularly if the City plays a role in granting water and sewer sery ice.
2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city's or county's share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory -built housing, mobilehomes, housing for agricultural employees, supportive housing, single -room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).) I _1&
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City of Downey's 6th Cycle Draft Housing Element Page 8 November 10, 2021
establish incentives to encourage intended uses consistent with the overlay giver allowable uses by the base zoning.
City -owned Sites.- The element should consider a schedule of actions to facilitate development of City -owned site(s). Additional actions include outreach with developers, incentives, fee waivers, priority processing and financial assistance.
3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities.
The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd.
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governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.
4. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (q)(5).) 1"161"M
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5. Develop a plan that incentivizes and promotes the creation of ADUs that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate -income households. For purposes of this paragraph, "accessory dwelling units" has the same meaning as "accessory dwelling unit" as defined in paragraph (4) of subdivision (i) of Section 65852.2. (Gov. Code, § 65583, subd.
Program 1.4 (Accessory Dwelling Units) generally includes outreach and some other actiorE but should consider additional commitment to incentives, particularly if the City continues t1l utilize ADUs toward a significant portion of the RHNA. Examples could include exploring a pursuing funding, modifying development standards and homeowner/applicant assistance tools. In addition, Program 1.4 (Accessory Dwelling Units) should monitor affordability in I
addition to ductions and must commit to take alternative actions beyond incentives if necessary (e.g., rezoning) and by a specified date (e.g., within 6 months). pro
City of Downey's 6th Cycle Draft Housing Element Page 9 November 10, 2021
C(ty of Downey -Summary of City &Ue,1Response to Hco Findings - Derember 2022 "Outreach: The element describes outreach efforts for the broader housing element, but it should also incorporate outreach relative to affirmatively furthering fair housing (AFFH):,. This outreach is particularly important to informing fair housing issues, contributing factors and appropriate goals and actions,. Outreach should consider a variety of methods to gather input on the various components of the assessment of flair leasingy e segregation and inte ration, disparities in apccess to opportunity, g ) g,g p pportunit ,disproportionate ousin needs)
Chapter ter 1 has been edited to
p expand the outreach discussion related to AFFH and components of the and ma utilize information from the 2d2P Anal sis ofm eb rudents to Fair Housingholes assessment ^
AA, Patterns and Trends The element reports data regardingthe patterns of various socio-economic €g characteristics across all components of the required analysis (e g., sd ru al{uarl arltH M15t1* r,11{onaccess to e 2tlTatnkiy, rdda.+;S�isrvmea7t), However, the element should also generally analyze the various socks -economic The AFFH analysis has been edited to add:
characteristics, An analysis should generally address patterns at a regional and local level and trends in patterns More local and regional information related to segregation overtime. Patterns at a regional level must compare conditions at the local level to the rest of the region., This Add information on low- and moderate -income areas of the City and surrounding region including analysis should compare the locality at a county level or other regional level such as a Council of Governments, adding LMI data to Figure 3..5
where appropriate, for the purposes of promoting more inclusive communities.: Patterns at a local level must • Summary of findings from local and regional data for segregation and integration address whether certain areas strongly differ from other areas,. The analysis should also address any ® Additional local and regional data and analysis for RIECAPs and Racially/Ethnically Concentrated coincidence with other components of the assessment of fair housing and local data and knowledge and other Areas of Affluence
.relevant factors as described 6.elaw,.
The AFFH analysis has been edited to add:
A3,. Disparities in Access to Opportunity: The element reports data from the TCAC(HCD Opportunity maps at a • Opportunity access information related to education, environmental justice, transportation, and composite level, but it should also separately report and analyze data, patterns and trends related to education, ernpkyment.
economy and transportation.,:
The AFFH analysis has been edited to add: -
• Regional data for overcrowding, displacement risk,
® Identification of overlapping coincidence with other components of the assessment A4,. Disproportionate Housing Need, Including Displacement Risk: The element describes displacement relative ® Additional regional comparison for substandard housing to tenure; however, it could also consider information from the HCO AFFH Data Viewer and provide analysis as Summary of findings from local and regional data for segregation and integration ..described above, includinPv overlapping coincidence with other components of the assessment sf fa housing__ I A..5,Local Data and Knowledge: The element should incorporate local data and knowledge of the jurisdiction Into the AFFH section, To assist in meeting this requirement, the element should provide local data not captured in regional, state, or federal data analysis, including information obtained through community The AFFH analysis has been edited to add a local knowledge section that addresses related issues 1particIRaton or consultaton
bentofied in the Rub is outreach. process aswell ashistorical paY[erns of development,.. _ _ A..6,. Other Relevant Factors: The element must include other relevant factors that contribute to fair housing 'issues in the jurisdiction.. For instance, the element can analyze historical Band use, zoning, governmental and nongovernmental spending including transportation investments, history of lending practices and demographic - The AFFH analysis has been edited to add a local knowledge section that addresses related issues trends,
identified is She public outreach_rocess as well as historical patterns of development,.
A;7;. Sites Inventory: The element discusses identfied sites relative to the TCAC/HCD Opportunity Map at a -
r compositive level but should also address the other components of the assessment affair housing (e.g., segregation and integration, disproportionate housing need, including displacement risk), identified sites by The sites inventory AFFH section is edited to identify areas thatthe AFFH analysis showed had Umco,mel. pup and location„mtude of the impactand any isolation of the RHNA by oncome�aroup. v disproportionate needs and higher eulnerabi9ity to disolacemerrt.
Ay, Contributing Factors to Fair Housing Issues. The element should re visit and prioritize contributing factors The AFFH analysis has been edited to the Identification and Prioritization of Local Fair Housing Issues and to fair housing based on the outcomes of a complete analysis,.. Contributing factors create, contribute to, ''..'. Contributing Factors discussion and includes a list of related contributing factors perpetuate or increase the seventy of fair housing issues and are fundamental to adequate goals and actions.
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[iRg of Downeg—Summary of Litt' Edt¢s/d7esgronse as Hop Findings— oecember2021 toopies include community opposition to affordable housing, housing discrimination, land use and zoning laws, lack of regional cooperation, location and type or lack of affordable housing and lack of public or private investment in areas of opportunity or affordable housing choices,. The analysis shall result in strategic a RRo?aches to inform and connect goals and actions mdi atcontributin ,facrors to affo dable housing _ _
A 9.. Strategies and Actions: Goals and actions must significantly seek to overcome contributing factors to fair -
housing issues.. Current program actions include the City's already existing strategies to provide adequate sites i and elo not demonstrate a connection to the fair housing issues and contributing factors identified. This is not li
adequate to satisfy the requirement for specific and meaningful actions.; Program actions should be proactive, i
facilitate meaningful change, and respond directly to the contributing factors to fair housing issues that were I
Identified. Furthermore, the element must include metrics and milestones for evaluating progress on programs, The element (particularly Program 5,2 in Chapter 6) is revised and enhanced with additional program actions, and fair housing results.. The element must add and revise programs based on a complete analysis and actions based on the complete analysis and listing and prioritization of contributing factors to fair housing rnnneet to prioritized contributing factors to fair housing. issues. issues i'.
A.2,1,.: Progress in Meeting the RHNA: TheCity's RHNA may be reduced by the number of new units built since June 30, 2021, but the element must describe the City's methodology for assigning these units to the various 1 j
income groups based on actual sales price or rent level of the units and demonstrate their availability m the + Information on the affordability of the two units at 12850 Woodruff Avenue has been added underli planning period.. Specifically, the element credits 28 townhomes (12850 Woodruff Avenue), of which Swill be the Approved and Proposed Projects heading in Chapter4.'. affordable to very low-income households. However, it must demonstrate affordability as described above, In + Residential development potential in the adopted Rancho Los Amigos South Campus Specific Plan 'addition, the element lists 600 approved units, of which 300 are expected to be affordable to very low-income has been moved from the Approved and Proposed Projects section to the Sites Inventory Section households, from the Rancho Los Amigos South Campus Specific Plan,: The element must address the status of The revisions address the status of the proposed units, including potential availability in the these proposed units, including potential availability in the planning period and demonstrate anticipated planning period and as well as information on recent development inquiries,. affordability as described above
A 2.2 Realistic Capacity: The methodology for calculating residential capacity on identified sites must account Chapter 4 is edited to add:
for land use controls, site improvements and typical densities of existing or approved residential developments text to clarify location of two affordable projects in the Downtown Downey Specific Plan at a similar affordability level. While the element utilizes various potential unit yields, it must still support these W Development interest in the two specific plan areas
assumptions. For example, for higher -density sites that do not require rezoning, the element assumes 80 Additional examples of multifamily development to support the use of 80%of maximum allowed percent of potential yield. The element supports this assumption by referring to two high -density density to calculate realistic capacity.: Recent project trends show that the density assumption is developments, one of which dates back to 2014,. Further support is needed to justify this assumption: The realistic.,
element does not clarify what zones these two high -density projects were developed in, or whether density bonus projects such as these are typical of residential development in those zones,. The element should Also, Chapter 4 is edited to clarify that the use of densities significantly lower than what is allowed demonstrate what specific trends, factors, and other evidence led to the assumptions, including a more holistic accounts for the potential development of mixed uses.. As part of the City's Housing Element -view of development trends,:
implementation (Program 1.3), the City is increasing allowable density in the R-3 zone to allow up to 40 units per acre and in the process adjust development standards, accordingly. Program 13 also includes an In addition, for sites where zoning allows 100 percent nonresidential uses, this analysis must adjust for the :action item to review and revise residential developments standards including building height limits in the'. likelihood of 100 percent nonresidential development. For example, the element could describe the underlying R-3 zoning district and to identify and codify incentives to encourage development of residential uses in zoning, whether 100 percent nonresidential development is allowed in these zones, analyze all development areas with the new Residential Overlay and Mixed -Use zone, activity in these non-residential zones, how often residential development occurs and adjust residential capacity calculation, policies and program accordingly... The element could also incorporate any relevant As part of the General Plan and Zoning update, The City will also adopt additional incentives for projects programs or policies the City is undertaking to facilitate residential development in zones allowing 100 percent that include lot consolidation as a way of adding more residential units to a project (Program 1 3). nonresidential uses.._
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A 2 3 Swtebility of Renascent Sites: The element must include an analysis demonstrating the potential for te redevelopment of nonvacant sites. To address this requirement, the element states that sites were selected based on ,faotentral capacitymcrease available to ftroperty owners and on location and existi usesjp 4 8)S:Chapter 4 is edited to:
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(7wyfDowmy-5,wm,ry of Cstyld1fir/Mrspares to use assume, - Dweaebw2021 r
the element alsogenerally describes some existing uses, but it must include analysis to demonstrate the Refine the site inventory and focus on sites that most the existing use, land value, and Intensification potential For additional development The analysis should consider factors including the extent to which existing criteria stated in the Chapter. As part of the revision process several sites were removed and replaced with uses may constitute an impediment no additional residential development, the City's past experience with more suitable sites,
converting existing uses to higher density residential development, the current market demand forthe existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent The City will include findings in the adopting resolution for the Housing Element that indicates that redevelopment of the site for additional residential development, development trends, market conditions, and existing uses are not an impediment to additional residential development and will likely discontinue in regulatory or other incentives or standards to encourage additional residential development on these sites, For the planning period
example, the element could clarify what is meant by "potential for intensification" In 4-6) and consider additional indicators such as age and condition of the existing structure, presence of expiring leases, expressed developer Interest in residential development, low improvement to land value ratio, and other factors In addition, because the, housing element relies upon monvarant sites to accommodate more than 50 percent of the RHNA for lower -income households, it must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period, (Gov. Coup, § 65583.2, subd. (g)(2),) Absent findings (e.g , adoption resolution) based on substantial evidence, the existing uses will he presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to u•;I9af. RtAtdA,.
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Consistent with updated Housing Element law {Assembly Bill 1397) related to the suitability of small and large sites, the lower -income sites inventory presented in this section is predominately limited to parcels between 0.5 and 10 acres in size, as HCD has indicated these size parameters best accommodate lower - income housing need, In this inventory, only 40 of the 424 parcels that make up the, sites inventory at less than half an acre in size (9%) and they are included only if they are Pact Of I larger site that function as one use (for example, a single structure or use over more than I parcel) and/or the parcels are adjacent and under common ownership .
A 2.4, Small Sites: The element identifies many sites at less than a half -acre, These sites are not eligible absent a demonstration that sites of equivalent size were successfully developed during the prior planning period for an Several sites comprising one or more parcels are less than one-half acre in size, These sites are included equivalent number of lower -income housing units as projected for the site or unless other evidence is provided, because the multiple parcels function as one site, such as a structure and its attached, surface, parking lot If the inventory indicates some sites can be consolidated it should also provide analysis demonstrating the or a single structure located on multiple parcels. Small sites (less than one-half acre) meeting the default potential for consolidation. For example, the analysis could describe the City's role or track record in facilitating density standard are NOT credited toward the lower -income RHNA, Lot consolidation assumptions in the small -lot consolidation, policies or incentives offered or proposed to encourage and facilitate lot consolidation, sites inventory are limited,
conditions rendering parcels suitable and ready for lot scruccidation, or information from the owners of each Mm"u-'adsite.=.h
Chapter A has been edited toclarify these points,
A,2,5 Accessory Dwelling Units (ADUs): The element assumes an average of 125 ADUs per year will be constructed during the planning period, for a total of 1,038 ADUs.. The element's analysis and programs do not support this assumption. Based on HCD records and numbers reported in the element, the City is averaging about 24 ADU permits per year since 2018, To include a realistic estimate of the potential for ADUs, the element must reduce the number cffADUa assumed per year and include analysis, policies and programs as Th. ADU portion ofthe sites inventory is edited to update the number of ADU permits provided in 2021 appropriate, The element must commit to monitor ADU production and affordability throughout the course of bre of October),. The revised estimates for the planning period account for pent-up demand at the start of the planning period and implement additional actions if not meeting target numbers antidleated in the housing the planning period and the potential leveling off ofADU development in the later part of the planning element by a certain date- Additional actions, if necessary, should be taken in a timely manner development under the provision, of 58 9 is also added, Page -
3 City fDowney-5ummaryof CRy EdttelResponse to HCD Findings-December202P months} Finally, if necessary, the degree of additional actions should be in stride with the degree of the gap in production and affordability, For example, if actual production and affordability of ADUs is far from anuci pared trends, then rezoning or something similar would be an appropriate action, afactual production and i affordability is pear anticipated trends, then measures like outreach and markeLog=ht be more an roiiriate.
The discussion under the Site Infrastructure and Constraints section in Chapmr4 has been updated to '.. include information on environmental hazards (earthquakes, liquefaction, landslides, flooding),. None of the parcels identified in the residential sites inventory are constrained by sensitive habitat or contamination that would prohibit developers from building.. The City requires engineering reports to establish appropriate design standards and mitigation measures taken to alleviate any identified hazards,. 3 A;2,:6.; Environmental Constraints: While the element generally describes a few environmental conditions within However, the necessity of these reports is offset by the need for public safety and welfare, and thus the the City, it must describe any known environmental constraints or other conditions that could impact housing City does not consider the reports a constraint to housing development, arming period,.
s develoEmenton identified sites in the pl _
Additional information for water and sewer capacity is added to the element under the "Site Infrastructure and Environmental Constraints" heading in Chapter 4,. To accommodate the 2021-2029 A.2.7.Infrastructure: The element generally describes infrastructure, However, it must also demonstrate RHNA of over 6,500 residential units, within three years of adopting this Housing Element, the City will 3 sufficient total water and sewer capacity (existing and planned) to accommodate the regional housing need by undertake a series of land use actions to increase development potential,: These proposed land use actions -community plan area; will require thorough infrastructure and environmental review, and any additional constraints will be ' identified at the time the actions are taken, along with any necessary mitigation measures to address I IIn addition, water and sewer service providers must establish specific procedures to grant priority water and infrastructure system and service provision. 3 :sewer service to developments with units affordable to lower -income households; (Gov,Code, § 65589_7.) The I:element should discuss compliance with this requirement and if necessary, add or modify programs to establish Program 3.9, included in the Draft Housing Element submitted to the Department, is already in place to a —man procedure by a date early to the o tl jn MR Eiod, �. address the required actions of the CrtV s water and sewer service providers, y A,2,8. Electronic Sites InventoryFor your information, pursuant to Government Code section 65583.3, the City --- must submit an electronic sites inventory with its adopted housing element,. The City must utilize standards, forms, and definitions adopted by HCD. Please see HCD's housing element webpage at 3 https:f(www. hcd.ca,pov/community development/housing-element/index shtmlgelement for a copy of the p form and instructions The City can reach out to HCD at chesinyentory[7a hcdza; og v for technical assistance., Noted.. 72:,.9..:7ooingfora Varietyaf Housing Types -
® Emergency Shelters. The element describes that emergency shelters are permitted In the H-M zone without discretionary action The element should also describe development standards, including parking requirements, for compliance with statutory requirements. In addition, the element states that no properties are available in the areas zoned to permit emergency shelters, As a result, the element should identify another zone and area The element has been edited to describe development standards, including parking requirements, for to accommodate the need for emergency shelters, including a description of rapacity and add or modify compliance with statutory requirements, As a result of this edit, a new action item is added to Program 3,5 Program 2.7 (Address Homelessness) to amend zoning as appropriate,.to identify the M-2 zone for emergency shelter development and to ensure compliance with State law, including addressing the Co's distancing requirements,. '.® Employee Housing: The element must demonstrate zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 at seq.) or add or modify programs. Specifically, section 17021.5 requires A heading for Employee Housing is added to Chapter 3 under Zoning for a Variety of Housing Types and employee housing for six or fewer employees to be treated as a single-family structure and permitted in the Program 1,3 is updated to add an action item committing to update the Zoning Code to define employee same manner as other dwellings of the same type in the same zone. Section 17021,6 requires employee ''. housing and to clarify that employee housing serving six or fewer employees shall be deemed a single - housing consisting of no more than 12 units or 36 beds to be permitted in the same manner as other family structure and shall be subject to the same standards for a single-family residence in the same zone t agricultural uses in the same zone
Page-4
City of Dawney—Summary of City Edite/Resw ase to HC® Findings —December 2621 Parking: Tables 3 3, 3,5, and 3,6 are updated to include parking standards, Following Table 3,6 is anew heading,"Parking for
A3, 1.,..Land Use Controls: The element most identify and analyze all relevant land -use controls as potential Multi -Family Developments" which addresses parking in the R-3 zone and in the Downtown Downey constraints on a variety of housing types, both independently and cumulatively with other land -use controls.
Specific Plan (DDSP) area:. Parking reductions for uses in the DDSP and for senior and affordable housing Further analysis is needed of the City's requirements related to heights in multifamily zones, particularly the are addressed..
Downtown Core, and parking requirements. The analysis should address any impacts on cost, supply, housing } choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs Building Heights: Chapter 3 under the Residential Development Standards heading is updated to add • to address identified constraints,
information on build inn heihts in the R 3 zone and in the Downtown Downey Specific Plan area A3.2,Site Plan Review: The element must analyze the City's Site Plan Review, including approval procedures and decisbn-making criteria, for their impact as potential constraints on housing supply, cost and approval Chapter 3 under the Site Plan Review heading is updated to include more information on the site plan certainty.. Specifically, certain approval findings, such as that a proposed development should "integrate '. review process and Program 1,.3 is updated to add that the City will update development standards for harmoniously", prevent "extremes of dissimilarity or monotony", and focus on the compatibility of the design, multi -family projects that will not require the Site Plan Review process and allow for this review to be '.. appear subjective and should be analyzed as a potential constraint..A full analysis should discuss whether completed administratively without discretionary approval, In addition, Program 33 is included and approval findings, standards and guidelines provide for development certainty and impact the cost and timing indicates that the City will adopt objective design standards to ensure that the City can provide local of approvals, The element must add ar modify pro ,rams as ap ro ria tP to address identified nstrawnts T' p R
� uidan rr_ p Y ,law°
t ....
A 3.3° Zomn and Fees Transparency: � s aeenc The element must clari its compliance withhew trans arenc a...�..�_f...a Q,nY....
Information about online access t the City's proses ,...._,,.,.w s information and resources is
I'. requirements for posting all zoning and development standards on the City's website, and include programs if added to Chapter 3 under the Residential Development Standards heading -appropriate
° The location of the City's fees is added at the end of the Fees and Exactions section in Chapter 3 A 4.L The element must include analysis of requests to develop housing at densities below those anticipated in 1-'
the site inventory, The element notes that the City does not discourage developers who choose to develop at I The discussion under Government Code 65583(a)(6) Development Analysis is edited to add more detail .lower densities, but it still must analyze any such requests and address any hinderances on the construction of and experiences with lower density requests and Programs 1,5 is edited to add additional actions to the RHNA,
encourage development at higher densities.
A SaL While the element quantifies various special needs groups, it must also analyze those housing needs.: The "
analysis should include, but is not limited to, factors such as household income, tenure, housing types, overpayment, trends, zoning and related strategies, available resources and gaps in addressing housing needs.
Chapter 2 under the Special Needs is edited to add:
Local officials, special needs service providers, or City/County social and health service providers may he able to Information on persons with disabilities by type (e,g„, ambulatory, vision difficulty, cognitive) as .assist with information to complete the analysis. For additional information and a zaample analysis, see the well as resources.
Building Blocks at f6i�.,...Ci%y;fSb4dRAlatdnity^{I'Q4t}gM1kMejlili�6dF•hftlp�CFB@g°IldbCkip �tiliJSlni!„PSk e{1+�,}�t+:RF�&lCr.• ® Resources far Seniors,..
families female-head-householdshtml„:
Housing stock, income and poverty information related to large households., ® The number offarmworkers at a county level
In addiition, to supplement analysis and better formulate policies and programs, the element should also :identity and analyze persons with disabilities by type (a p,,ambulatory, vision difficulty, cognitive) and ® Issues, number of households with children, change since 2014, resources for female headed households.
` permanent and seasonal farmworkers at a county level (e.g USDA APzncultural Census) FS.;2d1„ To have s heoefirial impact in the planning period and address the goals of the housing element, (,programs must be revised with discrete timelines, objectives and specific and clear commitment to outcomes,:
Program 1;.3 is edited to change "Review and, if needed, revise" to "revise" as it relates to development standards (minimum lot area requirements and building height limits in the R-3 Programs to be revised with discrete timelines (e,g„ annually, Spring 2022) include Programs 1„4 (Accessory zoning district and minimum unit sizes for all residential development), Dwelling Units), 1.5 (Density Bonus), 2,.1 (Special Needs Housing), 2..3 (Affordable Housing Development Program 1,4 is edited to is edited to add more information on ADD resources such as the one -stop y9
gl Incentives), 2 4 (Affordable Housing Technical Assistance), 2,6 (First -Time Home Buyer Assistance), 2,7 (Address wattage and to add that if production falls below levels anticipated in the Housing Element, the i" Homelessness�4, 2„8 (County and Regional Partnerships} and 3 5 (Special Needs Housing Law):,.
City will evaluate and ensure that adequate sites are available through the adopted sites mventan±, Page -
5 City of lyawavy—Summary of City EaftyResawme fo ML0 Findings— Oweember 202E r. f Y.T.-MCNIT17k
. aa..
or it wit identity additional sites to ensured continued provision of adequate sites. Additional Programs to be revised with objectives include Programs 1..5 (Density Bonus), 2.3 (Affordable Housing action items such as establishing ADU office hours are added..
Development Incentives), 2.6 (First -Time Homebuyer Assistance) and 3,6 (Energy Conservation),.. t Program 1.5 is edited to add additional action items, objectives, and timeframes v, Program 2.1 is edited to add a more specific timeframe Programs to be revised with specific and clear commitmeetto outcomes include:
Program 2.;2 is edited to remove the "review" action and commit to specific action 7 Program 2,3 is edited to add objectives and a specific timeframe fi ® Program 1..3 (Land Use Policy Changes) commits to revise residential standards, "if needed"; however, the Program 2.4 is edited to add specific timeframe details �. program should specifically commit to making revisions consistent with the feedback of expert practitioners as Program 2.6 is edited to add objectives and a specific timeframes noted on page 1-8.
Program 2...7 is edited to add specific timeframe details { - Program 2.2 (Housing for Persons with Disabilities) should go beyond reviewing procedures and revise Program 2,8 is edited to add specific timeframe details procedures to ensure objective procedures that promote approval certainty and address barriers to housing for Program 3..1 is edited to commit to more specific action and a new timeframe is added p{p persons with disabilities,
a Program 3,5 is edited to add action items related to zoning for emergency shelter and employee 6: ® Program 3.,1 (Lot Consolidation) should commit to additional actions given the lack of progress in the prior housing and specific timeframe details
planning period (p; 5-8) and reliance on small sites,.
a Program 3.is edited to provide more definitive action related to the modificationjreplacement of ® Program 3.6 (Definition of Family) commits to evaluate and amend the definition offamily if appropriate. the definition of "family'...,
Based on the information in the element, the definition of family is a constraint on housing for persons with am
Program 3:•:8 is edited to add objectives and timeframes :disabilities and the Program should clearly commit to amend the definition.
Program 3,.9 is edited to clarify that the City (which provides water and sewer services, does not ® Program 3,9 (Water and Sewer Providers) simply commits to confirm procedures are available for the eight- year planning period. However, confirmation should occur as part of the housing element update and clear have procedures in place to grant priority for the provision of water and sewer services proposed developments that include units affordable to lower -income households as required by commitment should be included to establish procedures, particularly if the City plays a role in granting water law,: An action item to address this is added as is a timeframe. and sewer service. .
_..._..,::.:: _...._...,.... ..............__._.. �..—�... ....�.____ _..._w,,.,.w.`----- B 1-2As noted in Finding AS, the element does not include a complete site analysis, therefore, the adequacy of .. .,.,.,.,.,.,.,.... ....... __.. .,-„„ -- --------_ ......, m• sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or coning available to encourage a variety of housing types.: In addition:
•. Program 1.,1 is edited to clarify by -right and minimum densities consistent with Government Code sections 65583,2 and reflects edits to the sites inventory.
Program 1.1 (Adequate Sites) commits to rezoning and satisfies many requirements, but it should also clarify Program 13 is edited to add thatthe City will identify and codify incentives to encourage by -right and minimum densities consistent with Government Code sections 65583,2, subdivisions (h) and (i) and '.:
development residential uses in areas with the new Residential Overlay and Mixed -Use zone and commit to establish incentives to encourage intended uses consistent with the overlay given allowable uses by to change "Review and, if needed, revise" to "revise" as it relates to development standards g the base zoning;
(minimum lot area requirements and building height limits in the R-3 zoning district and minimum e City -owned Sites: The element should consider a schedule of actions to facilitate development of City -owned unit sizes for all residential development).
site(s), Additional actions include outreach with developers, incentives, fee waivers, priority processing and a Program 2.4 is edited to add actions related to development on on City -owned sites.. ':financial assistance.
rr d
to HCO Ffinflegs -Deovabs,2022
Edits have been made to Program 1.3 that driver:
® Action item to remove Site Plan review process from multi -family housing approval process The element has been edited to describe development standards, including parking requirements, for compliance with statutory requirements, As a result of this edit, a new action item is added to Program 3,5 to identify the M-2 zone for emergency shelter development and to ensure compliance with State law, including addressing the City's distancing requirements,.
Editshave been made to Program 1,5 and an action item is added to provide a detailed list of completed 8,3.1, As noted in Findings AS and A4, the element requires a complete analysis of potential governmental and density bonus projects in Downey and in neighboring cities and a list of available concessions to Show nongovernmental constraints,. Depending upon the results of that analysis, the City may need to revise or add prospective developers the potential advantages of using the state's density bonus provisions and Shared or, us and delta all a are o ad constraints
m' aremove nt'L—co"tr ' t'
v- 0 at
W�rn lm,ubdm11,�g Ian, for multi f,,,Iy rf�,Smtx
2L��,L
ff, sfy i In ne"im"'onts Far
al n refim Al,A ' . element . .a Set 'a n'. P re ramsthat sati '�� AS noted
't nx 'a raroursers. Fan, hismang as. as Eased . n a complete analysis, the element P., "" a nd to . n psi'd , actions
C.s
The AFFH program has been revised to show the connection between the AFTH Issues, contributing ad M,
must pa�r, mg
factors, gram e'dons
a no I".,
1151, Program 1,1 (Accessory Dwelling Units) generally includes outreach and some other actions but should Program 14 is edited to add more information on ADU resources such as the one -staid webpSge and to consider additional commitment to incentives, particularly if the City continues to utilize ADUS toward a add that if production talk below levels anticipated in the Housing Element, the City will evaluate and significant portion of the RHNA,. Examples could include exploring and pursuing funding, modifying ensure that adequate sites are available through the adopted sites inventory, or it will identify additional deve opment standards and homeowner/applicant assistance tookM , In addition, Program (Accessory sites to ensured continued provision of adequate, sites, Additional action items Such as establishing ADtj Dwelling Units) should monitor affordability in addition to productions and must commit to take alternative office hours are added. More information on timing is also Santa& The City's ADU program reflects the and by a specified date (e,g,, within 6 months),
City's staffing and funding levels...
C M, HCD understands the City made the element available to the public two weeks prior its Submittal to HCD, By not providing ample opportunity for the public to review and comment an a draft of the element in advance of submission, the City has not yet complied with statutory mandates to make a diligent effort to encourage the I. public participation in the development of the element, This reduces HCD's ability to consider public comments in its review.. The availability of the document no the public and opportunity for public comment priorto submittal to HCD is essential to the public process and HCD's review, The City must Proactively make future revisions available to the public, including any commenters, prior to submitting any revisions to HCD and diligently consider and address comments, including making revisions to the document where appropriate, HCD's future review will consider the extent to which the revised element documents how the City solicited, The revised Draft Housing Element was made available to the public 10 days prior to submitting the considered, and addressed public comments in the element, The City's consideration of public comments must Housing Element for a 2r' review, Comments received and information an how they were addressed in the mtLdLllimited .bv _11cD, fndL1m,=n1h
Element is included in the Intraduction I)-
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TIERING 1
ANALYTICAL8ppnO�S�--,._-_--^-----....... ......... ^`........... -............................................... =°_~-"-~_.--^`3 3 PROJECT DESCRIPTKJhL_._.~.__....... _~.... ._..... ~_~_~~~__...... ~........... ~~~~____~~-__~=._~~~_=~_....... 5 3 DETERMINATION ................................................................................................................................................................................ 19 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED ............... -,......... _...... ._................ ................ 10 UETsnmwAT0w_... .__r...... _........ ~..... ~,...... _~....... ~_~,....... 1O
4 EVALUATION OF ENVIRONMENTAL IMPACTS ............................................................................................................................... 2O
1. AESTHETICS. .~~~~~_.__~_^..^...... ........ ^__.._
20 2. AGRICULTURAL RESOURCES ~~-~v_m.=_._......... _.......... --- ............ ..........._+"-~~22
3. AIR OU*UTY.,~..`...~~..._.~_--~._~___"._....... __--_-.~.-.-_....._..~.__.._^..-.^.~-_._.^__..... __"__.24
4. BIOLOGICAL REaoUmCsG_,°_.,,,_... ~_..~......... --- ...... ---- °=,.~......... ,-~-~^~_..^~_~_.~__._-°..=~...... ~__... 28 5. CULTURAL RESOURCES .... __.~.....___~.,........... ....~..__........ _,_,,`_____.___..... 30 0. EmsnGv___.......... ......... ........... ,,_~_r_~,.,__,__3�
7. GEOLOGY AND SOILS ........... _V�~,_�r_^,~��___�____."-~........... ... 34 U GnsswxOU0s��SEmoG|omu~_` -
� ___°__-__~`~�-__'��`~~.__,-�-_`--.-.�._~°-~�_-__°~�.^-~-__~_.__^.� 37 9. HAZARDS AND HAZARDOUS MATERIALS ................................................................... ...... .......... ~-,~..... 30 10. HYDROLOGY AND WATER QUxuTY~_°..._......~...,.-_._.~-....... .~........ ..__._.._~..._.~~^-..^__~-_°^....... _-......... --- 42 11. LAND USE AND PLANNING -._.__-__-~_~_,_....... ~~_�_45
12. MINERAL RESOURCES ........................................................................................................................................................................ 4G
13. 47
14. POPULATION AND HoUG|wG'... ---- ...... ��_�____�____�_�____^_,_............ .... _49
15. PUBLIC _,__-,~......
50 16
53 17 TRANSPORTATION AND ...... ~____.~~_.-__.__,^m_...... ........ "........ -=........ 53 18. TRIBAL CULTURAL RsG0UmCs8___,^_..... °_~__.._=___"__~_~~~..~~_.~~.°~_~_.,.._^~___°-_~~=~.~__~_,5G
19. UTILITIES AND SERVICE �,STsm8~_°._.......... ....... _,~,,____~~=,=,._.__... 57 20. WILDFIRE .... .... ................ ....... ...... ...... ............ ..._.._..._~5Q
21. MANDATORY FINDINGS OrG|Gm|F|CAwSc__—`.... ,-�__'�_^___"�_~~_..~-............... ___,_�____6O 5 LIST OF PREPARERS .........................................................................................................................................................................
G3
LEADAGENCY- ......... .__...-.~~~_..~.._~-.._.~-.._~~__............. _.... .---- ............ ~..=.~_~-.~.~~_.__......... ........
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TABLE 2-3 REGIONAL HOUSING NEEDS ASSESSMENT ALLOCATION ...........
TABLE 2-4 RHNA CREDITS AND REMAINING NEED ............
TABLE 2-6 UNDERUTILIZED LAND INVENTORY.,-, ....
LIST OF EXHIBITS
FIGURE 2-1REGIONAL CONTEXT AND VICINITY MAP ............................................................................................................................. 13
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ii 2021-2029 Housing Element
This Initial Study has been prepared in accordance with the California Environmental Quality Act (CEQA)Statutes and Guidelines and the City ofDowney local rules and regulations. The proposed Project requires discretionary approval by the City ufDowney and review bythe California Department ofHousing and Community Dovo|opmont(HCD). As the project initiator, and because of the |egio|okiwa approvals involved, the City of Downey is the Lead Agency with respect to this |niUo| Study pursuant to 815307 of the CEQA Guidelines. Specifically, the HEU Project requires City ofDowney approval of General Plan Amendment No.PLN-21'00139. Noother governmental agencies have discretionary permitting authority with respect to approval of the proposed Project, and no Trustee Agencieo, as defined in §21070 of the CEQA Statutoo, has jurisdiction over resources such that Trustee agency approval is required for entitlement approval. and that an EIR is not required.
This document has been prepared to comply with Section 15063 of the State CEQA Guidelines that sets forth the required contents of an Initial Study. These include:
• Adescription ofthe project, including the location ufthe project (see Section 2) • Identification ofthe environmental setting (see Section 2.11) • Identification of environmental effects by use of a checklist, matrix, or other methods, provided that entries on the checklist or other form are briefly explained to indicate that there is some evidence Uusupport the entries (see Section 3)
• Examination ofwhether the project iscompatible with existing zoning, plans, and other applicable land use controls (see Sections 2.0and 27)
• The name(s)ofthe person(n)who prepared orporticioate inthe preparation ofthe Initial Study (see Section 5.1)
(a) refers to using the analysis ofgeneral matters contained inebroader EKR (such aoone prepared for mgeneral plan orpolicy statement) with later EIRsand negative declarations onnarrower incorporating hxreference the general discussions from the broader EIR; and concentrating the later EIR or negative declaration solely on the issues specific bothe later project
8d Agencies are encouraged to tier the environmental analyses which they prepare for separate but related projects including general plans, zoning and development This approach can eliminate repetitive discussions nfthe same issues and focus the later £JRurnegative declaration onthe actual issues ripe for decision a/each level of environmental review. Tiering isappropriate when the sequence ofanalysis is from enE7Rprepared for egeneral plan, City of Downey
Purpose and Authority
policy, or program to an EIR or negative declaration for another plan, policy, or program of lesser scope, or to a site - specific EIR or negative declaration. Tiering does not excuse the lead agency from adequately analyzing reasonably foreseeable significant environmental effects of the project and does not justify deferring such analysis to a later tier EIR or negative declaration. However, the level of detail contained in a first tier EIR need not be greater than that of the program, plan, policy, or ordinance being analyzed.
(c) Where a lead agency is using the tiering process in connection with an EIR for a large-scale planning approval, such as a general plan or component thereof (e.g., an area plan or community plan), the development of detailed, site -specific information may not be feasible but can be deferred, in many instances, until such time as the lead agency prepares a future environmental document in connection with a project of a more limited geographical scale, as long as deferral does not prevent adequate identification of significant effects of the planning approval at hand, (d) Where an EIR has been prepared and certified for a program, plan, policy, or ordinance consistent with the requirements of this section, any lead agency for a later project pursuant to or consistent with the program, plan, policy, or ordinance should limit the EIR or negative declaration on the later project to affects which:
(1) Were not examined as significant effects on the environment in the prior EIR; or (2) Are susceptible to substantial reduction or avoidance by the choice of specific revisions in the project, by the imposition of conditions, or other means.
(e) Tiering under this section shall be limited to situations where the project is consistent with the general plan and zoning of the city or county in which the project is located, except that a project requiring a rezone to achieve or maintain conformity with a general plan may be subject to tiering.
A later EIR shall be required when the initial study or other analysis finds that the later project may cause significant effects on the environment that were not adequately addressed in the prior EIR. A negative declaration shall be required when the provisions of Section 15070 are met.
(1) Where a lead agency determines that a cumulative effect has been adequately addressed in the prior EIR that effect is not treated as significant for purposes of the later EIR or negative declaration, and need not be discussed in detail.
(2) When assessing whether there is a new significant cumulative effect, the lead agency shall consider whether the incremental effects of the project would be considerable when viewed in the context of past, present, and probable future projects. At this point, the question is not whether there is a significant cumulative impact, but whether the effects of the project are cumulatively considerable. For a discussion on how to assess whether project impacts are cumulatively considerable, see Section 15064(i).
(3) Significant environmental effects have been "adequately addressed" if the lead agency determines that (A) they have been mitigated or avoided as a result of the prior environmental impact report and findings adopted in connection with that prior environmental report; or
(B) they have been examined at a sufficient level of detail in the prior environmental impact report to enable those effects to be mitigated or avoided by site specific revisions, the imposition of conditions, or by other means in connection with the approval of the later project.
(g) When tiering is used, the later EIRs or negative declarations shall refer to the prior EIR and state where a copy of the prior EIR may be examined. The later EIR or negative declaration should state that the lead agency is using the tiering concept and that it is being tiered with the earlier EIR.
Purpose and Authority
0M There are various types of EIRs that may be used inatiering situation. These include, but are not limited to, the /M General Plan EIR(Section /5/00
CB Program £JR(Section 15/00
(4) Master BR(Section /5175)
(5) Multiple -family naokdemha/ development/residential and commercial or retail mixed -use development (Section y5/79.5)
/0 Redevelopment project (Section /5/80
(7) Projects consistent with community plan, general plan, or zoning (Section 15183) This Initial Study for the 2021-2029Housing Element has been prepared to tier from the General Plan "Program"BR of the City of Downey dated January 25, 2005 as amended or otherwise supplemented. For the City of Downey, documents by which the analysis recorded herein has been tiered from are available for public review at:
City of Downey
11111 Brookshire Avenue
Downey, California 9U241
BarbmnaJ. Riley Community & Senior Center
781OQuill Drive
Downey, California 9O242
Downey City Library
11121 Brookshire Avenue
Downey, California 9O241
The environmental analysis contained in this Initial Study is based on the following assumptions:
General Plan Consistency: Amthe General Plan is undated and/or amended, the City ofDowney will ensure that such updates and amendments donot prevent implementation of the policies contained inthe updated Housing Element.
Categorical Exemptions: Smaller -scale ministerial projects that require issuance of building pennMa without need for discretionary action are generally exempt from environmental review pursuant to CEQA in the absence of compelling evidence that the project iouniqueinthaddmayremu|tinaignifioentindividua|mnd/oroumu|adiwaimpocts. Smaller -scale projects mmyUe exempt from CEQA and require no further analysis. Exempt projects are considered to have no significant impact on the environment, audefined inSection 153DOufthe CEOAGuidelines.
Project Specific Environmental Review: Future development pmpneo|n not exempt from CEQA will be subject to the environmental review process to identify potential impacts and impose appropriate mitigation m*aounm' if needed, to avoid significant impacts,
Purpose of Environmental Review: The proposed Housing Element Update does not authorize any plan for construction of new homes orother uses orthe redevelopment ofany properties within the local jurisdiction. Nodirect environmental impacts, therefore, will occur as a result of adoption of the HEU. This Initial Study assesses the potential programmatic level City of Downey
�
Purpose and Authority
environmental impacts resulting from potential development facilitated by the Housing Element in accordance with the Lead agency's existing land use policies.
9 •fi 6
im 11 v 11 m &I C.16111
The purpose • the • analysis conducted for the Housing Element, as documented herein, is to determine general impacts that could result from implementation of the Housing Element. The analysis is based on a hypothetical development scenario • the Inventory Sites identified in the Housing Element and how construction and operation of those sites may result in impacts to the environment. Because this is a program -level analysis, some measure of forecast and asrspa-cufaftv-
tr unreasonable. Therefore, the program -level analysis of the potential impacts • the Housing Element is inherently broad 2nd typically qualitative due to the lack of specific project -level information, 4 2021-2029 Housing Element
2 PROJECT DESCRIPTION
PROJECT TITLE
City of Downey 2021-2029 Housing Element Update (General Plan Amendment Application No. PLN-21-00139)
LEAD AGENCYIPROJECT SPONSOR NAMEAND ADDRESS
City of Downey
11111 Brookshire Ave,
Downey, California 90241
CONTACT PERSON AND PHONE NumBER
Crystal Landavazo, City Planner
Planning Department
11111 Brookshire Ave.
Downey, California 90241
(562) 904-7154
Email: [email protected]
This Initial • analyzes the potential • impacts associated with adoption of the City • Downey's sixth cycle (2021-2029) Housing Element. The Housing Element is a required component of the City's General Plan and must be updated on a regular basis, as set forth in Government Code Section 65588.The Housing Element consists of these components, described in detail below: 1) housing needs, 2) constraints to housing development, 3) housing resources (available sites and funding sources), and 4) a housing plan.
The 2021-2029 Housing Element applies to all properties within the City of Downey on which existing and proposed General Plan land use designations and zoning districts allow residential and/or mixed -use development. The Housing Element does not sqecifically authorize the construction of am� housiny develoweftt�, projects will occur. The Housing Element is a policy document setting forth the City's plan to accommodate its share of regional housing needs, as determined by the Southern California Association of Governments (SCAG). For the 2021-2029 planning period, the City of Downey's share is 6,525 housing units. This allocation is referred to as the Regional Housing Needs Assessment, or RH NA.
Subsequent to this Housing Element update, the City will be undertaking focused General Plan and zoning ordinan amendments, described below and with separate CEQA review, to ensure sufficient land use capacity is available accommodate the RHNA. This Initial • examines the •i environmental impacts at a •.!• level for only t Housing Element since the Housing Element itself does not specifically authorize the construction of any housi development, nor ••...... it indicate where and when specific housing projects will occur. Impacts associated with the Gene of development allowed at specific sites.
wls��
Figure 2-1
Rosemead
Beverly Hills El Monte
Los Angeles Monterey Park
East Los
Angeles
Culver City Montebello
mt(a
Park s aaldw)n
a: Hitls
W
Huntington
Park Whittier
Inglewood
South Gate
Downey
RO S ecra n S
HOfs Lynwood
Hawthorne I Norwalk
Compton
Bellflower
Cerritos
Redondo Lakewood
Beach Torrance Carson --------
A
Pefos
Vefde Hills
A,"
Fort"r
Legend
L----j Downey City Boundary
6 2021-2029 Housing Element Update
Purpose and Authority
I 111111 1
'11114110, 111 NIN i 4111 its 1 11111, 1111111,11 IV._! 111011 111, ON 11 IN 111-1,111 1 KIIII, 11,11111 P111,111 1061 1 ASITI I 11 1111111 IV 61111 1 a 0 0 General Plan amendments to increase the allowable residential density in the Medium Density Residential (MDR) General Plan designation from 18-24 units per acre to 18-40 units per acre.
General Plan amendments to increase the allowable residential density in the Mixed -Use General Plan designation tf allow residential development at a density of at least 30 units per acre.
Table 2.1
Current Land Use Designations Allowing Residential Uses STS W. MUM 07 M-60— 0 1 Wagaus 011m%noll - 91 Loll
ON NIIII
amendments to the zoning ordinance and zoning map are being undertaken in conjunction with adoption of the Housing Element as follows:
Completing Zoning Code amendments to increase the allowable residential density in the R-3 zone from 18-24 units per acre to 18-40 units per acre.
Completing a land use and zone change to APN 6232-020-004 from Low Density Residential/R-1 to High Density Residential/R-3.
Adopt an implementing zone and development standards for the Mixed -Use General Plan designation that will allow residential development at a density of at least 30 units per acre.
Adopt a residential overlay zone that will allow high -density housing development at a density of at least 30 units per acre along key City corridors and allows residential development as a by right use. The overlay zone will apply to non -industrial, non-R-1 zoned properties located in key areas of six key commercial as well as one stand-alone property (APN 6283-001-035).
Add a residential component to three key specific plan areas with densities of at least 30 units per acre. The residential component will be implemented by a residential or mixed -use overlay or by amending or rescinding the governing specific plans (to be decided as part of the General Plan update).
Determination
Table 2-2 shows the current single family zoning districts while Table 2-3 shows the multi -family zoning districts in the City of Downey.
Lot area - minimum (square R
Lot width - minimum (feet)
Lot depth - minimum (feet)
interior lots
corner lots
— - -------------- - _
Floor area ratio — maximum (a)
Lot coverage`— maximum
Building height - maximum (feet)(b)
Table 2-1
5,000 6,000 7,500 8,500 10,01
50 1 50 1 _6'0 F — — — 6-5—T-70
Lot depths shall be within ten percent (10%) the average depth of the two (2) abutting R-I lots on both sides of the subject lot located on the same side of the street.
Corner lots shall be within ten percent (10%) the average depth of the adjoining two R-1 lots alon the common front and frontage.
.45 V A
' t) .45 .45 45
45% 45% 45% 45% 45%
main building
28 28 28 28 28
12 12 12 12 12
Front setback (1st floor) — minimum
20 20 20 20 20
(feet)(c,d)
2nd floor front setback — minimum
At the 2nd story fagade facing a front yard, the maximum width of the 2nd floor (feet)
fagade aligned with the 1 st floor fagade directly below shall be no greater than forty (40) percent of the entirety of the 1st floor fagade facing a front yard. Any additional portions of a 2nd floor facing a front yard shall be setback a minimum of five (5) feet from the I st floor fa ad:
Rear setback - minimum (feet)(d)
20 20 20 20 20
Side setback (1st floor) - minimum
Ten percent (10%) lot width, but not less than five feet (5) and not to exceed (feet)(e,f)
fourteen feet (14')
2nd floor side setback - minimum
At the 2nd story fagade facing a side yard, the maximum width of the 2nd floor (feet)
fagade aligned with the 1 st floor fagade directly below shall be no greater than forty (40) percent of the entirety of the 1 st floor fagade facing a side yard. Any additional portions of a 2nd floor facing a side yard shall be setback a minimum of __
five _fl��(�Jeet from the 1 st floo
Street side setback (1 st floor)
10 10 10 10 T 10
minimum (feet) d.
2nd floor street side setback -
At the 2nd story fagade facing a street side yard, the maximum width of the 2nd minimum (feet)
floor fagade aligned with the 1 st floor fagade directly below shall be no greater than forty (40) percent of the entirety of the 1 st floor fagade facing a street side yard. Any additional portions of a 2nd floor facing a street side yard shall be setback a minimum of five (5) feet from the 1st flo r facade, Dwelling unit size - minimum
(square feet)(9)
one (1) bedroom
700 700 700 700 700
two (2) bedroom
850 850 850 850 850
8 2021-2029 Housing Element Update
Purpose and Authority
three 3) bedroom 1,100 1,100 1,100 1,100 1,100
four (4) bedroom 1,300 1,300 1,300 1,300 1,300
more than four 4 bedrooms 1,500 1,500 1,500 1,500 1,500 Building separation - minimum
(feet)(h)
wall to wall 5 5 5 5 5
eave to eave 3 3 3 3 3
Walkway width — maximum 6 6 6 6
Source: -City of Downey Municipal Code, 2021
Notes:
(a) Single-family dwelling units in the R-1 Zone are eligible for a 0.05 FAR bonus for providing renewable energy sources, for a maximum FAR of 0.50, in accordance with the provisions of Section 9312,08(B)(2).
(b) Porch features, such as but not limited to entry porches, covered patios, and porte-cocheres, must have a top -of -plate height equal to or less than the first floor top - of -plate height of the main structure, not to exceed twelve feet (12'). Top -of -peak height must be equal to or less than the top -of -peak height of the main structure, not to exceed sixteen feet (16'). Slope and pitch must be equal to main structure. (c) Unless the property is identified on the prevailing setback map, as adopted by the Commission, in which case the greater of the two setbacks shall apply. (d) Garage setbacks are subject to Sections 9710 and 9534.22. (a) Any decimal fraction shall be rounded up to the nearest inch, (f) 1 st floor side yard setbacks may be reduced subject to Section 9534. (9) Exclusive of porches, balconies, garages, or other such accessory structures or architectural features. (h) Building separation for rear detached garages is also subject to back up triangle requirements located in Section 9710 City of Downey 9
Determination
Lot area - minimum �sguare feet_
Lot area per dwelling unit - minimum (square
feet)
Table 2-3
5,000 10,000 10,000
1,980 1,980
2,500 1,815 (for lots greater 1,815 (for lots greater
than 15,000 square than 15,000 square
Lot width - minimum (feet) 50
Lot depth - minimum (feet_ Lots shall conform to the
Lot coverage -jmpa�xercent)50
Building height - maximum (feet)
main building 1 30 feet or two stories,
accessory building
Yard setbacks - minimum (feet) _front
front
whichever is less
12 feet
100
100
_L
vera( e cI'eprp)th_oTf9 aTcent lots
— j_
_aj
5 50
0 50
35 feet or three
35 feet or three
stories, whichever is
stories, whichever is
less (a)
less (a)
12 feet
12 feet
20 15
iR
rear 20 see note (b) see note (b)
Yard setbacks (side) minimum (feet)
interior (c) 5 5 (c) 5 (C)
street 10 7.5 7.5
Dwelling unit size - minimum (square
feet) (d), (e)
studio units — 500 500
one (1) bedroom 700 600 600
two (2) bedroom 850 800 800
three (3) bedroom 1,100 1,000 1,000
four bedroom 1,300 1,300 1,300
Buildinq separation - minimum (feet) 10 10 10
Main building and detached garage 5 5 5
separation - minimum (feet
Usable open space area per dwelling unit — -- 200 200
Source: City of Downey Muflitipal Code, 2020
Notes:
* When abutting R-1 or R -2 zoned properties, the variable height requirement shall apply in accordance with Section 9534.24. * When the rear Yard abuts an R-1 Zone, the following minimum setbacks are required: twenty (20) feet for a one (1) story building, thirty (30) feet for a two (2) story building, and forty-six (46) feet for a three (3) story building. When the rear yard area abuts a fully dedicated public alley, the following minimum setbacks are required: no setback required for a one (1) story building, ten (10 feet) for a two (2) story building, and twenty-six feet for a three (3) story building. When the rear yard area abuts another R-3 Zone the following minimum setbacks are required: ten (10) feet for a one (1) story building, fifteen (15) feet for a two (2) story building, and twenty (20) feet for a three (3) storybuilding,
(0 When abutting the R-1 Zone, the minimum setback shall be ten (10) feet. (d) Exclusive of porches, balconies, garages, or other such accessory structures or architectural features. (0 Each additional bedroom over four (4) shall be a minimum of one hundred thirty (130) square feet, 10 2021-2029 Housing Element Update
Purpose and Authority
A Mousing Element is one of the required General Plan elements. It addresses existing and future housing needs of persons of all income levels and provides policy guidance to decision -makers and City staff. The City is not required to constru6 housing to meet those needs, but it must create a regulatory environment that supports and encourages housing production and equal access to housing.
- .1 . 1'VWtW;VVAq"&W. 1 MWPMM
3) housing resources, and 4) housing plan. Article 10.6, Section 65580 — 65589,8, Chapter 3 of Division 1 of Title 7 of the California Government Code establishes the legal requirements for a housing element and encourages the provision of affordable and decent housing, in suitable living environments, in all communities, in working toward statewide goals. The 1 K
elderly, large fami6s', female -headed households, households with a physically or developmentally disabled person, farm workers, and the homeless.
The 2021-2029 Housing Element examines the housing needs of different groups of people based on demographic metrics that include owners versus renters, lower -income households, overcrowded households, elderly households, special needs groups, and homeless persons.
Table 2-4
City of Downey Regional Housing Needs Assessment Allocation City of Downey 11
Determination
Table 2-5
VacantlUnderutilized Land Inventory
The Housing Element includes an inventory of vacanVunderutilized properties that could accommodate residential uses based on an analysis ofCounty Assessor data and field checks. The vacant/underutilized land inventory totals 30.31 oonea. These vacant sites, identified in Table 2-0 (Currently Available Vacant/Underutilized Land Inventory), have the potential to accommodate 2'223 units with applicable land use and zoning mquimmants, such as consideration of parking, landscaping, and right-uf-weyrequirements.
12 202/-2028 Housing Element Update
Purpose and Authority
Table 2-6
Currently Available Vacant/Underutilized Land Inventory Estimated ADU Production
acres total
acres total
Downtown DoTIg Specific Plan:
1.75 acres total
2.05 acres total
4.39 acres total
14.85 acres total
Total Sites C i Available
F�e`maining RHNA after a pp roved/pro posed
I
94 94
21 Estimated ADU production are credited toward the RHNA consistent with HCD guidelines and SCAG affordability distribution assumptions (SCAG Regional Accessory Dwelling Unit Affordability Analysis, 2020)
standard are credited toward the moderate- and above moderate -income category, The Housing Element identifies a remaining need for 3,510 units after consideration of credits and sites currently in place (no land use changes needed). The vacant land and underutilized land identified a combined capacity of2.222dwelling units of which 1.400 units include sites suitable for development ofvery low- to low-income housing. Based on the onu|yoia provided in the Housing Element, the City has determined that adequate sites are not available tuaccommodate the RHNAand that subsequent to adoption of the Housing Bemont, within three years of such adoption the City will amend the General Plan and zoning ondinanme/mopha accommodate the shortfall. The sites to be considered have been identified and are summarized in Table 2-7and shows that once appropriate land use and zoning ouUuno are taken, the City can adequately accommodate, and even exceed, the remaining RHNA of 3,510 units. While the table shows a deficit of 433 units for the low-income RHNA. those units can be addressed with the surplus of 683 very low-income sites.
Subsequent to and within three years of Housing Element adoption,the City will amend the General Plan and zoning ordinance/map to provide sufficient capacity to accommodate the RHNA allocation. This subsequent General Plan and zoning ordinance amendment process will basubject toCEOAreview. The Housing Element does not propose specific development on any specific Inventory Site at this time; thomfom, programmatic impacts of the Housing Element are similar to those already analyzed inthe General Plan BR.
City of Downey 13
Determination
Table 2-2
IVINkilivil�iWil IT ftY-.
Affordability Level
Above
Ex.Nery
Low Moderate
Moderate
Low (0-
(50.80% Income (80-
Income
50-16AM)l
(120%+AMI)
Total
High Density Residential (R-3) Sites
66 w 371
342
779
(1146 parcels, 24.5 acres total)
Low Density Residential site to
4 40
44 Rezone to High Density
Residential (R-3)
Mixed -Use Sites
143
44 44
231
(21 parcels, 7.78 acres total)
Corridor Residential Ove rli
Telegraph Road
96 44
44 184
, 6.19 acres total)__
Paramount Boulevard
285
151
136
572
(45 parcels, 19.03 acres total)
Florence Avenue
33 33
(1 parcel, 1.1 acres totalL_
Imperial Highway
297
77 77
451
31 parcels, 19.57 acres total)
Stonewood Center
175
175
524
874
70 170
511
851
Florence
92 46
46 184
Total Sites
11,1467
-- 1,078
13764
4,309
Remaining RHNA after approved/
784
433 706
1,587
3,510
proposed projects and sites currently
in place
Remainin RHNA (1-shortfall0su-1—s
—
+683
—
-433 +372
+177
—
+1,222
Notes:
Sites allowing the State -designated default density standard (at least 30 du/ac) are credited toward the lower income RHNA, Small sites (less than 0,5 acres) meeting the default density standard are credited toward the moderate -income
category. Sites that meet the density requirement but do not have a minimum ca aci for 16 units are re uired b law for lower -income, shortfall sites are credited toward the moderate -income RHNA shortfall, The proposed updated Housing Element includes the following goals, policies, and programs:
Goal 1. Encourage a variety of housing types to meet the existing and future needs of City residents.
Policy 1.1 Accommodate a variety of housing types to meet the needs of all residents.
Policy 1.2 Encourage and facilitate a range of housing to accommodate the City's share of regional housing and special housing needs.
Policy 1.3 Implement land use policies and standards that allow for a range of residential densities and housing types that will enable households of all types and income levels opportunities to find suitable ownership and rental housing in the City.
14 2021-2029 Housing Element Update
Purpose and Authority
Policy 1.4 Encourage the development of residential units and the provision of related services for special needs groups, including the *ldedy, large houuoho|ds, single pamnts, persons with disabilities, extremely low-income persons, and persons experiencing homelessness.
Policy 1.5 Encourage infill development and recycling of land to provide adequate residential sites, Policy 1.6 Support the assembly of small vacant or underutilized parcels to enhance the feasibility of infill development.
Policy 17 Facilitate the development of accessory dwelling units on single-family properties citywide.
Goal 2. Assist in the development of adequate housing and provide resources to meet the needs of low- and moderate -income and special needs households.
Policy 2.1 Facilitate housing development affordable to lower -income households by providing technical assistance, regulatory incentives and concessions, and financial resources as funding permits.
Policy 2.2 Encourage the inclusion of housing affordable to lower -income households when reviewing proposals fof new housing developments
Policy 2.3 Encourage and provide incentives for both the private and public sectors to produce or assist in the production of affordable housing, with emphasis on housing affordable to persons with disabilities, seniors, large families, female -headed households with children, and people experiencing homelessness.
Policy 2.4 Provide rental assistance to address existing housing problems and provide homeownership assistance to expand housing opportunities.
91olicy 2.5 Support regional efforts to develop affordable housing and address homelessness.
Goal 3. Where legally possible, remove governmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities.
Policy 3.1 Review and adjust residential development standards, regulations, ordinances, departmental processing procedures, and residential fees related to rehabilitation and construction that are determined to constrain housing development.
Policy 3.2 Utilize density bonuses, fee reductions, or other regulatory incentives, as available and appropriate, to minimize the effect of governmental constraints,
Policy 3.3 Monitor State and federal housing -related legislation, and update City plans, ordinances, and processes as appropriate to remove or reduce governmental constraints.
Policy 3.4 Facilitate coordination between lending institutions, the real estate and development community, and the City to better understand and address non -govern mental constraints and facilitate production of affordable Policy 3.5 Eliminate zoning and other regulatory barriers to the placement and operation of housing facilities for the homeless and special needs populations in appropriate locations throughout the City, Goal 4. Conserve and improve the conditions of neighborhoods and existing housing, especially affordable housing.
Policy 4.1 Assist in the conservation and preservation of all affordable housing units, including mobile home parks and govern ment-s u bs id ized housing, and especially those at risk of converting to market rate housing.
Policy 4.2 Promote the repair, revitalization, and rehabilitation of residential structures which have fallen into disrepair.
Policy 4.3 Leverage State and federal loans and grants to assist in preserving existing housing and rehabilitating unsound housing structures,
Policy 4.4 Pursue comprehensive neighborhood preservation and reinvestment strategies for portions of the community City of Downey 15
Determination
with aging and deteriorating housing and infrastructure, Policy 4.5 Encourage energy conservation and sustainable building measures in new and existing homes, Pu|ioy4.O Encourage development and long-range planning that uses compact urban forms that foster connectivity, walkability, and use of alternative transportation modes.
Goal 5. Promote and affirmatively further tm|r housing opportunities and promote housing throughout the community for all.
Policy 5.1 Affirmatively further fair housing related to the sale, rental, and financing of housing to avoid discrimination based on race, religion, age, sex, marital status, ancestry, national origin, color, familial status, or disability, orany other arbitrary factor.
Policy 5.2 Promote and affirmatively further fair housing nppndmnUiom and promote housing options throughout the community for all persons.
Policy 5.3 Assist in the enforcement of fair housing |owm by providing support to organizations that can receive and investigate fair housing eUegeUono' monitor compliance with fair housing |awo, and refer possible violations toenforcing agencies.
Policy 5.4 Ensure that persons with disabilities have adequate access tohousing.
Policy 5.5 Facilitate increased participation among traditionally underrepresented groups in the public decision -making process.
Pm|ioy5.O Provide outreach and education for the broader community of residents, residential property owners and operators regarding fair housing practices and requirements.
NOW '101
, Wt
and heavy), Transportation facilities Inventory Sites identified for single-family use are generally surrounded by single family residential uses and located near city boundaries, Inventory Sites identified for high density or mixed -use development are generally centrally located within the city adjacent to limited industrial or commercial uses. 16 202/-2029 Housing Element Update
Purpose and Authority
=11=
Downey City Boundary
Parks and Open Space
Figure 2-2
Approved Propoed Projects (Credits)
Sites To Be Rezoned
Nm Approved or Proposed Projects AM MDR/113 Sites to Rezone Sites Currently In Place
XM LDR/R1 Rezone to MDR/R3
Vacant and Underutilized III
1W Mixed -Use Sites to Rezone
Vacant and Underutitized R2
JIM Co—ercial Specific Plan Sites to RezonE
Downtown Downey SP Sites
Residential Overlay Sites
Residential Overlay Zone
City of Downey 17
Determination
The City ofDowney occupies approximately 12.8oquom miles of land and is located in the southeastern part ofLos Angeles County, about 12 miles southeast of downtown Loa Angeles. The City is bounded by Telegraph Road on the north.
Gardenda|e Street and Foster Road on the south, the San Gabriel River on the east, and the Rio Hondo River on the west, The Cities bordering Downey include Pico Rivera on the north' Santa Fe Springs on the northeast' Norwalk on the east, Bellflower and Paramount on the south, South Gate on the west. and the City ofCommerce onthe northwest. There is no unincorporated County land within the City and it has no Sphere ofInfluence outside ofits municipal boundaries. Regional access hoand from Downey is provided by 1-5 on the north' |-1D5onthe south, 1-005on the east and |-71Obathe west. IVITA GreonLine|ight-nai|1reinson/im*oaneovai|ab|eat1heLokowooUBuu|avardatotion|uootednextbathe|-1O5Fnaeway.
Southern California, including the City of Downey, contains a number of regional earthquake faults and has experienced moderate hosevere gmunduhaking in the past. Underlying soils contain oonU and silt and some areas have constraints for new buildings, Downey and the surrounding communities support developed urban uses and do not support listed or sensitive species ufplants oranimals.
The City is part of the Los Angeles Basin alluvial plain with a relatively flat topography. It is bounded by the San Gabriel River on the east and the Rio Hondo River on the wea1, both of which are fully improved flood control channels in this area.
Gtormwah*rgenerally flows east and west toward the two adjacent rivers.
The Los Angeles Basin has been inhabited by European settlers for hundreds of years, by Native American tribes for many thousands of years, and large mammals and other animals long before humans occupied the area, Themfure, excavation even of previously developed sites may yield paleontological resources (fossils), archaeological, or historical resources, The City of Downey is located within the South Coast Air Basin which has generally poor air quality as a result of car exhaust and other regional pollutants being trapped by seasonal inversion conditions. The mein existing noise sources within Downey include vehicular traffic on neighboring freeways as well as a number of major arterial streets in the City including Telegraph Road, Lakewood Buu|evanj, Bellflower Boulevard, Florence Avenue, Firestone Boulevard, and Imperial Highway.
The City Council must approve General Plan Amendment to incorporate the 2021-2029 Housing Element Update into the General Plan.
Subsequent to and within three years ofHousing Element adoption,the City will amend the General Plan and zoning ordinance/map 0oprovide sufficient capacity toaccommodate the RHNAallocation. This subsequent General Plan and zoning 18 2021-2029 Housing Element Update
Purpose and Authority
DETERMINATION
ENVIRONMENTAL I
LLAFFECTED
Aesthetics
Agriculture Resources
Air Quality
❑
Biological Resources
Cultural Resources
Geology /Soils
Hazards & Hazardous Materials
Hydrology ( Water Quality
Land Use / Planning
Mineral Resources
E]
Noise
❑
Population / Housing
Public Services
E]
Recreation
Transportation/Traffic
❑,
Utilities I Service Systems
Mandatory Findings of Significance
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 would be prepared,
I find that although the proposed project could have a significant effect on the environment, there would 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 would be prepared,
❑ 1 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" impZ on the environment, but at least one effect 1) has been adequately analyzed in an earlier document nt to applicabll e addressed 1i.i based i.. described 'g.i. standards, and ion sheets, An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be Iaddressed.
all Land a City P1 ®ate
ly of Downey
City of Downey 19
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
�A)
=Have a substantial adverse effect on a scenic
B)
Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and
EJ
EJ
El
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 a publicly
El
El
accessible vantage point). If the project is in an
urbanized area, would the project conflict with
applicable zoning and other regulations governing
scenic quality?
D)
Create a new source of substantial light or glare
which would adversely affect day or nighttime
1:1
El
N
El
views in the area?
A) Less Than Significant Impact. The City itself iarelatively flat with no discernable topographic features, however, on clear days the City has views of the nearby San Gabriel Mountains to the north as well as distant views of the Santa Monica Mountains tothe northwest and the Santa Ana Mountains tothe southeast (City 2020. The General Plan BR1 referenced the urban setting of the City and oono|uUoU that all visual and aesthetic impacts would be |eoo than significant and no mitigation was required (City 2005). Future development under the updated Housing Element will not substantially change the |ooadinn, distribution, or overall density of development within the City other than for the Inventory Sites. The City contains no designated scenic vistas although views of regional scenic features may still be available within the City orfrom elevated freeways. Impacts will be less than significant and no mitigation in required.
B)Less Than Significant Impact. Scenic resources are isolated, natural or manmade objects offering eunique visual display to the onlooker, incontrast to the expanse and variety of aesthetic values offered in scenic vistas. All of the Inventory Sites are currently undeveloped or previously developed properties. Significant impacts could occur if the Housing Element update and potential development of the Inventory Sites substantially damaged scenic resources, including, but not limited to, trees, rock outomppingo, and historic buildings within o State scenic highway. corridors, although it does indicate thai various scenic views of nearby mountains are enjoyed by City residents. The General 1 The Initial Study with the Notice mPreparation focused out aesthetics from omore detailed analysis mthe DER City of Downey 20
Plan EIR1 concluded that implementation of the General Plan policies described above would reduce overall aesthetic impacts to less than significant levels and no mitigation was required.
Future development ofany individual Inventory Site will be subject toproject-specific review pursuant to CEQA. Considering that the General Plan BRanalyzed impacts to scenic resources at the program level and concluded that impacts were less than significant, impact with adoption and implementation of the proposed Housing Element will be less than significant and no mitigation ierequired.
C) Less Than Significant Impact. Visual character is the composite physical values of a structure or structures, in contextof the built and/or natural nnvimnment, that include architectural treatment, landscaping, location, and the intangible qualities such as historical context or uniqueness that establish e thematic visual display for the onlooker when viewing the location.
Above most environmental iuuueo, defining visual character is generally uubjeotive, relying on the opinion of the onlooker coupled with the expertise and institutional knowledge of the local jurisdiction to define the visual character nfan area or property.
The visual character of the City varies by location as there are distinct districts and neighborhoods that exhibit their own nature and character. Residential uses are typical of Southern California Mid -Century development, relatively suburban in nature, and are generally distributed throughout the central and northern portions of the City. The "Little Beverly Hills" neighborhoods are primarily in the northern part of the City, The western portion of the City contains two large recreational facilities, the Rio Hondo Golf Club, the Loa Amigos Golf Course, while the oouth*uobum portion of the Cih/, including the former Boeing plant site, supports e variety ofretail commercial, light industrial, and medical -related uses. Smaller retail commercial uses are also distributed along major roadways such as Peramount. Downey, and Brookshire Avenues, and especially atintersections on many ofthe smaller non-residential otnaeta. The Qh/ nunboina little vacant land but many parcels of various sizes with older light industrial uses are slowly being redeveloped with modern uses.
Future development implemented through the policies of the Housing Element will have the effect ofincrementally changing the visual character of each Inventory Site. If the change in the visual character or quality of an Inventory Site, in contextof the existing visual character and quality of the surrounding onvimnment, can be perceived as 'degreding', then the effect of the project may result in potentially significant impacts. Adverse changes to the visual character of an area can reduce the quality of life for occupants and visitors of the area, reduce the uniqueness or singularity of the viewing experience, and/or reduce the historical and/or communal value ofthe visual setting.
Them is no widely recognized threshold for determining when the effects of omeo 'degrade' visual character urquality 10 the point that potentially significant envimnmente|impootsuouldounucHowever,thenunen CEQA1hemhold if whether ornot a projectUnonurhanizeduma\wnu|doonDictwithepp|icab|ezoningondothernagu|ationugovemingoo*nioqua|ity.Thuu. future development on the Inventory Sites will be subject to applicable General Plan Policies and zoning regulations related ko heiQht, mass and oca|e, mrchihadona| style, materials, landscaping, and e mohetv ofother standards that will ensure future housing development is consistent with the visual character intended for the area. Therefore, impacts due to changes to visual character or quality will be less than significant with implementation of existing regulations and no mitigation is required. light scattering in the eye. The effects of excessive light and glare can result in nuisance impacts ranging from viewer annoyance or an inability to see features in the night sky, to health and safety impacts such as temporary blindness while operating a motor vehicle.
City ofDowney 202/-2029 Housing Element Update 21
Environmental Impact Evaluation
nousing needs win be subject to the urty's ITIOnicipal Uode regulating tne installation and operation OT lignting. Implemen 4aion of the lighting requirements of the General Plan and Municipal Code will ensure that lighting is appropriately designed to provide necessary security while not creating undue nuisance or hazards for people at surrounding properties or on roadways in the vicinity of the Inventory Sites. Furthermore, future housing will be subject to standards enumerated in the Code or other documents, requiring review by staff that will limit the use of highly reflective materials thereby minimizing the potential for daytime glare. Impacts to daytime and nighttime views will be less than significant with implementation of exiting regulatory requirements and no mitigation is required,
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 (CALFIRE) regarding the State's inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project, as well as forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board (CARB).
Would the project:
Potentially
Less Than
Less Than
No Impact
Significant
Significant with
Significant
Impact
Mitigation
Impact
Incorporated
A) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the Farmland
El
Mapping and Monitoring Program of the California
Resources Agency, to non-agricultural 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 E]
El
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104 (g))?
D) Result in loss of forest land or conversion of forest land E] EJ EJ
Z
to non -forest use?
E) Involve other changes in the existing environment
which, due to their location or nature, could result in El E]
conversion of Farmland to non-agricultural use or
conversion of forest land to non -forest use?
/W No Impact. According (othe "Important Farmland Finder" within the state'a Farmland Mapping and Monitoring Program (FMMP) webeibe' the anUna City is designated as "not mopped" meaning them is no land considered Prime Famn|onda' 22 2021-2029 Housing Element Update
Environmental Impact Evaluation
WMETTETSTE I-ov
properties and will be subject to City review and approval. Therefore, implementation of the proposed Housing Element will not result in increased impacts as analyzed in the General Plan EIR. There will be no impacts related to the conversion of important farmland and no mitigation is required.
1101 L, rem M =6 a 01 9 9 - M. ITI
did not contain any forest land or land supporting forest resources. Therefore, the proposed Housing Element will not result in direct loss or substantial changes to any forest land and no mitigation is required.
I #
10111 WNIM11 W-1161
City of Downey 2021-2029 Housing Element Update 23
Environmental Impact Evaluation
We iMRTIY Mel rJOIR: W
As] III OJILS I M I I M W I rVJ#Iz1 CA Ira 0 1 islal I son I I rgxza 1 Ira 1011 101TITI I I g Ito VA W i i i I I i T Potentially Less Than Less Than No
Significant Significant with Significant Impact
Impact Mitigation Impact
Incorporated
A)
Conflict with or obstruct implementation of the
applicable air quality plan?
El
1:1
M
i
El
B)
Result in a cumulatively considerable net increase
of any criteria pollutant for which the Project
El
El
0 0
region is non -attainment under an applicable
federal or state ambient air quality standard?
C)
Expose sensitive receptors to substantial pollutant
concentrations?
D)
Create objectionable odors affecting a substantial
number of people?
respectively. The U.S. EPA delegates much of its authority over air quality to CARB which has geographically divided the State into 15 air basins for the purposes of managing air quality on a regional basis. An air basin is a CARB-designated management unit with similar meteorological and geographic conditions. rules • regulations.
24 2021-2029 Housing Element Update
M
1 N M I t I I I I I #A at] 11111 MATITM rMI.1 pis
to below the daily significance thresholds established by the SCAQMD. Subsequent to this Housing Element update, the City will #• undertaking focused General Plan and zoning ordinance amendments to ensure sufficient land use .•. is -W a_&M;
:iinly the Housing Element since the Housing Element itself does not specifically authorize the construction of any housing fevelopment, nor does it indicate where and when specific housing projects will occur. Therefore, programmatic impacts from implementation of the proposed Housing Element related to AQMP consistency will be less than significant and no mitigation is required.
•i • , TrIt "IT71"
mm�-a eff
levels is considerable by exceeding the annual emissions thresholds established by the SCAQMD in its CEQA Air Quality Analysis Handbook (SCAQMD 1993) and, furthermore, would be determined to potentially conflict with implementation of the AQMP. The Downey General Plan contains the following policies related to air quality:
Policy 1.6.1: The City shall monitor, review and comment on regional plans, as they relate to the City's General Plan Program 1.6.1.1: The City shall comply with and incorporate the applicable requirements of the Air Quality and Congestion Management ■
Program 1.6.1.2: The City shall examine and promote land uses that encourage telecommuting, thus reducing VMT (vehicle miles traveled) as required by the air quality plan.
`• 2.3.1: The City shall encourage the use of public transit. 2m4c2w-2—U-P�LEv,oLv.�&pjlniv-,ipp-LL
planning for public transit services,
Policy 2.3.2: The City shall encourage efforts to reduce the number and length of vehicle trips generated by land uses in Downey.
Program 2.3.2.1: Promote the development of park and ride facilities.
Program 2.3.2.2: Promote ridesharing through provision of information to the public.
Program 2.3.2.3: Promote transit -oriented developments.
Program 2.3.2.4: Promote on -site child-care facilities at major employment centers.
Program 2.3.2.6: Encourage efforts to shift the time of day of trips away from peak commuter hours through the use of flex- time, staggered working hours, and • means.
Policy 2.6.11: The City shall encourage bicycling as an attractive alternative to vehicular transportation.
Program 2.6. 1. 1: Encourage the use of bicycling as a form of transportation for employment commuting and business purposes, in addition to recreational purposes.
Program 2.3.1.2: Establish a bikeway master plan to link employment centers, recreational facilities, and bikeways along the Rio Hondo River, the San Gabriel River, Union Pacific Railroad Line, and those of neighboring communities via a network of bike routes, lanes, and paths.
Program 2.6.1.3: Encourage the provision of bicycle racks at retail service and other businesses for use by customers and employees.
Program 2.6.1.5: Promote street intersection design and signalization that are safe and convenient to bicyclists.
Program 2.6.1.6: Promote site development design that is safe and convenient to bicyclists.
1. 1 ill. so
LGAINORNIIINII �slillrdtelj 5115MI NOVE 11 #111154 11 to City of Downey 2021-2029 Housing Element Update 25
Environmental Impact Evaluation
so
require additional mitigation at thTis programmatic level. a"A5�4
pollution in the Basin. The SCAQMD is responsible for preparing the Air Quality Management Plan (AQMP) for the Bas (SCAQMD 2016). The AQMP includes strategies and control measures to reduce and/or maintain the effects that constructi and operation of various uses within the Basin have on regional air quality. The effects of future housing development regional air quality could result in potentially significant impacts on the health of residents if it is determined that a projec individual contribution to cumulative air pollution levels is considerable by exceeding the annual emissions threshol established by the SCAQMD in its CEQA Air Quality Analysis Handbook (SCAQMD 1993) and, furthermore, would determined to potentially conflict with implementation of the AQMP. Criteria pollutants can directly damage the environme both natural and man-made. Impacts to human health include a variety of acute and chronic respiratory illnesse Development • future housing will be subject to environmental evaluation for exemption and potential analysis pursuant CEQA upon application for entitlement permits. Projects found to be exempt from CEQA will not have a significant impact the environment as declared by state legislation. Other projects will be subject to standard analysis and mitigation if required.
The General Plan EIR concluded that build out of the General Plan will be inconsistent with the air district's air quali management plans and will result in substantial increases in criteria pollutant emissions within the air basin. The propos Housing Element does not propose any land use changes •r designate any Inventory Sites that were not already analyzed the General Plan EIR. Therefore Ion t ualit im acts in the Cit have alread been contemrD)Iated and the i)roi)os M M
odors that affect sensitive land uses such as residential areas. Implementation of the General Plan will ensure h-J. 26 2021-2029 Housing Element Update
Environmental Impact Evaluation
City of Downey 2021-2029 Housing Element Update 27
Environmental Impact Evaluation
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
|mpmo±
Impact
Mitigation
Impact
Incorporated
A)
Have a substantial adverse effect, either directly
or through habitat modifications, on any species
identified as a candidate, sensitive, or special
El
E]
z
11 status species in local or regional plans, policies, or regulations, or by the California Department of
Fish and Game or U.S. Fish and Wildlife Service?
B)
Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies,
El
z
El
regulations, or by the California Department of
Fish and Game or US Fish and Wildlife Service?
C)
Have a substantial adverse effect on federally
protected wetlands as defined by Section 404 of
the Clean Water Act (including, but not limited to,
E]
El
marsh, vernal pool, coastal, etc.) through direct
removal, filling, hydrological interruption, or other
D)
Interfere substantially with the movement of any
native resident or migratory fish or wildlife species
or with established native resident or migratory
El
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
El
El
11 z
preservation policy or ordinance?
F)
Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community
El
E]
[z
Conservation Plan, or other approved local,
regional, or state habitat conservation plan?
AA Less Than Significant Impact. According to the General Plan BR, the City does not contain any listed or sensitive species of plants or animals, or critical habitat for any such species. While the City does contain a number ofdrainage/flood oonbm| channels, they contain little or no riparian (otmamoide) or wetland resources subject hathe jurisdiction of various federal or state agencies (U.S. Fish and Wildlife Servioe, U.G. Army Corps of Engineers, Regional Water Quality Control Board, or California Department of Fish and Wildlife). The General Plan also indicates there is little or no potential for these species or other important biological resources to be present within the City (City 2005). The City has been largely developed for many years so no populations of rare or sensitive species are known to occur within the City limits, Duo to the level of disturbance within the Qtv, no sensitive plant species are expected to be encountered, and vegetation is primuri|yrudera| (weedy). Wildlife expected within the City would be non -sensitive wildlife that generally inhabit disturbed urban areas (such as nouuona, squirrels, onvoteu, nuts, common bird op*oieo. etc.), All listed orotherwise sensitive species have low orno potential 28 2021-2029 Housing Element Update
Plan requires that biological studies be prepared when necessary to assess habitat value, implementation of mitigation, a coordination with agencies and individuals with expertise in biological resources.
Subsequent to and within three years of Housing Element adoption, the City will amend the General Plan and zonii ordinance/map to provide sufficient capacity to accommodate the RHNA allocation. This subsequent General Plan and zoni I lie
rga-M Irma
notsing mement in ano 51 Itseii MA Mut IT I
programmatic impacts will be less than significant and no mitigation is required.
B-C) Less than Significant Impact. According to the General Plan EIR and the National Wetlands Inventory, there are riparian or wetland resources within the City of Downey (City 2005)(City 2020). The General Plan EIR determined th implementation of General Plan Policies will prevent any potential impacts resulting from the direct and indirect effects future development within the City to less than significant levels. As outlined in Threshold 4. above, the proposed Housi Element Update will require rezoning that will occur within three years of Housing Element adoption to accommodate t RHNA allocation. The Housing Element itself does not propose specific development on specific site so at this programma ;%qQE9_[_P�n El
Incorporation of the General Plan Policies discussed above will ensure that impacts to riparian and wetland resourc resulting from future development of housing will be less than significant and no mitigation measures are required.
D) Less than Significant Impact. The General Plan EIR concluded the City did not contain any regional wildlife moverne corridors and that impacts to wildlife movement will be less than significant with implementation of General Plan Policie Wildlife corridors and the movement of animals are important in maintaining genetic diversity, accommodating mati patterns, and ensuring that seasonal behavior is not interrupted. Future development of Inventory Sites will not result h incorQoration of General Plan Policies th s
and the like will remain open as wildlife corridors, Impacts ill be le ss than significant and no mitigation measures a required.
E) No Impact. According to the General Plan EIR, the City of Downey has not adopted local ordinances or regulatio X h an , 11•
adopted ordinance or regulation, No impact will result and no mitigation is required.
F) No Impact. There are no established Natural Community Conservation Plans (NCCPs) or Habitat Conservation Pla (HCPs) within or adjacent to the City of Downey. Therefore, implementation of the proposed Housing Element will not confli with any NCCP or HCP. No impact will occur and no mitigation is required.
City of Downey 2021-2029 Housing Element Update 29
Environmental Impact Evaluation
ISM83M
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
A) Cause a substantial adverse change in the
significance of a historical resource as defined in
El
El
0 El
I Section15064.5?
I
B) Cause a substantial adverse change in the
significance of an archaeological resource
El
0 pursuant to Section 15064.5?
C) Disturb any human remains, including those
El
El
interred outside of formal cemeteries?
9T. niarlUTMAN Kim H reTifilm. 11
"111011161111 -W- M-1_4 --- ----
I is 0 0 alp
l 0 - I of I
ig
IM W111W111 11 - is frie A%ar1Gn0 LOS Xmigoa-Tiatic A, TWIM 5 WOF, Q1 1-1 W16W., has been operating for over 125 years.
71 rnlejli ITT f j I I
those in San Marino and Hancock Park. Many of these homes were owned by engineers from the aerospace industry, as well as many doctors and other wealthy individuals, including the famous brother -sister singing duo "The Carpenters" from the 1970's.
30 2021-2029 Housing Element Update
Environmental
The City was once home to o number of facilities demonstrating ^Googie" architecture which was e typo of futurist architecture influenced bvcar culture, jets,th*SpaoeAoe.endtheAtomicAoeUhokwoopopu|orduhngthe|ate1940sinhnUh* miU-1960o. The fonnerJohni*'a Broiler on Firestone is now Bob's Big Boy' and the oldest standing MoDuna|d'a nU|| in operation was built at the corner of Lakewood and Florence in 1953, The first Taco Bell was also built on Firestone Boulevard close tnJohnie'aBroiler but ionulonger inoperation,
Summary. No buildings remain from the former Boeing P|ent, and few ufthe facilities with Googie architecture have been preserved. A number of mansions from the 1940's and 50's in the "Little Beverly Hills" neighborhoods still exist but many have been extensively remodeled. Unfortunately, the primary way of viewing Downey's past is viewing the archives of the Downey Historical Society located inApollo Park.
Because historic properties are not located on any of the identified Inventory Sites, implementation of the proposed Housing Element Update will not cause oubn1onUo| adverse change in significance of historical namnume. Impacts will be less than significant, and nomitigation iurequired.
B) Less Than Significant Impact. The Tungvoare an Indigenous people of California from the Los Angeles Basin and the Southern Channel |n|ando' an area covering approximately 4'OUOsquare miles. In the precolonial era, the people lived in as many as 100 villages and primarily identified bytheir village name rather than by e pan -tribal name. During colonization, the people were referred to aoGaUhe|ehnand F*mond0o. names derived from the Spanish missions built on their land - Mission San Gabriel As6n0e|and Mission San Fernando Rey de Eopofio.The name Tonovain widely used but others choose toidentify ouKizh.
Befomth*enivo|ofSponiahoott|eminthe17UOu.theanootha1wmu|d|aharbeoomaDowneynonuiotedofTnngvaPeop|eNai inhabited a village called G jatnga near the current City ofWhittier and the San Gabriel River. By 1806' the Tongva were providing conscripted labor for Spanish missions. The area was part of the early Spanish rancho of Jose Manuel Nieto. the holder ufthe largest Spanish land grant in California, stretching from the Pacific Ocean to the Puente Hills. Given the long history of Native American settlement in the region, followed by Spanish and Mexican rule, there is a high probability of finding prehistoric (archaeological) resources in the City. At least one prehistoric site is known within the general vicinity of the City (CA'LAN-182, observed in 1950)' which was described as a "historic Gebrie|ino Village," The exact location of this archaeological site isvague and there are three possible locations for the site, none ofwhich are within the City ofDowney.
Similar to potential impacts on historical resources, impacts to archaeological resources from future housing development can result inthe loss ofinformation important to the history (and potentially the pre -history) of California and the people who created and/or used the materials. The potential for uncovering significant neauumoe at Inventory She locations during construction activities is unknown given that no such resources have been discovered and/or recorded previously. The General Plan states that archaeological and historical resources shall be protected and preserved tothe maximum extent In addition, two changes to state law8SB 18 and AB 52) require cities toconsult directly with local Native American tribes to determine ifany tribal cultural resources will be impacted by private development orpublic works projects proposed in the City, All future development of the Inventory Sites will be required to prepare Cultural Resource Assessments (CRAs) to determine if there are any impacts to cultural or tribal cultural resources as required by the Ganono| Plan Conservation Element. This is considered regulatory compliance and not specific mitigation under CEQA.
The General Plan BRconcluded that build out ofthe General Plan will not result inless than significant impacts related |othe substantial adverse change in the significance of archaeological resources. Subsequent to this Housing Element update, the City will be undertaking focused General Plan and zoning ordinance amendments with separate CEQA compliance to ensure sufficient land use capacity is available to accommodate the RHNA. This Initial Study examines the potential environmental impacts at a program |*v*| for only the Housing Element since the Housing Element itself does not specifically authorize the construction of any housing development, nor does it indicate where and when specific housing projectswiU000ur.Thenefore' long-term impacts inthe City have already been contemplated and the proposed Housing Element Update will not result in City of Downey 2021-2029 Housing Bement Update 31
Environmental Impact Evaluation
0 6 "of M 1 0
s M I
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
A) Result in potentially significant environmental
impact due to wasteful, inefficient, or unnecessary
El
consumption of energy resources, during project
construction or operation?
B) Conflict with or obstruct a state or local plan for El 1:1
El
renewable energy or energy efficiency?
M-l""t ITMIM-7 TWO
transportation. According to the U.S, Energy Information Administration (USEIA), California is the most populous state in t United States, representing 12 percent of the total national population, has the largest economy, and is second only to Tex in total energy consumption. However, California has one of the lowest per capita energy consumption levels in the U,S. T is a result of California's mild climate, extensive efforts to increase energy efficiency, and implementation of alternati technologies. California leads the nation in electricity generation from solar, geothermal, and biomass resources (USEIL 2018).
32 2021-2029 Housing Element Update
Environmental Impact Evaluation
Natural Gas. California accounts for less than1% of total U.S. natural gas reserves and production; however, almost two- thirds of California households use natural gas for home heating (U.S. EV\ 2010. In 2018. California consumed about 12.638 million tkennmoofnatural gas. Approximately 35% of natural gas was consumed by the residential sector which makes up approximately two-thirds of county -wide consumption (CEC 2019b). The Southern California 6ou Company (8oCo|Gou) provides natural gas oemiuo to the City. GoCa|6ao is the principal distributor of natural gas in Southern California and provides natural gas for residential, commercial, and industrial markets.
Transportation. California's transportation sector consumed OO.0million Btu ofenergy per capita in2O17'which ranked 31of in the nation (U.S. E|A2O17). Most gasoline and diesel fuel sold in California for motor vehicles is refined in California to meet state -specific formulations required by the California Air Resources Board.
Housing Element Update. Futuna housing developed in accordance with the goals and policies of the HEU will have the effect of contributing to inommuod energy consumption in the City which will be part of regional growth in energy use and the surrounding communities continue to grow as well, Future growth in the City will be required to be consistent with the state's energy conservation regulations as codified in Title 24 of the CCR and the California Green Building Code. In addition, future development must meet the local requirements of the City'a Energy Action Plan (City 2016) which mainly address air quality and greenhouse gas emissions but which also have guidelines for energy conservation on new development. As long as future development adheres tuthese multiple energy conservation plans and requirements, the Housing Element Update will have less than significant impacts relative to energy consumption and efficiency and no mitigation in required. Therefona, the proposed HEU would not use energy in owasteful, inefficiency, orunnecessary manner. 13) Less Than Significant Impact. The analysis in Section 6.b above demonstrates that the proposed Project would not conflict with nor obstruct a state or local plan adopted for the purposes of increasing the amount of renewable energy or energy efficiency. As discussed above, future development under the HEU would be subject to the California Title 24 Building Code energy efficiency standards for residential and non-residential buildings, which would help reduce energy consumption overall within the City. New development would also be subject to the local requirements of the City's Energy Action Plan (City 2015).
Equipment and vehicles associated with construction and operation of new development would also be subject to fuel standards at the state and federal level. Truck traffic from some new non-residential development would inherently benefit from programs implemented to achieve the goals of the state's Sustainable Freight Plan, such as the turnover of older, less fuel -efficient trucks, as fuel economy standards are rolled out and zero emission vehicles (ZEV) trucks and vehicles in general becomes more widely available and cost effective for businesses and residents. Impacts associated with the General Plan and zoning ordinance amendments will be examined at a more focused level since these actions could increase the level of development allowed at specific sites.
Subsequent to this Housing Element update, the City will be undertaking focused General Plan and zoning ordinance amendments with ser)arate CEQA COUDliance to ensure sufficient land use car)acitv is available to accommodate the RHNA.
NO I N3
and when specific housing projects will occur. Future development of any individual Inventory Site will be subject to project - specific review pursuant to CEQA. Therefore, the Project would not conflict with nor obstruct a state or local plan for renewable energy or energy efficiency. Programmatic impacts of the HEU would be less than significant and no mitigation is City of Downey 2021-2029 Housing Element Update 33
Environmental Impact Evaluation
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
A)
Expose people or structures to potential
substantial adverse effects, including the risk of
loss, injury, or death involving:
i) 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,
ii) Strong seismic ground shaking?
❑
Z
❑
iii) Seismic -related ground failure, including
0 liquefaction?
iv) 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 El
El
z
❑
off -site landslide, lateral spreading, subsidence,
liquefaction or collapse?
D)
Be located on expansive soil, as defined in Table
18-1 -B of the Uniform Building Code (1997),
creating substantial 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?
34 2021-2029 Housing Element Update
Environmental Impact Evaluation
?.nd potentially active faults located close to Downey, In addition, new development is required to prepare a geotechnical hazards assessment to identify site specific design and construction guidelines to protect occupants and structures from anticipated seismic impacts. Therefore, impacts related to fault rupture would be less than significant and no mitigation is required.
F—"WM11R--MMdiF Mrs Mi i BriMMEMM FM• I . . Jig t.
1161110191OWN11 INN! 1 11!
all
Gate and Whittier Quadrangles, the entire City of Downey lies within a liquefaction zone (USGS 2020). This conclusion is shallow groundwater levels (CGS 2020b).
steep natural slopes (i.e., foothills or mountains) where fractured and steep slopes. Therefore, there would be no impact related to landslides and no mitigation is required.
B) Less Than Significant Impact. Natural forces, both chemical and physical, are continually at work breaking down and moving rocks, minerals, and soils. Erosion poses environmental hazards through the effect of removing soils that can undermine roads and buildings and destabilize slopes. Erosion can also result in environmental damage by depositing soils in Ownstrearn reservoirs, lakes, and drainage structures that can result in impacts to wildlife and human health by changing the tcological properties or the physical boundaries of the water body or drainage control device, The City of Downey General Plan EIR concluded that impacts will be less than significant with implementation of the General Plan and Municipal Code related to grading limitations.
OWN -01 -410
# 'T4 Rig
0 # I I VZO) M DION 11ATAW 11111 P. I IRN11 11T.M.1 PA
City of Downey 2021-2029 Housing Element Update 35
Environmental
is subject to moderate to severe gmunduhekingfrom frequent earthquakes. In addition to liquefaction, strong gmundahoNng can trigger other seismic hazards including lateral spreading, landslides, aubmidonue, or collapse (Downey 2004. The California Seu|ugiva| Survey (CGS) mapping indicate this portion of the Basin is underlain by Quaternary or Recent Alluvium /Qa|\ which consists of "recent o|uy' aiK' sand and gravel, unconso|idated, poorly stratified to well stnatified, including alluvial fan, flood -plain, and atnaombed deposits" (CGS 2020o\ No oman in the City are prone to landslides due tothe lack ofsteep natural slopes (i.e., foothills or mountains) where fractured and steep slopes.
New housing that would be built under the HEU would aUU be within the growth limits identified in the 2005 General Plan and evaluated in its BR. New housing would be subject to state seismic safety requirements of the California Building Code as adopted by the Qty. In addition, new development is required to prepare e genteohnioa| hazards assessment to identify site specific design and construction guidelines to protect occupants and structures from anticipated seismic impacts, including liquefaction, lateral spreading, |ondo|idee, subsidence, or collapse. Thorefona, impacts related to unstable geology orsoils would beless than significant and nomitigation isrequired.
D) Less Than Significant Impact. Expansive soils are those that greatly increase in volume when they absorb water and shrink when they dry out. Expansion is measured by shrink -swell potential defined by the relative volume change in soil while gaining in moisture. If the shrink -swell potential is rated moderate to high, damage to bui|dingo, meds, and other structures can occur. Although the City imgenerally underlain bysandy and silty alluvial uoi|s, there may be areas with soils exhibiting o high to moderately high shrink -swell potential which are considered expansion.
Future housing developed pursuant tothe policies ofthe proposed Housing Element will besubject hothe requirements ofthe California Building Cod* (CBC) an adopted by the Cdv, including preparation nfa soils report. Th*CBC requires analysis of soils and application ofengineering standards Vuensure project oihaaemmedoaudab|efnrbui|dingunnohuction'pertiou|adyin regard to foundation design. Foundation and structural design for proposed development of the Inventory Sites will be subject to analysis and design recommendations by a licensed geotechnical engineer for review and approval by the City, In addition, the General Plan requires the preparation ofpreliminary soil, geoteuhnice|, or seismic napuda. Themfove, impacts due to geological and soils hazards will be less than significant and no mitigation is required.
BLess Than Significant Impact. The City Municipal Code requires use of the public sewer system and prohibits the installation or maintenance of septic tanks or other facilities intended for the disposal of sewage. Therefore, there are no impacts and no mitigation is required.
FlLess Than Significant Impact. According to the General Plan EIR, there are no known geological resources and/or unique geological features located within the City including any of the Inventory Sites. The General Plan BR concluded that development inthe City would not have adverse effects on paleontological resources. The proposed Housing Element Update does not propose any land use ohenOoo or designate any Inventory Sites that were not o|naody analyzed in the Sanenu| Plan E|R. Therefore, long term impacts have already been evaluated and the proposed HEU will not result in impacts that are greater than those contemplated in the General Plan EIR. In addition, future development of the proposed Inventory Sites will be subject to the Goals and Policies of the General Plan and will be subject to environmental evaluation for exemption and potential analysis pursuant to CEQA. Therefore, potential impacts on paleontological resources related to implementation of the proposed Housing Element Update will be less than significant and no mitigation is required. 36 2021-2020 Housing Element Update
Environmental Impact Evaluation
Generate greenhouse gas emissions, either
directly orindirectly, thatmayhaveasignifiuun
impact on the environment?
13) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing the
emissions of greenhouse gases?
Potentially
Less Than
Less Than No
Significant
Significant with
Significant Impact
Impact
Mitigation
Impact
Incorporated
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L� � +—'
A) Less than Significant Impact. Climate change isthe distinct change inmeasures ofclimate for olong time period.
Climate change in the result of numerous, cumulative sources of greenhouse gam emissions all over the world. Natural changes in climate can be caused by indirect processes such as changes in the Earth's orbit around the Sun or direct changes within the climate oyubam itself (i.e., changes in ocean circulation). Human activities can affect the atmosphere through emissions nfgreenhouse gases (GHG) and changes 1othe planet's surface. Human activities that pmduoeQHGa are the burning of fossil fuels (coal, oil and natural gas for heating and electricity, gasoline and diesel for transportation); methane from landfill wastes, raising livestock, and deforestation activities; and some agricultural practices.2 Greenhouse gases differ from other emissions in that they contribute to the "greenhouse effect,"The greenhouse effect is natural occurrence that helps regulate the temperature of the planet. The majority of radiation from the sun hits the Earth's surface and wmnna it. The surface in turn radiates heat back towards the atmosphere, known an infrared radiation. Gases and clouds in the atmosphere trap and prevent some of this heat from escaping back into space and re -radiate it in all directions.
This pmoeuo is essential to supporting life on Earth because dwarms the planet by approximately OO" Fahrenheit. Emissions from human activities since the beginning of the industrial navn|uUnn (approximately 25O years ago) are adding to the natural greenhouse effect by increasing the gases in the atmosphere that trap heat, thereby contributing to an average increase in the Earth`ntemperadum. Greenhouse gases occur naturally and from human activities. Greenhouse gases produced by human activities include carbon dioxide (CO2)' methane (CH4), nitrous oxide (N20)' hvdroNuumuorbonn (HFCu), perfluomcurbono (PFCo). and sulfur h*xoflunhUe (GF6)- Since 1750. it is estimated that the concentrations of carbon dioxido, methone, and nitrous oxide in the atmosphere have increased owar50 percent, 148 percent, and 18 percent, respectively, primarily due bo human activity. Emissions of greenhouse gases affect the atmosphere directly by changing its chemical composition while changes to the land surface indirectly affect the atmosphere by changing the way the Earth absorbs gases from the atmosphere.
The General Plan BRdid not evaluate GHBimpacts asthat environmental issue was not considered in CEQA documents at that time. The General Plan BR which oondm1aM overall development would have significant air quality impacts and o Statement ofOverriding Considerations was adopted for that significant adverse and unavoidable impact. Subsequent to this Housing Element update, the City will be undertaking focused General Plan and zoning ordinance amendments with separate CEQ4compliance toensure sufficient land use capacity is available to accommodate the RHNA. This Initial Study examines the potential environmental impacts at a program level for only the Housing Element since the Housing Element itself does not specifically authorize the construction of any housing devo|opment, nor does it indicate where and when specific housing projects will occur.
NOW
2 United States Environmental Protection Agency. Frequently Asked Questions About Global Warming and Climate Change. Back mBasics, April 2009, City of Downey 202/-2020 Housing Element Update 37
Environmental lmoact Evaluation
I I mfg-&-fl • r-fs-1 I Fi FT-,TM7TrF7V7M tie pTWTFT77—,F3pFTMcT Ur their • GHG emissions.
.M
I 11T.51 51TI
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.604 111 a
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CEQA. The EAP states the following...
that are being considered and future opportunities that will contribute to the energy reduction goal. In addition, this E identifies other potential energy reduction measures that the City will consider for future implementation. The City's Ion term vision for energy efficiency focuses around four primary objectives: (1) Reduce the City's carbon footprint and adverse effect on the environment; (2) Conserve energy at the local government facilities; (3) Raise energy conservat awareness in local community and improve the quality of life; and (4) Achieve Platinum Status on the Local Governm Agency Partnership."
I 1 11111 1i L I I I C I
emissions.
38 2021-2029 Housing Element Update
9. HAZARDS AND HAZARDOUS MATERIALS
Would the project:
A) 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 with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
B)
Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
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E
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release of hazardous materials into the
environment?
C)
Emit hazardous emissions or handle hazardous
or acutely hazardous materials, substances, or
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waste within one -quarter mile of an existing or
proposed school?
D)
Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a
result, would it create a significant hazard to the
public or the environment?
E)
For a project located within an airport land use
plan or, where such a plan has not been adopted,
within two miles of a public airport or public use
1:1
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airport, would the project 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
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emergency evacuation plan?
G)
Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or
❑
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death involving wildland fires?
to potential hazards to the public or the environment because these uses do not involve the use, transport, or disposal of appreciable amounts of hazardous materials or wastes. For purposes of the following analysis, a "significant hazard to the azariit . . . . . .....
City of Downey 2021-2029 Housing Element Update 39
Environmental Impact Evaluation
reasonably foreseeable that upset and accident conditions cannot bamet bvthe use, transport, and disposal ufsuch materials and wastes from future residences. Consumer -level household hazardous materials and wastes are not subject hufederal or state permitting bythe consumer, and their use is at such |*ve|u as to not have the potential to result in risk ofupset or accident that could harm n substantial number of peop|o, including children attending schools in the area, or have o substantial effect onthe functions ufthe local urregional ecosystem.
Hazardous Sites: The proposed Inventory Sites are not listed as hazardous waste and aubnhunoan sites, leaking underground storage tank uitea, solid waste disposal nibao, hazardous waste facilities subject hocorrective eufiun' or sites regulated by the Regional Water Quality Board.3 There are no Cleanup Program Sites located within the City of Downey at this time. In addition, the General Plan requires that residential projects and other sensitive receptors be located an adequate distance from existing and potential sources of toxic emissions. In eUUiUon. CEQA requires the assessment of risk involving the transportation, dinpuoe[ menufaoturo, stonage, and handling of any hazardous materials for new development. Therefone, development of future housing on proposed Inventory Sites will be required to assess impacts due to the accidental release of hazardous materials as part of standard environmental review procedures pursuant to CEQA and City policy.
Materials and Wastes Transport: According bothe General Plan BR' hazardous materials pass through the City in route to other douUnaUmno via nei|, oudam* streets, and freeways. While train derailment can occur at any time, it is during an earthquake that a derailment and hazardous materials release would pose the greatestrisk ofhazards. The City has nodirect authority to regulate the transport ofhazardous materials on local and regional roadways or railways; however, under upset and accident uunditinnu, it is reasonably foreseeable that most ufthe spill would be contained within the right-of-way of roadway with minimal chance ofhazardous materials orwastes reaching adjacent homes. On the other hand, K is n0000nob|y foreseeable that train derailment would result in extensive impacts to adjacent residents as the train and multiple train cars leave the tracks and violently careen with the adjacent environment. Transportation of hazardous materials and wastes by truck and rail ioregulated bythe U.S. Department of Transportation (DOT). DOT regulations establish criteria for safe handling procedures, and federal safety standards are also included in the California Administrative Code, The California Health Services Department also regulates the heu|am ofhazardous waste but does not regulate all hazardous mateha|u. Although there is some reasonably foreseeable potential for exposure of future residents to hazardous materials and wastes under upset and accident conditions, federal and state regulations are in place with a focus on prevention of accidental releases and measures for appropriate containment and cleanup when accidents occur.
Facilities: According tnthe Envimstur4wmbaiteofthe California Department ufToxic Substances Control, the City ofDowney has 18 total facilities listed within Downey although only nine of them require further action (testing or namediatinn\. Theme aihao spread throughout the City as a result ofits long history with industrial uses. Both the federal government and the 6to0a of California require all buuin*uoao that handle hazardous materials or extremely hazardous mat*ho|o to submit Uuoinaou risk management plan to the local Certified Unified Program Agency (CUPA). The CUP4with responsibility for the City is the County'a Environmental Health Department. The business risk management plan must include an inventory of the hazardous materials and emergency response plans and procedures to be used in the event ofa significant release of hazardous material. Implementation of federal and state requirements for the operation of those types of facilities will ensure that exposure horesidential uses will beminimized uravoided.
Considering the preceding analysis, the proposed Housing Element Update will not result in effects from the use, transport, or disposal of hazardous or acutely hazardous materials or wastes, under normal o, upset and accident conditions, which could impact human health or the environment with implementation of existing negu|oUnnn, standards, and 6oneoo| Plan Policy.
Impacts will b*less than significant.
E) No Impact. Airport safety issues and their connection with land use planning are generally associated with hazards posed by departing and landing aircraft crashes and the effects those crashes could have on uuoo and people on the ground. qJ California Environmental Protection Agency. Cortese List Data Reaoumeo. http://wmvwoalopm.my [December 7.2U2O
40 202/-2029 Housing Element Update
Environmental Impact Evaluation
Development within the approach and departure zones of anairport mairstrip are subject to the effects of potentially wideopmad, although nena, aircraft crashes; thorefom, the denser the development and population within these zones, the greater the risk of impacts to human health. Aircraft crashes can result in the substantial loss of property and life depending on the size of the aircraft, its ve|ocity, the pitch, yaw, and mU at the moment of impuot, and the typo of cargo it is carrying.
Development within the vicinity of an airport can result in increased potential for impact due to height, glare, and electronic interference that can disrupt flight patterns and pilots operating out ofthe airport.
The Los Angeles County Airport Land Use Commission (ALUC) is responsible for ensuring that development within the vicinity of an airport does not cause undue risk to airport operations or the safety of persons on the ground. The commissioners represent the county, its cities, and the public. Legislation passed in 1002estoU|inhad adimot link between airport land use plans and the land use plans and regulations adopted by cities and oountine, as established in California Public UU|id*a Code Section 21076, In annondunoo with this |ogiu|o1Nn. Uh*ALUC must review the general and specific plans of local jurisdictions for consistency with the county's airport comprehensive land use plan (CLUP). Primary and Secondary Review Areas must be identified for each facility. Projects pmposmdwi1hinthogeognaphioboundehesofthePhmeryReviewAmuonanefemadho[he ALUCfor review and evaluation, Within the Secondary Review Area, only those projects invo|vingastnuo1umorothernbjent with u height that would exceed that permitted under adopted land use zoning would be referred tnthe ALUCfor review.
The closest airports tothe City are the Fullerton Airport located approximately 7.5miles tnthe southeast and the San Gabriel Valley Airport in B Monte located approximately 9.3 miles to the northeast. The City does not teU within the Planning Boundary/Airport Influence Area for either airport (DRP 2004). Therefore, Downey is not located within two miles of any airport and is not located within any airport land use p|on, so there is no impact and no mitigation required.
F) No Impact. The City Office ofEmergency Management coordinates disaster response and recovery efforts in the City of Downey. The City's goal is to respond to emergency situations with a coordinated system of emergency service providers and facilities. The City has planned nmponoao to extraordinary emergency situations associated with natural dieostana, technological incidents, terrorist activities, and war -related operations. The City is part ofa county and statewide emergency management system that addresses evacuation and movement of people in the event ufon emergency. It should be noted that the City'y plans are flexible in order to respond to the inherent nhuuu associated with disasters in a manner that is coordinated but responsive to the immediate needs of the situation, The proposed Housing Element Update does not include any land use, circulation, or safety changes that could conflict with implementation of the Office of Emergency Management or other emergency response programs, Noimpact will occur.
G) Less than Significant Impact. As noted by CALF|RE Fire Hazard Severity Zone Maps, the City is not located in an area of high fire threat (CGG 2020). Because Downey is on urbanized oommunib/, structural fires rather than wi|d|ond fires represent the greatest fire risk in the City. The CBC focuses on the construction and materials used in roofs, attic ventilation, exterior wmUo' decking, floors and underDoum, and ancillary bui|dinga, structures, and appendages. Implementation of these requirements will ensure that future housing with the WUI is constructed to withstand wildland fires, thereby minimizing any associated impacts. Therefore, impacts will be less than significant with implementation of existing regulations.
City of Downey 2021-2029 Housing Element Update 41
Environmental Impact Evaluation
10. HYDROLOGY AND WATER QUALITY
Would
the project:
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporation
A)
Violate any water quality standards or waste
discharge requirements or otherwise substantially
❑
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degrade surface or ground water quality?
13)
Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge
E]
Z
El
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 that
would:
(i) result in substantial erosion or siltation on- or
off -site;
(ii) substantially increase the rate or amount of
❑
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El
surface runoff in a manner which would result in
flooding on- or off -site;
(iii) create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide
substantial additional sources of polluted runoff;
or
(iv) impede or redirect flood flows.
D)
In flood hazard, tsunami, or seiche zones, risk
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release of pollutants due to project inundation?
E)
Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
1:1
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management plan?
A) Less Than Significant Impact. The City of Downey has prepared a Stormwater Management Implementation Plan to support the City's application for a Municipal Storm Water (MS4) Permit to the Los Angeles Regional Water Quality Control Board. The Plan represents the five-year management strategy for controlling the discharge of pollutants to the maximum extent practicable in storm water runoff during the first NPDES storm water permit term. Downey's Municipal Codt implement's the City's storm water quality management strategies consistent with its General Construction permit from the Regional Water Quality Control Board. These regulations are applicable to all storm water generated on any developed or undeveloped land within the city.
nousing is a GOMMOIFTJfe o i.n aelmopfn
42 2021-2029 Housing Element Update
Environmental Impact Evaluation
9 off
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term increases in demand for groundwater and other water resources. The City is situated between the San .• and Rio Hondo Rivers both of which are fully improved flood control channels. Water is essential to the proper function of an ecosystem and human life and activities; thus, water shortages can impact the health and well being of humans and the • • the •
According to state law, local water agencies must regularly update their Urban Water Master Plan and large development projects must prepare a separate water supply assessment (WSA) to identify how to avoid or reduce impacts on surface or groundwater supplies over a 20-year period even under drought conditions. #
$101111ir t I I LOI I 1011 IS I I I Rl I I a #J
s in Ticani impacts in glouliuwaftjr levels Men CUrllpaIeU LU 111U allal SIS a I 14950116clilu"111 5111n, I the General Plan ■
5 Los Angeles Regional Water Quality Control District. Water Quality Control Plan (Basin Plan)(CWB 2018) City of Downey 2021-2029 Housing Element Update 43
Environmental Impact Evaluation
reoourceo, decreased water quality with similar impacts to aquatic biological resources, and storm water backup that can result in similar types of flooding impacts.
According to the General PlanBR, implementation of the General Plan will reduce potential impacts related to additional runoff such anerosion and flooding 10less than significant |evo|uendmquiremfhemaintemanmeofadaquatefaci|iti*mforwater and storm drain services. Therefore, impacts due to the effects of changes in drainage patterns or potential erosion relative to the HEU will be less than significant with implementation of existing regulations and General Plan goals and policies.
Inundation from the Hoover Reservoir and Whittier Narrows Dam located 4.2 miles northeast of Downey poses the greatest threat from dam inundation for the City. The dam was built aooflood risk management and water conservation project in1957 and creates o reservoir capacity of975 million gallons of water. In 2015. the U.S. Army Corps of Engineers determined the dam is structurally unsafe and poses a potentially catastrophic risk to the communities along the San Gabriel River floodplain.
In addition, engineers found that the mile -long earthen structure could fail ifwater were bzflow over its crest or if seepage eroded the sandy aui| underneath. Measures to permanently oddnmon these issues are currently being developed and evaluated (as of2O2O). The U. G. Army Corps of Engineers (USACE) has determined that inundation from dam failure would affect all the commercial, industrial, and residential areas of the City (USACE 1985).
For future housing under the HEU, the General Plan requires each project to demonstrate it is not impacted by a 100-year flood zone or what steps it will take to eliminate that risk. CEQA also requires projects identify specific criteria and conditions that must be met to avoid potential impacts from flood hazards such as application of flood hazard regulations, evaluation of development sites for flood hazard potential, and application of flood -proofing strategies. Therefore, impacts will be less than significant and no mitigation is required.
Oeiche isthe process by which water sloshes outside its containing boundaries, generally due to anearthquake. Geiche can result in localized flooding that can result in property damage or personal injury. This could occur within an open reservoir, lake, or other large waterbody (see discussion regarding the Hoover Reservoir). The City does not contain any sizeable open nanemoim. |ekem. or other large bodies of water, therefom, impacts resulting from the effects ofueiuhe in the City will be |euo than significant and no mitigation is required. Atsunami io a large wave that generates in the ocean, generally from on earthquake, and builds intense strength and height before impacting a coast. Tsunami can result in significant pmpadx damage and loss of life due to the intense, destructive nature of the wave and the often -sudden occurrence with little chance for warning. The City would likely experience minimal impacts from the effects of a tsunami because it is located a minimum of 12 miles inland of the Pacific Ocean. In addition, according to the General Plan EIR, the City is relatively flat and risk of hazard due tomudf|uwioless than significant.
Therefore, the potential impacts of flooding, tsunami, or aeicho and any related release of pollutants would be less than significant and no mitigation is required.
E) Less Than Significant Impact. This assessment is for both surface water management planning and sustainable groundwater management plans.
""HIM oil
44 202/-202AHousing Element Update
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Angeles RWQCB region, and changes to beneficial use designations and associated water quality objectives. The General Plan requires future development to be consistent with the it Plan. Therefore, the HEU will not conflict with or obstruct implementation of a water quality control plan.
Groundwater Management Plan. In 2014 the governor signed the Sustainable Groundwater Management Act (SGMA) into law which requires governments and water agencies of high and medium priority basins to halt overdraft and bring groundwater basins into balanced levels of pumping and recharge. SGMA empowers local agencies to form Groundwater Sustainability Agencies (GSAs) to manage basins sustainably and requires those GSAs to adopt Groundwater Sustainability Plans (GSPs) for crucial groundwater basins in California. accommodate the RHNA. This Initial Study examines the potential environmental impacts at a program level for only the Housing Element since the Housing Element itself does not specifically authorize the construction of any housing development, nor does it indicate where and when specific housing projects will occur. Therefore, the HEU will not conflict with or obstruct implementation of a sustainable groundwater management plan. Impacts will be less than significant and no mitigation is required.
•
Would the project:
Potentially Less Than
Less Than
No
Significant Significant with
Significant
Impact
Impact Mitigation
Impact
Incorporated
a) Physically divide an established community?
10 El
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Z
b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
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1:1
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adopted for the purpose of avoiding or mitigating an
environmental effect?
A) No Impact. Communities form neighborhoods within a broader assemblage of land uses, acting as physically bounded and typically culturally and economically homogenous social networks that often define a person's local sense of place and help shape an individual's social and cultural perspective, particularly as a youth. Such communities typically are self -policing uidulv lJQseW`iile fabric aji!4 Dirit t'iat Demetug e e coil n A q ling I JJ1 f;L2.rJ—W-#J &—# rs J 7 TMDL is a regulatory term in the U,S,gWgftNq1g Act, describing a plan for restoring impaired waters that identifies the maximum amount of a pollutant that a body of water can receive while still meeting water quality standards City of Downey 2021-2029 Housing Element Update 45
Environmental ImPactEvaluatiu
if proposed Inventory Sites are sufficiently large orconfigured in such a way so auto create a physical barrier within an established community.
Subsequent to and within three years of Housing Element adoption,the City will amend the General Plan and zoning ordinance/map to provide sufficient capacity to accommodate the RHNA allocation, This subsequent General Plan and zoning ordinance amendment process will besubject tn a new and separate CEQA review process. The Housing Element does not pmpuua specific development on any specific Inventory Site atthis time. The proposed Housing Element identifies Inventory Sites throughout the City ofDowney. The General Plan does not designate any established communities defined by o Specific Plan that would be affected by implementation of the proposed Housing Element; therefore, implementation of the proposed Housing Element will not onaata any physical barrier within the community. Furthenmum, project implementation will not require new infrastructure systems such as roadways or flood control channels not already planned and previously considered in the General Plan BR. As such, the Housing Element update will not divide or disrupt neighborhoods or any other established community elements. No impact will occur and no mitigation is required.
B) No Impact. The Housing Element update sets forth policies toencourage housing development consistent with adopted |nmd use policies established in the General Plan. As outlined in Threshold 11.A above, the Housing Element does not propose construction on any ofthe Inventory Sites at this time, and the subsequent General Plan and zoning ordinance amendment process will be subject to o new and separate CEQ8review process. The Housing Element does not include any goals, policies, or programs that would conflict with adopted General Plan goals and policies to mitigate impacts due to effects generated bvdevelopment within the Planning Area, as specified in the certified General Plan BR. No impact will occur and no mitigation is required.
12.MINERAL RESOURCES
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
A) Result in the loss of availability of a known
mineral resource that would be of value to the
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region and the residents of the state?
B) Result in the loss of availability of a locally
important mineral resource recovery site
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delineated on a local general plan, specific plan or
other land use plan?
A-113)Less Than Significant Impact. Minerals refer to aggregate resources, mrock, sand, and gravel,energy-producing fields, including oil, Qoo' and geothermal uubutanoeo, and related mining operations. The California Department of Conservation (DOC) classifies land in the state into mineral resource zones based on the known or inferred mineral resource potential of that land (DOC, 2020a). The City is located in the San Gabriel Valley Production -Cons u m ption (P-C) Region of the greater Los Angeles metropolitan area (DOC. 2020b). Land in the City has been classified by the California Division of Mines and Geology /CDMG\ according to the presence or absence of significant sand and gnmv*| deposits (suitable for use in construction -grade aggregate). The land classification is presented in the form ofmaps showing Mineral Resource Zones (MRZ). There are four MRZ classifications, MRZ-1 through MRZ-4 as described below:
• MRZ'1 are areas where adequate information indicates that no significant mineral deposits are present, or where it is judged that little likelihood exists for their presence. • MRZ-2 are amoo where adequate information indicates that significant mineral deposits are present orwhere it is judged that a high likelihood for their presence exists. 46 2021-2029 Housing Element Update
• MRZ-3are areas containing mineral deposits the significance ofwhichoonno\Ueevouotedfrnmemui|abledate. • MRZ-4 are areas where availability information is inadequate for assignment to any other MRZ-zone.
The General Plan BRstates that the City has not designated locally important mineral resource recovery areas within or immediately adjacent to the City. The Downey General Plan BRonnduded that there will be no impact to the availability of mineral resources of value to the State or City.
Oil Wells. Union Oil of California first drilled two dry holes in 1919 before hitting a successful oil well on its third attempt in 1921 (Downey, 2020). Within a year, the Downey oil field was considered one of the richest pools in petroleum history, and the City became a promoters' paradise. In its peak during the 1920s, the oil field produced as much as 60 ' 000 barrels daily.
By 1924, 81 million barrels of oil had been pumped from the ground. Since 1977, more than 40 different providers havg maintained wells in the Downey oil field; however, the only active operator currently is Maverick Natural Resources (formerly Breitburn Energy). Active oil wells (wells still extracting oil) are located in the central and eastern portions of the oil field, occupying approximately 10 city blocks, or 784 acres.
According to the state Department u[Conservation, there are currently ototal of1,402 oil wells inthe City nfwhich 221are ecdme. 88 are idle. and 1.093 have been plugged (DOC 2020. Idle wells are oil and gas wells which are not in use for production, injection, or other purposes but also have not been permanently sealed. A well is plugged by setting mechanical or cement plugs inthe wmUboneodspecific intervals huprevent fluid flow.
Subsequent to and within three years of Housing Element . the City will amend the General Plan and zoning ondinen:e/nopVo provideouffioimnioopmodv1ooucommndat*thmRHNAa|location.ThioouboeouentGenena|P|mnsmdzoning ordinance amendment pmoeua will be subject to a new and separate CEQA review process. The Housing Element does not propose specific development on any specific Inventory Site at this time; therefore, programmatic impacts of the Housing Element are similar to those already analyzed in the General Plan EIR. In addition, none of the Inventory Sites have currently active oil or gas wells. Finally, any new development under the HEU would require on assessment ofhazards such as onaite oil or gas wells as part of the CEQA process. Therefore, impacts will be less than significant and no mitigation is required.
Would the project result in:
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
A) Generation of a substantial temporary or
permanent increase in ambient noise levels in the
vicinity of the project in excess of standards
F]
Pq
F]
established in the local general plan or noise
ordinance, or applicable standards of other
13) Generation of excessive groundborne vibration or
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groundborne 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, would the
Project expose people residing or working in the
project area to excessive noise levels?
City of Downey 2021-2029 Housing Element Update 47
Environmental Impact Evaluation�
A) Less Than Significant Impact. The City is bounded by Telegraph Road onthe north, GardondaleStreet and Foster Road on the south, the San Gabriel River on the east, and the Rio Hondo River on the west. Major include the 1'5on the north, 1'105on the south, 1-005on the east and |-71Ohuthe west. MTA Green Line light -rail train nemimao are available at the Lakewood Boulevard station located next to the 1-105 Freeway. The main existing noise sources within Downey include vehicular traffic on neighboring freeways as well as a number of major arterial streets in the Qh/ including Telegraph Road, Lakewood Bou|evond, Bellflower Boulevard, Florence Avenue, Firestone Boulevard, and Imperial Highway' as well as from commuter and freight trains.
Both the BNGFRailway and Union Pacific railroads operate inthe Downey area with uUnion Pacific railyard located adjacent to Los Nietoo Road and Union Pacific Distribution Services operating the VaUa noi|porton Sorenson Avenue. Rail freight operates within long- established rail ease me nts/rig hts-of-way that traverse the City, largely at at -grade crossings. Crossings are located primarily at arterial roadways. Exhibit 4.17-4 (Truck Weight Restrictions and Rail Yards) shows roadways and their respective weight restrictions, indicating where certain types of freight are permitted to travel. The at -grade crossings can be a source of congestion, restricting car and truck movement when long freight trains rumble through the City.
Toensure that noise producers donot adversely affect sensitive receptors, the City of Downey identifies land use compatibility standards within the General Plan to use for planning and development decisions. The General Plan Noise Element includes po|ioies, standards, oritaho, pmgnymo, diognama, and maps related to protecting public health and welfare from excessive noise exposure. General Plan Goals and Policies together with Municipal Code standards for noise unntm| are incorporated into the land use planning process to reduce noise and land use incompatibilities.
According to the General Plan BR, construction activity iotypically short-term in nature and iugenerally not considered to have a significant impact on noise sensitive uses as long as construction activity is limited to daylight hours. Acoustical analyses for future housing development projects under the HEU will eddmou construction noise impacts on nannidwa noise receptors and identify mitigation ifrequired.
Futuna housing developments on the proposed Inventory Sites are subject to the policies of the existing General Plan designed to minimize noise impacts to noise -sensitive properties. The General Plan requires noise studies as pod of the standard environmental review process for housing developments. These studies will evaluate noise levels and incorporate design features or mitigation measures necessary to minimize adverse noise impacts.
Subsequent to and within three years of Housing Element adoption,the City will amend the General Plan and zoning ordinance/map to provide sufficient capacity to accommodate the RH NA allocation. This subsequent General Plan and zoning ordinance amendment process will be subject to new and separate CEQ4 review process. The Housing Element does not propose specific development on any specific Inventory Site eithis time; thomfom, programmatic impacts associated with potential development of the Inventory Sites will remain within the scope of analysis in the General Plan EIR. Future Housing Development will be subject to preliminary environmental review pursuant to CEQA and if found not to be exempt, subject to full environmental analysis otwhich time all environmental issues will be vetted and appropriate mitigation incorporated, if needed, should noise impacts be identified. Potential impacts will be less than significant with implementation of existing standards and mQu|eUuna.
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48 202/-2029 Housing Element Update
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measures required if necessary.
Typical construction vibration mitigation includes routing and placement of equipment to maximize distance to receptors and use of alternative equipment, such as use of drilled pile drivers as opposed to impact drivers. Subsurface dampeners can also be utilized to reduce groundborne vibration. Short-term Impacts related to groundborne vibration during construction would be expected to be less than significant with implementation of local environmental review procedures. Typical mitigation for long- term vibration impacts related to occupied buildings include setbacks from vibration sources or building construction to. minimize transmission of vibration.
policy changes, developments, or infrastructure improvements are proposed as part of the Housing Element update. Impacts will be less than significant and no mitigation is required.
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on each Inventory Site will be evaluated as development is proposed over the long term pursuant to existing policies and procedures. With these existing policies and procedures in place, impacts related to increases in ambient noise levels will be less than significant and no mitigation is required.
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14. POPULATION AND HOUSING
Would the project:
Potentially
Less Than
Less Than No
Significant
Significant with
Significant Impact
Impact
Mitigation
Impact
Incorporated
A) Induce substantial unplanned population growth
in an area, either directly (for example, by
proposing new homes and businesses) or
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indirectly (for example, through extension of roads
or other infrastructure)?
City of Downey 2021-2029 Housing Element Update
Environmental Impact Evaluation
B) Displace substantial numbers of existing people
or housing, necessitating the construction of ❑
replacement housing elsewhere?
igirgpg
IN 1fl I ONE,
1•. share is 6,525 housing units. This allocation is referred to as the Regional • Needs Assessment, or RHNA.
The Housing Element identifies adequate land and planning mechanisms to accommodate the future housing needs of the growing population derived directly from the population growth estimates for the region, so the proposed housing Element Update would • induce unplanned population growth. No impact will occur. lge�� 13111 fli 111
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such redevelopment will result in the development of new housing units. Thus, the availability of residential units in respons.. to increases in population is supported by the Housing Element. Considering residential units will increase naturally as guided by the goals and policies of the proposed Housing Element, no impacts related to the displacement of housing or people would occur and no mitigation is required.
15. PUBLIC SERVICES
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, 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 public services:
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
A) Fire protection? El
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B) Police protection? 0
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C) Schools? El
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D) Parks? El
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E) Other public facilities? 1:1
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50 2021-2029 Housing Element Update
Environmental
A) Less Than Significant Impact. The Downey Fire Department (DFD) consists of about 1UUemployees providing evariety of comprehensive fire and life -safety services to the community of 112'322 residents located in southeast Los Angeles County. The 1241 square mile City iuprotected bvanInsurance Services Office U3O\Class 1 rated fire department operating out of 4 strategically located fire stations. These stations house four Paramedic -Engine Companies, one Truck Company, two Paramedic Squads, four Basic Life Support (BLS) Ambulances, one Urban Search & Rescue (USAR) Unit, and one Command Vehicle. The Department consists of six Divisions: Administration, Operations, Emergency Medical Services, Prevention, Communications, and Emergency Preparedness. The DFD responded toototal of1O.U1Semergency incidents in 2019-2020 (City 2021).
New development under the HEU will meuK in the incremental increase in need for fire protection services as the Cdv's population grows and the number ufresidential units increases. The City collects Development Impact Fees to offset the impact ofnew development, as it occurs. Construction and operation of new fire station will besubject to preliminary environmental review pursuant to CEQA and if found not to be exempt, subject to full environmental analysis at which time all environmental issues will be vetted and appropriate mitigation incorporated, if needed. Potential impacts resulting from the effects of operating the fire department aowell as constructing and operating future fire facilities will be |eou than significant with implementation of existing regulations.
13) Less Than Significant Impact. The Downey City Police Department provides police protection services bothe City.
According to the General Plan EIR, the Police Department anticipates that as the City grows additional police facilities to house additional equipment and officers may need to be constructed. The locations of future facilities are not known at this time. An expanded existing station of future stations may be required in order to maintain an acceptable level of service. The effects of constructing and operating a new police station are typical of any development project,VuoheepoUutont emissions from use of construction equipment and staff vehicle trips, changes in the visual character of the station site in the context of the neighborhood, and increased vehicle trips onlocal roadways. Police stations also result inthe specific effect ofgenerating periodic increases in noise from use of sirens, although typically uinana will be initiated while on patrol as opposed to directly initiating from the substation. The City collects Development |mpooL Fees to offset the impact ofnew development, as it occurs. Construction and operation of new substation will be subject to preliminary environmental review pursuant bu CEQA and if found not to be exempt, subject to full environmental analysis at which time all environmental issues will be vetted and appropriate mitigation incorporated, if needed. Potential impacts resulting from the effects of constructing and operating future police facilities will be less than significant with implementation of existing regulations.
C) Less Than Significant Impact. The Downey Unified Sohun| District provides K,12oduootiona| services bothe City of Downey and is comprised of13elementary schools, 4 middle schools, 3 high ouhuo|o, and an adult school. The effects of schools that can naou|t in environmental impacts are specific and include peak traffic levels occurring in the morning and early afternoon, playground noioe, and field lighting. Furthermone, one|yoma of school impacts are unique in that any impacts resulting from the effects of schools are considered fully mitigated through the payment of development impact fees pursuant to the Leroy F. Green School Facilities Act, therefore, pursuant to State law and the payment of development impact fees, impacts will boless than significant.
D) Less Than Significant Impact. Pursuant to State law, the City imposes parkland dedication orin-lieu fees onnew development equivalent to four anmo of parkland per 1.000 new residents. The proposed Housing Element Update will generate new or relocated residents that will require park and recreation facilities and associated pmgnumu, either through expansion of existing facilities or construction of new facilities. Construction or expansion of parks can result in nominal effects such as pollutant emissions from ounotmdUon activities and operational trip generation potentially resulting in similarly nominal impacts to the environment, The City will continue to collect in'|ieufeeu or require construction of new orexpanded parks from proponents ofnew housing tocompensate for incremental increases in parks and recreation service demand, thus providing odwqueha' per -capita facilities for future residents. The City of Downey also collects Development Impact Fees to offset the impact ofnew development, as it occurs. Construction and operation ofnew orexpanded parks and recreation facilities will be subject to preliminary environmental review pursuant to CEQA and if found not to be ex*mp1, subject to full environmental analysis at which time all environmental issues will be vetted and appropriate mitigation incorporated, if needed. Potential City of Downey 2021-2029 Housing Element Update 51
0711
impacts resulting from the effects of constructing and operating future parks and recreation facilities will be less thar significant with implementation of existing regulations. and policies of the proposed Housing Element Update will generate the incremental need for a variety of public and quasi - public services including libraries, medical clinics, urgent care facilities, hospitals, social service centers, senior centers, and other facilities. Construction and operation of new or expanded public service facilities will be subject to preliminary vmuf i--Ajjn---4
environmental issues will be vetted and appropriate mitigation incorporated, if needed. Potential impacts resulting from the regulations.
52 2021-2029 Housing Element Update
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
A) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial
0 physical deterioration of the facility would occur or be accelerated?
B) Does the project include recreational facilities or
require the construction or expansion of
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recreational facilities that might have an adverse
physical effect on the environment?
A-B) Less Than Significant Impact. Pursuant to State law, the City imposes parkland dedication or in -lieu fees unnew development equivalent tofour acres of parkland per 1.000 now residents. The proposed Housing Element Update will generate new or relocated residents that will require park and recreation facilities and associated pmQnamo, either through expansion ofexisting facilities orconstruction ufnew facilities. Construction orexpansion ufparks can result innominal effects such as pollutant emissions from construction activities and operational trip generation potentially resulting in similarly nominal impacts to the environment. The City will continue to collect in -lieu fees or require construction of new or expanded parks from proponents ofnew housing tocompensate for incremental increases in parks and recreation service demand, thus providing adequate, per -capita facilities for future neuidentu. Construction and operation of new or expanded parks and recreation facilities will be subject to preliminary environmental review pursuant to CEQA and if found not to be exempt, subject to full environmental ono|yaio at which time all environmental issues will he vetted and appropriate mitigation incnrponahad, if needed. Potential impacts resulting from the effects of constructing and operating future parks and recreation facilities will be less than significant with implementation of existing regulations.
17.TRANSPORTAT|ON AND TRAFFIC
Would the project:
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
A) Conflict with a program, plan, ordinance or policy
addressing the circulation system, including
transit, roadway, bicycle and pedestrian facilities?
B) Would the project conflict or be inconsistent with
CEQA Guidelines section 15064.3 subdivision
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C) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
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1:1
0 intersections) or incompatible uses (e.g., farm
D) Result in inadequate emergency access?
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City of Downey 2021-2029 Housing Element Update 53
Environmental lmnactEvaluation
A) Less than Significant Impact. The City is served by local transportation facilities including streets, passenger and freight railways, and bus routes in addition to non -motorized transportation facilities such as sidewalks, trails, and bikeways. These facilities provide options for travel modes that include passenger vehicles, trains, buses, bikes, and walking. This facilities and modes of travel comprise the circulation oyobam forth* Cdv' and the broader myobam' designed with the goals of efficiently moving people and goods throughout the region byproviding ease ofaccess homultiple modes oftravel.
Future housing development will primarily generate passenger vehicle trips that will disperse during the morning as residents drive hucommercial, induotrio|, and institutional facilities for avariety ofreasons but primarily for work and school. Some trips may Uebatransit centers, such that a portion of resident's trip may include alternative transportation modos, while others may simply walk to their destination or to other transit options. The return leg of a trip is generally anticipated to be the reverse of the initial leg of the trip during the afternoon, albeit with higher likelihood of a portion of the trip being dedicated to accessing shopping, entertainment, urother uses.
The concern regarding transportation facilities and their counterpart modes of travel is excessive use throughout the day or during morning end/or afternoon peak hours and the resulting effects on the pehbmnonms of the facilities' ebi|Uv to move people and goods. The direct effects of reduced circulation system performance are annoyance and otreae, thereby decreasing the quu|dv of life for the user. Direct failure or accelerated deterioration of circulation system facilities can also occur if the facility was not designed to function under increased loading. A variety of indirect impacts to human health and the environment are attributed specifically to excessive use of vehicles on local and regional roadways including effects related to air pollution and ambient noise.
While the RTP/SCG addresses the broader goals ofthe transportation network, the City'a General Plan Circulation Element identifies long-term transportation improvements for local facilities. The General Plan includes goals and policies aimed to provide on efficient multi -modal circulation system in the ndv. General Plan policies also encourage the development ofon efficient and safe bikeway and public transportation system.
Based on this preceding analysis, future housing development will not impede local or regional etorts to ensure an efficient circulation system. Future housing development will be subject to preliminary environmental review pursuant to CEQA and if lound not to be exempt, subject to full environmental analysis at which time all environmental issues will be vetted and appropriate mitigation incorporated, if needed, should transportation impacts be identified that are not covered under existing or future development impact fees. Potential impacts resulting from conflicts with local and regional transportation plans and performance requirements will be less than significant with implementation of existing standards and regulations.
B) Less Than Significant Impact. In response to Senate Bill (SB) 743, the California Natural Resource Agency certified and adopted new CEQA Guidelines in December 2018, which now identify Vehicle Miles Traveled (VMT) as the most appropriate metric to evaluate a project's transportation impact under CEQA (Section 15064.3). Effective July 1, 2020, the previous no longer constitute a significant environmental impact. 54 202/-2029 Housing Element Update
Environmental Impact Evaluation
Although VMT is now the accepted methodology for evaluating potential transportation impacts ofoproject, the City General Plan identifies standards for maintaining an adequate level of service (LOS) for City streets and intersections. To be consistent with the 2020 State CEQA Guidelines, o LOS analysis is no longer required for purposes of this |nido| Study impact analysis and determination of significant impacts unUerCEOA. Howev*r, an evaluation of the overall circulation network and memiuoo available 1nthe City iustill appropriate.
Transit. The public transportation system in Downey provides non -auto options for commute, uU|ity, and recreational hove|' with connections h>downtown Los Angeles, LAX' and other regional cities and destinations. The City ofDowney isserved by o number ofbus, commuter rail, and shuttle and ponahenuituemioem. The following agencies provide regional ounneoUvih/' providing unalternative todriving apersonal vehicle:
m" Mm@m1ink. M*bo|ink is o commuter rail system that consists ofO2 stations operating on 534 miles of rail network throughout Southern California, with key connections to most major cities. Mabn|ink operates seven different rail lines, with the Norwalk/ Downey Station serving two lines: 91/Perris Valley Line and Orange County Line. � Los Angeles County Metropolitan Transportation Authority (Metro). Metro provides rail and bus service throughout Los Angeles County, with a number of express and regular bus routes serving Downey. 0 Norwalk Transit. Norwalk Transit provides fixed- route and oaratranait service in Downey, Norwalk, Artesia, Bellflower, Cenitou, La Mirada, La Habra, Downey, and areas of unincorporated Los Angeles County. The agency serves nearly 0'30Opassengers each weekday onthe six transit routes.
Bus transit generally runs every 3Uho45 minutes during the peak poriode, with certain mutes running every 25 minutes or better. Generally, transit users prefer reliable wait times of less than 15 minutes when making trip choices.
MetrmEastside Corridor Phase 2. As of 2020, Metro is evaluating the Eastside Transit Corridor Phase 2, an extension of the Metro L Lino (Gold) further east from its current terminus at Atlantic Station (Pomona Boulevard/Atlantic Boulevard) in East Los Angeles through the cities ofCommerce, MnnkabeUu. Pico Rivera, and Downey. The proposed line would travel south along Atlantic Boulevard underground from the current Metro L Line (Gold) terminus at/t|antio Boulevard Station to the Citadel Outlets in Commerce. The route would then proceed east along Washington Boulevard via aerial and/or at -grade (street level) configurations ending at Lambed Road in Downey. The East Transit Corridor Phase 2exbanoinn was originally anticipated to be complete by 2035, but Metro's Twenty -Eight by '28 Initiative identifies the Gold Line Eastside Extension to Downey with u2O28target completion date.
Freight Rail. Both the BNSF Railway and Union Pacific railroads operate in the Downey area with a Union Pacific railyard located adjacent to Los Wietou Road and Union Pacific Distribution Services operating the Va||o nai|pmrton Sorenson Avenue in nearby Santa Fe Springs (east of Downey). Rail freight operates within long-established rail ease men ts/rig hts-of-way that traverse the City, largely at at -grade crossings. Crossings are located primarily at arterial roadways. The at -grade crossings can he e source of road nungaotiun, restricting car and tmoh movement when long freight trains rumble through the area just north nfthe City.
Bicycle Routes. Los Angeles County has established bikeways in various locations throughout the County. A Class I bikeway (off -road) provides e uump|sde|y o*perehsd right-of-way designated for the exclusive use of bicycles and pedestrians.
Cmoofluwuwith motorized vehicles are minimized. Very few opportunities for Class | bikeways are available in the City of Downey. However. C|ouu | bikeways are currently provided along the San Gabriel River and Rio Hando Flood Control Channels in the City of Downey. The Gan Gabriel River Mid Trail is a Qoao | pathway that extends 12 miles between the Whittier Narrows Dam/Legg Lake Recreation Area to South Street in Cerritos and the Lakewood border along the San Gabriel River.
A Class 11 bikeway (on -road) provides a restricted right-of-way on a roadway's shoulder designated for the exclusive or semi - exclusive use of bicycles. Through travel by motor vehicles or pedestrians is prohibited. Cmaeflowu by pedestrians and motorists are permitted. Vehicle parking is prohibited. Opportunities for Class || bikeways may exist on some of the less heavily utilized arterial roadways in the City of Downey. The City will continue to coordinate with Los Angeles County agencies City of Downey 202/-2029 Housing Element Update 55
Environmental Impact Evaluation
to enhance the bikeway system. The goal is to link residential areas, schools, parks and commercial centers so that residents can travel within the community without driving. New development projects will be required to include safe and attractivc sidewalks, walkways, and bike lanes, and homeowner associations will be encouraged to construct links to adjacent areas and communities where appropriate,
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on the design of existing or future streets. Therefore, it will not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). There will be no impac] and no mitigation is required.
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18. TRIBAL CULTURAL RESOURCES
Potentially Less Than Less Than No
Significant Significant with Significant Impact
Impact Mitigation Impact
Incorporated
Would the Project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
A) Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in F-1 F-1 9 El Public Resources Code section 5020.1 (k), or
B) 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 El Z 1:1
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?
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56 2021-2029 Housing Element Update
still exist but many have been extensively remodeled. Unfortunately, the primary way of viewing Dmw m/o past are viewing the archives ofthe Downey Historical Society located inApollo Park. Because historic properties are not located onany ufthe identified Inventory Sites, implementation of the proposed Housing Element Update will not cause substantial adverse change in significance of a historical resource. Impacts will be less than significant and no mitigation is required.
B) Less than Significant Impact. Before the arrival ofSpanish settlers inthe 1700s.the area that would later become Downey consisted of Tongva People that inhabited evillage called Sejatnga near the current City of Whittier and the San Gabriel River. By 1808. the Tongve were providing conscripted labor for Spanish missions. The area was part of the early Spanish rancho of Jose Manuel Nieto' the holder ofthe largest Spanish land grant in California, stretching from the Pacific Ocean to the Puente Hills. Given the long history of Native American settlement in the regiun, followed by Spanish and Mexican m|e' there is o high probability of finding prehistoric (archaeological) resources in the City. At least one prehistoric uibaioknownwithinthagenera|vicinitvoftheQh/(CA,LAN-182'oboenmdin195O).whiohwmudenchbedaso^hiohoho Gobrie|ino Village." The exact location of this archaeological site is vogue and there are three possible locations for the site, none ofwhich are within the City ufDowney.
Similar to potential impacts resulting from the effects of future housing on historical reoources, impacts to archaeological resources can muuU in the kmn of information important tothe history (and potentially the pre -history) of California and the people who created and/or used the materials. The potential for uncovering significant resources at Inventory Site locations during construction activities is unknown given that nosuch emounr*u have been discovered and/or recorded previously. The General Plan states that archaeological and historical resources shall be protected and preserved to the maximum extent feasible.
any tribal cultural resources will be impacted by private development or public works projects proposed in the City. All future development of the Inventory Sites will be required to prepare Cultural Resource Assessments (CRAs) to determine if there are any impacts to cultural or tribal cultural resources as required by the General Plan Conservation Element, This is considered regulatory compliance and not specific mitigation under CEQA. result in impacts that are greater than those contemplated in the General Plan EIR. In addition, future development of the proposed Inventory Sites will be subject to General Plan requirements and environmental evaluation for exemption and potential analysis pursuant to CEQA. Impacts related to implementation of the proposed Housing Element will be less than gignificant and no mitigation is required at this programmatic level.
Would the project:
Potentially
Less Than
Less Than No
Significant
Significant with
Significant Impact
Impact
Mitigation
Impact
Incorporated
A) Require or result in the relocation or construction
of new or expanded water, wastewater treatment
or storm water drainage, electric power, natural
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gas, or telecommunications facilities, the
construction or relocation of which could cause
City 20�/��29
of Downey �ouxmQ��m�n L¢�a� 57
Environmental Impact Evaluation
........
....... - - ----
significant environmental effects?
13)
Have sufficient water supplies available to serve
the Project and reasonably foreseeable future
E]
development during normal, dry and multiple dry
years?
C)
Result in a determination by the wastewater
treatment provider which serves or may serve the
Project that it has adequate capacity to serve the
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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
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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?
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ordinance amendment process will be subject to a new and separate CEQA review process. Future housing under the HEU will eventually consume additional water, electricity, and natural gas while producing additional wastewater for conveyancs- and treatment. The Housing Element does not propose specific development on any specific Inventory Site at this time; therefore, it is consistent on a programmatic level with the General Plan growth projections which were evaluated in thl; General Plan EIR. The various involved utility agencies and companies develop master service plans based on anticipated • uses outlined in the General Plans • the various jurisdictions they serve. In addition, future development is required tit assure adequate utility service during the development review and CEQA process. Therefore, utility impacts will be less than significant at this programmatic level and no mitigation is required, 13) No Impact. The Downey Public Works Department, Utilities Division, maintain 20 deep groundwater wells sites and three MWD imported water connections to provide domestic water service to City residents and businesses. The City overlies the Central (groundwater) Basin which was adjudicated in 1965 and the Central Basin Watermaster manages groundwater supplies and replenishment. The City Utilities Division regularly reviews and updates its Urban Water Management Plan (UWMP) and coordinates with the Central Basin Watermaster and MWD to assure it can provide adequate water service to the City under all anticipated conditions.
58 2021-2029 Housing Element Update
Environmental Impact Evaluation
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Impacts will be less than significant and no mitigation is required.
C) No Impact. Wastewater treatment is provided by the County Sanitation Districts of Los Angeles County (CSDLAC). The City also operates and maintains storm drains within its boundaries, although downstream flows are handled by the Los Anae es ountv Flood Control District. Future housing under the HEU will generate a�4itiojql u/aste\Y2tevfor-m-ivevajce aid A _'T SMIMONRION&M fiTatMAT.-M. 1:11M.Y16 =011HYSTO =WITO R.11MEWN—rX.M. W. Off M1127mer-TATM2. IN MR IN 1 011 1 M-1 I
CEQA process. Therefore, wastewater treatment impacts will be less than significant at this programmatic level and no gation is required.
D) No Impact. The City of Downey provides solid waste management for its residents and businesses although it contracts with CalMet Services for collection services. Wastes are taken to the Downey Area Recycling and Transfer (DART) facility where they are sorted and materials diverted (recycled) as appropriate. Non -recyclable and non -composting wastes are then solid waste regulations and procedures. Therefore, the HEU will have no solid waste impacts at this programmatic level and no mitigation is required.
E) No Impact. All new development will be required to comply with State mandates and City regulations regarding reduction/recycling of household waste. As outlined in Thresholds 19.A and 119.13 above, the Housing Element itself does not propose any specific development on specific sites at this time, and the subsequent General Plan and zoning ordinance amendments needed to implement the Housing Element will be subject to a new and separate CEQA review process. In addition ' none of the housing strategies in the Wo.posed Housing, conflicts with solid waste disposal regulations. No impact will occur and no mitigation is required.
20.WILDFIRE
Would the project:
Potentially
Less Than Less Than No
Significant
Significant with Significant Impact
Impact
Mitigation Impact
Incorporated
A) Substantially impair an adopted emergency
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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
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from wildfire or the uncontrolled spread of a
wildfire?
C) Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water resources, power lines
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or other utilities) that may exacerbate fire risk or
that may result in temporary or ongoing impacts
to the environment?
City of Downey 2021-2029 Housing Element Update 59
Environmental ImoactEvaluation
D) Expose people or structures to significant risks,
including downmlopomdownstream flooding or
landslides, aoaresult ufrunoff, post -fire slope
instability, urdrainage changes?
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1:1 �. El [9 []
A) Less Than Significant Impact. The City Office of Emergency Management coordinates disaster response and recovery efforts in the City ofDowney. The City'm goal is to respond to emergency situations with a coordinated system of emergency service providers and facilities. The City has planned responses to extraordinary emergency situations associated with natural diuonhem' technological incidents, terrorist activities, and war -related operations. The City in part ofa county and statewide emergency management system that addresses evacuation and movement of people in the event of an emergency.
The HEU does not involve any mad construction orany development activity and thus will not obstruct or restrict emergency aooeuu to or through the City. Future housing development facilitated by implementation of Housing Element policies will be subject to site plan review and approval during entitlement review and/or application for building permits. The City Fire Department reviews all plans toensure compliance with all applicable emergency access and safety requirements. Impacts involving emergency aooeua will be less than significant with continued implementation of development review procedures, Therefore, any impacts will be less than significant and no mitigation is required. 13) Less Than Significant Impact. The City is relatively flat and is completely urban uothere islittle mnnchance ofawildfire event affecting the City. However, the area does experience strong dry seasonal winds called "Santa Ana" winds that can sometime exacerbate the upnaeU of structural urban fires. No conditions in the City would lead residents to be exposed to pollutant concentrations in excess of those regional conditions that result in large wildfires in the more remote portions of the County, mainly the San Gabriel Mountains hathe north.
The HEU will allow the eventual construction of new housing in the City that may be subject to urban fires. However, there are no conditions in the City that would exacerbate wildfire hoku and expose project occupants to, pollutant concentrations from wildfire or the uncontrolled spread of wildfire due to a|opo, prevailing winds, and other factors. Impacts will be |emu than significant and nomitigation iorequired.
C. No Impact. The City of Downey is in a fully urbanized setting and does not have a moderate or high risk of wildfires. Its Fire Department has e Class | rating with the Insurance Service Organization UG[A which means it has full and complete protection from fire risks. The City o|nmdy has full infrastructure (muUo. water lines with Dm hydrants, etc.) to support fire protection services. Therefore, the HEU would not require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water resources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment. There are no impacts and no mitigation is required.
D. Lens Than Significant Impact. The City is relatively flat and bordered by the San BaUhe| River tuthe east and the Rio Hondo River to the west. Both of these channels are fully improved adjacent to the City. 8eoUunu 9.0 and 9.D of this Initial Study concluded that future housing in the Qh/ under the HEU would not experience significant impacts from flooding, Therefore, the HEU would not expose people urstructures hu significant risks, including downo|upaordownstream flooding or |andu|idoa, as a result ofrunoff, post -fire slope instabi|ib/, or drainage changes. Impacts will be |eua than significant and no mitigation imrequired.
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
a) Does the project have the potential todegrade the
60 202/-2029 Housing Element Update
Environmental Impact Evaluation
Potentially
Less Than Less Than
No
Significant
Significant with Significant
Impact
Impact
Mitigation Impact
:
Incorporated
quality of the environment, substantially reduce
the habitat of a fish or wildlife species, cause a
fish or wildlife population to drop below self-
sustaining levels, threaten to eliminate a plant or
animal community, reduce the number or restrict
the range of a rare or endangered plant or animal
or eliminate important examples of the major
periods of California history or prehistory?
b) Does the project have impacts that are
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 would cause substantial adverse effects on
El
1:1 0
1:1
human beings, either directly or indirectly?
lira �Leiwj I IgnAr.] I wallsowitrd I lmmrg im-0, go wl 1:1 1n, -m-n w Lej tq Op is E K;&JOJ 0 111% :i,rdinance amendment process will be subject to a new and separate CEQA review process. The Housing Element does not propose specific development on any specific Inventory Site at this time; therefore, it is consistent on a programmatic level with the General Plan growth projections which were evaluated in the General Plan EIR.
Coisiderito Ae #roararnmatic level of analvsis will not authorize anX develoQment glan. redevelooment of an� existing sites, IN OR
UUMUPIllellL, IL Will IlUt leSUlt III d1ly elleLAb Ll1dL 1TUML1Jt�1JFA_11U_1JJt_AJ _151"i Element's programmatic impacts related to degradation of the environment will be less than significant and no mitigation is required.
B) Less Than Significant Impact. Cumulative effects resulting from full implementation of City land use policies were 't R. ThascEej I'll,
V,,ZIL Housin�# Element U�tdate will not chanxe anp of these �solicies and does not propose any specific development or redevelopment project that could contribute to short-term or long-term cumulative. impacts that were not addressed sufficiently in the General Plan EIR. 14 11011,
City of Downey 2021-2029 Housing Element Update 61
Environmental Impact Evaluation
................
62 2021-2029 Housing Element Update
F-I Te 1=4
City of Downey
Planning Department
MIG
1650 Spruce
Riverside, California 92507
951-787-9222
Amanda North, Technician
City of Downey 63
List of Preparers
IMAJAZM
64 2021-2029 Housing Element Update
List of
California Department of Toxic Substances Control (DTSC 2020). Envirostor (comprehensive government hazmat database). Web: www,envirostdr.dtsc.ca.ov/ublic,[Accessed December 2020] California Department of Transportation (Caltrans) 2021. State Scenic Highway Program Website accessed April 20, 2021. https://dot.ca.gov/programs/design/lap-landscape-architecture-and- community-livability/lap-liv-i-scenic-highways:
2017b. CaIEEMod User Manual Appendix E Technical Source Documentation. Prepared for CAPCOA. Prepared by Trinity Consultants, Dallas TX. October 2017.
City of Downey (City 2020a). Zoning Code. Web: https://www.downeyca.org/our- city/departments/community-development/planning/zoning-code-map [Accessed December 2020],. . Public Works Department (City 2020b). Web: htti)s://waterzen.com/water-r)rovidersldownm- water [Accessed December 2020]
(City 2004). Downey Vision 2025 Comprehensive General Plan Update, Environmental Impact Report, Regional Environmental Setting (Section 4.2). Planning Center, July 28, 2004.
Downey Fire Department Website (City 2021 a).
https://www.downeyca.org/our-city/departments/fire
Downey Police Department (2021 b)
https://www.downeyca.org/our-city/departments/police
Downey Unified School District website. https: eb.dusd.net/ Department of Regional Planning (DRP 2004). Los Angeles County Airport Land Use Plan, Los Angeles County Airport Land Use Commission, Revised December 1, 2004.
KCET (KCET 2020). Downey. From Orange Groves to the Apollo Space Program. Mike Sonksen, KCET LA Letters. Web: https://www.kcet.org/history-society/downey-from-orange-groves-to-the-apollo- space-program [Accessed December 2020 - program first aired 2018] LAist (LAist 2017). A Brief History of L.A.'s Indigenous Tongva People. Annie Lloyd, LAist columnist.
October 9, 2017. Web: https://Iaist.com/2017/10/09/a_brief_history_of_the _tongva_people.php [Accessed December 2020]
California Office of Planning and Research (OPR) 2017. State of California General Plan Guidelines.
Sacramento, California. 2017.
California State Water Resources Control Board (WRCB 2020). GeoTracker (comprehensive government hazmat database). Web: htt s:// eotra ker.waterboards.ca. ov [Accessed December 2020].
California Water Boards (CWB 2020). Lower San Gabriel River Watershed Management Group. Web:
hftDs:// www.waterboard municipal/watershed_
management/san_gabriel/lower_sangabriel/index.html [Accessed December 2020].
City of Downey 2021-2029 Housing Element Update 65
List of Preparers
California Water Boards KCVVB2O1O\. Los Angeles R4.Water Quality Control Plan: Los Angeles Region Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties ("Basin Plan"). httt)s,//ww,w,waterboards.ca.govilosanqeles/water issues/programs/basin plan/ Last update August 8, 2018.
Los Angeles County Department ofPublic Works (LAC 2Q2Q). Flood Zone Determination Webxnfe, Web: https:/dl)w.lacountv.aov/floodzone/ [Accessed December 2020].
Los Angeles County Flood Control District (LACFCD2020. Web: LACFCO [Accessed December 2O20].
Los Angeles County Sanitation Districts (LACS[}).Web: [Accessed December 2U2Ql. '
South Coast Air Quality Management District (8CAC)K8[))(2D2Om). "Air Quality Analysis Handbook" 19S3A|r(]u8|ib/An@|yn|nHandbOoh(Updeted).VVeb:http:/kmvvw.oqnnd.gov/h0nn8/negu|atione/oeqB/mip quo|ih/-ane|yaia-hendbwmh. [Accessed July 2O2O].
______ (2020b). 8CA{}MDAir Quality Significance Thresholds. Diamond B8r, CA. Revised April 2019. Available online at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality- significance-thresholds.pdf?sfvrsn=2
. 2016. Air Quality Management Plan (AQMP). Adopted by the SCAQM D Governing Board on yNaroh3. 2017. Web: http://wVvvv.aqnnd.0ov/honne/r8Qu| eMone/kAocaaeed Ju|y2U2Ol.
Southern California Association of Governments (SCAG) 2016. 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy 09TPISCSJ.Adopted April 7.2010.
Southern California Edison Company (SCEC) 2021. Website accessed April 8, 2021. httpm://wxvw.noec|aenanergy.cmm/
Southern California Gas Company (SCGC) 2021. Website accessed April 9, 2021. httpo://wvxvv.umunb/offioe.org/aouthern-ca|ifornio-Qae-oonnpeny-emn-bernandino'ce-e8e/ United States Army Corps ofEngineers (U8ACE1A85). Flood Inundation Maps for Whittier Narrows Dann: Los Angeles County drainage area, San Gabriel and Rio Hondo Rivers, California. United States Army Corps of Engineers, Los Angeles
hftr)s://www.�iol.u�sace�,armv.mil/Missions/Asset-MangggMgEl8NbiU!g��l�M/ [Accessed December 2020].
United States Environmental Protection Agency (USEPA 2020a). Criteria Air Pollutants. Web:
https://www.epa.gov/criteria-air-pollutants . [Accessed July 2020]. _________ (UGEPA202Ob). Health and Environmental Effects mfHazardous Air Pollutants. Web:
https://www.epa.gov/haps/health-and-environmental-effects-hazardous-air-pollutants . [Accessed July U.S. Federal Highway Administration (FHWA) 2010. "Construction Noise Handbook, Chapter 9 Construction Equipment Noise Levels and Ranges:
66 2021-2029 Housing Element Update
List of Preparers
U.S. Federal Transit Administration (USFTA) 2018. Transit Noise and Vibration Impact Assessmen Manual. FTA Report No. 0123. Prepared • John A. Volpe National Transportation Systems Cent Washington, DC. September 2018. 1
No -
City of Downey 2021-2029 Housing Element Update 67
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF
DOWNEY RECOMMENDING THAT THE CITY COUNCIL APPROVE A
GENERAL PLAN AMENDMENT AND INITIAL STUDY AND NEGATIVE
DECLARATION (PLN-21-00139), THEREBY ADOPTING THE 2021-2029 HOUSING ELEMENT UPDATE FOR THE SIXTH HOUSING CYCLE.
THE PLANN-ISLft7w�07-MD§.-V#Dv-t
SECTION I. The Planning Commission of the City of Downey does hereby find, determine and declare
A. All cities and counties in the Southern California Association of Governments (SCAG) are required to obtain State certification from California Department of Housing and Community Development (HCD) for an updated Housing Element fol the 2021-2029 planning period no later than February 12, 2022; and, B. The City of Downey ("City") has been assigned a Regional Housing Needs Assessment (RHNA) allocation of 6,525 housing units for the sixth housing cycle (2021-2029); and,
C. On June 24, 2020, the City of Downey entered into a professional services agreement with Moore lacofano Goltsman, Inc. (MIG), a professional planning, architecture, and urban design firm to assist with the City's sixth cycle 2021-2029 Housing Element Update (HEU), replacing the 2013-2021 Housing Element of the City's General Plan; and,
D. The City held two virtual community workshops, due to the COVID-19 pandemic, December 17, 2020 and June 14, 2021, to gather community input and revise the draft in accordance to the input obtained by the community and HCD; and, E. On September 1, 2021, the City made the draft HEU available to the public for review at multiple City facilities and the City's website; and, F. On September 15, 2021, the City submitted the draft HEU to HCD for review and received a response with comments on November 10, 2021; and, G. On November 1, 2021, in compliance with the California Environmental Quality Ac (CEQA), a Notice of Intent (NOI) to adopt a Negative Declaration was posted with the California State Clearinghouse and published in the local newspaper Downey Patriot for public review from November 1, 2021 through November 30, 2021; and H. On December 15, 2021, the Planning Commission held a study session where the public was invited to attend and share input on the revised draft HEU based on overall community input and HCD's comments; and,
1. On December 22, 2021, the City submitted a revised draft HEU to HCD for final review; and, I
Attachment "E"
J. On January 6, 2022, notice of the pending General Plan Amendment was published in the Downey Patriot as a I/alh page ad in accordance with the requirements of the Downey Municipal Code; and,
K. The Planning Commission held a duly noticed public hearing on January 19, 2022, and after fully considering all oral and written testimony and facts and opinions offered at the aforesaid public hearing, adopted this resolution. 1ArJ0lIfiWW*1;1(J7H9lI 1-74-11RIIIAPiMMI
Policy - Provide an appropriate amount of land area to absorb the City's future population growth.
Program 1. 1. 2. 1. - Identify areas to absorb population growth and support additional housing.
Program 1. 1. 2.2. - Designate parts of the City as second unit development areas to absorb the need for additional housing.
Program 1. 1. 2.3.- Promote housing projects and mixed -use projects that include housing within areas designated for the downtown area, transit - oriented developments, and areas in the vicinity of the Downey Landing project
Goal 1. 2. - Advance livable community concepts,
Policy 1- 2. 1. - Promote livable communities concepts that allow added flexibility in addressing land use needs.
Program 1.2.1.2.- Promote mixed -use developments with housing on the same site or in proximity to commercial services to reduce the need for trips by vehicles.
Policy 1. 2.2 — Focus on areas where livable communities concepts are most likely [to] have the most impact to set a catalyst for similar projects elsewhere in the city.
Program 1.2.2.4 - Use the development of the Downey Landing as a catalyst for further economic development, including housing, on properties 2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 January 19, 2022 - Page 2
Aesolution No. 22-3158
1. V
2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 January 19, 2022 - Page 3
Resolution No. 22-3158
C. The proposed General Plan Amendment promotes the public health, safety, and general welfare and serves the goals and purposes of the Downey Municipal Code.
Specifically, the goals and policies found within the Housing Element Update lnclude� providing housing at all income levels, providing housing specifically for vulnerable populations, rehabilitation of existing homes, providing education and resources for homeownership, neighborhood preservation, and affirmatively furthering fair housing.
These types of policies fundamentally and inherently promote the public health, safety, and general welfare of the community. In terms of future development, through the sites inventory analysis a heavy emphasis was placed in determining where future development would be most appropriate in relation to nearby land uses.
D. Approval of the Housing Element does not alter any provisions of the Downey Municipal Code, including the City's subdivision ordinance. Rather zoning text amendments will follow in order to achieve the goals and policies out lined in the adopted Hosing Element. The purpose of the Downey Municipal Code is to be in accordance with the comprehensive General Plan.
E. Based on factors such as the age and condition of existing uses, the site la versus improvement value, lack of recent enhancements to existing uses, increased development intensity potential, and development interest, the existing uses on the sites identified in the site inventory to accommodate th lower income IRHNA are likely to be discontinued during the planning perio and therefore do not constitute an impediment to additional residential development during the period covered by the housing element. I Wil't Me.
21-00139), thereby adopting the 2021-2029 Housing Element Update for the sixth housing cycle.
2021-2029 Housing Element Update
W.14,x2ll.-ftby w�t 4942*9
January 19, 2122
Resolution No. 22-3158
11171 111�1111111`::I1I rillis
I HEREBY CERTIFY that the foregoing is a true copy of a Resolution adopted by the Planning Commission of the City of Downey at a regular meeting thereof, held on the 191l' day of January, 2022, by the following vote, to wit:
AYES:
COMMISSIO
Owens, Ortiz,
NOES:
COMMISSIONERS:
None
ABSENT:
COMMISSIONERS:
None
ABSTAIN:
COMMISSIONERS:
Uva
2021-2029 Housing Element Update
- i
January 19, 2022 - Page 5
I'MAN 921 111111T�
TO: PLANNING COMMISSION
SUBMITTED BY: ALDO E. SCHINDLER, DEPUTY CITY MANAGER/COMMU
DEVELOPMENT
REVIEWED BY: CRYSTAL LANDAVAZO, OTYPLANMER
PREPARED BY: IRVING ANAYA, ASSOCIATE PLANNER,
SUBJECT: PLN-21-00139 (GENERAL PLAN AMENDMENT) —THE CITY OF DOWNEY HOUSING ELEMENT UPDATE FOR THE 6 TH REGIONAL
HOUSING NEEDS ASSESSMENT (RHNA) ALLOCATION CYCLE AND
CORRESPONDING INITIAL STUDY AND NEGATIVE DECLARATION
gork1l 0 11 �Gik ::
Pursuant to California State law, each city and county requires a state -certified Housing Element that must be updated and adopted every eight years in accordance with a specific ,achedule of dates established by the State. The Housing Element must demonstrate the City's 2bility to accommodate the projected number of housing units, including affordable housing Units, needed to house existing and future Downey residents. The City of Downey's Planning Department contracted the assistance of MIG, Inc., to prepare the 2021-2029 General Plan Housing Element Update (HEU) in compliance with many State laws that have been adopted in -ecent years. The HEU covers the planning period of October 15, 2021 through October 15, OP029 and identifies strategies and programs to encourage the development of a variety of housing opportunities for all residents.
F
Ild
periods, and a study session. The next steps in this process include City Council action and further engagement with HCD to obtain a final certified Housing Element in accordance with State law.
T Px= uorgs — - 1. MWkM1%W&Wz
adopt the following titled resolution:
A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF
DOWNEY RECOMMENDING THAT THE CITY COUNCIL APPROVE A
GENERAL PLAN AMENDMENT AND INITIAL STUDY AND NEGATIVE
DECLARATION (PLN-21-00139), THEREBY ADOPTING THE 2021-2029 HOUSING ELEMENT UPDATE FOR THE SIXTH HOUSING CYCLE.
Attachment 'T"
The Housing Ekannenk is a State -mandatory Element of the Cit/a General Plan. This e|enoerd identifies ways in which the housing needs of existing and future residents can be met.
California planning law provides more detailed requirements for the Housing Element. The HEU was prepared in response to those requirements with the goal of retaining conditions and policy directives unique to the City of Downey. The current Housing Element update will cover the period ofOctober 15.2O21through October i5.2O29 also known oathe 6mCycle Housing Element update. The Housing Element must plan for the City'eRegional Housing Needs Assessment (RHNA)Allocation nf6.525housing units.
Pursuant to state law, the Housing Element must include the following key sections ° Ananalysis ofexisting and projected housing needs;
� An analysis of potential constraints on housing;
° Ananalysis ofassisted housing developments that are ^at-riok" and eligible tochange from low-income housing uses;
� An inventory of sites suitable for housing development; w An analysis of the plan's conformance with Affirmatively Furthering Fair Housing requirements;
° Ananalysis nfany special housing needs;
" Ananalysis ofopportunities for residential energy conservation; � Anevaluation mf the previous Housing Element; and
" Goo|e, obieotiuem, po|icimo, and implementation programs.
C>nJanuary 0.2O22.notice cf the pending public hearing was published inthe Downey Patriot as a 1 /�h page ad in accordance with the requirements of the Downey Municipal Code.
The prepared 2021-2029 Housing Element is comprised of six chapters that outline current and future housing needs of the community, housing resources constraints to building housing units, and ahousing plan. The housing plan within the HEUbuilds upon and revises the goals, policies, and programs of the existing element to ensure that the City can meet the housing needs of all Downey residents through 2029. The updated Housing Element is supported by greater detailed information within the text and appendices.
Regional Housh2g Needs Assessment EtLNAJ
The California Department of Housing and Community Development (HCD) assesses and determines the existing and projected needforhouainQvv|th|nthroughout all regions ofthe state. The RHNA numerically allocates the future housing need by household income group for each locality within the region. Once HCC} determines the regional allocation for the Southern California region, the Southern California Association of Governments (GCAG) distributes a RHNA 8||Dc@Uon to each city within the region. This housing allocation must be reflected in the locality's Housing Element of the City's General Plan. For this sixth cycle, the City of Downey has aRHNAallocation of6.525housing units. Table 2.8(bm|oxv) taken from the Housing Element Update, illustrates the income distribution for the City'aoverall RHNAallocation.
'Table 2.8: Regional Housing Needs Allocation 2021-2029 Very Low'
0-50%
2,079
32%
Low
>50-90%
946
14%
Moderate
>80-1200A
915
14%
Above Moderate
120%+
20585
40%
Total
6,S25
100%
The demand for housing in Downey, and all of Southern California in general, has significantly increased over the past decade due to slow housing production. The City's sixth cycle RHNA allocation is five times higher than the 2014-2021 RHNA allocation (1,201 units) and amounts to more than 18 percent of the City's existing housing stock (2019) which has been developed over the course of more than 60 years. The following section summarizes the HEU's objectives and goals in order tackle the current challenge.
The City must demonstrate in the HEU that its housing plans, policies, and zoning can facilitate the allocation of 6,525 housing units. This was a challenge due to current built -out conditions within the City, and led to a three -step approach to meeting the RHNA requirement. The first step was assessing development projects currently proposed or under review and expected to be built during the 6 th RHNA cycle; this approach resulted in a credit of 193 units. The second step was identifying the potential capacity that could be built within the City's existing zoning districts and built environment; this resulted in a credit of 2,779 units. The remaining 3,553 units requires amendments to the City's existing zoning map and development standards to create new housing opportunities in areas that had not previously been considered for housing.
The methodology used when considering new housing opportunities within the community was a focus on locating housing opportunities near transit corridors and maintaining the character of existing residential neighborhoods. As a result, the HEU has established a set of policies and programs that will work to address the challenge. These actions include:
General Plan and Zoning Code amendments to increase the allowable residential density in the Medium Density Residential (MDR) General Plan designation and the R-3 zone.
• Adopt zone and development standards for the Mixed -Use General Plan designation that will allow residential development at a minimum of 30 units per acre. • Adopt a residential overlay zone that will allow high -density housing development at a minimum density of 30 units per acre along key commercial corridors. • Add a residential component to three commercial specific plans, requiring a minimum density of 30 units per acre.
• No alterations or changes are proposed on properties developed with single-family residences in R-1 zoned neighborhoods.
i •h H eme•ertification from
redeveloped but, it is required to show that there is viability for meeting the required RHNA. The following criteria was applied to identify sites with potential for new development or recycling opportunities:
• Parcel is currently vacant; or
• If parcel is not vacant:
• Existing uses are not higher -density residential (condominiums or apartments) • Age of structure: most sites in the inventory have existing uses that were built over 30 or 40 years ago. In The downtown area, a few sites have structures that are 100 years old (but not historically significant).
• Characteristics of existing uses such as declining uses and large underused portions of the property.
• Land values are higher than improvement values.
• No recent, significant enhancements have been made (exempt enhancements include site cleanup or paint)
• Gas stations are also not included since redevelopment is more complex given the need to mitigate underground storage tanks.
• Potential for lot consolidation is also taken into consideration including common ownership of adjacent parcels.
Table 4.5. RHNA/Sites Inventory Sum
Sites Currently Available (inclu
estimated ADU production)
Sites to be Rezoned
Total Sites
RHNA status
52 50
0 91
193
1,269
379
203
928
2,779
1,727
1,003
1,712
4,442
3,048
429
1,206
2,731
7,414
"_9
2,079
2079
915 1
2,585
6,525
9:6 �9
�945
+29-1---J—
1 +889
As shown in this report, Figure 4.2, from the HEU, encompasses the overall sites that the City has identified in order to meet the sixth cycle RHNA allocation,
01,111, 11 0 - Im �t # -
In Chapter 6 of the Housing Element, the Housing Plan provides goals, policies, and programs for high -quality housing development. These have been established to address housing issues inthe City and meet State law housing requirement. These goals and policies were informed bv recent community input, the housing needs assessment (Chapter 2 mfHEU). housing constraints analysis (Chapter 3 ofHEU). housing resources analysis (Chaoter4 ofHEU). and the review of program accomplishments from the previous (2014-2021) Housing Element (Chapter 5 of the HEU). Overall, the Housing Plan is made up of five goals, 29 policies, and 35 programs.
The programs developed for each goal identify actions that will be taken tomake sites available during the planning period with appropriate land use and development standards, as well as services and facilities to accommodate the City's share of regional housing need for each income level. The programs address identified housing issues in the City and approaches to meet State |axv housing requirements. Programs generally include a statement of specific City action(s) necessary to implement a policy or goal and identify the City department or other agency responsible for implementation, the quantified objectives (where applicable), and a timeframe for completion. A summary of quantified objectives is included in the program descriptions ofthe Housing Plan.
lAnDlementation
The proposed HEU is before the Planning Commission for review and recommendation to the City Council. The HEU will then be presented to the City Council with the Planning Commission's recommendation for their consideration of adoption of the Housing Element. If the City Council votes to adopt the Housing Element Update, then the final step will be certification from HCD before the Housing Element can be considered complete and compliant with state regulations.
The draft HEU was submitted to HC[}for review on September 15. 2021 and o response with comments from HCD was received on November 10, 2021. Primarily, most comments from HCD identified a need for additional justification and reasoning for different components of the element, such as the sites inventory, constraints, and additional specification for timelines of various programs. Staff addressed the comments provided by HCD and resubmitted the document toHCC>for final review onDecember 22.2021.
After adoption and certification of the Housing Element Update, there will be need for a secondary phase where the programs adopted in the Housing Element will need to be implemented. The most notable will be the General Plan and Zoning amendments tmapply m residential overlay on major COnnnnernim| corridors within the City. This phase will include the establishment ofdevelopment standards specifically for corridors to identify a||ovvob|e building heights, building articulation, and design standards. These amendments will incorporate public comments and be presented to the Planning Commission and City Council for consideration and action.
Public Outreach and Partkc/oation
Public participation plays akey role |nthe development ofall City actions, and efforts were made for that Um remain true during this Housing Element update. In adddUon, as required by state law the Housing Element must reflect the values and preferences of the community.
Section 65583(c)(6)(B) of the Government Code states: "The local government shall make diligent effort to achieve public participation of all economic segments of the community in the development of the housing element, and the program shall describe this effort." Public outreach not only included residents, but also coordinated participation among local agencies and housing groups, community organizations, and housing sponsors. A list of agencies and
organizations invited to the workshop are listed in Appendix A of the Housing Element and included over 100 groups and agencies working with special needs groups, civic and religious groups and housing developers and local businesses.
Staff hosted two community workshops and one Planning Commission study session. The community workshops were held on December 17, 2020 and June 14, 2021. The Planning Commission study session was held on December 15, 2021. The community workshops were held virtually via xvebC8nndue tothe C(]V|[)-1Spandemic. Although the City was precluded from hosting traditional in -person meetings, there was a positive turn -out of 116 participants over both virtual nnest|nQe. |naddition fQthe community meetings, individuals were also given 8n opportunity to participate via an online survey. ACity xvebpmgewas exclusively dedicated to the Housing Element allowing individuals to obtain up-to-date information and documents, including information for how to participate.
Community input from meetings and survey included the following:
• Need for affordable housing
• Consideration for vulnerable populations
• Housing near transit and transit -oriented development ° Continue support ofAccessory Dwelling Units (4C>U)
• Address climate change issues and resilience
• Parking, safety, and traffic concerns
• Property rehabilitation
• Further Fair Housing
• Preferred locating new housing along major corridors and large retail npacea, instead single-family zones.
w Having efuture orientation tosupport young people growing up|nDowney and young families who want to stay in the City.
• Support lower income and rent -burdened households
L8GUy` the City utilized a variety Ofpublic outreach outlets including social nnedio, mobile app|icatinne, f|yero, direct enne||a. C|hvvvabaite and newspaper. All outreach materials and meeting were accessible to both English and Spanish speakers. The community input identified above served ms a guide throughout the update process and was used to inform development of all programs within the Element.
FINDINGS
Pursuant to Municipal Code Section 9834.08, there are four (4) findings that must be adopted prior toapproving the General Plan Amendment. The findings are enfollows:
A. Consistency. The proposed General Plan Amendment |s consistent with all other goals, policies, programs, and land uses of applicable elements mfthe General Plan.
The project is in conformance with all other applicable obiectivea, po|icieo, and programs specified in the City's General Plan. Additional general plan amendments and zone changes will be executed in order to meet the policies and goals of the Housing Element Update. Staff will continue to ensure that those actions remain consistent with the overall General Plan. In add|bon, in order for the City to remain in compliance with state |evv governing the overall General Plan and Housing Element, the City isrequired to perform periodical updates every eight years. State law requires the housing element to address the following key topics: 1\ housing needs, 2\ constraints to housing development, 3) housing resources, and 4) housing plan. The Housing Element will be in strict conformance with the previous four topics. The following are current policies promoted by the proposed General Plan Amendment:
Policy 1. 1. 2 - Provide an appropriate amount of land area to absorb the City's future population growth.
Program 1. 1. 2. 1. -
Identify areas to absorb population growth and support additional housing.
Program 1. 1. 2.2. -
Designate parts of the City as second unit development areas to absorb the need for additional housing.
Program 1. 1. 2.3. -
Promote housing projects and mixed -use projects that include housing within areas designated for the downtown area, transit - oriented developments, and areas in the vicinity of the Downey Landing project
Goal 1.2.-
Advance livable community concepts.
Policy 1. 2. 1. -
Promote livable communities concepts that allow added flexibility in addressing land use needs.
Program 1.2.1.2.-
Promote mixed -use developments with housing on the same site or in proximity to commercial services to reduce the need for trips by vehicles.
Policy 1. 2.2 —
Focus on areas where livable communities concepts are most likely [to] have the most impact to set a catalyst for similar projects elsewhere in the city.
Program 1.2.2.4 -
Use the development of the Downey Landing as a catalyst for further economic development, including housing, on properties along the periphery of the site.
One of the key topics of the Housing Element is addressing housing needs and accommodating the 6,525 units stipulated by the State's RHNA. As a part of assessing the City's housing needs, a sites inventory was performed to identify the specific parcels that can best fit increased densities. The majority of those sites are found along the City's main traffic corridors. This includes large commercial sites such as the Stonewood Mail, Downey Promenade, and Downey Landing. These developments are encouraged to utilize a mixed -use component. In addition, new mixed -use zoning and overlays will be proposed as a result of the Housing Element in an effort to implement the City's existing Mixed -use General Plan Designation. Lastly, the Housing Element will continue to comply with State regulations related to Accessory Dwelling Units (ADU), formerly known as Second Unit Developments. It is estimated that 930 ADUs will be constructed during this Housing Element cycle.
Policy 1.3.2. — Monitor and address changes in land use trends.
Program 1. 3.2. 1. - Adopt a comprehensive update of the zoning chapter of the municipal code.
Program 1.3.2.2.- Adjust the codes, policies, and regulations in response to changes in land use trends.
New and evolving development is continuously introduced into the city, and it remains a responsibility to analyze and determine the viability of these changes in the City of Downey. Some land use changes and trends discussed in the Housing Element aim to address low housing stock, affordability, and development constraints. As a result, there will be future Zone Text Amendments and General Plan amendments. These amendments include implementation of the City's Mixed -use General Plan Designation, increase in housing density, and if viable inclusionary housing policies.
Policy 1. 4. 1. - Promote Neighborhood Identity.
Program 1. 4.1.4. - Promote public participation in the planning process.
Program 1.4.1.5.- Provide public information on ways residents and property owners can improve their neighborhoods.
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I I Fee 1.11 flit b-,-1 eba el Im--af ft--5rctKewr lite[ 5 Givilit dlbv pluTlue IffP11-rid a uUnrffnITRUJ receive information via the Housing Element webpage. At the community meetings, residents were introduced to the intent of the Housing Element and the Regional Housing Needs Assessment (RHNA). Participants shared thoughts related to affordability, sustainability, parking/traffic, support for ADUs, and resources for vulnerable residents.
The information received at these meetings was incorporated • the proposed document.
Lastly, the workshop, surveys, and all outreach material was accessible to both • and Spanish •`
Goal 1.4 - Protect and enhance the residential neighborhoods.
Policy 1. 4.2. - Promote residential construction that complements existing neighborhoods.
Program 1. 4.2. 1. - Discourage residential construction not in hannony with the surrounding neighborhood.
Future development resulting from the goals of the proposed Housing Element will occur along the City's major corridors and large commercial spaces where it is more compatible with high density development. The City's Single-family (R-1) neighborhoods will remain largely the same in terms of character. The R-1 neighborhoods are well established and are part of the City's identity making up 57.1 % of all homes. It remains a priority to preserve that identity. Ultimately, single-family lots will more appropriately help meet housing needs by increasing housing stock via ADUs.
B. Adverse Effects. The proposed General Plan Amendment will not adversely affect surrounding properties or the surrounding environment.
The Housing Element Update only establishes a regulatory environment that supports and encourages housing production. Therefore, no projects are authorized or approved by this action. Future projects, including zone text amendments and new housing units, will be evaluated •::• the appropriate review process, and potentially subject to further environmeiital review.
The Housing Element was reviewed • compliance with the California • Quality Act. Again, because no physical construction is proposed, the analysis is based on a hypothetical development scenario for the Inventory Sites identified in the Housing Element and how construction and operation of those sites may result in impacts to the environment. The Initial Study determined that the Housing Element would result in a "less than significant impact." Therefore, a Negative Declaration is proposed for adoption.
C. Public Health, Safety and Welfare. The proposed General Plan Amendment promotes the public health, safety, and • welfare and serves the goals and purposes • this article.
The goals and policies found within the proposed Housing Element include: providing housing at all income levels, providing housing specifically for vulnerable populations, rehabilitation of existing homes, providing education and resources for homeownership, neighborhood preservation, and affirmatively furthering fair housing. These types of policies fundamentally and inherently promote the public health, safety, and •' welfare of the community. In terms of future development, through the sites inventory analysis a heavy emphasis was placed in determining where future development would be most appropriate in relation to nearby land uses.
D. Conflicts. The proposed General Plan Amendment will not conflict with provisions of this article, including the City's subdivision ordinance.
Approval Cfthe Housing Element does not alter any provisions ofthe Downey Municipal Code. including the City'e subdivision ordinance. Rather zoning text amendments will follow in order to achieve the goals and policies out lined in the adopted Hosing Element.
The purpose ofthe Downey Municipal Code intobeinaccordance with the comprehensive General Plan.
ENVIRONMENTAL ANALYSIS
In accordance with the provisions of the California Environmental Quality Act (CEOA). an Initial Study for environmental impacts was prepared for the proposed project. Thiaenvironnnente| review im analyzed at a "program |evm|^, rather than at "project |evm|^ because there is no request for physical development, and the proposed Housing Element remains consistent with the other elements found within the City'o General Plan atthis time. Therefore, this environmental review tiers off of the City's broader General Plan Environmental Impact Report.
However, future development and changes to the General Plan as a result of the Housing Element Update may be subject to a new and separate CEQA review process.
The initial study finds that the project vvmu|dhave^|mms than significant innpec1m''.and aNegative Declaration will befiled. Acopy ofthe Initial Study/Negative Declaration (|S/NC))|aattached 10 this report as Exhibit D. A 30-day public comment period for the proposed IS/ND was provided starting November 1.2021 and ended onNovember 3O.2031.
CORRESPONDENCE
On January 6, 2022, notice of the pending public hearing was published in the Downey Patriot osa1/8th page ad and noticed at designated City facilities, in accordance with the requirements of the Downey Municipal Code. In addition, Planning staff posted the notice on the project - designated webpage . and advertised onthe Cih/`asocial media platforms. Asofthe date that this report was printed, the City has not received any correspondence regarding this report.
CONCLUSION
Based on the analysis and information contained within this report, staff recommends that the Planning Commission approve the Initial Study and Negative Declaration and adopt the 2021- 2029 Housing Element recommending to the City Council for final adoption.
EXHIBITS °
A. Draft Resolution
�
B. �� Cycle 2021-2O29Housing Element
C. HCOLetter dated November 1D.2U21 and City Responses
O. Initial Study/Negative Declaration
*To avoid redundancy Exhibits A, B, C, D are not included because they have been incorporated as attachments in the City Council Agenda Memo.