02. PH-Adopt a Negative Dec and General Plan Amendment Updating Housing Element — Downey City Council, October 11, 2022 (part 2 of 2)

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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. • information, please see the Technical Advisories • by the Governor's Office of Planning and Research at:
h ftp://or)r.ca.aov/docs/OPR Appendix C final.pdf and
We are committed to assist the City in addressing all statutory requirements • State Housing Element Law. If you have any questions or need additional technical assistance, please contact Colin Cross, of our staff, at gdincrossQhcd.mQov.

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The following changes are necessary to bring the ity's housing element into compliance witil 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 furtherfing] 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, subd. (c)(10)(A)-) Outreach: The element describes outreach ei�orts for the broader housing element, but if - 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.

PattemsandTrends- 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 1 November 10, 2021

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Contributing Factors to Fair 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.

Straiggies and -Adions ' , 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 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, 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

Code, § 65583, subd.

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 va�ious 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 Capacily: 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 to justify 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.
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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 incorpora any relevant programs or policies the City is undertaking to facilitate residential development in zones allowing 100 percent nonresidential uses.

City of Downey's 6th Cycle Draft Housing Element Page 3 November 10, 2021

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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 • • incentives • standards to encourage additional •^ development • these sites. • example, the element could clarify what is meant •: "potential ::• • :• • and consider additional indicators such as .• and condition • the existing structure, presence of expiring leases, expressed developer interest in residential development, low improvement to land value ratio, and other factors.

Small Sites: The element identifies many sites at less than a half -acre. These sites are • eligible • a demonstration that sites • 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 • • track record in facilitating • consolidation, policies • incentives offered or proposed to encourage and facilitate lot consolidation, conditions rendering parcels suitable and ready for lot consolidation, or information from the • • each aggregated site.

Access2[y_Dweffing 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 •- a realistic estimate • the •• for 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 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 • 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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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 complianot with this requirement and if necessary, add or modify programs to establish a written procedure by a date early in the planning period.

Electronic Sites lnv8ntoN- 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 at hltp$�.ItWWw�hcda.gov/bomLnunft�- qgyglop,MenVbpg�liament/index.shtM]#eloMb�ht for a copy of the form and instructions. The City can reach out to HCD at sit&§invehtoN@hcd1qagov 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 con,trtgls as potential constraints on a variety of housing types, both independently and cumu a ive 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. I
Site Plan Review: The element must analyze the City's Site Plan Review, including approval procedures and decision -making criteria, for their impact as potential constraints on housing supply, cost and approval certainty. Specifically, certain approval findings, such as that a proposed development should "integrate harmoniously", prevent "extremes 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 discuss whether approval findings, standards and guidelines provide for development certainty and impact the cost and timing of approvals. The element must add or modify programs as appropriate to address identified constraints.

Zoning and Fees Transparency: 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).)
City of Downey's 6th 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, § 65583, subd. (a)(7).)
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 Blocks at httio-// www.hcd.ca.aov/community-devglppM� gnt/buildin -b-l0CkS/h0US`ln -nee-dS/largj 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).

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

Code, § 65583, subd. (c).)
To 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 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 6th 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 service.

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).) Program 1. 1 (Adequate Sites) commits to rezoning and satisfies many requirements, but it should also clarify by -right and minimum densities consistent with Government Code sections 65583.2, subdivisions (h) and (i) and commit to 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. (c)(3).)
As noted in Findings 1.3 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 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. (c)(5).) As noted in Finding All, the element does not contain programs that satisfy the AFFH requirements for specific and meaningful actions to overcome fair housing issues. Based on a complete analysis, the element must add or revise programs.

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. (c)(7).) 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 6th Cycle Draft Housing Element Page 9 November 10, 2021

Local governments shall make a diligent effort to achieve public participation of all economic segments • the • in the development • 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 a draft of the element in advance of submission, the City has not yet complied with statutory mandates to make a diligent effort to encourage the public participation in the development of the element. This reduces HCD's ability to consider public comments in its review. The availability • the document to the public and opportunity for public • prior to • 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, considered, and addressed public comments in the element. The City's consideration of public comments must not be limited by HCD's findings in this review letter.

City of Downey's 6th Cycle Draft Housing Element Page 10 November 10, 2021

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DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.cio
Aldo Schindler, Director
Community Development Department
City of Downey
11111 Brookshire Avenue
Downey, CA 90241
Dear Aldo Schindler:

Thank you for submitting the City of Downey's (City) revised draft housing element received for review on December 22, 2021, along with revisions received on February 3, 2022. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review.

The revised draft element addresses many statutory requirements described in HCD's November 10, 2021 review-, however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code). The enclosed Appendix describes revisions needed to comply with State Housing Element Law.

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

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the statutory deadline (October 15, 2021), then any rezoning to accommodate the regional housing needs allocation (RHNA), including for lower -income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government's housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i).

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element

FAMANTIRSAMMARMWIT

Page 2 ends

process, the City should continue to engage the community, including organizations that represent lower -income and special needs households, by making information regularly available and considering and incorporating comments where appropriate.

Several federal, state, and regional funding programs consider housing element compliance as an eligibty or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD's Affordable Housing and Sustainable Communities programs; and HCD's Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City meets housing element requirements for these and other funding sources.

For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor's Office of Planning and Research at:
-httr)-//or)r.ca.gov/docs/OPR Appendix _Q final.pdf and 01122twf.cai� ovklocsffinal 626A&pff
HCD is committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Colin Cross, of our staff, at colin.crossahcd.ca.. ov, Sincerely,
VXr
Paul McDougall I
-1 -14A.Iylawafir -w-
Enclosure

APPENDIX
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, subd. (c)(10)(A).) LL •I V I
but shoul complete an analysis with trends and how local data and knowledg and other relevant factors relate to the data and explanations of patterns. Please s e HCD prior review for additional information.

I U155 IN I'letrier U15trildlitAlu UT 511e: OF UAaGerUa1e5 GUHU11101-15. IT SlIeS exacerbate conditions, the element should identify further program actions that will be taken to mitigate this (e.g., anti -displacement strategies). For more information, please refer to HCD's prior review.

City of Downey's 6 th Cycle Revised Draft Housing Element Page 1 February 18, 2022

r I r I
and fair housing results.

Code, § 65583, subd.

I I M a 11:4.1 V L17421 4 rt 1 W r-lyk:j Lej OJ I a Ak ---------- -]a(* law Qr A L Nqnv,acantSijgLs: As noted in the prior review, the element must include an analysis to demonstrate the potential for additional development on nonvacant sites. 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.

In response, the element now includes some discussion of factors used to determine potential for additional development. However, the element should still include analysis of recent experience in converting existing uses and how that experience relates to factors and identified sites. The analysis should also address the extent existing uses impede additional development.

In addition, the element relies on nonvacant sites to accommodate 50 percent or more of the housing needs for lower -income households. As a reminder, this reliance triggers requirements to make findings based on substantial evidence that the existing use is not an impediment and will likely discontinue in the planning period.

City of Downey's 6th Cycle Revised Draft Housing Element Page 2 February 18, 2022

be revised to provide analysis demonstrating the potential for lot consolidation. For more information, please refer to HCD's prior review.

Accessor y Dwelling Uiqits (ADUs 6 Program 1.4 is revised to commit to ADU monitoring by production and affordability, and to commit to additional action should ADU production fall short of numbers assumed in the element. However, the revised element assumes 106 ADUs per year will be constructed during the planning period, for a total of 848 ADUs. The element's analysis and programs do not support this assumption.

Based on numbers reported in the element, the City is averaging 44 ADUs per year. To include a realistic estimate of the potential for ADUs, the element must reduce the number of ADUs assumed per year or include additional analysis and programs to demonstrate the likelihood of these ADU assumptions.

Infrastructure- The element now generally describes infrastructure capacity, but it should clarify sufficient total water and sewer capacity (existing and planned) to accommodate thc. regional housing need allocation and include a program if necessary.

Electronic Sites Invento[y. 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 at
develooment/housinq-element/index.shtml#element for a copy of the form and instructions. The City can reach out to HCD at sitesinventorv(,5-hcd.ca.gov for technical assistance.

Zoning for a Varijety of'Housing T�pe�s (EmeLgency Shelters)* The element now lists development standards and includes a program to address spacing requirements as a constraint. However, parking requirements also appear to be a constraint and do not comply with statutory requirements. The element should add or modify programs to address this constraint.

Land -Use Controls: The element now lists multifamily parking requirements and conclud-'" parking requirements are based on unit type and size and are not considered a significa constraint. However, parking requirements exceeding two spaces per unit are a constraii on development, particularly for studio and one -bedroom units. Also, the City requires th spaces to be in a garage which impacts development costs. The element should add or modify programs to address this constraint. I
City of Downey's 6 th Cycle Revised Draft Housing Element Page 3 February 18, 2022

4. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)
The element is revised to state that there is a low need for farmworker housing in Downey. However, the element must still provide an estimate of the number of Tarmworkers based on both seasonal and permanent employment. Please see HCD's prior review for additional information.

Code, § 65583, subd. (c).)
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2s follows:
• Programs 2.3 (Affordable Housing Development) and 2.4 (Affordable Housing Technical Assistance) should include proactive outreach with developers with a discrete timeline (e.g., annual).
• Program 3.1 (Lot Consolidation) should commit to specific incentives • Program 3.5 (Special Needs Housing) should modify the timeline earlier in the planning period (e.g., within one year).

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).) City of Downey's 6th Cycle Revised Draft Housing Element Page 4 February 18, 2022

IJLSI MOMMATO ME IN
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WIeHIFTIeFlIdl arIU f1*11YU, I Ital -UtH511aIIII5. ACAN!M11111S IA1011 Me IC5111L-5 10711 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. (c)(5)) As noted in Finding Al, the element does not contain programs that satisfy the AFFH requirements for specific and meaningful actions to overcome fair housing issues. Based on a complete analysis, the element must add or revise programs.

City of Downey's 64h Cycle Revised Draft Housing Element Page 5 February 18, 2022

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STATE �QE� qALIEORNfA - BUSINEa�� CONSUMER SEWCEES AND HOUSIN6 AGEN.CY...G.AVIN NE...

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.qo
Aldo Schindler, Director
City of Downey
11111 Brookshire Avenue
Downey, CA 90241
Thank you for submitting the City of Downey's (City) revised draft housing element received for review on December 22, 2021, along with revisions received on February 3, 2022. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review.

The revised draft element addresses many statutory requirements described in HCD's November 10, 2021 review; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code). The enclosed Appendix describes revisions needed to comply with State Housing Element Law.

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), a local government fails to adopt a compliant housing element within 120 days of the statutory deadline (October 15, 2021), then any rezoning to accommodate the regiona housing needs allocation (RHII including for lower -income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government's housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i).

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element Attachment "C"

M1011jR1111 N
Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD's Affordable Housing and Sustainable Communities programs; and HCD's Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City meets housing element requirements for these and other funding sources.

HCD is committed to assisting the City in addressing all statutory requirements of Statc Housing Element Law. If you have any questions or need additional technical assistance, please contact Colin Cross, of our staff, at pciih�crosg@bcd,moov.

Sincerely,
I;Vll/�Jy t�
MIT06=2

APPENDIX
JWMhOrmylakk
The following changes are necessary to bring the City's housing element into compliance wi Article 10.6 of the Government Code. Accompanying each recommended change, we cite t supporting • •: the Government Code. I
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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, subd. (q)(10)(A).) •, should complete an analysis with trends and • •', data and knowledge and other relevant factors relate to the data and explanations of patterns. Please see HCD's prior review I• additional information.

MCI L It* I so uiswlss,iineul flu 015MOITIOn of SITES Imprures i r Mceruates conallion A exacerbate conditions, the element should identify further program actions that will be taken to mitigate this (e.g., anti -displacement strategies). For more information, please refer • HCD's prior review.

and fair housing results.

2. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality's housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov, Code, § 65583, subd. (a)(3).)
NonvacantSites- As noted in the prior review, the element must include an analysis to demonstrate the potential for additional development • nonvacant sites. 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, developmervt trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites.

In addition, the element relies on nonvacant sites to accommodate 50 percent or more the housing needs for lower -income households. As a reminder, this reliance triggers requirements to make findings based on substantial evidence that the existing use is n an impediment and will likely discontinue in the planning period.

Small Sites- The response -to -comments document submitted alongside the element claims that "lot consolidation assumptions in the inventory are limited". However, the inventory still contains many parcels less than half an acre in size, and element is revised to affirm that these sites are anticipated to consolidate, noting the sites "are t included because the multiple parcels function as one site" (p. 4-25). The element musl

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4. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency she/ter (Gov. Code, § 65583, •
The element is revised to state that there is a low need for farmworker housing in Downey. However, the element must still provide an estimate of the number of farmworkers based on both seasonal and permanent employment. Please see HCD's prior review for additional information.

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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, ♦ • subd.

To have a beneficial impact in the planning period and address the goals of the housing element, programs must still be revised with discrete timelines and specific commitment, as follows:
• Programs 2.3 (Affordable Housing Development) and 2.4 (Affordable Housing Technical Assistance) should include proactive outreach with developers with • timeline (e.g., annual).
• Program 3.1 (Lot Consolidation) should commit to specific incentives • Program 3.5 (Special Needs Housing) should modify the timeline earlier in th planning period (e.g., within one year), I

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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))
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IMIRITOIN =I- Fine MI
11tal LANSUdIlIt5. ff�&Aerllllig IA'*Fl Ifle levW51115 is, 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. (c)(5)) As noted in Finding Al, the element does not contain programs that satisfy the AFFH requirements for specific and meaningful actions to overcome fair housing issues. Based on a complete analysis, the element must add or revise programs.

dd of Downey
Housing Element Udate
2021-2029
Program Initial } Study
and
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Lead Agency
City tDowney
Planning Department
12:��#«wl�f
#■« «» ?±� w�
Consultant
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This document is designed for double -sided printing

Table of Contents
1 PURPOSE AND AUTHDRITY_....... _........... ---_...... --'-_--....... ....... ~~.... ......... ----------........ .......... ----1
CowTswTo 1
TIERING 1
2 PROJECT DESCRIPTION ...................................................................................................................................................................... 5 3
19 ENVIRONMENTAL FACTORS POTENTIALLY AppsuTso_-°_.... ~__~~__^~_~_.=~"~__~-~........... °~=~~....... ...... _~-...... ~~_~1A DETERMINATION ,,"__...... ........ ____ ........... ........ _^,_...... ,........ ............ ...... ...... _,^____...... ....... _10 4 EVALUATION OFENVIRONMENTAL IMPACTS ............................................................................................................................... 20 1 AESTHETICS.. � ........'`�r_.cv

2. AGRICULTURAL RESOURCES .........

3. AIR QUALITY ^.~__.~.._..~..-.._^~_~_..°._~--^.__..... ......~~~..._...^=_....~_.-.._.~_~....... ~.~..__..~.... .24

4. BIOLOGICAL RESOURCES .............. _~_.___~~_~._~_`.___~__~.~.___~-_~~__,_°_.~__._~_~_~.~_~__........ _.28

5. CULTURAL RESOURCES ................ __________~.~._._^__.~,~__-~~_,.~_.,=_____.^_~-~__.___...... ""___.3U

0. EwcRSr_=................. ....... __...... ...... ____r__,...... ~........ ___"__....... _-_.... __=_s32

7. GEOLOGY AND SO|U;___.... __~-....... ....... ....... ....... _..~_-.34 8 ��sswx0Uac��8Em|�S0wG
'--/-��-_-�----._�,.--9��°._��_-`,_�-__-��_x�-°��'--�.--F_---^"��--��'« 7 0. HAZARDS AND HAZARDOUS MxTsnIA0-_-.~.~_-~.~^~~~.~_........ ~-~.^.._._~_.~~~_~._~a-~.~~_~_..,~~.a..~~^... 3O

10. HYDROLOGY AND WATER OUxLnY._~_^~_--- __~.___~_..~___~~___~.^_.~~~~_-_..-~.."_~..__~~~_~42

11. LAND USE AND PLANNING ,~,-~°_-_~_.~.~~_-._~~_._~._........ ~.~..... --_........ ...... _~45

12. MINERAL RESOURCES ..... ~~...... _°___^___,,__°~,.,__^~_,_.~__^_,_~__~~___,__,___.... ____�____~48

13. NOISE .... -........ =_............... _......... ....... ........ .............. ........ `_............... ...... ,..... .47

14. POPULATION AND HOUSING. ... ....... ........... .._~_.-_,........ ~____.... ___ .... ~_,4Q � =~--_--°�._-�'�"-�-��-��_�'�-��^�--_-�-_��---��-~�_.-�-�_�_--�°-�-_- 15 PUouo8snv|CsG
50 16. RECREATION ........ ........... ..... ~,.............. ___........ _............. ..... .......... .... ... ...... ...... ^___._...... ___~^~..... 53 17. TRANSPORTATION AND TRAFFIC .... __.............. _.^a ....... -.__..... .. .......... ...... _~_-'"-'_-53 18, TRIBAL CULTURAL RESOURGcG._-~,--__~__~_-._-_~^.~_~.~~~_~___~^~~°_~._^_-__~_~^.._~^..°_~5G

19. UTILITIES AND SERVICE SvSTsw8__~~.=._._.^^=.,._..,_,_.^_.._^..___._=,,__,.^_._^_=~.___,~~,..-.~__~.,~°.,57

20. WILDFIRE ...................... ._.... ....... ,_........ _....,,__....... _....... _,5Q

21. MANDATORY FINDINGS OFSIGN|pICxNCs____,_...... ...... _~_.,..,...... ................ _...... ~...~6O LEAD AGENCY...

TiESTAITTETWER
TABLE 24RESIDENTIAL AND MIXED -USE LAND USES .................................................. ........... ........ ...... '6 TABLE 2-2 RESIDENTIAL ZONING DISTRICTS..,,_-,.,, ......... ... ..... ____ ....... ...... ___ ...... 8 TABLE 2-3REGIONAL HOUSING NEEDS ASSESSMENT ALLOCATION � 8 -----�'.�,�_--�-�_�-��___�`-�-�*~-@'_�_--
TABLE24RHNACRED|TSANDREMA|N|NGNEED__.~_..~..~.~~_-~_.__~_=~_"_______~~=.~~`-_~.-~=_,-_.^~8 TABLE 2'5VACANT LAND INVENTORY .............. _-^..~`_~^.,"=~.~~__~_^_'___.'_^._.-~-_-.~_.^-_-___^~~___^-._Q TABLE 2'GUNDERUTILIZED LAND INVENTORY. 10
TABLE 2-7 LAND INVENTORY AND NEEDS COMPARISON . ... ------- 10

LIST OFEXHIBITS
F|GURE21REG|0NALCONT�XTAWDV|QN|TY�A 13
- __^�__�^__o,_'
FIGURE 2-2DOWNEYSITES INVENTORY ...... ....... _,... ___ ~~____ ......... __~_^-___...... ................ ... _.......... ... .... ....... ____ 15 City of Downey ^i

Table of Contents
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The purpose of this Initial Study is to identify and assess the significance of the physical effects onthe environment due to potential future development guided by the goals and policies of the City of Downey portion of the 2021-2029 Housing Element Update. Pursuant to the California Environmental Quality Act (CEQA), the proposed Housing Element Update (HEU) ioconsidered a''P 'ont' and thus requires analysis and determination of environmental effects prior to approval.

This Initial Study has been prepared in accordance with the California Environmental Que|dv An K}EOA\ Statutes and Guidelines and the City ofDowney local rules and regulations. The proposed Project requires discretionary approval by the City of Downey and review by the California Department nfHousing and Community Development (HCD). As the project initiator, and because of the legislative approvals involved, the City of Downey is the Lead Agency with respect to this Initial Study pursuant to G15307 of the CEQA Guidelines. Specifically, the HEU Project requires City of Downey approval of a General Plan Amendment No.PLN-21'00139. No other governmental agencies have discretionary permitting authority with respect to approval of the proposed Project, and no Trustee Agencies, as defined in §21070 of the CEOA Statutes, has jurisdiction over resources such that Trustee agency approval is required for entitlement approval.

Pursuant ho015U74ufthe CEOAGuidelines, prior toapproving the Project, the City nfDowney isobligated tuconsider the findings of this Initial Study and to either adopt aNegative Declaration (W0or a Mitigated Negative Declaration (MN0or determine that an Environmental Impact Report (BR) is required due to potentially significant, unavoidable environmental impacts. The findings of this Initial Study support adoption of a Negative Declaration (ND), as discussed in Section 4. Either of theme determinations indicate that the environmental impacts of the programs for accommodating housing pursuant to the proposed HEU' in accordance with the governing land use planning policies and zoning standards, will be less than significant and that anBRienot required.

This document has been prepared tocomply with Section15063 of the State CEQAGuidelines that sets forth the required contents of an Initial Study. These include:
• A description ofthe project, including the location of the project (see Seution2) w Identification ofthe environmental setting (see Section 211\ • Identification of environmental effects by use ofechecklist, matrix, urother methods, provided that entries on the checklist or other form are briefly explained to indicate that there is some evidence to support the entries (see Section 3)
• Examination of whether the project iscompatible with existing zoning, plans, and other applicable land use controls (see Sections 2.Oand 27)
• The name(s) of the person(s) who prepared or participated in the preparation of the Initial Study (see Section 5.1)
Section 15152 et al of the CEQA Guidelines describes "tiering" as a streamlining toolas follows:
() 7ienno"refers ho using the analysis of general matters contained i7abroader EIR (such eaone prepared for aQeneny plan orpolicy with later £7Ruand negative declarations onnarrower incorporating bvreference the general discussions from the broader EIR; and concentrating the later EIR or negative declaration solely on the issues specific hothe later project
/@ Agencies are encouraged to tier the environmental analyses which they prepare for separate but related projects including general plans, zoning changes, and development projects. This approach can eliminate repetitive discussions cfthe same issues and focus the later BRornegative declaration onthe actual issues ripefordncisionetmeoh6axe/of environmental review. Tiering isappropriate when the sequence ofanalysis is from an£JRprepared 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. 2 2021-2029 Housing Element

Purpose and Authority
0H There are various types of EIRs that may be used inatiering situation. These include, but are not limited to, the following:

CU General Plan £}R /5160
CB StaoedBR /0187)
(3) Program EIR /5/80
(4) Master BR(Section /5/75)
(5) Multiple -family residential developm*ntlresiden/ial and commercial or re/ail mixed -use development (Section /5Y7A.5)
/0 Redevelopment project (Section Y5/80
(7) Projects consistent with community plan, general plan, m'zoning (Section /5103U This Initial Study for the 2021-2029 Housing Element has been prepared to tier from the General Plan "Program"BRof 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 nfDowney
11111 Brookshire Avenue
Downey, California 90241
Barbara J.Riley Community & Senior Center
7O1OQuill Drive
Downey, California 8O242
Downey City Library
11121 Brookshire Avenue
Downey, California 90241
The environmental analysis contained in this Initial Study is based on the following assumptions:

General Plan Consistency: As the General Plan in updated and/or amended, the City ofDowney will ensure that such updates and amendments do not prevent implementation of the policies contained in the updated Housing Element, Categorical Exemptions: Smo||*r-aue|e ministerial projects that require issuance of building permits without need for discretionary action are generally exempt from environmental review pursuant to CEQA in the absence ofcompelling evidence that the project iouniquein1hetitmeynaSu|tinuignifinuntindivi0ua|mnU/oroumu|e1iveimpectu.SmoUer-yoa|op joctsm8ybe exempt from CEQAanU require nofurther analysis. Exempt projects are m}nViU*md to have no significant impact on the environment, audefined inSection 1530Oofthe CEQAGuidelines.

Project Specific Environmental Review: Futuna development proposals not exempt from CEQA will be subject to the environmental review process to identify potential impacts and impose appropriate mitigation measures, if needed, to avoid significant impacts.

Purpose of Environmental Review: The proposed Housing Element Update does not eoLhnhz* any plan for construction of new homes or other uses or the redevelopment of any properties within the local jurisdiction. No direct environmental impacts, therefore, will occur as a neou|1 of adoption of the HEU. This Initial Study eaue000a the potential programmatic level City of Downey� - ---

Purpose and Authority
zmvironmental impacts resulting from potential development facilitated by the Housing Element in accordance with the Lead agency's existing land use policies.

I hail I W1 C we 0
110"I'M we
3 19M myMW67111MM
documentation, to ensure sufficient land use capacity is available to accommodate the RHNA The purpose of the environmental analysis conducted for the Housing Element, as documented herein, is to determi general impacts that could result from implementation of the Housing Element. The analysis is based on a hypotheti development scenario for the Inventory Sites identified in the Housing Element and how construction and operation of tho sites may result in impacts to the environment. Because this is a program -level analysis, some measure of forecast a I or unreasonable. Therefore, the program -level analysis of the potential impacts of the Housing Element is inherently bro and typically qualitative due to the lack of specific project -level information. 4 2021-2029 Housing Element

PROJECT
TiTLE City ofDowney 2O21-2U2SHousing Element Update Plan Amendment Application No. PLN-21-X) 39)

LEAD AGENCT SPONSOR NAME AND ADDRESS
City of Downey
11111 Brookshire Ave.

California 9O241
CONTACT PERSON AND PHONE NU80BER
Cwata|Londavozo' City Planner
Planning Department
11111 Brookshire Ave.

California 9U241
/502 904-7154
Email: HEUod org
This Initial Study analyzes the potential environmental impacts associated with adoption of the City of Downey'asixth cycle /2021-2029Housing Element. The Housing Element is e required component of the Cdy'u General Plan and must be updated on a regular booiu' as set forth in Government Code Section 055887he Housing Bement consists of these components, described in detail below: i\ housing needs, 2\ constraints to housing development, 3\ housing mooumao (available sites and funding sources), and 4) a housing plan.

The 2021-2O29Housing Element applies to all properties within the City of Downey onwhich existing and proposed General Plan land use designations and zoning districts allow residential and/or mixed -use development. The Housing Element does not specifically authorize the construction ofany housing development, nor does itindicate where and when specific housing projects will occur, The Housing Element is a policy document setting forth the Cih/m plan to accommodate its share of regional housing needo, as determined by the Southern California Association of Governments (GCAG). For the 2021'2029 planning period, the City ofDownoy`ashare io0'525 housing units. This allocation is referred toauthe Regional Housing Needs Assessment, orRHNA.

Subsequent to this Housing Element update, the City will be undertaking focused General Plan and zoning ordinance amendmenh;, described below and with separate CEQA review, to ensure sufficient land use cooanhv is available to accommodate the RHNA. This Initial Study examines the potential environmental impacts eta program level for only the Housing Bement since the Housing Element itself dmau not specifically authorize the construction of any housing dove|opment, nor does itindicate where and when specific housing projects will occur. 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 atspecific sites.

The City of Downey is located in the County of Los Angeles' approximately 13niles southeast of downtown Los Angeles and adjacent tothe cities ofPico Rivera, Santa FeSprings, Norwalk, Bellflower, Paramount, South Gate. Bell Gardens, and Commerce. Major freeways and roadways serving the City include |nbarstateu5. 005'105' end710, Lakewood Boulevard (SR 19), Florence Avenue, Firestone Boulevard, Imperial Highway, and Paramount Boulevard (see Figure 2-1).

City of Downey 5

IM7.71r,
Figure 2-1
unyw(lou
Rosemead
Beverly Hills "'e i y 3 El Monte
Monterey Park
Los Angeles
.:as; iv'j
East Los
Anaeies
Culver City 'e","4W
Montebello
nn�ca
Park Baldwin
HIPS 'tN' 540
Huntington
Park Whitfler,,,
ln'glawand
South Gate N
Downey
R c r a n s Lynwood
4awthorne I Norwalk
r
-Marine, Ave Compton
Bellflower
Cerritos
ns
Rodondo Lakewood
Reach Torrance
Palos
•
vrsdr'
Post
6 2021-2029 Housing Element Update

Purpose and Authority
11MR:00570021-
mop! i
Wall i
6 4101 le M Wir.] In 11161*111111 its] I [#I ilLyrj 1JiJp[#L4JOJ ILS] llpopplififfim qr:jatl;]-- I I a 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 to allow residential development at a density of at least 30 units per acre.

Table 2-1
General Plan Land Use Designations
_F
Allowed Uses
------ -
Low Density Residential
Single-family Dwellings,
1 to 8.9 units per acre
Accessory qDwelli Units
based on lot size'
Low/Medium Density Residential
Duplex Dwellings,
9to 17 units per acre
AccessoqAtIling Units
Medium Density Residential
Duplex Dwellings, Multi -Family
18 to 24 units per acre
Dwellings, Accessory Dwelling Units
Mixed Use
Multi -Family Dwellings, Mixed -Use
Maximum of 24 units per acre
Source: Ci of Downe ,Vision 2Q25 General Plan,: 2005
FZOMTTTCT/ c�
The Housing Element indicates that the City's zoning regulations currently do not provide the appropriate range of housidne densities and that insufficient zoning capacity exists citywide to accommodate the RHNA at the various income ranges. Thu amendments to the zoning ordinance and zoning map are being undertaken in conjunction with adoption of the Housi 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-fig 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).

City of Downey 7

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.

Table 2-1
Sinale FamIlIX Zoning Districts, Revised MaX 2021
Lot area - minimum (square feet) 5,000 6,000 7,500 8,500 10,000 Lot width - minimum (feet) 5-0 F50 --- --------- 60 - — ----- - -65 70 Lot depth - minimum (feet)
interior lots
corner lots
Floor area ratio — maximum (a)
Lot coverage — maximum
Building height - maximum (feet)(b)
main building
_____ 1.1-1—
Lot depths shall be within ten percent (110%) the average depth of the two (2) abutting R-1 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 alo g the common front and frontage,
.45 .45 .45 .45 �45 �40
_::::�45% 45% 45% 45% 45% 5
I
Front setback (1stfloor) — minimum 20
(feet)(c,d) I
211d floor front setback — minimum
(feet)
Rear setback - minimum (feet)(d)
Side setback (1st floor) - minimum
(feet)(e,f)
28 28
28 28
12 1 12
12 12
20 20
20 20
At the 2nd story fagade facing a front yard, the maximum width of the 2nd floor 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 1 st floor facade.
20 1 20 1 20 20 20
Ten percent (110%) lot width, but not less than five feet (5) and not to exceed 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) I fagade aligned with the 1 st floor fagade directly below shall be no greater than Street side setback (1 st floor) -
minimum (feet) d,
2nd floor street side setback -
minimum (feet)
Dwelling unit size - minimum
(square feet)(9)
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 feet from the 1 st floor facade,
10 10 10 10 10
At the 2nd story fagade facing a street side yard, the maximum width of the 2nd 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 floor facade. 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 (feet) 6 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. (e) 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 uare feet
Lot area per dwelling unit - minimum (square
feet)
Lot width - minimum (feet)
!=2t depth minimum feet�
Lot coverage -maximum (perar
Building height - maximum (feet)
main building
accessory building
Yardsetbacks - minimum (feet) front
front
rear
Yard setbacks (side) minimum (feet)
interior (c)
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
Lots shall conform to t
50 30 feet or two stories,
whichever is less
12 feet
20 20
5 100 1
100
verage depth of adjacent lots
50 50
35 feet or three
35 feet or three
stories, whichever is
stories, whichever is
less (a)
less (a)
12 feet
12 feet
15 see note (b)
5 (C)
15 see note (b)
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 (4) bedroom
1,300
1,300
1,300
Buildina separation - minimum (feet)
10 10
10 Main building and detached garage 5 5 5
se aration -minimum feet
Usable open space area per dwelling unit — 200 200
minimum (square fee)__
Source: City of Downey Municipal Code, 2020
Notes:
0) When abutting R-1 or R -2 zoned properties, the variable height requirement shall apply in accordance with Section 9534.24, (b) 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, di Exclusive of porches, balconies, garages, or other such accessory structures or architectural features.

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 Housing 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 construct housing to meet those needs, but it must create a regulatory environment that supports and encourages housing production and equal access to housing.
awrx;f
3) housing resources, and 4) housing plan. Article 10.6, Section 65580 — 65589.8, Chapter 3 of Division I of Title 7 of t California Government Code establishes the legal requirements for a housing element and encourages the provision affordable and decent housing, in suitable living environments, in all communities, in working toward statewide goals. T 1:161FM M1e]MAA1*1
11UV3U11U1U5 dlt� pajilly MUM WWI UKJ-j Udll HUM 1U1
elderly, large families, female -headed households, households with a physically or developmentally disabled person, farrr- workers, and the homeless.
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
State law requires that jurisdictions demonstrate in the Housing Element that land inventory is available and adequate to accommodate the RHNAallocation. The City ofDowney has determined that the inventory ofvacant residential sites, vacant mixed -use sites in the Downtown Downey Specific Plan, and estimated production of accessory dwelling undo during the planning period is not sufficient to accommodate the remaining RHNA of 5,732 units. Subsequent to and within three years of Housing Element adoption, the City will amend the General Plan and zoning undinonce/mapto provide sufficient capacity.

Sites currently available and appropriate to accommodate a portion of the RHNA are categorized and summarized below.

KapanbUndemuti0zedLand Inventory
The Housing Element includes an inventory nfvacant/underutilized properties that could accommodate residential uoao based on on analysis ofCounty Assessor data and field checks. The vacant/underutilized land inventory totals 30.31 acres. These vacant sites, identified in Table 2'8 (Currently Available Vacant/Underutilized Lend |nmanhon), have the pohanUe| to e000mmodote2'222 units with applicable land use and zoning noquivemento, such as consideration of parking, landscaping, and hght-of-wayrequirements.
12 2021-2029 Housing Element Update

Table 2-6
Currently Available Vacant/Underutilized Land Inventory Estimated ADU Production
Vacant/underutilized R-1 sites — 6 parcels, 1.74
acres total
Vacant/underutilized R-2 sites -10 parcels, 5.53
acres total
Downtown Down SS ecific Plan:

District 1 - 20-40 du/ac - 5 parcels (3 sites) and

1.75 acres total
District 2 - 8-40 du/ac-12 parcels (4 sites) and

2.05 acres total
District 3 - 20-40 du/ac -18 parcels (6 sites) and

4.39 acres total
District 5 - 40-75 du/ac- 35 parcels (9 sites) and

14.85 acres total
Total Sites Currently Available
Remaining RHNA after approved/proposed
Remaining
Purpose and Authority
244 463
22 309
1,038
_e
14 14
w
94 94
36 8
9 53
10 11
42 67
35 36
138
575 -
134
134
843
943 463
209
607
2,222
1,727 896
915
2,194
5,732
. 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)
< Sites allowing the State -designated default density standard (at least 30 dulac) are credited toward the lower income RHNA Small sites meeting the default density 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 of 2,222 dwelling units of which 1,406 units include sites suitable for development of very low- to low-income housing. Based on the analysis provided in the Housing Element, the City has determined that adequate sites are not available to accommodate the RHNA and that subsequent to adoption of the Housing Element, within three years of such adoption the City will amend the General Plan and zoning ordinance/map to accommodate the shortfall. The sites to be considered have been identified and are summarized in Table 2-7 and shows that once appropriate land use and zoning actions 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 be subject to CEQA review. 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.

City of Downey 13

Determination
Table 2-2
Sites to be Rezoned boAccommodate RHNAShortfall
ordability Level
Ex.Nery
Low Moderate
Moderate
High Density Residential (R-3) Sites
66 371
342
779
(146 parcels, 24.5 acres total)
Low Density Residential site to
4 40
44 Rezone to High Density
Residential (R-3)
(1 parcel, 1.3 acres total)
(21 parcels, 7.78 acres total)_
Telegraph Road
96 (45 parcels, 19.03 acres total)
Florence Avenue
33 33
(1 parcel, 1.1 acres total)
(31 parcels, 19.57 acres total)
proposed projects and sites currently
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 capacity for 16 units are reqyj�ir �Ilaw for �Iower-incomeshorffall �sites arecredited toward the moderate -income RHNA shortfall,
The proposed updated Housing Element includes the following goals, policies, and programs:

Goal1. Encourage avariety cfhousing types tqmeet the existing and future needs ofCity residents.

Polioy11 Accommodate evariety ufhousing types tomeet the needs ofall residents.

Policy 12 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 tofind suitable ownership and rental housing inthe City.
14 2021-2029 Housing Element Update

Purpose and Authority
Policy 1.4 Encourage the development ofresidential units and the provisionofrelated services for special needogmupo. including the elderly, large houuohoNu, single perents, persons with disabi|ities, extremely low-income persons, and persons experiencing homelessness.

Policy 1.5 Encourage infiUdevelopment and recycling ofland toprovide adequate residential sites.

Policy 1.8 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 huuuehn|0o 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 for new housing developments
Policy 2.3 Encourage and provide incentives for both the private and public oeotum 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 24 Provide rental assistance to address existing housing problems and provide homeownership assistance to expand housing opportunities.

Policy 2.5 Support regional efforts to develop affordable housing and address homelessness.

Goal 3. Where lemoUv possible, remove governmental constraints to the maintenance, improvement, and development ofhousing, including housing for all income levels and housing for persons with disabilities.

Policy 3.1 Review and adjust residential development standavdo, negu|adiono, 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 reductione, or other regulatory incentives, as available and appmphate, to minimize the effect ofgovernmental constraints.

Policy 3.3 Monitor State and federal housing -related legislation, and update City plans, ordinances, and processes as appropriate toremove orreduce 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 ted|i1ehs production of affordable housing.

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 ofneighborhoods and existing housing, especially affordable housing.

Policy 4.1 Assist in the conservation and preservation of all affordable housing undm, including mobile home pedm and govern ment-subsWizedhousing, 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 43 Leverage State and federal loans and grants to eeuimd 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 —�� --

with aging and deteriorating housing and infrastructure.

Policy 4.5 Encourage energy conservation and sustainable building measures in new and existing homes.

Policy 4.6 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 fair housing opportunities and promote housing throughout the community for all.

Policy 5.1 Affirmatively further fair housing related to the ao|e' rental, and financing of housing to avoid discrimination based on nuue, religion, age, sex, mehba| stetum, anomobv, national nhgin, color, familial stotua, or disability, orany other arbitrary factor,
Policy 5.2 Promote and affirmatively further fair housing opportunities and promote housing onUunm throughout the community for all persons.

Policy 5.3 Assist in the enforcement of fair housing |mwm by providing support to organizations that can receive and investigate fair housing allegations, monitor compliance with fair housing laws, and refer possible violations huenforcing agencies,
Policy 5.4 Ensure that persons with disabilities have adequate access tohousing.

Policy 5.5 Facilitate ioonmeued participation among traditionally underrepresented groups in the public decision -making process.

Po|ioy5.O Provide outreach and education for the broader community of residents, residential property owners and operators regarding fair housing practices and requirements. an heavy). Transportation facilities Inventory Sites identified for single-family use are generally surrounded by single fam residential uses and located near city boundaries. Inventory Sites identified for high density or mixed -use development a - generally centrally located within the city adjacent to limited industrial or commercial uses. 16 202/ Element Update

Purpose and Authority
Figure 2-2
Base Map Features
Downey City Boundary Approved Propoed Projects (Credits) Sites To Be Rezoned and JIM Approved or Proposed Projects MDRIR3 Sites to Rezone Parks Open Space
Rivers and Waterbodies Sites Currently in Place LDR/R1 Rezone to MD Vacant and Underutilized R I NM Mixed -Use Sites to Rezone NNIN Vacant and Underutilized R2 Commercial Specific Plan Sites to Rezone ISM Downtown Downey SP Sites Residential Overlay Sites
RM Residential Overlay Zone
City of Downey 17

Determination
The City of Downey occupies approximately 12.8square miles of land and is located in the southeastern part of Los Angeles County, about 12 miles southeast of downtown Loy Angeles. The City is bounded by Telegraph Road on the north' GanUenda|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 F* Springs on the northeoot. Norwalk on the east, Bellflower and Paramount on the south, South Gate on the weat, and the City nfCommerce on the northwest. There is no unincorporated County land within the City and it has no Sphere of Influence outside of its municipal boundaries. Regional access 10and from Downey is provided by |-5onthe north, 1'105on the south, 1-005on the east and |-71Utothe west. IVITA Green Line light -rail train services are available at the Lakewood Boulevard station located next Vuthe |-1O5Freeway.

Southern California, including the City ofDowney, contains a number ofregional earthquake faults and has experienced moderate tosevere gmundohekinq in the pout. Underlying soils contain sand and silt and some oman have constraints for new buildings. Downey and the surrounding communities support developed urban uses and do not support listed or sensitive species ofplants 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 west, both of which are fully improved flood cnn1m| channels in this area.

G1nrmwotergenerally flows east and west toward the two adjacent rivers.

The Los Angeles Basin has been inhabited by European oeM|em for hundreds of years, by Nodiwa American tribes for many thousands of years, and large mammals and other animals long before humans occupied the area. Therefora, 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 o number ofmajor aderia| u1nmeta in the City including Telegraph Rood' Lakewood Bnu|evand, Bellflower Boulevard, Florence Avenue, Firestone Boulevard, and Imperial Highway.

The City Council must approve oGeneral Plan Amendment toincorporate the 2021-2029Housing Element Update into the General Plan.

Subsequent to and within three years of Housing Element ' 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 be subject to a new and separate CEQA review process, The State ofCalifornia, Department ofHousing and Community Development OHC0isrequired toreview the Housing Element for compliance with State law (Article 10.0 of the California Government Code) but does not have actual approval 18 2021-2029 Housing Element Update

Purpose and Authority

DETERMINATION

ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
Aesthetics
Agriculture Resources
Air Quality
Biological Resources
Cultural Resources
Geology /Soils
❑
Hazards & Hazardous Materials
❑',
Hydrology / Water Quality
Land Use I Planning
❑
Mineral Resources
Noise
Population I Housing
Public Services
Recreation
`,
Transportation/Traffic
p
Utilities I Service Systems
El
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.

E I fend that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
♦ that the proposed project chave"potentially iimpact"or "potentially f gateimpact on the environment, but at least one
ffect 1) has been adequately
nalyzed in an earlier document pursuant to applicable
■' `i. i. 1 i 1` .i1y '1 i mitigation +based on described on sheets, An ENVIRONMENTAL '+CT REPORT is required, but only be addressed.
f i,. i `. i
♦L. 1 . i. i i" .: i i*i ♦i i. 'i i .. 1 *. - '� i t �+ i i i ': i. i i i ' 1. • i ♦ iii "` i i i `: i i * i :` ♦'.

C al Latla n�11�
Date,
t'of Downey
City of Downey

1. AESTHETICS
Would the project:

A)
Have a substantial adverse effect on a scenic
Potentially
~
Significant
Impact
El
Less
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
B)
Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and
El
1:1
0 11
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
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
El
1:1
views in the area?
A) Less Than Significant Impact. The City itself is relatively 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 asdistant views of the Santa Monica Mountains hothe northwest and the Santa Ana Mountains tothe southeast (City 2O20. The 6onem| Plan E|RI referenced the urban setting of the Qh/ and concluded that all visual and aesthetic impacts would he less than significant and no mitigation was required (City 2OO5). Future development under the updated Housing Element will not substantially change the location, distribution, or omanu|| 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 or from elevated freeways. Impacts will be less than significant and no mitigation is required.

B) Less Than Significant Impact. Scenic resources are isolated, natural mmanmade objects offering eunique visual display to the onlooker, incontrast to the expanse and variety of aesthetic values offered inscenic vistas. All ofthe 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 ouhomppinga, and historic buildings within a State scenic highway.

According to the California Department of vebsite, none of the freeways in the vicinity ofthe City of Downey are designated as scenic oreligible to be designated as e scenic highway or mute (Caltronu 2020. The 2005 City General Plan does not indicate that any of the freeway or roadway segments within the City are designated as scenic roads or cnnidom, although it does indicate that 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 amore 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 besubject to review pursuant to[EQA. Considering that the General Plan BRanalyzed impacts 0oscenic 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 iorequired.

C) Less Than Significant Impact. Visual character is the composite physical values of a structure or structures, in contextof the built and/or natural environment, that include architectural treatment, landscaping, location, and the intangible qualities such as historical context or uniqueness that establish o thematic visual display for the onlooker when viewing the location.

Above most environmental iuoueo, defining visual character is gmn*nuUy uubjeoUva, relying on the opinion of the nn|nnkor coupled with the expertise and institutional knowledge of the |000| jurisdiction to define the visual character ofon 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 ofthe City. The wooham portion of the City contains two large recreational facilities, the Rio Hondo Golf Club, the Los Amigos Golf Course, while the southeastern portion of the Cdv' including the former Boeing plant site, supports a variety of retail commercial, light industrial, and medical -related uses. Smaller retail commercial uses are also distributed along major roadways such as Paramount. Downey, and Brookshire Avenues, and nopeoio||y at intersections on many of the smaller non-residential streets. The City contains little vacant land but many pom*|s 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 of incrementally changing the visual character ofeach Inventory Site. If the change inthe visual character nrquality ofenInventory Site, incontext of the existing visual character and quality of the surrounding envimnmont, can be perceived as 'degmding', then the effect of the project may nmuK in potentially significant impacts. Adverse changes to the visual character ofan area can reduce the qum|dv uflife 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.

There is no widely recognized threshold for determining when the effects of omeo 'degrade' visual character orquality ho the pointthatpotenUa|lyninifinantonvimnment8|impaotsnouNoccucHoweve[thncurrentCEQAUhrenholdif whether urnot a project (in an urbanized ema) would conflict with applicable zoning and other regulations governing scenic quality. Thuu, future development on the Inventory Sites will be subject to applicable General Plan Policies and zoning regulations related to height, mass and scale, architectural style, materials, landscaping, and a variety of other 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.

C8Less Than Significant Impact. Future development guided bvthe implementation of the proposed Housing Element Update will mxuK in new sources nflight and glare. Outdoor lighting will be required in parking lots and pedestrian pathways for security purposes and may be included as accent lighting in landscaping and architectural features. Indoor lighting will also likely be visible through windows. Lighting associated with vehicle travel to and from the Inventory Sites will also begenerated, Outdoor lighting when viewed a1night can result in glare that can be defined as "excessive, uncontrolled brightness" from o |uminaim. Glare can also occur during the day due bn light reflecting off building materials such as highly polished metal and reflective glass. Inappropriate installation oflight and reflective materials in future housing could result in effects on nighttime and daytime views through scattering excessive light in the viewers' eyes, causing a partial or complete inability to see due to light scattering in the eye. The effects of excessive light and glare can result in nuisance impacts ranging from viewer annoyance or an inability tosee features in the night sky, to health and safety impacts such as temporary blindness while operating amotor vehicle.

City 0fDowney 202/-2020 Housing Element Update 21

Environmental Impact Evaluation
The General Plan BR found that impacts related to light and glare will be less than significant with implementation of lighting requirements set fofth in the General Plan and zoning regulations. Future housing developed to meet local and regional housing needs will b*subject huthe City'u Municipal Code regulating the installation and operation of lighting. Implementation of the lighting requirements of the G*nonu| 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 Q|em. |mpoda to daytime and nighttime views will be less than significant with implementation of exiting regulatory requirements and nomitigation iorequired,
In determining whether impacts to eghouUuna| resources are significant emvimnnmnta| efects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (CALESA) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. |ndetermining whether impacts to forest mooumeo. including timberland, are significant environmental effects, lead og*noiam 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
Significant
��
Significant with
Less Than No Impact
Impact
Mitigation
Significant
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 El
El
E] 0
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
El
El
El Z
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 El
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?
AQ No Impact. According tothe "Important Farmland Finder" '
within the utate'o Famn|onU Mapping
and Monitoring Program
(FK4MP) wmboihn, the entire City is designated as "not mapped" meaning there is no land
considered Prime Fomn|unda'
22 2021-2029 Housing Element Update

Environmental Impact Evaluation
General Plan E|Rfound there would bonosignificant imoants related buthe loss ofimportant farmland bvfuture development within the City. The proposed Housing Element Update does not propose the re -zoning or re -designation of any Inventory Gi1*o to agricultural use* or zones as analyzed in the General Plan BR. In addition, the Housing Bement dnou not propose any specific development that will result in the conversion of farmland to non-agricultural use. Future development consistent with the proposed Housing Element will be subject to General Plan Policies related to the orderly development of undeveloped 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 BR. There will be no impacts related hxthe conversion of important farmland and nnmitigation isrequired.

B) No Impact. According to the California Department ofConservation, Williamson Act reports and ataUnUco. 8lem are no Williamson Act Lend Conservation Contract lands within the City including any Inventory Sdau or surrounding emeu (OOC 2020b). The lands within the City are classified as Non -Enrolled Land or Urban and Built -Up Land. Therefore, the General Plan BRfound there would be no impacts related 1nthe loss of land under Williamson Act contract. The proposed Housing Element does not propose the re -zoning or re -designation of any Inventory Sites to agricultural uses or zones as analyzed in the General Plan BR. Future development consistent with the proposed Housing Element will be subject to General Plan Policies related to the orderly development of undeveloped properties and will be uuN*c1 to City review and approval.

Therefore, implementation of the proposed Housing Element will not naou|t in inomoy*d impacts as analyzed in the General Plan EIR. There will be no impacts related to the loss of land under Williamson Act contract and no mitigation is required.

C^D)Nn Impact. Public Resources Code Section 12220(g) identifies forest land as 'land that can support 10 percent native tree cover ofany opooi*o, including hardwoods, under natural oonditiona, and that allows for management ofone or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits.' There is noforest land located within the City including any proposed Inventory Sites. The General Plan BR indicated the City 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. 2] No Impact. As discussed above. Ohom is nodesignated farmland or forest land within the City including any Inventory Sites. Therefore, the proposed Housing Bement will not nmuK in the indirect conversion of any agricultural or forest land to non-agricultural or non -forest uses. There will be no impact and no mitigation is required.

City of Downey 2021-2029 Housing Element Update 23

Environmental Impact Evaluation
VVhom available, the significance criteria established by the applicable air quality management n,air pollution control district may berelied upon homake the following determinations.

Would the project:

Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
A) Conflict with or obstruct implementation of the
E]
0 El
applicable air quality plan?
13) Result in a cumulatively considerable net increase
of any criteria pollutant for which the Project
El
0 region is non-aftainment under an applicable
federal or state ambient air quality standard?
C) Expose sensitive receptors to substantial pollutant
El
El
Z
El
concentrations?
D) Create objectionable odors affecting a substantial
El
number of people?
The U.8.EPA and CARB are the federal and State agencies charged with maintaining air quality in the nation and California. respectively. The U.S. EPA delegates much of its authority over air quality \o 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.

The City of Downey is located in the South Coast Air Basin (Basin) which includes Orange County and the non-clesert portions of Los Angeles, San Bernardino, and Riverside counties. The basin encompasses approximately 0.745 square miles of coastal plains and in bounded by the San Gabriel, Gen Bernardino, and San Jacinto Mountains tothe north and east. Air quality in the Basin is managed by the South Coast Air Quality Management District (SCAQMD). Pursuant to the California Clean Air Act, GCADMDioresponsible for bringing air quality within the basin into conformity with federal and State air quality standards by reducing existing emission |evo|u and ensuring that future emission |ove|o meet applicable air quality standards.

SCAQMD works with federal, State, and local agencies to reduce pollutant emissions through adoption and implementation of rules and regulations.

The U.S. EPA has established National Ambient Air Quality Standards (NAAQD) for six common air pollutants: ozone (06. particulate matter (PM), which consists of "inhalable coarse" PM (particles with an aerodynamic diameter between 2.5 and 10 microns in diameter, or PM,o) and "fine" PM (particles with an aerodynamic diameter smaller than 2.5 microns, or PM2.5), CO, nitrogen dioxide (NO2). sulfur dioxide (SO2), and lead. The U.S. EPA refers 0othese six common pollutants as ^ohheha" pollutants because the agency regulates the pollutants on the basis of human health and/or environmentally -based ohkeho and because they are known bocause adverse human health effects and/or adverse effects onthe environment (U8EPA 2020a and 2020N. CARB has also established California Ambient Air QuoUh/ Standards (CAAJ]S) for the six criteria air pollutants regulated bythe federal Clean Air Act (the CAAQSare more stringent than the NAAQS\.

A0 Less Than Significant Impact. Future development under the General P|en, and updated Housing Element, will have to demonstrate compliance with the current SCAQMD regional and local significance thresholds and prepare site -specific studies of criteria air pollutants. Pursuant to the methodology provided in Chapter 12 of the 8CAQMD CEQA Air Quality Handbook (SCAQMD 1993), this analysis will include compliance with the Air Quality Management Plan (AQMP) if a project:iuoonaistent with the growth assumptions in the AQMP (Chb*hon 1) and does not increase the frequency or severity of an air quality standards violation or cause a new one (Criterion 2). The 2005 General Plan E|R determined that air quality impacts of the 24 2021-2029 Housing Bement Update

Environmental Impact Evaluation
General Plan would Uesignificant and unavoidable because ofthe number ofnew residential units that would bebuilt inthe future as well as the amount of new non-residential development anticipated. The Findings of Fact for certification of the General Plan BR included u Statement of Overriding Considerations for several significant and unavoidable impacts, including air quality, even with implementation of the General Plan goals and policies as the recommended mitigation. These goals and policies include actions that future development would have to implement to reduce potential air pollutant emissions to below the daily significance thresholds established by the SCAQMD, Subsequent to this Housing Element update, the City will be undertaking focused General Plan and zoning ordinance amendments to ensure sufficient land use capacity is available to accommodate the RHNA. This |niU@| Study examines the potential environmental impacts uda program level for only the Housing Element since the Housing Bement itself does not specifically authorize the construction of any housing development, nor does it indicate where and when specific housing projects will occur. Therefon*, programmatic impacts from implementation of the proposed Housing Element related toAQMP consistency will be less than significant and no mitigation is required.

GBLess Than Significant Impact. The effects nffuture housing development on regional air quality could result in potentially significant impacts on the health of residents if it is determined that a project's individual contribution to cumulative air pollution |evo|o is considerable by exceeding the annual emissions thresholds established by the SCAQMD in its CECAAir 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 1.6.111: The City shall monitor, review and comment on regional plans, as they relate to the City's General Plan Program 1.6././:The City shall comply with and incorporate the applicable requirements ofthe Air Quality and Congestion Management Plan.

Program 1.6.1.2: The City shall examine and promote land uses that encourage telecommuting, thus reducing VMT (vehicle miles traveled) aorequired bythe air quality plan.

Policy 2.3.1:The City shall encourage the use ufpublic transit.

Program 2.3.1.8: Encourage Downey businesses to provide employee information to public transit authorities to assist in their planning for public transit services.

Policy 2.3.2: The City shall encourage efforts to reduce the number and length ofvehicle trips generated by land uses in Downey.

Program 2.8.2.1: Promote the development nfpark and ride facilities.

Program 2.3.2.2:Promote hdeuhahngthrough provision ufinformation hothe public.

Program 2.3.2.3: Promote transit -oriented developments.

Program ��2.4:Promote on -site child-care facilities mtmajor emplovmendmenters.

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,otaggenedmmrkinghoum,andntherm8ans.

Policy 2.6.1: The City shall encourage bicycling as an attractive alternative to vehicular transportation.

Program 2.5././: Encourage the use of bicycling as e form of transportation for employment commuting and business puqpoueu, in addition torecreational purposes.

Program 2.3.12Establish abikeway master plan 0olink employment centers, recreational facilities, and bikeways along the Rio Hondo River, the San Gabriel River, Union Pacific Railroad Line, and those ofneighboring communities via o network of bike routes, lanes, and paths.

Program 2.6.1.3: Encourage the provision of bicycle racks at nat8i| 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 2.0.1.0:Promote site development design that iosafe and convenient lobicyclists.

Policy 2.8.2:The City shall encourage walking as an attractive alternative to vehicular transportation.

Program 2.6.2.1: Promote site development design that is safe and convenient to pedestrians.

City of Downey 2021-2029 Housing Element Update 25

Environmental Impact Evaluation
The General Plan BRconcluded that growth within the City, consistent with the General Plan, would have significant and cumulatively considerable air quality impacts due to the amount of new housing and non-residential growth, A Statement of Overriding Considerations was prepared for this significant impact which was outweighed by the community and environmental benefits of having o Gonane| Plan that provided housing for 8 wide range of the market and provided o wide range 0femployment for its citizens and the region as a whole. Subsequent to this Housing Bement update, the City will be undertaking focused General Plan and zoning ordinance amendments with separate CEQAcompliance hnensure sufficient land use capacity io available toaccommodate the RHNA. This Initial Study examines the potential environmental impacts ato pmQnom |*wo| 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 proposed HEU is consistent with the findings of the General Plan EIR, will not create a new or significantly increased impact, and will not require additional mitigation at this programmatic level.

Future housing developed in accordance with the goals and policies of the Housing Element will have the effectof contributing incrementally to the mobile, energy, and area sources that cumulatively contribute to criteria pollutant levels and associated air pollution in the Basin, The SCAQMD is responsible for preparing the Air Quality Management Plan (AQMP) for the Basin (SCAQMD 2016). The AQMP includes strategies and control measures to reduce and/or maintain the effects that construction and operation of various uaou within the Basin have on regional air quality. The effects of future housing development on regional air quality could result in potentially significant impacts on the health of residents if it is determined that a project's individual contribution to cumulative air pollution levels is considerable by exceeding the annual emissions 1hmmhn|da established by the SCAQMD in its CEQA Air Quality Analysis Handbook (8CAQMD 1993) and, fuhhennnm, would be determined to potentially conflict with implementation of the AQMP. Criteria pollutants can directly damage the environment, both natural and man-made. Impacts to human health include a variety of acute and chronic respiratory i||nnuomo.

Development offuture housing will be subject to environmental evaluation for exemption and potential analysis pursuant to CEOA upon application for entitlement permits. Projects found to be exempt from CEQAwi|| not have a significant impact on the environment audeclared bystate legislation. Other projects will besubject bostandard analysis and mitigation ifrequired.

The General Plan BRconcluded that build out ufthe General Plan will beinconsistent with the air district's air quality management plans and will result in substantial increases in criteria pollutant emissions within the air basin. The pmpnu*U Housing Element does not propose any land use changes or designate any Inventory Sites that were not already analyzed in the General Plan BR. Therefore, long tonn air quality impacts in the Qb/ have already been contemplated, and the proposed Housing Element will not result in impacts that are greater than those contemplated in the General Plan EIR. In addition, future development nfthe proposed Inventory Sites will besubject hothe Goals and Policies ufthe General Plan and will hosubject to environmental evaluation for exemption and potential analysis pursuant to CEQA. Impacts related to implementation of the proposed Housing Element will be less than significant and no mitigation is required. .

C\ Less Than Significant Impact. Common sensitive receptors include children under age 14, the elderly over age 85. e1Netea, and people with cardiovascular and chronic respiratory diseases. Each of the residential Inventory Sites is surrounded by residential uo*a and the mixed -use Inventory Sites are surrounded by residential, onmmemim|. and limited industrial uses. Future housing projects are not considered uses that emit substantial levels ofhazardous air pollutants that could have an effect on the environment such that potentially significant impacts will occur.

In addition, industrial pm000meo with state or federal Vmio emissions must prepare health risk assessments, minimizing impacts to surrounding uses. With implementation of existing regulatory requirements (or mitigation if required), impacts to sensitive receptors will be |eeo than significant and no separate programmatic mitigation for this Housing Element Update is required.

D) Less Than Significant Impact. Residential land uses du not generate objectionable odors that could impact a substantial number of people, therefore, future housing development will not result in effects related to odors that could impact a substantial number ufpeople. Then* are no sources of- objectionable odors located in the vicinity of any Inventory Site identified inthe proposed Housing Element. Audiscussed inthe General Plan E|R.future industrial uses could Uesources of odors that affect sensitive land uses such as nooidenUe| onaeo. Implementation of the General Plan will ensure that 20 2021-2029Housing Element Update

Environmental Impact Evaluation
WFIJOiTF MMUMORMOMMUMP - the Housing Element Update will be less than significant and no mitigation is required, City of Downey 2021-2029 Housing Element Update 27

Environmental Impact Evaluation
4 BIOLOGICAL RESOURCES
Would the project:

Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
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
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?
13)
Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies,
regulations, or by the California Department of
Fish and Game or US Fish and Wildlife Service?
C)
Have a substantial adverse effect on federally
protected wetlands as defined by Section 404 of
the Clean Water Act (including, but not limited to,
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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
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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
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preservation policy or ordinance?
F)
Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community
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11 Conservation Plan, or other approved local,
regional, or state habitat conservation plan?
AU Less Than Significant Impact. According to the General Plan E|R. 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 nfdrainage/flood control channels, they contain ||M|e or no riparian (otmemuide) or wetland resources subject 1othe jurisdiction of various federal or state mg*noinm (U.S. Fish and Wildlife Service, U.G. Amoy 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. Due to the level of disturbance within the City, no sensitive plant species are expected to be encountered, and vegetation is primarily mdere| (weedy).Wildlife expected within the City would be non -sensitive wildlife that generally inhabit disturbed urban areas (such as racoons, squirrels, cuvnteu' rats, common bind species, etc.). All listed or otherwise sensitive species have low or no potential to occur within the City due to the marginal suitable habitat available or lack of habitat (City 2020). In addition, the General 28 �202/-2029 Housing
-Element Update

Environmental Impact Evaluation
Plan requires that biological studies be prepared when necessary to assess habitat value, implementation ofmitigation, and coordination with agencies and individuals with expertise in biological resources.

Subsequent to and within Ulnm years of Housing Element adoption, the City will amend the General Plan and zoning ordinance/map k}provide sufficient capacity toaccommodate the RHNAallocation. This subsequent General Plan and zoning ordinance amendment pmcouS will be subject to 8 new and separate CEQA review process. The Housing Bement itself does not specifically authorize the construction of any housing deve|npmeni, nor does it indicate where and when specific housing projects will occur; thus, programmatic impacts associated with potential development of the Inventory Sites will remain within the scope of analysis certified in the General Plan E|R. Future development of the Inventory Sites will be subject to project - specific environmental review pursuant CEQA' as applicable. Considering that the General Plan E|R ene|yoad impacts to sensitive species and impacts were found to be less than significant with mitigation incorporated, and that the proposed Housing Element inand ofitself will not result inincreased impacts than previously contemplated inthe General Plan E|R'its programmatic impacts will be less than significant and no mitigation in required, B-C)Less than Significant Impact. According to the General PlanBR and the National Wetlands Inventory, there are no riparian or wetland resources within the City of Downey (City 2005)(City 2020). The General Plan BR determined that implementation of General Plan Policies will prevent any potential impacts resulting from the direct and indirect effects of future development within the City to less than significant levels. As outlined in Threshold 4.A above, the proposed Housing Element Update will require rezoning that will occur within three years of Housing Element adoption to accommodate the RHNA allocation. The Housing Element itself does not propose specific development on specific site so at this programmatic level its impacts associated with the Inventory Sites will remain within the scope of analysis certified in the General Plan EIR.

Incorporation of the General Plan Policies discussed above will ensure that impacts to riparian and wetland resources resulting from future development of housing will be less than significant and no mitigation measures are required, [U Less than Significant Impact. The General Plan BR concluded the City did not contain any regional wildlife movement corridors and that impacts 0mwildlife movement will be less than significant with implementation of General Plan Policies.

Wildlife corridors and the movement of animals are important in maintaining genetic diversity, accommodating mating patterns, and ensuring that seasonal behavior is not interrupted. Future development of Inventory Sites will not naau|t in significant impacts to any creeks, rivers, or other water bodies with incorporation of General Plan Policies, thus, creeks, rivers, and the like will remain open as wildlife corridors. Impacts will be |eua than significant and no mitigation mnoVunau one required.

E) No Impact. According to the General PlanBR, the City of Downey has not adopted local ordinances or regulations pertaining hobiological resources, therefore, implementation nfthe proposed Housing Element will not conflict with any locally adopted ordinance or regulation. No impact will result and no mitigation is required.

F\ No Impact. There are no established Natural Community C0000meUmn Plans (NCCPa) or Habitat Conservation Plans (HCPs) within or adjacent to the City of Downey. Therefore, implementation of the proposed Housing Element will not conflict with any NCCPorHCP.Noimpact will occur and nomitigation iurequired, City of Downey 202/-2029 Housing Element Update 29

Environmental ImoactEvaluation
Would the project:

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
B) Cause a substantial adverse change in the
significance of an archaeological resource
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0 0
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pursuant to Section 15064.5?
C) Disturb any human remains, including those
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1:1 0
n
interred outside of formal cemeteries?
A) Less Than Significant Impact. During the early Spanish era ofCalifornia, the site of Downey was originally part of the 30O'OUUfmmManual NietoLand Grant. |n1834,the Nieto heirs split upthis grant and the portion between the banks ofthe Rio Hondo and Gen Gahh*| River became Rancho Santa 6mrtmdeo. Sometime near the end of the Civil VYor. an |hnh immigrant, John G. Downey, purchased 17.UOOacres ofland then known eothe Los NietoaVa||ey. Situated between the San Gabriel and Rio Hondo Rivers, the land where Downey now sits has always been very fertile.

The settlement of Downey was established in 1873 and it remained an oghouUum| area until the end of the Second VVndd War. The arrival of the Southern Pacific Railroad in the mid-1870s gradually accelerated the development, However, Downey remained largely rural with citrus orchards, dairy farms, ranches, dirt roads, and small homes well into the 20th Century.

Though Downey was settled in 1873' it did not become an official incorporated odv until 1950. Thenih/u population more than tripled between 1940 and 1880with the rapid growth of the aerospace industry during VVndd VVer || then the Cold War.

Aviation pioneer Jerry Vu|boebought the old Downey airstrip in1938and started mnairplane production plant. Vu|baewas one of the nation's largest producers of military aircraft and later became North American Aviation, then North American Rockwell which was eventually bought by Boeing. During the 1950o' the Downey site trnneitionnd from aircraft to missile technology with over 25.00Oemployees eventually working onthe Apollo Space Program.

With the end of the Cold War in1991.the Boeing plant downuizedand its large aircraft hangars became the Downey (mcvie) Studios but was eventually demolished in 2012. An organization called "The Aerospace Legacy Foundation" ebU exists in Downey and has helped preserve the aerospace history of the City. According to the Foundation, many writers and historians refer to the city as the "Cradle of the Cosmic Age." The former Boeing site was so large it has supported several new private developments and public facilities, including the KainerPermanenh* Hospital, the Downey Landing Shopping Cump|ox, a new pork, and the Columbia Memorial Space Center, an interactive museum unthe aerospace industry.

Located in the southwestern portion of the City, Apollo Park iuhome tothe Downey Historical Society. Apollo Park was once called Imperial Park but the name was changed h>commemorate role inthe Apollo Space Program. Near the park is the Rancho Los Amigos National Rehabilitation Center which is one of the largest rehabilitation hospitals in the country and has been operating for over 125years.

According to the historical society, Downey was once called "Little Beverly Hills" because dhas many mansions that resemble 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 137U'o.
30 202/-2029 Housing Element Update

Environmental Impact Evaluation
The City was once home to a number of facilities demonstrating ^Gougie" architecture which was a type of futurist architecture influenced bycar culture, jets, the Space Age, and the Atomic Age that was popular during the late 1940sinto the mid4960o. The former Jnhnie'o Broiler on Firestone is now o Bob's Big Buy, and the oldest standing McDnna|d'u a\iU in operation was built atthe corner nfLakewood and Florence in1S53.The first Taco Bell was also built onFirestone Boulevard close 1nJnhnie'oBroiler but iunulonger inoperation.

Summary. No buildings remain from the former Boeing Plant, and few of the 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 Hiehurioe| Society located in Apollo Park.

Because hiohnho properties are not located on any of the identified Inventory 8iVau, implementation of the proposed Housing Element Update will not cause substantial adverse change in significance ufa hiuhuhoo| resource. Impacts will be less than significant, and numitigation isrequired.

BU Less Than Significant Impact. The Tnngveare enIndigenous people of California from the Los Angeles Basin and the Southern Channel |u|ando, an area covering approximately 4'OODsquare miles. In the precolonial *ra. the people lived in as many as 100 villages and primarily identified bvtheir village name rather than by e pan -tribal name. During colonization, the ponp|* were referred to as Gabrie|*hnand Femandoho. names derived from the Spanish missions built on their land ' Mission Son Gabriel Ancbngo|and Mission Gan Fernando Roy U* Espoha.The name Tbngvaia widely used but others choose toidentify aaKizh.

Before the arrival of Spanish settlers in the 1700s, the area that would later become Downey consisted of Tongva People that inhabited a village na||*d G 'adnga near the current City of Whittier and the San Gabriel River. By 1806. the TonAva were providing conscripted labor for Spanish missions. The area was part of the early Spanish rancho of Jose Manuel Nietn' the holder of the 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) menumeu in the City. /t 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 GabheAno Village." The exact |noe8nn of this archaeological site is vague and there are three possible locations for the site, none of which are within the City of Downey.

Similar to potential impacts on historical resources, impacts to archaeological resources from future housing development can result in the loss of information 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 resources at Inventory Site locations during construction eoUvibeu is unknown given that no such resources have been diuoowonmd end/or recorded previously, The General Plan states that archaeological and historical resources shall be protected and preserved to the maximum extent In eUU0nn' two changes tostate law (GB 18end AB 52) require cities hoconsult directly with Nuo| Native American tribes to determine ifany tribal cultural reouum*o 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 nenoum*o as required by the General 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 in less than significant impacts related tothe substantial adverse change in the significance of archaeological resources. Subsequent tnthis 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 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 projectswi||ncour.Thorefone. long-term impacts in the City have already been contemplated and the proposed Housing Element Update will not result in City of Downey 202/-2020 Housing Element Update 31

Environmental Impact Evaluation
impacts that are greater than those identified in the General Plan BR. In adU0on, future development of the proposed Inventory Sites will besubject hothe Goals and Policies ofthe General Plan and will besubject huenvironmental evaluation for exemption and potential analysis pursuant to CEOA. Therefore, programmatic impacts related to implementation of the proposed Housing Element will be less than significant and no mitigation is required.

C1Less Than Significant Impact. According to the General PlanBR, this region has been occupied by Native American tribes for thousands of years, Future development of the proposed Inventory Sites that require site preparation and eorthmuving activities have the unlikely potential to uncover buried o, uurficia| human remains outside of e recognized cemetery or other burial location, Construction activities that result in disturbing or destroyinghumenmmainnonu|Umau|tin impacts to our knowledge of the burial pmdin*a of the people who were buheU. the people who buried the e+mainu, and the pre -historic or historic context and circumstances under which the buried became deceased. Should human remains be discovered, the contractor io required tocomply with State Health and Safety Code 87050.5. This requires halting work in the immediate area of the find and notifying the County Coroner, who must then determine whether the remains are of forensic interest. If the Coroner, with the aid of a supervising archaeologist, determines that the remains are nrappear hobeofNative American origin, the Coroner is required to contact the Native American Heritage Commission for further investigations and proper recovery of such remains, if necessary. Implementation of existing regulations will ensure that any discovered remains are appropriately collected and examined for any significant information that can be elicited. Potential impacts due tueffects on human remains will be |eao than significant with implementation of existing naAu|eUone and no mitigation is required, 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
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1:1
E]
consumption of energy resources, during project
construction or operation?
B) Conflict with or obstruct a state or local plan for
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11 renewable energy or energy efficiency?
A)Less Than Significant Impact. Energy is primarily categorized into three areas: electricity, natural gas, and fuels used for transportation. According to the U.S. Energy Information Administration (U8EIA). California is the most populous state in the United States, representing 12 percent of the total national population, has the largest economy, and iusecond only hoTexas intotal energy consumption. However, California has one ofthe lowest per capita energy consumption levels inthe U.G.This is a result of California's mild climate, extensive efforts to increase energy efficiency, and implementation of alternative technologies. California leads the nation in electricity generation from solar, geothermal, and biomass resources (UGE|A 2018).

Electricity. |n2D18,almost half ofCalifornia's net electricity generation was from renewable resources, including hydropower (U.8.BA.2O10. |n2O18the California electric system used 281.12OGYVhof electricity, nearly 7196ofwhich (199.585GVVh) was produced in -state (CEC 2019a). Southern California Edison (SCE) is the oU|dv provider in Downey. In the 2018fisoa| year, GCE sold approximately 87,143 million kilowatt hours (kWh) of electricity (SCE 2019a); approximately 40% of the electricity that SCE delivered hucustomers came from carbon -free resources, including solar energy (approximately 13%), wind energy (approximately 13%), and geothermal energy (approximately 8%) (SCE 2019b), 32 2021-2029 Housing Element Update

Environmental Impact Evaluation
Natural Gam California accounts for less than 1% of total U.G. natural gas reserves and production; however, almost two- thirds of California households use natural gas for home heating (U.S. EIA 2019). In 2018, California consumed abou12.638 million 1hemnu3 of natural gas. Approximately 3596 of natural gas was consumed by the residential sector which makes up approximately two-thirds of county -wide consumption (CEC 2018U). The Southern California Gam Company (GoCa|Gaa) provides natural gas service to the City. SoCalGas is the principal distributor of natural gas in Southern California and provides natural gas for residential, commercial, and industrial markets.

Transportation. transportation sector consumed 80.0million Btu of energy per capita in 2017, which ranked 31 st inthe nation 0.G.EiA207l. Most gasoline and diesel fuel sold in California for motor vehicles is refined inCalifornia tumeet state -specific formulations required by the California Air Resources Board.

Housing Element Update. Future housing developed in aonnndenno with the goals and policies of the HEU will have the effect of contributing to increased energy consumption in the City which will be part nfregional growth in energy use and the surrounding communities continue to grow as well. Future growth in the City will be required to beconsistent with 1heutate'e 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's Energy Action Plan (City 2015) which mainly address air quality and greenhouse goo emissions but which also have guidelines for energy conservation on new development. As long as future development adheres hothese multiple energy conservation plans and requirements, the Housing Bement Update will have less than significant impacts relative to energy consumption and efficiency and no mitigation is required. Therefore, the proposed HEUwould not use energy ina wasteful, inefficiency, Vrunnecessary manner.

B) Less Than Significant Impact. The analysis in Section 6.babove 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 2U15).

Equipment and vehicles associated with construction and operation of new development *muN 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 atate'o Sustainable Freight P|an, such as the turnover of older, |eoo fuo|'effioiontbnoka, aofuel economy standards are rolled out and zero emission vehicles /ZEVl1muku and mahiu|eo 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 o more focused level since these actions could increase the level of development allowed atspecific sites.

Subsequent to this Housing Element update, the City will be undertaking focused General Plan and zoning ordinance amendments with separate CEQAcompliance bo ensure sufficient land use capacity in 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 development, nor does it indicate where and when specific housing projects will occur. Future development of any individual Inventory Site will be subject to project - specific review pursuant toCEOA.Therefore, the Project wmu|dnotconflictvvithnorobutructoo1ateor|oco|p|onfor renewable energy orenergy efficiency. Programmatic impacts ofthe HEUwould beless than significant and nnmitigation io required.

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?
E]
El
E]
iii) Seismic -related ground failure, including
El
El
liquefaction?
iv) Landslides?
0 El
Z
B)
Result in substantial soil erosion or the loss of
El
1:1
M
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
11 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),
Z
El
creating substantial risks to life or property?
E)
Have soils incapable of adequately supporting the
use of septic tanks or alternative wastewater
EJ
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
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0 geologic feature?
A] Less Than Significant Impact (Fault Rupture\Major active fault zones are located southwest and northeast ufthe City.

Based on current mapping available from the California Geological Survey (CGS), there are no known Alouiat-Phnlo Earthquake Fault Zones within the City limits. However, a number of faults are located in the vicinity ofthe City, including the Newport -Inglewood Fault, the Compton -Los Alamitos Fault, the Whittier -Elsinore Fault, the Elysian Park thrust system, the Palos Verdes Hills Fault, and the San Andreas Fault. The two regional faults with the greatest potential to impact the City of Downey are the Newport -Inglewood Fault and the Cnmpton'LuoA|amihna Fault, located approximately six and ten miles southwest of the City, respectively. The Newport -Inglewood Fault is capable of a maximum credible magnitude of 7.10 and the 34 2021-2029 Housing Element Update

Environmental Impact Evaluation
Compton -Los Alamitos Fault is capable of maximum credible magnitude of7.2O (Downey 2OU4). Although there are active and potentially active faults located close to Downey.

All new housing would be subject to state seismic safety requirements of the California Building Code as adopted by the City.

In eUdition, new development in required to prepare e geo1echniva| 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 beless than significant and no mitigation is required.

A.ii) Less Than Significant Impact (Gnwundshak|n0). Seismicity is m well-known hazard of Southern California. The San Andreas Fault nepnaoen1a the boundary between two tectonic plates, the northwest -moving Pacific plate and southeast - trending North American plate. Movement along this boundary has resulted in many earthquakes from the neginn's numerous faults (CGS 2020a). According to the current California Building Code, the City of Downey is within Seismic Zone 4 (CBC 2019)which indicates moderate hosevere gmundmhaking is possible.

New housing that would be built under the HEU would still be within the growth limits identified in the 2005 General Plan and evaluated in its E|R. Now housing would be subject to state seismic safety requirements of the California Building Code an adopted by the Qty. In addition, new development is required to prepare a geoteohnioa| hnzen1a assessment to identify site specific design and construction guidelines to protect occupants and structures from anticipated seismic impacts. Therefore, impacts related toseismic gmundohakingwould be less than significant and no mitigation is required.

J\Ji|) Less Than Significant Impact (Liquefaction). Liquefaction occurs when water -saturated sediment temporarily loses strength and acts as a fluid. Liquefaction -induced ground failure historically has been a major cause of earthquake damage in Southern California. Liquefaction potential and severity depends on oowenu| factors, including ani| and slope conditions, proximity to fault, earthquake mognitude, and type of earthquake, According to the UGGS Seismic Hazard Zones Maps, South Gate and Whittier Quadrangles, the entire City ofDowney |ioa within o liquefaction zone (U8G82O20). This conclusion is supported bysimilar mapping from the California Geological Survey (CGG)which indicates the entire City ofDowney is within an identified liquefaction hazard zone due to the local potential for strong gmundshaking' prevalence ofsandy soils, and often shallow groundwater levels (CGS 2O2Ob).

New housing would be subject to state seismic safety requirements of the California Building Code as adopted by the City. In addition, new development is required to prepare e geutoohnioo| hazards assessment to identify site specific design and construction guidelines to protect occupants and structures from anticipated seismic impacts, including liquefaction. Therefore, impacts related to seismic groundshaking would be less than significant and no mitigation is required.

A.iv) No Impact (Landslides). The City isunderlain bvdeep alluvial soils consisting ofgravel, sand, silt, and clay derived mainly from runoff out of the San Gabriel Mountains to the north. No areas in the City are prone to landslides due to the lack of steep natural o|upoe (i.e., foothills ormountains) where fractured and steep slopes. Therefore, there would be no impact related hulandslides and nomitigation iorequired.
13) Less Than Significant Impact. Natural forces, both chemical and physical, are continually at work breaking down and moving moku' minerals, and moils. Erosion poses environmental hazards through the effect of removing moils that can undermine roads and buildings and destabilize slopes. Erosion can also result in environmental damage by depositing soils in downstream nseonmim, |akom' and drainage structures that can n*au|t in impacts h)wildlife and human health by changing the onu|og|ne| properties or the physical boundaries of the water body or drainage control device, The City of Downey General Plan E|R concluded that impacts will be |oou than significant with implementation of the General Plan and Municipal Code related to grading limitations,
Future developments on proposed Inventory Sites are subject to Federal and State regulations limiting erosion pursuant to NPDESrequirements, and SCAQMDrules. Therefore, impacts will baless than significant undnomitigoU0niorequired.

C) Less Than Significant Impact. The City is underlain by deep alluvial soils consisting of gravel, sand, silt, and clay derived mainly from runoff out of the San Gabriel Mountains to the north. The City of Downey, similar to the entire Los Angeles Basin, City of Downey 2021-2029 Housing Element Update 35

Environmental Impact Evaluation
I' FIVII-W M7rMM'fn'TA'ff17MTff IF
evaluated in its EIR. New housing would be subject to state seismic safety requirements of the California Building Code as adopted by the City. 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, including liquefaction, lateral spreading, landslides, subsidence, or collapse. Therefore, impacts related to unstable geology or soils would be less than significant and no mitigation is required.

D) Less Than Significant Impact. Expansive soils are those that greatly increase in volume when they absorb water and ...........

KIM, r:roMR*T�Mi
the General Plan requires the preparation of preliminary soil, geotechnical, or seismic reports. Therefore, impacts due to geological and soils hazards will be less than significant and no mitigation is required.

E) Less 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.
36 2021-2029 Housing Element Update

Environmental Impact Evaluation
Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
A) Generate greenhouse gas emissions, either
directly or indirectly, that may have a significant
impact on the environment?
13) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing the
El
E
El
emissions of greenhouse gases?
/W Less than Significant Impact. Climate change is the distinct change in measures of climate for a long time period.

Climate change is the result of numerous, cumulative sources of greenhouse gas emissions all over the world. Natural changes in climate can be caused by indirect processes such as changes in the Eorth'u orbit around the Gun or direct changes within the climate system itself (i.e., changes in ocean circulation). Human activities can affect the atmosphere through emissions of greenhouse gases (GHG) and changes to the planet's surface. Human activities that produce GHGs 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 effectis natural occurrence that helps regulate the temperature of the planet. The majority of radiation from the sun hits the Earth'o surface and warms it, The surface in turn radiates heat back towards the atmosphere, known as 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 process is eauonUu| to supporting life on Earth because it warms the planet by approximately OU" Fahrenheit. Emissions from human activities since the beginning of the industrial revolution (approximately 250 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 Eadh'utempenetune. Greenhouse gases occur naturally and from human activities. Greenhouse gases produced by human activities include carbon diuxide(COu). methane(CH^), nitrous oxide (NuO), hydroNuomuarbons/HFCo\. perDuomoarbono (PFCe), and sulfur hexaOuohde (SF6). Since 1750' it is estimated that the concentrations of carbon diox|de, methane, and nitrous oxide in the atmosphere have increased over3O percent, 148 percent. and 18 percent, noopecUwo|y, primarily due bn human activity. Emissions of greenhouse Quaoo 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 GHG impacts as that environmental issue was not considered in CEOAdocuments at that time. The General Plan BRwhich concluded overall development would have significant air quality impacts and a Statement of Overriding 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 CEQAcompliance tuensure sufficient land use capacity is available to accommodate the RHNA. This |niUm| 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 d*v*|opmont, nor does it indicate where and when specific housing projects will occur.

Future development will emit greenhouse gases from various sources depending on type of use and size of the project. All projects will borequired buestimate their GHGemissions and comply with the City'nEnergy AubonPlamomeppmphate,which also helps reduce GH8 emissions. Therefore, impacts will be |eoy than significant okthis program level and no programmatic 2 United States Environmental Protection Agency, Frequently Asked Questions About Global Warming and Climate Change, Back mBasics. April 2009.

City of Downey 202/-2029 Housing Element Update 37

Environmental
mitigation is needed. However, dislikely that future projects, especially larger ones, will require for their estimated GHGemissions.
ra
�EQA. The �AP states the following...
"California
Future housing will beconstructed on undeveloped and currently developed, underutilized properties. 6HGemissions will be evaluated during the Chvo standard environmental review process as required by CEOA, relying on the City of Downey Energy Action Plan, and using the BPS method promulgated by the GCAQMD. Applicable measures will be incorporated into future projects, enuuringGHG emissions are reduced to levels that will not be considered cumulatively considerable in the context ofglobal climate change and resulting impacts. Some projects maybemquinadtoidentifvaGHGemiueionoinventnry using regulatory and industry standard methodologies and measures, Incorporation of appropriate BPS will ensure compliance with the nogiOnm| CCAP and by extension the targets identified in the state Sooping Plan for reduction of 6HQ emissions.

Future development will also be required to comply with the City's Energy Action Plan which also helps reduce GHG emissions. Thorefonm, impacts will be less than significant atthis program level and no programmatic mitigation is needed.

However, itiulikely that future projects, eapeci8Uy|ergeroneu,wiUmquinaproject-specificmitiQaUonfortheirootimutedGHG emissions.
30 202/-2020 Housing Element Update

Environmental Impact Evaluation

9. HAZARDS AND HAZARDOUS MATERIALS
Would
the project:

Potentially
Less Than
Less Than
No
Significant
Significant with
Significant
Impact
Impact
Mitigation
Impact
Incorporated
A)
Create a significant hazard to the public or the I
environment through the routine transport, use, or
E]
El
disposal of hazardous materials?
B)
Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
El
El
0 1:1
release of hazardous materials into the
C)
Emit hazardous emissions or handle hazardous
or acutely hazardous materials, substances, or
waste within one -quarter mile of an existing or
proposed school?
D)
Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a
result, would it create a significant hazardto the I
public or the environment?
E)
For a project located within an airport land use
plan or, where such a plan has not been adopted,
within two miles of a public airport or public use
airport, would the project result in a safety hazard
or excessive noise for people residing or working
in the project area?
F)
Impair implementation of or physically interfere
with an adopted emergency response plan or
emergency evacuation plan?
G)
Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or
death involving wildland fires?
A-D)Less than Significant Impact. Residential and mixed -use housing development donot cause orcontribute substantially to oubmUa| hazards to the public or the environment because these uses do not involve the use, 8anapuh[ or disposal of appreciable amounts of hazardous materials or wastes. For purposes of the following analysis, o "significant hazard to the public or the environment" is characterized by the effects ufexposure ha hazardous materials and/or wastes from ufacility or facilities that are subject to uperatiune'apeuificfedem|' u1aha, negiona|, or local regulations and implementation pmcanoeo (including permitting, accident contingency, and clean-up requirements) based on the amount ufmaterial urwaste undergoing use, transport, or disposal and the resulting impacts to human health or ecosystem functions. Residential uses are characterized by the use of common, widely available hazardous materials including paints and other solvents, cleaners, and pesticides. The remnants of these and other products are disposed of as household hazardous waste (HHVV) that includes batteries, electronic wastes, and other wastes that are prohibited or discouraged from being disposed ofatlocal landfills. Use of common household hazardous mabnha|u are not subject to federal or state permitting at the consumer level and it in City of Downey 2021-2029 Housing Bement Update 39

Environmental Impact Evaluation
reasonably foreseeable that upset and accident conditions cannot 0omet bvthe use, transport, and disposal nfsuch materials and wastes from future residences. Consumer -level household hazardous materials and wastes are not subject to federal or state permitting bvthe consumer, and their use is at such |ove|u as to not have the potential to result in risk ofupset or accident that could harm a substantial number of people, including children attending schools in the area, or have o substantial effect onthe functions ofthe local orregional ecosystem.

Hazardous Sites: The proposed Inventory Sites are not listed as hazardous waste and substances oihao, leaking underground storage tank sites, solid waste disposal sites, hazardous waste facilities subject to corrective action, or sites regulated by the Regional YVahnr Quality Boand.x Them one 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 mnec8om be located on edoqueba distance from existing and potential sources of toxic emissions. In addition, CEQA requires the assessment of risk involving the transportation, disposal, manufaotuna, otunage, and handling of any hazardous materials for new development. Therefore, 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 1nthe General Plan E|R, hazardous materials pass through the City in route to other d*uUnoUnno via mi|, surface otnaetu, and freeways. While train derailment can occur at any time, it is during on earthquake that a derailment and hazardous materials release would pose the greatest risk ufhazards. The City has no direct authority to regulate the transport of hazardous materials on local and regional roadways or railways; howev*r, under upset and accident conditions, it is reasonably foreseeable that most ofthe spill would be contained within the right'of-wayofa roadway with minimal chance of hazardous materials or wastes reaching adjacent homes. On the other hand, it is reasonably 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 mmbariu|o and wastes by truck and rail iuregulated bythe U.G.Department ofTransportation /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 haulers of hazardous waste but does not regulate all hazardous materials. Although there is some reasonably foreseeable potential for exposure of future residents to hazardous materials and waohau 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 to the Envimotor4 *ebaibm of the California Department of Toxic Gubotonuao Control, the City of Downey has 18 total facilities listed within Downey although only nine of them require further action (testing or remediation). These uihso spread throughout the City as a result ofits long history with industrial uses. Both the federal government and the State of California require all businesses that handle hazardous mah*he|a or extremely hazardous materials tosubmit a business risk management plan to the local Certified Unified Program Agency (CUPA), The CUPA with responsibility for the City is the County's Environmental Health Department. The business risk management plan must include an inventory of the hazardous mah»ha|u and emergency response plans and procedures to be used in the event ufosignificant release of hazardous material. Implementation of federal and state requirements for the operation of these types of facilities will ensure that exposure bxresidential uses will beminimized uravoided.

Considering the preceding analysis, the proposed Housing Element Update will not result in effects from the use, transport, or disposal ofhazardous oracutely hazardous materials nrwastes, under normal orupset and accident conditions, which could impart human health or the environment with implementation of existing re0u|etiunu, standards, and General Plan Policy.

Impacts will Umless than significant.

E1 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 uses and people on the ground.

California Environmental Protection Agency. Cortese List Data Resources. http://www.calepa.ca.gov/SiteCleanup/CofteseLisg [December 7,2020
40 202/-2020 Housing Element Update

Environmental
Development within the approach and departure zones ofanairport mairstrip are subject tothe effects of potentially widespread, although nem, aircraft crashes; therefore, 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 velocity, the pitch, yaw, and roll at the moment of impact, and the type 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 of the airport.

The Lon Angeles County Airport Lund 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 gmund. The commissioners represent the county, its ciUou' and the public. Legislation passed in 1982 established edirect link between airport land use plans and the land use plans and regulations adopted by cities and counties, as established in California Public Utilities Coda Section 21676. In accordance with this legislation, the ALUC must review the general and specific plans oflocal 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 pmpouedvvithinth*g*ngraphicbounderieuofthePrimaryReviewAnaaavenefermdtothe ALUC for review and evaluation. Within the Secondary Review Area, only those projects involving a structure orother object with aheight that would exceed that permitted under adopted land use zoning would be referred tothe ALUCfor review.

The closest airports hothe City are the Fullerton Airport located approximately 7.5 miles to the southeast and the San Gabriel Valley Airport in E| Monte located approximately 9.3 miles to the northeast. The City does not fall within the Planning Bounclary/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 plan, 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 responses to extraordinary emergency situations associated with natural disasters, technological incidents, terrorist aoUvi1ieu, and war -related operations. The City is part ufa county and statewide emergency management system that od0neoueo evacuation and movement ofpeople in the event ufan emergency. It should be noted that the Cib/'u plans are flexible in order to respond to the inherent chaos associated with diaosVam in e 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. Nuimpact will occur.

G)Less than Significant Impact. Ao noted UyCALF|RE Fire Hazard Severity Zone Maps, the City iunot located in an area of high fire threat (CSG 2020). Because Downey is an urbanized cnmmunity, mtmotum| finan rather than wi|d|and fires represent the gnuubaat fire risk in the Qty. The CBCfnnuueo on the construction and materials used in roofs, attic ventilation, exterior walls, denkinA, floors and unUorf|oom' and ancillary bui|dinga, utmntuveo, 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

Enw�n�n�
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u�opo��|mmm��md|��r��n��dm��mou��i��d��e�eir��|��mndmin myeh*m�DiachargeufpoUuten�sinho�a�rbodi*eounmouKin�f��oon�he0�n��oia|uoemufthew@�rboUy�BenmDcio|uoee ino|ud� vva��rfureghou|tunm| uaea, mp�cia| am�o fnr bio|ogica| nmoouncee. uo|d ��uhwmt�r �abitat, cumm�mia| end upo� fiahing.mu|titudauofhabitato.��uhwmbarrop|enioUmont�oumeo.anaamof��i�uim|ornatura|gmund��t�rnanhmrgm'wmbarf�r indumtria| oupp|y and pmc�uu. wmharfordumeetio uoeo, wm��xS uo�� fornovigaUon. onmma vvhem rane or�nUangened upeoiem 42 � —�
2O�/'2U2A�ouo�pf�n��n L�m��

could occur, fish spawning grounds, migration, shellfish hameuUng, and recreational aotivdies.sThe resulting impacts due to effects on water quality and associated beneficial uses include disruption of the ecosystem due tothe loss ofhabitat, potential harm or death to sensitive epaoiem, and a narrowing ofmigratory options and species' gene pools. Impacts to humans range from quality of life iuuuou such as the |nau of recreational waters to potential health impacts due to contamination of drinking water supplies and contamination of fish and other marine life farmed and sold for food.

The proposed Housing Element does not include any policies or programs that would conflict with implementation of the NPDEG program such that future residential development could result in exreodunne of the waste discharge requirements and thus will not substantially impact downstream water quality. Furthermore, future housing development will be subject to environmental inquiry and potential review pursuant to CEQA. Impacts related to violation of water quality standards and waste discharge requirements will be less than significant with implementation of existing permit regulations.

B) Less Than Significant Impact. The proposed Housing Element can accommodate projected housing demand over the next eight years, which will require potable water for drinking, food preparation, cleaning, and bathing as well as water for landscape irrigation. Future housing will generate demand for water in addition to the demand of existing umam and the incremental increase in demand as growth occurs in the area. therefore, the future housing will contribute hocumulative, long- term increases in demand for groundwater and other water moounmw. The City is situated between the San Gabriel 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 quality ufthe environment.

According to state law, local water agencies must regularly update their Urban Water Master Plan and large development projects must prepare a oopumb* water supply assessment (VVGA) to identify how to ovoid or reduce impacts on surface or groundwater supplies over u2U'yoorperiod even under drought conditions.

Subsequent to and within three years of Housing Bement 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 be subject to a new and separate CEQA review process.

The proposed Housing Bement Update does not involve development ofany ofthe Inventory Gih*u; and does not designate any additional Inventory Sites than were evaluated in the General Plan E|R. Therefore, potential programmatic impacts associated with the Inventory Sites will remain within the scope of analysis in the General Plan EIR. Future development of the Inventory Sites will be subject toenvironmental inquiry and possible project -specific environmental review pursuant tn CEQA.

Considering the proposed Housing Bement ioconsistent with the analysis documented in the General Plan E|R and will not increase surface urgroundwater demand beyond that assessed in the General Plan E|R, the HEU will result in equivalent or less than significant impacts related hothe decline in groundwater levels when :umpenoU hothe analysis and conclusions in the General Plan E|R.

C\ Less Than Significant Impact. The City is situated between the Gan Gabriel and Rio Hondo Rivers both of which are fully improved flood control channels. Future development ofhousing will occur on currently urpreviously developed oih*o and undeveloped sites but would not alter existing drainage channels or patterns. Development on currently or previously Uewa|npod eihaa is unlikely to substantially change the hvdno|ugioe| conditions of the site that was undoubtedly graded and engineered to convey on -site flows to |000| storm drains or water quality basins in accordance with the City standard requirements for drainage and flood oon1m|, as specified in the Municipal Code, Development on previously undeveloped oihan may result in more substantial changes to the site topography and drainage conditions as cut and fill activity occurs to balance the site for building construction. The concern with changes in on -site drainage is the potential for flooding, erosion, siltation, pollutant |oading, and exceedance of storm drain capacity due to the lack of or improperly designed conveyance of runoff. The effects of changes in drainage patterns can result in impacts to human health and quality of life and the environment through damage nrdestruction of structures, sedimentation of downstream vvahor bodies and the nmou|Ung impact to aquatic biological 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
resources, decreased water quality with similar impacts toaquatic biological resources, and storm water backup that can result in similar types of flooding impacts.

According to the General Plan BR,implementation of the General Plan will reduce potential impacts related to additional runoff such aserosion and flooding huless than significant levels and requires the maintenance nfadequate facilities for water and storm drain services. Therefore, impacts due to the effects of changes in drainage patterns or potential erosion relative to the HEUwill bmless than significant with implementation of existing regulations and General Plan goals and policies.

D) Less Than Significant Impact. Most ofDowney faces minimal flood hazands, as outlined by the Federal Emergency Management Agency (FEMA) hazard maps. The City is adjacent to the Rio Hondo and San Gabriel Rivers which are auooeoiib|o to 10-yearflooding events but they are contained within the improved banks of their respective channels. The FEk8A maps also show the entire City is at risk of flooding from e 500'ye@rf|uod event (LAC 2020). However, none of the proposed Housing Element Inventory Sites are located within a 1 00-year flood hazard area.

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 aaa flood risk management and water conservation project in1957 and creates a reservoir capacity of9J5 million gallons of water. In 2018. 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 addibon, engineers found that the mile -long earthen structure could tuii ifwater were huflow over its onoet or if seepage eroded the sandy soil underneath. K8oauumu to permanently address these iouuou are currently being developed and evaluated (as nf2O2O). The U. G. Army Cnqm of Engineers (U3ACE) 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 requiem each project to demonstrate it is not impacted by a 100-year flood zone ovwhat steps it will take Voeliminate that risk. CEQAa|oo 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.
8eiche isthe process by which water sloshes outside its containing boundaries, generally due to an earthquake, Geichecan result in localized flooding that can euuK in property damage or personal injury, This could occur within an open reservoir, lake, orother large watermdy (see discussion regarding the Hoover Reservoir). The City does not contain any sizeable open meemuim. |akou. or other large bodies of water, therefom, impacts resulting from the effects ofueiohe in the City will be |*ou than significant and no mitigation in required. A tsunami is o large wave that generates in the ocean, generally from an earthquake, and builds intense strength and height before impacting o coast. Tsunami can result in significant property 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 tumudflowialess than significant.

Therefore, the potential impacts offlooding, tsunami, or seicheand any related release of pollutants would be less than significant and no mitigation is required.

E) Leas Than Significant Impact. This ausonumnnk is for both surface water management planning and sustainable groundwater management plans.

Water Quality Control Plan. The Water Quality Control Plan Los Angeles Region, Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties (Basin P|en)6 isthe water quality control plan for the greater Los Angeles Basin, including the City of Downey. The Basin Plan designates beneficial uses, establishes water quality objectives, and contains 44 202/-2029 Housing Element Update

implementation programs and policies to achieve those objectives for all waters addressed through the Basin Plan (CWB 2010. The Basin Fqem imcontinually being updated toinclude amendments related hoimplementation of the total maximum daily Ioad7 (TMDL) of specific potential pollutants or water quality stressors, revisions of programs and policies within the Los Angeles RVVQCB mg|on, and changes to beneficial use designations and eamodohed water quality objectives. The General Plan requires future development to be consistent with the Basin Plan. Therefore, the HEU will not conflict with or obstruct implementation ofawater quality control plan.

Groundwater Management Plan. In 2014 the governor signed the Sustainable Groundwater Management Au 0SGMA\ 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. GGIVIAempowem local agencies 0aform Groundwater Sustainabi|ih/Aoeno|ou (GSAV)k> manage basins auota|noh|yand requires those GSAuho adopt Groundwater Guutainabi|ib/ Plans (GSPs) for crucial groundwater basins in California.

The Downey Public Works Department, Utilities Division, maintain 20 deep groundwater wells sites and three NWDimported water connections to provide domestic water service to City residents and businesses. The City overlies the Central (groundwater) Basin which was adjudicated in 1905 and the Central Basin VYotennootermonmgem groundwater supplies and replenishment, The City Utilities Division coordinates with the Watermaster to assure adequate water service to the City. The master groundwater planning of the VVabermeohar is based on adopted land use plans in the General Plans of the cities that utilize Central Basin groundwater. Subsequent to this Housing Element update. the City will be undertaking focused General Plan and zoning ordinance amendments with separate CEQAcompliance toensure sufficient land use capacity ioavailable to accommodate the RHNA. This Initial Study examines the potential environmental impacts at a program level for only the Housing Element since the Housing Bement itself does not ep*xiOcu||y authorize the construction of any housing dewa|opment, nor does it indicate where and when specific housing projects will occur, Therefore, the HEU will not conflict with or obstruct implementation of sustainable groundwater management plan. Impacts will be |eao 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?
El
0 11
b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
El
0 El
E
adopted for the purpose of avoiding or mitigating an
environmental effect?
A0NoImpact. Communities form neighborhoods withinmbmadexooeemblageof|andu000.ecUngomph i |hboundodand typically culturally and economically homogenous social networks that often define e pemon'm local sense ofplace and help shape an individuo|'s oncie| and cultural pempecdve, pah|ou|mdy as o youth. Such communities typically are self -policing groups with internal codes of conduct and social norms that help define community character while ensuring individuals do not unduly upset the fabric and spirit that perpetuate the community in operating as a undo| unit. Aoignifinont impact would occur ` TwoL is aplan for restoring impaired waters that identifies the maximum amount mapollutant that ubody m water can receive while still meeting water -quality standards City of Downey 2021-2029 Housing Element Update 45

Environmental Impact Evaluation
if proposed Inventory Sites are sufficiently lame or configured in such a way so as to create o physical barrier within an established community.

Subsequent to and within three years of Housing Element . 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 be subject to a new and separate CEOA review process, The Housing Element does not propose specific development on any specific Inventory Site at this time. The proposed Housing Element identifies Inventory Sites throughout the City ofDowney. The General Plan does not designate anyosteb|iuhedcommunitieodefinedbyaSponific Plan that would be affected by implementation of the proposed Housing Element; therefore, implementation of the proposed Housing Element will not create any physical barrier within the community. Furthermore, projectimp|om*nto1iunwiUnot require new infrastructure systems such as roadways or flood control channels not already planned and previously considered in the General Plan E|R. As such, the Housing Bement update will not divide or disrupt neighborhoods or any other established community elements. No impact will occur and no mitigation is required.

BU No Impact. The Housing Element update meta forth policies to encourage housing development consistent with adopted land use policies established in the General Plan. As outlined in Threshold 11.A above, the Housing Element does not propose construction on any of the Inventory Sites at this time, and the subsequent General Plan and zoning ordinance amendment process will be subject to a new and separate CEQA review process. The Housing Element does not include any gna|e. policies, Vrprograms that would conflict with adopted Sonono| Plan goals and policies to mitigate impacts due to effects generated bydevelopment within the Planning Area, as specified inthe certified General Plan E|R. 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
El
E]
0 region and the residents of the state?
B) Result in the loss of availability of a locally
important mineral resource recovery site
delineated on a local general plan, specific plan or
other land use plan?
A-B)bess Than Significant Impact. Minerals refer to aggregate resources, mrock, sand, and gravel,energy-producing fields, including oil, gas, and geothermal substances, and related mining operations. The California Department of Conservation (DOC) classifies land inthe 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 Prod uction-Cons u mption (P-C) Region of the greater Los Angeles metropolitan area (DQC, 2020U). Land in the City has been classified by the California Division of Mines and Geology /CDM6> according to the presence or absence of significant sand and gmwm| deposits (suitable for use in uunmtmotinn'gnmdeaggmgat*). The land classification is presented inthe form ofmaps showing Mineral Resource Zones (MRZ). There are four MRZ classifications, MRZ-1 through MRZ-4 as described below:
• K8RZ'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. w K4RZ'2 are emou where adequate information indicates that significant mineral deposits are present orwhere it is judged that a high likelihood for their presence exists. 46 202/-2029 Housing Element Update

The General Plan EIR states that the City has not designated locally important mineral resource recovery areas within immediately adjacent to the City. The Downey General Plan EIR concluded that there will be no impact to the availability mineral resources of value to the State or City.
kv All I is-i rel
INIC47-rJ M'ffng Merl
cement plugs in the wellbore at specific intervals to prevent fluid flow.

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
El
established in the local general plan or noise
ordinance, or applicable standards of other
agencies?
B) Generation of excessive groundborne vibration or
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
El
1:1
2 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, GardendaleStreet and Foster Road onthe south, the San Gabriel River onthe east, and the Rio Hondo River on the west. Moor freeways include the |'5onthe north, 1-105 on the south, 1'005 on the east and |'710bJthe west. MTA Green Line light -rail train services are available at the Lakewood Boulevard station located next tothe 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 City including Telegraph RoaU, Lakewood Buu|even1' Bellflower Boulevard, Florence Avenue' Firestone Boulevard, and Imperial Highway, as well as from commuter and freight trains.

Both the BNSF Railway and Union Pacific railroads operate in the Downey area with a Union Pacific railyard located adjacent to Los Nietoa Road and Union Pacific Distribution Services operating theVaUe rei|purton Sorenson Avenue. Rail freight operates within long- established rail easements/rights-of-way that traverse the City, largely atat-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, To ensure that noise producers do not 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 policies, standards, criteria, programs, diagrams, 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 control are incorporated into the land use planning process to reduce noise and land use incompatibilities.

According to the General Plan BR, construction anUvdv iotypically short-term in nature and is generally not considered to have o significant impact on noise uenuMiwa uses as long as construction activity is limited to daylight hours. Acoustical analyses for future housing development projects under the HEU will address construction noise impacts on sensitive noise receptors and identify mitigation ifrequired.

Future 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 n*quinau noise studies as part ofthe 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 RHNA allocation. This subsequent General Plan and zoning ordinance amendment process will be subject to V new and uepomha CEOA review process. The Housing Element does not propose specific development on any specific Inventory Site at this time; therefore' 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 at which time all environmental issues will Uevetted and appropriate mitigation incorporated, if needed, should noise impacts be identified. Potential impacts will be |eau than significant with implementation of existing standards and regulations.
13) Less Than Significant Impact. Vibration is sound radiated through the ground. The rumbling sound caused by the vibration of mom surfaces is oa||od gmunUbome noise. The ground motion caused by vibration is measured as particle velocity in inches per second, and in the U.G. is referenced as vibration decibels (VdB). The background vibration velocity level in nmuiUenUa| and educational onmam is usually around 50VdB while the vibration velocity level threshold ofperception for humans is approximately 65 VdB, A vibration velocity level of 75 VdB is the approximate dividing line between barely perceptible and distinctly perceptible levels for many people. Sources within buildings such as operation of mechanical equipment, movement ofpeople, or the slamming of doors cause most perceptible indoor vibration. Typical outdoor sources of perceptible gmundbum*vibration are construction equipment, steel -wheeled trains, and traffic on rough roads. If roadway is smunth, thegmundbome vibration from traffic is nanm|y perceptible. The range ofinterest is from approximately 5OVdB, which 48 2021-2029 Housing Element Update

Environmental Impact Evaluation
isthe typical background vibration velocity level, and 100 VdB, which is the general threshold where minor damage can occur in fragile or historic buildings.

As mentioned in the Gemnnd Plan BR, it is unknown if rail operations through the City could increase in the future, therefore, noise levels generated bvthe train would remain the same muunder existing conditions where land uses within 125 feet of the train tracks may experience noise |ev*|u in excess ofOU dB. Because the proposed Housing Element Update identifies some Inventory Sites proximity hothe rail corridor, potential future development and redevelopment to occur within the area may be exposed to noise levels in excess of 60 dB. With regard to railroad operations, noise and vibration impacts would be evaluated on a pjeot-Uy'p ject basis pursuant to CEQA and the City's local implementation procedures, and projectopecifiumiUgaUnn measures required ifnecessary.

Tvoioo| construction vibration mitigation includes muting and placement ofequipment 10 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 toreduce gmundbumevibration. Short-term Impacts related togmundbumevibration 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 ofvibration.

No short- or long-term impacts will be associated with vibration at a programmatic level for this Housing Element Update as no policy changes, developments, or infrastructure improvements are proposed as part of the Housing Element update. Impacts will beless than significant and nomitigation iurequired.

Cumulative Impacts. Residential land uses typically do not produce excessive noise either individually or cumulatively that could substantially increase existing, ambient noise levels. The future development of the Inventory Sites could increase ambient noise levels due Voincreased traffic generation inthe project vininih/.Thuo.deve|opmantuf\he|nvenhoryGitemwiU partially contribute to the noise volumes identified in the General Plan BR. The City reviews all new development proposals per CEOAwhioh includes the analysis ufvehicular traffic nuioe. As outlined in Threshold 13.A above, the Housing Element does not propose any specific development at this time that would invalidate this prior finding or further increase traffic levels beyond those analyzed inthe General Plan BR. Project -specific increases in ambient noise levels due hofuture development 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 p|aoy, impacts related to increases inambient noise levels will be less than significant and nnmitigation iorequired.

C) No Impact. The City nfDowney is not located within two miles or within a comprehensive land use plan for any public or private airport. In addition, no private airstrips are located within the City. No specific new development is associated with the proposed Housing Element update, and no changes to safety policies related to air traffic are proposed, No impacts will occur.

14.POPULATION AND HOUSING
City of Downey 2021-2029 Housing Element Update 49
City of Downey 2021-2029 Housing Element Update 49

Environmental ImoactEvaluation
13) Displace substantial numbers of existing people
or housing, necessitating the construction of El
replacement housing elsewhere?
A) No |mmact and implementation of the Housing Element will not in and of itself, directly result in population growth. Population growth is aoomphm interaction nfimmigration, emigration, births, deaths, land use, and economic factors of which the General Plan and Housing Element are only o pad. Regional models of population growth and change, accounting for these complexities, are developed by the California Department of Housing and Community Development (HCD) and Southern California Association of Governments (GQ4G). The proposed Housing Element update is designed to guide and accommodate the Cit/m share of the projected regional population growth and associated housing over the next eight years, Pursuant to Government Code 65584, the California Department of Housing and Community Development (HCD) is required to determine the Regional Housing Needs Allocation /RHNA\, by income oahegory, for Council of Governments (CDGo) throughout the State. The RHNA is based on the California Deportment of Finance population projections and regional population forecasts used in preparing regional transportation plans. COGs are required to allocate to each locality a share of housing need totaling the RHNAfor each income category. The RHNAiu based on the California Department of Finance population projections and regional population forecasts used in preparing regional transportation plans. COGsana required to allocate to each locality a share of housing need totaling the RHNA for each income category.

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 Dnwmey'oshare is 8.525houuing units. This allocation is referred to as the Regional Housing Needs Assessment, orRHNA.

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 regiun, eu the pnnpnoad housing Element Update would not induce unplanned population growth. No impact will occur.

B)NoImpact. The proposed Housing Element update is intended encourage and facilitate housing development and preserve and enhance existing housing stock. The natural recycling of land will not result in the loss of housing units because such redevelopment will result in the development nfnew housing units. Thus, the availability ofresidential units in response to increases in population is supported by the Housing Element. Considering residential units will increase naturally ooguided by the goals and policies of the proposed Housing Bement' no impacts related to the displacement of housing or people would occur and nnmitigation ierequired.

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?
E]
El
0 El
13)
Police protection?
El
El
E
El
50 2021-2029 Housing Element Update

Environmental Evaluation
A0Less Than Significant Impact. The Downey Fire Department 0]FD\consists ofabout 100 employees providing evariety ufcomprehensive fire and | oomic*u to the community of 112.322 residents located in southeast Los Angeles County. The 1241 square mile City io protected by an Insurance Services Office (ISO) C|eao 1 rated fire department operating out nf4strategically |ooehadOnastaVnno.Theoeutat|onuhouaehourPommeUin'EngineCnmpaniee'oneTmokCompony'twm 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 toatotal of1O.O19emergency incidents in 2019'2020 (City 2021).

New development under the HEU will result in the incremental increase in need for fire protection services as the Cdv's population gm*u and the number ofresidential units increases, The City collects Development Impact Fees to offset the impact of new development, as it occurs. Construction and operation of a new fire station will be subject 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 deportment as well as constructing and operating future fire facilities will be |*no than significant with implementation of existing regulations.
13) Less Than Significant Impact. The Downey City Police Department provides police protection services to the City.

According to the General Plan E|R' the Police Department anticipates that as the City grows additional police facilities to house additional equipment and Nffio*nu 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,VuuhaopoUuten1omiooione 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 on local roadways. Police stations also result in the specific effectof generating periodic increases in noise from use of sirens, although typically sirens will be initiated while on patrol as opposed to directly initiating from the substation. The City collects Development Impact Fees buoffset the impact ofnew development, as it occurs, Construction and operation of a new substation will be subject 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 constructing and operating future police facilities will bnless than significant with implementation ofexisting regulations.

C) Less Than Significant Impact. The Downey Unified School District provides K-12 educational services tothe City of Downey and is comprised uf13elementary schools, 4 middle oohnn|a' 3 high schools, and an adult school. The effects of schools that can result in environmental impacts are specific and include peak traffic levels occurring in the morning and early aftomoon, playground noin*, and field lighting. Fudhemnore, una|yaou of anhno| impacts are unique in that any impacts resulting from the effects of schools are considered fully mitigated through the payment of development impactfees pursuant to the Lamy F. Green School Facilities Act, therefore, pursuant to State law and the payment ofdevelopment impact fees, impacts will be less than significant.

D) Less Than Significant Impact. Pursuant to State law, the City imposes parkland dedication min -lieu fees on new development equivalent h)four acres of parkland per 1.000 new residents. The proposed Housing Element Update will generate new or relocated nmidonha that will require park and recreation tmci|iU*o and associated pmgnymo, 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 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 of new housing h)compensate for incremental incnaeu*y in pedm and recreation service demand, thus providing adequate, per -capita facilities for future residents. The City of Downey also collects Development Impact Fees to offset the impact of new development, as it occurs. 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 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

Environmental Impact Evaluation
impacts resulting from the effects • constructing and operating future parks and recreation facilities will be less than significant with implementation of existing regulations. "-- .1 IN MIN W0114"'I"1111111111 ITT
INW11111116MI,
�nvironmental issues will be vetted and appropriate mitigation incorporated, if needed. Potential impacts resulting from the fzkm ybAv-
regulations.
52 2021-2029 Housing Element Update

Environmental Evaluation
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
physical deterioration of the facility would occur or
be accelerated?
B) Does the project include recreational facilities or
require the construction or expansion of
0 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 on new development equivalent to four acres of parkland per 1.00 new residents. The proposed Housing Element Update will generate new or relocated residents that will require port and recreation facilities and associated pmgn*mn' 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 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 of new housing to compensate for incremental increases in parks and nauneaUnn service demand, thus providing adequate, per -capita facilities for future residents. Construction and operation of new orexpanded 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 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 parks and recreation facilities will be less than significant with implementation of existing regulations.

17.TRuNSPORTATON AND TRAFFIC
City of Downey 2021-2029 Housing Element Update 53
City of Downey 2021-2029 Housing Element Update 53

Environmental ImnactEvaluation
A) Less than Significant Impact. The City is served by local transportation facilities including streets, passenger and freight noi|wayo, and bum routes in addition to non -motorized transportation facilities such aasidewalks, 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 system for the City, and the broader system, designed with the 8no|u of efficiently moving people and goods throughout the region byproviding ease ofaccess tomultiple modes nftravel.

Future housing development will primarilygenerate passenger vehicle trips that will disperse during the morning as residents drive to commercial, industrial, and institutional facilities for a variety of reasons but primarily for work and school. Some trips may betotransit centers, such that aportion of resident's trip may include alternative transportation modes, while others may simply walk totheir destination nrhoother transit options, The return leg ofatrip iegenerally anticipated 0ubethe 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, orother uses.

The concern regarding transportation facilities and their counterpart modes of travel is excessive use throughout the day or during morning and/or afternoon peak hours and the resulting effects on the performance of the facilities' ability to move people and goods. The direct effects of reduced circulation system performance are annoyance and utreeo, thereby decreasing the quality 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.

SCAGPlans. Two planning efforts guide the improvement ofthe circulation system atthe regional and local levels.

The Regional Transportation Plan (RTP) and Sustainable Communities Strategy (RTP/SCS) is administered by the Southern California Association of Governments (SCAG) to meet the needs of travel and goods movement through the year 2040.

While the RTP/SCS addresses the broader goals of the transportation network, the City's General Plan Circulation Element identifies long-term transportation improvements for local facilities. The General Plan includes goals and policies aimed to provide onefficient multi -modal circulation system inthe city. General Plan policies also encourage the development ofon efficient and safe bikeway and public transportation system.

Summary. These local and regional planning efforts are designed to reduce the direct and indirect effects of travel so as to minimize oravoid resulting impacts on human health and the environment. The proposed Housing Element is consistent with the growth assumptions used inthe development nfthe RTFYGCSand does not include any land use changes tuthe General Plan growth projections, th*refom.Uh*HousingBoment will not conflict with the goals oftransportation planning efforts ofthe City orGCAG. Furthermore, according to the General Plan BR, implementation of General Plan policies will avoid or reduce impacts of General Plan build out on the performance of the roadway system.

Based on this preceding analyuis, future housing development will not impede local or regional efforts to enomna an efficient nin:u|aUun system. Future housing development will be subject to preliminary environmental review pursuant to CEQA and J found not to be exempt' subject to full environmental analysis at which time all environmental issues will be vetted and appropriate mitigation inourporated, 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. 13) Less Than Significant Impact. In response to Senate Bill (8B) 743' the California Natural Resource Agency certified and adopted new CEQASuide|inoe in Denember2018. which now identify Vehicle Miles Traveled (VMT) as the most appropriate metric toevaluate o p jed'u transportation impact under CEQA(Section 15004.3). Effective July 1. 2020, the previous CEQA metric of level of service (LOS), typically measured in terms of automobile delay, roadway capacity and congestion, will nnlonger constitute asignificant environmental impact.
54 202/-2029 Housing Element Update

Environmental Impact Evaluation
Although VMT is now the accepted methodology for evaluating potential transportation impacts ofaproject, the City General Plan identifies standards for maintaining enadequate level ofservice (LOS)for City streets and intersections, Tnb*consistent with the 2020 State CEQA Guidelines, o LOG analysis is no longer required for purposes of this Initial Study impact analysis and determination ufsignificant impacts under CEQA.However, anevaluation ofthe overall circulation network and services available to the City is still appropriate.

Transit. The public transportation system in Downey provides non -auto options for commute, utility, and recreational travel, with connections hadowntown Los Angeles, LAX, and other regional cities and destinations. The City ofDowney isserved by u number of bus, commuter noi|' and shuttle and paratranuituemioeo. The following agencies provide regional nonnectivdv, providing an alternative hzdriving a personal vehicle:
m #NetTm|ink. Metm|inK is acommuter rail system that consists uf82stations operating on 534 miles of rail network throughout Southern California, with key connections to most major cities. K4etm|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. � Norwalk Transit. Norwalk Transit provides fixed- mute and paratransit service in Downey, Norwalk, Arteeia, Bellflower, CenUoe, La Mirada, La Huhna' Downey, and areas ofunincorporated Los Angeles County. The agency serves nearly 8,3DOpassengers each weekday nnthe six transit routes.

Bus transit generally runs every 3Oto45 minutes during the peak pohudo, with certain routes running uvery25 minutes or better. Generally, transit users prefer reliable wait times of less than 15 minutes when making trip choices, Metro EastskdeCorridor Phase Z As of 2020, Metro is evaluating the Eastside Transit Corridor Phase 2, an extension of the Metro L Line (Gold) further east from its current terminus at Atlantic Station (Pomona Boulevard/Atlantic Boulevard) in East Los Angeles through the cities of Commerce, Montebello, Pico Rivera. and Downey. The proposed line would travel south along Atlantic Boulevard underground from the current Metro L Line (Gold) terminus at Atlantic Boulevard Station to the Citadel Outlets in Commerce. The route would then proceed east along Washington Boulevard via oeho| and/or at -grade (street level) configurations ending at Lambert Road in Downey. The East Transit Corridor Phase 2extension 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 a2U28target 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 Nietoo Road and Union Pacific Distribution Services operating the VaUa nei|porton Sorenson Avenue in nearby Santa Fe Springs (east ofDownev). Rail freight operates within long-established rail ease mente/righto'of-wmythat traverse the City, largely at at -grade crossings. Crossings are located primarily at arterial roadways. The at -grade crossings can be a source of road cnngoabon, restricting car and truck movement when long freight trains rumble through the area just north ofthe City.

Bicycle Routes. Los Angeles County has established bikeways in various locations throughout the County. A Class I bikeway (off -road) provides a completely separated right-of-way designated for the exclusive use of bioyo|om and pedestrians.

CmoaOuwm with 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 Son Gabriel River Mid Trail is a C|ouu | 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 AClass Ubikeway km-roud\provides arestricted hg on ushoulder designated for the exclusive ursemi- exclusive use of bicycles. Through bame| by motor vehicles or pedestrians is prohibited. CmooOows by pedestrians and motorists are permitted. Vehicle parking is prohibited. Opportunities for Class 11 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 2021-2020 Housing Element Update 55

Environmental Impact Evaluation
10enhance the bikeway system. The goal is to link residential areeu, schools, parks and commercial centers mnthat residents can travel within the community without driving. New development projects will be required to include safe and attractive eidowa|ko, wa|kwuva, and bike lanes, and homeowner associations will be encouraged to o0nndmct links to adjacent areas and communities where appropriate.

Pedestrian Facilities. Downey has sidewalks and crosswalks on most streets. Bicycle movement is accommodated on a developing system uflocal bikeways that connect tnregional facilities.

Summary. The HEU will result in the future development ofadditional housing in the City although the anticipated gmmdk will be within the limits identified in the existing General Plan and its EIR. This additional housing will not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

Therefore, any impacts will be less than significant and no mitigation is required.

C) No Impact. The Housing Element update does not authorize the construction of any roadway and will result in no effects on the design of existing or future mtneeta. Therefore, it will not substantially increase hazards due to u geometric design feature (*.g, sharp curves or dangerous intersections) or incompatible uses (e.g,femn equipment). There will be no impact and nomitigation iarequired.

D) Less Than Significant Impact. The HEU does not involve any moU construction nrany development activity and thus will not obstruct or restrict emergency access to or through the City. Future housing development facilitated bvimplementation of Housing Bement policies will be subject to site plan review and approval during entitlement review and/or application for building permits. The Fire Department reviews all plans to ensure compliance with all applicable emergency access and safety requirements. Impacts involving emergency access 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.

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 El El
register of historical resources as defined in
Public Resources Code section 5020.1 (k), or
13) 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 El 0 El subdivision (c) of Public Resource Code Section
5024.1, the lead agency shall consider the
significance of the resource to a California Native
American tribe?
A) Less than Significant Impact. Nobuildings remain from the former Boeing Plant, and few of the facilities with Guogie architecture have been preserved. A number of mansions from the 1940's and 50's in the "Little Beverly Hills" neighborhoods 56 —�— 2021-2020 Housing Element Update

Environmental Impact Evaluation
aUU exist but many have been extensively remodeled. Unfortunately, the primary way ofviewing past are 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 substantial adverse change in significance nfa historical resource. Impacts will be |mye than significant and no mitigation is required.

B) Less than Significant Impact. Before the arrival ofSpanish settlers in the 1700s.the area that would later become Downey consisted nfTnngvo People that inhabited e village called Sejatnge near the current City ofWhittier and the Sun Gobho| River. By 1800' the Tongve were providing onnuohoted labor for Spanish missions. The area was pad of the early Spanish rancho of Jose Manuel Nietn, the holder of the |epg*u1 Spanish land grant in California, stretching from the Pacific Ocean to the Puente Hills. Given the long history of Native American oeM|omon1 in the region, followed by Spanish and Mexican rule, there is a high probability of finding prehistoric (archaeological) resources in the City. /t least one prehistoric site is known within the general vicinity of the City (CA,LAN'182. observed in 1950). which was d000hbnd as o "historic Gabhe|inu Village." The exact location of this archaeological site is vogue and there are three possible |Vombonu for the site, none nfwhich are within the City ofDowney.

Similar to potential impacts resulting from the effects offuture housing development on historical resources, impacts to archaeological resources can result in the loss of information 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 resources at Inventory Site locations during construction activities iounknown given that nosuch resources have been discovered and/or naonndod previously. The General Plan states that archaeological and historical resources shall Ueprotected and preserved to the maximum extent feasible.

Two changes hostate |mw(SB 1Band A852) require cities tuconsult directly with local Native American tribes todetermine if any 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 General Plan Conservation Element. This is considered regulatory compliance and not specific mitigation under CEQA.

The General Plan BRconcluded that build out of the General Plan will not result in less than significantimpacts related to the substantial adverse change in the significance of archaeological resources. The proposed Housing Element Update does not propose any land use changes ordesignate any Inventory Sites that were not already analyzed in the General Plan BR.

Therefore, long-term impacts inthe City have already been contemplated, and the proposed Housing Element Update will not result in impacts that are greater than those contemplated in the General Plan E|R. In addition, future development of the pmpnu*U Inventory Sites will be subject to General Plan requirements and environmental evaluation for exemption and pohmnUo| uno|yuio pursuant to CEQA. Impacts m|ohsd to implementation of the proposed Housing Element will be |eua than significant and nomitigation imrequired otthis 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
El
E]
El
gas, or telecommunications facilities, the
construction or relocation of which could cause
City of Downey 202/'2028 Housing Element
—'— — ��-- 57

B,mironmenta/IMDact Evaluation
significant environmental effects?
13)
Have sufficient water supplies available to serve
the Project and reasonably foreseeable future
El
1:1
Z
development during normal, dry and multiple dry
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
E]
El
0 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
1:1
El
0 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?
A) No Impact. The City Public Works Department, Utilities Division, manages water service and wastewater collection services to City residents and businesses. Wastewater treatment is provided by the County Sanitation Districts of Los Angeles County. The City also operates and maintains storm drains within its bmundahe*, although downstream flows are handled by the Los Angeles County Flood Control District. On Octuber24. 2017th* City Council authorized the City ofDowney bo join o |ooe| consortium, the Clean Power Alliance (CPA) to purchase wholesale electrical power for residents and businesses at competitive rates. CPA began serving the City in 2019 by purchasing electricity generated from renewable sources and delivering that electricity through the same Southern California Edison (SCE) power poles and power lines that previously supplied City customers, Natural gas is provided by the Southern California Gas Company.

Subsequent to and within three years of Housing Element adoption, the City will amend the General Plan and zoning ordinance/map hoprovide sufficient capacity toaccommodate the RHWAallocation. This subsequent General Plan and zoning ordinance amendment pmo*uo will be subject to e 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 conveyance and treatment. The Housing Bement does not propose specific development on any specific Inventory Site at this time; therefore, dieconsistent unaprogrammatic level with the General Plan growth projections whiohw*neeva|uatedinthe General Plan E|R. The various involved utility agencies and companies develop master service plans based on anticipated land uo*o outlined in the General Plans of the various jurisdictions they serve. In addition, future development is required to ouuum adequate utility service during the development review and CEQA process. Therefore, utility impacts will be less than significant otthis programmatic level and nomitigation iorequired. 13) No Impact. The Downey Public Works Department, Utilities Division, maintain 20deep groundwater wells sites and three MYVD imported water connections to provide domestic water service to City residents and businesses. The City overlies the Central (groundwater) Basin which was adjudicated in 1865 and the Central Basin VVa\*rmoster manages groundwater supplies and replenishment. The City Utilities Division regularly reviews and updates its Urban Water Management Plan (UVVMP) and coordinates with the Central Basin VVutennusterand MVVD to assure it can provide adequate water service k> the City under all anticipated conditions.

As outlined in Threshold 19,A above, the City will amend the General Plan and zoning ordinance/map to provide sufficient capacity hoaccommodate the RHNAallocation. This subsequent General Plan and zoning ordinance amendment process will besubject bnanew and separate CEQA review process. The Housing Element does not propose specific development at this time, mn programmatic impacts of new housing growth under the HEU will not exceed that identified in the General Plan and 58 202/-2028 Housing Element Update

Environmental Impact Evaluation
evaluated inthe General PlanBR. The City's UWIVIP is based on the General Plan and the IVIWD's master water planning is based on adopted land use plane in the General Plans of the cities that utilize Central Basin groundwater, Thorefone, at a programmatic level the HEU will not conflict with or obstruct implementation of sustainable groundwater management plan, Impacts will beless than significant and numitigation iurequired, C) No Impact. Wastewater treatment is provided by the County Sanitation Districts of Los Angeles County (C8DLAC). The City also operates and maintains storm drains within its boundaries, although downstream flows are handled by the Loy Angeles County Flood Control District. Future housing under the HEU will generate additional wastewater for conveyance and treatment. The new housing |uconsistent with the General Plan growth projections whiuhweneeva|uetedintheGenenm|P|8n E|R. The CGDLAC has o master service plans based on anticipated land uses outlined in the General Plans of the various jurisdictions they serve. Therefore, the CSDLAC master plan has already taken into account the growth anticipated under the VEU. In addition, future development is required to assure adequate wastewater service during the development review and CEQA process. Therefore, wastewater treatment impacts will be |*ou than significant at this pmgnemmoUo level and no mitigation iorequired.

D) No Impact. The City of Downey provides solid waste management for its residents and businesses although it contracts with Cu|Med Services for collection services. Wastes are taken to the Downey Area Recycling and Transfer (DART) teci|ih/ where they are sorted and materials diverted (recycled) as appropriate. Non -recyclable and non -composting wmutoe are then sent to nearby County landfills for disposal. Future development under the HEU would be required to comply with established 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 mgu|uUunu regarding reduction/recycling of household waste. As outlined in Thresholds 19.A and 19.13 above, the Housing Bement itself does not propose any specific development on specific uNee atthis time, and the subsequent General Plan and zoning ordinance amendments needed to implement the Housing Element will basubject to u new and separate CEQA review pmoono. In addition, none of the housing strategies in the proposed Housing Element update will have any effect upon or nmuU in any conflicts with solid waste disposal regulations. No impact will occur and no mitigation is required. 20MILDIFIRE
City of Downey 2021-2029 Housing Element Update 59
City of Downey 2021-2029 Housing Element Update 59

Environmental Impact Evaluation
D) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post -fire slope 0 El instability, or drainage changes?
A) Less Than Significant Impact. The City Office of Emergency 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 responses to extraordinary emergency situations associated with natural diaastem, technological incidents, terrorist activities, and war -related operations. The City is part nfa 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 road construction nvany development activity and thus will not obstruct or restrict emergency access to or through the City. Future housing development facilitated by implementation of Housing Bement 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 10ensure compliance with all applicable emergency access and safety requirements. |mpodo involving emergency onoeuo will be |eou than significant with continued implementation of development review procedures.

Therefore, any impacts will be less than significant and no mitigation is required.

BALess Than Significant Impact. The City is relatively flat and is completely urban ynthere is little mnnchance ofewildfire event affecting the City. However, the area does experience strong dry seasonal winds called "Santa Ana" winds that can sometime exacerbate the spread 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 tothe north.

The HEU will allow the eventual construction nfnew housing inthe City that may besubject tuurban fires, However, there are no conditions in the City that would exacerbate wildfire hoha and expose project occupants to, pollutant concentrations from wildfire or the uncontrolled spread of wildfire due to m|opm, prevailing windo, and other factors. Impacts will be less than significant and no mitigation is required,
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 a Class | rating with the |nuununro Service Organization USCA which means U has full and complete protection from fire risks. The City already has full infrastructure (roads, water lines with fine hvdnants, etc.) to support fire protection services. Therefore, the HEU would not require the installation ormaintenance nfassociated 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 orongoing impacts tothe environment. There are noimpacts and nnmitigation iorequired.

D.Less Than Significant Impact. The City is relatively flat and bordered by the San Gabriel River to the east and the Rio Hondo River tothe west. Both ofthese channels are fully improved adjacent hathe City. Sections 9.0and 9Dufthis Initial Study concluded that future housing in the City under the HEU would not experience significant impacts from flooding.

Therefore, the HEU would not expose people or structures to significant risks, including downslope or downstream flooding or |endo|idem, as a result ofrunoff, post -fire slope inmtabi|Kv, or drainage changes. Impacts will be |euo than significant and no mitigation iorequired.

Potentially
Less Than
Less Than No
Significant
Significant with
Significant Impact
Impact
Mitigation
Impact
Incorporated
a) Does the project have the potential to degrade the El El A
M 1:1
60 2021-2020 Housing Element Update

Environmental
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
("Cumulatively considerable" means that the
0 El
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 El
Z El
human beings, either directly or indirectly?
1 -1
1 1
A)Less Than Significant Impact. The results of the preceding analysis indicate that the proposed project will have less -than - significant impacts to sensitive biokmkm[ historical, omhaenbmical, and paleontological resources. Programmatic impacts of the Housing Element to scenic vistas and visual character and resources will be less than significant.

Subsequent to and within three years of Housing Element ' the City will emend 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 be subject to a new and separate CEQA review process. The Housing Element does not propose specific development on any specific Inventory Site atthis time; therefore, it isconsistent nn a programmatic |nv*| with the General Plan growth projections whiohwenaeva|uatedintheSeneno|P|anBR.

Considering the programmatic level ofanalysis will not authorize any development plan, redevelopment ofany existing sites, or construction of new inhaxtmdum, and will not change existing City land use policy regarding |ouoUonu or intensities of development, itwill not result inany effects that would degrade the quality of the environment, The City finds that the Housing Element's programmatic impacts related to degradation of the environment will be less than significant and no mitigation is BULess Than Significant Impact. Cumulative effects resulting from full implementation of City land use policies were evaluated in the General Plan EIR. The proposed Housing Element Update will not change any of these policies and does not pmpnuo any specific development or redevelopment project that could contribute to short-term or long-term cumulative impacts that were not addressed sufficiently inthe General Plan E|R.

The discussion in Threshold 21.AaUnve demonstrates the Housing Element is consistent with the programmatic analysis in the General Plan BR. The City hereby finds that the proposed Housing Element's individual contribution to potentially significant cumulative impacts is not considerable and no mitigation is required.

City of Downey 2021-2029 Housing Element Update 61

Environmental Impact Evaluation
62 2021-2029 Housing Element Update

City of Downey
Planning Department
11• i •OVMI
MIG
1-ULSP-M I rF—qIT-pj I_q WRJ-0-6
Riverside, California 92507
951-787-9222
Bob Prasse, Director of Environmental Services
Kant N#K#h, SaMir Euirii5meMal Plan-ne-r/Prtf&cV�IarI&g6r Amanda North, Technician
City of Downey 63

List of Preparers
Bay Area Air Quality Management District (BAAQMD) 2017. California Environmental Quality Act Air Quality Guidelines. San Francisco, CA. June 2010, updated May 2017.

California Air Pollution Control Officers Association (CAPCOA). 2017a. CalEEMod User Manual Appendix A Calculation Details. Prepared for CAPCOA. Prepared by Trinity Consultants, Dallas TX October 2017.

California Air Resources Board (GARB). (2020a). Common Air Pollutants. Web:
https://ww2.arb.ca.gov/resources/common-air-pollutants . [Accessed July 2020]. _. (2020b). Reducing Toxic Air Pollutants in California's Communities. Web:
https://www.arb.ca.gov/toxics/brochure.pdf . [Accessed July 2020]. _. (2020c). Clean Car Standards — Pavley, Assembly Bill 1493. Web, https://www.arb.ca.gov/cc/ccms/ccms.htm . [Accessed October 2020]. _. (2020d), SB 375 Regional Greenhouse Gas Emissions Reduction Targets. Web:
https://www.arb.ca.gov/cc/sb375/finaltargets2Ol8.pdf . [Accessed October 2020]. .2007. Staff Report California 1990 Greenhouse Gas Emissions Level and 2020 Emissions Limit. Sacramento, CA. November 16, 2007.
http://www.arb.ca.gov/cc/inventory/pubs/reports/staff— report-1 990_level.pdf California Department of Conservation (DOC)(2020a). Farmland Mapping and Monitoring Program, Important Farmland Finder. Web: https://maps.conservation.ca.gov/DLRP/CIFF/ [Accessed October 2020].
_. (DOC 2020b). Williamson Act Program: Reports and Statistics. Web:
https://www.conservation.ca.gov/dIrp/wa/Pages/stats_reports.aspx . [Accessed October 2020]. _. (2020c). California Department of Conservation, Division of Oil, Gas, and Geothermal Resources. (DOGGR). 2020. DOGGR Well Finder. Web: (Accessed October 292O j hltp://maps.gonservation.ca,aov/d000r/welifinder.
_. (2020d). California Geological Survey (CGS) Warehouse: Mineral Land Classification. Web:
[Accessed October 2020]
httb�§'HmaD��.conservation.cia.g�O�gs/ihfb"atiotiWarehouge"""`/""""""l"""""""ridex�4tnil?rnob--mIc. _. (2020e). DOC Maps: Mines and Minerals. Web:
hftps:L/maps.conservafion.ca.gov/mineralresoLirces/. [Accessed October 20201 California Department of Forestry and Fire Protection (CalFire 2020). Web:
https://forest-practice-caIfire-forestry.hub.arcgis.com/ [Accessed December 2020].

California State Geoportal (CSG 2020). California Fire Hazard Severity Zone Viewer. Web:
hftr)s://ais.dgi,ta,ca.gov/datasets/789d5286736248f69c4515cO4f58f414. [Accessed November 2020], 64 2021-2029 Housing Element Update

List of Preparers
California Department of Toxic Substances Control (DTSC 2020). Envirostor (comprehensive government hazmat database). Web: www.envirostor,dtsc.ca,aovloublic [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-developmenVplanning/zoning-code-map [Accessed December 2020]. . Public Works Department (City 2020b). Web: ttps.//waterzen.comlwater-E)roviders/dowopy- 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 (2021b)
https://www.downeyca.org/our-city/departments/police
Downey Unified School District website. -httr)s.//web.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:Hlaist.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: https,fl eotracker.waterbogLds.ca,_qov/ [Accessed December 2020].

California Water Boards (CWB 2020). Lower San Gabriel River Watershed Management Group. Web:
https,// www.waterboards.ca.aov/losa; n eles/water issues/ programs/stormwatertmunicipal/watershed management/san_gabriel/lower—sangabriel/index.htmI [Accessed December 2020].

City of Downey 2021-2029 Housing Element Update 65

List of Preparers
California Water Boards (CWB 2018), Los Angeles R4. Water Quality Control Plan: Los Angeles Region Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties ("Basin Plan"). https,:// www.waterboards.ca.gov/losanaeles/Water _issues/ ro r rnslbe in Galen/ Last update August 8, 2018.

Los Angeles County Department of Public Works (LAC 2020). Flood Zone Determination Website.

Web: htt s://d w.Iacoun s ov/tloodzone/ [Accessed December 2020].

Los Angeles County Flood Control District (LACFCD 2020). Web: httos://pwlacour oy/'LACFCD [Accessed December 20201.

Los Angeles County Sanitation Districts (LACSD). Web: httos://+ lacsd,ord/;[Accessed December 2020].

South Coast Air Quality Management District (SCAQMD)(202Oa). `Air Quality Analysis Handbook." 1993 Air Quality Analysis Handbook (Updated). Web: http://www.agmd.gov/home/regulations/cega/air- quality-analysis-handbook. [Accessed July 2020].
. (2O20b). SCAQMD Air Quality Significance Thresholds. Diamond Bar, CA. Revised April 2019. Available online at: http://www.agmd.gov/docs/default-source/ceqa/handbook/scagmd-air-quality- significance-thresholds.pdf?sfvrsn=2
2016. Air Quality Management Plan (AQMP). Adopted by the SCAQMD Governing Board on March 3, 2017. Web: http://www.agmd.gov/home/regulations/ [Accessed July 2020].

Southern California Association of Governments (SLAG) 2016. 2016-2040 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). Adopted April 7, 2016.

Southern California Edison Company (SCEC) 2021. Website accessed April 8, 2021. https://www.scecleanenergy.com/
Southern California Gas Company (SCGC) 2021. Website accessed April 9, 2021. https://www.countyoffice.org/southern-californ is-gas-company-san-bernardino-ca-a8e/ United States Army Corps of Engineers (USACE 1985). Flood Inundation Maps for Whittier Narrows Dam: Los Angeles County drainage area, San Gabriel and Rio Hondo Rivers, California. United States Army Corps of Engineers, Los Angeles District. 1985. Web:
hft s://www.s l,u ace.arL .mil/Missions/Asset--Mane emen ittier-1 arro rs-Darn/'[Accessed December 2020].

United States Environmental Protection Agency (USEPA 202Oa). Criteria Air Pollutants. Web:
https://www.epa.gov/criteria-air-pollutants . [Accessed July 2020]. (USEPA 2O2Ob). Health and Environmental Effects of Hazardous Air Pollutants. Web:
https://www.epa.gov/haps/health-and-environmental-effects-hazardous-air-pollutants . [Accessed July 2020].

U.S. Federal Highway Administration (FHWA) 2010. "Construction Noise Handbook, Chapter 9 Construction Equipment Noise Levels and Ranges:
https://www.fhwa.dot.gov/environ ment/noise/construction—noise/handbook/handbook00.cfm 66 2021-2029 Housing Element Update

List of Preparers
U.S. Federal Transit Administration (USFTA) 2018. Transit Noise and Vibration Impact Assessment Manual. FTA Report No. 0123. Prepared by John A. Volpe National Transportation Systems Center.

Washington, DC. September 2018.

PA1040 NexAvor�-EiRAITj I Im III IV411t;l Ord F;1 mn IR Emmimm IN 'Up 11m;A61migivilimil g4olivillen City of Downey 2021-2029 Housing Element Update 67

RESOLUTION OF ,NNING COMMISSION OF OF
DOWNEY RECOMMENDING•APPROVE A

GENERAL PLAN AMENDMENT AND INITIAL STUDY AND NEGATIVE
DECLARATIONi i139), THEREBY ADOPTINGP i
HOUSING'+f FOR THE SIXTH HOUSING
THE PLANNING COMMISSION OF OF DOWNEY DOES RESOLVEAS i • SECTION- Planning Commission of of Downey does herebyfind, deter -nine and declare
citiesA. All • countiesthe Southern California• • of • - _ (SCAG) were required to obtain State certification from CaliforniaDepartment of Housing and CommunityDevelopment (HCr updated Housing Element for the 1 1 •' planning period • later than February1' and, B. The City of Downey ("City") has been assigned a Regional Housing Needs Assessment (RHNA) allocation of 6,525 housing units forthe sixth housing cycle 1 1 • ., •
C. On June 24, 2020, the City of Downey entered into a professional services agreement with Moore lacofano Goltsman, Inc. (MIG), a professional planning, • urban design • assist with the -2021-2029
Housing Element Update (HEU), replacing the 2013-2021 Housing Element of the City's General Plan; •'
D. The City held two virtual community workshops, due to the COVI D-1 9 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,
F. On September• the•. r for reviewand
received a response with comments on November 10, 2021; and, G. On Novembert • - with the California Environmenta ti �i - • to adopt ■ • • •
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 • Commission held a study• - th
public was invited to attend and share input on the revised draft HEU based on overall communityr, •i r • and,

1. On December 121, the City submitted a revised draft HEU to HCD for r
2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 October 5, 2022 - Page 1
Attachment " "

Resolution No.

Downey Planning Commission
J. On January 6, 2022, notice of the pending General Plan Amendment was published inthe Downey Patriot mma1/8thpage edinaccordance with the requirements ofthe Downey Municipal Code; and,
K. On January 19, 2022 the Planning Commission held a duly noticed public hearing on and after fully considering all oral and written testimony and facts and opinions adopted the resolution to recommend approval of the 2021-2029 Housing Element Update tothe City Council; and,
L. On January 27, 2022, notice of the pending public hearing for City Council was published in the Downey Patriot as a 1/8th page ad in accordance with the requirements nfthe Downey Municipal Code; and,
M. [)nFebruary 8.2O22.the City Council held a duly noticed public hearing tQfully consider all oral and written testimony and facts and opinions before approving the amendment tothe General Plan and Negative Declaration; and, N. On February 10, 2022. HCO provided as response with additional comments; and. (]. On September 12, 2022, the City submitted a revised draft HEU to HCD for final review; and,
P. On September 12. 2022, notice of the pending General Plan Amendment was published |nthe Downey Patriot aaa1/8t»page adinaccordance with the requirements ofthe Downey Municipal Code; and.

Q. On October 5, 2022 the Planning Commission held a duly noticed public hearing on and after fully considering all oral and written testimony and facts and opinions adopted the resolution to recommend approval of the 2021-2029 Housing Element Update tnthe City Council; and.

SECTION . The Planning Commission further finds, determines and declares the requested General Plan Amendment, after preparing an Initial Study in compliance with the requirements ofCEC>A.found that the General Plan Amendment (pr jec8vv|Uhava''|eaathan significant impacts" because there is no request for physical development, and the HEU nenno|no consistent with other elements found in the City'e General Plan. A Negative Declaration was prepared |naccordance tothe findings inthe Initial Study.

SECTION . Having considered all mfthe oral and written evidence presented 1o|tet said public hearing, the Planning Commission further finds, determines and declares that:

A. The project is in conformance with all other applicable objectives, poUo|es, and programs specified in the City's General Plan. Additional general plan amendments and zone changes will beexecuted |norder tomeet the policies and goals ofthe Housing Element Update. The City will continue to ensure that those actions remain consistent with the ow9r8|| General Plan. In addition, in order for the City to remain in compliance with state law governing the overall General Plan and Housing Element, the City is required to perform periodical updates every eight years. State |axv 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 2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139

Resolution No.

Downey Planning Commission
2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 October 5, 2022 - Page 3

Resolution No.

Downey Planning Commission
Program Y. 4.t4.-Promote public participationin the planning process.

Program Y.4.1.5.-Provide public information on ways residents and property owners rani wn8heirneighbonhmDos.

Public participation was vital in drafting the proposed documents. The City held two separate public outreach workshops and a Planning Commission Study Session where residents were invited to attend and share their thoughts. In addition to community nneetingo, residents and stakeholders could also provide input via e community survey and receive information via the Housing Element webpage. At the community nneetingo, residents were introduced to the intent of the Housing Element and the Regional Housing Needs Assessment (RHNA). Participants shared thoughts related to gffordabi|itv, susteinebi|i1y, parhing/trafDu, support for A[}Ue. and resources for vulnerable residents. The information received at these meetings was incorporated into the proposed document. Lest|y, the workshop, aun/myo, and all outreach material was accessible toboth English and Spanish speakers.

Goal t4- Protect and enhance the residential
Pmlicvf. 4.2.- Promote residential construction that complementsem/isbng neighborhoods.

Program 1. 4.2. 1. - Discourage residential construction not in harmony with the surrounding neighborhood.

B. The proposed General Plan Amendment will not adversely affect surrounding properties or the surrounding environment because 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 through the appropriate review process, and potentially subject to further environmental review. The Housing Element was reviewed for compliance with the California Environmental Quality Act. No physical construction is propooed, 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 Update would result in o "less than significant innpao1.^Therefore, m Negative Declaration |mproposed for adoption.

C. The proposed General Plan Amendment promotes the public health, safety, and general welfare and serves the goals and purposes ofthe Downey Municipal Code.

Specifically, the goals and policies found within the Housing Element Update include:
providing housing at all income levels, providing housing specifically for vulnerable popu|aUone, rehabilitation of existing honnes, 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 ofthe community. |nterms offuture development, through the sites inventory analysis aheavy emphasis was placed indetermining where future development would be most appropriate in relation to nearby land uses.

D. Approvalofthe Housing Element does not alter any provisions ofthe Downey Municipal Coda, including the City'ssubdivision 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.
2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration PLm-21*0139 October 5.zouz Page

.Zesolution No.

E. Based on factors such as the age and condition of existing uses, the site lani- 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 the lower income RHNA are likely to be discontinued during the planning period, and therefore do not constitute an impediment to additional residential development during the period covered by the housing element. jEghQNA. Based upon the findings set forth in Sections 1 through 3 of this • �Tfg
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.
2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 October 5, 2022 - Page 5

Resolution No.

Patrick Owens, Chairman
11011 Ij
'W11111, F oil
O-PO22, by the following vote, to wit:

I j We ��g
L& I LTA 1
-10
F-11 M W-11 101
�kej Lvi I LVA I PSI•
1 0 Z W
DIM4 -M-6-M FUME
2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 October 5, 2022 - Page 6

• STAFF REPORT

PLANNING DIVISIOU
-1 A T E: OCTOBER 5, 2022
SUBMITTED BY: CRYSTAL LANDAVAZO INTERIM COMMUNITY DEVELOPMENT

DIRECTOR
SUBJECT- PLN-21-00139 (GENERAL PLAN AMENDMENT) —THE CITY •; DOWNEY HOUSING ELEMENT UPDATE FOR THE 6 TH REGIONAL
• NEEDS ASSESSMENT (RHNA) ALLOCATION CYCLE AND

CORRESPONDING INITIAL STUDY AND NEGATIVE DECLARATION
T4_T*7SNF!1i1,1 Jill, �b
,• 1� WIN!" I I i I :iiiii 11 •
This is a -• to re -adopt the 2021-2029 General Plan Housing Element Update (HEU) • • • requested by the California Department •: Housing and • Development (HCD.) Comments from HCD consist of additional clarification for items related to fair housing and potential development constraints.

Pursuant • • State law, each city and • `• a state -certified Housing Element that must be updated and adopted every eight years in accordance with a specific schedule 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 HEU in compliance with many State laws that have been adopted in recent years. The HEU covers the planning period of October 15, 2021 through October 15, 2029 and identifies r.trategies and programs to encourage the development of a variety of housing opportunities for 911 reside -its.

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periods, and a study session. The next steps in this process include • Council action and further engagement with HCD to obtain a final certified Housing Element in accordance with State law.

Attachment 'T"

Based on the analysis contained in this report, staff is recommending the Planning Commission adopt the following titled resolution:

The Housing Element is a State -mandatory Element of the City's General Plan. This element 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 H was prepared in response to those requirements with the goal of retaining conditions and polI directives unique to the City of Downeyup . The current Housing Element date will cover the period of October 15, 2021 through October 15, 2029 also known as the 6 th Cycle Housing Element update. The Housing Element must plan for the City's Regional Housing Needs Assessment (RHNA) Allocation of 6,525 housing units.
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An analysis of existing and projected housing needs;
An analysis of potential constraints on housing;
An analysis of assisted housing developments that are "at -risk" and eligible to change from low-income housing uses;
An inventory of sites suitable for housing development; An analysis of the plan's conformance with Affirmatively Furthering Fair Housing (AFFH) requirements;
An analysis of any special housing needs;
An analysis of opportunities for residential energy conservation; An evaluation of the previous Housing Element; and
Goals, objectives, policies, and implementation programs.

The Planning Commission previously deliberated, and approved, the 2021-2029 General Plan HEU on January 19, 2022. As is the case with many jurisdictions throughout the State, HCD provides final reviews and certifications regardless if the document has been adopted. HCD provided further comments and request for clarifications on February 18, 2022. Since receiving the letter from HCD, staff has periodically collaborated with the state and submitted portions of the revised HEU in order to gain feedback before officially submitting. The City made modifications to the existing HEILI and submitted for additional HCD review on September 12, 2022.
- 0 -
2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 October 5, 2022 - Page 2

needs of all Downey residents through 2029. The updated Housing Element is supported by greater detailed information within the text and appendices in Exhibit C. Added clarification and descriptions of the overall project can be found in the January 19, 2022 Planning Commission Staff Report in Exhibt B.

The following sections detail comments provided by HCD after their review of the previously adopt HEU, and the sections that were modified by staff in order to address HCD comments.

Affin-natively Furthefit7g Fair Housing L' i �
AFFH refers to meaningful actions that address significant disparities in housing needs and access to opportunity/resources.AFFH further aims replace segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity. The duty to affirmatively further fair housing extends to all of the City's activities and programs relating to housing and community development.

In an effort to meet this objective, all policies and programs found within the HEU allow for equal allowances and opportunities throughout the City regardless of location within the City. In addition, when selecting opportunity sites for additional development the City's methodology purposefully excluded single family properties. This was done to preserve the City's single family character to the greatest extent possible. Those protections are extended to all single family residents with no other criteria taken into acount. Historically the City of Downey's development patterns differ among separate parts of the City. In particular, over concentration and over payment for housing is experienced predominently south of Firestone Boulevard. This is largely due to previously common discriminatory real estate practices, during the midcentury, which prohibited homeowners and landlords from selling or leasing to individuals of a particular race or social economic standing. At the time, this practice was common throughout the country.

Additionally, larger densities and more development occurred south of Firestone Boulevard due to an abundance of vacant industrial land after the shut down or relocation of the City's aerospace industry. Many of the properties experienced turnover into commercial and residential lots. The policies and programs within HEU aim to combat the over development of any specific area, and provide the same opportunities in all parts of the City.

Lastly, an important practice in ensuring fair housing is effective community involvement and communication with all members of the public. Additional information was provide in the latest version of the HEU describing the City's public outreach efforts and translation resources.

I ev°eio rrrent Constraints
Among the major objectives and interest of HCD is the removal of governmental and non- governmental constriants. Specifically, the City must consider and eliminate potential contraints that may hinder the implamentation and execution of the policies and programs within the HEU.

The City aims to accomplish this objective by eliminating administrative processes, providing incentives, and easing development standards. All multifamily development will be subject to the City's administrative review process, rather than the current Site Plan Review process. Site Plan Reviews are subject to Planning Commission approval, and experience a 4 months minimum review time. Administrative Permits, alternatively, are subject to City Planner approval and have a minimum review time of 30 days.
2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 October 5, 2022 - Page 3

In regard to development standards, parking regulations will be closely reviewed when the policies and programs of the HEU are codified. The objective is to apply parking standards that better reflect demonstrated need and take into account unit sizes and bedrrom count.

Development incentives include the elimination of fees for lot consolidation. Lot consolidation may make development easier onspecific lots, orgroup lots that currently cannot bedeveloped.

Lastly, the lack of appropriate infrastructure capacity is also categorized as a potential constraint. The rmxieimd HEU provides confirmation from the Cih/'o Public Works Department that the City's current water and sewer infrastructure would meet the demands of the proposed

6.525 units required by RHy4A. In regards towater infraatructune, appropriate capacity in anticipated with the proper installation of up to date conservation fixtures, landscaping, and irrigation requirements per the latest plumbing and building code in effect atthe time ofthe development and also maximized use of recycled water where available. In regards to emw/age, when new development does occur it may be required to install larger fittings and pipes to connect 10City main lines dependaentupon the size ofadevelopment.

FINDINGS
Pursuant to Municipal Code Section 9834.08, there are four findings that must be adopted prior to approving the General Plan Amendment. The findings are as follows:

The project is in conformance with all other applicable objectives, poiciem, and programs specified in the City's General Plan. Additional general plan amendments and zone changes will be executed inorder tomeet the policies and goals oYthe Housing Element Update. Staff will continue to ensure that those actions remain consistent with the overall General Plan. In addit|on, in order for the City to remain in compliance with state !oxv governing the overall General Plan and Housing Element, the City is required to perform periodical updates every eight years. State |ovv 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 Y./.2- Provide an appropriateamount ofland area &oabsorb the Citvbfuture population growth.

Program Y.Y. 2.1.-
Identify areas 8oabsorb population growth and support additional FrooramtY.2.2.-
Designate parts ofthe City assecond unit development areas to absorb the d for additional housing.

Pnyonsnn 1.1.2.3.-
Promote housing projects andnn/xwo-umsprojects8hmt/nnl/de housing within areas designated for the downtown area, transit - oriented developments, and areas /n the vicinity of the Downey Landing project
Goal 1.2.-
Advance livable community concepts.

Policv1. 2. 1.-
Promote livable communities concepts that allow added flexibility /n addressing land use needs.
2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139

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.
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traffic corridors. This inclu es large commercial sites such as the Stonewood Mall, 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.

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.

Lastly, the workshop, surveys, and all outreach material was accessible to both English and Spanish speakers.

Goal t4-Protect and enhance the residential
Policy Y.4.2.'Promote residential construction that complements existing neighborhoods.

Program Y.4.2. 1. - Discourage residential construction not in harmony with the surrounding neighborhood.

Future development resulting from the goals of the proposed Housing Element will occur along the City'amajor oorhdonaond|argenmnnmnencia|apaneoxvheneitinnnonenonnootibha with high density development. TheC|h/'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 ofthe Citv'e identity making up 57.196 of all homes. It remains a priority to preserve that identity. U|UnnG0B|y, single-family lots will more appropriately help meet housing needs bvincreasing housing stock via AC>Us.

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. Thermfome, no projects are authorized or approved by this action. Future projects, inc|ud|n8zone&em1annendnmenteondnevxhous|ngun|ts.mi||be evaluated through the appropriate review process, and potentially subject tofurther environmental review.

The Housing Element was reviewed for compliance with the California Environmental Quality Act. Aoe|n, because no physical construction is proposed, the analysis is based on ahypothetical development scenario for the Inventory Sites identified inthe 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 general welfare and serves the goals an1 purposes of this article.

The goals and policies found within the proposed Housing Element include: providing housing at all income levels, providing housing specificallyfor 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 ofthe community. |nterms mffuture development, through the sites inventory analysis aheavy emphasis was placed indetermining 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 of the Housing Element does not alter any provisionsof the 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. 2021-2029 Housing Element Update
General Plan PLw-21-00139

The purpose ofthe Downey Municipal Code iatobeinaccordance with the comprehensive General Plan.

In accordance with the provisions of the California Environmental Quality Act (CEQA). on Initial Study for environmental impacts was prepared for the proposed project. Thisonwironmenta| review imanalyzed sda"program |evm|^.rather than sto"project |eve|^becauoathee*ionu request for physical development, and the proposed Housing Element remains consistent with the other elements found within the Cih/'s General Plan at this time. Therefone, this environmental review tiers off of the City's broader General Plan Environmental Impact Report.

However, future development and changes tothe General Plan os aresult ofthe Housing Element Update may besubject toanew and separate CECJAreview process.

The initial study finds that the project vvnu|dheVe''|emmthaneignifinontinnpacts^.andaNegeUxe Declaration will be filed. A copy of the Initial Study/Negative Declaration (IS/ND) is attached to this report as Exhibit D. A 30-day public comment period for the proposed IS/ND was provided starting November 1, 2021 and ended on November 30, 2021. The recent update to reflect HCD comments did not result in any changes to the environmental assessment.

CORRESPONDENCE
OnSeptember 22.2022.notice of the pending public hearing was published inthe Downey Patriot ema 1/8mpage edand noticed etdesignated Cdvfaci|itiee.inaccordanoevviththe requirements ofthe Downey Municipal Code. In addition, Planning staff posted the notice onthe project -designated webpageadvertised nnthe City'ssocial media platforms. As of the date that this report was printed, the City has not received any correspondence regarding this report.

CONCLUSION
Based onthe 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. January 19.2D22Planning Commission Staff Report
C. 0mCycle 2O21-2D29Housing Element
O. HCC) Letter dated November 10. 2021 and City Responses E. Initial Study/Negative Declaration
oou1-2oun Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration PLm'21*0139

DATE:

TO:

SUB77ED BY:

WRL MINI IF] PT1351]
W A
ALDO E. SCHINDLER, DEPUTY CITY MANAGER/COMMUNITY

DEVELOPMENT
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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
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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 schedule of dates established by the State. The Housing Element must demonstrate the City's ability 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 recent years. The HEU covers the planning period of October 15, 2021 through October 15, 2029 and identifies strategies and programs to encourage the development of a variety of housing opportunities for all residents.

The proposed HEU has been an ongoing, 19-month long, project which included community engagement through virtual public workshops, an online community survey, public commenting 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.

Ir
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

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directives unique to the City of Downey. The current Housing Element update will cover the period of October 15, 2021 through October 15, 2029 also known as the 6 th Cycle Housing Element update. The Housing Element must plan for the City's Regional Housing Needs Assessment (RHNA) Allocation of 6,525 housing units.

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• An analysis of existing and projected housing needs;
• An analysis of potential constraints on housing;
• An analysis of assisted housing developments that are "at -risk" and eligible to change from low-income housing uses;
• An inventory of sites suitable for housing development; • An analysis of the plan's conformance with Affirmatively Furthering Fair Housing requirements;
• An analysis of any special housing needs;
An analysis of opportunities for residential energy conservation; An evaluation of the previous Housing Element; and
Goals, objectives, policies, and implementation programs.

On January 6, 2022, notice of the pending public hearing was published in the Downey Patriot as a 1/8th page ad in accordance with the requirements of the Downey Municipal Code. 79�*
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and a housing plan. The housing plan within the HEU builds 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.

RegLional Housing Needs Assessment,tEYNA2
The California Department of Housing and Community Development (HCD) assesses and determines the existing and projected need for housing within throughout all regions of the state. The RHNA numerically allocates the future housing need by household income group for each locality within the region. Once HCD determines the regional allocation for the Southern California region, the Southern California Association of Governments (SCAG) distributes a RHNA allocation 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 a RHNA allocation of 6,525 housing units. Table 2.8 (below) taken from the Housing Element Update, illustrates the income distribution for the City's overall RHNA allocation. 2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 January 19, 2022 - Page 2

Table 2.8: Regional Housing Needs Allocation 2021-2029
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6,152S
100 9 6
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 AETthat its housing plans, policies, and zoning can facilitat 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 t 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 uni 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 commu it wa See A
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• 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.

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2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 January 19, 2022 - Page 3

redeveloped but, it is required to show that there is viability for meeting the required RHNA. TIM following criteria was applied to identify sites with potential for new development or recycling opportunities: I
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 Summa
Sites Currently Available (including
;
estimated S®
Sites to be Rezoned
ia
1691-2029 RHNA
...... . . .....

As shown in this report, Figure 4.2, from the HELI, encompasses the overall sites that the City has identified in order to meet the sixth cycle RHNA allocation. 2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 January 19, 2022 - Page 4

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General Plan Amendment and Initial Study and Negative Declaration - PL-21-00139 January 19, 2022 - Page 5

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 in the City and meet State law housing requirement. These goals and policies were informed by recent community input, the housing needs assessment (Chapter 2 ofHEU). housing constraints analysis (Chapter 3 of HEU), housing resources analysis (Chapter 4 of HEU), 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 to make 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 |avv 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.

Implementation
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 HCC)for review on September 15. 3021 and a response with comments from HCDwas received mnNovember 1O.2O21. 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 byHCDand resubmitted the document toHCDfor final review onDecember 22.2D21.

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 to apply a residential overlay OO major commercial corridors within the City. This phase will include the establishment of development standards specifically for corridors to identify a||nvvab|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.

Publi treach and Ea
Public participation plays a Key role in the development ofall City antinne, and efforts were made for that 1m remain true during this Housing E|ennmn1 update. In addition, as required by state law the Housing Element must reflect the values and preferences of the community.

Section 655G3(o)(6)(B)ofthe 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 nu1nemoh not only included neaidento, but also coordinated participation among local agencies and housing groups, community organizations, and housing sponsors. A list of agencies and 2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration PLm'21*0139 January 19.2022 Page

organizations invited to the workshop are listed in AppendixAofthe 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 vxebcemn due tothe C(]\/|[)-19 pandemic. Although the City was precluded from hosting traditional in -person meetings, there was a positive turn -out of 116 participants over both virtual meetings. In addition tOthe community meetings, individuals were also given an opportunity to participate via an online survey. A City webpage was exclusively dedicated to the Housing Element allowing individuals toobtain up-to-date information and documents, including information for how 10 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 (A[>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 spoces, instead single-family zones.
• Having a future orientation to support young people growing up in Downey and young families who want to stay in the City.
• Support lower income and rent -burdened households
Lastly, the City utilized a variety of public outreach outlets including social nnedie, mobile epp|icabone, f|yerm, direct ennei|e. Cib/xvebeite and newspaper. All outreach materials and meeting were accessible toboth English and Spanish speakers. The community input identified above served as a guide throughout the update process and was used to inform development of all programs within the Element.

FINDINGS
Pursuant toMunicipal Code Section 9034.D0.there are four (4)findings that must beadopted prior toapproving the General Plan Amendment. The findings are eafollows:

A. Consistency. The proposed General Plan Amendment |s consistent with all other goals, poUicies, programs, and land uses of applicable elements of the General Plan.

The project is in conformance with all other applicable objectives, policies, 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 tmensure that those actions remain consistent with the overall General Plan. In add|t|mn, in order for the City to remain in compliance with state |ow/ governing the overall General Plan and Housing Benment, the City iorequired tm perform periodical updates every eight years. State law requires the housing element to address the following key topics: 1\ housing needs, 3\ 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:
uoo1-2uoo Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration puw-21*0139 January 19.2022 Page

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.
2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 January 19, 2022 - Page 8

Lastly, the workshop, surveys, and all outreach material was accessible to both English and Spanish speakers.

Goal 1.4 - Protect and enhance the residential neighborhoods.

Policy 1.4.2.- Promote residential construction that complements existing neighborhoods. 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.
v. Adverse Effects. The proposed General Plan Amendment will not adversely affect surrounding properties or the surrounding environment.
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 through the appropriate review process, and potentially subject to further environmental review.

The Housing Element was reviewed for compliance with the California Environmental 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 general welfare and serves the goals and purposes of 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 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. Conflicts. The proposed General Plan Amendment will not conflict with provisions of this article, including the City's subdivision ordinance. 2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 January 19, 2022 - Page 9

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.
• ANALYSIS
In accordance with the jtrovisions of the California Environmental *,ualito Act fCE—RA) an Initial Study for environmental impacts was prepared for the proposed project. This environmental review is analyzed at a "program level", rather than at a "project level" because there is no request for physical development, and the proposed Housing Element remains consistent with the other elements found within the City's General Plan at this time. Therefore, this environmental review tiers • • the City's broader General ■ Environmental Impact -r• 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 would have "less than significant impacts", and a Negative Declaration will be filed. A copy of the Initial Study/Negative Declaration (IS/ND) is attached to this report as Exhibit D. A 30-day public comment period for the proposed IS/ND was provided • November 1, 2021 and •-• • November 30, 2021.

CORRESPONDENCE
On January 6, 2022, notice of the pending public hearing was published in the Downey Patriot as a 1/�h •.•- .• and noticed at designated City facilities, in accordance with the -• • the Downey Municipal ••- In addition, Planning staff posted the notice • the project - designated webpage (MNAAdWneVcaoro/heupdPLe), and advertised on the City's social media • As of the 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. • th Cycle 2021-2029 Housing Element
C. HCD Letter dated November 10, 2021 and City Responses D. Initial Study/Negative Declaration
2021-2029 Housing Element Update
General Plan Amendment and Initial Study and Negative Declaration - PLN-21-00139 January 19, 2022 - Page 10

I to $] k, 101 :?-1 1:

FROM: OFFICE OF THE CITY MANAGER
BY: ALDO E. SCHINDLER, DEPUTY CITY MANAGER / COMMUNITY

DEVELOPTTEVT
SUBJECT: ADOPT 2021-2029 HOUSING ELEMENT UPDATE AND CORRESPONDING

CALIFORNIA ENVIRONMENTAL QUALITY ACT INITIAL STUDY/ NEGATIVI DECLAR4 M'N
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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 schedule of dates established by the State. The Housing Element must demonstrate the City's ability to accommodate the projected future housing need for the community. 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 recent years. The HEU covers the planning period of October 15, 2021 through October 15, 2029 and identifies strategies and programs to encourage the development of a variety of housing opportunities for all residents.

Attachment "11"

units. Table 2.8 in the Housing Element, and included below for reference, illustrates the income distribution for the City's overall RHNA allocation.

Table 2.8: Regional Housing Needs Allocation 2021-2029
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 35,838 units housing stock 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 accommodate 6,525 housing units. This was a challenge due to current built -out conditions within the City. The first step was assessing development projects currently proposed or under review; 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. When opportunities near transit corridors and maintaining the character of existing residential The sites inventory identified inChapter 4ofthe Housing Element encompasses sites within existing residential zones and sites that require rezoning actions; these sites total 7.414units, J.477unit ofwhich are inthe very low- and low-income F<HNAcategories. Therefore, the City can adequately accommodate the R|HNAafter rezoning actions are completed. Table 4.5ofthe Housing Element update, provided below for reference, shows a shortfall of 517 low-income units but those can beaddressed with the surplus ofsite capacity inthe very low-income category.

Ell I 1 1 .M*Ib-fftb-ELEJTfER-F#PDATE
FEBRUARY 8, 2022
PAGE 3
Sites Currently Available ii
estimated ADU pro
Sites to be Rezoned
Total Sites
y RHAM
oil a -So 0 . - • •. - / -
-

GENERAL L - 2021-2029 HOUSINGELEMENT UPDATE

FEBRUARY ,
2022
PAGE 4
Base Map Features ApprovedIY.-. Projects (Credits) Sites To Be) 1.

Downey City Boundary is= Approved or Proposed Projects MDR/R3 Sites to Rezone Parlm and •pen Space Sites Currently in Place Mixed -Use. Rezone Rivers and Waterbodies VM Vacant and Underutilized Rl Commercial I. Plan Sites , .. , .IM Vacant and Underutilized R2 Residential Overlay Sites JWW Downtown Downey Residential Overlay,

GENERAL PLAN AMENDMENT —2O21-2O28HOUSING ELEMENT UPDATE FEBFlUARY0.2D22
PAGE 5
In Chapter 6 of the Housing Element, the Housing Plan, provides goake, ooicies, and programs for high -quality housing development. These have been established to address housing issues inthe City and meet State law housing requirements. These goals and policies were informed byrecent community input, the housing needs assessment (Chapter 2 ofHEU). housing constraints analysis (Chapter 3 ofHEU). housing resources eno|yaio (Chaptar4 of HEU), and the review of program accomplishments from the previous (2014-2021) Housing Element (Chapter 5ofthe MEU).Overall, the Housing Plan ismade upoffive goals, 29policies, 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 |evv housing requirements. Programs generally include o statement ofspecific 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.

The draft HEUwas submitted toHCDfor review onSeptember 15.2021and aresponse with comments from HCDwas received onNovember 1O.2O21.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 bvHC[Jand resubmitted the document toHCC>for final review onDecember 22.2021.

On January 19, 2022, the Planning Commission held a duly noticed public hearing to review and consider the General Plan Amendment. After considering all written and oral testimony, the Planning Commission adopted Resolution No. 21-3158, bva4-O-1 vote with one commissioner abstaining and the remaining four |nfavor. The Resolution recommends that the City Council adopt the General Plan Amendment for the 2021-2029 Housing Element and corresponding Initial Study/Negative Declaration.

After adoption and certification of the Housing Element Update, there will beneed fora 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 to apply a neeidGnU8| overlay on major commercial corridors within the City. This phase will include the establishment of development standards specifically for corridors to identify a||ovvob|e building he|ghte, building ort|cu|ation, and design standards. These amendments will incorporate public comments and be presented to the Planning Commission and City Council for consideration and action.

GENERAL PLAN AMENDMENT —2O21-3029HOUSING ELEMENT UPDATE FEBRUARY8.2O22
PAGE
Public participation plays a key role inthe developmentofall City actions, and efforts were made for that bm remain true during this Housing Eh*rnant update. Public outreach not only included nasidentn, but also coordinated participation among local agencies and housing gnoups, community organizations, and housing sponsors. A list nfagencies 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, one Planning Commission study session, and another presentation for Planning Commission recommendation. 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 webcam due to the COVID-19 pandemic. Although the City was precluded from hosting traditional in -person rnaedingo, there was a positive turn -out of 110 participants over both virtual meetings. In addition to the community nnee{ings, individuals were also given an opportunity to participate via an online survey. A City mxabpogewas exclusively dedicated to the Housing Element allowing individuals to obtain up -to -data 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 A\[}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 epmoes, instead single-family zones.
� Having a future orientation to support young people growing up in Downey and young families who want to stay in the City.
� Support lower income and rent -burdened households
Lastly, the City utilized a variety of public outreach outlets including social media, mobile applications, flyers, direct emails, City website and newspaper. All outreach materials and meeting were accessible to both English and Spanish speakers. The community input identified above served as a guide throughout the update process and was used to inform development of all programs within the Element.

GENERAL PLAN AMENDMENT — 2021-2029 HOUSING ELEMENT UPDATE FEBRUARY 8, 2022
PAGE 7
Pursuant to Municipal Code Section 9834.08, there are four (4) findings that must be adopted prior to approving the General Plan Amendment. The findings are as follows:

The project is in conformance with all other applicable objectives, policies, 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 addition, in order for the City to remain in compliance with state law governing the overall General Plan and Housing Element, the City is required 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.

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.

GENERAL PLAN AMENDMENT —2021-2028HOUSING ELEMENT UPDATE FEBRU8RY8.2O22
PAGE
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 tocomply with State regulations related to Accessory Dwelling Units (ADU), formerly known as Second Unit Developments. It is estimated that 930AC}Uawill be constructed during this Housing Element cycle.

Policy 1.3,2.—Monitor and address changes /nland use trends.

Program 1.3.2.Y.-Adopt acomprehensive update ofthe zoning chapter ofthe municipal code.

Program 1.3.2.2.-Adjust the nodes, policies, and regulations /n response to changes in land use trends.

New and evolving development is continuously introduced into the city, and it remains responsibility to analyze and determine the viability of these changes in the City of Downey. Some land use changes and trends discussed inthe Housing Element aim bz address low housing ptocN, afhondebi|dx, and development constraints. Aso neau|t, 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 ino|uoionGry housing policies.

Policy Y.4.t'Promote Neighborhood Identity.

Program 1.4.Y.4L-Promote public participation in the planning process.

Program 1.4.t5.-Provide public information Onways residents and property owners can improve their neighborhoods.

Public participation was vital in drafting the proposed documents. The City held two separate public outreach workshops and a Planning Commission Study Session where residents were invited to attend and share their thoughts. In addition to nonnnnun|tv rnmet|ngs, residents and stakeholders could also provide input via a community survey and receive information via the Housing Element Vvebpage. Atthe 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, eun1ainab||itv, parking/traffic, support for ADUs. and resources for vulnerable residents.

The information received at these meetings was incorporated into the proposed document.

Lastly, the workshop, surveys, and all outreach material was accessible to both English and Spanish speakers.

Goal Y.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 harmony with the surrounding neighborhood.

GERERAL PLAR ACTIEV%D[TIERT — 2021-2029 A01SIO%G ELEITlEil%T UPDATE FEBRUARY 8, 2022
PAGE 9
B. Adverse Effects. The proposed General Plan Amendment will not adversely affect surrounding properties or the surrounding environment. I I Me
't
action. Future projects, including zone text amendments and new housing units, will be evaluated through the appropriate review process, and potentially subject to further environmental review.

C. Public Health, Safety and Welfare. The proposed General Plan Amendment promotes the public health, safety, and general welfare and serves the goals and purposes of 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 general welfare of the community. In terms of future development, through the sites inventory most appropriate in relation to nearby land uses.

Conflicts. The proposed General Plan Amendment will not conflict with provisions of this article, including the City's subdivision ordinance. I 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.

In accordance with the provisions of the California Environmental Quality Act (CEQA), an Initi Study of environmental impacts was prepared for the proposed project and resulted in a Negative Declaration. This environmental review is analyzed at a "program level", rather than a "project level" because there is no request for physical development, and the proposed Housing Element remains consistent with the other elements found within the City's General Plan at this time. Therefore, this environmental review tiers off of the City's broader General Plan Environmental Impact Report. However, future development and changes to the Generall Plan as a result of the Housing Element Update may be subject to a new and separate CEQA review process. 'I

GENERAL PLAN AMENDMENT — 2021-2029 HOUSING ELEMENT UPDATE FEBRUARY 8, 2022
PAGE 10
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Efficiency & Adaptability
Public Engagement I
Auality of Life, Neighborhood and Infrastructui

FISCAL IMPACT
Attachment A — City Council Resolution
Attachment B — 6 th Cycle 2021-2029 Housing Element
Attachment C — HCD Letter dated November 10, 2021 and City Responses Attachment D — Initial Study/Negative Declaration
Attachment E — Planning Commission Resolution No. 22-3158 Attachment F — Planning Commission Staff Report

Downey City CouncilOctober 11, 2022

Downey City Council
October 11, 2022