Agenda packet — Escondido City Council, March 22, 2023 (part 4 of 6)

EXHIBIT “C”

THIRD ADDENDUM TO THE FINAL CERTIFIED

ESCONDIDO GENERAL PLAN UPDATE, DOWNTOWN SPECIFIC PLAN UPDATE, AND CLIMATE ACTION PLAN ENVIRONMENTAL IMPACT REPORT (SCH #2010071064)

TO AMEND THE GENERAL PLAN AND ADOPT
THE 2021-2029 HOUSING ELEMENT UPDATE; AND COMMUNITY HEALTH AND SERVICE

CHAPTER UPDATE

EXECUTIVE SUMMARY
Purpose and Background
This Third Addendum to the Final Certified Escondido General Plan Update, Downtown Specific Plan Update, and Climate Action Plan Environmental Impact Report (“Addendum”) has been prepared by the City of Escondido (“City”) in conformance with the California Environmental Quality Act (Public Resources Code section 21000 et seq.) (“CEQA”), the regulations promulgated thereunder (14 California Code of Regulations sec tion 15000 et seq.) (“CEQA Guidelines”), and the City’s Environmental Review Guidelines (Article 47 of the Escondido Zoning Code) to amend the General Plan, consisting of the following (collectively referred to herein as the “Project”):

1. A General Plan amendment to update the City of Escondido’s Housing Element for the 6th Cycle planning period from April 15, 2021 to April 15, 2029. The Housing Element, which is part of the City’s General Plan, is a policy document designed to provide the City a coordinated and comprehensive strategy for promoting the production of safe, decent, and affordable housing within the community . The City is able to meet its fair share of regional housing needs assessment requirement without any changes to Genera l Plan designations or densities allowed. Therefore, the 2021 -2029 Housing Element is consistent with the basic planning assumptions that were utilized to prepare the 2013- 2021 Housing Element. Approving the Project would repeal in its entirety the 2013-2021 Housing Element and adopting in full new text, graphics, and figures comprising the 2021- 2029 Housing Element to the General Plan.

2. A General Plan text amendment to update the Community Health and Services Chapter.

As part of its effort to address environmental justice goals, policies, and objectives, Civic Engagement goals in the Community Health and Services Chapter of the General Plan are being amended to include additional policies to expand outreach efforts to disadvantaged communities and target populations, particularly on issues that relate to social equity and health. Increased civic engagement provides a diverse perspective to inform future city policy and thus relates to all elements of the General Plan. Increased civic engagement in and of itself is therefore consistent with all other elements of the General Plan.
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The purpose of this Addendum is to provide updated information to the Final Certified Escondido General Plan Update, Downtown Specific Plan Update, and Climate Action Plan Environmental Impact Report (“Final EIR”). Section 15164(a) of the CEQA Guidelines states that “ [t]he lead agency or a responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred .” Section 15162 of the CEQA Guidelines provides that a subsequent EIR is required when (1) substantial changes are proposed in t he project or circumstances that will require major revisions of the prior EIR due to new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or (2) new information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the prior EIR was certified, shows that (a) the project will have one or more significant effects not discussed in the prior EIR, (b) significant effects previously examined will be substantially more severe than shown in the prior EIR, (c) mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project but the project proponents decline to adopt the mitigation measure or alternative, or (d) mitigation measures or alternatives that are considerably different from those analyzed in the prior EIR would substantially reduce one or more signifi cant effects on the environment but the project proponents decline to adopt the mitigation measure or alternative.

As discussed in the following sections, the new information and minor technical modifications are not considered “significant” pursuant to CEQA. Specifically, the Addendum to the Final EIR finds that the impacts resulting from implementation of the 2012 General Plan Update and the Climate Action Plan as described in the Final EIR, as well as the Downtown Specific Plan Update, remain the same, aside from the Project’s proposed modification, and the mitigation measures would remain unchanged and are still valid and enforceable . No considerably different mitigation measures or feasible alternatives have been identified. The Addendum to the Final EIR finds that the previously identified impacts and mitigation measures, as described in the Final EIR, are still applicable to the updated General Plan. Therefore, the Final EIR, as certified, remains adequate and complete. The Housing Element is one of the mandatory elements of the General Plan and is required by State law to be updated for the 2021 -2029 planning period (also called the 6 th Cycle planning period). State law requires the Public Safety Element, which is another mandatory element of the General Plan, to be updated upon revision of the Housing Element.

The City of Escondido has prepared a n update to the Housing Element to include an analysis required by State law related to: 1) existing demographics and housing characteristics; 2) market, government, and environmental constraints; 3) land, financial, and administrative resources available to meet housing demand; 4) establishment of goals and policies to address housing needs; and 5) a review of past accomplishments unde r the 2013 -2021 Housing Element. The City is able to meet its fair share or regional housing needs without any changes to General Plan designations or densities allowed. Revised policies are included in the 2021 -2029 Housing Element Update, updating existing major strategies and policies from the 2013 -2021 Housing Element, prepared for the 5th Cycle planning period.

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The Safety Element, which is called the Community Protection Chapter in the 2012 Escondido General Plan, addresses potential and existing hazards in the City, which are outlined in the following categories: Emergency Preparedness, Geological Hazards/Seismic Activity, Flood Hazards, Hazardous Material and Mining Hazards, Public Safety Services and Facilities, Fire Hazards and Protection, and Severe Weather Hazards. Among other updates, additional categories for Climate Change Resiliency and Mitigation must be added. These updates will be incorporated into a future General Plan amendment and are not part of this Project.

In addition, t he City is also required by Government Code section 65302(h) to include environmental justice goals , policies, and objectives in the General Plan when two or more elements of the General Plan are updated concurrently. Environmental justice is defined by the State of California as the “fair treatment and meaningful involvement of people of all races, cultures, incomes, and national origins with respect to the development, adoption, implementation, and enforcement of laws, regulations, and policies” (California Government Code section 65040.12(e)). Inclusion of these goals, policies, and objectives may be accomplished through adoption of a n Environmental Justice Element, or integration of related goals, policies, and objectives into other elements. Upon approval of the Project, certain environmental justice goals and policies will be integrated into the C ity’s Community Health and Services Chapter.

Additional environmental justice goals, policies, and objectives will be integrated into the Community Protection Chapter in a future General Plan amendment.

All such draft strategies and policies build upon, augment, or refine existing strategies and policies of the current General Plan, and they introduce no new policies that would conflict with existing General Plan elements having the most direct relation to allowable use and development, such as land use, circulation, or safety element policies. Si milarly, the 2021-2029 Housing Element did not eliminate any existing strategies for its programmatic approach to housing. Therefore, the Project may be approved as an activity covered within the scope of the Final EIR.

All other environmental analysis sections are not contained herein because the original Final EIR for those environmental areas are still applicable and do not require updated information. CEQA does not require that the original Final EIR be circulated with the Addendum, but the original Final EIR is available for public review from the City of Escondido upon request. Therefore, please refer to the original Final EIR for other environmental topics not contained in this Addendum.

1.0 Introduction

This section provides information related to CEQA and the revised analysis to the Final EIR, as it relates to the Housing Element Update . This s ection discusses the original Final EIR (SCH #2010071064), which was certified in 2012. This section provides background information on the need to provide updated infor mation to the original analysis in reference to the General Plan amendment.

1.1 Project Description:
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Pursuant to Go vernment Code section 65583, a H ousing Element is required to consist of an identification and analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives, financial resources, and scheduled programs for the preservation, improvement, and development of housing. Specifically, a Housing Element is required to contain the following:

 An assessment of housing needs and an inventory of resources and constraints relevant to the meeting of these needs (Government Code section 65583(a));  A statement of the community’s goals, quantified objectives, and policies relative to the maintenance, preservation, improvement, and development of housing (Government Code section 65583(a)); and
 A program that sets forth a schedule of actions during the planning perio d, each with a timeline for implementation of the policies and achieve the goals and objectives of the housing element (Government Code section 65583(c)).

The proposed draft 2021-2029 Housing Element consists of the following major components:

 A profile and analysis of the City’s demographics, housing characteristics, and exi sting and future housing needs.
 A review of the real or potential constraints to housing production and preservation.

Constraints include potential market, governmental, policy, and environmental limitations to meeting the City’s identified housing needs.
 An assessment of resources available to meet the City’s objectives regarding housing production and preservation.
 Strategies to address the City’s identified housing needs, including housing goals, policies, and programs, including changing housing needs, including preparation of a Regional Housing Needs Allocation (“RHNA”) plan (Government Code section 65584(a)).

A critical measure of compliance with Housing Element Law is the ability of a jurisdiction to accommodate its share of the regional housing needs based on a RHNA prepared by HCD for each Council of Governments in the state that identifies projected housing units needed for all economic segments based on Departme nt of Finance population estimates. The San Diego Association of Governments (“SANDAG”) is the Council of Governments for the San Diego region and allocates to the 18 cities and the unincorporated area of San Diego County their fair share of the total RHNA housing needed for each income category. Overall, the region needs to plan for an additional 171,685 units. The City’s share of the regional housing need for the 2021 -2029 RHNA period is allocated by SANDAG based on several factors, including recent growth trends, income distribution, and capacity for future growth. Each local government must demonstrate that it has planned to accommodate all its regional housing need allocation in its Housing Element.

Escondido’s share of regional future housing needs is a total of 9,607 new units for the period of April 15, 2021, to April 15, 2029. This allocation is divided into various income categories, of which 3,113 new units must be reserved for households in the low- and very low-income category.

The overall RH NA allocation process reflects a need for cooperation between both public and private sectors to expand housing opportunities that will allow for new housing development that 572
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benefits everyone in the community, such as a greater mix of housing types and choices. It allows local governments to maintain control over where and what type of development should occur in their communities, while allowing the private sector to meet market demand. While the Housing Element must contain a variety of community stati stics to frame future housing needs, pursuant to Government Code section 65583, all cities must accommodate their RHNA allocations in their Housing Elements by adopting land use plans that accommodate the minimum amounts of housing unit goals and RHNA allocations.

Housing Element Law requires that jurisdictions demonstrate in the Housing Element that the land inventory is adequate to accommodate that jurisdiction’s share. A jurisdiction may meet the RHNA requirement using potential development on suitable vacant and/or non-vacant sites within the community. A jurisdiction must document how zoning and development standards on the proposed sites facilitate housing to accommodate the remaining RHNA requirement. Government Code section 65863(c) requires the City to identify available sites for the rezone, in order to satisfy its RHNA obligations, but also contains procedures for the City to follow in the event that a site becomes unavailable. To ensure that the City monitors its compliance with SB 166 ( “No Net Loss”), the City will monitor the consumption of residential acreage to verify an adequate inventory is available to meet the City’s RHNA obligations. To ensure sufficient residential capacity is maintained to accommodate the RHNA, the City will deve lop and implement a formal ongoing (project-by-project) evaluation procedure pursuant to Government Code section 65863. If an approval of development results in a reduction of capacity below the residential capacity needed to accommodate the remaining nee d for lower income households, the City will identify (and, if necessary, rezone) sufficient sites to accommodate the shortfall and ensure “no net loss” in capacity to accommodate the RHNA. The City will maintain an inventory of available sites for residential development and provide it to prospective residential developers upon request. The parcel-by-parcel inventory is located in the Sites Inventory Appendix of the Housing Element.

Community Health and Services Chapter

SB 1000 (2016) requires cities and counties to integrate environmental justice goals, policies, and objectives into the General Plan upon the concurrent update to two or more elements. Although the Project only includes an update to the Housing Element, that update also requires the Safety Element to be updated, which will occur in the coming months. The proposed General Plan text amendment to the Community Health and Safety Chapter (optional element to the General Plan) directly relates to topics mandated for the environmental justice policies of the General Plan.

Environmental justice goals are achieved when everyone in the City has the same degree of protection from environmental and health hazards; a healthy environment in which to live, learn, and work; and equal access to the decision-making process. Environmental justice policies will be aimed at reducing health risks, promoting civic engagement, and prioritizing the needs of disadvantaged communities with implementable actions that achieve them.

1.1 California Environmental Quality Act:

CEQA requires that state and local government agencies consider the environmental consequences of projects over which they have discretionary authority before taking action on those projects (Public Resources Code sections 21000 et seq.). CEQA also requires that each 573
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public agency mitigate or avoid, wherever feasible, the significant environmental impacts of a project that it approves or implements. A significant impact is one that would lead to a substantial adverse change in the physical conditions of the environmental areas affected by the project.

An ElR is an informational document used in state, regional, and local planning and decision - making processes to meet the requirements of CEQA. The ElR for a proposed project must disclose environmental effects that cannot be avoided; growth-inducing effects; effects found not to be significant; and significant cumulative impacts of all past, present and reasonably anticipated future projects. In addition, an EIR must identify potential methods of avoiding or reducing effects (i.e., mitigation measures) and alternatives to the proposed project or program

1.2 Final EIR for the 2012 General Plan Update, Downtown Specific Plan Update, and Climate Action Plan:

The Final EIR add resses a full range of environmental issues associated with the 20 -year planning horizon of the 2012 General Plan (2035). The Final EIR was certified on May 23, 2012, by the Escondido City Council (Resolution No. 2012-53.) A Mitigation Monitoring and Reporting Program (“MMRP”); Findings of Fact including significant and unavoidable air quality, biological resources, noise, vibration, housing, traffic, and utilities impacts ; and a Statement of Overriding Considerations were also adopted at the same public hearing.

The Addendum constitutes the third addendum to the Final EIR. The first addendum to the Final EIR was prepared for the Downtown Specific Plan Density Transfer Program, which was adopted by City Council Resolution 08-62 on August 19, 2008. T he second addendum to the Final EIR was prepared for the Downtown Specific Plan amendment to address and remove ground -floor retail requirements; which as of this writing has not been reviewed or considered for adoption by the City Council.

1.3 Lead Agency and Discretionary Approvals:

This Addendum documents the City’s consideration of the potential environmental impacts resulting from the change in the project and explains the City’s decision that a subsequent EIR is not required. The City of Escondido is the lead agency and has approval authority over the Project and changes.

1.4 Documents Incorporated by Reference:

CEQA Guidelines section 1510 authorizes agencies to incorporate by reference other documents that provid e relevant data and analysis into their environmental documents . The following documents are hereby incorporated by reference within this Addendum, and all of these documents are considered part of the Final EIR.

• Draft Environmental Impact Report – City of Escondido General Plan Update, Specific Plan Update, and Climate Action Plan , Draft Environmental Impact Report, State 574
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Clearinghouse #2010071064 , prepared for the City of Escondido, by Atkins, dated January 10, 2012.

• Draft Environmental Impact Report – City of Escondido General Plan Update, Specific Plan Update, and Climate Action Plan, Draft Environmental Impact Report, State Clearinghouse #2010071064, prepared for the City of Escond ido, by Atkins, dated April 23, 2012.

• An Addendum to the previously adopted EIR for 2012 General Plan Update, Downtown Specific Plan Update , and Climate Act ion Plan, prepared for the City of Escondido, by Harris & Associates, dated March 1, 2019.

1.5 Document Availability:

The Office of the City Clerk is the custodian of the administrative record for the Final EIR. The administrative record is available for public review during normal business hours.

1.6 CEQA Requirements for Use of an Addendum:

Section 15160 of the CEQA Guidelines explains that there are several mechanisms and variations in environmental documents that can be tailored to different situations and intended uses of environmental review. These variations, including Subsequent EIRs, Supplemental EIRs, and Addenda, are not exclusive. “Lead agencies may use other variations consistent with the guidelines to meet the needs of other circumstances.” (CEQA Guidelines § 15160.)

Public Resources Code section 21166 sets the standard to determine whether another EIR should be prepared when an original EIR has been prepared. Section 21166 states:

When an environmental impact report has been prepared for a project pursuant to this division, no subsequent or supplemental environmental impact report shall be required by the lead agency or by any responsible agency, unless one or more of the following events occurs:

(a) Substantial changes are proposed in the project which will require major revisions of the environmental impact report.

(b) Substantial changes occur with respect to the circumstances under which the project is being undertaken which will require major revisions in the environmental impact report.

(c) New information, which was not known and could not have been known at the time the environmental impact report was certified as complete, becomes available.

Similarly, CEQA Guidelines section 15162 states:

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(a) When an EIR has been certified or a negative declaration adopted for a project, no subsequent EIR shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more o f the following:

(1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;

(2) Substantial changes occur with respect to the circumstances under which the project is undertaken, which will require major revisions of the previous EIR or Negative Declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or

(3) New information of substantial importance which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the Negative Declaration was adopted, shows any of the following:

(A) The project will have one or more significant effects not discussed in the previous EIR or negative declaration;

(B) Significant effects previously examined will be substantially more severe than shown in the previous EIR;

(C) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or

(D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

(b) If changes to a project or its circumstances occur or new information becomes available after adoption of a negative declaration, the lead agency shall prepare a subsequent EIR if required under subsection (a). Otherwise, the lead a gency shall determine whether to prepare a subsequent negative declaration, an addendum, or no further documentation.

(c) Once a project has been approved, the lead agency’s role in project approval is completed, unless further discretionary approval on that project is required. Information 576
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appearing after an approval does not require reopening that approval. If after the project is approved, any of the conditions described in subsection (a) occurs, a subsequent EIR or negative declaration shall only be prepared by the public agency which grants the next discretionary approval for the project, if any. In this situation no other Responsible Agency shall grant an approval for the project until the subsequent EIR has been certified or subsequent negative declaration adopted.

(d) A subsequent EIR or subsequent negative declaration shall be given the same notice and public review as required under Section 15087 or Section 15072. A subsequent EIR or negative declaration shall state where the previous document i s available and can be reviewed.

Thus, CEQA Guidelines section 15162 clarifies that a subsequent EIR or supplemental EIR is only required when "substantial changes" occur to a project or the circumstances surrounding a project, or "new information" about a project implicates "new significant environmental effects" or a "substantial increase in the severity of previously significant effects." In evaluating whether these thresholds are met, the key is to determine if any circumstances have changed enough to justify repeating a substantial portion of the environmental documentation process. If conditions do not justify a new or supplemental EIR, but minor additional or technical changes are appropriate to keep the document current and useful, an agency may prepare an addendum. (CEQA Guidelines § 15164).

Specifically, CEQA Guidelines section 15164 states:

(a) The lead agency or a responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred

(b) An addendum to an adopted negative declaration may be prepared if only minor technical changes or additions are necessary or none of the conditions described in Section 15162 calling for the preparation of a subsequent EIR or negative declaration have occurred.

(c) An addendum need not be circulated for public review but can be included in or attached to the final EIR or adopted negative declaration.

(d) The decision-making body shall consider the addendum with the final EIR or adopted negative declaration prior to making a decision on the project.

(e) A brief explanation of the decision not to prepare a subsequent EIR pursuant to Section 15162 should be included in an addendum to an EIR, the lead agency's required findings on the project, or elsewhere in the record. The explanation must be supported by substantial evidence.

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Here, the City has opted to prepare an Addendum to assess the minor modifications of the Project that have transpi red since preparation of the Final EIR. This Addendum will document the character of any changes or additions to support the determination to prepare an Addendum. It will also provide an opportunity to evaluate all components of section 15162 to determine if the Final EIR still reflects the full scope of the environmental impact. Where appropriate, citations to the Final EIR will be made, and assumptions made in the Final EIR will be evaluated for continuing validity.

1.7 Summary of Analysis and Findings:

Based upon the supporting checklist responses (Section 2), other than the minor changes to the Project in reference to map changes and text changes, the environmental effects associated with the changes in the Project do not require additional analysis beyond the analysis previously prepared and distributed in the Final EIR.

Pursuant to CEQA Guidelines section 15164 , the City of Escondido finds that only minor modifications are required and that none of the conditio ns described in Public Resources Code section 21166 or CEQA Guidelines s ection 15162 requiring preparation of a subsequent or supplemental EIR have occurred. More specifically, the City of Escondido has determined all of the following:

• There are no substantial changes to the Project that would require major revisions of the Final EIR due to new significant environmental effects or a substantial increase in the severity of impacts identified in the previous Final EIR.

• No substantial changes have occurred in the circumstances under which the project is being undertaken that will require major revisions of the Final EIR to disclose new significant environmental effects or that would result in a substantial increase in the severity of the impacts identified in the Final EIR.

• There is no new information of substantial importance, which was not known at the time that the previous Certified Final EIR for the proposed Project was circulated, indicating that:
o The Project will not have one or more significant effects not previously discussed in the Certified Final EIR;
o There are no impacts that were determined to be significant in the previous Certified Final EIR that would be substantially more severe. o There are no additional mitigation measures or alterna tives to the project that would substantially reduce one or more of the significant effects identified in the previous Certified Final EIR; and
o There are no additional mitigation measures or alternatives which were rejected that are considerably different from those analyzed in the previous Certified Final EIR that would substantially reduce any significant impact identified in the Certified Final EIR.
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2.0 Environmental Analysis

This section of the Addendum analy zes the potential environmental effects associated with the implementation of the Specific Plan Amendment to address the ground-floor retail requirement as compared to the environmental analysis provided in the Final EIR. Each environmental topic is organized first to identify the impacts and significance level determinations previously identified in the Final EIR , second to identify the impacts of the Project and whether new or increased severity of significant impacts would occur, and third to evaluate whether the Project would result in substantial changes in the circumstances or new information not previously identified in the Final EIR. This section provides substantial evidence to support the findings and basis to prepare the Addendum, which is that the Project would not create substantial changes, or bring to light new information of substantial importance that was not previously examined in the Final EIR, that would trigger the preparation of a subsequent or supplemental EIR as set forth in CEQA Guidelines sections 15162 and 15163. As such, the Addendum is consistent with the provisions of CEQA Guidelines s ection 15164because only minor changes and additions to the Final EIR are necessary to address the project.

2.1 Aesthetics:

The Final EIR previously identified the following impacts associated with aesthetics and determined the corresponding level of significance.

Issue 4.1-1 Scenic Vistas (Less than Significant)

Issue 4.1-2 Scenic Resources (Less than Significant)

Issue 4.1-3 Visual Character or Quality (Less than Significant)

Issue 4.1-4 Light or Glare (Less than Significant)

These less than significant impacts were addressed in Section 4.1, Aesthetics, of the Final EIR , on pages 4.1-1 through 4.1-50 under the headings noted above.

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no actual development is pr oposed as part of the Housing Element Update. However, implementation of the programs contained in the document would accommodate development required to meet the City’s regional housing needs assessment, which specifies a need for land appropriately zone d to facilitate the production of new housing.

Although the City does not build the housing, the Housing Element does create a plan and 579
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regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built.

The City’s update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, will identify issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives will be developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.

New land use development projects would implement the proposed Housing Element Update goals and policy text changes. Those future projects would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review.

All future projects would be required to adhere to relevant development standards and design guidelines contained in the City’s zoning ordinance. The potential impacts of any specific future residential development projects would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.

As described in the Final EIR Section 4.1, Aesthetics, Issues 4.1-1, 4.1-2, 4.1-3, and 4.1-4 would result in less than significant impacts resulting from the implementation of the Escondido General Plan Update (“GP 2012 Update”), Downtown Specific Plan Update (“DSP Upd ate”), and the Escondido Climate Action Plan (“E-CAP”). Implementation of the GP 2012 Update, DSP Update, and E -CAP would not obstruct existing views and resources by complying with existing regulations and the proposed GP 2012 Update and DSP Update policies. Implementation of the City’s Grading and Erosion Ordinance and General Plan update policies in the Resource Conservation Element would protect views of ridgelines by requiring development to comply with grading design guidelines for development on al l steep slopes, requiring slope analyses and visual analyses for development near skyline ridges, and prohibiting development on skyline ridges. Implementation of the GP 2012, DSP Update, and E -CAP, would have the potential to change the existing visual c haracter or quality in some areas of the City, but not degrade it.

Development consistent with the GP 2012 Update and DSP Update would be high quality development designed to be compatible with existing adjacent land uses. Additionally, there would not be substantial impacts in regards to lighting or glare, as all new development would be required to comply with the City’s outdoor lighting ordinance. Also, the GP 2012 Update and DSP Update include policies that require new development, including developme nt that would install reflective surfaces as part of the E-CAP implementation, to avoid light and glare impacts, including spillover light and incompatible glare. Therefore, impacts to Issues 4.1-1 through 4.1-4 would be less than significant. Based on the above discussion, the Project is not expected to result in new or more severe impacts to aesthetics. Refer to the Final EIR for the original environmental analysis for aesthetics.

2.2 Agricultural Resources:

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The Final EIR previously identified the f ollowing impacts associated with agricultural resources and determined the corresponding level of significance.

Issue 4.2-1 Conversion of Agricultural Resources (Less than Significant)

Issue 4.2-2 Land Use Conflicts (Less than Significant)

Issue 4.2-3 Indirect Conversion of Agricultural Resources

These less than significant impacts were addressed in Section 4.2, Agricultural Resources, of the Final EIR on pages 4.2-1 through 4.2-28 under the headings noted above.

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementati on of the programs contained in the document would accommodate development required to meet the City’s regional housing needs assessment, which specifies a need for land appropriately zoned to facilitate the production of new housing.

Although the City do es not build the housing, the Housing Element does create a plan and regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built.

The City’s update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, will identify issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives will b e developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.

As described in the Final EIR Section 4.2, Agricultural Resources, Issues 4.2-1, 4.2-2, and 4.2-3 would result in less than significant impacts resulting from the implementation of the GP 2012 Update, DSP Update, and the E-CAP. Implementation of the GP 2012 Update would result in the potential direct conversion of 1,846 acres of agricultural resources. However, the GP 2012 update 581
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provides multiple policies within various elements that promote preservation and encourage agricultural uses within the City. The E -CAP provides reduction measures that encourage agricultural efficiencies. Additionally, zoning designations would be made consistent with the GP land use designations with the adoption of the GP 2012 Update and would not impact any land under an existing Williamson Act Contract. Implementation of the GP 2012 Update policies and smart growth planning strategies would reduce the potential for agricultural resources to be converted to non-agricultural uses. Therefore, impacts would be less than significant under Issues

4.2-1, 4.2-2, and 4.2-3.

2.3 Air Quality:

The Final EIR previousl y identified the following impacts associated with air quality and determined the corresponding level of significance.

Issue 4.3-1 Air Quality Plans (Less than Significant)

Issue 4.3-2 Air Quality Violations – Direct and Cumulative (Significant and Unavoidable)

Issue 4.3-3 Sensitive Receptors (Less than Significant with Mitigation)

Issue 4.3-4 Objectionable Odors (Less than Significant)

These issues were addressed in Section 4.3, Air Quality, of the Final EIR on pages 4.3-1 through

4.3-40 under the headings noted above.

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementation of the programs contained in the document would accommodate development required to meet the City’s regional housing needs assessment, which specifies a nee d for land appropriately zoned to facilitate the production of new housing.

Although the City does not build the housing, the Housing Element does create a plan and regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built.

The City’s update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, will identify issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives will be developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communitie s. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
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As described in the Final EIR Section 4.3, Air Quality, implementation of the GP 2012 Update, DSP Update, and the E -CAP is consistent with the SANDAG projections accounted for in the Regional Air Quality Strategy ( “RAQS”) and the State Impl ementation Plan ( “SIP”). Future development would be required to demonstrate compliance with the strategies and measures adopted as part of the RAQS and SIP during the City’s environmental review process, as well as with the requirements of the City and/or the San Diego Pollution Control District ( “SDAPCD”) to reduce emissions of particulate matter. Therefore, impacts would be less than significant under Issue 4.3-1.

Annual construction emissions and operational emissions associated with future development under the GP 2012 Update would result in significant emissions of volatile organic carbons (“VOCs”), particulate matter 10 (“PM10”), and PM2.5. Realistically, yearly construction emissions for all pollutants may be greater or lower depending on how development is implemented. Future development under the GP 2012 Update would be required to comply with CARB motor vehicle standards, SDAPCD regulations from stationary sources and architectural coatings, and the GP 2012 Update goals and policies. Ad ditionally, the San Diego Air Basin ( “SDAB”) is a nonattainment area for the state standards for ozone, PM10, and PM2.5. Therefore, with the implementation of the GP 2012 Update, DSP Update, and E-CAP, there would be a cumulatively considerable impact for these pollutants. Mitigation measures Air -1 and Air -2 would be incorporated to mitigate these effects. While these measures and policies are intended to reduce impacts associated with air quality violations, these measures cannot guarantee that emissions would be reduced to a less than significant level. Therefore, even with the implementation of mitigation, impacts from construction and operation would remain significant and unavoidable under Issue 4.3-2.

Future development consistent with the GP 2012 Update, DSP Update, and E-CAP, would result in potentially significant emissions of diesel particulate matter (“DPM”) and toxic air contaminants (“TACs”). Land development projects are required to comply with AB 2588, SDAPCD RULE 1210, Toxic Air Contaminant Public Health Risks – Public Notification and Risk Reduction, and CARB standards for diesel engines. The GP 2012 Update Air Quality and Climate Protection Element requires future land uses to be sited according to CARB recommendations. However, CARB does not make specific recommendations for certain potential sources of TACS including waste transfer, industrial, medical, and research and development facilities. Incorporation of mitigation measures Air-3 and Air-4 would reduce potential impacts associated w ith exposure of sensitive receptors to TACs to less than significant under Issue 4.3-3. 583
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While odor sources are present within the GP 2012 Update and DSP Update planning areas, compliance with SDAPCD Rule 51 and the GP Update 2012 would ensure that a sub stantial number of sensitive receptors would not be exposed to objectionable odors. Therefore, impacts would be less than significant under Issue 4.3-4.

2.4 Biological Resources:

The Final EIR previously identified the following impacts associated with biological resources and determined the corresponding level of significance.

Issue 4.4-1 Special Status Species – Cumulative (Significant and Unavoidable)

Issue 4.4-2 Riparian Habitat and Other Sensitive Natural Communities – Cumulative (Significant and Unavoidable)

Issue 4.4-3 Federally Protected Wetlands (Less than Significant)

Issue 4.4-4 Wildlife Movement Corridors – Cumulative (Significant and Unavoidable)

Issue 4.4-5 Local Policies and Ordinances (Less than Significant)

Issue 4.4-6 Habitat Conservation Plans and Natural Community Conservation Plans (Less than Significant)

These issues were addressed in Section 4.4, Biological Resources, of the Final EIR on pages

4.41 through 4.4-40 under the headings noted above.

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementati on of the programs contained in the document would accommodate development required to meet the City’s regional housing needs assessment, which specifies a need for land appropriately zoned to facilitate the production of new housing.

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understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.

As described in the Final EIR Section 4.4, Biological Resources, implementation of the GP 2012 Update, DSP Update, and the E -CAP would have the potential to result in direct and indirect impacts to special status plant and wildlife species and their habitats, riparian habitats, sensitive communities, wildlife corridors, and native wild life nursery sites. Existing federal and state regulations and land use agreements prohibit the take of sensitive species without permitting from wildlife and limit the amount of habitat that can be impacted by new development. The goals and policies of th e GP 2012 Update included in the Resource Conservation Element, Community Health and Services Element, and Land Use and Community Form Element require projects with the potential to impact sensitive species to prepare a biological survey and mitigate any impacts that would occur. Appropriate mitigation is required to be determined through consultation with the wildlife agencies. Compliance with these goals and policies would lessen impacts from the GP 2012 Update, DSP Update, and the E-CAP under Issues 4.4-1, 4.4-2, and 4.4-4; however, a significant cumulative impact still exists for these issues. Adoption of the City’s Multiple Habitat Conservation Program ( “MHCP”) Subarea Plan would establish an implementation program to protect biological resources. Until the City has adopted this plan, these impacts would be cumulatively considerable.

Implementation of the GP 2012 Update, DSP Update, and the E-CAP would have the potential to result in impacts to federal wetlands from future development. However, future development that would potentially impact a wetland would be required to obtain permitting from federal and/or state regulations. Additionally, GP 2012 Update policies included in the Resource Conservation element would ensure impacts would be less than significant under Issue 4.4-3.

Future projects under the GP 2012 Update, DSP Update, and the E -CAP would be required to comply with all applicable sections of the City’s Zoning Ordinance, existing regulations, preservation agreements, and applicable habit at conservation plans and Natural Community Conservation Plans ( “NCCPs”) as well as policies in the GP 2012 Update. Therefore, impacts associated with conflicts with local polices and ordinances and habitat conservation plans and NCCPs would be less than significant under Issues 4.4-5 and 4.4-6.

2.5 Cultural and Paleontological Resources:

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The Final EIR previously identified the following impacts associated with cultural and paleontological resources and determined the corresponding level of significance.

Issue 4.5-1 Historical Resources (Less than Significant with Mitigation)

Issue 4.5-2 Archeological Resources (Less than Significant with Mitigation)

Issue 4.5-3 Paleontological Resources (Less than Significant)

Issue 4.5-4 Human Remains (Less than Significant)

These issues were addressed in Section 4.5, Cultural and Paleontological Resources, of the Final EIR on pages 4.5-1 through 4.5-48 under the headings noted above.

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementation of the programs contained in the document would accommodate development required to mee t the City’s regional housing needs assessment, which specifies a need for land appropriately zoned to facilitate the production of new housing.

Although the City does not build the housing, the Housing Element does create a plan and regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built.

As described in the Final EIR Section 4.5, Cultural and Paleontological Resources, implementation of the GP 2012 Update, DSP Update, and the E -CAP would have potentially significant impacts to historical and archeological resources. Future development projects would 586
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have the potential to result in substantial adverse changes to the significance of archeological and historical resources through demolition, destruction, alteration, or structural relocation as well as disturbance of an important archeological site that contains or has the potential to contain information important to history or prehistory. While existing City and County policies and regulations and the GP 2012 Update and DSP Update goals and policies are intended to protect historical and archeological resources, the incorporation of mitigation measures Cul-1, Cul-2, Cul- 3, Cul -4, Cul -5, and Cul -6 are necessary to ensure the intended protections are achieved.

Therefore, with the inclusion of mitigation, impacts would be less than significant under Issues

4.5-1 and 4.5-2.

Future development under the GP 2012 Update, DSP Update, and E -CAP would have the potential to damage or destroy paleontological resources in the underlying rock units due to construction-related and earth -disturbing actions. The plan areas range from no potential to moderate potential for paleontological resources meaning it is possible for ground -disturbing activities to destroy fossil-bearing geologic formations. However, existing policies and regulations and the GP 2012 Update goals and policies (i.e. Goal 5 of the Resource Conservation Element and Policy 5.2) would protect unique paleontological resources. Therefore, impacts would be less than significant under Issue 4.5-3.

Implementation of the GP 2012 Update, DSP Update, and the E-CAP would have the potential to disturb human remains, including those located outside of formal cemeteries, due to ground disturbing activities from the development of land. However, compliance with existing federal and state policies and regulations (i.e. Health and Safety Code Section 7050.5 and Public Resources Code 5097.98) would reduce impacts associated with human remains to a level below significant under Issue 4.5-4.

2.6 Geology and Soils:

The Final EIR previously identified the following impacts associated with geology and soils and determined the corresponding level of significance.

Issue 4.6-1 Exposure to Seismic-Related Hazards (Less than Significant)

Issue 4.6-2 Soil Erosion or Topsoil Loss (Less than Significant)

Issue 4.6-3 Soil Stability (Less than Significant)

Issue 4.6-4 Expansive Soils (Less than Significant)

Issue 4.6-5 Wastewater Disposal Systems (Less than Significant)

These less than significant impacts were addressed in Section 4.6, Geology and Soils, of the Final EIR on pages 4.6-1 through 4.6-38 under the headings noted above.

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The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing progra m that was updated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementation of the programs contained in the document would accommodate development required to m eet the City’s regional housing needs assessment, which specifies a need for land appropriately zoned to facilitate the production of new housing.

Although the City does not build the housing, the Housing Element does create a plan and regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built.

New land use development projects would implement the propos ed Housing Element Update goals and policy text changes. Those future projects would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review.

All future projects would be require d to adhere to relevant development standards and design guidelines contained in the City’s zoning ordinance. The potential impacts of any specific future residential development projects would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.

As described in the Final EIR Section 4.6, Geology and Soils, Issues 4.6 -1, 4.6-2, 4.6-3, 4.6-4, and 4.6 -5 would result in less than significant impacts on geology and so ils with the implementation of the GP 2012 Update, the DSP Update, and the E-CAP. The GP 2012 Update would designate land uses that would allow development to occur in areas with geologic hazards such as seismically-induced ground shaking, liquefaction, an d landslides as well as impacts to topsoil, expansive soils, and wastewater disposal systems. Impacts from seismically induced fault rupture would not occur due to the lack of active fault traces in the area. Future development would be required to comply with all relevant federal and state regulations and building standards, including Seismic Design Categories E and F structural design requirements identified in the California Building Code ( “CBC”) and the National Pollutant Discharge Elimination System (“NPDES”) to control erosion of unstable soils. The GP 2012 Update also includes multiple policies intended to reduce seismic hazards, soil erosion, landslides, expansive soils, and soils incapable of adequately supporting the use of septic tanks. Compliance with these regulations and policies would reduce potential impacts to less than significant under Issues 4.61 through

4.6-5.

2.7 Greenhouse Gas Emissions:
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The Final EIR previously identified the following impacts associated with greenhouse gas emissions and determined the corresponding level of significance.

Issue 4.7-1 Compliance with AB 32 (Less than Significant)

Issue 4.7-2 Potential Effects of Global Climate Change on the Proposed General Plan Update (Less than Significant)

These less than significant impacts were addressed in Section 4.7, Greenhouse Gas Emissions, of the Final EIR on pages 4.7-1 through 4.7-30 under the headings noted above.

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementation of the programs contained in the document would accommodate development required to meet the City’s regional housing needs assessment, which specifies a need for land appropriately zoned to facilitate the production of new housing.

Although the City does not build the housing, the Housing Element does create a plan and regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built.

The City’s update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, will identify issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives will b e developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.

All future projects would be required to adhere to relevant development standards and design guidelines contained in the City’s zoning ordinance. The potential impacts of any specific futu re residential development projects would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.

As described in the Final EIR Section 4.7, Greenhouse Gas Emission s, Issues 4.7-1 and 4.7-2 would result in less than significant impacts from the implementation of the GP 2012 Update, DSP Update, and the E -CAP. Implementation of the GP 2012 Update, DSP Update, and the ECAP would be in compliance with Assembly Bill ( “AB”) 32, which sets reduction targets of statewide greenhouse gas (“GHG”) emissions to 1990 levels by 2020 or, as outlined in the AB 32 Scoping 589
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Plan, the functional equivalent of 15 percent below current (2005) levels. The GP 2012 Update and E -CAP incorporate s GHG -reducing policies and measures that would re duce the City’s emissions by 21% from the 2020 emissions inventory. (The E-CAP was recently amended on March 10, 2021, and the new GHG reductions target is 52% by 2035.) Additionally, future development consistent with the policies of the GP Update 2012 and the reduction measures of the E-CAP, particularly those measures designed to conserve water and reduce energy, would work to reduce the effects of global climate change. Therefore, impacts would be les s than significant under Issues 4.7-1 and 4.7-2.

2.8 Hazards and Hazardous Materials:

The Final EIR previously identified the following impacts associated with hazards and hazardous materials and determined the corresponding level of significance.

Issue 4.8-1 Transport, Use and Disposal of Hazardous Materials (Less than Significant)

Issue 4.8-2 Accidental Release of Hazardous Materials (Less than Significant)

Issue 4.8-3 Hazards to Schools (Less than Significant)

Issue 4.8-4 Existing Hazardous Materials Sites (Less than Significant)

Issue 4.8-5 Public Airports (Less than Significant)

Issue 4.8-6 Private Airports (Less than Significant)

Issue 4.8-7 Emergency Response and Evacuation Plans (Less than Significant)

Issue 4.8-8 Wildland Fires (Less than Significant)

These less than significant impacts were addressed in Section 4.8, Hazards and Hazardous Materials, of the Final EIR on pages 4.8-1 through 4.8-54 under the headings noted above.

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementati on of the programs contained in the document would accommodate development required to meet the City’s regional housing needs assessment, which specifies a need for land appropriately zoned to facilitate the production of new housing.

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The City’s update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, will identify issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives will b e developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.

As described in the Final EIR Section 4.8, Hazards and Hazardous Materials, issues 4.8-1, 4.8- 2, 4.8-3, 4.8-4, 4.8-5, 4.8-6, 4.8-7, and 4.8-8 would result in less than significant impacts with the implementation of the GP 2012 Update, DSP Update, and the E -CAP. Future businesses, operations, or facilities developed under the GP 2012 Upd ate, DSP Update, and the E -CAP, would involve an increase in the transport, use, and disposal of hazardous waste as well as potential accidental releases of hazardous waste. Additionally, there is potential for hazardous emissions and hazardous materials handling by future development within one-quarter mile of an existing or proposed school as well as human habitation or occupation on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5.

However, all future development allowable under the proposed land use designations identified in the GP 2012 Update would be required to comply with applicable federal, state, and local regulations related to hazardous materials and wastes. Therefore, impacts w ould be less than significant under Issues 4.8-1, 4.8-2, 4.8-3, and 4.8-4.

Future development with the implementation of the GP 2012 Update, DSP Update, and the ECAP would be predominantly low -density residential land uses or public land/open space with in two miles of public or private airports. These land uses have low concentrations of persons, which would reduce the risk of safety hazards for people residing or working in the area. Therefore, significant impacts would not occur under Issues 4.8-5 and 4.8-6.

The GP 2012 Update, DSP Update, and E -CAP does not include measures that would impair emergency response or evacuation plans. However, it is possible that land uses and development implemented under these plans would require the updating of these emergency response plans.

Compliance with existing regulations and continual updating of emergency response and evacuation plans would prevent implementation of the GP 2012 Update and DSP Update from impairing emergency response and evacuation plans. Impa cts would be less than significant under Issue 4.8-7.

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Implementation of the GP 2012 Update and DSP Update would result in land uses that allow residential, commercial, and industrial development in areas that are prone to wildfires due to a majority of the area being susceptible to wildland fires. However, compliance with existing regulations, including the Community Wildfire Protection Plan by the Escondido Fire Department, and implementation of the proposed General Plan Update policies within the Commu nity Protection Element would reduce impacts to a level below significant under Issue 4.8-8.

2.9 Hydrology and Water Quality:

The Final EIR previously identified the following impacts associated with hydrology and water quality and determined the corresponding level of significance.

Issue 4.9-1 Water Quality Standards and Requirements (Less than Significant)

Issue 4.9-2 Groundwater Supplies and Recharge (Less than Significant)

Issue 4.9-3 Erosion or Siltation (Less than Significant)

Issue 4.9-4 Flooding (Less than Significant)

Issue 4.9-5 Exceed Capacity of Stormwater Systems (Less than Significant)

Issue 4.9-6 Housing within a 100-Year Flood Hazard Area (Less than Significant)

Issue 4.9-7 Impeding or Redirecting Flood Flows (Less than Significant)

Issue 4.9-8 Dam Inundation and Flood Hazards (Less than Significant)

Issue 4.9.9 Seiche, Tsunami and Mudflow Hazards (Less than Significant)

These less than significant impacts were addressed in Section 4.9, Hydrology and Water Quality, of the Final EIR on pages 4.9-1 through 4.9-48 under the headings noted above.

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no a ctual development is proposed as part of the Housing Element Update. However, implementation of the programs contained in the document would accommodate development required to meet the City’s regional housing needs assessment, which specifies a need for land appropriately zoned to facilitate the production of new housing.

Although the City does not build the housing, the Housing Element does create a plan and regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built.
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The City’s update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, will identify issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives will be developed by identifying disadvantaged communities and demographics to better understand the unique a nd disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.

New land use development projects would implement the proposed Housing Elem ent Update goals and policy text changes. Those future projects would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review.

As described in the Final EIR Section 4.9, Hydrology and Water Quality, Issues 4.9-1, 4.9-2, 4.9- 3, 4.9-4, 4.9-5, 4.9-6, 4.9-7, 4.9-8, and 4.9-9 would result in less than significant impacts with the implementation of the GP 2012 Update, DSP Update, and the E-CAP. Construction and operation of future development under the GP 2012 Update and DSP Update would mandatorily comply with all applicable existing regulations including but not lim ited to the Clean Water Act, NPDES permit program, Porter -Cologne Water Quality Control Act, San Diego Basin Plan, City of Escondido water quality management plans, as well as policies proposed under the GP 2012 Update in the Resource Conservation Element, Community Protection Element, Mobility and Infrastructure Element, and Land Use Element. The plans would not utilize groundwater for any purpose and would, therefore, not deplete groundwater supplies. Further, the GP 2012 Update, DSP Updates, and measures identified in the E -CAP would not result in the placement of development in areas that would expose people to hazards associated with inundation by a tsunami, seiches, or mudflows. Therefore, impacts would be less than significant under Issues

4.9-1, 4.9-2, 4.9-3, 4.9-4, 4.9-5, 4.9-6, 4.9-7, 4.9-8, and 4.9-9.

2.10 Land Use:

The Final EIR previously identified the following impacts associated with land use and determined the corresponding level of significance.

Issue 5.10-1 Physical Division of an Established Community (Less than Significant)

Issue 5.10-2 Conflicts with Land Use Plans, Policies, and Regulations (Less than Significant)

Issue 5.10-3 Conflicts with HCPs or NCCPs (Less than Significant)

These less than significant impacts were addressed in Section 4.10, Land Use, of the Final EIR on pages 4.10-1 through 4.10-38 under the headings noted above. 593
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The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementation of the programs contained in the document would accommodate development required to meet th e City’s regional housing needs assessment, which specifies a need for land appropriately zoned to facilitate the production of new housing.

Although the City does not build the housing, the Housing Element does create a plan and regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built.

New land use development projects would implement the proposed Hou sing Element Update goals and policy text changes. Those future projects would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review.

All future projects would be required to a dhere to relevant development standards and design guidelines contained in the City’s zoning ordinance. The potential impacts of any specific future residential development projects would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.

As described in the Final EIR Section 4.10, Land Use, Issues 4.10 -1, 4.10-2, and 4.10-3 would result in less than significant impacts with the implementation of the GP 2012 Upd ate, DSP Update, and the E -CAP. The GP 2012 Update and DSP Update do not propose any new roadways or other specific features that would physically divide an established community.

Growth under the GP 2012 Update would be concentrated in 15 designated study areas and would not substantially change physical development patterns in established communities.

Development standards in the GP 2012 Update would ensure that new development would not preclude future development as long as it is consistent with the proposed land use plan. The DSP Update would retain the development standards that ensure compatibility with the character and vision for the downtown area. The GP 2012 Update, DSP Update, and the E -CAP would not conflict with ant HCPs or NCCPs and would comp ly with regulations set forth in the Resource Conservation Element in the GP 2012 Update. Therefore, impacts would be less than significant under Issues 4.10-1, 4.10-2, and 4.10-3.

2.11 Mineral Resources:

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The Final EIR previously identified the following impacts associated with mineral resources and determined the corresponding level of significance.

Issue 4.11-1 Mineral Resource Availability (Less than Significant)

Issue 4.11-2 Mineral Resource Recovery Sites (Less than Significant)

These less than significant impacts were addressed in Section 4.11, Mineral Resources, of the Final EIR on pages 4.11-1 through 4.11-14 under the headings noted above.

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementati on of the programs contained in the document would accommodate development required to meet the City’s regional housing needs assessment, which specifies a need for land appropriately zoned to facilitate the production of new housing.

The City’s update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, will identify issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives will b e developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.

As described in the Final EIR Section 4.11, Mineral Resources, Issues 4.11 -1 and 4.11-2 would result in less than significant impacts from the implementation of the GP 2012 Update, DSP Update, and the E-CAP. The existing GP 2012 Update, DSP Update, and E-CAP does not include any goals or policies specifically related to mineral resource s or mineral resource extraction.

However, if new mineral extraction facilities were to be approved, it would be required to comply with the goals and policies that apply to all development. The existing GP 2012 Update planning area is developed with land uses that limit the availability of mineral resources. Additionally, only 595
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a small portion of the planning area has been designated as containing known mineral resources of value. New development proposed near existing extraction facilities would be require d to demonstrate compatibility with existing land uses as part of project approval. Therefore, impacts would be less than significant under Issue 4.11-1 and 4.11-2.

2.12 Noise:

The Final EIR previously identified the following impacts associated with noise and determined the corresponding level of significance.

Issue 4.12-1 Excessive Noise Levels (Less than Significant)

Issue 4.12-2 Excessive Groundborne Vibration (Significant and Unavoidable)

Issue 4.12 -3 Permanent Increase in Ambient Noise Leve ls - Cumulative (Significant and Unavoidable)

Issue 4.12-4 Temporary Increase in Ambient Noise Levels (Less than Significant)

Issue 4.12-5 Excessive Noise Exposure from Airports (Less than Significant)

These issues were addressed in Section 4.12, N oise, of the Final EIR on pages 4.12 -1 through

4.12-54 under the headings noted above.

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementation of the programs contained in the document would accommodate development required to meet the City’s regional housing needs assessment, which specifies a nee d for land appropriately zoned to facilitate the production of new housing.

Although the City does not build the housing, the Housing Element does create a plan and regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built.

The City’s update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, will identify issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives will be developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communitie s. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.
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As described in the Final EIR Section 4.12, Noise, future development under the GP 2012 Update, DSP Update, and E-CAP would have the potential to expose noise -sensitive land uses (NSLU) and new commercial, office, and industrial land uses to excessive noise levels from existing roadway noise and noise related to existing commercial, industrial, and extractive land uses, and the Palomar Energy Center power plant. However, compliance with existing regulations such as the Noise Ordinance, and implementation of the GP 2012 Update’s goals and policies, including Noise Policies 5.1 through 5.4 and the Noise Compatibility Guidelines, would reduce impacts under Issue 4.12-1 to less than significant.

Construction of new land uses under the GP 2012 U pdate, DSP Update, and E -CAP and placement of new development in close proximity to the SPRINTER rail line would have the potential to result in impacts associated with excessive groundborne vibration. This includes significant impacts related to groundbor ne noise during construction and potential damage to buildings that may be susceptible to vibration damage from construction equipment. The potential also exists for cumulative construction projects to result in combined construction impacts if occurring simultaneously or construction activities in close proximity to the

SPRINTER line. The GP 2012 Update Noise Policy 5.5 requires compliance with the Federal Transit Administration (FTA) vibration criteria for construction that would occur under these plans.

However, additional mitigation is necessary to ensure proper setbacks are established. Mitigation measures Noi -1 and Noi -2 would be implemented to reduce direct and cumulative impacts associated with groundborne vibrations, but not to a less than signific ant level. Impacts would remain significant and unavoidable under Issue 4.12-2.

Future development and redevelopment consistent with the GP 2012 Update, DSP Update, and E-CAP would have the potential to substantially increase ambient noise levels above existing conditions as a result of increases in roadway noise and new operational noise sources. However, implementation of the GP 2012 Update Noise Policy, including Noise Policy 5.6 which requires technical reports be prepared for future development that would have the potential to substantially increase ambient noise levels, the Incremental Noise Impact Standards by the FTA, and the City’s Noise Ordinance would reduce direct impacts related to permanent increases in ambient noise to less than significant under Issue 4.12 -3. However, land use development in accordance with these plans would still contribute to cumulative future regional noise increases associated with roadway traffic. Two mitigation measures were identified to fully reduce impacts to below a level of significance but the City determined that these measures were infeasible.

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Future development under the GP 2012 Update, DSP Update, and E -CAP would have the potential to result in temporary increases in ambient noise levels due to construction of new land uses and infrastructure. However, existing City policies, the GP 2012 Update goals and Policies, and the City’s Noise Ordinance would reduce impacts to less than significant under Issue 4.12-4.

Future development under the GP 2012 Update, DS P Update, and E -CAP would not expose people residing or working in the GP 2012 Update area to excessive noise levels from a nearby public airport or private airstrip. Impacts would be less than significant under Issue 4.12-5.

5.13 Population and Housing

The Final EIR previously identified the following impacts associated with population and housing and determined the corresponding level of significance.

Issue 4.13-1 Population Growth (Less than Significant)

Issue 4.13-2 Displacement of Housing and People (Significant and Unavoidable)

These issues were addressed in Section 4.13, Population and Housing, of the Final EIR on pages

4.13-1 through 4.13-24 under the headings noted above.

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementati on of the programs contained in the document would accommodate development required to meet the City’s regional housing needs assessment, which specifies a need for land appropriately zoned to facilitate the production of new housing.

The City’s update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, will identify issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives will b e developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.

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residential development projects would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.

As described in the Final EIR Section 4.13, Population and Housing , implementation of the GP 2012 Update, DSP Update, and E -CAP would directly and indirectly induce population growth that is consistent with forecasted growth for these plan areas. The GP 2012 Update is a comprehensive plan to guide future growth and includes a framework for land use development, as well as goals and policies to prevent unanticipated or inappropriate population growth in the GP and DSP area. Compliance with the GP 2012 Update policies and regulations would reduce impacts to less than significant under Issue 4.13-1.

Future development under the GP 2012 Update, DSP Update, and the E-CAP would result in the displacement of substantial number of existing housing and people, necessitating the construction of replacement housing elsewhere. The GP 2012 Update land uses would displace up to 142 existing residential dwelling units and the GP 2012 Update’s proposed Mobility and Infrastructure Element would have the potential to displace up to 300 businesses and residences. Mitigation measure Pop-1 would be implemented to mitigate impacts related to the displacement of homes.

Despite compliance with existing regulations, implementation of the proposed GP 2012 Update policies, and mitigation measures Pop-1, the project’s direct impact would remain significant and unavoidable.

2.14 Public Services:

The Final EIR previously identified the following impacts associated with public services and determined the corresponding level of significance.

Issue 4.14-1 Fire Protection Services (Less than Significant)

Issue 4.14-2 Police Protection Services (Less than Significant)

Issue 4.14-3 School Services (Less than Significant)

Issue 4.14-4 Library Services (Less than Significant)

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was updated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementation of the programs contained in the document would accommodate development required to meet the City’s regional housing needs assessment, which specifies a need for land appropriately zoned to facilitate the production of new housing.

Although the City does not build the housing, the Housing Element does create a plan and 599
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regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built.

The City’s update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, will identify issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives will be developed by identifying disadvantaged communities and demographics t o better understand the unique and disproportionate challenges faced by these communities. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.

All future proje cts would be required to adhere to relevant development standards and design guidelines contained in the City’s zoning ordinance. The potential impacts of any specific future residential development projects would be assessed at the time when the projects are actually proposed, and mitigation measures would be adopted as necessary, in conformance with CEQA.

As described in the Final EIR Section 4.14, Public Services, Issues 4.14-1, 4.14-2, 4.14-2, 4.14- 3 and 4.14-4 would result in less than significant impacts resulting from the implementation of the GP 2012 Update, DSP Update, and E-CAP. Implementation of the GP 2012 Update, DSP Update, and E-CAP would not increase the demand for fire protection, police protection, school services, and library services. Development consistent with the GP 2012 Update and DSP Update includes policies that help to minimize deterioration of fire and policy agency response times and school and library services and environmental impacts related to the construction or expansion o f additional facilities. Therefore, impacts would be less than significant under Issues 4.14 -1, 4.14- 2, 4.14-3 and 4.14-4.

2.15 Recreation

The Final EIR previously identified the following impacts associated with recreation and determined the corresponding level of significance.

Issue 4.15-1 Deterioration of Parks and Recreational Facilities (Less than Significant)

Issue 4.15-2 Construction of New Recreational Facilities (Less than Significant)

These less than significant impacts were addressed in Section 4.15, Recreation, of the Final EIR on pages 4.15-1 through 4.15-24 under the headings noted above.

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conditions and legal requirements; no actual development is proposed as part of the Housing Element Update. However, implementation of the programs contained in the document would accommodate development required to meet the City’s regional housing needs assessment, which specifies a nee d for land appropriately zoned to facilitate the production of new housing.

Although the City does not build the housing, the Housing Element does create a plan and regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built.

The City’s update to the Community Health and Services Chapter to integrate certain environmental justice policies, goals, and objectives, will identify issues and needs anticipated to be of ongoing concern to people in the City. Environmental justice goals, policies, and objectives will be developed by identifying disadvantaged communities and demographics to better understand the unique and disproportionate challenges faced by these communitie s. This will guide the City’s efforts to address issues related to public health, social equity, and environmental justice.

As described in the Final EIR Section 4.15, Recreation, Issues 4.14-1 and 4.14-2 would result in less than significant impacts resulting from implementing the GP 2012 Update, DSP Update, and E-CAP. As analyzed in the Final EIR, neighborhood and community parks are currently deficient in the City and implementation of the GP 2012 Update, DSP Update, and E-CAP would increase use of existing parks, thereby resulting in accelerated deterioration of recreational facilities.

Additionally, the const ruction or expansion of recreational facilities to address the increased growth, may have an adverse effect on the environment. However, implementation of the proposed General Plan Update policies and Planning Principal and Guideline 1k(1) within the Downtown Specific Plan Update and E-Cap measures would reduce impacts to below a level of significance under Issues 4.14-1 and 4.14-2.

2.16 Transportation and Traffic:

The Final EIR previously identified the following impacts associated with transportation and traffic and determined the corresponding level of significance.

Issue 4.16-1 Traffic and LOS Standards (Significant and Unavoidable)

Issue 4.16-2 Air Traffic (Less than Significant)

Issue 4.16-3 Rural Road Safety (Less than Significant)
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Issue 4.16-4 Emergency Access (Less than Significant)

Issue 4.16-5 Alternative Transportation (Less than Significant)

These issues were addressed in Section 4.16, Transpo rtation and Traffic, of the Final EIR on pages 4.16-1 through 4.16-88 under the headings noted above.

As described in the Final EIR Section 4.16, Issues 4.16-2, 4.16-3, 4.16-4 and 4.16-5 would result in less than significant impacts and Issue 4.16 -1 wou ld result in significant and unavoidable impacts resulting from the implementation of the GP 2012 Update, DSP Update, and E -CAP.

Implementation of the GP 2012 Update, DSP Update, and E-CAP would not result in changes to air traffic patterns, result in incr eased traffic on roadways with horizontal or vertical curves that are sharper than existing standards, or impair emergency access. In addition, implementation of policies in the DSP Update and E-CAP measures would create provisions for alternative modes of transportation, including multi -modal transit stations, bike lanes, bus stops, trails, and sidewalks. Therefore, impacts would be less than significant under Issues 4.16-2, 4.16-3, 4.16-4 and 4.16-5.

Implementation of the GP 2012 Update, DSP Update, and E-CAP would result in 14 deficient roadway segments and seven deficient intersections throughout the proposed project area resulting in a significant direct and cumulative impact. Implementation of the proposed GP 2012 Update and DSP Update policies and m itigation measures, in addition to compliance with applicable regulations, would reduce nine traffic impacts to a level below significant. However, 11 roadway segment and intersection impacts would remain above a level of significance because mitigation for these impacts has been determined to be infeasible by the City. Therefore, the proposed project would result in significant and unavoidable traffic and level of service (LOS) impacts under Issue 4.16-1.

5.17 Utilities and Service Systems:

The Final EI R previously identified the following impacts associated with utilities and service systems and determined the corresponding level of significance.

Issue 4.17-1 Wastewater Treatment Requirements (Less than Significant)

Issue 4.17-2 New Water or Wastewater Treatment Facilities (Less than Significant)

Issue 4.17-3 Sufficient Stormwater Drainage Facilities (Less than Significant)

Issue 4.17-4 Adequate Water Supplies (Significant and Unavoidable)

Issue 4.17-5 Adequate Wastewater Facilities (Less than Significant)

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Issue 4.17-6 Sufficient Landfill Capacity (Significant and Unavoidable)

Issue 4.17-7 Solid Waste Regulations (Less than Significant)

Issue 4.17-8 Energy (Less than Significant)

These issues were addressed in Section 4.17, Utilities and Service Systems, of the Final EIR on pages 4.17-1 through 4.17-58 under the headings noted above.

The Project seeks to amend the Housing Element portion of the General Plan to meet the statutory requirements of Housing Element Law, as it was described previously in the Final EIR. The 2021- 2029 Housing Element Update is a policy document and its adoption would not, in itself, produce environmental impacts. It consists of a housing program that was u pdated to reflect current conditions and legal requirements ; no actual development is proposed as part of the Housing Element Update. However, implementation of the programs contained in the document would accommodate development required to meet the City ’s regional housing needs assessment, which specifies a need for land appropriately zoned to facilitate the production of new housing.

Although the City does not build the housing, the Housing Element does create a plan and regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built.

New land use development projects would implement the proposed H ousing Element Update goals and policy text changes. Those future projects would be subject to future environmental review, as required under CEQA, once sufficient information is available to complete such review.

As described in the Final EIR Section 4.17, Utilities and Service Systems, Issues 4.17-1, 4.17-2,

4.17-3, 4.17-5, 4.17-7, and 4.17-8 would result in less than significant impacts resulting from the implementation of the GP 2012 Update, DSP Update, and E-CAP. Issues 4.17-4 and 4.17-6 would result in significant and unavoidable impacts resulting from the implementation of the GP 2012 Update, DSP Update, and E-CAP. Implementation of the GP 2012 Update, DSP Update and E - CAP could result in the demand for wastewater treatment services to increase at a rate disproportionate to facility capabilities, which would result in a violation in wastewater treatment standards. However, complia nce with existing regulations and implementation of the GP 2012 603
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Update and E-CAP reduction measures would reduce this impact to below a level of significance.

Similarly, the implementation of the GP 2012 Update, DSP Update, and E -CAP could have the potential to increase the demand requiring the construction of new or expanded water, wastewater, and stormwater facilities and increase the demand for wastewater treatment services. However, existing regulations and policies in the GP 2012 Update and E-CAP reduction measures would reduce impacts to these facilities and services to levels below significance.

Similarly, implementation of the GP 2012 Update, DSP Update, and E -CAP would increase demand for energy, resulting in the need for new or expanded energy facilities to be constructed, which would have the potential to result in significant environmental effects. However, the construction of new energy facilities would be subject to CEQA and/or NEPA and impacts would be mitigated, to the extent feasible. Additio nally, multiple GP 2012 Update and E -CAP policies exist that would reduce energy consumption and the need to build new energy facilities.

Therefore, impacts associated with energy would be less than significant under Issues 4.17 -1,

4.17-2, 4.17-3, 4.17-5, 4.17-7, and 4.17-8.

Implementation of the GP 2012 Update, DSP Update, and E-CAP would result in significant and unavoidable impacts associated with adequate water supplies. Adequate water supply may not be available to serve the proposed project due to p rojections of water shortages during multiple dry water years by San Diego County Water Authority ( “SDCWA”), Vallecitos Water District (“VWD”) and Rincon Del Diablo Water District ( “RDD”). Cumulative projects would also result in a significant cumulative i mpact and the proposed project would contribute to a significant cumulative impact associated with adequate water supplies. Even with compliance with existing regulations, policies contained in the GP 2012 Update policies, E-CAP reduction measures, and mitigation measure Util-1, impacts would remain significant and unavoidable under Issue 4.17-4.

Similarly, the 2012 GP Update, DSP Update, and E -CAP has the potential to be served by a landfill with insufficient capacity to accommodate the solid waste dispos al needs of the project.

Compliance with existing regulations and GP 2012 Update policies and E -CAP reduction measures would reduce impacts associated with sufficient landfill capacity, although not to below a level of significance. Mitigation measures have been identified to reduce impacts to a less than significant level; however, the City finds these measures to be infeasible because they do not meet the project objectives, would prohibit growth, and place undue burden on developers to create additional landfill capacity. Until additional solid waste disposal facilities are permitted and constructed within the San Diego region, the proposed project’s impact would remain significant and unavoidable. Therefore, the 2012 GP Update, DSP Update, and E -CAP woul d result in significant direct and cumulative impacts under Issue 4.17-6.

3.0 Findings

3.1 Rationale for Addendum:

The Addendum to the Final EIR finds that the impacts resulting from implementation of the 2012 GP Update, DSP Update, and E -CAP remain the same, aside from the Project’s proposed modification, and the mitigation measures would remain unchanged and are still valid and enforceable. No considerably different mitigation measures or feasible alternatives have been 604
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identified. The Addendum to finds that the previously identified impacts and mitigation measures, as described in the Final EIR, are still applicable to the General Plan. Therefore, the Final EIR, as certified, remains adequate and complete. The Project can be approved as an activity covered within the scope of the Final EIR . No circumstances exist calling for the preparation of a subsequent or supplemental EIR pursuant to CEQA Guidelines sections 15162 and 15163.

3.2 Substantial Changes in Circumstances, New Information Showing Greater Significant Effects, or the Ability to Reduce Significant Effects in Previous EIR:

There are no substantial changes to the circumstances under which the proposed Project is undertaken that would require major revisions to the Final EIR. There is no new information of substantial importance that was not known or could not have been known at the time the Final EIR was certified that shows the proposed Project would have significant effects not discussed previously; a substantial increase in severity of a previously identified significant impact; mitigation measures or alternatives previously found infeasible that would now be feasible and would substantially reduce one or more significant effects; or mitigation measures or alternatives that are considerably different from those analyzed in the Fina l EIR that would substantially reduce one or more significant effects on the environment. Environmental effects associated with the Project were evaluated in the Final EIR. The Project would not result in new or more severe impacts beyond those addressed in the Final EIR, and would not meet any other standards for requiring further environmental review under CEQA Guidelines sections 15162 and 15163. No further analysis is required.

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Attachment “1”

ATTACHMENT 1
FEBRUARY 28, 2023 STAFF REPORT AND AGENDA PACKET
Due to the number of pages of Attachment 1, the following link has been provided to review the document electronically on the City’s web site:
https://www.escondido.org/Data/Sites/1/media/Planning/HCIS/02-28-23PCMeetingAgendaPacket.pdf A hardcopy of the Attachment is available for review in the Office of the Planning Division during normal business hours (8:00 a.m. to 3:00 p.m.) located at 201 N. Broadway, Escondido, CA 92025. 606
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Attachment “2”
ATTACHMENT 2
AUGUST 11, 2021 STAFF REPORT AND AGENDA PACKET
Due to the number of pages of Attachment 1, the following link has been provided to review the document electronically on the City’s web site:
https://www.escondido.org/Data/Sites/1/media/Planning/HCIS/08-11-21CCMeetingAgendaPacket.pdf A hardcopy of the Attachment is available for review in the Office of the Planning Division during normal business hours (8:00 a.m. to 3:00 p.m.) located at 201 N. Broadway, Escondido, CA 92025. 607
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City of Escondido
Sixth Cycle Housing Element –
Response to Comments
2021-2029
February 2023
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Contents
Introduction .................................................................................................................................................. 3 Comment Letter A – Patricia Borchmann ..................................................................................................... 5 Response to Comments ............................................................................................................................ 9 Comment Letter B - Sierra Clun North County Group (SCNCG) .................................................................. 10 Response to Comments .......................................................................................................................... 28 Comment Letter C – Scott Graves ............................................................................................................... 30 Response to Comments .......................................................................................................................... 31 Comment Letter D - Lauren Harper and Erik Felix ...................................................................................... 32 Response to Comments .......................................................................................................................... 37 Comment Letter E - San Diego Housing Federation (SDHF) ....................................................................... 39 Response to Comments .......................................................................................................................... 42 Comment Letter F – Escondido Community Housing Coalition (ECHC) ...................................................... 43 Response to Comments .......................................................................................................................... 51 Comment Letter G – California Department of Housing and Community Development (HCD) ................ 53 Response to Comments .......................................................................................................................... 61 Comment Letter H – Southwest Regional Council of Carpenters (SWRCC) ................................................ 65 Response to Comments .......................................................................................................................... 71 Comment Letter I – Legal Aid Society of San Diego (LASSD) ...................................................................... 72 Response to Comments .......................................................................................................................... 77 Comment Letter J – Bob Conifer ................................................................................................................. 79 Response to Comments .......................................................................................................................... 80

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Introduction
The Escondido City Council adopted Resolution No. 2021-110, approving the 6th cycle Housing Element of the General Plan on August 11, 2021. On August 10, 2021, City staff received a letter from the Department of Housing and Community Development (HCD) with comments outlining outstanding items the City needed to address in order to certify the City’s draft adopted housing element. In addition to the comments issued by HCD, the City received written public comment associated with the adoption of the draft housing element.

City staff reviewed the received comment letters, including those submitted from the San Diego Housing Federation (SDHF), Escondido Community Housing Coalition (ECHC), Sierra Club North County Group (SCNCG), Erik Felix and Lauren Harper, Patricia Borchmann, Scott Graves, as well as from HCD. After the August 2021 City Council adoption, City staff met with the SDHF, ECHC, SCNCG, Erik Felix and Lauren Harper, and HCD to discuss how their comments may be integrated into the revised housing element document. City staff met with several of the public commenters, as outlined in Table 1 below. City staff reviewed comments from Patricia Borchmann and Scott Graves and provide responses in this document.

In February and May of 2022, the City received additional public comment letters from the Escondido Community Housing Coalition (ECHC). The City also received a comment letter from the Southwest Regional Council of Carpenters (SWRCC) in May 2022 and then received the same letter with an updated date in August 2022. City staff reviewed these comment letters and provide response to those comments in this document.

On June 2, 2022, City submitted draft revisions and required materials to HCD for subsequent review. On August 2, 2022, City staff received a subsequent letter from HCD with comments outlining outstanding items the City needed to address in order to certify the City’s draft adopted housing element. Again, the City made draft revisions to the adopted 2021- 2029 Housing Element and resubmitted the proposed modifications to HCD on October 17, 2022. On December 8, 2022, the City received a letter from HCD stating the draft revisions to the housing element meet the statutory requirements needed for certification, with exception of the City’s rezoning efforts in compliance with AB 1398.

On December 27, 2022, the City received an additional public comment letter from the San Diego Legal Aid Society (LASSD). On January 26, 2023, City staff met with LASSD staff to discuss their comments, concerns, and issues. On January 5, 2023, the City received a public comment from an individual, Bo b Conifer, and staff responded via email. That response is provided in this document.

Response to comments are subsequently provided in this document, and City staff posted a previous version of this document with the revised draft housing element on the City’s Housing and Community Investment Study (HCIS) webpage: https://www.escondido.org/hcis . For commenters that provided
multiple letters, they are combined into one document, in chronological order. Where revisions to the draft housing element were in response to public comment, that modification is noted in the response to the comment letter.

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Table 1 Comment Roster
Letter
ID
Commenting Organization, Person, or Public
Agency
Public Comment
Date(s) Meeting Date
A Patricia Borchmann March 23, 2021 --
B Sierra Club North County Group (SCNCG)
March 23, 2021
March 24, 2021
April 19, 2021
April 25, 2021
May 9, 2022
November 11, 2021
C Scott Graves March 24, 2021 --
D Lauren Harper and Erik Felix June 11, 2021 December 29, 2021 E San Diego Housing Federation (SDHF) July 7, 2021 January 27, 2022 F Escondido Community Housing Coalition
(ECHC)
July 26, 2021
February 10, 2022
May 25, 2022
November 11, 2021
January 25, 2022
February 22, 2022
G Department of Housing and Community
Development (HCD)
May 20, 2021
August 10, 2021
August 2, 2022
December 8, 2022
April 30, 2021
December 15, 2021
March 21, 2022
May 5, 2022
August 29, 2022
September 29, 2022
H Southwest Regional Council of Carpenters
(SWRCC)
May 10, 2022
August 22, 2022 --
I Legal Aid Society of San Diego (LASSD) December 27, 2022 January 26, 2023 J Bob Conifer January 5, 2023 --

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From: patricia borchmann
To: Mike Strong; Adam Finestone
Subject: [EXT] Re: Agenda #H1 , Escondido Planning Commission, Housing and Community Investment Study (Please Read Aloud)
Date: Tuesday, March 23, 2021 10:03:46 PM
CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender email address AND know the content is safe.

Mike Strong and Adam Finestone,
Fyi, after the Planning Commission meeting was adjourned, I looked again at the online website regarding Planning Commission information. I found the online portal system address, that I should have used, instead of the email that I sent earlier this afternoon. Even though my submittal was too late, at least I learned the proper method for submittal of public comments to the Planning Commission for future Agenda items.

So no response is needed
to respond to that question in my recent email.

Although it was submitted too late, I just sent my public comment for the Planning Commission on that portal for the purpose of making a personal effort to see if it could be included in the public record on Agenda item H-1. for the "Housing and Community Investment Study".

I was glad to hear Chairman Weiller request that the Sector Feasibility Study be scheduled for future consideration by the Planning Commission, once the study is completed, and that it be released online for public review.

And I was encouraged to see that the requests by
Commissioner Barba would be Agendized for April 13, 2021, which are also items of great interest to the public.

Thank you.

On Tue, Mar 23, 2021 at 9:18 PM patricia borchmann <[email protected]> wrote:

Mike Strong and Adam Finestone -
I was disappointed that the Public Comment that I submitted earlier this afternoon (at 4:01 pm) for Planning Commission Agenda #H-1 for the Housing and Community Investment Study were not shared, or read into the public record for this item.

So I would appreciate it if you could inform me why not, or what alternative method is necessary to submit formal public comments to Planning Commission in the future ? As far as I know, the public is not expected to send emails directly to Planning Commissioners,
and that Agenda-related emails from the public to the Commission are controlled by Director Mike Strong. .

If possible, even though my public comment was excluded during Planning Commission meeting tonight, please advise if it is possible to enter my email into the public record ?

For your convenience, I cut/pasted the earlier email I sent this afternoon, so it appears below.

Comment Letter A – Patricia Borchmann
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Thank you.
................................................................

Dear Planning Commissioners,
Generally I support the intent of the Housing and Community Investment Study, and I previewed the Staff Report which describes HCIS plan, that will cover: 1) Housing Element Update, 2) Sector Feasibility Study, and 3) East Valley Specific Plan, however I have a personal concern that the rushed process applied to this Agenda item compromised an adequate public review process, especially for a topic of this scope, scale and importance. . .

I observed that the last four (4) Planning Commission meetings were canceled, but it now seems unfortunate, and unfair that there was no opportunity for earlier public exposure and comment on this important item.

Now there is an overly rushed schedule for this same item which will also be considered tomorrow night by Escondido City Council, as Agenda #9 on March 24, 2021.

Some stakeholders consider it inappropriate to take up the slack by scheduling back to back public hearings on consecutive days between the Planning Commission and City Council meetings.

It is not conducive to thorough public review, and I suggest it reflects a presumption that no action by the Planning Commission tonight will require adjustments, or potential changes that can possibly be reflected at Escondido City Council tomorrow night in a meaningful way.

Expediency in streamlined processing is one thing,
but this compressed schedule does not indicate that the City of Escondido values either public comment, or potential comments by the Planning Commission, that could make a difference. I cannot help thinking that it is an undeserved insult to be blunt, to both the Planning Commission, and the public. This concern is further emphasized by the fact that this Planning Commission Agenda item was only released to the public five days ago, which is too brief a period for most stakeholders to realistically have time to preview, analyze the complex Staff Report, and prepare meaningful public comment.

While more extensive time to preview Agenda material in the future is encouraged, please consider a few personal comments, based on a quick preview which was not as thorough as many would prefer :
. First, make sure Inclusionary Housing is fully integrated into the Housing Plan update, without allowances for waivers or exceptions.

Next, on page 12, I observed the Staff Report indicates: "If a local government has adopted, through regulations or ordinance, minimum density requirements that explicitly prohibit development below the minimum density, the Housing Element may establish the housing unit capacity based on the established minimum density". Since you have the authority, I urge the Planning Commission to recommend to the City Council that this specific minimum density requirement be applied to the Housing Element Update, to prohibit development below the minimum density, to avoid irrevocable land use decisions that are a
mistake.

Based on the recent approval of Palomar Heights project, for only 510 dwelling units and a reduced square footage for mixed use, it was only a small fraction of the maximum allowable density, and ground floor retail space in a project that was not publicly supported, especially where there were no affordable housing dwellings proposed with deed restricted units. .

Approval of that project, with exemption from Community Facilities District (CFD) was a major disappointment to many stakeholders, taxpayers and organizations with Attachment "3"
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expertise in Affordable Housing.

Unfortunately stakeholders learned the hard way what can go wrong with careless proposals, especially for those projects that are 'in the pipeline'. As a result, public stakeholders want to take every opportunity to prepare and submit meaningful public comments whenever opportunities arise.

You can be sure that many stakeholders plan to do so, to ensure a balanced mix of housing types, and affordability categories will be constructed in Escondido, to provide home-ownership opportunities to stakeholders in all income categories, for sustainable projects that will contribute to the quality of life for all.

Thank you for thoughtful consideration.
.

On Tue, Mar 23, 2021 at 4:01 PM patricia borchmann <[email protected]> wrote:

Now there is an overly rushed schedule for this
same item which will also be considered tomorrow night by Escondido City Council, as Agenda #9 on March 24, 2021.

Some stakeholders consider it inappropriate to take up the slack by scheduling back to back public hearings on consecutive days between the Planning Commission and City Council meetings.

Expediency in streamlined processing is one thing,
but this compressed schedule does not indicate that the City of Escondido values either public comment, or potential comments by the Planning Commission, that could make a
difference. I cannot help thinking that it is an undeserved insult to be blunt, to both the Planning Commission, and the public. This concern is further emphasized by the fact that this Planning Commission Agenda item was only released to the public five days ago, which is too brief a period for most stakeholders to realistically have time to preview,
analyze the complex Staff Report, and prepare meaningful public comment.

While more extensive time to preview Agenda material in the future is encouraged, please Attachment "3"
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consider a few personal comments, based on a quick preview which was not as thorough as many would prefer : . First, make sure Inclusionary Housing is fully integrated into the Housing Plan update, without allowances for waivers or exceptions.

Approval of that project, with exemption from Community Facilities District (CFD) was a major disappointment to many stakeholders, taxpayers and organizations with expertise in Affordable Housing.

Unfortunately stakeholders learned the hard way what can go wrong with careless proposals, especially for those projects that are 'in the pipeline'.

As a result, public
stakeholders want to take every opportunity to prepare and submit meaningful public comments whenever opportunities arise.

You can be sure that many stakeholders plan to
do so, to ensure a balanced mix of housing types, and affordability categories will be constructed in Escondido, to provide home-ownership opportunities to stakeholders in all income categories, for sustainable projects that will contribute to the quality of life for all.

Thank you for thoughtful consideration.

Attachment "3"
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Response to Comments
Ms. Patricia Borchmann’s comment letter includes concerns regarding public participation in the Housing and Community Investment Study (HCIS) process, specifically concern regarding the number of initial community outreach and engagement opportunities and the timeline at which public meetings were held.

Ms. Borchmann also comments on the need for inclusionary housing in the City , for a minimum density threshold for development, and concerns regarding the approval of the Palomar Heights development. • Inclusionary Housing: The City conducted a residential sector feasibility study (study) as a part of the HCIS process. The study presents an economic analysis to evaluate the financial feasibility of various new construction residential product types and densities, and the cost for developers to comply with an onsite affordable housing obligation through application of an inclusionary housing ordinance. The study concludes that an inclusionary mechanism 10% low, or 5% low and 5% very low would be economically infeasible for all but one housing product type (for -sale townhomes) analyzed. City staff included revisions to the draft housing element to address further study and research on inclusionary mechanisms, including land value recapture (Program

2.9 – Inclusionary Housing Assessment).
• Minimum Density: Minimum density requirements exist within certain zoning designations. Table 33-98b of Article 6 - Residential Zones states, "No vacant or underdeveloped lot or parcel of land in any R- 3, R-4, and R -5 zone shall be improved or developed at a density below seventy (70) percent of the maximum permitted density. Exceptions to the minimum density requirement may be granted in writing as part of the plan approval required by section 33 -106 provided the development will not preclude the city from meeting its housing needs as described in the housing element of the Escondido general plan. Minimum density requirements shall not apply to property owners seeking to enhance or enlarge existing dwelling units or construct other accessory structures on a site." Further, the draft East Valley Specific Plan includes minimum density requirements for residential development (Section 3.2, Table 3-1, pp. 19-20). • Review Periods/Public Participation: Subsequent to the August 2021 adoption, and in response to concerns regarding review periods of revised drafts and the need for additional public participation, the City provided a voluntary 30-day review period on the initial revised draft of the housing element in May 2022, and held a public meeting on May 10th at the regularly scheduled planning commission to inform the planning commission and general public of revisions included in the draft housing element. Subsequent revisions to the May 2022 draft included additional refinement to meet HCD’s concerns regarding AFFH programs. The City provided a voluntary 14- day review period for the revisions submitted to HCD in October 2022; the October revisions are the changes proposed for adoption.

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From: [email protected]
To: Mike Strong
Subject: [EXT] Sierra Club NCG comments on item H.1 Housing Element for tonight"s meeting bcc Commissioners Date: Tuesday, March 23, 2021 1:53:47 PM
CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender email address AND know the content is safe.

Dear Planning Commissioners,
Sierra Club NCG has been very active in this issue, but given the very short timeline we have not been able to fully review all the drafts. While we plan to engage in the public review process, we request that the city not begin the environmental analysis or submit the draft plan to the state until there is a longer review period on these documents and there has been at least one public workshop where the public can provide comments on the newly released drafts.

In spite of the short timeline, we would like to make the following points and request that the Planning Commission make the following recommendations to Council:

1. First, we disagree with the statement on page 5 of the staff report which states, “The City has historically met, and plans to continue meeting, the need for low- and very low- income housing through designation of appropriately zoned land.” This is incorrect.

The City has not met its requirements or the real need for very-low and low income housing at all. That is why we have a significant housing problem for low-income families in Escondido.

To address this problem, the Housing Element and city policies should:
a. Require a minimum density for development where needed especially near transportation corridors;
b. Adopt an inclusionary housing ordinance or other requirement which will result in
construction of actual affordable housing like many other cities require;
c. Commit to using some of its American Rescue Plan funding to create a city sponsored Affordable Housing Fund or Land Trust in order to ensure development of housing we need; and,
d. Develop a multi-action Affordable Housing Program comprising of multiple commitments to address this issue.

2. We request major revision to the strategy that the city seems to be pursuing that affordable units and market rate units are, primarily, planned to be segregated into separate projects.

The strategy should be revised to include a mix of housing for residents in more economic ranges to create a more inclusive community.

3. The 90 units from the Palomar Heights listed under affordable housing in Table A-2 is incorrect.

These units are not deed-restricted and, merely by the fact they are designated for ‘seniors’, does not mean they will house low-income residents. While many seniors live on very limited means, many others do not. The city should require Comment Letter B - Sierra Club North County Group (SCNCG) Attachment "3"
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these to be deed-restricted to stay on the list—or remove them here.

4. In assessing the environmental health impacts on Table 58 the State CalEnviroScreen should also be incorporated as a data source.

5. New housing should not be located within 500 feet of a freeway per the California Air Resources Board Land Use Guidance on locating vulnerable communities close to significant pollution sources.

6. There is a significant disconnect in policies the city plans to pursue and the RHNA status Table 56. Although the city has significant ‘Identified’ sites for Very Low income, there are zero approved, undergoing entitlement, or under construction.

Further, we
know that ‘planned’ units may fail to materialize such as occurred with the Palomar Heights decision where 1350 units were reduce to 510 –significantly under density and including no affordable housing.

All of this demonstrates the dire need for
some kind of guaranteed affordable housing requirement that travels with project approvals for Above Moderate units. If there had even been a very modest 10% requirement for affordable units in a project built to the density it was planned, the current total would have yielded 135 additional affordable units.

What the city is
currently doing to provide for affordable housing is not working. This Housing Element update is the perfect opportunity to change that.

In closing, it is worth noting that the last four Planning Commission meetings were cancelled. One or more of those meetings would have been a perfect opportunity to bring these lengthy and complicated drafts forward for more in-depth and less rushed discussion as they will have not.

Something this important should not be this rushed.

Thank you for your consideration.

Laura Hunter, Chair
Sierra Club NCG Conservation Committee
Attachment "3"
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March 24, 2021
Mayor McNamara and City Council
City of Escondido
Via Email
RE: Sierra Club NCG initial Comments on Draft 2021 Escondido Housing Element Dear Mayor and City Council Members:

Sierra Club North County Group (NCG) has previously submitted extensive comments in the planning stages on both the proposed Housing Element and the East Valley Specific Plan Update.

NCG plans to engage in the public review process but we request that the city not begin the environmental analysis or submit the draft plan to the state until you have had some (longer than a few days) review period on the Housing Element and the East Valley Specific Plan, and there has been at least one public workshop in which the Council can consider amending actions to the draft. Our experience with the Climate Action Plan is that once the draft went in for the environmental analysis it was far more difficult to make significant changes to the goals, approach, or other aspects that may be needed.

Overall comment
NCG supports the housing and development strategy outlined in the Quality of Life Coalition letter dated November 18, 2019 which read, in part,
As more development projects come before you, to focus and maximize resources now and to realize a successful transit-oriented future, projects adopted by the city should meet clear objectives. Projects that the city supports should reduce (not increase) VMT; avoid high -risk fire areas; ensure safe evacuation routes for all residents; add to affordable housing stock; qualify as infill developments; contribute to the support of transit; preserve and protect core habitat and open space areas; are on or near transportation corridors; require the job quality and workforce standards…; address climate impacts in the near and long-term; and, implement land use patterns consistent with tenets of good planning. Projects that do not meet these objectives, should not be pursued.

The Housing Element Update should reflect and incorporate all of these factors and detail how they will be achieved to maximize production of needed housing, support job quality, ensure effective climate action, and implement good planning.

Attachment "3"
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Specific Comments

1. First, we disagree with the statement in the staff report which states, “The City has historically met, and plans to continue meeting, the need for low- and very low-income housing through designation of appropriately zoned land.” This is incorrect. The City has not met its requirements for very-low and low income housing at all. That is why we have a significant housing problem in Escondido.

The most recent example of Palomar Heights decision highlights the issue. The site was zoned for dense development but permitted for much less. Over and over in urban Escondido, the planned designation of units does not turn into the promised density.

To address this problem, we recommend the city:
a. Require a minimum density for development where needed and b. Adopt an inclusionary housing ordinance or other requirement which will result in construction of actual affordable housing like many other cities require; c. Commit to using some of its American Rescue Plan funding to create a city sponsored Affordable Housing Fund or Land Trust in order to ensure development of actual housing we need; and,
d. Develop a multi-action Affordable Housing Program comprising of multiple commitments to address this issue.

2. We request revision to the
strategy where the city seems to
be pursuing where affordable
units and market rate units are,
primarily, planned to be
segregated. A quick look at Table
A-3 Projects under review
reinforces that economic
segregation. An ordinance of
some kind must be adopted to
require that, as project go in,
affordable units must be included
in the project itself to build a more inclusive community.

3. The 90 units from the Palomar Heights project listed under affordable housing in Table A-2 are incorrectly noted there. These units are not deed-restricted and, merely by the fact they are designated for ‘seniors’, does not mean they will be affordable. While many seniors live on very limited means, many others do not. Either the city should deed - restrict these units or take them off the guaranteed affordable housing list.

Attachment "3"
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4. There is a significant disconnect in policies the city plans to pursue and the RHNA status Table 56. Although the city has significant ‘Identified’ sites for Very Low income, there are zero approved, undergoing entitlement, or under construction. Further, we know that ‘planned’ units may fail to materialize such as occurred with the Palomar Heights decision where 1350 units were reduce to 510 –significantly under density and including no affordable housing. All of this demonstrates the dire need for some kind of guaranteed affordable housing requirement that travels with project approvals for Above Moderate units. If there had even been a very modest 10% requirement for affordable units in a project built to the density it was planned, the current total w ould have yielded 135 additional affordable units.

What the city is currently doing to provide adequate affordable housing is not working. This Housing Element update is the perfect opportunity to change that.

5. In assessing the environmental health impacts on Table 58 the State CalEnviroScreen should also be incorporated as a data source.

6. RNHA sites should be selected to respect ARB guidance on air quality buffers from freeways. In both the North and South City land use designations for RHNA site show a significant number of areas that are within the 500-foot buffer that the Air Resources Board states in it Land Use Guidance document is unhealthful. Locations within 500 feet of a major freeway or heavily
trafficked road should be used for
commercial or other uses and not
to house vulnerable residents in an
area known to have a major
negative impact on their health.

Attachment "3"
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7. Expressed commitment to avoiding conversion of ridgetops and building on steep slopes and in high hazard areas are yet more reason that Harvest Hills should be abandoned by the city. Wasting time, energy, money, and goodwill on the pursuit of a land speculators fantasy is not appropriate.

We expect to have additional comments during the public comment period. Please contact us at [email protected] with any questions or for more information.

Sincerely,
Laura Hunter, Chair
NCG Conservation Committee
cc. Planning Commission
Attachment "3"
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April 19, 2021
Ad-Hoc Council Housing Subcommittee
Planning Commission
City of Escondido
Via Email
RE: NCG recommendations for Draft 2021 Escondido Housing Element Dear Councilmembers Garcia and Martinez and Commissioners:

Sierra Club North County Group (NCG) appreciates the creation of the Ad-Hoc City Council Housing Committee and the interest of the Planning Commission to take a deeper review of housing issues in Escondido and the Draft Housing Element. NCG has previously submitted extensive comments in the planning stages on both the proposed Housing Element and the East Valley Specific Plan Update and a letter late last month when the new draft was discussed. We intend to submit additional comments on a variety of topics related to the Housing Element.

Now that there is time to focus on some key changes that should be made to the draft and strategies of the city. We would like to focus in this first letter on two important actions in this letter. To summarize, we support the following actions:
a. Adopt an inclusionary housing ordinance or other requirement which will result in a requirement to construct 10-20% affordable units with market rate housing like many other cities require;
b. Policy to prohibit housing be built within 500 feet of a freeway. Housing within 1,000 feet should be required to include mitigation measures outlined in the CARB Technical Advisory.

Rationale
There are a couple realities that should be acknowledged so that strategies can be based on resolving these challenges.

1. Escondido has not produced adequate affordable housing with its ‘voluntary, developer-driven’ approach. We need an affordable housing requirement.

While the city may have designated adequate land for very-low and low income housing, what matters is the production of it. This failure of actual production of affordable and workforce housing is why we have a significant housing problem in Escondido.

Attachment "3"
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The practice of designation alone or market-driven voluntary strategy has not worked and must be strengthened.

The example of Palomar Heights demonstrates the failure of our current system. A site zoned for over 1,300 units, perfectly located on a transportation corridor, perfect for density, was built far under-density and with no guaranteed (deed-restricted) affordable housing.1 If there had been even a very modest 10% requirement for affordable units in a project built to the density it was planned, the current total would have yielded 135 additional affordable units. Another example is from the April 14, 2021 Planning Commission meeting where a housing development for 120 market-rate rentals in an area zoned for 230 was approved. No deed-restricted affordable and barely 50% of the planned density for an area on a major transportation corridor.

Another issue that would be improved by requiring a percentage of housing to be affordable would be more inclusion and economic integration of residents. Without it, we are concerned that economic separation of affordable units and market rate units will continue.

Inclusionary housing policies are a critically important means to increase actually built affordable units in an economically inclusive manner.

A good working definition of inclusionary zoning is,
Local requirement[s] and/or incentive[s] for developers to create below-market rental apartments or for-sale homes in connection with the local zoning approval of a proposed market-rate development project. Often accompanied by ‘density bonus’ to offset the cost of providing the below market-rate units.2
Inclusionary housing is used in hundreds of communities across the country to create units that are affordable to lower-income households in new market-rate residential developments. More than 170 cities and counties in California3 and 900 country-wide4, have inclusionary-housing policies to help address affordable-housing needs while advancing equitable-development goals.5 The Local Government Commission lists some benefits of an Inclusionary Ordinance, A well-designed ordinance can generate numerous benefits for communities seeking to increase housing affordability and develop diverse, inclusive neighborhoods. These include:
• More choices for lower-income households about where to live. 1 The senior units should not be qualified as affordable units. They are not deed -restricted and, merely by the fact they are designated for ‘seniors’, does not mean they will be affordable. While many seniors live on very limited means, many others do not.
2 Draft National Sierra Club Guidance Document for Smart Growth and Urban Infill 3 Local Government Commission, Meeting California’s Housing Needs: Best Practices for Inclusionary Housing Website https://www.lgc.org/advancing-inclusionary-housing-policy/ 4 Draft National Sierra Club Guidance Document for Smart Growth and Urban Infill 5 5Local Government Commission, Meeting California’s Housing Needs: Best Practices for Inclusionary Housing Website https://www.lgc.org/advancing-inclusionary-housing-policy/ Attachment "3"
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• Reduced opposition to affordable housing by producing affordable units within communities as they develop, not after.
• Support for compact infill development, reduced sprawl and achievement of local Regional Housing Needs Assessment (RHNA) targets for all income levels. • Reduced vehicle miles traveled (VMT) and greenhouse gas emissions by providing people at all income levels more opportunities to live closer to work and in transit-rich areas. • Ensuring that the entire community benefits from a growing economy. Public and private investments help create economic growth that raises property values. Inclusionary housing helps capture some of the value created by these investments to ensure that the benefits do not accrue solely to property owners and helps buffer against displacement pressures by ensuring that lower-income residents can remain in the community. • Reduced segregation and concentration of poverty. 6
Several cities in the County, including San Marcos, already have inclusionary ordinances. The County is developing one now. While Escondido has encouraged affordable housing on a voluntary basis, the voluntary, market-drive strategy has not met the need.

Further, the last two projects that have come before the Planning Commission have not proposed any affordable housing in spite of the fact that, at least one location, was designated as a RHNA location suitable for affordable housing. To understand the reason for this, we can just look to the March 23, 2021 meeting of the Planning Commission. A 60-unit infill project was proposed for South Escondido. A Commissioner asked why it didn’t include any affordable housing (e.g. all market-rate), the answer was that ‘it wasn’t required.’ This is exactly the problem. It would be nice if the voluntary effort worked, but it doesn’t.

We need an affordable housing development requirement, such as an inclusionary ordinance or other such measure to effectively address this issue.

2. Location of housing within 500 feet of a freeway is known to be hazardous to human health and should be avoided.

Development locations within 500 feet of a major freeway or heavily trafficked road are hazardous for human health and should not be used to house vulnerable residents. The California Air Resources Board (CARB) did a Land Use Guidance document in 2005 and its guidance is clear, Avoid siting new sensitive land uses within 500 feet of a freeway, urban roads with 100,000 vehicles/day, or rural roads with 50,000 vehicles/day. 7 6Meeting California’s Housing Needs: Best Practices for Inclusionary Housing https://www.lgc.org/wordpress/wp- content/uploads/2018/11/inclusionary-factsheet_v2.pdf
7AIR QUALITY AND LAND USE HANDBOOK: A COMMUNITY HEALTH PERSPECTIVE, April, 2005 https://ww3.arb.ca.gov/ch/handbook.pdf, page 4
Attachment "3"
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While not a regulation, this guidance is heavily based on extensive science that underpins the recommendation and should be adopted as part of good planning. In fact, the hazard area is 1,000 feet from a freeway, which would be a more healthful buffer to adopt.

Then, in 2017, a CalEPA and CARB Technical Advisory was issued which cited evidence that the risks were actually higher than the 2005 report found. It states, In spite of past successes and ongoing efforts to improve near roadway air quality in California, exposure to traffic pollution is still a concern because pollution concentrations and exposure levels near high-volume roadways continue to indicate that there is a lingering public health concern. In addition, the Office of Environmental Health Hazard Assessment (OEHHA) recently revised its methodology for risk assessment in order to estimate more accurately the health impacts of exposure. This reanalysis has resulted in a revision of cancer risks from exposure to toxic air contaminants, including those emitted by transportation-related sources, to significantly higher levels… (emphasis added) These recent studies highlight the importance of protecting at-risk populations/communities from traffic emissions and indicate that exposure reduction strategies may be needed to protect people that live and spend time in environments that are more than 500 feet from high volume roadways.8 (emphasis added)
Further, they found that the air quality concerns will persist even with changes to regulations and technology.9
The Advisory does discuss the kind of development and measures that may be appropriate for these locations.
. … In fact, planners and developers may want to consider siting non-sensitive uses and developments that will be primarily used and occupied during the daytime—such as commercial uses and offices. … commercial and office buildings are often equipped with indoor filtration systems that can remove particulates from the air inhaled by building occupants, and these buildings are more likely to have permanently closed or sealed windows. This means that, when these buildings are sited close to roads, people that spend time in them are less likely to breathe harmful pollutants and experience negative health impacts.10 8 Technical Advisory, Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways https://ww3.arb.ca.gov/ch/rd_technical_advisory_final.pdf, page 14 9 Ibid
10 Ibid
Attachment "3"
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As you can see from these excerpts of housing
locations in both the North and South City land use
designations for RHNA site show a significant
number of areas that are within the 500-foot buffer
that the Air Resources Board states in its Land Use
Guidance document is unhealthful. RNHA sites
should be selected to respect ARB guidance on air
quality buffers from freeways.

In closing, these are two areas that could use significant improvement in the draft 2021 Housing Element. We request that the Ad-Hoc and Planning Commission investigate and recommend the following actions.

NCG Recommendations for addressing healthful and affordable housing.

To address the issues discussed above, we request the draft Housing Element be revised to include the following:
a. Adopt an inclusionary housing ordinance or other requirement which will result in a requirement to construct 10-20% affordable units with market rate housing like many other cities require;
b. Policy to prohibit housing be built within 500 feet of a freeway. Housing within 1,000 feet should be required to include mitigation measures outlined in the CARB Technical Advisory.

In the future, we plan to provide additional comments and information on land value recapture policies, protection policies for renters, design and implementation of Eco-Planning Districts including urban greening, minimum densities, the danger of locating any housing in very-high fire risk zones, and other housing related policies.

Please contact us at [email protected] with any questions or for more information.

Sincerely,
Laura Hunter, Chair
NCG Conservation Committee
cc. City Manager
Attachment "3"
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April 25, 2021
Ad-Hoc Housing Committee Members Garcia and Martinez
Planning Commissioners
Via Email
RE: Additional policy and program recommendations for Escondido Housing Element Dear Ad-Hoc members Garcia and Martinez and Planning Commissioners, Sierra Club North County Group (NCG) is submitting this second comment letter on policy and program recommendations for the Housing Element for your discussion and consideration.

NCG is still developing more specific recommendations on these topics, but hope to offer these ideas into the important discussion the city is having so that, perhaps, we can build a community consensus around how to approach our need for housing development and community investment in Escondido.

As you evaluate and discuss amendments/revisions to the Draft 2021 Escondido Housing Element, we hope you will consider further evaluation of these policies and programs.

NCG Housing Element Recommendations (Second set)

1. Establishing ‘minimum density requirements’ in key areas linked to development of the Regional Transportation Plan.

2. Strengthen programs a focus on low-income home ownership such as creation of a Community Land Trust and innovative programs.

3. Land Value Recapture and America Rescue Funds as means for producing additional affordable housing
Rationale

1. Establishing ‘minimum density requirements’ in key areas linked to development of the Regional Transportation Plan.

As we see regularly, Escondido is failing to build to planned density in areas where density is appropriate and needed. Palomar Heights was a little over one third and the proposed Mercado project is just half of the planned density. We acknowledge that there are many areas where higher densities are not appropriate. However, being as we are in a climate emergency, we need to seriously plan for a carbon reduced or neutral future if our communities are to survive.

Attachment "3"
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Urban infill and higher densities near transportation corridors are part of what we must do to plan for a survivable future. City plans always set ‘maximum’ allowable densities, so why not ‘minimum required’ densities in areas where we need higher density. Setting a maximum and hoping developers will build to it, isn’t working. Minimum density requirements in key transit focused areas are needed to meet the fullness and effectiveness of our urban planning efforts.

There are other benefits of these requirements as well. According to Puget Sound Regional Council Housing Innovations Committee:

Adopting minimum densities can also support other community goals such as maximizing transit investments, expanding housing choices, protecting open space, and reducing greenhouse gas emissions.1
In 2014, Seattle adopted a minimum density program for specific areas with the purpose to:
…limit new low-density, suburban-style development that conflicts with the desired urban design and pedestrian-orientation goals of these areas. It achieved this by:
• Preventing new development from substantially under-developing sites • Preserving activity adjacent to the sidewalk
• Discouraging substantial parking
• Protecting development opportunities on sites near transit and services2 We think these are good criteria for Escondido to consider and include in our urban planning.

Establishing minimum densities will be increasingly important and we may wish to begin with the new East Valley Specific Plan. In addition, the city could do an additional analysis to evaluate transportation corridors in existing plans and recommend minimum densities.

We recommend that Escondido tie minimum densities and up-zoning for land value recapture (see #3 below) to the plan for improved public transit currently under development at SANDAG for the new regional transportation plan.

We really can’t wait. With each urban infill project built below density, we are losing opportunities that won’t come again for a generation to provide housing and reduce our overall GHG emissions needed for a sustainable future.

2. Strengthen programs that focus on low-income home ownership such as creation of a Community Land Trust and innovative programs.

While most dedicated affordable housing are rentals, in the name of housing justice and equity, we should be working toward programs that help low-income families enter the home ownership market.
1 Fact Sheet on Minimum Densities https://www.psrc.org/sites/default/files/hip-min-density.pdf 2 https://www.seattle.gov/sdci/vault/minimum-density
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Equity in a home is a major factor in creation of wealth for current and future generations of residents. Such opportunities for low and moderate income families for home ownership is something the Housing Element should address and find ways to facilitate.

One way that this can be supported is through Community Land Trusts (CLT). The model of CLTs is over 50 years old and can be adapted to meet community housing needs, including permanently affordable homeownership. CLTs are being used to support housing equity and reduce displacement. It is also an innovative way to provide affordable housing.

There are many ways a CLT can be created. Here is one model, 3 One option that might be applicable for Escondido is for the city to retain ownership of the public property it currently sells to developers (e.g. Mercado, proposed Aspire) and lease it to them instead. This could significantly lower the cost of the development (reduced land cost) and the value could be re-captured in the form of affordable housing unit-- rental and for sale.

We are sure this is more complex idea than it sounds, but we hope we will have a chance to look ‘with new eyes’ on this idea. Land in the urban area owned by the public (city, hospital etc…) is an important and highly valuable asset. We should develop programs that leverage and maximize that asset for the public.

An innovative organization called Grounded Solutions Network is offering a free one hour webinar on May 5, 2021 on how CLTs can be used to provide community control over important land assets. We hope that our decision-makers and staff will take an opportunity to learn more about this tactic to build homeownership in our community.

The Urban Institute reported on a non-profit organization approach that supports lower income homeownership. The New Mexico Homewise model,
… issues two mortgages—the first is for 80 percent of the home’s value, and the second is for 18 percent. The first mortgage is resold on the secondary market to raise capital for additional clients, and Homewise holds on to the riskier second mortgage so that the client pays only a 2 percent down payment while still eliminating the need for mortgage 3 https://www.strongtowns.org/journal/2018/4/4/organizing-and-the-community-land-trust- model?gclid=Cj0KCQjwvYSEBhDjARIsAJMn0lgMZShrqmwUG_3vzd4U6KX3_E25Gob9S8tVehdNygkjyPH- tXO2EvoaAvtyEALw_wcB
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insurance. Homewise services both loans so that they can monitor loan performance on each and intervene early if there is a problem.

Homewise also offers a suite of other services including financial counseling, homebuyer education, real estate development, real estate sales, mortgage origination, and loan servicing, as well as an in-house incentivized savings program.4 5 This model addresses one of the most significant barriers to home ownership-- the initial savings for a down payment. We hope that this can be evaluated as a supplement or in addition to the current city Homebuyer Entry Loan Program.6
Another option is to give a preference in your affordable housing RFPs/NOFAs to Low-Income Housing Tax Credit (LIHTC) projects which will ultimately sell the apartments to the low- income residents. California Tax Credit Allocation Committee Regulations dated December 21, 2020 Section 10326(j)(4) allows for apartments financed with LIHTC to be sold to low-income residents after the initial 15-year IRS regulatory period. This can be an option for the City to leverage its funding at a low ratio for the benefit of low-income buyers.

These are only three options for innovative ways to help low and moderate income residents become homeowners. We request that these, and other innovative strategies, are examined for applicability in Escondido.

3. Zoning for Land Value Recapture and America Rescue Funds as means for funding additional affordable housing
It should be remembered that, with (in our case) the punch of three buttons by the City Council, in a zoning decision can created 1,000s or millions of dollar of additional value for property to which the decision applies. Since there are strict rules about governmental decisions not eliminating property value to landowners, it seems fair that when property values are significantly increased through new zoning, the public retain some of that benefit. A great way to ‘recapture value’ is through requirements for affordable housing—a desperate need for the public.

In their article, Inclusionary Housing, Incentives, and Land Value Recapture Local Housing and planning experts Nico Calavita (San Diego State University) and Alan Mallach (Brookings Institution) discuss how many ‘incentives’ for inclusionary housing often just transfer costs to the public.7 In fact, they note that incentives and cost offsets provided to development may carry potentially high public costs.8 This cost to the public while the landowner accrues the increased value of the governmental action. The authors list several means by which the public ends up paying for the benefits.
4 https://www.urban.org/urban-wire/innovative-model-reducing-gaps-homeownership 5 https://www.sciencedirect.com/science/article/abs/pii/S1051137717301729 6 https://www.escondido.org/Data/Sites/1/media/pdfs/Housing/FirstTimeHomebuyerProgramEnglish.pdf?v=8 7 Calavita and Mallach,Inclusionary Housing, Incentives, and Land Value Recapture Local Housing, January, 2009, Lincoln Institute of Land Policy, p 18
8 Ibid
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A better idea is to recapture some of the land value increases that come about through new zoning for the public good.

Calavita and Mallach make the case that the better way to achieve integrated, inclusionary housing is to better integrate inclusionary housing into good planning practices that begin to recapture for the public good some part of the unearned increment in land values resulting from the exercise of public land use regulatory powers.9
A second funding area that we hope can be investigated is the potential use of American Rescue Funds the city will receive for the development of affordable housing. Since many people lost their jobs and some their housing, the provision of new affordable housing we think may be an acceptable and compliance use of some of the funds.

We look forward to the discussion of the Planning Commission on these topics at your April 27th meeting and hope to attend any Ad-Hoc meeting held by the Ad-Hoc Housing Committee.

Thank you for the opportunity to comment on this important planning effort. Please contact us at [email protected] with any questions or for more information.

Sincerely,
Laura Hunter, Chair
NCG Conservation Committee
cc.

Jeff Epp, City Manager
Mike Strong, Community Development Director
Karen Youel, Housing and Community Investment Director
Karla Ortega, First Time Homebuyers program manager
9 Ibid, p 21
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From: Laura Hunter
To: Adam Finestone; Veronica Morones; Jessica Engel; Zachary Beck Cc: [email protected]
Subject: [EXT] May 10, Planning Commission meeting, item H1-NCG Comment on updated Draft Housing Element Date: Monday, May 9, 2022 5:16:40 PM
Attachments: Inclusionary Housing, Incentives and Land Value Recapture-1.pdf CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender email address AND know the content is safe.

Please Forward to commissioners prior to the meeting. Thank you +++++++
Dear Planning Commissioners,
NCG Sierra Club is a member of the Escondido Community Housing Coalition and has written several comment letters on this topic.

While improvements have been made in the new iteration, there are still two areas of major
concern.

First, we still do not believe the amended language on inclusionary housing (IH)is enough to make a difference. Without inclusionary requirements in place, land values-- the most important issue when trying to build affordable housing (AH)- will continue to increase.

It will then follow that building AH will never ‘pencil out’.

The inclusionary ordinance must come first. Economists generally agree that an inclusionary housing ordinance would lead to a decline in land values because of the increased cost
for the developer- over a period of three to five years, the time that it would take for the land market to adjust to the new requirements. The IH Ordinance, then, could be phased in as well.

We suggest
a dual approach, one based on IH applied to
existing zoning, as in the case of
typical IH ordinances, and
the other based on plan changes or up-zonings in areas
slated for development (see attached article: “Inclusionary Housing, Incentives and Land Value Recapture”). IH requirements would be higher in the second case because land values would increase as a result of up-zonings, plan changes or updates.

In this case the IH requirements should be based on the public benefit received by the landowner (to be established on the basis of an economic analysis). This approach is preferable to density bonuses. The County seems to be moving in this direction.

How land value changes up (up-zonings) or down (IH) should be an integral part of an IH study, including the desirability of a phasing approach to allow for land markets to adjust to plan changes and regulations.

Second, the element is still deficient in community participation and engagement around the important issue of housing.

The Escondido Community Housing Coalition has
repeatedly requested a re-start of the Housing Commission or a Housing Working Group as a place where housing issues can be addressed and improved. A Council Subcommittee, which meets during work hours, and has not (until recently) been Attachment "3"
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accessible to the public is not adequate. In fact, the stated purpose of the Subcommittee is "to discuss pertinent housing issues within the City and convey information to City staff on such matters." Without any acknowledgement or commitment to engaging the public.

Thank you for your consideration of our comments
Laura Hunter, Chair, Conservation Committee
Sierra Club North County Group
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Response to Comments
The SCNCG’s letters outline support for transit-oriented development, climate resiliency and adaptation, adoption of citywide inclusionary housing requirements as well as minimum density thresholds, strengthening homeownership opportunities for low income households, increasing affordable housing production within the City, and development of affordable housing programs such as an affordable housing fund and/or community land trust.

The SCNCG highlights concerns regarding longer review periods for draft revisions of the 6 th cycle housing
element, the City’s historic trend of meeting very low and low income housing needs and the strategies drafted to address this need (i.e., fair housing concerns), air quality impacts to sites identified within the site inventory that are located within 500 -feet of a freeway or major roadway, conversion of ridgetops and development within high and very high fire hazard severity zones, and the need for additional public participation in the 6
th cycle housing element process.
• Inclusionary Housing: The City conducted a residential sector feasibility study (study) as a part of the Housing and Community Investment Study (HCIS) process. The study presents an economic analysis to evaluate the financial feasibility of various new construction residential product types and densities, and the cost for developers to comply with an onsite affordable housing obligation through application of an inclusionary housing ordinance. The study concludes that an inclusionary mechanism 10% low, or 5% low and 5% very low would be economically infeasible for all but one housing product type (for -sale townhomes) analyzed. The City staff included revisions to the draft housing element to address further study and research on inclusionary mechanisms, including land value recapture (Program 2.9 – Inclusionary Housing Assessment). • Minimum Density: Minimum density requirements exist within certain zoning designations. Table 33-98b of Article 6 - Residential Zones states, "No vacant or underdeveloped lot or parcel of land in any R -3, R-4, and R -5 zone shall be improved or developed at a density below seventy (70) percent of the maximum permitted density. Exceptions to the minimum density requirement may be granted in writing as part of the plan approval required by section 33 -106 provided the development will not preclude the city from meeting its housing needs as described in the housing element of the Escondido general plan. Minimum density requirements shall not apply to property owners seeking to enhance or enlarge existing dwelling units or construct other accessory structures on a site." Further, the draft East Valley Specific Plan includes minimum density requirements for residential development (Section 3.2, Table 3-1, pp. 19-20). • Affordable Housing Trust Fund: The draft East Valley Specific Plan would include development of an Affordable Housing Trust Fund to assist in the delivery of affordable housing within the Plan Area. Likewise, an in -lieu fee for development proposed below minimum den sity thresholds would be used by the trust fund to develop moderate- and low-income housing developments. • Review Periods/Public Participation: Subsequent to the August 2021 adoption, and in response to concerns regarding review periods of revised drafts and the need for additional public participation, the City provided a voluntary 30-day review period on the initial revised draft of the housing element in May 2022, and held a public meeting on May 10th at the regularly scheduled planning commission to inform the planning commission and general public of revisions included in the draft housing element. Subsequent revisions to the May 2022 draft included additional Attachment "3"
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refinement to meet HCD’s concerns regarding AFFH programs. The City provided a voluntary 14- day review period for the revisions submitted to HCD in October 2022; the October revisions are the changes proposed for adoption.
• Air Quality and Fire Hazards : The City is currently working on an update to the City’s Safety Element, known as the Community Protection chapter of the General Plan and creation of a new environmental justice element— both of which are required as a direct result of the 6 th Cycle Housing Element Update. Specifically, SB 1035 requires the General Plan Safety Element to be reviewed and revised to include any new information on fire hazards, flood hazards, and climate adaptation and resiliency strategies with each revision of the housing element. These elements will discuss fire hazards surrounding development within the City and air quality concerns as they relate to safe and sanitary housing and pollution burden for communities. • Fair Housing: The City seeks to contain a majority of future residential development within the urban core of the City, where proximity to existing transit such as the NCTD Sprinter are located.

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From: Scott Graves
To: Zachary Beck; Mike Strong
Subject: [EXT] Today"s Housing Element Comment
Date: Wednesday, March 24, 2021 6:14:53 PM
CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender email address AND know the content is safe.

Greetings Zack,
My public comment that I submitted through the website was not read aloud on the live feed.

Here is my comment.

Greetings Mayor and City Council Members.

My comments are in reference to page 81, Environmental and Infrastructure Constraints section.

Pages 81-83 goes into detail regarding the following environmental and infrastructure constraints to the feasibility and cost of developing housing: soil, steep slopes, seismic safety, flood hazards, hazardous materials, ridgeline and hillside conservation, water supply, and wastewater capacity.

The document has separate paragraphs addressing each one of these issues except wildfire. Not elaborating on wildfire and its effects on the Housing Element, and potential housing projects in the Wildlife Urban Interface (WUI) demonstrates a glaring omission. The last several years have shown the increasing frequency, widespread devastation, economic damage, and most importantly, loss of life, due to wildfire. In my opinion, failing to address whatsoever, the largest environmental and infrastructure constraint, wildfire, renders Escondido’s Housing Element incomplete.

It should also be noted that on page 97,
“Ability to Meet RHNA, Based on the City’s currently available residential and mixed-use sites, adequate residential capacity is available to meet the City’s RHNA for all income groups.”

It is not necessary to develop the high fire risk backcountry to comply with RHNA requirements.

Thanks for your time and consideration.

Escondido Resident,
Scott Graves
Comment Letter C – Scott Graves
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Response to Comments
Mr. Scott Graves’ comment letter addresses concerns regarding the draft housing element’s Environmental and Infrastructure Constraints se ction and contends that utilizing sites within the City located in areas of high fire risk for residential development are not necessary for RHNA compliance. • Fire Hazards: The City is currently working on an update to the City’s Safety Element, known as the Community Protection chapter of the General Plan and creation of a new environmental justice element—both of which are required as a direct result of the 6 th Cycle Housing Element Update. Specifically, SB 1035 requires the General Plan Safety Element to be reviewed and revised to include any new information on fire hazards, flood hazards, and climate adaptation and resiliency strategies with each revision of the housing element.

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M E M O R A N D U M
TO: Members of the Escondido City Council and Escondido Planning Commission
FROM: Erik Felix and Lauren Harper
DATE: 06/11/2021
SUBJECT: Recommendations for Escondido’s 6th Cycle Housing Element Dear members of the Escondido City Council and Planning Commission, Upon reviewing your 6th Cycle Housing Element, we would like to share some thoughts and observations that we feel are critical to consider to meet the housing needs of Escondido residents. The city has experienced a demographic shift over the past ten years, with a growing Hispanic population and decreasing white population. Escondido’s total Regional Housing Needs Allocation (RHNA) is 230% more than the previous cycle.

Despite these demographic changes and large expectations, Escondido’s Housing Element is riddled with vague and aspirational language and estimates that go against the standards set forth by the California Department of Housing and Community Development (HCD).1 As urban planning graduate students, we find it imperative that the state grow in an equitable and inclusive manner. Escondido’s growing Hispanic and low-income population gives the City Council and Planning Commission an integral role in achieving that goal. We’ve organized our comments under the following topics:
updating programs for Escondido’s growing low-income population, improving siting and tenant protections to Affirmatively Further Fair Housing (AFFH), mitigating development fee burdens, invalidating Proposition S, and designing a mid-cycle Accessory Dwelling Unit (ADU) development trigger.

Updating programs for Escondido’s growing low-income population Escondido’s growing population of cost-burdened and low-income households is a signal to the City Council and Planning Commission that it must proactively address its stagnant housing production. Between 2010-2020, population growth increased 6.3%, yet housing units only grew 2.4%. This difference partly explains the growing rent burden your residents are experiencing. When compared to other jurisdictions in North San Diego, Escondido reported the most cost burdened residents, with 44.8% of all households paying more than 30% of their income on housing. Cost-burdened 1 "Affirmatively Furthering Fair Housing - California Department of ...." 27 Apr. 2021, https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf. Accessed 26 May. 2021.

Comment Letter D - Lauren Harper and Erik Felix
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households are forced to spend less on basic necessities like healthcare and food.2 Not actively meeting the housing needs of your residents will place them in increasing precarity. This is extremely important considering Escondido has a majority low-income community (53%) and the lowest median household income in North San Diego.

Escondido has identified sites for a total capacity of 8,109 low-income units. Yet, Escondido’s quantified objectives only plan to meet 45% of their low-income RHNA goal.3 This is unacceptable. Worse, it appears that even this unaspiring estimation is inflated. Sixteen of your 21 programs from last cycle were not met and carried over into this housing element, and you have fewer programs this cycle, 18. Your last cycle yielded approximately 11% of its low-income RHNA goal, or 200 units.4 For your 6th cycle, you estimate 795 low-income units will be built. How do you expect to build almost four times more low-income housing with essentially the same programs? Escondido should reconsider the design of its programs and incorporate mid-cycle triggers that facilitate by-right, multifamily development to house its growing cost- burdened and low-income residents.

Improving siting and tenant protections to Affirmatively Further Fair Housing AB 686 requires that housing elements include affirmatively furthering fair housing (AFFH) as part of their planning process. The goal of AFFH is to “combat housing discrimination, eliminate racial bias, undo historic patterns of segregation, and lift barriers that restrict access in order to foster inclusive communities and achieve racial equity, fair housing choice, and opportunity for all Californians5.” More specifically, this includes a spatial analysis to ensure that low-income units are distributed across neighborhoods of all income levels, as well as ensuring investment in low-income neighborhoods.

We conducted an AFFH site score analysis to calculate the spatial distribution of low- income RHNA units by block group median household income. This analysis results in a value from 1 to -1, where 1 is perfectly distributed and -1 is perfectly segregated.

Escondido scored a -0.69, indicating that a majority of low-income units are sited in low- income areas. The goal of AFFH is to break-up areas of concentrated poverty and affluence by siting low-income housing in higher income neighborhoods.

The Housing Element addresses this shortcoming, noting “many RHNA units are located in lower resource census tracts. However, through specific planning, the City is 2 National Low Income Housing Coalition. 2020. The Gap: A Shortage of Affordable Homes. National Low Income Housing Coalition. https://reports.nlihc.org/sites/default/files/gap/Gap-Report_2020.pdf 3 City of Escondido 6th Cycle Housing Element - Draft.” Page 123. March 2021. https://www.escondido.org/Data/Sites/1/media/PDFs/Planning/HCIS/PublicReviewDraftEscondidoHE3- 18-21.pdf Accessed 28 May. 2021.
4 "5TH CYCLE REGIONAL HOUSING NEEDS ... - SANDAG."
https://www.sandag.org/uploads/publicationid/publicationid_4647_27206.pdf. Accessed 27 May. 2021. 5 “Affirmatively Furthering Fair Housing in California.” California Department of Housing and Community Development. https://www.hcd.ca.gov/community-development/affh/index.shtml Accessed 28 May. 2021.

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actively pursuing improvements on neighborhoods with low resources6.” Indeed, the Downtown, East Valley, and South Centre City Parkway Specific plans do indicate future investment in neighborhood infrastructure in those areas. However, if greater investment makes these neighborhoods more attractive areas to live, how will the City ensure that low-income units are built and remain affordable? The Housing Element does not provide specific funding or incentive plans to develop low-income housing in these areas, beyond high-density zoning.

Additionally, the AFFH site score analysis may be skewed due to how the site inventory categorizes sites by income. A table titled “Summary of RHNA Status” shows how the City anticipates meeting the RHNA goals based on the site inventory7. However, the City lumps nearly all identified sites into the “very low” income category due to zoning density greater than 30 du/acre. This leaves other income categories well below the RHNA requirement. The City recognizes this shortfall and argues that “excess capacity on lower income sites can accommodate the remaining balance8”. Because this designation is based only on zoning density and not other programs directly incentivizing housing at certain income-levels, there is functionally no plan to ensure housing will be produced at lower income levels, and will likely skew toward above moderate market rate development. Escondido must design tenant protections and land use policies that will facilitate the development of affordable housing and maintain its accessibility for low-income households.

Source: Draft City of Escondido 6th Cycle Housing Element 2021-2029 In a further blow to AFFH goals, the housing element states that “the City retains certain amount of large-lot zoning to accommodate the housing needs and preferences of moderate and higher income households7”. Reserving large lots for high-income households while anticipating low-income development in low-resourced neighborhoods is antithetical to AFFH goals.
6 “City of Escondido 6th Cycle Housing Element - Draft.” Page 105. March 2021. https://www.escondido.org/Data/Sites/1/media/PDFs/Planning/HCIS/PublicReviewDraftEscondidoHE3 - 18-21.pdf Accessed 28 May. 2021.
7 City of Escondido 6th Cycle Housing Element - Draft.” Table 56. March 2021. https://www.escondido.org/Data/Sites/1/media/PDFs/Planning/HCIS/PublicReviewDraftEscondidoHE3 - 18-21.pdf Accessed 28 May. 2021.
8 City of Escondido 6th Cycle Housing Element - Draft.” Page 97. March 2021. https://www.escondido.org/Data/Sites/1/media/PDFs/Planning/HCIS/PublicReviewDra ftEscondidoHE3- 18-21.pdf Accessed 28 May. 2021.

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Mitigating development fee burdens
The Escondido Housing Element correctly recognizes that development fees can be a barrier to building housing, but its portrayal of its development fees being low to moderately priced compared to the region is misleading. The Housing Element compares Escondido to coastal cities in North San Diego like Carlsbad and Oceanside.

Relative to these cities, Escondido generally has lower fees and total per unit costs. But these cities are twenty miles away from Escondido. Between them is San Marcos, a jurisdiction that is directly adjacent to Escondido. When compared to its direct neighbor, Escondido’s planning fees are 33% to 400% higher than San Marcos.9 Escondido’s per unit permit and impact fees are also higher than San Marcos and another nearby city, Vista. For all four housing types – from single family homes to apartments - Escondido’s total fees were $5,500 - $15,170 more expensive than San Marcos and Vista. Yet, Escondido claims that “these fees have not been found to act as a constraint” to development10. This appears to be false. When excluding above moderate housing, your last cycle yielded approximately 7% of its remaining RHNA goals.11 Multi-family developments require grading exemptions (for grading exceeding requirements), precise development plans and variances. None of their costs are given in the Housing Element. Escondido should evaluate these and all their development and impact fees to ensure they are not deterring developers from contributing to its lower income housing stock.

Invalidating Proposition S
Escondido’s Proposition S is a potential barrier to development, but the City does not actually have to abide by it. Proposition S is an ordinance passed in 1998 that requires voter approval for changes made to the General Plan that alters or increases residential density and land use categories. To Escondido’s credit, the Housing Element includes a program to monitor the effects Proposition S has on reaching the City’s RHNA goals and will explore potential mitigation measures, if needed. But the City does not have to abide by Proposition S. According to SB-330, growth management ordinances, like Proposition S, are only valid if the county where the city is located consists of more than 550,000 acres of agricultural land or is at least one-half agricultural land.12 San Diego 9 "Draft Housing Element — San Marcos General Plan Update." 12 Mar. 2021, https://sanmarcos.generalplan.org/draft-housing-element. Accessed 27 May. 2021. 10 City of Escondido 6th Cycle Housing Element - Draft.” Page 72. March 2021. https://www.escondido.org/Data/Sites/1/media/PDFs/Planning/HCIS/PublicReviewDraftEscondidoHE3- 18-21.pdf Accessed 28 May. 2021.
11 "5TH CYCLE REGIONAL HOUSING NEEDS ... - SANDAG."
https://www.sandag.org/uploads/publicationid/publicationid_4647_27206.pdf. Accessed 27 May. 2021. 12 Housing Crisis Act of 2019, SB-330, Senate (California 2019). https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201920200SB330 Attachment "3"
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County consists of 250,000 acres of agricultural land, making it 9% agricultural.13 14 Proposition S is no longer valid as a smart growth ordinance in Escondido. The city should analyze where Proposition S has been restricting development and leverage developable parcels to reach more than its stated goal of achieving 45% of its low- income RHNA.15
Designing a mid-cycle ADU development trigger
The housing element estimates that 80 ADU units per year will be constructed in the 6th cycle, for a total of 640 units.16 Based on ADU permitting data from the previous three years (25, 40, and 74 permitted), the Safe Harbour calculation provided by the Housing Element estimates 45 units per year, for a total of 365 units. The Housing Element describes 80 ADUs per year as a “conservative production rate” and anticipates a growing trend in ADUs permitted. However, substantial evidence is not provided, beyond stating “City is considering adopting other incentives to encourage and promote ADUs, including allowing ADUs on religious properties.” The City needs more concrete evidence that ADU permitting will continue to increase and significantly exceed the Safe Harbour calculation. An automatic mid-cycle trigger should be considered to address any shortfalls in production.

Additionally, the City should consider a recent study by UCLA Ziman Center for Real Estate which found that up to 20% of ADUs permitted were not used as housing.17 The City should not assume that all permitted ADUs will contribute toward housing production for the RHNA goals.

Conclusion
Over the past few years, legislation has given the state more tools to make sure each jurisdiction is doing their part in upholding the goals of AFFH through their housing elements. HCD is already reviewing housing element drafts for cities in San Diego County and, thus far, have found all of them deficient in AFFH. This cycle has already proven to be different from past cycles, and we encourage you to consider our recommendations to design a housing element that will guide Escondido in providing housing security to its residents.
13 "San Diego Agriculture – The San Diego County Farm Bureau." https://www.sdfarmbureau.org/san- diego-agriculture/. Accessed 26 May. 2021.
14 "U.S. Census Bureau QuickFacts: San Diego County, California ...." https://www.census.gov/quickfacts/fact/table/sandiegocountycalifornia,CA/PST045219 . Accessed 26 May. 2021.
15 City of Escondido 6th Cycle Housing Element - Draft.” Page 123. March 2021. https://www.escondido.org/Data/Sites/1/media/PDFs/Planning/HCIS/PublicReviewDraftEscondidoHE3 - 18-21.pdf Accessed 28 May. 2021.
16 City of Escondido 6th Cycle Housing Element - Draft.” Page 95. March 2021. https://www.escondido.org/Data/Sites/1/media/PDFs/Planning/HCIS/PublicReviewDraftEscondidoHE3 - 18-21.pdf Accessed 28 May. 2021.
17 “How are ADUs Used? The Impact of Accessory Dwelling Units in Los Angeles.” May 2021. https://www.anderson.ucla.edu/documents/areas/ctr/ziman/2021/UCLA_Economic_Letter_Crane_052521 v3.pdf
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Response to Comments
Mr. Erik Felix and Ms. Lauren Harper comment on the following topics, updating programs for Escondido’s growing low -income population, improving siting and tenant protections to Affirmatively Further Fair Housing (AFFH), mitigating development fe e burdens, invalidating Proposition S, and designing a mid - cycle Accessory Dwelling Unit (ADU) development trigger.

Specifically, Mr. Felix and Ms. Lauren express concern regarding the City’s ability to construct a targeted number of low-income residential units with housing programs similar in nature to the previous cycle, and the impacts lack of low -income housing construction will cause in the City when there is a large portion of the population experiencing low income and high financial burdens. Additional concerns pertain to concentration of low - and very-low income allocations within the City and the need to design tenant protections and land use policies that will facilitate the development of affordable housing and its accessibility. Their comment le tter contends that the City’s draft housing element should address affirmatively furthering fair housing goals and policies more effectively.

Further public comment targets the City’s fee schedule comparison noted under Table 45 of the draft housing element, which compared the City’s fees against City of Carlsbad and Oceanside only, as well as direction that the City need not abide by Proposition S due to Senate Bill 330 (SB 330). Mr. Felix and Ms.

Harper also address the need for a mid -cycle accessory dwe lling unit (ADU) development trigger to address potential shortfalls in ADU development, which the City sites as a means for fulfilling a portion of RHNA requirements.
• Fair Housing: The City seeks to contain a majority of future residential development within the urban core of the City, where proximity to existing transit such as the NCTD Sprinter are located.

Concentrations of low -income units and incentivization of development hav e the potential to reinforce economic segregation and cause displacement of at -risk populations, such as low - income residents and communities of color. Therefore, the City includes Programs 2.1 - Accessory Dwelling Units, 2.9 - Inclusionary Housing Assessment, 2.10 - SB 9 Ordinance, and Program 3.4 - Fair Housing. These programs seek to increase affordable housing types, such as ADUs and urban lot splits and duplexes, within low density areas which are typically higher resourced than higher density areas; evaluate other forms of inclusionary housing than those assessed under the 2021 Housing Sector Feasibility Study; an d, explore education and adoption of anti -displacement regulations, facilitating community organizing and advocacy, and an environmental justice element with prioritization of improvements in disadvantaged communities. • ADU Development Trigger: The revised draft includes language added to Program 2.1 – Accessory Dwelling Units that would require exploring a density bonus on ADUs if development falls short of projections. The City tracks all ADU development in the City, including affordability rates. Data on affordability is provided by the applicant/developer and accessed annually as a part of the housing element’s annual reporting.
• Proposition S: Program 1.8 has been modified to include a requirement to assess Proposition S’ impact (if any) on housing production and fair housing within the City. • Table 45 of the draft element: The initial cities within Table 45 represented the “full service” cities located in North County San Diego. However, in response, the City revised Table 45-Planning and Development Fees Regional Comparison to include all cities along the Highway 78 corridor (i.e., San Marco and Vista fees are now included). The City of Vista fees are based on the July 2021 Fee Attachment "3"
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Schedule and the City of San Marcos fees are based on their adopted sixth cycle housing element.

Based on these added cities for comparison, planning fees from the City of Vista are comparable to that of Escondido, while City of San Marcos maintains fees costs relatively low compared to all other Highway 78 corridor cities. For impact/capacity fees, the City of Vista is higher than Escondido when it comes to parks fees, and traffic impact fees. City of San Marcos also has higher traffic impact fees, and substantially higher drainage fees than Escondido. Based on the City of Vista’s fee schedule and City of San Marcos’ adopted housing element, certain fees vary and so providing a total per unit fee cost based on the independently listed fees cannot be determined.

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July 7, 2021
Ms. Kristina Owens
Associate Planner
City of Escondido
201 North Broadway
Escondido, CA 92025
Submitted via email: [email protected]
Re: Draft 6th Cycle Housing Element
Dear Ms. Owens:

On behalf of the San Diego Housing Federation, we are writing to provide comments and feedback on the draft 6th Cycle Housing Element for the City of Escondido.

The draft Housing Element contains several actionable items that will help Escondido make progress toward meeting its housing goals. We applaud these components of the draft Housing Element and would like to make some additional recommendations to strengthen the plan’s impact on achieving housing goals.

Implementing State Legislation
The San Diego Housing Federation was a proud co-sponsor of AB 1486, a bill that strengthened and clarified the state’s Surplus Land Act. City implementation of this bill will help the city make progress toward the need for 3,113 low- and very-low income units for the Regional Housing Needs Allocation for the 2021-2029 cycle (p. 84). Identifying unused City-owned sites for housing can help to ensure the City is compliant with the State Surplus Land Act and helps support the development of affordable housing. We encourage Program 1.4 regarding City- owned land (p. 114) to include a provision to update city policies to comply with the Surplus Land Act.

We are pleased to see Program 1.6 to amend the City’s zoning ordinance to comply with state law (p. 115). We recommend that the City move quickly to implement AB 1763, a bill we supported which provides a density bonus for developments that are 100 percent affordable, to serve as a tool for building affordable housing. The City should also work to implement AB 2345, a bill we supported that builds on the success of the City of San Diego’s Affordable Homes Bonus Program (AHBP) by taking the program statewide. A report by Circulate San Diego, “Equity and Climate for Homes,” found that 63 percent of AHBP projects were located in high and highest resource census tracts, demonstrating the program’s role in affirmatively furthering fair housing.

Public Comments
PHG 20-0030
Comment Letter E - San Diego Housing Federation (SDHF)
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Local funding for affordable housing
The draft Housing Element recognizes the need for funding to build housing that is affordable to low-income individuals and families and that federal and state funding is a critical piece to the resources puzzle. We strongly support Program 2.7 to pursue funding sources for the construction, acquisition and rehabilitation, and preservation of affordable housing (p. 119). We recommend that the Housing Element specifically include a goal to prioritize funds made available through the Permanent Local Housing Allocation (PLHA), also known as the Building Homes and Jobs Act (SB 2, 2017), for the development of deed-restricted affordable housing.

Maximizing the use of these funds to build housing for extremely low-, very low-, and moderate income households will help the City meet its RHNA obligations. As local gap financing is critical, we also strongly support the City including recycled RDA funds as a local financing source.

Affirmatively furthering fair housing and equity
As noted in the housing element, there are two areas of poverty and racial concentration in Escondido (p. 99). As we know, housing development policies – how much and where new housing can be built – play a role in patterns of segregation within a community.

While Housing Policy 1.1 to expand the stock of all housing (p. 116) is laudable, the constraints created by the City’s Proposition S, which requires voter approval of specified future changes to the Escondido General Plan, can hinder the goals of those policies and can play a role in creating exclusion. We recommend that Program 1.7, Monitoring of Growth Management Measure (p. 115) be updated to fully examine the impact of Proposition S on housing production and fair housing goals.

We further recommend that the City work with HCD on AFFH recommendations as they relate specifically to Housing Elements and incorporate those recommendations in the plan.

Housing and Climate Change
Our September 2016 report, “Location Matters: Affordable Housing and VMT Reduction in San Diego County,” found that lower-income households are more likely to live in transit-rich areas, own fewer cars, are likely to live in larger building and smaller units, all factors that make affordable housing near transit a key greenhouse gas reduction strategy. The City’s Climate Action Plan calls for pursuing state grants such as the Affordable Housing and Sustainable Communities (AHSC) Grant to support affordable housing near transit (Climate Action Plan, March 2021, p. 3-14). However, the mentions of addressing climate change in the Housing Element are in relation to climate resilient homes and make no mention of dense, deed- restricted affordable housing as a greenhouse gas reduction tool nor pursuing AHSC funds. We urge the City to examine the role of affordable housing in helping the City to meet both its RHNA obligations and its Climate Action Plan goals.

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We thank you for consideration of our feedback and comments. We appreciate the time and effort that staff have dedicated to the draft Housing Element document and look forward to supporting Escondido in adopting a robust plan that will help to meet the City’s housing goals.

Sincerely,
Laura Nunn
Chief of Policy & Education
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Response to Comments
The SDHF’s letter outlines support for the implementation of recently approved state legislation in a timely manner. The City currently has programs within the draft housing element that outline the City’s effort to comply with any updates to state legislation, such as density bonus law and the Surplus Land Act.

SDHF comments on their support of the City’s draft Program 1.6 – Density Bonus and recommends the City include language in Program 1.4 – City-Owned Sites that requires the City comply with state law. The SDHF’s letter includes additional comments on local funding for affordable housing, including the prioritization of Permanent Local Housing Allocation (PLHA) funds for affordable housing development, as well as affirmatively furthering fair housing (AFFH) and equity and how Proposition S may impact AFFH, and including context in the draft document on how affordable housing can help the City meet its RHNA obligation and Climate Action Plan (CAP) goals.
• Fair Housing: The City seeks to contain a majority of future residential development within the urban core of the City, where proximity to existing transit such as the NCTD Sprinter are located.

Concentrations of low -income units and incentivization of development hav e the potential to reinforce economic segregation and cause displacement of at -risk populations, such as low - income residents and communities of color. Therefore, the City includes Programs 2.1 - Accessory Dwelling Units, 2.9 - Inclusionary Housing Assessment, 2.10 - SB 9 Ordinance, and Program 3.4 - Fair Housing. These programs seek to increase affordable housing types, such as ADUs and urban lot splits and duplexes, within low density areas which are typically higher resourced than higher density areas; evaluate other forms of inclusionary housing than those assessed under the 2021 Housing Sector Feasibility Study; and, explore education and adoption of anti- displacement regulations, facilitating community organizing and advocacy, and an environmental just ice element with prioritization of improvements in disadvantaged communities. • Proposition S: Program 1.8 has been modified to include a requirement to assess Proposition S’ impact (if any) on housing production and fair housing within the City. • Implementing State Legislation: The City recently updated the City’s Density Bonus Ordinance to comply with AB 1763 in October 2021. Additionally, staff revised Program 1.4 to include language requiring review of the City’s policies to ensure compliance with the Surplus Land Act. • Local Funding and Climate Change : The City added Housing Policy 1.11 to the draft document which outlines the City pursue funding, including the Affordable Housing and Sustainable Communities Grant and PLHA, for funding to support affordable housing projects. Additionally, Program 2.8 – Affordable Housing Development details the funding sources the City will pursue or continue to pursue for affordable housing for development within the City.

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Escondido Community Housing Coalition
July 26, 2021
Mayor and City Council
Planning Commissioners
City of Escondido
Via Email – Corrected version sent July 30, 2021
RE: Escondido Community Housing Coalition Recommendations for Amendments to Escondido Revised Draft Housing Element
Dear Mayor and City Council and Planning Commissioners:

The Escondido Community Housing Coalition (ECHC) is composed of social and environmental justice organizations within San Diego County that have united in advocating for the creation of inclusive, thriving communities, where every resident in the City of Escondido has access to affordable, safe, housing near job and transit centers.

We urge the Planning Commission and City Council to make the following revisions to the Draft Revised Escondido Housing Element (HE):

1. Create an Escondido Housing Commission.

Escondido has not had a Housing Commission for over 10 years. However, it is clear that such a commission is now timely and could be helpful to further housing goals in our city. We recommend that the EHE re-establish an Escondido Housing Commission. There seem to be many programs dispersed throughout the city that can be unified under a centralized Housing Commission. The Housing Commission in Oceanside is a successful model of community involvement and oversight of a city’s housing programs and initiatives. The mandatory public involvement requirement for the housing element could be achieved through a commitment to a Housing Commission. Housing is an important issue, especially now as the California Eviction Moratorium ends on September 30, 2021. Escondido needs to establish an advisory Housing Commission.

Comment Letter F – Escondido Community Housing Coalition (ECHC) Attachment "3"
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2. Require development of an Inclusionary Housing Ordinance for Escondido.

Ten of the 18 cities in San Diego County already have inclusionary housing ordinances (IHO). The County has directed its staff to create an IHO for the unincorporated area. The incentives-only strategy has thus far failed to serve the residents of Escondido with the affordable housing that is needed. We request that the Council direct staff to investigate and propose an IHO for Escondido with an ultimate goal of 25%, on-site, deed restricted, affordable housing requirement for nearly all new housing projects. If in-lieu fees are to be attached to a future IHO, we request that they be significant enough to result in actual affordable housing project construction. We recommend that Escondido require developers to pay an in-lieu fee of $25/sf such as is required by the City of San Diego. Last, other cities also include an in-lieu fee for projects between 2-10 units. This would be another aspect to include in the analysis.

3. Create a two-tiered approach to inclusionary housing.

As part of an IHO, we recommend the city establish a two-tiered inclusionary program. The first tier based on the existing zoning framework and the second associated with city actions that increase land values, such as plan updates, density bonuses, specific plans, and up-zonings. Those public actions can significantly increase land values and it is only fair and inclusive policy to recapture some of those increases for public benefit through higher inclusionary requirements.

4. Remove proposed housing locations within 500 feet of a freeway or routes heavily trafficked by diesel trucks.

Housing development within 500 feet of a major freeway or heavily trafficked road is extremely hazardous for human health and should not be used to house vulnerable residents. The California Air Resources Board (CARB) did a Land Use Guidance document in 2005 and its guidance is clear, avoid siting new sensitive land uses within 500 feet of a freeway, urban roads with 100,000 vehicles/day, or rural roads with 50,000 vehicles/day. Any targeted location for affordable housing development under the RHNA delegation should be removed and relocated to a more healthful location.

5. Remove proposed housing from locations in Very High Fire Severity Zones and concentrate in area served by transit and other existing infrastructure.

Sprawl development in high-VMT and high fire hazard areas is one of our region’s greatest sources of air emissions. Development in these areas threatens the health of all residents, especially those unable to protect themselves during fires. Directing infrastructure and maintenance resources away from the city core to support sprawl is an injustice and does represent equitable development. Further, it does not comport with the city’s General Plan commitment to sustainable development. The EHE should prohibit development of housing in hazardous fire areas far from existing infrastructure and should focus resources, time, and attention on funding and improving Escondido’s urban core

6. Urban Greening should be an integral part of improving housing in Escondido.

The recent heat waves are a direct threat to the health and well-being of residents in Escondido. Adequate tree canopies are known to lower heat in impacted areas as much as 10 degrees. The Priority Investment Neighborhoods designated in the Climate Action Plan should receive early planning and funding for increased tree canopy, parks, and green spaces where they are supported by the residents. Further, studies have shown that access to green spaces is Attachment "3"
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important for children and healthy families. We recommend that the EHE specifically commit to early focus on tree canopy and other green infrastructure improvement as described in the Escondido Climate Action Plan noted below.
“Develop an urban heat island reduction program that includes an urban forest program or plan for priority investment neighborhoods (“PINs”) that achieves a tree planting coverage of at least 35 percent. Expand and focus tree plantings in low canopy neighborhoods and neighborhoods at a higher risk of adverse outcomes of urban heat island effects and to encourage urban agriculture through edible landscapes within some publicly accessible areas.” (ECAP at 3-23)

7. EHE should include actions to specifically ensure Rent Forgiveness programs are accessed by residents and a Tenant Protection Ordinance and Rent Registry System should be adopted.

We recommend the EHE commit the city to create a Tenant Protection Board which would be responsible for providing legal, mediation, and arbitration services to tenants in Escondido to protect them from illegal evictions and homelessness. In addition, a Rent Registry System should be created where landlords can register their units with the city.

8. New Home buying programs should set higher performance goals and be expanded to include city-initiated/supported community land trusts.

Facilitating home ownership by low-income residents is an important means to create wealth that can lift people out of poverty. The current EHE stated goal for the First-Time Homebuyer Assistance proposed is to assist one family a year, which is extremely insufficient. We request that this target be set higher for this important effort. A proven program nationwide that can offer opportunities for ownership/wealth creation for low-income families is through Community Land Trusts (CLTs). We request that the EHE commit to collaborating with CLTs and developing programs for affordable housing development.

The member organizations of the Escondido Community Housing Coalition are committed to working with you and your staff to achieve housing goals for the city. Our coalition will continue to reach out to other organizations with an interest and expertise in housing. We understand that these issues are complex and need discussion and analysis and we look forward to an on- going process. We appreciate your consideration of these recommendations.

Sincerely,
Natasha Howell, Chair Housing Committee
Rob Jenkins, First Vice-President
North San Diego County NAACP
Yusef Miller, Director
North County Equity and Justice Coalition
Estela De Los Rios, Executive Director
CSA San Diego Fair Housing
Madison Coleman, Policy Advocate
Climate Action Campaign
Laura Hunter, Chair Conservation
Committee
Sierra Club North County Group
Evelyn Langston, President
Escondido Mobile Home Positive Action
Committee (EMPAC)
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Escondido Community Housing Coalition
Requests for Amendments to Escondido Housing Element 2022 February 10, 2022

1. Include an Escondido Housing Public Advisory Committee.

Meaningful public participation is an asset and will improve city programs and policies. Our key recommendation is that the Housing Element require the establishment of an appointed, scheduled, participatory public advisory committee to provide input and assist with outreach on housing related topics. This committee should be collaborative and not just informational. It should have a work plan, regular meetings, and serve as a hub where all residents feel invited and comfortable to participate. Spanish language interpretations should be provided. Other languages as needed.

2. Strengthen and Broaden the Affordable Housing Program:

The Affordable Housing Program should consist of the following strategies:
a. Requirement for all new housing development to have a percentage of deed-restricted, on- site affordable housing.
b. Reference the County’s Innovative Housing Trust Fund when creating Escondido’s Affordable Housing Trust Fund (AHTF). The AHTF must prioritize the development of low to middle income (30%-80% AMI), deed restricted housing in underserved communities near transit priority areas. All in-lieu fees should go into the AHTF. c. To improve the quality of life of Escondido residents the Housing Element must commit to the development of green spaces and tree shade canopies for urban dwellers. Escondido should commit $5 million to prioritizing the development of green spaces in underserved communities first.
d. Prioritize infill development, up-zoning, and missing middle income housing such the development of small/tiny housing villages, duplexes, triplexes, ADUs, the creation of ‘small lot ordinance, etc.
e. Create a rent registry to collect data and resources that will support legal services that give tenants more accessible and affordable housing opportunities. At a minimum, information collected through the Rent Registry will include:

1. Address of rental unit, type of unit, and rental payment

2. Name and address of property owner and landlord

3. Whether the landlord lives on-site or not

4. Declaration that all information required by the Tenant Protection Board is provided to each unit

3. Require Safe Housing Locations
a. All proposed and future housing development locations must be at least 500 feet away from the nearest freeway.

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b. Stop current sprawl development and prevent all future sprawl development.

Sprawl development in high VMT, high fire hazard areas is one of our region’s greatest sources of emissions. Approval of further sprawl projects, such as Harvest Hills, will only exacerbate the climate crisis. We urge the Council to pass a Housing Element that requires all new housing developments to align with SB 743 and are near existing and future mobility hubs.

4. Understand our history and require projects to meaningfully embed equity by conducting Racial Equity Impact Assessments (REIA).

A Racial Equity Impact Assessment (REIA) is one way to conduct a systematic examination of how different racial and ethnic groups—with attention to the full spectrum of intersecting marginalized identities—will be affected by a proposal. We request the city follow the guidelines contained in NAACP’s Guidelines for Equitable Community Involvement in Building & Development Projects and Policies

5. Amend policies in key East Valley Specific Plan adopted policies as follows (changes in underline) LU-2.2: Support a flexible range of housing types – such as smaller unit sizes, compact housing types, live-work, ancillary dwelling units, tiny or studio home villages, or other innovative housing formats and design techniques.

LU-2.3: Develop or identify new incentives for affordable housing within the Plan Area, such as innovative funding sources like tax credit programs, community land trusts, coops, re- villaging efforts, small lot zoning, and public-private partnerships.

LU-2.4: Offer a range of options for development of ordinances which establish a clear plan to meet and fulfill affordable housing requirements.

LU-2.7: Improve the quality and availability of housing by addressing declining homeownership, neighborhood stability and overcrowding by establishing an ambitious program to support homeownership in priority areas.

LU-2.8: Establish an Affordable Housing Trust Fund (AHTF) to assist in the delivery of affordable housing within the Plan Area. The AHTF should be used to provide affordable housing for lower and middle income households. The AHTF can be used to augment State and Federal programs to expand affordable housing opportunities for these underserved groups and to meet the requirements of an affordable housing development program.

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May 25, 2022
Ms. Sohab Mehmood, Department of California Housing and Community Development Ms. Veronica Morones, City of Escondido
Via Email [email protected], [email protected]

RE: Escondido Community Housing Coalition request for revisions to Escondido Draft Housing Element
Dear Ms. Mehmood and Ms. Morones:

The undersigned members of the Escondido Community Housing Coalition (ECHC) are writing today regarding the new draft of the Escondido Housing Element. Since we have limited resources, we ask that this letter serve as our comment letter to the city on the new draft and our comment letter to Housing and Community Development (HCD) if no changes to it are made by the city.

As drafted, the ECHC urges the city to make the following revisions and urges HCD to deny certification until three major amendments are made.

1. Housing Element should require development of an inclusionary housing ordinance.

Requirements for affordable housing in development is an urgent need for Escondido.

There is no need to ‘wait and see’ if future projects yield adequate affordable housing. The failure of the 5th Housing Cycle is evidence enough that requirements are needed in this 6th cycle plan. The results of the 5th Housing cycle report showed Escondido has developed only 13.5% of requirements for very-low income, 17% for low income, and 15% of the goal for moderate, but 119% for above moderate market rate housing.

The development of Palomar Heights is also prime and recent example of Escondido’s failure to secure affordable housing. This project was located on an old hospital site, a perfect location in the center of the urban core and on transit corridors. The final project was significantly under density (by 500 units) with no deed restricted affordable housing.

By now we know the future of affordable housing development in Escondido if an inclusionary housing (IH) ordinance is not in place.

ECHC has been advised by Mr. Nico Calavitas, Professor Emeritus of Land Use Planning at San Diego State University regarding appropriate means to phase in inclusionary requirements. He suggests a reasonable dual approach, one based on IH applied to existing zoning, as in the case of typical IH ordinances, and the other based on plan changes or up- Attachment "3"
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zonings in areas slated for development (see attached article: “Inclusionary Housing, Incentives and Land Value Recapture”). IH requirements would be higher in the second case because land values would increase as a result of up-zonings, plan changes or updates.

How land value changes up (up-zonings) or down should be an integral part of an IH study, including the desirability of a phasing approach to allow for land markets to adjust to plan changes and regulations.

2. Housing Element should include a true public engagement committee or commission.

Second, the element is still deficient in community participation and engagement around the important issue of housing. The Escondido Community Housing Coalition has repeatedly requested a re-start of the Housing Commission or a Housing Working Group as a place where housing issues can be studied, addressed, and improved. The cited Council Subcommittee, which meets during work hours, and has not (until recently) been noticed to the public is inadequate. In fact, the stated purpose of the Subcommittee in the new draft is "to discuss pertinent housing issues within the City and convey information to City staff on such matters." Without any acknowledgement or commitment to engaging the public.

3. Please remove RHNA housing sites from areas adjacent to the freeway, a known high health hazard area.

Repeated commenters requested that housing be moved at least 500 feet away from freeways per Air Resources Board Guidance. The response of the city to move that issue to the Community Safety Element (CSE) update is not responsive. The risks are known now and we are concerned that these unsafe sites may be considered, ‘grandfathered’ in as it will be too hard to change the Housing Element once certified. This is a long known, existing problem and housing should not be located there. Please remove these locations.

In conclusion, ECHC strongly requests that the city amend or HCD reject this draft until these important aspects are improved.

Thank you for the consideration of our comments. Please communicate with us the results of your actions. We can be reached at [email protected].

Sincerely,
Robert Jenkins, North San Diego County NAACP
Yusef Miller, North County Equity and Justice
Coalition, Clean Earth4Kids
Estela De Los Rios, CSA San Diego County
Madison Coleman, Climate Action Campaign
Yazmin Doroteo, North County Resident
Xochitl Castillo, Escondido Resident
Emilia Ruiz Venegas, Escondido Resident
Barbara Valle, Escondido Resident
Estela Chamu, Escondido Resident
Estela De Los Rios, CSA San Diego County
Laura Hunter, Sierra Club North County Group
Christine Nava, Escondido Resident
Joanne Tenney, Escondido Resident
Patricia Borchmann, Escondido Resident
Joan DeVries, Escondido Mobile Home Positive
Action Committee
Nico Calavita, Professor Emeritus, San Diego
State University
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Response to Comments
The ECHC’s letters outline support for a housing public advisory committee and housing commission, an inclusionary housing ordinance , affordable housing trust fund, and other affordable housing programs, the removal of RHNA sites from within 500-feet of a freeway and truck routes, removal of RHNA sites from very high fire hazard severity zones, urban greening, tenant protections, and new home buying programs.

The ECHC discusses concerns regarding the potential environmental justice concerns that may result from RHNA sites located within 500-feet of freeways and truck routes, as well as those associated with RHNA sites located in the very high fire hazard severity zones. The ECHC requests the City conduct a racial equity impact assessment for the City to examine how different racial and ethnic groups will be affected by the 6th cycle draft housing element.

Lastly, the ECHC highlights several recommended text changes to the draft East Valley Specific Plan, which is a project under the Housing and Community Investment Study (HCIS) process. • Inclusionary Housing: The City conducted a residential sector feasibility study (study) as a part of the Housing and Community Investment Study (HCIS) process. The study presents an economic analysis to evaluate the financial feasibility of various new construction residential product types and densities, and the cost for developers to comply with an onsite affordable housing obligation through application of an inclusionary housing ordinance. The study concludes that an inclusionary mechanism 10% low, or 5% low and 5% very low would be economically infeasible for all but one housing product type (for -sale townhomes) analyzed. The City staff included revisions to the draft housing element to address further study and research on inclusionary mechanisms, including land value recapture (Program 2.9 – Inclusionary Housing Assessment). • Housing Commission/Advisory Committee: The City of Escondido discontinued its Housing Commission due to lack of funding (primarily a result of the dissolution of redevelopment). The Housing Commission’s responsibility included outreach and coordination of housing programs. In 2021, the City Council established the Housing Subcommittee, an ad hoc committee comprised of two councilmembers, a representative from the City Manager’s Office, the City Clerk, counsel from the City Attorney’s Office, and the Director of Community Development. The Housing Subcommittee’s purpose is to discuss pertinent housing issues within the City and convey information to City staff on such matters. At the most recent housing subcommittee meeting, held on April 21, 2022, the topics discussed included an update on the 6th cycle housing element process, and presentation by the City’s qualified fair housing provider, the Legal Aid Society of San Diego.
• Affordable Housing Trust Fund: The draft East Valley Specific Plan would include development of an Affordable Housing Trust Fund to assist in the delivery of affordable housing within the Plan Area. Likewise, an in -lieu fee for development proposed below minimum density thresholds would be used by the trust fund to develop moderate- and low-income housing developments. • Review Periods/Public Participation: Subsequent to the August 2021 adoption, and in response to concerns regarding review periods of revised drafts and the need for additional public participation, the City provided a voluntary 30-day review period on the initial revised draft of the housing element in May 2022, and held a public meeting on May 10th at the regularly scheduled planning commission to inform the planning commission and general public of revisions included in the draft housing element. Subsequent revisions to the May 2022 draft included additional Attachment "3"
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refinement to meet HCD’s concerns regarding AFFH programs. The City provided a voluntary 14- day review period for the revisions submitted to HCD in October 2022; the October revisions are the changes proposed for adoption.
• Air Quality and Fire H azards: The City is currently working on an update to the City’s Safety Element, known as the Community Protection chapter of the General Plan and creation of a new environmental justice element— both of which are required as a direct result of the 6 th Cycle
Housing Element Update. Specifically, SB 1035 requires the General Plan Safety Element to be reviewed and revised to include any new information on fire hazards, flood hazards, and climate adaptation and resiliency strategies with each revision of the ho using element. These elements will discuss fire hazards surrounding development within the City and air quality concerns as they relate to safe and sanitary housing and pollution burden for communities. • Sites within Fire Zones: The current suitable sites inventory for the draft housing element includes 18 sites, with a potential for 149 new dwelling units, out of a total 888 sites with a potential for 9,463 units, that contain a portion of their area designated as very high fire hazard severity zone area. Of those 18 sites, 7 are wholly located within the very high fire hazard severity zone, meaning the total area of the site is designated as such. These 18 sites account for approximately 2% of the total sites inventory and the potential for 149 new units account for approximately 1.5% of the total new dwelling unit potential.
• Fair Housing: The City seeks to contain a majority of future residential development within the urban core of the City, where proximity to existing transit such as the NCTD Sprinter are located.

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STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
August 10, 2021
Mik
e Strong, Director
Community Development Department
City of Escondido
201 North Broadway
Escondido, CA 92025
Dear M
ike Strong:

RE:

Review of Escondido’s 6th Cycle (2021-2029) Revised Draft Housing Element Update
Thank y
ou for submitting the City of Escondido’s (City) revised draft housing element received for review on June 17, 2021. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. In addition, HCD considered comments from Lauren Harper, Erik Felix, and Escondido Community Housing Coalition, pursuant to Government Code section 65585, subdivision (c).

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

1. Aff
irmatively further[ing] fair housing (AFFH) in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)
Prom
ote AFFH 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).)
The ele
ment includes some data and information regarding AFFH but must still add data and analysis to address this statutory requirement, as follows:

Comment Letter G – California Department of Housing and Community Development (HCD) Attachment "3"
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Local Data and Knowledge: Local data and knowledge is information obtained through community participation, consultation with stakeholders, and peoples lived experiences in your City and captures unique aspects about your community that is not usually reflective in state or federal data. For example, the City should review comments and feedback received from the public while updating the housing element and through other planning processes, including formal comment letters, such as those from Lauren Harper, Erik Felix, and Escondido Community Housing Coalition, regarding AFFH strategies.

Other Relevant Factors: The element must include information on other relevant factors. Other relevant factors include past changes in zoning and land use rules that have impacted segregation patterns, known past redlining activities, restrictive covenants or any other discriminatory practices such as community opposition, lack of investment in certain communities, historical context and relevant demographics.

Strategies and Actions:

Hous
ing Mobility – Housing mobility strategies consist of removing barriers and enhancing access to areas of opportunity. The City has census tracts that could be considered racially concentrated areas of affluence (RCAA). These tracts also have access to better schools, higher environmental quality, and are considered moderate resourced areas. While the element does include some mobility strategies, such as allowing accessory dwelling units (ADU) on places of worships, given the fair housing conditions in the City, the element must include stronger programs to truly overcome existing patterns of segregation and enhance access to areas of opportunity.

Plac
e-Based Strategies – The City has concentrated a large portion of its lower-income Regional Housing Needs Allotment (RHNA) in census tracts that are also considered as racially/ethnically concentrated areas of poverty (R/ECAP) and have several fair housing issues including a concentration of households experiencing disproportionate housing needs, low resources, and significantly lower education domain scores compared to other neighborhoods with largely white populations. The element includes adopting the EVSP, “focusing planning and intervention programs in areas currently experiencing social or environmental injustice,” and the City will “consider” establishing equity considerations for planning projects. These actions do not adequately encourage community revitalization and conservation, replace segregated living patterns, and transform these census tracts into areas of opportunity. Programs and actions must clearly list milestones, metrics, deliverables and implementations dates with clear commitments to the actions. For example, the element could utilize place-based strategies in the EVSP.

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Displacement Risks – The element must add or modify programs to address the risk of displacement. Programs included requiring by-right approval for sites are being reused from the last planning period and rezoned, pursuing one affordable housing project and prioritizing funding for rehabilitation in the downtown (p.139).

The City has several communities located in the central part of the City that are vulnerable to displacement (p.E-45). These census tracts also have several overlapping fair housing issues noted above. The element must be revised to include programs and strategies targeted to specific census tracts and seek to minimize displacement risks.

For technical assistance and further guidance, including sample policies and strategies, please visit HCD’s AFFH Memo at:
https://www.hcd.ca.gov/community-development/affh/index.shtml.

Suitability of Nonvacant Sites: The element includes some analysis to address the potential for redevelopment on nonvacant sites using three factors:
improvement to land value, age of structures, and number of additional units that could be added to a property (new net unit ratio). The analysis states that sites with existing uses were only considered if the building age was at least 31 years or older. The sites inventory includes a column titled “year built.” After further follow-up with the City, HCD has found that the inventory included several sites where the existing structures was built from 2000-2020, making that existing structure anywhere from 1-20 years old. This appears inconsistent with the methodology listed in the element or is not adequately supported by analysis.

Additionally, several sites in the element with existing uses such as neighborhood shopping centers, garage parking lots, used car lots, generic commercial, etc., are listed as “unknown” under building age. The inventory should be revised to only include sites with a known building age and where the existing uses are at least 31 years or older as supported by the analysis.

The element stated that sites that could add a minimum of five times the existing units were included in the inventory. However, the inventory includes several sites that have new net unit ratio of 1-4. For example, several sites identified to accommodate above moderate-income households list a new net unit ratio at two. The element should be revised to remove these sites. Additionally, the element includes past projects that achieved a new net ratio ranging from 15-40 additional units per site. These examples do not support the assumption of using a new net ratio of five. Rather, the examples demonstrate that the new net ratio should be at a higher threshold than five. The element should be revised to Attachment "3"
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remove sites with a new net unit ratio of five or provide examples that support this assumption.

Small Sites: Sites smaller than a half-acre in size are deemed inadequate to accommodate housing for lower-income households unless it is demonstrated that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower-income housing units as projected for the site or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower-income housing (Gov.

Code, § 65583.2, subd. (c)(2)(A).). While the element includes an analysis discussing how small sites are appropriate to accommodate lower-income housing, given the strong reliance on utilizing small sites for the lower-income RHNA, the element must be revised to include commensurate programs with incentives that facilitate development on small sites. Additionally, the element must include a program that monitors development on small sites and commits to alternative actions as appropriate by a date certain.

The element will meet the statutory requirements of State Housing Element Law once it has been revised to comply with the above requirements.

As a reminder, the City’s 6th cycle housing element was due April 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 make revisions to the element as described above, adopt, and submit to HCD to regain housing element compliance.

To remain on an eight-year planning cycle, the City must adopt its housing element within 120 calendar days from the statutory due date of April 15, 2021 for San Diego Association of Governments (SANDAG) localities. If adopted after this date, Government Code section 65588, subdivision (e)(4), requires the housing element be revised every four years until adopting at least two consecutive revisions by the statutory deadline. For more information on housing element adoption requirements, please visit HCD’s website at:
http://www.hcd.ca.gov/community-development/housing-
element/housing-element-memos/docs/sb375_final100413.pdf.

Pursuant to Government Code section 65583.3, subdivision (b), the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory.

Please see HCD’s housing element webpage at
https://www.hcd.ca.gov/community-
development/housing-element/index.shtml for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance.

Please note, upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to [email protected].

Attachment "3"
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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 will meet housing element requirements for these and other funding sources.

HCD appreciates the hard work and responsiveness City staff Jessica Relucio, you, and the City’s consultants Veronica Tam, Jamie Power, Aaron Barrall, and Dan Wery provided during the course of our review. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Sohab Mehmood, of our staff, at [email protected]
.

Sincerely,

Shannan West
Land Use & Planning Unit Chief
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STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
August
2, 2022
Mik
e Strong, Director
Community Development Department
City of Escondido
201 North Broadway
Escondido, CA 92025
Dear M
ike Strong:

RE: E
scondido’s 6th Cycle (2021-2029) Revised Draft Housing Element Update Thank y
ou for submitting the City of Escondido’s (City) revised draft housing element received for review on June 2, 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. In addition, HCD considered comments from Escondido Community Housing Coalition and Sierra Club North County Group (NCG), pursuant to Government Code section 65585, subdivision (c).

The re
vised draft element addresses many statutory requirements; however, the following revisions will be necessary to comply with State Housing Element Law (Article

10.6 of the Gov. Code):

1. Aff
irmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)
Prom
ote 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... (Gov. Code, § 65583, subd. (c)(5).) Strategies, Actions, Metrics, and Milestones: HCD’s prior review found that the element must include stronger actions to address housing mobility, displacement risks, and place-based strategies. Additionally, prior reviews found that the element must include metrics or numeric objectives to target meaningful affirmatively furthering fair housing (AFFH) outcomes in the planning period.

While the element included revisions, it still should be revised with significant programs to enhance housing mobility and include quantifiable metrics or numerical objectives to target beneficial impacts for people, households, and Attachment "3"
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nei
ghborhoods (e.g., number of people or households assisted, number of housin
g units built, number of parks or infrastructure projects completed). HCD will be following up under a separate cover with additional information and specific guidance.

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... (Gov. Code, § 65583, subd. (a)(3).) Suitability of Nonvacant Sites: While the element now clearly details the methodology and criteria used when identifying sites, it should support the assumptions and criteria utilized as part of the methodology. For example, the element included project examples in Appendix B and anecdotally discussed projects throughout the analysis. However, several of the projects discussed did not align with the criteria utilized. The examples listed in Appendix B only highlighted existing uses and occasionally referenced the land to improvement ratio (LIR) while the methodology considered, at minimum two out of three factors including building age, LIR, and new net ratios. To clearly relate project examples to the methodology, the element could include a table listing out project examples with the same characteristics utilized in the methodology. The examples should also include information about existing uses, location and affordability.

As a reminder, since the element relies upon nonvacant sites to accommodate more than 50 percent of the regional housing needs allocation (RHNA) for lower- income households, absent of findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and nonvacant sites will not be utilized toward demonstrating adequate sites to accommodate the RHNA. The City’s resolution for the adopted housing element (adopted August 11, 2021) did not include the required findings. Any future re-adoption of the housing element must include the appropriate finding as part of the adoption resolution.

The ele
ment will meet statutory requirements of State Housing Element Law once it has been revised and adopted to comply with the above requirements pursuant to Government Code section 65585.

Purs
uant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), a jurisdiction that failed to adopt a compliant housing element within one year from the statutory deadline cannot be found in compliance until all required rezones of sites pursuant to Government Code section 65583, subdivision (c),paragraph (1), subparagraph (A) and Government Code section 65583.2, subdivision (c) are completed. As the year has Attachment "3"
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passed and Program 1.1 (Sites Inventory and No Net Loss…) and Program 1.3 (By- right Approvals on Reuse Sites…) has not been completed, the housing element is out of compliance and will remain out of compliance until the rezoning have been completed.

For your information: Pursuant to Government Code section 65583.3, subdivision (b), the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory (for all income-levels). Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-development/housing-element/index.shtml for a copy of the form and instructions. Please note, upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to [email protected].

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element 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. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

HCD appreciates the hard work and responsiveness of City staff Adam Finestone and Veronica Morones during the review. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Sohab Mehmood, of our staff, at [email protected].

Sincerely,

Paul McDougall
Senior Program Manager
Attachment "3"
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Response to Comments
The Department of Housing and Community Development (HCD) provided comments outlining items for revisions that are necessary to comply with State Housing Element Law. Specifically, HCD details the City’s need to provide further data and information regarding local data and knowledge, other relevant factors, and strategies and actions as they all relate to affirmatively furthering fair housing (AFFH). HCD also noted the City’s need to clarify the suitable sites inventory methodology and utilization of small sites. Direction from HCD included additional public participation during the housing element adoption process.

August 2, 2022
• Strategies, Actions, Metrics, and Milestones: City staff revised a number of existing housing element programs to include metrics, milestones, and actions that work to address affirmatively furthering fair housing concerns. Changes made include the following o Program 3.2 – Focus on Neighborhoods: Language added quantifying number of families and individuals the City seeks to aid with tenant rental assistance, as well as a tim eline metric.
o Program 3.4 – Fair Housing: Language added to numerous sections that include quantifying number of outreach/public participation meetings associated with the fair housing program and their timeline; quantifying of individuals/families/units for achievement throughout the program; and identification of place -based strategies with milestone metrics.
• Suitability of Nonvacant Sites: City staff provided additional language to Appendix B clarifying whether identified example projects support the assumptions and criteria utilized as part of the revised methodology.

August 10, 2021
• Public Participation: Subsequent to the August 2021 adoption, and in response to concerns regarding review periods of revised drafts and the need for additional public participation, the City provided a voluntary 30-day review period on the initial revised draft of the housing element in May 2022, and held a pu blic meeting on May 10th at the regularly scheduled planning commission to inform the planning commission and general public of revisions included in the draft housing element. Subsequent revisions to the May 2022 draft included additional refinement to meet HCD’s concerns regarding AFFH programs. The City provided a voluntary 14- day review period for the revisions submitted to HCD in October 2022; the October revisions are the changes proposed for adoption.
• Local Data Knowledge: The revised draft document includes summarized comments received at City Council meeting and potential programs to explore in the future. City staff reviewed public comments and staff met with commenting parties (i.e., SCNCG, Erik Felix and Lauren Harper, SDHF, and ECHC). Changes to the draft housing element as a result of local knowledge integration are noted beginning page E -43 through E -44. Additional information added/revised regarding public comment can be found under Section 1(D): Public Participation, on page 6. • Other Relevant Factors: City staff added language regarding past practices, such as redlining, and specific City ordinances regarding impediments to housing of protected classes, on page E-44. An Attachment "3"
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inclusionary strategy has been added under Program 2.9. Additional revisions have been made to Programs 3.2, 3.3., and 3.4 regarding housing strategies. • Suitability of Nonvacant Sites: A dditional discussion on how providing additional opportunities in the EVSP and Downtown will help rejuvenate stagnant or declining neighborhoods in the absence of redevelopment has been added on page E-58.
o Building age data was not available for over 300 buildings/sites. The City’s c onsultant team manually identified and verified building age using assessor parcel data and aerial imagery. All 888 RHNA sites now include a verified age. This enabled the use of building age as one of several selection criteria for underutilized land. All of the buildings on the RHNA sites list are at least 30 years old or older, with many much older. Approximately 130 sites were confirmed to not include any buildings other than a small storage shed. o The inventory is conservative in that many sites are excluded due to a series of restrictive filters based on land use, ownership, lot size, environmental constraints, etc. Remaining eligible sites were then selected and prioritized as the best and most suitable and likely sites to be developed within the next 8 years based on additional criteria including:
underutilization, development potential, and strong profit motive. All 888 RHNA sites now meet at least 2 of the 3 primary selection and prioritization criteria of: Land -to- Improvement Ratio >1.0; Building Age > 30 Years; and/or Net New Unit Ratio 5.0 or greater. This revision resulted in the following:
 Eliminated approximately 18 sites that only met one of the three primary criteria.

This resulted in a loss of 58 units (25 lower, 15 moderate, 18 above moderate).  The inventory was amended to include additional site eligibility, substantiation and prioritization criteria including:
a. Sites within ½ mile of transit stops (800, 90%)
b. Sites within ¼ mile of services, employment, community facilities (600, 68%)
c. Sites in Specific Plans with infrastructure, improvement plans, incentives (600, 68%)
d. Sites in areas exhibiting redevelopment and affordable housing (727, 82%)
e. Low-moderate density lots with capacity to add moderate to above- mod income units without displacing existing units (317, 36%) o The narrative was revised to compare and justify the extremely conservative Net New Unit Ratio of 5.0+ relative to the 0.25 and 1.0 ratios used by other cities in the San Diego region.
o The total RHNA site inventory has increased by 800 units from 8,663 to 9,346. Part of this increase was a result of an adjustment of the assumed project yield for very high-density zoned sites from 50% to 62.5% as supported by the documented yield trend analysis (refer to pages 52 – 54).
o Increased the project yield from 50% to 62.5% for sites in the Downtown Specific P lan zoned for 75-100 du/ac.
• Small Sites: The narrative on page 89 was revised to note that lot consolidation is not a significant impediment to housing development in the region or Escondido. It occurs as part of the normal course of the land development process and is common to a large percentag e of development Attachment "3"
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projects. It occurs as part of the market conditions without incentive or subsidy as demonstrated by the projects described in the chapter. Program 1.5 - Lot Consolidation has been modified to implement incentives for lot consolidation no later than end of 2023. Additionally, a mechanism for review of lot consolidation and development has been added so ensure monitoring of lot consolidation trends.

Attachment "3"
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VIA E-MAIL
August 22, 2022
Zack Beck, City Clerk
City Hall, Second Floor
201 North Broadway
Escondido, CA 92025
Em: [email protected]
Veronica Morones, Senior Planner
City of Escondido
201 North Broadway
Escondido, CA 92025
Em: [email protected]
RE: City of Escondido’s Housing and Community Investment Study and 2021-2029 Housing Element Update
Dear Zack Beck and Veronica Morones
On behalf of the Southwest Regional Council of Carpenters (“Southwest Carpenter” or “SWRCC”), my Office is submitting these comments for the City of Escondido’s (“City”) August 23, 2022, Planning Commission Hearing for the 2021-2029 Housing Element Update (“Project”).

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

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

SWRCC expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearings and proceedings related to this Project. Cal. Gov. Code § 65009(b); Cal. Pub. Res. Code § 21177(a); Bakersfield Citizens Comment Letter H– Southwest Regional Council of Carpenters (SWRCC) Attachment "3"
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for Local Control v. Bakersfield (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121.

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

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

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

Community benefits such as local hire and skilled and trained workforce requirements can also be helpful to reduce environmental impacts and improve the positive economic impact of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing localized economic benefits. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:
[A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the signif icance of the Attachment "3"
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reduction would vary based on the location and urbanization level of the project site.

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

Skilled and trained workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the UC Berkeley Center for Labor Research and Education concluded:
. . . labor should be considered an investment rather than a cost – and investments in growing, diversifying, and upskilling California’s workforce can positively affect returns on climate mitigation efforts. In other words, well trained workers are key to delivering emissions reductions and moving California closer to its climate targets.
1 Local skilled and trained workforce requirements and policies have significant environmental benefits since they improve an area’s jobs-housing balance, decreasing the amount of and length of job commutes and their associated greenhouse gas emissions. Recently, on May 7, 2021, the South Coast Air Quality Management District found that that the “[u]se of a local state-certified apprenticeship program or a skilled and trained workforce with a local hire component” can result in air pollutant reductions.
2 Cities are increasingly adopting local skilled and trained workforce policies and requirements into general plans and municipal codes. For example, the City of Hayward 2040 General Plan requires the City to “promote local hiring . . . to help 1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https://laborcenter.berkeley.edu/ wp-content/uploads/2020/09/Putting-California-on-the-High-Road.pdf. 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http://www.aqmd.gov/docs/default- source/Agendas/Governing-Board/2021/2021-May7-027.pdf?sfvrsn=10.

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achieve a more positive jobs-housing balance, and reduce regional commuting, gas consumption, and greenhouse gas emissions.”3
In fact, the City of Hayward has gone as far as to adopt a Skilled Labor Force policy into its Downtown Specific Plan and municipal code, requiring developments in its Downtown area to requiring that the City “[c]ontribute to the stabilization of regional construction markets by spurring applicants of housing and nonresidential developments to require contractors to utilize apprentices from state-approved, joint labor-management training programs, . . .”
4 In addition, the City of Hayward requires
all projects 30,000 square feet or larger to “utilize apprentices from state-approved, joint labor-management training programs.”5
Locating jobs closer to residential areas can have significant environmental benefits. .

As the California Planning Roundtable noted in 2008:

People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.
6 In addition, local hire mandates as well as skill training are critical facets of a strategy to reduce vehicle miles traveled. As planning experts Robert Cervero and Michael Duncan noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions since the skill requirements of available local jobs must be matched to those held by local residents.
7 Some municipalities have tied local hire and skilled and 3 City of Hayward (2014) Hayward 2040 General Plan Policy Document at p. 3-99, available at https://www.hayward-ca.gov/sites/default/files/documents/General_Plan_FINAL.pdf. 4 City of Hayward (2019) Hayward Downtown Specific Plan at p. 5-24, available at https://www.hayward-c a.gov/sites/default/files/Hayward%20Downtown% 20Specific%20Plan.pdf.
5 City of Hayward Municipal Code, Chapter 10, § 28.5.3.020(C). 6 California Planning Roundtable (2008) Deconstructing Jobs-Housing Balance at p. 6, available at https://cproundtable.org/static/media/uploads/publications/cpr-jobs- housing.pdf
7 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: Jobs- Housing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT- 825.pdf.

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trained workforce policies to local development permits to address transportation issues. As Cervero and Duncan note:

In nearly built -out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing.” The city’s First Source program encourages businesses to hire local residents, especially for entry- and intermediate-level jobs, and sponsors vocational training to ensure residents are employment -ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.

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

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

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

Attachment "3"
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Response to Comments
The Southwest Regional Council of Carpenters (SWRCC) provided written comment to the City regarding the draft adopted Housing Element. Specifically, SWRCC requests the City require the use of local skilled and trained workforce for development within the City for the benefit of economic development, and reduction in vehicle miles traveled (VMT) and greenhouse gas emissions. The SWRCC submitted the above letter in both May and August 2022, which includes an approximately 257-page greenhouse gas modeling exhibit. Since the two letters provide the same content, an excerpt of the August 22, 2022 cover letter is provided. For the May 10, 2022 letter and 257 -page greenhouse gas modeling exhibit, please follow the below link:
https://www.escondido.org/Data/Sites/1/media/Planning/HCIS/publiccommentletters/20220510_SWR CC_EscondidoHousing_Comment_Complete.pdf
• Local Skilled and Trained Workforce: The City has received the comment letters from the SWRCC requesting policy language requiring the use of local skilled and trained workforce for development. The City does not build housing; however, the Housing Element does create a plan and regulatory framework that provides opportunities for the private sector to do so where market conditions determine when and where housing is built. As a result, the City is not pursuing policy inclusion mandating the use of local skilled and trained workforce as it pertains to residential construction.

Attachment "3"
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City of Escondido
201 North Broadway
Escondido, CA 92025
[email protected]
[email protected]
December 27, 2022
RE: Legal Aid Society of San Diego’s Review of the City of Escondido’s Housing Element of the General Plan for Compliance with the Statutory Obligation to Affirmatively Further Fair Housing
Dear City of Escondido:

Thank you for your commitment to promot ing equal housing opportunities in the City of Escondido (“the City”). The U.S. Department of Housing and Urban Development has tasked the Fair Housing team at the Legal Aid Society of San Diego to educate public housing authorities, subsidized housing providers, and entitlement jurisdictions on their fair housing responsibilities. As such, we have reviewed the City of Escondido’s General Plan Housing Element and Consolidated Plan. We trust that the City will strongly consider the following recommendations in order to remain in compliance with the current statutory obligation to affirmatively further fair housing (“AFFH”).

Housing Element
The AFFH obligation, codified in the federal Fair Housing Act of 1968, mandates that all federal agencies, including HUD and its funding recipients, take steps to proactively address segregation associated with programs and activities related to housing and community development. 42 USC 3608, et seq. In 2015, HUD issued a rule to strengthen the analysis and reporting required by AFFH. However, in 2018, this rule was suspended. Currently, the definitions contained in the 2015 rule have been reinstated, but there is no obligation under federal fair housing law to conduct an analysis under the 2015 rule. Nevertheless, the City, like all public agencies in California, must abide by state law and perform an analysis under the strengthened 2015 rule. See Cal. Gov. § 8899.50, et seq.

Generally, AFFH obligates a public agency to:
…Tak[e] meaningful actions, in addition to combating d iscrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.

Specifically, affirmatively furthering fair housing means taking meaningful Comment Letter I – Legal Aid Society of San Diego (LASSD) Attachment "3"
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actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of po verty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws.

Gov. § 8899.50(a)(1).

Within the AFFH obligation is a requirement that Housing Elements contain an AFFH analysis which includes:

(i) A summary of fair housing issues in the jurisdiction and an assessment of the jurisdiction's fair housing enforcement and fair housing outreach capacity. (ii) An analysis of available federal, state, and local data and knowledge to identify integration and segregation patterns and trends, racially or ethnically concentrated areas of poverty and affluence, disparities in access to opportunity, and disproportionate housing needs, including displacement risk. The analysis shall identify and examine such patterns, trends, areas, disparities, and needs, both within the jurisdiction and comparing the jurisdiction to the region in which it is located, based on race and other characteristics protected by the California Fair Empl oyment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2) and Section 65008. (iii) An assessment of the contributing factors, including the local and regional historical origins and current policies and practices, for the fair housing issues identified under clauses (i) and (ii).
(iv) An identification of the jurisdiction's fair housing priorities and goals, giving highest priority to those factors identified in clause (iii) that limit or deny fair housing choice or access to opportunity, or negatively impact fair housing or civil rights compliance, and identifying the metrics and milestones for determining what fair housing results will be achieved. (v) Strategies and actions to implement those priorities and goals, whi ch may include, but are not limited to, enhancing mobility strategies and encouraging development of new affordable housing in areas of opportunity, as well as place-based strategies to encourage community revitalization, including preservation of existing affordable housing, and protecting existing residents from displacement.

Gov. § 65583(c)(10)(A).

Given this statutory framework, we issue the following recommendations. As a preliminary matter, we note that our analysis is based on the City’s most recent publicly available Housing Element, whether in draft or final form.

1. Perform an Analysis of Impediments to Fair Housing Choice specific to the City of Escondido.

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The Housing Element is informed by an Analysis of Impediments report (“AI”) which analyzes fair housing choice throughout the County of San Diego. While the AI contains tables with data specific to each jurisdiction, much of the analysis considers this data in the aggregate, for the County as a whole. We recommend issuing an AI which focuses its discussion of historical residential settlement patterns, analysis of demographic data, and proposed fair housing action plan on the City of Escondido, rather than the San Diego region.

We recommend the jurisdiction identi fy specific action items and implement timeframes for completing them. Accountability measure should be implemented to ensure completion of these action items by their deadlines. For example, agency departments and specific staff should be designated as re sponsible parties for completing action items and should be responsible for reporting on progress or lack thereof to supervisors and/or city council. This approach should be applied to those housing programs which contain specific milestones, timeframes, and/or deadlines.

See Housing Element, at p. 112 et seq.

Additionally, the City should designate a specific staff member to serve as the single point of contact for members of the public to inquire about information on the jurisdiction’s housing element.

2. Adopt robust policies and programs to encourage the creation and preservation of housing affordable to low and very low-income households.

A shortage of low and very low affordable housing disparately impacts protected classes, such as those with disabilities , since many have specialized housing needs which are unable to be met by market rate housing. Thus, we recommend implementing an inclusionary housing ordinance which requires new housing projects to dedicate between 10 and 20 percent of their market rate units for deed -restricted affordable housing. See: https://voiceofsandiego.org/2022/12/05/the-need-for- inclusionary-housing-the-case-of-la-mesa/

3. Conduct a more thorough and holistic analysis of the intersection between segregated housing patterns and disparate exposure to detrimental environmental factors which lead to unfair employment and educational opportunities for protected groups.

The City of Escondido deserves to have a substantive discussion of environmental justice issues, yet this term appears nowhere in the Housing Element. We recommend that the Housing Element contain a specific section devoted to environmental justice, with analysis of the particular environmental justice issues resulting from the City’s unique development history.

4. Commit early in the process to a dynamic public outreach plan to elicit participation from a broad and diverse cross-section of the community when drafting and/or updating the Housing Element.

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Public input is critical to the planning process. To ensure the plan’s credibility and legitimacy, all segments of the community must feel welcome to provide comment on the plan . We recommend that the City budget for and work with a public communications expert to form and execute a public outreach plan with the goal of obtaining input from as many varied stakeholders as possible. The public outreach plan should be subject to public comment and include partnerships with trusted community ambassadors who w ill conduct outreach and education on the Housing Element draft process.

Recognizing that many individuals from underrepresented and marginalized groups work during business hours and may feel unwelcome in certain settings, such as police stations, consideration must be given to the time and place of public meetings which seek public input. We recommend holding community workshops after business hours and in venues familiar to these groups, such as community centers, churches, or schools. Especially for the immunocompromised, attendees should have the option of joining the meeting either in person or through a remote option.

The City has a significant number of individuals with Limited English Proficiency.

Accordingly, we recommend that, at a minimu m, the Housing Element be made publicly available in the threshold languages recognized by the San Diego County Registrar of Voters, namely Spanish, Filipino, Vietnamese, and Chinese (traditional).

Translated public documents are critical to allow for public participation from a wide and divers e cross section of the community in the planning process. We also recommend conducting outreach and education meetings specifically targeted to these language populations, and other languages as well, should the community express a desire for additional language services.

5. Improve and expand reasonable accommodations policies.

The Housing Element should address reasonable accommodations as they relate to requests from persons with disabilities to modify zoning and development standards.

Federal and state housing laws regarding reasonable accommodations for persons with disabilities are expansive. We recommend providing the federal and state definition of “reasonable accommodations”, the definition of “disability”, and a description of the procedural requirements to make a request for accommodations.

Consolidated Plan

1. Create AFFH indicators in programmatic reports.

Legal Aid Society of San Diego ( LASSD) recommends including AFFH milestones or indicators in monthly or quarterly programmatic reports from CDBG subrecipients.

This will assist the City with AFFH obligations and will allow subrecipients to monitor progress toward meeting this goal. For example, a subrecipient could report on any Section 504 Complaints received and their disposition.

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As a reminder, Section 504 of the Rehabilitation Act does not allow funding to organizations who use discriminatory practices. See Section 504 of the Rehabilitation Act of 1973 (24 CFR § 8.4(b)(1)(v)) found at
https://www.govinfo.gov/content/pkg/CFR-2018-title24-vol1/xml/CFR-2018-title24- vol1-part8.xml.

2. List and include all protected classes.

We recommend adding a section that provides a general background on state and federal fair housing rights, including a list of all existing state and federal protected classes, respectively.

3. Include HUD and CRD contact information.

We recommend that the City provide contact information for the U.S. Department of Housing and Urban Development and the California Civil Rights Department. We recommend listing this information to encourage constituents to take action as a result of suspected housing discrimination.

The Fair Housing team at the Legal Aid Society of San Diego recognizes that the process to draft and update both the General Plan Housing Element and the Consolidated Plan requires a great investment of both time and capital. For that reason, we greatly appreci ate your commitment to this effort. By adopting the recommendations contained here, we can ensure that this process yields planning documents which affirmatively further fair housing, to benefit of all who live and work in the City of Escondido. We look forward to continuing to work with you to strengthen the communities we serve.

Sincerely,

Fair Housing
Legal Aid Society San Diego

This letter is based on work supported by the Department of Housing and Urban Development (HUD) under FHIP Grant FEOI1210026. Any opinion, findings, conclusions, or recommendations expressed in this material are those of the author(s) and do not necessarily reflect the views of HUD.

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Response to Comments
The Legal Aid Society of San Diego (LASSD) provided written comment to the City regarding the draft adopted Housing Element. Specifically, LASSD focuses on the topic of compliance with statutory obligations to affirmatively further fair housing. The comment letter recommends the following changes to the City’s draft adopted Housing Element: per form an analysis of impediments to fair housing choice specific to the City of Escondido; adoption of an inclusionary housing ordinance; conduct more environmental justice analyses as a part of the housing element; conduct robust outreach and engagement; and, improve and expand upon reasonable accommodations within the document. City staff met with representatives of LASSD in January 2023, approximately one -month after receiving LASSD’s comment letter and discussed the following information regarding the comments. • City-specific Analysis of Impediments: For the purposes of the draft adopted 2021-2029 Housing Element, the City utilized the countywide 2020 Regional Analysis of Impediments to Fair Housing Choice. This document provides an analysis specific to E scondido; however, the findings of this regional analysis are not specific to Escondido. As a part of the Housing Element Update, the City provides a summary of the regional impediments to fair housing choice and provides discussion on their applicability to Escondido.
• Inclusionary Housing: The City conducted a residential sector feasibility study (study) as a part of the Housing and Community Investment Study (HCIS) process. The study presents an economic analysis to evaluate the financial feasibility of various new construction residential product types and densities, and the cost for developers to comply with an onsite affordable housing obligation through application of an inclusionary housing ordinance. The study concludes that an inclusionary mechanism 10% low, or 5% low and 5% very low would be economically infeasible for all but one housing product type (for -sale townhomes) analyzed. The City staff included revisions to the draft housing element to address further study and research on inclusionary mechanisms, including land value recapture (Program 2.9 – Inclusionary Housing Assessment). In addition, the draft East Valley Specific Plan would include development of an Affordable Housing Trust Fund to assist in the delivery of affordable housing within the Plan Area. Likewise, an in-lieu fee for development proposed below minimum density thresholds would be used by the trust fund to develop moderate- and low-income housing developments. • Segregated Housing Patterns and Environmental Justice: The draft adopted 2021-2029 Housing Element contains an Affirmative Furthering Fair Housing appendix (Appendix E) that discusses segregation and integration based on race. In addition, t he City initiated a separate work effort for the update to the Safety Element and creation of a new environmental justice chapter of the City’s General Plan in December 2021. In an effort to provide adequate engagement and analysis to create a stand-alone environmental justice element, the City separated this work effort from the Housing Element Update. Topics related to safe and sanitary housing, including background information on development patterns within the City, as well as a number of additional environmental justice topics will be discussed under the forthcoming environmental j ustice chapter.
• Reasonable Accommodations: Page 72 of the draft adopted 2021 -2029 Housing Element provides discussion on reasonable accommodations. It provides an overview of what reasonable accommodations are under Federal and State laws, the findings the City established for assessing reasonable accommodation requests, and the permit process for such a request.

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• Public Participation: The City undertook a public involvement process to help engage residents, businesses, and other community members in the development of three different housing studies and plans, consolidated under a single work program, called the Housing and Community Investment Study (“HCIS”). On June 10, 2020, the City Council considered and endorsed a Public Participation Plan (“Outreach Plan”) and associated timeline to involve the community. Among other things, the work plan and schedule proposed a series of meetings with the Planning Commission to discuss different aspects and components related to the HCIS. The Outreach Plan can be accessed through this link
. The City also developed a periodic review page that can be accessed online at the link below to help the public access key documents. Informational reports and data generated during the review will be available for the public to view online, found at this
link.

Public participation played an important role in the formulation and refinement of the City’s housing goals and policies and in the development of the Housing Element. City residents had several opportunities to recommend strategies, review, and comment on the adopted 2021-2029 Housing Element. During the first and second phase of outreach, as part of the HCIS, which includes the development of an updated Housing Element, Reside ntial Sector Feasibility Study (Sector Feasibility Study, 2021), and an East Valley Specific Plan (current draft), the City worked with development experts, community-based interest groups, stakeholders, and the community at-large. When a draft of the Housing Element was available for review and comment, in summer 2021, public meetings to review the draft goals, policies, and programs were conducted in-person and virtually. Following review by HCD, the July 27, 2021, public hearing was scheduled with the Planning Commission to review and consider the adopted 2021-2029 Housing Element.

Subsequent to the August 2021 adoption, and in response to concerns regarding review periods of revised drafts and the need for additional public participation, the City pro vided a voluntary 30-day review period on the initial revised draft of the housing element in May 2022, and held a public meeting on May 10
th at the regularly scheduled planning commission to inform the planning commission and general public of revisions included in the draft housing element.

Subsequent revisions to the May 2022 draft included additional refinement to meet HCD’s concerns regarding AFFH programs. The City provided a voluntary 14 -day review period for the revisions submitted to HCD in October 2022; the October revisions are the changes proposed for adoption.

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From: Holly Nelson
To: Veronica Morones; Adam Finestone
Subject: FW: Your Comment Matters - Housing Department: 6 Cycle Housing Plan 2021 to 2029 Date: Wednesday, January 4, 2023 5:43:04 PM
Attachments: image001.jpg
Hi Veronica and Adam,

I received a public comment related to the Housing Element from an Escondido resident. Please see below.

Thanks,
Holly

Holly Nelson, LCSW
Housing & Neighborhood Services Manager
City Manager’s Office | City of Escondido
Direct: 760-839-4518
www.escondido.org

Confidentiality Statement: This communication contains information that may be confidential, and it may also be legally privileged or otherwise exempt from required disclosure. If you are not the intended recipient, please do not read, distribute or copy this communication and please delete the message from your computer.

From: [email protected] <[email protected]>
Sent: Wednesday, January 4, 2023 4:30 AM
To:

Holly Nelson <[email protected]>
Subject: Your Comment Matters - Housing Department: 6 Cycle Housing Plan 2021 to 2029

Bob
[email protected]
On page 29 for the 6TH Cycle Housing Element 2021 to 2029 on Table 14. for the
"SPECIAL
NEEDS GROUPS" :
>>>>>>> 54.7% of THAT TABLE for the population of Escondido California are : "Seniors"
Is the City of Escondido giving these "Seniors" a 55% PRIORITY for funding
-OR- at least some Administrative attention &
understanding ? ? ?
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Response to Comments
Mr. Bob Conifer’s comment focuses on a concern for special needs groups within the City. Specifically, Mr. Conifer references Table 14 within the adopted 2021-2029 Housing Element, which shows that of the special needs population within the City, over 50% of that population are seniors. Mr. Conifer asked for clarification on what actions the City takes to support the senior population. • Special Needs Groups: The City works with housing developers to fund senior housing development, with the most recent of project being the 50 -unit Valley Senior Village housing development currently under construction at the corner of Ivy and Valley Parkway. The City also operates a monthly subsidy program for low -income seniors within Escondido. This program is currently very small, serving approximately 30 individuals. The draft revisions to the adopted 2021-2029 Housing Element would continue to support housing opportunities for special needs groups, as described in Programs 1.4 – City-Owned Sites, 2.7 – Special Needs Housing, 2.8 – Affordable Housing Development, and Program 3.4 – Fair Housing.

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STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
Dec
ember 8, 2022
Mi
ke Strong, Director
Community Development Department
City of Escondido
201 North Broadway
Escondido, CA 92025
Dear
Mike Strong:

RE
: Escondido’s 6th Cycle (2021-2029) Revised Draft Housing Element Thank
you for submitting the City of Escondido’s (City) revised draft housing element received for review on October 18, 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 dr
aft revisions to the element meet the statuary requirements described in HCD’s August 2, 2022 review. However, the housing element cannot be found in full compli
ance until the City has completed necessary rezones (please see below). The housing element will comply with State Housing Element Law (Article 10.6 of the Gov.

Code) when rezones are completed and the element is adopted, submitted to, and approved by HCD, in accordance with Government Code section 65585.

Pur
suant to AB 1398, a juri sdiction that failed to adopt a compliant housing element within one year from the statutory deadline cannot be found in compliance until r ezones
to make prior identified sites available or accommodate a shortfall of sites pursuant to Government Code sections 65583, subdivision (c)(1)(A) and 65583.2, subdivision (c) are completed. As this year has passed and Programs 1.1 (S ites Inventory and No Net Loss…) and Program 1.3 (By-right Approvals on Reuse Sites) have not been completed, the housing element is out of compliance and will remain out of compliance until the rezoning have been completed. Once the City completes the rezone, a copy of the resolution or ordinance should be transmitted to HCD. HCD will review the documentation and issue correspondence identifying the updated status of the City housing element compliance.

Publ
ic p
articipation in the development, adoption and implementation of the housing element is essential to effective housing planning. During the housing element revision process, the City must continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly Attachment "4"
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available while considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting to HCD.

As a reminder, since the element relies upon nonvacant sites to accommodate more than 50 percent of the regional housing needs allocation (RHNA) for lower-incom e
households, absent of findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and nonvacant sites will not be utilized toward demonstrating adequate sites to accommodate the RHNA. The City’s resolution for the adopted housing element (adopted August 11, 2021) did not include the required findings. Any future re-adoption of the housing element must include the appropriate finding as part of the adoption resolution.

Pursuant to Government Code section 65583.3, subdivision (b), the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory.

Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community- development/housing-element/index.shtml for a copy of the form and instructions. While the City has already submitted an electronic sites inventory, please note, upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to [email protected].

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:
https://www.opr.ca.gov/planning/general-plan/guidelines.html.

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HCD appreciates the cooperation and diligence of City staff, Adam Finestone and Veronic Morones, during the review. We are committed to assist the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Sohab Mehmood, of our staff, at [email protected].

Sincerely,

Paul M
cDougall
Senior Program Manager
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City of Escondido
Sixth Cycle Housing Element
2021-2029
Adopted by City Council August 11, 2021
Revised September April 2022
June 2021
Com
munity Development Department
201 North Broadway
Escondido, CA 92025
NOTES:

1. Revisions to the Table of Contents’ page
numbers, and Figures E -25 through E -34
occurred but are not shown in
strikethrough/underline to preserve
document length. Revisions to Figures E-25
through E- 34 reflect the updated site
inventory parcels or clarify chart data.

2. Incorporation/removal of commas and
hyphens are not shown in
strikethrough/underline.

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Table of Contents

1. Introduction ................................................................................................................................ 1 Escondido’s General Plan Vision ............................................................................................. 1 Escondido’s Housing Element Outline ..................................................................................... 1 Community Context .................................................................................................................. 2 Public Participation ................................................................................................................... 3 Data Sources and Methodology ............................................................................................... 7 General Plan Consistency ........................................................................................................ 7

2. H
ousing Needs Assessment ..................................................................................................... 8 Pop ulation Characteristics ........................................................................................................ 8 Economic Characteristics ....................................................................................................... 11 Household Characteristics ..................................................................................................... 15 H ousing Problems .................................................................................................................. 19 Special Needs Groups ........................................................................................................... 23 Housing Stock Characteristics ............................................................................................... 36 Housing Cost and Affordability ............................................................................................... 42

3. A
ffordable Housing .................................................................................................................. 47 Publicly Assisted Housing ...................................................................................................... 47 Preservation of At-Risk Housing ............................................................................................ 48

4. H
ousing Constraints ................................................................................................................ 50 Market Influences ................................................................................................................... 50 Governmental Constraints ...................................................................................................... 54 Environmental and Infrastructure Constraints ........................................................................ 82

5. H
ousing Resources ................................................................................................................. 86 Regional Housing Needs Assessment ................................................................................... 86 Credits Toward RHNA ............................................................................................................ 86 Development Trends, Yields, and Realistic Capacity for Housing ......................................... 87 Density and Affordability Levels ............................................................................................. 92 Methodology for Identifying Sites to Accommodate the RHNA .............................................. 93 Sites Inventory and Residential Development Potential ......................................................... 98 No Net Loss .......................................................................................................................... 107 Ability to Meet RHNA ............................................................................................................ 108 Financial Resources ............................................................................................................. 109 Administrative Capacity ........................................................................................................ 111 Opportunities for Energy Conservation ................................................................................ 111 Attachment "5"
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6. Housing Plan .......................................................................................................................... 113 State Housing Goals ............................................................................................................ 113 City Housing Goals, Policies, and Programs ........................................................................ 113 Summary of Quantified Objectives ....................................................................................... 138 Appendix A
: RHNA Credits .......................................................................................................... A-1 Appendix B: Sites Inventory ........................................................................................................ B-1 Appendix C: Public Participation ................................................................................................ C-1 Appendix D: Review of Past Accomplishments ......................................................................... D-1 Appendix E: Affirmatively Furthering Fair Housing .................................................................. E-1

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List of Tables
Table 1: Population Growth (2000-2020) ............................................................................................ 8 Table 2: Age Distribution (2010-2018) .............................................................................................. 10 Table 3: Race and Hispanic Origin (2018) ........................................................................................ 11 Table 4: Employment Characteristics - (2010-2018) ......................................................................... 13 Table 5: Mean Salary by Occupation - San Diego Region (2020) .................................................... 14 Table 6: Changes in Household Types (2010 – 2020) ...................................................................... 16 Table 7: Household Size (2018) ........................................................................................................ 16 Table 8: Median Household Income (2014-2018) ............................................................................. 18 Table 9: Income Distribution (2000-2018) ......................................................................................... 19 Table 10: Housing Assistance Needs of Lower Income Households (2017) .................................... 20 Table 11: Overcrowded Housing Units (2010-2018) ......................................................................... 21 Table 12: Household Cost Burden (2017) ......................................................................................... 22 Table 13: Cost Burden by Tenure and Income Level (2017) ............................................................ 22 Table 14: Special Needs Groups ...................................................................................................... 23 Table 15: Inventory of Services for Special Needs Populations ....................................................... 24 Table 16: Persons Age 65 and Older (2018) .................................................................................... 25 Table 17: Elderly Households by Tenure and Income Level (2017) ................................................. 26 Table 18: Disabilities Tallied by Age and Type (2018) ...................................................................... 27 Table 19: Large Households (2018) .................................................................................................. 29 Table 20: Large Households by Tenure and Income Level (2017) ................................................... 30 Table 21: Single Parent Households (2018) ..................................................................................... 31 Table 22: Extremely-Low-Income Households by Tenure and Type ................................................ 32 Table 23: Homelessness in North County Cities (2020) ................................................................... 34 Table 24: Housing Unit Growth (2000 to 2020) ................................................................................. 37 Table 25: Projected Housing Units (2020-2040) ............................................................................... 37 Table 26: Projected Housing Unit by Type (2020-2040) ................................................................... 38 Table 27: Tenure of Occupied Housing Units (2010-2018) ............................................................... 39 Table 28: Household Size by Tenure (2018) .................................................................................... 39 Table 29: Vacancy Rates and Property Age (2019) .......................................................................... 40 Table 30: Year Housing Built (2018) ................................................................................................. 41 Table 31: Substandard Units (2018) ................................................................................................. 41 Table 32: C
hanges in Median Home Sale Prices (2020) .................................................................. 42 Table 33: Average Monthly Rent (2019) ........................................................................................... 44 Table 34: Affordable Housing Cost (2020) ........................................................................................ 46 Table 35: Inventory of Assisted Rental Housing Projects ................................................................ 47 Table 36: Disposition of Home Loans (2017) .................................................................................... 51 Table 37: Project Development Yield Trends by Zoning ................................................................... 53 Table 38: Assumed Realistic Capacities by Density range ............................................................... 54 Table 39: Land Use Designations Permitting Residential Use .......................................................... 55 Table 40: Downtown Specific Plan Residential Development Standards ......................................... 58 Table 41: East Valley Specific Plan Land Use Designations ............................................................ 59 Table 42: Residential Development Standards ................................................................................. 64 Table 43: Escondido Residential Parking Requirements .................................................................. 66 Table 44: Use Regulations for Residential Zones ............................................................................. 67 Table 45: Planning and Development Fees Regional Comparison (2020/21) .................................. 75 Table 46: Total Fee Comparisons (2019-2020) ................................................................................ 76 Table 47: Processing Time by Development Type ........................................................................... 79 Table 48: Processing Time by Process / Permit ............................................................................... 81 Table 49: RHNA Allocation by Household Income (2021-2029) ....................................................... 86 Table 50: Credits Toward RHNA ....................................................................................................... 87 Table 51: Affordable Housing Yields ................................................................................................. 89 Attachment "5"
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Table 52: Site Capacity Estimation (EVSP) ...................................................................................... 91 Table 53: Site Capacity Estimation (Non EVSP) ............................................................................... 92 Table 54: Affordability by Density ...................................................................................................... 93 Table 55: ADU Affordability Level (2018-2020) ............................................................................... 107 Table 56: Average ADU Affordability Level (2018-2020) ................................................................ 107 Table 57: Estimated Sixth Cycle ADU Production .......................................................................... 107 Table 58: No Net Loss Buffer Estimate ........................................................................................... 108 Table 59: Summary of RHNA Status .............................................................................................. 109 Table 60: Summary of Quantified Objectives .................................................................................. 138

Table A- 1: RHNA Credits – Entitled Units ...................................................................................... A-1 Table A- 2: RHNA Credits - Approved Projects .............................................................................. A-1 Table A- 3: Projects Under Review ................................................................................................. A-2

Table D- 1: Review of Past Accomplishments ................................................................................ D-1

Table E- 1: Racial/Ethnic Dissimilarity Index ................................................................................... E-3 Table E- 2: Domains and List of Indicators for Opportunity Maps ................................................. E-20 Table E- 3: Opportunity Map Scores by Census Tract .................................................................. E-30 Table E- 4: Opportunity Indicators in Escondido and San Diego County ...................................... E-33 Table E- 5: Any Housing Problem by Tenure and Race ............................................................... E-35 Table E- 6: Housing Problems for Elderly and Large Households by Tenure ............................... E-35 Table E- 7: Cost Burden by Tenure and Race .............................................................................. E-36 Table E- 8: Cost Burden for Elderly and Large Households by Tenure ........................................ E-36 Table E- 9: Location of Sites by TCAC Designation ..................................................................... E-56

List of Figures
Figure 1: Age Composition (2018) .................................................................................................... 10 Figure 2: Households by Income Categories (2013-2017) ............................................................... 17 Figure 3: Household Income Distribution (2014-2018) ..................................................................... 18 Figure 4: Housing Types (2020) ........................................................................................................ 38 Figur
e 5: Median Home Price (2020) ................................................................................................ 42 Figure 6: Downtown Escondido Specific Plan – Residential Densities ............................................. 57

Appenidx B: Listing of Parcels for City of Escondido RHNA ................................................... B-2 Appenidx B: Map of City of Escondido Housing Sites ............................................................ B-56 Appenidx B: Map of City of Escondido Housing Sites – Downtown Sites ............................ B-57 Appenidx B: Map of City of Escondido Housing Sites – East Valley Sites ........................... B-58 Appenidx B: Map of City of Escondido Housing Sites – South Centre City Sites ................ B-59 Figure B-1: Site Typology ........................................................................................................... B-60

Figure E-1: Areas of Minority Concentration in Escondido (2018) .................................................. E-5 Figure E-2: Predominant Populations- White and Hispanic Majorities ............................................ E-6 Figure E-3: Change in Racial Composition, 1990-2015 .................................................................. E-7 Figure E-4: Distribution of Persons with Disabilities ........................................................................ E-9 Figure E-5: Percent Population of Adults Living Alone ................................................................. E-11 Figure E-6: Percent Population of Adults Living with Spouse ....................................................... E-11 Figure E-7: Percent Children in Married Households .................................................................... E-12 Attachment "5"
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Figure E-8: Percent Children in Single Female-Headed Households ........................................... E-12 Figure E-9: Low and Moderate Income (LMI) Areas in the County ............................................... E-14 Figure E-10: Low and Moderate Income (LMI) Areas in Escondido ............................................. E-15 Figure E-11: Distribution of Housing Choice Vouchers in Escondido ........................................... E-17 Figure E-12: Affordability Index in Escondido ............................................................................... E-18 Figure E-13: Poverty Status in Escondido .................................................................................... E-19 Figure E-14: 2021 TCAC/HCD Opportunity Map .......................................................................... E-21 Figure E-15: Mission Park Community .......................................................................................... E-22 Figure E-16: Racially and Ethnically Concentrated Areas of Poverty (R/ECAPs) - SD County .... E-24 Figure E-17: Racially and Ethnically Concentrated Areas of Poverty (R/ECAPs) - Escondido ..... E-25 Figure E-18: Racially/Ethnically Concentrated Areas of Affluence (RCAAs) - Escondido ............ E-27 Figure E-19: Overpayment by Renter and Owner Households ..................................................... E-38 Figure E-20: Distribution of Overcrowded Households ................................................................. E-40 Figure E-21: Median Year Structure Built ..................................................................................... E-41 Figure E-22: Sensitive Communities ............................................................................................. E-42 Figure E-23: RHNA Sites and Minority Population by Census Block Group ................................. E-46 Figure E-24: RHNA Units and City Acreage Comparison by Minority Population ......................... E-47 Figure E-25: RHNA Sites and Population with a Disability by Census Tract ................................ E-48 Figure E-26: RHNA Units and City Acreage Comparison by Disability Status .............................. E-49 Figure E-27: RHNA Sites and Children in Married-Couple Households by Census Tract ............ E-50 Figure E-28: RHNA Sites and Low to Moderate Income Population by Census Block Group ...... E-51 Figure E-29: RHNA Units and City Acreage Comparison by Low to Moderate Income ................ E-52 Figure E-30: RHNA Sites and R/ECAP Areas .............................................................................. E-53 Figure E-31: RHNA Sites and TCAC Designation ........................................................................ E-55 Figure E-32: RHNA Units and City Acreage Comparison by TCAC Composite Score ................. E-55 Figure E-33: RHNA Sites and CalEnviroScreen 4.0 Percentile Scores ........................................ E-57 Figur
e E-34: RHNA Units and City Acreage Comparison by Cal EnviroScreen 4.0 Percentile .... E-58 Attachment "5"
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1. Introduction
The Housing Element is a component of the General Plan that assesses the housing needs of all economic segments of the City of Escondido. In addition, the Housing Element defines the goals and policies that will guide the City’s approach to resolving those needs and recommends a set of programs that would implement policies over the next few years.

State law requires that all cities adopt a Housing Element and with prescribed details and content.

This Housing Element responds to those requirements, and responds to the special characteristics of the City’s housing environment. The Element incorporates the most current data readily available at the time of writing and an evaluation of the Housing Element adopted in 2013. Also included are assessments of the current and potential housing actions, and resources of the private sector and all levels of the public sector.

This Escondido Housing Element is prepared for the 2021-2029 update (Sixth cycle) for jurisdictions in the San Diego Association of Governments (SANDAG) region.

The Housing Element’s Purpose
The Housing Element is concerned with specifically identifying ways in which the housing needs of existing and future residents can be met. This Housing Element covers the planning period of April 15, 2021 to April 15, 2029, and identifies strategies and programs that focus on:
• Conserving and improving existing affordable housing; • Providing adequate housing sites for meeting the projected housing demand; • Assisting in the development of affordable housing;
• Removing governmental and other constraints to housing development; and • Promoting equal housing opportunities.

Escondido’s General Plan Vision
The City of Escondido envisions itself becoming the vibrant and dynamic cultural, economic, and recreational hub of inland North San Diego County. This vision calls for an outstanding quality of life with exemplary public services and a safe environment that support a wide-range of housing types; quality educational facilities; desirable workplaces offering diverse employment opportunities; convenient transportation options, and unique cultural/recreational amenities. A lively, active downtown with unique and exciting land uses and a revitalized surrounding urban core are the focus for appropriate higher -intensity infill developments that maximize opportunities for alternative transportation, and strengthen pedestrian linkages. Planning for quality, managed growth ensures the adequate provision of infrastructure, preserves perimeter viewsheds, respects and enhances the character of established single-family neighborhoods, and assures long-term sustainability for Escondido’s future. This Housing Element provides policies and programs that will allow the City to achieve this vision.

Escondido’s Housing Element Outline
The 2021-2029 Escondido Housing Element consists of the following major components:

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• Introduction: An overview of the purpose and contents of the Housing Element. • Housing Needs Assessment: An analysis of the demographic and housing characteristics and trends.
• Housing Constraints: A review of potential market, governmental, and environmental constraints to meeting the identified housing needs.
• Housing Resources: An evaluation of resources available to address housing goals. • Housing Plan: A strategy to address the identified housing needs given the City’s constraints and resources.

An evaluation of the City’s achievements in implementing the 2013 Housing Element is also included in the appendix.

Community Context
Escondido is located in the North Central portion of San Diego County. Its natural setting, Mediterranean climate, rolling hills, and location at the intersection of two state highways provide a unique and attractive living environment. This setting has a substantial impact on the employment characteristics as well as the City’s economic base. These conditions attract growth, which in turn creates a competitive residential atmosphere.

Escondido has experienced significant residential development since 1970. It is crucial that public services expand to meet the needs of the increasing population. These services include sewers, streets, police, fire, schools, and recreation. It is also important to locate housing to be accessible to other functions such as employment, services, shopping, and transportation.

In 2020, the City population was 153,008, an increase of about six percent in the last ten years.

During this same period, the housing stock increased by approximately two percent. The growth in population has, in turn, increased diversity within the City. From 2010 to 2020, Escondido became more racially and ethnically diverse. The population of White residents has continued to decrease from 68% in 2000 to 35% in 2020. Meanwhile, the City’s population of Hispanic residents has increased from 39% to 52%. The City’s Asian population has also increased from four percent in 2000 to seven percent in 2020.

The 2018 American Community Survey (ACS) Five-Year estimates reported an increase in average household size from 3.06 persons per household in 2010 to 3.21 persons in 2018. This trend can be partially attributed to the increase in families with children and the shift in racial and ethnic composition, since many Asian and Hispanic households are typically larger than White households.

Escondido offers a mix of housing types. Single-family homes make up about 57 % of the housing stock, the multi-family share is about 36%, and mobile homes comprise the remaining eight percent.

Over three-fourths (76%) of Escondido’s housing stock is over 30 years old (built before 1990), with approximately 10% of the housing stock being built before 1969 (over 50 years old).

The median price of a single-family home in Escondido is estimated at about $540,000 as of 2019.

Apartment rents range from $1,490 for a one-bedroom apartment to $2,273 for a three-bedroom apartment. Lower income households in the City are unable to afford homeownership and affordable rental options are also limited. The City has been actively addressing its housing issues by developing affordable housing, improving the existing housing, and providing assistance to households in need.

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Public Participation
The City of Escondido envisions itself as a sustainable community through various environmental, economic, health, and social equity initiatives. T he ability to increase housing production and preservation is a key factor to a sustainable future. To accomplish this, the Housing Element must provide goals, objectives, policies, and implementation programs demonstrating how Escondido will meet its existing and future housing needs for all income levels. Although the City does not build the housing, the Housing Element does create a plan and regulatory framework, which provides opportunities for the private sector to do so, where market conditions determine when and where housing is built. In order to make sure that the City develops a good “housing” strategy, the City needs to identify all types of community-supported solutions.

The City was awarded Senate Bill (“SB”) 2 grant funding in 2020 to develop three different hosing studies and plans: a Housing Element Update, a Sector Feasibility Study, and an East Valley Specific Plan. These three housing studies and plans will be linked together, through a common work program theme, called the “Housing and Community Investment Study.” The coordination of the three studies helps identify a comprehensive vision for maintaining, preserving, and developing housing to address Escondido’s quality of life needs. Through the consolidated work program, the City undertook a strategically focused public involvement process to help engage residents, businesses, and other community members in the development of three different housing studies and plans. Since the Housing Element, Sector Feasibility Study, and East Valley Specific Plan are related to each other, consolidating the work program in terms of project management into one project helped ensure that public participation-related activities and tasks were grouped to be more efficient. This in turn led to more effective public outreach and more-informed community engagement.

Components of the Housing and Community Investment Study The Housing and Community Investment Study (“HCIS”) identifies the City’s housing needs and establishes clear goals and objectives to inform future housing decisions. This important effort will guide Escondido’s future housing policy creation and implementation. It will address things like how best to increase or accommodate affordability, substandard housing rehabilitation, existing demand for new housing, eliminating housing development constraints, and fair housing.

The Housing Element Update identifies:
• Policies for new housing construction, rehabilitation and conservation of the existing affordable housing stock.
• The current Housing Element sets a number of ambitious goals to increase housing production and preservation, ensure neighborhood livability, prevent discrimination, and end homelessness. This foundation has allowed Escondido to advance a progressive set of programs and initiatives to develop and preserve both market-rate and affordable housing.

This update presents an opportunity to build on that foundation as we continue to address the housing crisis.

The Sector Feasibility Study identifies:
• Market information about how new development could be financed, and assess if, and to what degree, housing development is financially/economically feasible under rising cons truction, land, and regulatory costs.

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East Valley Specific Plan identifies:
• A comprehensive planning and zoning scheme for an area just east of the former, downtown hospital campus.
• Opportunity sites ready for development. The area map shows the location of potential re- visioning.
• New ways to accommodate streamlined housing with community-supported solutions.

Public Participation of the HCIS
A goal of the HCIS was to ensure that the future housing accommodation strategies embraced the distinct identity and character of Escondido where one can live their entire life with housing for all ages, incomes and abilities. For that purpose, a Public Participation Plan was developed to help create meaningful outreach engagement activities. During the course of the Study, the City work ed with development experts, community-based interest groups, stakeholders, and the community at large to achieve the best plan possible through engagement tools including meetings, community workshops, and online engagement. Information about the first and second phase of outreach is available and provided on the City’s website (https://www.escondido.org/hcis.aspx ) and summarized
below. Additional information on the City’s public participation is detailed in Appendix C.

First Phase of Outreach
The first phase of outreach of the HCIS focused on developing background information and feedback on overarching housing issues and concerns:
• Direct mailers, electronic e-mail blasts, and electronic flyers in English and Spanish • Planning Commission and City Council meetings and status updates • July 23, 2020 virtual workshop (English and Spanish services) • Presentation Videos posted online (English and Spanish recordings) • For Residents:
o East Valley Specific Plan downloadable comment forms: English and Spanish o East Valley Specific Plan online form to submit comments o Housing Element online survey (July 2020 - December 2020): English and Spanish • For Businesses:
o East Valley business survey (August 2020 - September 2020): English and Spanish o Housing Element online survey (July 2020 - December 2020): English and Spanish Second Phase of Outreach:

The City explored different strategies to develop more housing to meet state housing requirements and to meet its goals for maintaining community identity. Public feedback in the second phase of outreach was utilized to determine the locations and densities of new housing options. • Direct mailers, electronic e-mail blasts, and electronic flyers in English and Spanish Attachment "5"
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• October 7, 2020 virtual workshop (English and Spanish services) • Presentation Video posted online “Land Use Alternative Workshop” (English and Spanish recordings)
Housing Element Study Sessions
The City conducted two study sessions in March 2021, one before the Planning Commission (March 23) and one before the City Council (March 24) to review the Draft Housing Element.

Consideration of Community Feedback
The joint planning process for the EVSP Specific Plan and Housin g Element included the outreach and participation of community members, business stakeholders and interest groups. Overarching comments received from the two rounds of community involvement for the EVSP included:
• Providing affordable to moderate income housing
• Promoting walkability through mixed-use buildings and complete streets concepts • Enhancing streetscapes and building frontages through design and amenities • Creating more public open space for the residents and visitors • Providing affordable housing with appropriate design standards • Including parks and urban canopy as these are important concepts for an urban setting • Mindfully establishing parking standards to accommodate future and current needs • Allowing for community services and other existing uses while facilitating new opportunities Using community input gathered in the first phase of outreach, three Land Use Alternatives were developed for the City and community to assess and select a Preferred Land Use Alternative. The Preferred Land Use Alternative acts as a base in which the East Valley Specific Plan establishes the land uses, circulation network, design guidelines, and design standards. During the outreach activities, the community was informed that a significant portion of the City’ RHNA would be accommodated in this new growth area. Input gathered through this second outreach effort was folded into the Preferred Land Use Alternative, which is presented in the EVSP.

More generally related to housing across the entire City, the Housing Survey asked residents to rank housing challenges and needs across different categories. Overall , respondents ranked items as follows:
• Greatest housing challenges: housing costs, fair housing services, and neighborhood physical conditions
• Groups with greatest need: young adults, large households, persons formerly experiencing homelessness
• Greatest housing stock need: ADUs, housing for formless persons experiencing homelessness, housing for persons with disabilities
• Most important housing programs/activities : affordable housing, homelessness, first-time homebuyers.

The City also received oral and written public comments during the Planning Commission meetings on the draft Housing Element. Comments focused on implementing an inclusionary ordinance, minimum density requirements, value recapture requiring affordable housing, and homeownership opportunities for lower income households.

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To address concerns related to fair housing, Escondido has included Program 3.4. Escondido will continue the enforcement of the Fair Housing Action Plan and continue to contract with the Legal Aid Society of San Diego to provide fair housing services. Program 3.2, Focus on Neighborhoods, utilizes proactive code enforcement, housing rehabilitation, and capital improvement to improve physical conditions of Escondido neighborhoods.

As part of the Housing and Community Investment Study (HCIS), the City conducted a housing sector feasibility study to evaluate housing construction viability under different affordability scenarios. The Sector Feasibility Study explores all the direct and indirect costs associated with new construction to better understand market conditions and patterns of housing and community development policy, including the benefit/impact of potential inclusionary housing programs. The results of the 2021 study showed that even a 10% inclusionary requirement makes housing construction infeasible at higher residential densities. That is, an inclusionary requirement has been determined, by substantial evidence, to be a potential constraint to new home construction at the default densities deemed appropriate to accommodate housing for lower income households (30 units per acre). It is important to note that most of the sites suitable for near term development in the City are at densities that are at or exceed 30 units per acre. Development expected under the existing regulations and partnerships, or even through the programmed implementation of the 2021-2029 Housing Element, would help the City determine if more affordable housing can be achieved through various zoning incentives or subsidies – or identify such opportunities, and then seek their implementation.

However, in response to public comment surrounding inclusionary housing requirements, the City has included Program 2.9, Inclusionary Housing Assessment, to continue research and feasibility on a potential inclusionary housing mechanism for the City.

The East Valley Specific Plan (EVSP) requires minimum densities of 21 units/acre in the EV-U-5 zone and 30 units/acre in the EV-MU zone. The EVSP and Downtown Specific Plan also include a Density Transfer Program, allowing the City to transfer densities from vacant or underutilized sites to other properties in the Plan Area, enabling an increase in density beyond what is allowed under the current density (see Program 1.2). The transferred density will be held in a Density Credit Pool.

The City has included Program 2.2, First-Time Homebuyer Assistance, to assist lower income first- time homebuyers. The program utilizes HOME funds and aims to assist one household annually. The City will also actively pursue funding to expand this program. Program 2.4, Mobile Home Park Conversion, to assist applicants applying for funding from HCD to pursue mobile home park conversion to resident ownership.

Public Review of Draft Housing Element
The Draft Housing Element has been available for public review on City website since March 19. 2021. The City received public comment letters on the draft housing element and overall process, prior to the City Council initial adoption of the document on August 11, 2021. City staff reviewed received comment letters, including those submitted from the San Diego Housing Federation, Escondido Community Housing Coalition, Sierra Club North County Group, and Erik Felix and Laura Harper, as well as from HCD. After the August 2021 City Council adoption, City staff met with each group listed to discuss how their comments may be integrated into the revised housing element document. Meetings with each group occurred between January and February of 2022. On April 15, 2022, the City posted the revised adopted Housing Element for a 30-day review period, prior to resubmittal to HCD. City staff presented the draft changes in a public meeting on May 10, 2022 to the City’s Planning Commission and general public.

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The City will continue to provide updated versions of the Draft Housing Element for public review.

Data Sources and Methodology
In preparing the Housing Element, various sources of information are consulted. The 2000 and 2010 Census provides the basis for population and household characteristics. Unfortunately, the 2020 Census data is not scheduled to be released in time for the preparation of this Housing Element. As of the writing of this Housing Element (February 2021), no 2020 Census data has been released.

Therefore, several sources are used to provide reliable updates to the 2010 Census, including the following:
• 2014-2018 American Community Survey by the Census Bureau • Population and demographic data updated by the State Department of Finance • Housing market information, such as home sales and rents, from Corelogic and Zillow, among other sources
• Lending patterns from the Home Mortgage Disclosure Act (HMDA) database • Labor statistics from California Employment Development Department General Plan Consistency
According to State planning law, the Housing Element must be consistent with the other General Plan elements. Certain goals and policies of each element may also address issues that are primary subjects of other elements. This integration of issues throughout the General Plan creates a strong basis for the implementation of plans and programs and achievement of community goals. The Housing Element is most closely tied to the Land Use Element as residential development capacities established in the Land Use Element are incorporated into the Housing Element.

The Escondido General Plan includes the following elements:
• Land Use and Community Form
• Mobility and Infrastructure
• Housing
• Community Health and Services
• Community Protection
• Resource Conservation
• Growth Management
• Economic Prosperity
This Housing Element is consistent with the policies and proposals set forth by the updated General Plan, but also incorporates new development opportunities offered by the East Valley Specific Plan.

The Safety Element was also updated concurrent with the Housing Element update.

When an element in the General Plan is amended in the future, the Housing Element will be reviewed and modified if necessary to ensure continued consistency among the various elements. The City will ensure that updates to these Elements achieve internal consistency with the Housing Element.

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2. Housing Needs Assessment
The City strives to achieve a balanced housing stock that meets the varied needs of all income segments of the community. To understand the City’s housing needs, the nature of the existing housing stock and the housing market are comprehensively evaluated. This section of the Housing Element discusses the major components of housing needs in Escondido, including population, household, economic, and housing stock characteristics. Each of these components is presented in a regional context, and, where relevant, in the context of other nearby communities. This assessment serves as the basis for identifying the appropriate goals, policies, and programs for the City to implement during the 2021-2029 Housing Element cycle.

Population Characteristics
Understanding the characteristics of a population is vital in the process of planning for the future needs of a community. Population characteristics affect the type and amount of housing need in a community.

Issues such as population growth, race/ethnicity, age, and employment trends are factors that combine to influence the type of housing needed and the ability to afford housing. The following section describes and analyzes the various population characteristics and trends that affect housing need.

Population Growth
According to the California Department of Finance population estimates, the City population in 2020 was 153,008, increasing from 133,559 in 2000 and 143,911 in 2010. Between 2010 and 2020, the City population increased by approximately 10,000 people, representing an increase of approximately six percent (Table 1). During the same period, San Diego County population increased by eight percent. The City population as a proportion of the County population has remained the same over the past 30 years (4.6%).

Table 1: Population Growth (2000-2020)
2000 2010 2020 2000-2010 2010-2020
Escondido 133,559 143,911 153,008 7.8% 6.3%
San Diego Region 2,813,833 3,095,313 3,343,355 10.0% 8.0% Escondido as a % of the County 4.7% 4.6% 4.6% -2.0% -1.6% Sources: Bureau of the Census, 2000, and 2010; California Department of Finance, 2020.

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Age Characteristics
A community’s current and future housing needs are determined in part by the age characteristics of residents. Typically, each age group has distinct lifestyles, family types and sizes, ability to earn incomes, and therefore, housing preferences. As people move through each stage of life, housing needs and preferences change. Traditional assumptions are that the young adult population (20 to 34 years old) tends to favor apartments, low to moderate cost townhomes/condominiums, and smaller single-family units.

The adult population (35 to 64 years old) represents the major market for moderate to relatively high cost condominiums and single-family homes. The senior population (65 years and older) tends to generate demand for low to moderate cost apartments and condominiums, group quarters, and mobile homes. In order to create a balanced community, it is important to provide housing options that suit the needs of various age groups.

In 2010, 31% of residents in the City were under the age of 20 years, 23% were young adults between 20 and 34 years, 36% were mature adults between 35 and 64 years, and 10% were elderly persons over 65 years of age (Table 2). According to the 2014-2018 ACS, the age distribution of Escondido residents was as follows: 28% of residents in the City were under the age of 20 years, 25% were between 20 and 34 years, 36% were between 35 and 64 years, and 11.6% were over 65 years of age. Overall, the City’s population is aging, with the median age increasing from 32.5 to 33.8 between the 2010 Census and the 2014-2018 ACS. Figure 1 shows that the proportion of population for all age categories under 55 has decreased between 2010 and 2018 (except for 25 to 34 years old) while population over 55 at all age categories has increased (except 75+ years old).

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Table 2: Age Distribution (2010-2018)
Age 2010 2018
Total % of Total Total % of Total
Under 5 years 11,638 8.1% 11,164 7.4%
5-9 years 10,795 7.5% 9,976 6.6%
10-14 years 10,686 7.4% 9,858 6.5%
15-19 years 10,976 7.6% 10,735 7.1%
20-24 years 11,138 7.7% 11,554 7.6%
25-29 years 11,436 7.9% 14,280 9.4%
30-34 years 10,167 7.1% 11,383 7.5%
35-39 years 9,759 6.8% 9,589 6.3%
40-44 years 9,681 6.7% 9,246 6.1%
45-49 years 9,617 6.7% 9,490 6.3%
50-54 years 9,190 6.4% 9,418 6.2%
55-59 years 7,725 5.4% 8,937 5.9%
60-64 years 6,019 4.2% 7,853 5.2%
65-69 years 4,237 2.9% 5,619 3.7%
70-74 years 3,162 2.2% 4,125 2.7%
75+ years 7,685 5.3% 7,888 5.2%
Total 143,911 100.0% 151,115 100.0%
Median Age 32.5 33.8
Source: Bureau of the Census, 2010 Census; American Community Survey, 2014-2018.

Figure 1: Age Composition (2018)

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Race/Ethnicity
Race/ethnicity of the population is important to an analysis of housing needs and conditions for several reasons. The cultural influences of races are often reflective of preferences for housing type, location of housing, associated services, and household composition. For example, the concept of “extended family” can have implications on the definitions of overcrowding and housing conditions.

The racial and ethnic composition of a community’s population should also be more carefully examined at the neighborhood level. In general, Hispanic and Asian households exhibit a greater propensity than White households for living in extended families. However, with the rising housing crisis in California, and the recent economic challenges presented by COVID -19, extended family members sharing housing arrangements or adult children moving back with parents have become a trend in many California communities.

Escondido, like many communities throughout California, has experienced gradual changes in the racial and ethnic composition of its population. According to the 2010 Census, White residents (40%) no longer comprised the largest racial/ethnic group in the community. T he proportion of White residents continued to decrease, comprising only 36% of the population by 2018. Meanwhile, the City’s Hispanic residents now make up over half (52%) of the City’s population, which is a two percent increase since 2010 (Table 3).

Table 3: Race and Hispanic Origin (2018)
Race and Ethnicity Number Percent
Non-Hispanic Races
White 53,623 35.5%
Black or African American 3,302 2.2%
American Indian 553 0.4%
Asian 10,032 6.6%
Native Hawaiian and Other Pacific Islander 380 0.3%
Some other race 299 0.2%
Two or more races 4,545 3.0%
Hispanic 78,381 51.9%
Total 151,115 100.0%
Source: American Community Survey, 2014-2018.

Economic Characteristics
Employment has an important impact on housing needs. Incomes associated with different jobs and the number of workers in a household determines the type and size of housing a household can afford. In some cases, the types of jobs themselves can affect housing needs and demand (such as in communities with military installations, college campuses, and large amounts of seasonal agriculture). Employment growth typically leads to strong housing demand, while the reverse is true when employment contracts. In addition, the relationship between the location of housing and the location of employment has an impact upon transportation systems. Escondido is north of the major employment centers in San Diego County and, to a lesser extent, east of other areas in northern San Diego County.

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Employment
The San Diego region currently has a smaller share of its employment in manufacturing than California and the nation. The decline in the proportion of jobs in manufacturing has been progressing for more than half a century nationwide. During the 1990s and continuing after 2000, the region’s economy continued to diversify away from manufacturing and defense-related industries.

Manufacturing’s share of total non-farm employment fell from 12.8% in 1990 to 10.3% in 2000 and

9.2% during 2014-2018, following a similar trend for the state and the nation. Conversely, s ervice occupations now comprise about 19.5% of the employment according to the 2014-2018 ACS.

The earnings gap between low - and high-paying jobs has also widened because of unbalanced job growth and the region’s capacity for low -paying jobs has increased through public and private investments in low value-added industries, such as tourism, entertainment, and retail trade, without compensating investments for high value-added industries. However, as digital technology continues to improve, fostering online shopping and streaming of entertainment, entertainment and retail jobs may be in jeopardy and are certainly most impacted by the Coronavirus pandemic.

As of September 2020, unemployment rate in Escondido was reported by the State Employment Development Department at 8.5%, below the regional average of 9.0% and the statewide average of

11.0%. The current COVID-19 crisis is expected to have long-lasting impacts on the economy. The “pre- COVID” unemployment rate in Escondido was reported at 4.0% as of March 2020. The impacts of COVID- 19 on housing affordability and housing problems (such as cost burden) are expected to worsen, although no data is available yet to substantiate the projections.

Table 4 highlights the difference in employment composition in Escondido versus the region. The table shows that employment in the agriculture and mining, construction, manufacturing, transportation, communication and utilities, wholesale trade, and public administration sectors are higher in Escondido.

Compared to the region, Escondido has a lower proportion of higher paying jobs in the finance/real estate insurance, retail trade, and professional services sectors. Of course, it is important to note that this data set largely ignores the growing number of Escondido residents that have a single part-time job, multiple part-time jobs, or have other sources of income such as that from the gig economy, rather than traditional full-time employment.

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Table 4: Employment Characteristics - (2010-2018)

Industry Sector
2006-2010 ACS 2014-2018 ACS Median
Earnings
(Escondido
2018)
% of Escondido
Employment
% of Region
Employment
% of Escondido
Employment
% of Region
Employment
Agriculture, Mining 2.0% 0.7% 2.3% 0.9% $ 23,727
Construction 11.1% 7.2% 9.3% 5.9% $33,206
Manufacturing 11.5% 9.2% 9.6% 9.2% $ 41,896
Transportation,
Communication,
Utilities

2.7% 2.9% 3.3% 2.4% $ 36,638
Wholesale Trade 12.7% 10.8% 12.5% 10.5% $24,421
Retail Trade 2.6% 3.8% 3.9% 4.1% $47,267
Finance 1.9% 2.5% 1.6% 2.2% $50,231
Real Estate,
Insurance 5.4% 7.4% 4.8% 6.2% $39,682
Professional Services 12.1% 14.2% 14.2% 15.1% $32,035
Education, Health, and
Social Services 16.9% 19.9% 17.3% 21.3% $32,783
Arts, Recreation,
Entertainment 11.4% 10.6% 11.6% 11.9% $20,236
Other Services 6.5% 5.2% 7.0% 5.4% $20,310
Public Administration 3.3% 5.4% 2.4% 5.0% $59,136
Total 100.0% 100.0% 100.0% 100.0% $30,993
Sources: Bureau of the Census, 2006-2010; American Community Survey, 2014-2018. 2018 Census San Diego County Median Household Income = $81,500
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Salary/Income
Table 5 displays mean annual wage data for occupations compiled by the California Employment Development Department (EDD) for the San Diego Metropolitan Statistical Area. Table 5 shows that the food preparation and serving, farming, fishing and forestry, personal care, and healthcare support occupations offer the lowest wages.

According to the ACS, approximately 14% of Escondido residents work at educational, health and social services occupations. Education and social services usually generate employment at the moderate income levels. Other major employment sectors for Escondido include arts, recreation and entertainment (17.3%) and wholesale trade (12.5%); both provide generally jobs at lower to moderate scales. Also refer to the next section regarding Escondido household incomes.

Table 5: Mean Salary by Occupation - San Diego Region (2020) Occupations Average Salary
Management $136,531
Legal $120,265
Computer and Mathematical $104,627
Healthcare Practitioners and Technical $102,053
Architecture and Engineering $99,949
Life, Physical and Social Science $87,579
Business and Financial Operations $80,850
Education, Training and Library $66,690
Arts, Design, Entertainment, Sports and Media $61,614
Construction and Extraction $60,047
Protective Service $58,837
Community and Social Service $56,793
Installation, Maintenance and Repair $54,945
Sales $45,974
Office and Administrative Support $45,385
Production $43,823
Transportation and Material Moving $39,362
Building, Grounds Cleaning, and Maintenance $36,248
Healthcare Support $35,609
Personal Care and Service $34,806
Farming, Fishing and Forestry $33,243
Food Preparation and Serving Related $31,942
All Occupations $61,770
Source: California Employment Development Division, Occupational Employment Statistics (OES), Q1, 2020.

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Household Characteristics
The Census defines a "household" as all persons who occupy a housing unit, which may include single persons living alone, families related through marriage or blood, or unrelated persons sharing living quarters. Persons living in retirement or convalescent homes, dormitories, or other group living situations are not considered households. Furthermore, the Census classifies households by type according to the gender of the householder and the presence of relatives. Household characteristics such as size, type, income and tenure reveal important information about the housing needs of a community. Different household sizes, types and income levels often prefer different housing options.

According to the 2020 California Department of Finance housing estimates, there were 1,226,879 households (also known as occupied housing units) in San Diego County. Of these, 49,211 households, or approximately four percent, were located in Escondido.

Household Type and Size
Different household types generally have different housing needs. Seniors or young adults usually comprise the majority of the single-person households and tend to reside in apartments, condominiums or smaller single-family homes. Families with children often prefer single-family homes.

Escondido had 43,817 households in 2000. By 2010, this number grew marginally to 44,574, an increase of two percent. The number of households in Escondido increased an additional four percent to 46,338 households by 2018. Table 6 shows that, increasingly, Escondido households are comprised primarily of families. However, the greatest change between 2010 and 2018 was the increase in other ‘non-traditional’ families, including single parents. Married couples with children and single households living alone experienced numerical and proportional decreases.

According to the 2014-2018 ACS, 72% of the Escondido households were family-households. Of the City’s family households, 36% were married couples with children under the age of 18 and 34% were married couples without children. The proportion of other families continued to grow, representing 31% of all family-households.

Approximately 28% of Escondido households were non-family households with the majority of them (72%) being residents living alone. By 2018, the average household size in the City increased to 3.21 and the average family size increased to 3.69.

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Table 6: Changes in Household Types (2010 – 2020)
Household Types 2010 2020 Change
2010-2020
# % # % # %
Families 31,816 71.4% 33,324 71.9% 1,508 4.7%
Married with Children 12,419 39.0% 11,819 35.5% -600 -4.8% Married, no Children 10,587 33.3% 11,227 33.7% 640 6.0% Other Families 8,810 27.7% 10,278 30.8% 1,468 16.7%
Non-Families 12,758 28.6% 13,014 28.1% 256 2.0%
Single- Living Alone 9,940 77.9% 9,324 71.6% -616 -6.2% Other Non-Families 2,853 22.4% 3,690 28.4% 837 29.3%
Total Households 44,574 100.0% 46,338 100.0% 1,764 4.0% Average Household Size 3.06 persons 3.21 persons 4.9%
Average Family Size 3.58 persons 3.69 persons 3.1%
Sources: Bureau of the Census, 2006-2010; American Community Survey, 2014-2018.

Household size is an important market characteristic. Housing demand is shaped by the composition of its household sizes. The small household (one to two persons per household) traditionally prefers units with zero to two bedrooms, while the large household (five or more persons per household) prefers units with at least three bedrooms. Information on Table 7 shows that a pproximately 18% of Escondido households included five or more persons.

Table 7: Household Size (2018)
Persons Owner HHs Percent Renter-
HHs Percent Total
HHs Percent
One 3,963 16.9% 5,361 23.4% 9,324 20.1%
Two 8,210 35.0% 5,375 23.5% 13,585 29.3%
Three 4,070 17.4% 3,736 16.3% 7,806 16.8%
Four 3,684 15.7% 3,507 15.3% 7,191 15.5%
Five 1,955 8.3% 3,014 13.2% 4,969 10.7%
Six 850 3.6% 1,125 4.9% 1,975 4.3%
Seven or more 694 3.0% 794 3.5% 1,488 3.2%
Total 23,426 100.0% 22,912 100.0% 46,338 100.0%
HHs = Households
Source: Bureau of the Census, American Community Survey 2014-2018.

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Household Income
Household income is directly connected by the ability to afford housing. Income levels influence the range of housing prices within a region and the ability of the population to afford housing. Home ownership rates rise as household income increases. As household income decreases, households tend to pay a disproportionate amount of their income for housing and the number of persons occupying unsound and overcrowded housing increases.

For planning and funding purposes, the California State Department of Housing and Community Development (HCD) has developed the following income categories based on the Area Median Income (AMI) of a metropolitan area (such as San Diego County):
• Extremely Low: Households earning up to 30% of the AMI • Very Low: Households earning between 31 – 50% of the AMI • Low: Households earning between 51 – 80% of the AMI
• Moderate: Households earning between 81 - 120% of the AMI • Above Moderate: Households earning over 120% of the AMI Combined, the extremely low, very low, and low income groups are referred to as lower income. Federal programs provide assistance primarily to households in the lower Income category (up to 80% AMI). In 2017, approximately 47% of Escondido households earned moderate or above moderate incomes (Figure 2), while 53% of households had incomes in the lower income levels. 1 Figure 2: Households by Income Categories (2013 -2017)

1 Data was obtained from the Comprehensive Housing Affordability Strategy (CHAS) prepared for HUD by the Census Bureau using 2013-2017 Census data. CHAS data does not provide a breakdown of household income for those with more than 80% AMI as those households are not qualified for federal housing programs.

Extremely
Low
16%
Very Low
18%
Low
19%
Moderate or
Above
47%
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Household incomes in Escondido tend to be lower than those in the region as a whole. Median household income in the City was $54,457 in 2009, compared to the San Diego County median household income of $62,901. The ACS estimates the median household income in Escondido between 2014 and 2018 was $62,319, compared to $74,855 in the County. Figure 3 compares household income in Escondido and in the San Diego region between 2014 and 2018. Approximately 60% of Escondido households had incomes over $49,999, seven percentage points lower than regionwide. Approximately 29% of Escondido households earned $100,000 or more, compared to 37% in all of San Diego County. Approximately 27% of Escondido residents earned less than $35,000 annually, compared to 23% region wide.

Figure 3: Household Income Distribution (2014- 2018)

Median household income compared to neighboring communities provides a way to measure income in Escondido against other cities. Table 8 compares median income in Escondido to other North County cities and the reg ion. Median household income in the City was one of the lowest in the region, comparable to the City of Vista.

Table 8: Median Household Income (2014-2018)
Jurisdiction Median HH Income* Percent Above/Below
Regional Median
Carlsbad $107,172 43.2%
Encinitas $113,175 51.2%
Escondido $62,319 -16.7%
Oceanside $68,652 -8.3%
Poway $105,732 41.2%
San Marcos $76,619 2.4%
Vista $65,696 -12.2%
San Diego Region $74,855 ----
Source: Bureau of the Census, American Community Survey, 2014-2018.

Median household income provides only partial insight into a community’s income profile. A more detailed breakdown of households by income category can provide more information about the proportion of households in Escondido whose limited incomes may lead them to have a higher incidence of housing

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

40.0%
Less than
$14,999
$15,000-
$24,999
$25,000-
$34,999
$35,000-
$49,000
$50,000-
$99,000
$100,000
or more
Escondido 8.0% 9.1% 9.6% 13.8% 31.0% 28.5%
San Diego County 8.1% 7.0% 7.5% 11.0% 29.5% 37.0%
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problems such as overpayment (paying more than 30% of income on housing) or overcrowding (having more than one person per room).

Household incomes improved from 2000 to 2010 ( Table 9). The percentage of wage earners with annual incomes over $50,000 increased, while the percentage of those earning less than $50,000 decreased, through the majority of this increase was due to a 7.2% increase in residents earning $100,000 or more. Since 2010, while the proportion of households earning over $100,000 continued to increase, the proportions of households earning below $15,000 decreased from 10% to eight percent, indicating a decrease in the number of households earning extremely low incomes.

Table 9: Income Distribution (2000-2018)
Household Income Income Distribution Percentage Change
2000 2010 2018 2000-2010 2010-2018
< $10,000 3.8% 5.5% 4.9% 1.7% -0.6%
$10,000 - $14,999 5.0% 5.0% 3.1% 0.0% -1.9%
$15,000 - $24,999 11.8% 10.5% 9.1% -1.3% -1.4%
$25,000 - $34,999 14.3% 11.4% 9.6% -2.9% -1.8%
$35,000 - $49,999 16.5% 15.8% 13.8% -0.7% -2.0%
$50,000 - $74,999 22.2% 19.1% 18.1% -3.1% -1.0%
$75,000 - $99,999 12.3% 11.4% 12.9% -0.9% 1.5%
$100,000 or more 14.1% 21.3% 28.5% 7.2% 7.2%
Total 100.0% 100.0% 100.0% -- --
Source: Bureau of the Census, 2000 Census; 2005-2009 American Community Survey 2005-2009; American Community Survey 2014-2018.

Housing Problems
The Comprehensive Housing Affordability Strategy (CHAS) developed by the Census for HUD provides detailed information on housing needs by income level for different types of households in Escondido.

Detailed CHAS data based on the 2013-2017 American Community Survey is displayed in Table 10.

Housing problems considered by CHAS include:
• Units with physical defects (lacking complete kitchen or bathroom); • Overcrowded conditions (housing units with more than one person per room); • Housing cost burden, including utilities, exceeding 30% of gross income; or • Severe housing cost burden, including utilities, exceeding 50% of gross income.

The types of problems vary according to household income, type, and tenure. Some highlights include:
• In general, renter -households had a higher level of housing problems (66% ) compared to owner-households (36%).
• Large renter-families had the highest level of housing problems regardless of income level (84%).
• Extremely low income (78% ) and very low income households (85 %) had the highest incidence of housing problems.

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Table 10: Housing Assistance Needs of Lower Income Households (2017) Household by Type, Income,
and Housing Problem
Renters Owners Total
Households Elderly Small
Families
Large
Families
Total
Renters Elderly Large
Families
Total
Owners
Extremely Low Income (0-30% AMI) 1,085 2,335 720 5,465 910 55 1,835 7,300 % with any housing problem 75.1% 87.4% 97.9% 84.1% 65.9% 100.0% 60.5% 78.2% % with cost burden >30% 74.2% 86.5% 96.5% 82.8% 66.5% 100.0% 60.8% 77.3% % with cost burden > 50% 65.0% 72.6% 83.3% 71.0% 48.4% 100.0% 48.2% 65.3% Very Low Income (31-50% AMI) 865 2,645 1,180 5,600 1,115 420 2,250 7,850 % with any housing problem 86.1% 95.7% 95.3% 93.4% 52.0% 88.1% 64.9% 85.2% % with cost burden >30% 85.0% 90.2% 85.6% 88.5% 51.6% 59.5% 59.1% 80.1% % with cost burden >50% 42.2% 39.5% 33.1% 40.0% 30.0% 21.4% 37.8% 39.4% Low Income (51-80% AMI) 685 2,220 1,195 5,170 1,420 635 3,495 8,665 % with any housing problem 78.1% 68.5% 87.0% 72.8% 39.8% 70.1% 54.6% 65.5% % with cost burden >30% 75.2% 53.8% 41.8% 55.3% 39.1% 55.9% 51.9% 54.0% % with cost burden > 50% 24.1% 7.2% 7.9% 9.5% 16.2% 13.4% 19.9% 13.7% Total Households 3,495 10,285 3,865 22,695 6,960 2,865 22,485 45,180 % with any housing problem 65.5% 65.5% 83.8% 66.0% 34.9% 59.3% 35.7% 50.9% Note: Data presented in this table are based on special tabulations from sample Census data. The number of households in each category usually deviates slightly from the 100% total due to the need to extrapolate sample data out to total households.

Interpretations
of these data should focus on the proportion of households in need of assistance rather than on precise numbers.

Source: HUD Comprehensive Housing Affordability Strategy (CHAS), 2013-2017.

Overcrowding
Overcrowding is typically defined as a housing unit occupied by more than one person per room. A severely overcrowded household is defined as one with more than 1.5 persons per room. Under State law a housing unit is considered overcrowded if there is less than 120 square feet of livable space (all space except the bath, kitchen and hallways) for the first two people and less than an additional 50 square feet for each additional person. Overcrowding can indicate that a community does not have an adequate supply of affordable housing, especially for large families.

Overcrowding typically occurs when there are not enough adequately sized units within a community, when high housing costs relative to income force too many individuals to share a housing unit than it can adequately accommodate, or when families reside in smaller units than they need to devote income to other necessities, such as food and health care. Overcrowding tends to accelerate the deterioration of housing. Therefore, maintaining a reasonable level of occupancy and alleviating overcrowding are critical to enhancing quality of life.

Table 11 shows that nearly 10% of the households in Escondido were overcrowded in 2010, inclusive of the 12% that were severely overcrowded. Overcrowding was more prevalent among renter-households than owner-households, as rental units are typically smaller in size and renter-households typically have lower incomes. The situation with overcrowding worsened significantly between 2010 and 2018, with over 12% of the City’s households being overcrowded. Specifically, over 4% of the households were severely overcrowded. The prevalence of overcrowding among owner-households did not change significantly between 2010 and 2018. However, the prevalence of renter-households increased from 16% to 20% and Attachment "5"
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severely overcrowded renter-households increased nearly three percent to 7.5 % between 2014 and 2018.

Table 11: Overcrowded Housing Units (2010-2018)
Overcrowding
Owner-Households Renter-Households Total Households
Number % of
Owners Number % of
Renters Number % of Total
2010
Total Overcrowded
(More than 1.0 persons/room) 1,073 4.4% 3,236 15.9% 4,309 9.7% Severely Overcrowded
(More than 1.5 persons/room) 324 1.0% 841 4.1% 1,075 2.4% 2018
Total Overcrowded
(More than 1.0 persons/room) 1,263 5.4% 4,475 19.5% 5,738 12.4% Severely Overcrowded
(More than 1.5 persons/room) 285 1.2% 1,725 7.5% 2,010 4.3% Source: Bureau of the Census, 2006-2010; American Community Survey, 2014-2018.

Cost Burden
Measuring the portion of a household’s gross income that is spent for housing is an indicator of the dynamics of demand and supply. This measurement is often expressed in terms of “ cost burden”-- households paying an excessive amount of their income for housing, therefore decreasing the amount of disposable income available for other needs. This indicator is an important measurement of local housing market conditions as it reflects the affordability of housing in the community. Federal and state agencies use cost burden indicators to determine the extent and level of funding and support that should be allocated to a community.

Table 12 shows that in 2017, 41% of households in the San Diego region were paying over 30% of their income towards housing costs. In Escondido, nearly 45% of all households were cost burdened. Renters were more likely to experience cost burden than owners; in Escondido 58 % of renters were cost burdened, compared to 32% of owners. Escondido had the highest level of cost burdened renters while Encinitas had the lowest level. For owner-households, Vista had the highest level of cost burden and Carlsbad had the lowest level.

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Table 12: Household Cost Burden (2017)

All HH Renters Owners
Total % Paying
30%+ Total % Paying
30%+ Total % Paying
30%+
Carlsbad 43,280 34.6% 15,130 46.1% 28,150 28.4%
Encinitas 24,285 35.5% 8,790 45.6% 15,495 29.8%
Escondido 45,175 44.8% 22,685 57.5% 22,490 31.9%
Oceanside 61,980 42.2% 27,290 55.1% 34,685 32.0%
Poway 15,770 33.9% 4,035 48.3% 11,735 28.9%
San Marcos 29,175 40.9% 11,285 53.6% 17,885 32.8%
Vista 30,570 44.7% 15,530 55.5% 15,040 33.6%
San Diego Region 1,111,740 41.3% 522,595 52.0% 589,145 31.7% Note: Households do not equal total presented in other tables because housing costs were not computed for all households.

Source: HUD Comprehensive Housing Affordability Strategy (CHAS), 2013-2017.

Table 13 provides more details on cost burden by income group for Escondido. Approximately 70% of lower income households were cost burdened versus 17 % of moderate and above moderate households.

Table 13: Cost Burden by Tenure and Income Level (2017) Household Income Group Total Renters Total Owners Total Extremely Low (<=30% AMI) 3,552 1,184 4,736
Cost Burden >30% 3,012 919 3,931
% Cost Burden >30% 84.8% 77.6% 83.0%
Very Low (>30% to <=50% AMI) 4,298 1,705 6,003
Cost Burden >30% 3,451 1,023 4,478
% Cost Burden >30% 80.3% 60.0% 74.6%
Low (>50% to <=80% AMI) 5,077 3,782 8,859
Cost Burden >30% 2,193 1,728 3,925
% Cost Burden >30% 43.2% 45.7% 44.3%
Moderate & Above (>80% AMI) 7,479 16,670 24,149
Cost Burden >30% 524 3,134 3,671
% Cost Burden >30% 7.0% 18.8% 15.2%
Total 20,406 23,341 43,747
Cost Burden >30% 9,183 6,816 15,968
% Cost Burden >30% 45.0% 29.2% 36.5%
Note: Totals may not be exact due to rounding; the Census Bureau uses a special rounding scheme for special tabulations such as these; totals may not match other census datasets Source: HUD Comprehensive Housing Affordability Strategy (CHAS), 2013-2017

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Special Needs Groups
Certain segments of the population may have more difficulty in finding decent, affordable housing due to their special needs. Special circumstances may be related to one’s employment and income, family characteristics, disability and household characteristics, among other factors. Consequently, certain residents in Escondido may experience higher incidences of housing cost burden, overcrowding, or other housing problems.

The special needs groups analyzed include the elderly, people with disabilities (including persons with developmental disabilities), homeless people, single parents, large households, military personnel, farm workers, and students (Table 14). Many of these groups overlap, for example many farm workers may be homeless, and many elderly people have a disability of some type.

The majority of these special needs groups would be assisted by an increase in affordable housing, especially housing located near public transportation and services. Table 15 provides a list of services and facilities available to assist households/persons with special needs.

Table 14: Special Needs Groups
Special Needs Group # of People
or HHs
#
Owners
%
Owner
#
Renters
%
Renter
% of Total
HHs or
Population
Households with Seniors 11,169 -- -- -- -- 24.1%
Senior Headed Households 9,915 6,919 29.5% 2,996 13.1% 21.4% Seniors Living Alone 4,255 2,201 9.4% 2,054 9.0% 9.2%
Persons with Disabilities 15,626 -- -- -- -- 10.3%
Large Households 8,432 3,499 14.9% 4,933 21.5% 18.2%
Single-Parent Households 5,127 -- -- -- -- 11.1%
Female-Headed Households 6,806 2,457 10.5% 4,349 19.0% 14.7% Female-Headed Households with children 3,739 -- -- -- -- 7.3% People Living in Poverty 22,270 -- -- -- -- 14.7%
Farmworkers1 1,707 -- -- -- -- 1.1%
Homeless 429 -- -- -- -- 0.3%

1. ACS category includes “Agriculture, forestry, fishing and hunting, and mining.” Source: Bureau of the Census, American Community Survey, 2014-2018; Regional Housing Task Force on the Homeless 2020.

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Table 15: Inventory of Services for Special Needs Populations Services Program Details
Emergency
Shelters,
Permanent, &
Transitional
Housing
Hidden Valley House
Provides temporary, emergency shelter for survivors of domestic violence and their children. Offers safety planning, crisis counseling, advocacy services and assistance with obtaining long- term safe housing.

Inland Service Center/
Interfaith Community
Services
Haven House Year-Round Shelter provides emergency housing for up to 49 homeless men and women each night.

Also offers temporary beds for veterans with or without a housing intervention already in place to assist in their transition from homelessness to permanent housing.

Interfaith offers a variety of permanent housing units and programs that provide safe and affordable housing for homeless community members.

Serenity Village Transitional Housing for women and women with children.

Tikkun House
Provides temporary emergency shelter for homeless mentally or emotionally disturbed women. Case planning, counseling, and advocacy are offered.

Interfaith Community
Services
Resources to find affordable housing, transition housing, emergency shelter
Las Casitas Community
Housing
Housing education and workshops, low -income housing lists, homebuyer loans and foreclosure prevention.

Veterans
Aster 10 beds (short-term recuperative)
Aster Apartments 28 beds
Fairweather Lodge 6 mentally ill veterans (permanent supportive housing) Merle’s Place 44 beds (dormitory)
New Resolve 44 beds (homeless, veterans)
Raymond’s Refuge I & II 6 beds each for homeless seniors/ disabled (permanent supportive housing)
Veterans Villas PSH & affordable units owned by VVSD on S Escondido Blvd. (total 54 units in development)
Senior/Disability
Services Joslyn Center Senior support
Source: City of Escondido

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Seniors
Many senior-headed households have special needs due to their relatively low incomes, disabilities or limitations, and dependency needs. Specifically, people aged 65 years and older often have four main concerns:
• Housing: Many seniors live alone and may have difficulty maintaining their homes. • Income: People aged 65 and over are usually retired and living on a limited income. • Health care: Seniors are more likely to have high health care costs. • Transportation: Many of the elderly rely on public transportation; especially those with disabilities.

The limited income of many elderly persons often makes it difficult for them to find affordable housing. In the San Diego region, the elderly spend a higher percentage of their income for food, housing, medical care, and personal care than non-elderly families. Many elderly households need smaller “efficiency” units to make independent living possible and many single elderly persons need some form of housing assistance.

Table 16 shows that 17,632 persons were age 65 and older in Escondido in 2018. This accounted for about 12% of residents, comparable to the percentage found in the region as a whole. In comparison, most surrounding communities had higher proportions of seniors. Among the City’s senior population, 9,915 seniors were heads of households, representing about 21% of the City’s overall households (Table 14). Specifically, 4,255 senior-headed households were seniors living alone.

Table 16: Persons Age 65 and Older (2018)
Jurisdiction Total Age 65+ Percent Age 65+
Carlsbad 113,670 19,151 16.8%
Encinitas 62,713 11,124 17.7%
Escondido 151,115 17,632 11.6%
Oceanside 175,389 27,214 15.5%
Poway 49,842 8,123 16.3%
San Marcos 94,709 11,057 11.7%
Vista 100,108 9,676 9.7%
San Diego Region 3,302,833 439,595 13.3%
Source: American Community Survey, 2014-2018.

Table 17 shows elderly households by tenure and income level in 2017. About the same proportion of elderly renter-occupied households and renter-occupied households (65.5% and 66%, respectively) experience a housing problem. Housing problems are defined as cost burden greater than 30% of income, and/or overcrowding, and/or without complete kitchen or plumbing facilities. Additionally, 64% of elderly renter-occupied households were paying more than 30% of their income for housing compared with 58% of all renter-households. Elderly owner-occupied households, on the other hand, tend to be better off than all households as a group (51%) but only marginally better than all owner-occupied households. About 35% elderly owner-occupied households had any housing problem compared with 36% of all owner- occupied households. It appears that elderly owner-renter households are disproportionately affected by cost burden since about 36% are cost-burned compared to 31% of all owner-occupied households. Also, Attachment "5"
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while most elderly owner-households no longer hold a mortgage, some elderly homeowners may not be able to afford the costs of maintenance and repairs.

Table 17: Elderly Households by Tenure and Income Level (2017) Household by Type, Income and Housing
Problem
Renters Owners Total
Households Elderly
Renters
Total
Renters
Elderly
Owners
Total
Owners
Household Income <=30% AMI 1,085 5,465 910 1,835 7,300
% with any housing problems 75.1% 84.1% 65.9% 60.5% 78.2% % Cost Burden >30% 74.2% 82.8% 66.5% 60.8% 77.3%
% Cost Burden >50% 65.0% 71.0% 48.4% 48.2% 65.3%
Household Income >30 to <=50% AMI 865 5,600 1,115 2,250 7,850 % with any housing problems 86.1% 93.4% 52.0% 64.9% 85.2% % Cost Burden >30% 85.0% 88.5% 51.6% 59.1% 80.1%
% Cost Burden >50% 42.2% 40.0% 30.0% 37.8% 39.4%
Household Income >50 to <=80% AMI 685 5,170 1,420 3,495 8,665 % with any housing problems 78.1% 72.8% 39.8% 54.6% 65.5% % Cost Burden >30% 75.2% 55.3% 39.1% 51.9% 54.0%
% Cost Burden >50% 24.1% 9.5% 16.2% 19.9% 13.7%
Household Income >80% AMI 860 6,460 3,515 14,905 21,365 % with any housing problems 22.7% 21.6% 19.5% 23.8% 23.1% % Cost Burden >30% 19.8% 11.1% 19.2% 19.6% 17.0%
% Cost Burden >50% 5.8% 1.0% 2.8% 1.8% 1.6%
Total Households 3,495 22,695 6,960 22,485 45,180
% with any housing problems 65.5% 66.0% 34.9% 35.7% 50.9% % Cost Burden >30 63.7% 57.5% 34.6% 31.9% 44.8%
% Cost Burden >50 36.8% 29.4% 15.9% 12.0% 20.7%
Notes:

Any housing problems: cost burden greater than 30% of income and/or overcrowding and/or without complete kitchen or plumbing facilities. Other housing problems: overcrowding (1.01 or more persons per room) and/or without complete kitchen or plumbing facilities.

Elderly households: 1 or 2 person household, either person 62 years old or older.

Source: HUD Comprehensive Housing Affordability Strategy (CHAS), 2013-2017.

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Persons with Disabilities
In Escondido and elsewhere, persons with disabilities have a wide range of housing needs, which vary depending on the type and severity of the disability as well as personal preference and lifestyle. Physical, mental, and/or developmental disabilities may prevent a person from working, restrict one’s mobility, or make it difficult to care for oneself. “Barrier-free design” housing, accessibility modifications, proximity to services and transit, and group living opportunities represent some of the types of considerations and accommodations that are important in serving this group. Also, some residents suffer from disabilities that require living in a supportive or institutional setting.

According to 2014-2018 ACS data, approximately 10% of Escondido residents had a disability. The ACS also tallied the number of disabilities by type for residents with one or more disabilities. Among the disabilities tallied, cognitive, ambulatory, and independent living difficulties were almost equally prevalent (Table 18).

Table 18: Disabilities Tallied by Age and Type (2018)
Disability Type Under 18 Age 18 to 64 Age 65+ Total
With a hearing difficulty 8.8% 8.6% 17.0% 12.6%
With a vision difficulty 9.3% 8.5% 7.6% 8.2%
With a cognitive difficulty 54.9% 23.2% 13.1% 20.1%
With an ambulatory difficulty 8.8% 26.4% 28.7% 26.5%
With a self-care difficulty 18.2% 10.5% 11.1% 11.2%
With an independent living difficulty 0.0% 22.8% 22.4% 21.4% Total Disabled Persons 1,724 14,811 14,879 31,414
Note: A person can have multiple disabilities.

Source: American Community Survey, 2014-2018.

Four factors – affordability, design, location, and discrimination – significantly limit the supply of housing available to households of persons with disabilities. The most obvious housing need for persons with disabilities is housing that is adapted to their needs. Most single-family homes are inaccessible to people with mobility and sensory limitations. Housing may not be adaptable to widened doorways and hallways, access ramps, larger bathrooms, lowered countertops, and other features necessary for accessibility.

Location of housing is also an important factor for many persons with disabilities, as they often rely upon public transportation to travel to necessary services and shops. “Barrier free design” housing, accessibility modifications, proximity to services and transit, and group living opportunities are important in serving this group. Incorporating barrier-free design in all new multi-family housing is especially important to provide the widest range of choices for the disabled.

Housing advocacy groups report that people with disabilities are often the victims of discrimination in the home buying market. People with disabilities, whether they work or receive disability income are often perceived to be a greater financial risk than persons without disabilities with identical income amounts.

The 2014-2018 ACS reported that 19% of persons with disabilities in Escondido were living below the poverty level. It also estimated that 73% of people with disabilities between the ages of 16 and 64 years in the City were not in the labor force.

A change in State law requires that the Housing Element discuss the housing needs of persons with developmental disabilities. As defined by federal law, “developmental disability” means a severe, chronic disability of an individual that:

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• Is attributable to a mental or physical impairment or combination of mental and physical impairments;
• Is manifested before the individual attains age 18;
• Is likely to continue indefinitely;
• Results in substantial functional limitations in three or more of the following areas of major life activity: self-care; receptive and expressive language; learning; mobility; self- direction; capacity for independent living; or economic self- sufficiency; • Reflects the individual’s need for a combination and sequence of special, interdisciplinary, or generic services, individualized supports, or other forms of assistance that are of lifelong or extended duration and are individually planned and coordinated.

The Census does not record developmental disabilities. Acc ording to the U.S. Administration on Developmental Disabilities, an accepted estimate of the percentage of the population that can be defined as developmentally disabled is 1.5 %. This equates to 2,295 persons in the City of Escondido with developmental disabilities based on the 2020 California Department of Finance population estimates.

The San Diego Regional Center, which provides services for persons with developmental disabilities, publishes client statistics for its four area offices. The City of Escondido is served by the North County office in San Marcos. As of June 2019, 1,672 residents Escondido residents had received services from the Regional Center.

Many developmentally disabled persons can live and work independently within a conventional housing environment. More severely disabled individuals require a group living environment where supervision is provided. The most severely affected individuals may require an institutional environment where medical attention and physical therapy are provided. Because developmental disabilities exist before adulthood, the first issue in supportive housing for the developmentally disabled is the transition from the person’s living situation as a child to an appropriate level of independence as an adult.

Large Households
Large households are defined as those consisting of five or more members. These households comprise a special need group because of the limited supply of adequately sized and affordable housing units in a community. To save for other basic necessities such as food, clothing and medical care, it is common for lower income large households to reside in smaller units, which frequently results in overcrowding and can accelerate the deterioration of housing.

The City had 8,111 large households in 2000, comprising about 19% of the City’s total households. The proportion increased to 21% by the following decade. The 2010 Census data indicated that there were 9,410 households with five or more members. By 2018, the number of large households decreased to 8,432, or 18 % of all households in the City. Table 19 compares the number of large households in Escondido to that in the region as a whole. In 2018, 18% of households in Escondido consisted of five or more persons, compared to 12% region wide. Renter-households represented the majority (59%) of all large households.

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Table 19: Large Households (2018)
Jurisdiction Persons in Household Total
Households 5 6 7+
Escondido 4,969 1,975 1,488 8,432
Percent of Total 10.7% 4.3% 3.2% 18.2%
San Diego Region 78,930 32,607 21,051 132,588
Percent of Total 7.1% 2.9% 1.9% 11.8%
Source: Bureau of the Census, 2014-2018 American Community Survey.

As shown in Table 20, a greater percentage of larger households had housing problems than all households (51%) in 2017. Housing problems can be defined as cost burden greater than 30% of income, and/or overcrowding, and/or without complete kitchen or plumbing facilities. Renter -occupied large households (as a group) tend to have more housing problems than owner-occupied large households.

The majority of renter-occupied large households (84%) had one or more housing problems, while more than half of larger owner-occupied households (59%) had one or more housing problems.

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Table 20: Large Households by Tenure and Income Level (2017) Household by Type, Income, & Housing
Problem
Renters Owners
Total
Households
Large
Related
(5 or more
members)
Total
Renters
Large
Related
(5 or more
members)
Total
Owners
Household Income <=30% AMI 720 5,465 55 1,835 7,300
% with any housing problems 97.9% 84.1% 100.0% 60.5% 78.2% % Cost Burden >30% 96.5% 82.8% 100.0% 60.8% 77.3%
% Cost Burden >50% 83.3% 71.0% 100.0% 48.2% 65.3%
Household Income >30 to <=50% AMI 1,180 5,600 420 2,250 7,850 % with any housing problems 95.3% 93.4% 88.1% 64.9% 85.2% % Cost Burden >30% 85.6% 88.5% 59.5% 59.1% 80.1%
% Cost Burden >50% 33.1% 40.0% 21.4% 37.8% 39.4%
Household Income >50 to <=80% AMI 1,195 5,170 635 3,495 8,665 % with any housing problems 87.0% 72.8% 70.1% 54.6% 65.5% % Cost Burden >30% 41.8% 55.3% 55.9% 51.9% 54.0%
% Cost Burden >50% 7.9% 9.5% 13.4% 19.9% 13.7%
Household Income >80% AMI 770 6,460 1,755 14,905 21,365 % with any housing problems 48.1% 21.6% 47.3% 23.8% 23.1% % Cost Burden >30% 6.5% 11.1% 18.2% 19.6% 17.0%
% Cost Burden >50% 0.0% 1.0% 2.6% 1.8% 1.6%
Total Households 3,865 22,695 2,865 22,485 45,180
% with any housing problems 83.8% 66.0% 59.3% 35.7% 50.9% % Cost Burden >30% 58.3% 57.5% 34.2% 31.9% 44.8%
% Cost Burden >50% 28.1% 29.4% 9.6% 12.0% 20.7%
Note: Totals may not match other 2014-2018 ACS products due to rounding.

Any housing problems: cost burden greater than 30% of income and/or overcrowding and/or without complete kitchen or plumbing facilities.

Source: HUD Comprehensive Housing Affordability Strategy (CHAS), 2013-2017.

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Single Parent Households
Single-parent families, particularly female- headed families with children, often require special consideration and assistance because of their greater need for affordable housing and accessible day care, health care, and other supportive services. Female-headed families with children are considered a vulnerable group because they must balance the needs of their children with work responsibilities, often while earning limited incomes.

Table 21 shows that in 2018, Escondido had 5,127 single-parent households (11% of all households). Of these, the majority (66%) were female-headed households. In comparison, about eight percent of all County households were single-parent households, but 72% of these households were female-headed households.

Table 21: Single Parent Households (2018)

Total
HHs
Single
Parent
HHs
Percent
Total HHs
Female
Headed
HHs
Percent
Single
Parent
HHs
Below Poverty
Female Headed
HHs
Percent
Female
Headed HHs
Escondido 46,338 5,127 11.1% 3,379 65.9% 1,454 43.0%
San Diego Region 1,118,980 92,411 8.3% 66,423 71.9% 22,186 33.4% HHs = Households
Source: American Community Survey, 2014-2018.

Residents Living Below Poverty
Female-headed families are particularly affected by poverty disproportionately. In 2010, 21% of the City’s total residents (29,055 persons) were living in poverty. Approximately 34% of female-headed households with children, however, had incomes below the poverty level. In comparison, the 2014-2018 ACS reports that the percent of the City’s population living below the poverty level decreased to 15% while percent of female-headed families increased by nine percent to 43%.

Extremely Low-Income Households
Extremely low-income (ELI) is defined as households with income less than 30% of area median income. The area median income in the County is $92,700. For ELI households, this results in an income of $31,200 or less for a four-person household or $24,300 or less for a one-person household (See Table 34). ELI households have a variety of housing situations and needs. For example, most families and individuals receiving public assistance, such as social security insurance (SSI) or disability insurance are considered ELI households.

According to the most recent data from HUD, approximately 7,300 ELI households resided in the City, representing 16% of the total households. Most ( 78%) ELI households experience a high incidence of housing problems (defined as cost burden greater than 30% of income and/or overcrowding and/or without complete kitchen or plumbing facilities) . Most (75%) ELI households are also renters, and renter ELI households experience housing problems at higher rates than owner ELI households (84% versus 61%, respectively). Elderly households make up almost one third (1,995) of all ELI households. In addition, over 60% of ELI households have a member with a disability.

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Table 22: Extremely-Low-Income Households by Tenure and Type Renters Owners All ELI
HH Elderly Small
Related
Large
Related
Total
Renters
Elderly Small
Related
Large
Related
Total
Owners
ELI Households 1,085 2,335 720 5,465 910 550 55 1,835 7,300 % with Any Housing
Problem 75.1% 87.4% 97.9% 84.1% 65.9% 39.1% 100.0% 60.5% 78.2% % with Cost Burden >30 74.2% 86.5% 96.5% 82.8% 66.5% 40.0% 100.0% 60.8% 77.3% % with Cost Burden >50 65.0% 72.6% 83.3% 71.0% 48.4% 33.6% 100.0% 48.2% 65.3% With Disability N/A N/A N/A 3,335 N/A N/A N/A 1,210 4,545 % with Disability N/A N/A N/A 61.0% N/A N/A N/A 65.9% 62.2% Total HH 3,495 10,285 3,865 22,695 6,960 10,535 2,865 22,485 45,180 % of HH ELI 31.0% 22.7% 18.6% 24.1% 13.1% 5.2% 1.9% 8.2% 16.2% Source: HUD CHAS 2013-2017 ACS Estimates
ELI households will likely seek rental housing and housing that is accessible to elderly residents and/or residents with disabilities. To address the range of needs, the City will promote a variety of housing types by locating ELI housing across the City (in the Downtown, East Valley, and South Centre planning areas), along with other transit-supportive uses and improvements. In addition, the City will facilitate and encourage low-income housing through the following Programs:
• ADUs: Explore tools and incentives to facilitate ADU construction, including on religious properties.
• Supportive Housing: Review and amend their Municipal Code to ensure supportive housing is allowed where residential uses are allowed.
• Affordable Housing Finance Programs: Support the construction, acquisition/rehabilitation, and preservation of affordable housing in the community, especially for ELI and special needs households.

In addition, the City has a variety of programs that support existing ELI households:
• Essential Middle Income Rental Housing Program: Acquisition and conversion of existing market-rate apartment communities to rent-restricted units for Low -Income, Median-Income, and Moderate-Income households earning no more than 120% of AMI. • Mobile Home Park Rent Review: Conduct hearings on rent increases. • Preservation of at-risk units.

Homeless
Throughout the San Diego region and country, homelessness has become an increasingly important issue. Factors contributing to the rise in homelessness include a lack of housing affordable to low and moderate income persons, increases in the number of persons whose incomes fall below the poverty level, reductions in public subsidies to the poor, and the de-institutionalization of the mentally ill.

State law (Government Code section 65583(7)) mandates that municipalities address the special needs of homeless persons within their jurisdictional boundaries. “Homelessness” as defined by the U.S.

Department of Housing and Urban Development (HUD), describes an individual (not imprisoned or otherwise detained) who:

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• Lacks a fixed, regular, and adequate nighttime residence; and • Has a primary nighttime residence that is:
• A supervised publicly or privately operated shelter designed to provide temporary living accommodations (including welfare hotels, congregate shelters, and transitional housing for the mentally ill);
• An institution that provides a temporary residence for individuals intended to be institution- alized; or
• A public or private place not designed for, or ordinarily used as, a regular sleeping accommodation for human beings.

This definition does not include per sons living in substandard housing, (unless it has been officially condemned); persons living in overcrowded housing (for example, doubled up with others), persons being discharged from mental health facilities (unless the person was homeless when entering and is considered to be homeless at discharge), or persons who may be at risk of homelessness (for example, living temporarily with family or friends.)
The Regional Task Force on the Homelessness (“RTFH”) is San Diego County’s leading resource for information on issues of homelessness. Established in 1985, the Task Force promotes a regional approach as the best solution to ending homelessness in San Diego County. The Task Force is a public/private effort to build a base of understanding about the multiple causes and conditions of homelessness.

According to the Task Force, the San Diego region’s homeless population can be divided into two general groups: (1) urban homeless, and (2) rural homeless, including farm workers and day laborers who primarily occupy the hillsides, canyons and fields of the northern regions of the county. It is important to recognize that homeless individuals may fall into more than one category (for example, a homeless individual may be a veteran and a substance abuser), making it difficult to accurately quantify and categorize the homeless.

Since the homeless population is very difficult to quantify, Census information on homeless populations is often unreliable, due to the difficulty of efficiently counting a population without permanent residences.

The Task Force compiles data from a physical Point-In-Time (“PIT”) count of sheltered (emergency and transitional) and street homeless persons. The 2020 Count was conducted on January 22, 2020, and the results are shown in Table 23 Oceanside and Escondido had the largest homeless populations of the North County cities.

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Table 23: Homelessness in North County Cities (2020)
Jurisdiction Sheltered Unsheltered Total
Carlsbad 53 94 147
Escondido 165 264 429
Encinitas 33 47 80
Oceanside 166 242 408
Poway 0 15 15
San Marcos 0 8 8
Vista 49 51 100
San Diego Region 3,648 3,971 7,619
Source: Regional Housing Task Force on the Homeless (2020).

Military Personnel
The military population’s influence on the demand for housing takes two forms: (a) the existing service households trying to find housing; and (b) the former (either retirement or non-retirement separations) service households trying to find housing. The San Diego region is home to a disproportionate share of the State's and the nation’s military personnel. According to the one-year 2018-2019 ACS, 54 % of California’s 150,746 uniformed military personnel were stationed in the San Diego region, and seven percent of the nation’s 1.2 million armed forces were located in the region.

The greatest concentration of military personnel to the overall labor force in the region is found in Coronado, home to Naval Air Station North Island. Almost one out of every two members of Coronado’s total labor force is in the military. Other areas with relatively high concentrations of military personnel are the City of National City and the unincorporated area. However, the City of San Diego has the largest number of people in the armed forces (32,617), accounting for about 40% of the region’s enlisted military personnel. The existing military family housing is scattered across the region, and some communities, such as Escondido, have substantial portions of their housing stock occupied by military families.

However, less than one percent of the region’s armed forces reside in Escondido.

Student Housing Need
Student housing is considered a factor that affects housing availability. Although students may produce only temporary housing need, the impact upon housing demand and post-study residence is critical in the immediate university areas. San Diego State University, the largest university in the region, has an enrollment of 33,870 students as of the Fall of 2020, but only provides housing for approximately 3,500 students on campus. The University of San Diego houses approximately 3,800 students on campus for a student enrollment of 8,861 (Fall 2020). The University of California at San Diego provides on-campus housing for about 11,000 students for a student enrollment of 37,629 (Fall 2019). Other smaller universities and junior colleges in the County create similar housing problems. For example, the location of California State University San Marcos has had some impact on local housing, due to its location a few miles west of Escondido.

Typically, students are low income and are, therefore, impacted by a lack of affordable housing, especially within easy commuting distance from campus. They often seek shared housing situations to decrease expenses, and can be assisted through roommate referral services offered on and off campus. The lack of affordable housing also influences choices students make after graduation which can have a detrimental effect on the region's economy. The recent graduates provide a specialized pool of skilled Attachment "5"
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labor that is vital to the region; however, the lack of affordable housing often leads to their departure from the area.

Farm Workers
Farm workers are defined as those households whose wage earners make their living through seasonal agricultural work and who move with the seasons to different farming areas or communities. Permanent residents, who work in agriculture doing similar work, but who live in Escondido the entire year, are included in the City’s estimates of households needing assistance due to affordability. However, the undocumented immigrant and migrant worker form a substantial part of the farm worker population. The ability to gather information about this segment of the farm worker population is limited because they are so mobile and reluctant to participate in any survey.

Due to the high cost of housing and low wages, a significant number of migrant farm workers have difficulty finding affordable, safe and sanitary housing. According to the State Employment Development Department, the average farm worker earned a mean annual wage of $31,729. 2 This limited income is
exacerbated by their tenuous and/or seasonal employment status.

The housing needs of farm workers are difficult to quantify due to the fear of job loss and the fear of authority. Thus, farm workers are given low priority when addressing housing needs, and often receive the least hospitable housing. The San Diego County Regional Task Force on the Homeless estimates that many of the farm workers in the County live in migrant camps throughout the region.

The 2014-2018 ACS provided a few indicators of the potential farm worker population. The ACS revealed that approximately 1,308 individuals in Escondido were employed in the farming, fishing, and forestry industry. More recent estimates for the number of farm workers, however, vary depending upon the different growing seasons. The National Center for Farmworker Health (“NCFH”) estimates that there are over 12,000 hired farm workers and nearly 2,000 contract farm workers in San Diego County. 3 The
numbers can change quickly as more work becomes available. This population remains highly migratory, following the work as it becomes available and even returning home for short periods during the off season. Other estimates of farmworker population come from the U.S. Department of Agriculture (USDA).

According to the USDA’s 2017 Census of Agriculture, 2,202 persons were hired farm labor (full time), 7,982 persons were employed for 150 days or more, and 4,353 were hired for 150 days or less in San Diego County (data is only available at a county level).

The number of encampments located throughout the County has become very difficult to estimate because encampments move frequently and are now much smaller than in the past. It is estimated that there are between 100 and 150 farm worker camps located throughout the San Diego region, primarily in rural areas.4 These encampments range in size from a few people to a few hundred and are frequently found in fields, hillsides, canyons, ravines, and riverbeds, often on the edge of their employer’s property.

Some workers reside in severely overcrowded dwellings, in packing buildings, or in storage sheds.

Because camps tend to be in remote locations, this population is often under-counted. Most farm workers and day laborers have moved from living inside the local jurisdiction’s boundary lines to just outside them in the unincorporated areas. The City of Escondido recognizes the needs of farm workers and allows housing to be partially provided through provisions in the Zoning Ordinance. The City is one of a few 2 State Employment Development Department, Occupational Employment (May 2019) and Wage Data (1st Quarter, 2020). 3 National Center for Farmworker Health, Inc., Migratory and Seasonal Farmworker Population Estimates (2017). 4 California Institute for Rural Studies. The Agricultural Worker Health Study, Case Study 2: North San Diego County (July 2002).

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which allows, as a permitted use in agricultural and estate residential zones, living quarters for persons employed on the premises in conjunction with authorized agricultural uses.

The City completed the development of nine units for farm workers as part of a 24-unit affordable housing complex for low income households in 2001. The project is located at 1801– 1821 South Escondido Boulevard and is called Eucalyptus View Cooperative Apartments. The development provides 24 units of affordable housing to families earning less than 50% of the area median income. The unit mix includes four one-bedroom units, 11 two- bedroom units and eight three -bedroom units. As a limited -equity cooperative, Eucalyptus View provides a form of homeownership. The initial share prices are equivalent to what is typically required for rent and security deposits for a rental unit. Long- term affordability is guaranteed and resale prices are limited to a percentage of annual increases in the equity investment.

Housing Stock Characteristics
A community’s housing stock is defined as the collection of all housing units located within the jurisdiction.

The characteristics of the housing stock, including growth, type, age and condition, tenure, vacancy rates, housing costs, and affordability are important in determining the housing needs for the community. This section details the housing stock characteristics of Escondido to identify how well the current housing stock meets the needs of current and future residents of the City.

Housing Growth
During the 1980s and 1990s, the City’s housing stock grew significantly that led to the City implementing several growth management policies that dramatically limited the number of units that could be built each year in order to ensure the provision of adequate facilities and services prior to development of future housing stock. As a result, the rate of housing growth declined sharply between 2000 and 2010, at less than seven percent (Table 24). The decrease in housing production also occurred as a result of the recession. While there were building permits available to be pulled for units in some of the large subdivisions, developers chose not to build due to the decline in the market.

Recovery from the recession had been slow. While several neighboring jurisdictions experienced large increases in their housing stock over the last 20 years, such as Carlsbad and San Marcos, oth ers jurisdictions, including Escondido, experienced only moderate increases. Table 24 shows that between 2010 to 2020, Escondido’s housing stock increased only 2.4%, below the countywide average (5.3%) and significantly below the nearby Carlsbad and San Marcos, where housing growth exceeded six percent and 13%, respectively.

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Table 24: Housing Unit Growth (2000 to 2020)
Jurisdiction 2000 2010 2020 Percent Change
2000-2010 2010-2020
Carlsbad 33,812 44,673 47,629 32.1% 6.6%
Encinitas 23,829 25,740 26,625 8.0% 3.4%
Escondido 45,050 48,044 49,211 6.7% 2.4%
Oceanside 59,583 64,435 66,078 8.1% 2.6%
Poway 15,714 16,715 16,932 6.4% 1.3%
San Marcos 18,862 28,641 32,460 51.8% 13.3%
Vista 29,814 30,986 32,874 3.9% 6.1%
San Diego Region 1,040,149 1,164,786 1,226,879 12.0% 5.3% Source: Bureau of the Census, 2000 and 2010 Censuses; California Department of Finance, 2020 Population and Housing Estimates.

Projected Housing Units
Table 25 shows that between 2020 and 2030, Escondido is projected to gain 12 % in housing stock.

Regionwide, approximately ten percent more units will be added to the housing stock. Between 2020 and 2040, Escondido is projected to see an increase of 13% in housing stock and approximately 17% more units will be added in the region.

Table 25: Projected Housing Units (2020-2040)
Jurisdiction 2020
(Actual) 2030 2040 Percent Change
2020-2030 2020-2040
Carlsbad 47,629 49,629 50,491 4.2% 6.0%
Encinitas 26,625 26,646 27,100 0.1% 1.8%
Escondido 49,211 55,322 55,826 12.4% 13.4%
Oceanside 66,078 69,506 70,612 5.2% 6.9%
Poway 16,932 17,406 17,714 2.8% 4.6%
San Marcos 32,460 35,758 37,401 10.2% 15.2%
Vista 32,874 34,028 37,280 3.5% 13.4%
San Diego Region 1,226,879 1,348,802 1,434,653 9.9% 16.9% Source: California Department of Finance, 2020 Population and Housing Estimates & SANDAG Regionwide 2050 Forecast Series

13. Housing Type
Figure 4 shows that in 2020, the largest percentage (51%) of housing units in Escondido was single- family detached units. Approximately six percent were single-family attached units, 36% were multi-family developments, and eight percent were mobile homes/trailers.

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Figure 4: Housing Types (2020)

Table 26 shows that the proportion of both single-family units and mobile homes in Escondido is projected to decrease slightly, while the proportion of multi-family units is expected to increase. However, this figure may be misleading because SANDAG forecasts mobile homes by determining the region’s mobile home growth rate and applying it to each jurisdiction.

Table 26: Projected Housing Unit by Type (2020-2040)
Housing Type 2020 % of
Total
2030
(Projected)
% of
Total
2040
(Projected)
% of
Total
Single-Family 27,878 56.6% 28,474 51.5% 28,670 51.4%
Multi-Family 17,537 35.6% 23,109 41.8% 23,417 41.9%
Mobile Homes 3,796 7.7% 3,739 6.8% 3,739 6.7%
Total Housing 49,211 100.0% 55,322 100.0% 55,826 100.0% Source: California Department of Finance, 2020 Population and Housing Estimates; SANDAG Regionwide Forecast 2050, Series

13. 0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%
Single-
Family
Detached
Single-
Family
Attached
Multi-
Family
Mobile
Homes
Escondido 50.6% 6.1% 35.6% 7.7%
San Diego Region 50.8% 8.7% 36.8% 3.8%
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Housing Availability and Tenure
Housing tenure and vacancy rates are important indicators of the supply and cost of housing. Housing tenure refers to whether a unit is owned or rented. Tenure is an important market characteristic because it is directly related to housing types and turnover rates. The tenure distribution of a community’s housing stock can be an indicator of several aspects of the housing market, including the affordability of units, household stability and residential mobility among others. In most communities, tenure distribution generally correlates with household income, composition and age of the householder.

In 2010, among the City’s occupied housing units, approximately 52% were owner-occupied, while 48% were renter-occupied (Table 27) . According to the 2014- 2018 ACS, the home ownership rate in Escondido decreased slightly to 51% of the occupied units. Renter-occupied housing units made up almost 49% of the City’s occupied housing stock. Approximately four percent of total housing units were vacant.

Table 27: Tenure of Occupied Housing Units (2010-2018)
Tenure 2010 Census 2014-2018 ACS
Number Percent Number Percent
Owner Occupied 23,759 52.2% 23,426 50.6%
Renter Occupied 21,725 47.8% 22,912 49.4%
Total 45,484 100.0% 46,338 100.0%
Sources: Bureau of the Census, 2010 Census; American Community Survey, 2014-2018.

Renter-occupied households had a slightly higher average household size than owners (Table 28).

Approximately 54% of households with four or more persons were renter-households. In 2010, average renter-household size was 3.26 persons compared to 2.99 persons per for the average owner-household.

In 2018, average renter-household size increased to 3.28 persons compared to 3.15 persons for the average owner-household, narrowing the discrepancy in average household size based on tenure.

Table 28: Household Size by Tenure (2018)
1-3 Persons 4+ Persons Total
Number Percent Number Percent Number Percent
Owner 16,243 52.9% 7,183 46.0% 23,426 50.6%
Renter 14,472 47.1% 8,440 54.0% 22,912 49.4%
Total 30,715 100.0% 15,623 100.0% 46,338 100.0%
Source: American Community Survey, 2014-2018.

Vacancy rates are an important housing indicator because they indicate the degree of choice available.

High vacancy rates usually indicate low demand and/or high supply conditions in the housing market. Too high of a vacancy rate can be difficult for owners trying to sell or rent. Low vacancy rates usually indicate high demand and/or low supply conditions in the housing market. Too low of a vacancy rate can force prices up making it more difficult for low and moderate income households to find housing.

Vacancy rates between two to three percent are usually considered healthy for single-family housing; and five to six percent for multi-family housing. However, vacancy rates are not the sole indicator of market conditions. They must be viewed in the context of all the characteristics of the local and regional market.

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According to the 2014-2018 ACS, the overall vacancy rate in Escondido was four percent. Specifically, ownership housing had a vacancy rate of one percent while the rental vacancy rate was 3.5%.

Additional vacancy information was obtained for Spring 2019 from the San Diego County Apartment Association (“SDCAA”) and is shown in Table 29. Vacancy rates in Escondido were similar to those in the Northern San Diego County region.

Table 29: Vacancy Rates and Property Age (2019)
Jurisdiction Combined Property Ages Over 25 Years 6 to 25 Years Less than 6 Years %
Vacant
Total
Units
#
Vacant
%
Vacant
Total
Units
#
Vacant
%
Vacant
Total
Units
#
Vacant
%
Vacant
Total
Units
#
Vacant
Carlsbad 1.9% 526 10 1.9% 526 10 -- -- -- -- -- --
Del Mar 6.1% 246 15 7.4% 202 15 -- -- -- -- -- --
Encinitas 0.0% 10 0 0.0% 10 0 -- -- -- -- -- --
Escondido 3.9% 535 21 2.8% 250 7 5.0% 202 10 -- -- --
Oceanside 3.9% 487 19 3.2% 282 9 0.0% 4 0 -- -- --
Solana
Beach 1.1% 176 2 1.1% 176 2 -- -- -- -- -- --
N. County
Region 4.0% 3,730 148 3.5% 2,628 93 4.9% 206 10 0.0% 0 0 San Diego
City 4.0% 9,544 378 3.6% 4,374 157 3.4% 1,944 66 11.1% 1,002 111 SD Region 4.1% 23,000 936 -- -- -- -- -- -- -- -- --
Source: San Diego County Apartment Association Survey, Spring 2019.

Housing Age and Condition
Housing age can be an important indicator of housing condition within a community. Like any other tangible asset, housing is subject to gradual physical or technological deterioration over time. If not properly and regularly maintained, housing can deteriorate and discourage reinvestment, depress neighboring property values, and eventually impact the quality of life in a neighborhood. Many federal and state programs also use the age of housing as one factor in determining housing rehabilitation needs. Typically, housing over 30 years of age is more likely to have rehabilitation needs that may include new plumbing, roof repairs, foundation work and other repairs. Although the Censuses did not include statistics on housing condition based upon observations, they did include statistics that correlate very closely with substandard housing.

The three factors most commonly used to determine housing conditions are age of housing, overcrowding, and lack of plumbing and kitchen facilities. Table 30 shows that in 2018 approximately 88% of the housing stock was more than 20 years old and 76% was over 30 years old. Table 31 provides estimates of substandard housing conditions in the City.

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Table 30: Year Housing Built (2018)
Year Built Number Percent
2014 or later 243 0.5%
2010-2013 672 1.4%
2000-2009 4,741 9.8%
1990-1999 6,045 12.5%
1980-1989 13,327 27.6%
1970-1979 12,433 25.8%
1960-1969 6,206 12.9%
1950-1959 2,872 6.0%
1940-1949 646 1.3%
1939 or earlier 1,083 2.2%
Total 48,268 100.0%
Source: American Community Survey, 2014-2018.

Table 31: Substandard Units (2018)
Number Percentage
Lacking complete plumbing facilities 224 0.5%
Lacking complete kitchen facilities 387 0.8%
Total occupied substandard units 611 1.3%
Total occupied units: 46,338
Sources: American Community Survey, 2014-2018.

Housing that is not maintained can discourage reinvestment, depress neighboring property values, and can negatively impact the quality of life in a neighborhood. Improving housing is an important goal of the City. The age of the City’s housing stock indica tes a potential need for continued code complianc e, property maintenance and housing rehabilitation programs to stem housing deterioration.

Because substandard housing can cause serious health and safety issues, physical defects should not be used as the only indicator of substandard housing. The Housing Division considers housing units in compliance with local building codes to be standard units. Any housing unit that does not meet these requirements is considered substandard. Common housing code violations make a unit unsafe and/or unsanitary, including problems with electrical wiring, plumbing, windows, roofs and exterior, and heating and air conditioning systems. The City’s Housing Rehabilitation program assists an average of 22 households annually given funding limitations and receives 5-10 calls per month seeking assistance for rehabilitation. The City estimates that in any given year, about 300 units may be considered substandard and requiring rehabilitation. Escondido's substandard units are all suitable for rehabilitation.

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Housing Cost and Affordability
Housing costs are indicative of housing accessibility to all economic segments of the community.

Typically, if housing supply exceeds housing demand, housing costs will fall. If housing demand exceeds housing supply, housing costs will rise. This section summarizes the cost and affordability of the housing stock to Escondido residents.

Homeownership Market
Median home prices in the North County areas of San Diego ranged from $579,500 in Oceanside to $1,200,000 in Encinitas (Figure 5). Median home sale prices in Escondido increased 13% between 2019 and 2020 (Table 32). All neighboring communities and the County, other than Encinitas, saw similar increases in median home sale prices.

Figure 5: Median Home Price (2020)

Source: Corelogic.com California Home Sale Activity by City, August 2020.

$0
$200,000
$400,000
$600,000
$800,000
$1,000,000
$1,200,000
Carlsbad Encinitas Escondido Oceanside Poway San Marcos Vista SD County $898,000
$1,200,000
$610,000 $579,500
$850,000
$652,500
$590,000 $640,000
Table 32: Changes in Median Home Sale Prices (2020)
Jurisdiction 2020 Percent Change in Median
Sale Price 2019-2020 Number Sold Price
Carlsbad 237 $898,000 10.9%
Encinitas 79 $1,200,000 -7.3%
Escondido 230 $610,000 13.0%
Oceanside 275 $579,500 9.3%
Poway 53 $850,000 21.4%
San Marcos 162 $652,500 10.6%
Vista 144 $590,000 13.2%
San Diego Region 4,122 $640,000 9.4%
Source: Corelogic.com California Home Sale Activity by City, August 2020.

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Rental Market
The primary source of information on rental costs in the San Diego region is the San Diego County Apartment Association (“SDCAA”). SDCAA conducts two surveys of rental properties per year. For the Spring 2019 survey, 6,000 surveys were sent out to rental property owners and managers throughout San Diego County. Responses were received for 23,000 units. Although this survey sampled a broad variety of rental housing, it was not a scientific sampling. Table 33 shows that in the Spring of 2019, average monthly rents in Escondido ranged from $1,490 for a one-bedroom apartment to $2,273 for a three-bedroom apartment. Apartment rents tend to be slightly lower in Escondido than those in the County of San Diego.

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Table 33: Average Monthly Rent (2019)
Zip Code Unit Type
Spring 2019
Units/
Properties
Surveyed
Spring 2019
Monthly
Rent
Spring 2019
Rent/Sq.

Foot
Fall 2018
Monthly
Rent
Spring
2018
Monthly
Rent
Carlsbad
92008, 92009,
92010, 92011
Studio 11/3 $1,214 $3.26 $1,099 $1,081
1 BR 44/4 $1,724 $2.60 $1,457 $1,635
2 BR 457/6 $2,546 $2.53 $2,685 $2,448
3+ BR 14/2 $2,937 $2.36 -- $2,561
Encinitas
92023, 92024
Studio 0/0 -- -- -- $1,289
1 BR 4/1 $1,800 $3.27 $1,295 $1,581
2 BR 5/2 $2,100 $2.98 $2,145 $1,840
3+ BR 1/1 $1,350 $0.96 $2,150 $2,150
Escondido
92025, 90026, 90027,
90029, 90030, 90033,
90046
Studio 0/0 -- -- -- --
1 BR 168/4 $1,490 $2.17 $1,462 $1,138
2 BR 322/7 $1,901 $1.82 $1,728 $1,701
3+ BR 45/9 $2,273 $1.68 $1,784 $2,143
Oceanside
92049, 92050, 92051,
92052, 92054, 92056,
92057, 92058
Studio 43/4 $1,298 $3.02 $1,620 $1,123
1 BR 257/9 $1,420 $2.46 $1,503 $1,529
2 BR 184/11 $1,817 $2.03 $1,774 $1,844
3+ BR 3/3 $1,960 $1.38 $2,195 $1,995
Poway
92064
92074
Studio 0/0 -- -- -- --
1 BR 12/1 $1,695 $2.42 -- $1,000
2 BR 40/1 $1,885 $1.98 -- --
3+ BR 0/0 -- -- $2,350 --
San Marcos
92069
92073
92076-79
Studio 27/1 $1,905 $3.30 -- --
1 BR 39/1 $2,030 $2.93 $1,021 $1,387
2 BR 95/3 $2,089 $2.10 -- $1,586
3+ BR 40/2 $2,297 $2.06 $1,650 $1,500
Vista
92081
92083-85
Studio 140/3 $1,278 $2.65 $1,313 $1,247
1 BR 614/5 $1,580 $2.15 $1,636 $1,595
2 BR 679/8 $1,775 $1.89 $1,863 $1,799
3+ BR 57/4 $2,051 $1.74 $2,493 $1,881
County of San Diego
(including City of San
Diego)
Studio 659/56 $1,315 $3.03 -- --
1 BR 8265/221 $1,684 $2.48 -- --
2 BR 12143/301 $2,071 $2.04 -- --
3+ BR 1933/121 $2,526 $2.01 -- --
Source: San Diego County Apartment Association Survey, Spring 2019.

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Housing Affordability by Income Level
Housing affordability can be inferred by comparing the cost of renting or owning a home in the City with the maximum affordable housing costs for households at different income levels. Taken together, this information can generally show who can afford what size and type of housing and indicate the type of households most likely to experience overcrowding and overpayment.

Table 34 shows the maximum amount that a household can pay for housing each month without incurring a cost burden (over-payment). This amount can be compared to current housing asking prices (Table 32) and market rental rates (Table 33) to determine what types of housing opportunities a household can afford.

Extremely Low Income Households
Extremely low income households earn 30% or less of the County area median income – up to $24,300 for a one-person household and up to $34,650 for a five-person household in 2020. Extremely low income households cannot afford market-rate rental or ownership housing in Escondido without assuming a cost burden.

Very Low Income Households
Very low income households earn between 31% and 50% of the County area median income – up to $40,450 for a one-person household and up to $57,750 for a five-person household in 2020. Given the costs of ownership housing in Escondido, very low income households would not be able to afford a home in the City. Similarly, very low income renters could not afford appropriately-sized market-rate rental units in the City.

Low Income Households
Low income households earn between 51% and 80% of the County’s area median income - up to $64,700 for a one-person household and up to $92,400 for a five-person household in 2020. Based on the asking prices of homes for sale in 2020 (Table 32), ownership housing would not be affordable to low income households. As of Spring 2019, most low income households in Escondido would not be able to find adequately sized affordable apartment units (Table 33).

Moderate income Households
Moderate income households earn between 81% and 120% of the County’s Area Median Income – up to $111,250 depending on household size in 2020. Moderate income households in Escondido would have trouble purchasing adequately-sized homes. Appropriately-sized market-rate rental housing is generally affordable to households in this income group.

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Table 34: Affordable Housing Cost (2020)
Annual Income
Affordable
Housing
Cost
Utilities, Taxes, and
Insurance Affordable Price
Utilities Taxes/Insurance Sale Rent
Extremely Low Income (30% of Area Median Income)
1-Person $24,300 $608 $164 $213 $60,846 $444
3-Person $27,750 $694 $198 $243 $66,792 $496
4-Person $31,200 $780 $240 $273 $70,498 $541
5-Person $34,650 $866 $283 $303 $73,809 $583
Very Low Income (50% of Area Median Income)
1-Person $40,450 $1,011 $164 $354 $130,009 $847
3-Person $46,200 $1,155 $198 $404 $145,806 $958
4-Person $52,000 $1,300 $240 $455 $159,576 $1,061
5-Person $57,750 $1,444 $283 $505 $172,736 $1,161
Low Income (80% of Area Median Income)
1-Person $64,700 $1,618 $164 $566 $233,862 $1,454
3-Person $73,950 $1,849 $198 $647 $264,647 $1,651
4-Person $83,200 $2,080 $240 $728 $293,192 $1,841
5-Person $92,400 $2,310 $283 $809 $321,128 $2,027
Median Income (100% of Area Median Income)
1-Person $64,900 $1,623 $164 $568 $234,719 $1,459
3-Person $74,150 $1,854 $198 $649 $265,504 $1,656
4-Person $83,450 $2,086 $240 $730 $294,263 $1,847
5-Person $92,700 $2,318 $283 $811 $322,413 $2,035
Moderate Income (120% of Area Median Income)
1-Person $77,900 $1,948 $164 $682 $290,392 $1,784
3-Person $89,000 $2,225 $198 $779 $329,100 $2,028
4-Person $100,150 $2,504 $240 $876 $365,782 $2,264
5-Person $111,250 $2,751 $283 $973 $401,855 $2,498
Source: CA Dept. of Housing and Community Development (2020) and Veronica Tam & Associates Assumptions: 2020 HCD income limits; 30% gross household income as affordable housing cost; 35% of monthly affordable cost for taxes and insurance; 10% down payment; and 3% interest rate for a 30-year fixed-rate mortgage loan. Utilities based on San Diego County Utility Allowance
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3. Affordable Housing
State law requires that the City identify, analyze, and propose programs to preserve existing multi-family rental units that are eligible to convert to non-low-income housing uses due to termination of subsidy contract, mortgage prepayment, or expiring use restrictions during the next ten years. Thus, this at-risk housing analysis covers the period from June 30, 2020 through April 15, 2029. Consistent with State law, this section identifies publicly assisted housing units in Escondido, analyzes their potential to convert to market rate housing uses, and analyzes the cost to preserve or replace those units.

Publicly Assisted Housing
The City of Escondido has a large inventory of publicly assisted rental housing affordable to lower and moderate income households. Table 35 provides a summary listing of affordable projects in the City.

Overall, 25 projects (totaling 1,659 rental housing units) include affordable units. Specifically, 1,642 units are set aside as housing for lower and moderate income households.

Table 35: Inventory of Assisted Rental Housing Projects Name of Project Total Units Assisted
Units
Funding
Source Type2 Earliest
Conversion
15th Avenue Cooperative
1500 Orange Place 32 32 T, H Family 2037
Aster Street
518-524/526-532 Aster Street 8 8 R, H Family 2034
Aster Street
557-563 Aster Street 4 4 H Family 2072
Avocado Court
215 E El Norte Parkway 36 35 R, H, T Family 2067
Cobblestone Village Apartments
360 E Washington Avenue 44 43 R, T, C Family 2055
Daybreak Grove
1256 E Washington Avenue 13 13 R, T Family 2054
Emerald Garden Townhomes
425 W 11th Avenue 16 16 R, H, T Family 2053
Escondido Garden Apartments
500 N Midway Drive 92 91 T Seniors 10/31/2038
Eucalyptus View Coop
1805 S. Escondido Blvd 24 24 H, T Family 2041
Juniper Senior Village
215 E Washington Avenue 61 60 R, T, H, C Seniors 2076
Las Ventanas
1404 S Escondido Boulevard 80 80 R, T Family 2063
Manzanita
260 N Midway Drive 200 198 H, T Family 2070
Orange Place Apartments
1611 S Orange Place 15 15 R, H, T Family 2068
Silvercrest Residence
1303 Las Villas Way 75 74 HUD 202 Rental 4/30/2022
Solutions Escondido 33 32 R, T Family 2070
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Table 35: Inventory of Assisted Rental Housing Projects Name of Project Total Units Assisted
Units
Funding
Source Type2 Earliest
Conversion
1560 E Escondido Boulevard
Sonoma Court
508 E Mission Avenue 61 60 R, H, T Family 2054
Summit Rose Apartments
460 E Washington Avenue 91 89 T Family 2070
Sunrise Place
1245 E Grand Avenue 8 8 R, T Family 2054
The Crossings @ Escondido
735 Mission Grove Place 55 54 R, T Family 2065
The Crossings @ Escondido Manor
1150-1166 N Escondido Boulevard 44 43 R, H, T Family 2070 The Terraces
1301 Morning Dew View Drive 190 190 R, T Family 2051
Veterans Villas
1538-1540 S Escondido Blvd 54 53 R Veteran 2075
Via Roble
1553 S Escondido Boulevard 72 71 R, T, C Family 2068
Villa Escondido
511 E Grand Avenue 112 112 T Senior 2041
Village Grove Apartments
600 N Quince Street 161 160 T Family 2054
Windsor Gardens
1600 W Ninth Avenue 132 130 R, T Seniors 2074
R = Redevelopment Funds; H = HOME; C = CDBG; T = Low Income Housing Tax Credit Source: City of Escondido.

Preservation of At-Risk Housing
Within the 2021-2031 “at-risk” housing analysis period, only Silvercrest is at low risk of converting to market rate housing. Though Silvercrest’s earliest date of conversion is in 2022, the City considers the risk of conversion low because the project is being managed by a non-profit organization (The Salvation Army), which has the mission to provide permanent affordable housing. Furthermore, HUD has established priority for the renewal of project-based Section 8 assistance for housing for seniors and persons with disabilities.

Preservation and Replacement Options
To maintain the existing affordable housing stock, the City works to preserve the existing assisted units or facilitate the development of new units. Depending on the circumstances of the at-risk projects, different options may be used to preserve or replace the units. Preservation options typically include: 1) transfer of units to non-profit ownership; 2) provision of rental assistance to tenants using other funding sources; and 3) purchase of affordability covenants. In terms of replacement, the most direct option is the development of new assisted multi-family housing units.

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Transfer of Ownership
Transferring ownership of an at-risk project to a non-profit housing provider is generally one of the least costly ways to ensure that the at-risk units remain affordable for the long term. By transferring property ownership to a non-profit organization, low income restrictions can be secured and the project would become potentially eligible for a greater range of governmental assistance. However, Silvercrest is already a nonprofit-owned project; therefore, this option is not necessary. Specifically, because Silvercrest is a nonprofit senior housing project, it is at low risk of converting to market-rate housing.

Rental Assistance
Tenant-based rent subsidies could be used to preserve the affordability of housing. Similar to Section 8 vouchers, the City, through a variety of potential funding sources, could provide rent subsidies to tenants of at-risk units. The level of the subsidy required to preserve the at-risk units is estimated to equal the Fair Market Rent (“FMR”) for a unit minus the housing cost affordable by a lower income household.

The 2021 FMR for a one-bedroom unit in Escondido is $1,540. As shown in Table 34, a very low income one-person household can generally afford about $850 in rent, leaving an affordability gap of about $690 ($51,060 month for the 74 units or $612,720 annually).

Purchase of Affordability Covenants
Another option to preserve the affordability of the at-risk project is to provide an incentive package to the owner to maintain the project as affordable housing. Incentives could include writing down the interest rate on the remaining loan balance, providing a lump-sum payment, and/or supplementing the rents to market levels. The feasibility and cost of this option depends on whether the complex is too highly leveraged and interest on the owner’s part to utilize the incentives found in this option.

Construction of Replacement Units
The construction of new low income housing units is a means of replacing the at-risk units should they be converted to market-rate units. The cost of developing housing depends upon a variety of factors, including density, size of the units (i.e., square footage and number of bedrooms), location, land costs, and type of construction. With an estimated construction/land cost of $350,000 per unit, the 75-unit Silvercrest would cost $26.3 million to replace.

Resources for Preservation
Owners of government-assisted developments cannot terminate subsidy contracts, prepay a federally assisted mortgage, or discontinue use restrictions without first providing an exclusive "notice of opportunity to submit an offer to purchase" to potential purchasers using HCD’s list of Qualified entities.

The List of current Qualified Entities is maintained and updated by HCD and is subject to change – (https://www.hcd.ca.gov/policy-research/preserving-existing-affordable-housing.shtml ). Current
entities on the list include:
• Innovative Housing Opportunities
• Nexus for Affordable Housing
• TELACU
• San Diego County Department of Housing and Community Development Services • Housing Development Partners of San Diego

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4. Housing Constraints
Constraints to the provision of housing affect the development of new housing and the maintenance of existing units for all income levels. Governmental and non-governmental constraints in Escondido are similar to those in other jurisdictions in the region and are discussed below. One of the most, if not the most, significant and difficult constraints to housing in Escondido and elsewhere in the San Diego region is the high cost of land. This section describes various market, governmental, and environmental constraints on the development of housing that meets the needs of all economic segments of Escondido population.

Market Influences
Market constraints significantly affect the cost of housing in Escondido and can pose barriers to housing production and affordability. These constraints include the availability and cost of land for residential development, the demand for housing, financing and lending, construction costs, development fees, and neighborhood opposition which can make it expensive for developers to build affordable housing. The following highlights the primary market factors that affect the production of housing in Escondido.

Land and Construction Costs
Raw land and improvements costs comprise approximately 40% of the total development costs of a residential dwelling. Land prices in Escondido have risen significantly in recent years. However, land costs in Escondido are generally less when compared to land costs in many other areas of San Diego County. Furthermore, raw land values must be considered in relation to costs rising from the provision of adequate facilities and services, and the City's efforts to encourage redevelopment and rehabilitation will help lower costs where facilities and services are already provided.

The lack of vacant land for residential construction, especially land available for higher density residential development, has served to keep the cost of land high. Based on listings at Zillow.com, land near the downtown areas ranges from $335,000 per acre to up to $ 1.8 million per acre. 5 Land
outside of the urban core ranged from $80,0000 to $155,000 per acre (and larger lots were available ranging from 1.5 to 5 acres).

Basic construction costs for residential developments have rapidly increased, and together with land prices, have increased the cost of housing, making homeownership unattainable for many households. These costs are relatively constant over the region. The basic components of labor and material do not fluctuate much by area. Site preparation costs can be substantial, but the variations are more a function of the site, than of the jurisdiction. The Freeman Construction Inc. Custom Home Building Home Guide in San Diego County estimates that site costs can range from $75,000 to $150,000

6. One indicator of construction costs is Building Valuation Data compiled by the International Code Council (ICC). The unit costs compiled by the ICC include structural, electr ical, plumbing, and mechanical work, in addition to interior finish and normal site preparation. The data are national and do not take into account regional differences, nor include the price of the land upon which the building 5 Land size available at urban/downtown center at time of survey was less than one acre. 6 https://tfgonline.com/wp-content/uploads/2020/09/custom-home-building-cost-guide-in-san-diego-county-by-freemans-construction- inc.pdf
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is built. In 2020, according to the latest Building Valuation Data release, the national average for development costs per square foot for apartments and single-family homes in 2020 are as follows:
• Type I or II, R-2 Residential Multifamily: $148.82 to $168.94 per sq. ft. • Type V Wood Frame, R-2 Residential Multifamily: $113.38 to $118.57 per sq. ft. • Type V Wood Frame, R-3 Residential One and Two Family Dwelling: $123.68 to $131.34 per sq. ft.
• R-4 Residential Care/Assisted Living Facilities generally range between $143.75 to $199.81 per sq. ft.

Local estimates from the ProMatcher 2018 Cost Report estimated building costs in 2018 as ranging from $128.71 - $191.11 per square foot in Escondido.7
The City has no influence over materials and labor costs, and the building codes in Escondido are not substantially different than most other cities in San Diego County. In recent years, construction costs for materials and labor have increased at a slightly higher pace than the general rate of inflation according to the Construction Industry Research Board.

Availability of Financing
The availability of financing affects a person’s ability to purchase or improve a home. Under the Home Mortgage Disclosure Act (“HMDA”), lending institutions must disclose information on the disposition of loan applications by the income, gender, and race of the applicants involving home purchases, improvements and refinancing, whether financed at market rate or with government assistance.

The disposition of loan applications submitted to financial institutions in 2017 for home purchase, refinance, and home improvement loans in Escondido is summarized in Table 36. Included is information on loan applications that were approved and originated, approved but not accepted by the applicant, denied, and withdrawn by the applicant or incomplete. Overall, home purchase financing is available but home improvement financing is more limited.

Table 36: Disposition of Home Loans (2017)
Loan Type Total
Applicants Originated Approved Not
Accepted Denied Withdrawn/
Other
Conventional - Purchase 2,335 67.1% 4.1% 9.8% 19.0%
Government-Backed - Purchase 1,131 71.4% 3.8% 9.7% 15.1% Home Improvement 545 52.3% 2.8% 27.0% 18.0%
Refinance 4,414 52.5% 2.6% 18.3% 26.6%
Total 8,426 59.0% 3.2% 15.3% 22.4%
Source: Lendingpattern.com
“Percent Other” includes withdrawn or incomplete applications Impacts of COVID-19
With the outbreak of the COVID-19 pandemic, over 26 million unemployment insurance claims were filed between March 15 and April 18 at the start of stay -at-home orders as reported by the US 7 Price range takes into account building a new home labor. Does include permitting, pouring the foundation, standard building materials, basic finishes, and cleanup. Cost does not include purchasing the land, blueprints, premium upgrades (granite countertops, spray foam insulation, etc.), modular homes, deep foundations, and deck construction. Reported by: ProMatcher Research Team. https://home- builders.promatcher.com/cost/san-diego-ca-home-builders-costs-prices.aspx Attachment "5"
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Department of Labor. In response Congress passed major relief bills including the $2 trillion CARES Act, which includes benefits and expanded eligibility for unemployment insurance, forgivable small - business loans, economic relief payments sent directly to most US households, aid to state and local governments, and increased funding for housing assistance and other safety net programs.

The Census Bureau along with other governmental agencies partnered to design the Household Pulse Survey to publish data in as close to real time as possible during the COVID-19 pandemic. The survey provides vital insights on how American households are affected and coping during the pandemic. The Census Bureau expects to collect data for 90 days and release data weekly. One such way the Census Bureau is measuring household experiences during the coronavirus pandemic is through the Household Pulse Survey. Household Pulse Survey results have been reported for State and Metropolitan Area geographies but data for the San Diego Metropolitan Area only has not been reported. Results for the Week 23 Survey (Week of January 20 to February 1, 2021) showed that

56.3% (16.8 million) of adults in California reported that they or someone in their household had experienced a loss of employment income since March 13, 2020. About 10.3 million adult respondents (34.7%) also expected themselves or someone in their household to lose employment income in the next 4 weeks.

In the San Diego region, multiple reports have been completed by the SANDAG to show the impacts of COVID-19. On October 15, 2020 SANDAG published the “COVID-19 Impacts on The San Diego Regional Economy” report showing a six -month economic analysis since the Stay at Home Order.

According to this report, an estimated 176,000 workers were unemployed due to COVID -19 in the San Diego region with lower income workers more likely to be out of work compared to middle and high income workers. Pre-COVID, the region had just over 50,000 unemployed workers. The report also identified the Tourism, Retail, and Education sectors as disproportionally affected by COVID-19.

These sectors lost an estimated 141,000 workers, representing 80% of those unemployed due to COVID-19 in the region. Females in the Education sector and Hispanic workers were also found to be more likely to lose their jobs in the Tourism sector during this period.

SANDAG also reported on June 16, 2020 that Black and Hispanic communities had been disproportionally impacted by COVID -19 throughout the County. These minorities account for a significant portion of essential workers who continued to go to work, and those who became unemployed in Tourism and “non-essential” Retail sectors due to the pandemic. Black and Hispanic populations were four times as likely to live in areas that had been impacted by COVID -19 and unemployment than White population and twice as likely when compared to the Asian population.

Overall, the southern part of the County is also most affected by both the highest unemployment rates and highest percentage of COVID-19 cases in the region. Before the pandemic, areas in the southern region now most affected by the pandemic also reported household income of less than $45,000 and a large share of families with children. The report classified ZIP codes with high unemployment rates and high percentages of COVID-19 cases as “hardest hit” areas.

As of June 1, 2020, Escondido was identified among the hardest hit ZIP codes . Of the ZIP codes reported, South Escondido ranked 16
th in unemployment level and 24th in COVID-19 cases and East Escondido ranked 25th in unemployment level and 39th in COVID-19 cases. As of July 25, 2020 (the most recent data), Escondido remained among the hardest hit zip codes.

Timing and Density
Non-governmental market constraints can also include timing between project approval and requests for building permits. In most cases, this may be due to developers’ inability to secure financing for Attachment "5"
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construction. In Escondido, the average time between project approval /entitlement and request for building permit is typically two to six months.

Requests to develop below the maximum or target densities may also be indicators of non- governmental constraints. The Fifth Cycle Housing Element assumed that H ousing Element sites would develop at approximately 75% of the maximum allowed in the Downtown Specific Plan Area and 70% in all other sites. A review of residential and mixed-use projects proposed, approved, and constructed over the Fifth Cycle Housing Element found that projects averaged 80% maximum density in the Downtown Area (SP 9) and all other zonings averaged 90%, which is higher than as assumed in the Fifth Cycle sites inventory (Table 37).

Table 37: Project Development Yield Trends by Zoning
Zoning Max Density Allowed Average Yield % of Max
RE-30 1.5 102%
PD-R-1.9 1.9 99%
RE-20 2.2 82%
R-1-10 4.3 67%
R-1-7 6.2 66%
R-1-6 7.3 66%
R-1-X 7.3 40%
R-2-12 12 111%
R-3-18 18 140%
U-3 (GPA) - Was RE-20 18 98%
S-P 24-30 123%
SP-9 (Downtown) 75-100 80%
Average Yield % of all Projects 88%
In the Sixth Cycle Housing Element, the realistic capacity assumptions were adjusted to show the proposed East Valley Specific Plan Land Use target production points (Table 38). While there have been no residential projects under the E VSP yet, it is expected that projects will reach at least the target production point density to avoid paying fees. For areas outside of the EVSP, the realized densities averaged 88% of the maximum allowable density (see Table 37 above) and averaged 90% in lower density zones and 80% in higher density zones ( Table 37 and Table 38). While recent production trends indicate that site capacity could reasonably be estimated at 88% of the maximum density allowed by zoning, some developments will likely be built at lower densities , so conservative assumptions were used. Additional discussion of development trends can be found under the Housing Resources Section (Development Trends, Yields, and Realistic Capacity for Housing).

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Table 38: Assumed Realistic Capacities by Density range Density Range Assumed Realistic Density (% of Max) Average Realized Density (Fifth Cycle) EVSP
21-30 (Urban IV/V) 83%1 N/A
20-80 (Mixed-use) 56%2 N/A
Non-EVSP
0-45 75% 90%3
46-100 62.5%50% 80%4
1 Based on 25 du/ac target production point (i.e. with a TPP of 25 du/ac, developments achieve at least 83% max density allowed) 2 Based on 45 du/ac target production point
3 Based on average of past projects with density range 0-30 (see Table 37) 4 Based on average of past projects with density range 75-100 (see Table 37) Governmental Constraints
Aside from market factors, housing affordability is also affected by factors in the public sector. Local policies and regulations can impact the price and availability of housing and, the provision of affordable housing. Land use controls, site improvement requirements, fees and exactions, permit processing procedures, among other issues may constrain the maintenance, development and improvement of housing. This section discusses potential governmental constraints in Escondido and efforts to address them.

Land Use Controls
The Land Use Element sets forth City policies for guiding local land use development. These policies, together with existing zoning regulations, establish the amount and distribution of land allocated for different uses. The City completed a comprehensive update to its General Plan in 2012. The General Plan update was focused around smart growth opportunities – adding new residential and employment capacity in areas well served by infrastructure and transit. The update also examined different land use policies and opportunities for growth, added a new high-density residential category, and removed development constraints. Most future residential growth will continue to be focused in the Downtown Specific Plan and south Centre City Parkway Specific Plan areas. The General Plan also calls for the update of the East Valley Specific Plan (“EVSP”) for the area immediately adjacent to the downtown. In mid-2020, the City initiated the preparation of the EVSP, which is anticipated to complete in winter 2021/2022Spring 2022 and provide approximately 6,000 units that were not previously allocated in the General Plan.

Residential Land Use Designations
The land use policies of the City have a direct impact upon the provision of housing for all economic sectors of the community. The General Plan designates substantial areas of land for residential development, and the Zoning code permits a wide variety of residential uses, ranging from multi - family housing to large estates. Table 39 lists the residential land use designations in the General Plan. Higher-density multi-family designations were assigned minimum densities during the General Plan update.

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Table 39: Land Use Designations Permitting Residential Use Land Use
Category
Zoning
District
Max. Density
(du/acre) Character
Rural I R-A 1 unit/4, 8, 20
acres
To promote a rural living environment in areas of agricultural production, rugged terrain, and environmentally constrained lands that are remote from urban development.

Rural II R-A 1 unit/2, 4, 20
acres
To promote a rural livin g environment in areas of agricultural production or rugged terrain that is relatively remote from urban development.

Estate I R-E 1 unit/1, 2, 4, 20
acre
To promote a large lot, single -family development in areas bordering Rural lands. This classification is typified by development along Mary Lane, North Broadway and around Felicita Park.

Estate II R-E Up to 2.0
To promote single-family urban development on relatively large lots. This classification typified by development at Lomas Serenas, Rancho Verde, and along Citrus Avenue around San Pasqual Valley Road.

Suburban R-1 Up to 3.3
This residential classification is characterized by single -family homes.

The density is appropriate where the traditional neighborhood character of detached sing le-family units prevails. This classification is typified by development at Summercreek and areas southeast of Bear Valley Parkway along Citrus Avenue and along the south side of Avenida del Diablo.

Urban I R-1 Up to 5.5
Detached single -family homes, characteristic of much of Escondido, constitute this medium density category. Typical R- 1 development is found along Country Club Lane and between Ash and Citrus north of Washington.

Urban II R-2 Up to 12
This residential classification allows living accommodations, ranging from conventional single-family units to mobile homes. Development at this level of intensity normally would be semidetached or attached units, and include duplexes, triplexes, and fourplexes. Typical Urban II development is found on North Broadway between Lincoln and Sheridan Avenues, and Citrus Avenue between Valley Parkway and the Flood Control Channel.

Urban III R-3 Up to 18
This residential category is typified by low -rise townhouses and apartment buildings. Typical projects at this density can be found near Centre City Parkway at El Norte, east Grand Avenue, and near Washington and Fig.

Urban IV R-4 Up to 24
This residential category is predominantly characterized by apartment buildings about three stories in height. Representative development at this density is found south of 9th Avenue west of I15.

Urban V R-5 Up to 30 This residential category is characterized by high -density, multi -family developments.

Source: Land Use Element, City of Escondido General Plan Attachment "5"
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Specific Plans
The City of Escondido has adopted a number of specific plans, which offer a range of housing types, densities, and mix of uses. The City anticipates that much of its new residential growth will occur in the following areas:
• Downtown Specific Plan (Revised February 10, 2021)
• South Centre City Area Plan (April 4, 2018)
• East Valley Specific Plan (Revised September 22, 2004, and 2021)

Downtown Area Specific Plan
The Downtown Specific Plan area encompasses approximately 460 acres extending from I-15 and West Valley Parkway to Palomar Hospital, between Washington and Fifth Avenues. The Specific Plan Area includes the City’s urban core along Grand Avenue where Escondido was incorporated in 1888.

The Downtown Specific Plan provides a comprehensive plan for land use, development regulations, development incentives, design guidelines and other related actions aimed at implementing the following strategic goals for Downtown Escondido:
• An economically viable Downtown with an appropriate mix of retail, office, residential, entertainment and cultural uses.
• A local and regional destination for specialty shopping, dining, nightlife, employment, culture, and the arts.
• A vibrant and exciting environment with land uses that foster an “18-hour” atmosphere, in addition to areas that provide mixed-use, office employment and high-density residential opportunities.
• Development and signage that strengthen the character of Downtown and are architecturally compatible with the existing urban fabric.
• Street-level and hum an-scale design elements in new and remodeled developments that improve pedestrian orientation.
• Preserved historically significant sites and structures that enhance the character of Downtown.
• Pedestrian-oriented, ground-floor, specialty retail and restaurant uses on Grand Avenue that reinforce and expand its unique character.
• Higher residential densities in key locations that support Downtown non-residential uses. A pedestrian environment that provides connections, convenient access and opportunities for alternative modes of transportation.
• Embellished landscaping, public art, comfortable street furniture and décor that improves walkability and pedestrian connections.
• Maximized parking opportunities.

The Downtown Specific Plan includes seven distinct land use districts that allow for residential development or mixed-use development with substantial residential components:
• Historic Downtown District (HD)
• Park View District (PV)
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• Centre City Urban District (CCU)
• Gateway Transit District (GT)
• Mercado District (M)
• Southern Gateway District (SG)
• Creekside Neighborhood District (CN)
Figure 6: Downtown Escondido Specific Plan – Residential Densities

Residential development above 45 units per acre can be accommodated in most of the Downtown Specific Plan area, with a substantial area allowing up to 75 units per acre and 100 units per acre.

There are some areas where residential is not allowed and others where a ground-floor commercial or office component is required.

In 2019, the City adopted a “Downtown Density Transfer Program,” which allows for the transfer of residential density from underutilized properties to properties that are being redeveloped. This program allows property owners to re-assign or transfer units to other properties via a city - administered density credit pool. The City holds the density credits until a redeveloping property acquires the density. In effect, the density transfer program prevents the loss of potential units when a property is redeveloped in support of achieving a full-build out in the Downtown area. Two entitled projects are utilizing the density transfer program. The project (ADM 20-0085) noted in Table A-3 is also contemplating the use of this program. There have also been requests to expand this program to other parts of the City.

The Downtown Specific Plan also establishes development standards that differ from the rest of the City. Table 40 summarizes the standards specific to the City’s downtown area.

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Table 40: Downtown Specific Plan Residential Development Standards District
Maximum
Building
Height (ft.)
Setbacks (ft.)
Min. Lot
Size
Max.

Building
Coverage
Allows
Mixed-
use? Front Side
Street
Side
Yard
Rear
Yard
HD 45-120

0 0
0 None None Y
PV 35-85 10
0 CCU 75 10 5
GT 60-75 0
0 M 60-75 0
SG 35-75 0
CN 75 10 5 10

South Centre City Specific Plan
The South Centre City Specific Plan was adopted in 2018 to implement policy direction from the 2012 General Plan update that focused on implementing smart growth goals into four target growth areas.

The plan contains eight districts, each with different development regulations and standards.

For residential land use, the plan seeks to maximize affordable housing opportunities and provide opportunities for a balanced mix of housing types through a variety of incentives and programs. The Plan provides for a Mixed-Use (MU) designation that permits the integration of residential, commercial, and professional office uses in a single project.

The plan allows for high-density residential of up to 24 units per acre in the 9th Avenue Overlay, and up to 30 dwelling units per acre in the Escondido Boulevard Mixed- Use Overlay and the Southern Entry Mixed-Use Overlay zones.

East Valley Specific Plan
The East Valley Specific Plan (“EVSP”) covers areas along East Valley Parkway. The existing land use pattern reflects prior decisions and uses along East Valley Boulevard are almost exclusively commercial in nature; there is no existing housing within the commercial area. The 2012 General Plan Update calls for the amendment of the area plan to re-assess the land use plan, in particular to introduce high-density housing to the area. The EVSP is expected to be adopted concurrent with the Housing Element. Table 41 provides a summary of the land use designations in the proposed EVSP.

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Table 41: East Valley Specific Plan Land Use Designations Land Use Applicable
Zoning Description
Min.

Density/
FAR
Max.

Density/
FAR
Target
Production
Point
Appr. Yield
Urban IV/V R-5-30
Assumes 24 du/ac. Multi-family residential
units, townhomes, apartments, flats, and
condominiums. 15,000 sf/ac retail and
office uses are permitted
21 du/ac 30 du/ac 25 du/ac
1,495 units
453,789 sf of
commercial
General
Commercial C-G
Local-serving commercial, automobile
service, eating/drinking establishments,
entertainment facilities, retail, office,
service establishments, etc. Intended for
other commercial uses not suitable for
residential zones.

0.25 FAR 1.0 FAR 0.5 FAR
0 units
59,014 sf of
commercial
Mixed-Use M-U
Vertical or horizontal mixed-use. Multi-
family residential units, appropriate along
major thoroughfares, proximate to
shopping centers, entertainment,
community facilities and employment
opportunities.
20 du/ac

1.5 FAR
80 du/ac

3.0 FAR 45 du/ac
4,669 units
703,338 sf of
commercial
Park Overlay
Zone POZ
Active and passive parks as well as land to
protect, maintain, and enhance the
community’s natural resources and include
detention basins and creek corridors.

Development Impact Fees contribute to
park space in these areas.
--- --- ---
10 acres
minimum of
parkland and
open space
Growth Management Controls
The City has two growth management measures that impact the pace and capacity of residential growth:
• Ordinance 94-16
• Proposition S
Ordinance 94-16
This ordinance is a Citywide Facilities Management Plan that came into effect on May 18, 1994 and replaced all prior growth management ordinances. While facilities are generally available citywide, the North Broadway Region of Influence has had critical infrastructure deficiencies with respect to drainage and water storage capacity. The region is located in the northeast part of Escondido. Should adequate facilities not be available within the region, the ordinance allows development of projects subject to the approval of a development agreement. The agreement must ensure that the project either provides facilities necessary to upgrade existing deficiencies or financially participates toward their solution.

The North Broadway Deficiency Area is identified by the Citywide Facilities Plan as having critical infrastructure deficiencies. New land use development projects need to either provide facilities necessary to upgrade the deficiencies or cumulatively (i.e. financially) participate towards their solution. Ordinance 94- 16 helps new land use development projects address off-site cumulative CEQA issues as part of the entitlement process, which helps expedite CEQA review and streamline housing projects. The developer contribution of a $12,500 per unit helps new projects participate in the costs of drainage and water storage requirements. Over the decade or so, there have been three Attachment "5"
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large projects that have been constructed within this area, including 179 homes in Hidden Valley Ranch, 70 in Pradera, and 40 in Zenner (189 total homes). This demonstrates that the Ordinance 94- 16 fee is not a constraint to housing development.

A subsequent ordinance (95-11) also allows development of a single-family residence on an existing vacant lot of record, zoned for residential use, where the lot was created prior to June 6, 1990, within the Region of Influence. A supplemental deposit is required at the time of Building Permit issuance to ensure facility impacts are addressed.

Proposition S
Proposition S was adopted by voters 1998 and requires voter approval of specified future changes to the Escondido General Plan. General Plan changes, subject to Proposition S, include increasing residential densities, changing or increasing the residential land use categories, or changing any residential designation to a commercial or industrial designation on any property designated as Rural, Estate, Suburban, or Urban. Thus, voter approval is required for amendments that would increase residential densities, but also deters the loss of residential land when associated with an amendment to commercial or industrial. Furthermore, Proposition S states, “Nothing in this initiative shall be constructed to:
• Interfere with rights to obtain density bonuses or other entitlements available under affordable housing laws, or Proposition S
• Limit right or entitlements available under affordable housing laws.” Prop S applies to the intensification of land uses in residential areas of the City. Specifically, under Policy E 2.3: “Permitted land uses in the residential areas of the City shall be intensified only when the voters approve such changes.”
The intent of Prop S is to focus on current residential zones, rather than rezones from nonresidential to residential. A rezone from a non -residential zone to a residential zone does not trigger Prop S.

Therefore, Prop S does not act as a cap on the number of housing units constructed or permits that can be approved either annually or for some other time period. It also does not limit the population of the City.

The City may amend the existing EVSP without a vote of the public and can therefore accommodate additional units within the East Valley Area for the 2021-2029 RHNA planning period. Outside of the East Valley Area, this Housing Element examines the residential development capacity under the existing General Plan, zoning, and specific plans, and has demonstrated adequate capacity to accommodate the City’s RHNA for the sixth cycle Housing Element planning period.

The City recognizes that Proposition S may serve to constrain housing development in the long term, beyond 2028. Therefore, the City initiated a comprehensive General Plan update in 2008 to address land use distribution, preservation of neighborhoods, and identification of appropriate growth centers within the community. The updated General Plan was approved by the City Council on May 23, 2012.

Portions of the updated General Plan were placed on the November 2012 ballot and approved by Escondido residents.

The General Plan update preserved most existing land use policies in much of the City’s residential neighborhoods, but did provide opportunities for employment and residential intensification. The maximum allowed density of a mixed-use development along South Escondido Boulevard was increased from 24 to 30 units per acre, which resulted in increased capacity in the City.

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The approval of the General Plan update by the voters increased the City’s capacity for residential growth over the long term. Recognizing Proposition S as a potential constraint, the Housing Element includes a program to monitor the impact of this growth management measure.

Overlay Zones and Other Districts
Mixed-use Overlay Zone
As part of the 2012 General Plan update, new areas for mixed-use development were designated in areas with high potential for commercial and residential development.

Flood Plain Overlay Zone
The Flood Plain (FP) overlay zone establishes land use regulations in areas with properties situated within designated flood plains of rivers, creeks, streams and water courses in order to protect the public health, safety and welfare and to minimize losses to property and life due to flooding and periodic inundation. The City restricts or prohibits uses in this zone which are dangerous to health, safety or property in times of flood or cause excessive increases in flood heights or velocities. The City also requires uses vulnerable to floods to be protected against flood damage at the time of initial construction.

Planned Development (P-D) Zone
The purpose of the Planned Development (P-D) zone is to provide a more flexible regulatory procedure by which the basic public purposes of the Escondido general plan and the Escondido zoning code may be accomplished. The P-D zone serves to encourage creative approaches to the use of land through variation in the siting of buildings and the appropriate mixing of several land uses, activities and dwelling types.

For planned developments in which residential uses are proposed on parcels of land in the R-3, R-4, and R-5 zones, area plans, and in specific plan areas with a maximum specified multifamily residential density, no planned development will be approved at a density below 70% of the maximum permitted density of the underlying multifamily zone, area plan or specific plan multi-family designation. Residential planned developments in this zone are also encouraged to depart from standard subdivision and housing design by providing a variety of lot sizes and housing types, provided that the overall residential density yield conforms with the City’s policies.

Old Escondido Neighborhood Historic District
The boundaries of this District are Fifth Avenue on the north, Chestnut Street on the east, Thirteenth Avenue on the south and South Escondido Boulevard on the west (excluding properties fronting on Escondido Boulevard) and including north side of Fifth Avenue from Juniper to Date. The purpose and intent of the Old Escondido Neighborhood historic district is to preserve the single -family residential character of the neighborhood and the historic/cultural resources of the neighborhood as well as emphasize orientation towards pedestrian activities. The historic nature of this district precludes the properties on it for higher density residential re-use.

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Density Bonus and Residential Incentive Ordinance
Government Code section 65915 et. seq. requires an agency to provide developers with a density bonus and other incentives or concessions for the production of lower income housing units or for the donation of land within the development if the developer agrees to construct a specified percentage of units for very low, low, and/or moderate income households or qualifying residents. Density bonus is a California state requirement and as such not subject to the discretion of local governance bodies – land use development requests that meet the law's requirements are entitled to the Density Bonus, as of right.

The City adopted its Density Bonus and Residential Incentive Ordinance in the 1990s. In 2018, the California Legislature approved four bills that expanded the density bonus to a wider range of housing projects and strengthened procedures to make the density bonus more workable for developers. The current ordinance (Chapter 33, Article 67) , last updated May 2020, allows a minimum density bonus and deviations from the Zoning Code for affordable or senior housing in accordance with the State Density Bonus Law (California Government Code Sections 65915 – 65918) and reflects the State Legislature’s commitment to incentivizing housing development in California.

Since parking and setbacks can be reduced, a developer could feasibly increase the number of units or bedrooms without increasing the size of the site. The City’s Density Bonus and Residential Incentive Ordinance is useful in the acquisition and rehabilitation of developments made affordable to low income residents in the higher multi-family zones. For example, the ordinance was utilized to increase the number of bedrooms in the acquisition and rehabilitation of the 15th Avenue Cooperative and Sonoma Court, affordable housing projects. Furthermore, the South Centre City Specific Plan has an added provision to allow three or more units to be a qualifying project under Density Bonus Law.

Current State law requires jurisdictions to provide density bonuses and development incentives to all developers who propose to construct affordable housing on a sliding scale, where the amount of density bonus and number of incentives vary according to the amount of affordable housing units provided. Specifically, State law requires the provision of certain incentives for residential development projects that set aside a certain portion of total units to be affordable to lower and moderate income households. Under State law, a development of more than five units is eligible to receive density bonuses if it meets at least one of the following:
• At least 5% of the housing units are restricted to very low income residents. • At least 10% of the housing units are restricted to lower income residents. • At least 10% of the housing units in a for-sale common interest development are restricted to moderate income residents.
• 100% of the housing units (other than manager’s units) are restricted to very low, lower and moderate income residents (with a maximum of 20% moderate). • At least 10% of the housing units are for transitional foster youth, disabled veterans or homeless persons, with rents restricted at the very low income level. • At least 20% of the housing units are for low income college students in housing dedicated for full-time students at accredited colleges.
• The project donates at least one acre of land to the city or county for very low income units, and the land has the appropriate general plan designation, zoning, permits and approvals, and access to public facilities needed for such housing. • The project is a senior citizen housing development (no affordable units required).

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• The project is a mobile home park age-restricted to senior citizens (no affordable units required).

AB 2345 was passed in September 2020, amending the Density Bonus Law to increase the maximum density bonus from 35% to 50%. To be eligible for the maximum bonus, a project must set aside at least (i) 15 % of total units for very low income households, (ii) 24% of total units for low income households, or (iii) 44% of for-sale units for moderate income households. Levels of bonus density between 35% and 50% are granted on a sliding scale. Cities must update their density bonus ordinances to codify these new bonus requirements. This Housing Element includes a program to update the City’s Density Bonus provisions to be consistent with the most recent changes in State Density Bonus Law.

The Density Bonus and Residential Incentives Ordinance enc ourages development of housing for lower income and senior households. Other processes in the Zoning Ordinance help in the development of housing for the higher income households as well as the lower income households.

Escondido has an income distribution that skews toward the lower income compared to the region.

As a means to diversify the City’s socioeconomic profile, the City retains certain amount of large-lot zoning to accommodate the housing needs and preferences of moderate and higher income households. This strategy is aimed at satisfying high-tech businesses desiring to locate in Escondido.

Planned Developments, Specific Plans and Administrative Adjustments are also available to assist in the development and rehabilitation of housing for all economic sectors of the community.

These processes are particularly helpful where properties may be constrained. Specific Plans and Planned Developments allow for clustering of smaller lots into buildable areas, while preserv ing unique or environmentally sensitive areas such as ridgelines, stream courses and steep slopes.

Planned Developments and Specific Plans are useful for large scale developments, while administrative adjustments are more useful on a small scale basis where deviations from the code may enable the development on a constrained site or an addition to an existing single-family home or apartment complex.

Residential Development Standards
Citywide, outside the specific plan areas, the City regulates the type, location, density, and scale of residential development primarily through the Zoning Code. The following summarizes the City’s existing residential zoning districts:
• Residential Agricultural (R -A) – 1 unit per 5 to 10 acres: This zone is designed to protect agricultural uses from encroachment by urban uses until residential, commercial or industrial uses in such areas become necessary or desired. The densities in this zone are based on the minimum lot sizes of 5 to 10 acres.
• Residential Estates (R-E) – 0.2 to 2 units per acre: This zone is to provide an area exclusively for single-family dwellings in a rural setting. Provisions are made for the maintenance of limited agricultural pursuits as well as those uses necessary and incidental to single family living. The densities in this zone are based on the minimum lot sizes of 20,000 square feet to 210,000 square feet.
• Single-Family Residential (R-1) – 1.74 to 7.26 units per acre: This zone is to encourage and promote a suitable environment for family life by providing a district for the establishment of one-family, detached dwellings, exclusively. The densities in this zone are based on the minimum lot sizes of 6,000 square feet to 25,000 square feet.

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• Mobile Home Residential (R-T): This zone is established to encourage and promote a suitable environment for family life by providing a district for one-family detached mobile homes. • Light Multiple Residential (R -2) – 12 units per acre: This zone is established to provide low height, low density residential areas in close proximity to single-family residential neighborhoods.
• Medium Multiple Residential (R-3) – 18 units per acre: This zone, is established to provide medium density, low-height residential areas for two, three and multifamily dwelling units. • Heavy Multiple Residential (R-4) – 24 units per acre: This zone is established to provide an area for a suitable environment for family life for those wishing to live in apartments near the city’s center.
• Very High Multi -Family Residential (R-5) - 30 units per acre: Thi s zone is established to provide a multi-family setting for family life in higher-height, very high-density dwelling units in close proximity to other multi-family neighborhoods and near the city’s center.

Development standards specific to each zone district are designed to protect and promote the health, safety, and general welfare of residents as well as implement the policies of the General Plan. These standards also serve to preserve the character and integrity of existing neighborhoods. Specific residential development standards are summarized in Table 42.

Generally, development standards can limit the number of units that may be constructed on a particular piece of property. These include density, minimum lot and unit sizes, height, and open space requirements. Limiting the number of units that can be constructed will increase the per -unit land costs and can, all other factors being equal, result in higher development costs that may impact housing affordability.

Table 42: Residential Development Standards
Zoning
District
Maximum
Building
Height
(ft.)
Minimum
Net Lot
Area
(sq. ft.)
Minimum
Lot Width
(ft.)
Setbacks (ft.) Maximum
Lot
Coverage
Floor
Area
Ratio Front Rear Side
R-A 35 217,800 150 25 20 10 20% 0.3
R-E 35 20,000 100 25 20 10 30% 0.4
R-1 35 6,000 60 15 20 5 40% 0.5
R-T -- 4,500 55 15 5 5 60% --
R-2 25 6,000 60 15 15 5 -- 0.6
R-3 35 6,000 60 15 10 5 -- 0.7
R-4 75 6,000 50 15 10 5 -- 0.8
R-5 75 6,000 50 15 10 5 -- 0.9
Source: City of Escondido Zoning Ordinance, 2020.

Setback Requirements
Setback requirements can encourage or discourage development. As seen on Table 42, the City's residential setback requirements are minimal. The City also offers adjustments to requirements (up to 25%) with the approval of the Community Development director. Even further reductions to setback requirements for landscaping and parking are available to affordable or senior housing proposals, pursuant to the Residential Incentive Ordinance.

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Building and Parcel Requirements
Building and parcel requirements for residential development can also encourage or discourage development. While development standards are necessary in order to preserve the character of that particular zone, those that are too restrictive can increase development costs and inhibit or reduce the achievable number of permitted dwelling units.

Building and parcel requirements in the City are not overly restrictive and offer the flexibility needed to encourage development. Minimum parcel sizes vary, depending on the zone, and are minimal in the multi-family zones. Minimum unit sizes are closely tied to the minimum standards required by the State for health and safety purposes. Lot coverage and floor area ratios are high enough to have little or no constraint on development proposals. And usable open space requirements are low and can be lowered further for affordable and senior housing development proposals. Building and parcel requirements in the Downtown and South Centre City Parkway areas are even less restrictive than those of the single-family and multi-family zones.

Zone Changes and General Plan Amendments
Residential zone changes that propose density increases consistent with the General Plan do not require an initiative or a referendum. Pursuant to proposition S, General Plan amendments involving an increase in residential densities or change from residential to commercial or industrial require a majority vote by the people.

Proposition S specifies that General Plan amendments or specific plans cannot be adjusted without a vote of the people, if changes increase residential density, alter or increase the General Plan's residential land use categories, or change any Rural, Estate, Suburban or Urban residential designation to a commercial or industrial designation. Thus, voter approval is required for amendments that would increase residential densities, but also deters the loss of residential land when associated with an amendment to commercial or industrial.

The General Plan update was approved by the City Council on May 23, 2012 and portions involved voter approval decided at the November 2012 election; Escondido residents approved the changes to the General Plan. The updated General Plan provides for increased residential development capacity through mixed -use development, primarily along South Escondido Boulevard. Most other residential areas retain their current General Plan and zoning designations. Furthermore, Proposition S states, “Nothing in this initiative shall be construed to:
• Interfere with rights to obtain density bonuses or other entitlements available under affordable housing laws, or
• Limit right or entitlements available under affordable housing laws.” Additionally, few residential subdivisions have been denied, and current zoning allows multi -family development by right with ministerial processing only.

Parking Standards
High numbers of parking spaces required per dwelling unit can negatively impact the feasibility of providing affordable housing by reducing the achievable number of dwelling units per acre and increasing development costs. The cost and amount of required parking has a high impact on the cost of housing. Typically, the concern for high parking standards relates mostly to multi -family, affordable, or senior housing. Escondido’s requirements for single-family and multi-family residential Attachment "5"
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are summarized in Table 43. In some instances, tandem spaces are permitted and in others, guest parking may be provided on-street.

Table 43: Escondido Residential Parking Requirements
Type of Residential
Development Required Parking Spaces Per Unit
Single-Family or
Two-Family Residence Two (2) car garage or carport spaces Accessory Dwelling Unit Zero (0) parking spaces
Multiple-Family Dwelling*
Efficiency Unit One (1) parking space
One-Bedroom Unit One and one-half (1.5) parking space
Two-Bedroom Unit One and three-quarter (1.75) parking space Three or More Bedrooms Two (2) parking spaces
Senior housing Two (2) plus three (3) for every four (4) efficiency units or one bedroom units. Units with two (2) or more bedrooms require one and one-half (1.5) spaces per unit.

Source: City of Escondido Zoning Ordinance, 2020
* One space is required for each four (4) units required for guest parking

Escondido’s Density Bonus and Residential Incentive Ordinance allows parking reductions for affordable and senior development at the following ratios: one space/one-bedroom unit; 1.2 spaces/two-bedroom unit, and 1.5 spaces/three-bedroom unit. These standards are lower than even the State-mandated parking standards for density bonus projects. Additionally, on-street resident parking for affordable or senior units can be substituted for required off-street parking at a ratio of one-to-one on non-Circulation Element streets. Requirements to cover spaces can also be waived.

Provision for a Variety of Housing Opportunities
Housing element law specifies that jurisdictions must identify adequate sites to be made available through appropriate zoning and development standards to encourage the development of a variety of housing types for all economic segments of the population. This includes single- family homes, multi-family housing, second units, mobile homes, emergency shelters, and housing for persons with disabilities. Table 44 below summarizes the various housing types permitted within the City’s zoning districts.

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Table 44: Use Regulations for Residential Zones
Use R-A R-E R-1 R-T R-2 R-3 R-4 H-P C-G Mixed-use
Overlay
Single-Family Dwelling P P P -- P P P -- -- --
Accessory Dwelling Unit P P P -- P P P -- -- --
Multi-Family Dwelling -- -- -- -- P P P -- -- P
Mobile Home Park C C C C C C C -- -- --
Manufactured Housing P P P P -- -- -- -- -- --
Care Facility (6 or fewer) P P P P P P P C C P
Care Facility (7 or more) C C C -- C C C C C P
Senior Housing P P P P P P P -- -- P
Transitional (6 or fewer) P P P P P P P P/C P/C P
Transitional (7 or more) C C C C C C C P/C P/C P
Disabled (6 or fewer) P P P P P P P -- -- P
Disabled (7 or more) C C C C C C C -- -- P
Single Room Occupancy -- -- -- -- -- -- -- -- -- C
Farm Worker Housing P P -- -- -- -- -- -- -- --
P = Permitted Use
C = Conditional Use
Source: City of Escondido Zoning Code, 2020

Single-Family Dwelling
“Single-family dwellings” are defined in the Zoning Code as detached or semi -detached buildings.

Single-family dwellings are permitted in all residential zones, except the R -T zone. As part of the General Plan update, the City established a 70% minimum density for R -3, R-4, and R -5 zoning districts, effectively discouraging single-family homes to be developed on properties designated for multi-family uses. This change promotes the efficient use of the City’s residential land and mitigates neighborhood compatibility issues.

Accessory Dwelling Units
Accessory dwelling units (“ADUs”) and junior accessory dwelling units (“JADUs”) are attached or detached dwelling units that provide complete independent living facilities for one or more persons including permanent provisions for living, sleeping, cooking and sanitation. ADUs may be an alternative source of affordable housing for lower-income households and seniors. Recent state laws, including AB 68, AB 587, AB 670, AB 881, AB 671 and SB 13 in 2019 and AB 3182 in 2020, require cities to use a ministerial process to consider accessory dwelling units in an effort to facilitate the production of affordable housing state-wide. Accessory units must be permitted in all residential and mixed-use zones where a residential unit already exists.

Recent ordinances by the City of Escondido have updated the zoning provisions related to ADUs and JADUs. In 2020, and subsequently in 2021, the City amended the Zoning Code to comply with AB
68, AB 587, AB 670, AB 671, AB 881, AB 3182 and SB 13 to reflect changes to Government Code section 65852.2 and section 65852.22. The City of Escondido permits ADUs and JADUs in area zoned to allow single-family or multi-family residential use, subject to the approval of an ADU permit. ADUs must Attachment "5"
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also comply with the development standards of the underlying zone, except where precluded by state law. Other requirements for accessory dwelling units include:
• The owner of the property must reside on the parcel on which a JADU is located. • No limit on the number of bedrooms is allowed.
• A setback requirement of not more than four feet for detached accessory dwelling units. • Any development standards that regulate the size of the ADU must permit at least an 850 square foot ADU to be constructed.
• The accessory unit shall respect the residential scale and design character of existing homes.

Additionally, the zoning code has a provision that states that the section “shall be interpreted liberally in favor of accessory dwelling unit construction,” which further removes constraints on ADU production in case of ambiguities in the standards. The City does not require any parking for ADUs or JADUs. Copies of Ordinance No. 2020-31R and 2021-10 were transmitted to HCD in accordance with Government Code 65852.2(h)(1).

Multi-Family Dwelling
According to the State Department of Finance, multiple-family housing makes up approximately 36% of the 2020 housing stock in Escondido (Table 26). The Zoning Code provides for multi -family developments in the higher density residential zones (R -2, R-3, and R-4, R-5) and in specific plans.

The maximum density for the R-5 zone is 30 units per acre.

Mobile Home Parks and Manufactured Housing
Manufactured housing and mobile homes can be an affordable housing option for low and moderate income households. Mobile homes represent about eight percent of the City’s housing stock as of January 2020. A mobile home built after June 15, 1976, certified under the National Manufactured Home Construction and Safety Act of 1974, and built on a permanent foundation may be located in any residential zone where a conventional single-family detached dwelling is permitted subject to the same restrictions on density and to the same property development regulations. Manufactured/ mobile homes are permitted in all of the City’s lower density residential zones (R-A, R-E, R-1 and R- T). In today’s construction methods, manufactured housing can also apply to multi -family housing construction. The Zoning Code will be amended to permit manufactured homes meeting the California Building Code standards to be permitted where residential uses are permitted.

Residential Care Facilities
Residential care facilities licensed or supervised by a Federal, State, or local health/welfare agenc y provide 24-hour non-medical care of unrelated persons who are handicapped and in need of personal services, supervision, or assistance essential for sustaining the activities of daily living or for the protection of the individual in a family-like environment. The Community Care Facilities Act (California Health and Safety Code) and Lanterman Developmental Disabilities Services Act (California Welfare and Institution Code) require that State-licensed residential care facilities serving six or fewer persons (including foster care) be treated as a regular residential use and therefore must be permitted by right in all residential zones allowing residential uses. These facilities cannot be subject to more stringent development standards, fees, or other standards than the same type of housing single-family homes in the same district.

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The City amended its Zoning Code, in accordance with the Lanterman Developmental Disabilities Services Act of the California Welfare and Institutions Code and the Health and Safety Code in 2004.

The amendment clarifies that the use of property for the care of six or fewer disabled persons is a “residential use” for the purposes of zoning. A State-authorized, certified or authorized family care home, foster home, or group home serving six or fewer disabled persons or dependent and neglected children on a 24-hour -a day basis is considered a residential use that is permitted in all residential zones. The amendment also clarifies that in Commercial and Hospital Professional zones, licensed residential care facilities serving any number of residents are permitted by right, and in residential zones (except the R -T zone), licensed residential care facilities serving more than six persons are permitted with a Conditional Use Permit. The CUP process may be considered a constraint to housing for persons with disabilities.

Emergency Shelters
Senate Bill 2, enacted in October 2007, requires local governments to identify one or more zoning categories that allow emergency shelters (year-round shelters for the homeless) without discretionary review. The statute permits the City to apply limited conditions to the approval of ministerial permits for emergency shelters. The identified zone must have sufficient capacity to accommodate at least one year -round shelter and accommodate the City’s share of the regional unsheltered homeless population. The San Diego Regional Task Force on the Homeless “We All Count 2020” found that Escondido’s homeless population is estimated to be 429 individuals , 264 of those individuals are unsheltered.

In 2013, the City amended its zoning code to add an Emergency Shelter Overlay Zone subject to the following standards:
• Each shelter shall be located within an entirely enclosed, permanent structure. • Each shelter may have a maximum 50 beds to serve a maximum of 50 clients. • The maximum length of stay at any one time for any person shall be six months in any 12- month period.
• Parking shall be two spaces per facility plus one space for each employee. • There shall be no camping or sleeping in vehicles on site. • An emergency shelter shall be located at least 300 feet from another shelter. • Each shelter shall conform to the requirements of the Outdoor Lighting Ordinance. • The emergency shelter operator shall submit a written management plan.

The zone allows for year -round emergency shelters and can accommodate the City’s unsheltered homeless population. Emergency shelters are allowed without discretionary approval in the overlay zone. The zone is approximately 69 acres and encompasses 64 parcels zoned for M-1 and M-2 (light industrial), which are currently occupied by mostly light industrial, commercial, and warehousing uses.

Some buildings in the area are antiquated, with deferred maintenance issues, and were developed below the allowable intensity. Therefore, development of emergency shelters in this area can occur either as new construction on one of the underutilized properties, or as adaptive reuse of an existing vacant building (or just a portion of the building). The overlay zone is appropriate for emergency shelters since it contains underutilized properties and is located near the Nordahl Road transit station and the new Palomar Hospital.

In 2020, the City amended the Zoning Code to comply with AB 139, which sets parking standards based primarily on staffing level only. Ordinance 2020-31R amended the Zoning Code to require two spaces per facility plus one space for each employee. This standard is slightly inconsistent with AB Attachment "5"
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139. Furthermore, the City will amend the Zoning Code to revise the separation requirement to a maximum of 300 feet pursuant to SB 2 (2007).

Transitional and Supportive Housing
California Health and Safety Code (Section 50675.2) defines “transitional housing” and “transitional housing development” as buildings configured as rental housing developments, but operated under program requirements that call for the termination of assistance and recirculation of the assisted unit to another eligible program recipient at some predetermined future point in time, which shall be no less than six months.

Residents of transitional housing are usually connected to supportive services designed to assist the homeless in achieving greater economic independence and a permanent, stable living situation.

Transitional housing can take several forms, including group quarters with beds, single-family homes, and multi-family apartments and typically offers case management and support services to help return people to independent living (often six months to two years).

Supportive housing links the provision of housing and social services for the homeles s, people with disabilities, and a variety of other special needs populations. California Health and Safety Code (Section 50675.2) defines “supportive housing” as housing with no limit on length of stay, that is occupied by low income adults with disabilities, and that is linked to on- site or off-site services that assist the supportive housing resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community. Target population includes adults with low incomes having one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health conditions, or individuals eligible for services provided under the Lanterman Developmental Disabilities Services Act (Division 4.5, commencing with Section 4500, of the Welfare and Institutions Code) and may, among other populations, include families with children, elderly persons, young adults aging out of the foster care system, individuals exiting fro m institutional settings, veterans, or homeless people.

Escondido’s Zoning Code makes provisions for transitional and permanent supportive housing.

Transitional and supportive housing that is operated as regular housing developments (i.e. no state care lic ense) is permitted by -right in all residential zones, regardless of size or on -site services.

Transitional and supportive housing that is operated as group quarters with six or fewer persons is permitted by right in all residential zones. Transitional and supportive housing that is operated as a group quarters with seven or more persons is conditionally allowed in all residential zones except the R-T zone (Mobile Home Park Zone). Potential conditions for approval of large residential care facilities (for mo re than six persons) as transitional/supportive housing may include hours of operation, security, loading requirements, noise regulations, and restrictions on loitering. Conditions would be similar to those for other similar uses and would not serve to constrain the development of such facilities. SB 745 (2014) specifies that transitional housing and supportive housing should be considered a residential use of property, and subject only to those restrictions that apply to other residential dwellings of the same type in the same zone. This would extend residential uses as permitted in mixed -use and nonresidential zones. Pursuant to AB 2162 (2018), supportive housing meeting certain criteria must be permitted by right where residential uses are permitted, inc luding mixed-use and nonresidential zones. Escondido’s Zoning Code does not permit mixed -use development outside of specific plan areas; these plans do not explicitly identify transitional and supportive housing as separate from residential uses. The City will review SB 745 and AB 2162 and ensure compliance.

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Senior Housing
The Zoning Code permits senior housing (for persons aged 55 or over) as regular housing across the City. Senior Housing is allowed by right in all residential zones.

Single Room Occupancy Units (SROs)
Single Room Occupancy (“ SRO”) units are one-room units intended for occupancy by a single individual. They are distinct from a studio or efficiency unit, in that a studio is a one -room unit that must contain a kitchen and bathroom. Although SRO units are not required to have a kitchen or bathroom, many SROs have one or the other and could be equivalent to an efficiency unit. The zoning code officially classifies SROs as “rooming house, boarding house, mini-dorms, etc. with central kitchen, interior access to sleeping roomsa living or efficiency unit, as defined by California Health and Safety Code section 17958.1, intended or designed to be used as a primary residence for a period of more than thirty (30) consecutive days.” The City adopted a hotel conversion ordinance in 2021 which permits for SRO development through a hotel conversion permit and accompanying CUP, if required, such as in some districts of the South Centre City Specific Plan.conditionally allows these uses in the R-2, R-3, R-4, and R-5 zones, and in some districts of the South Centre City Specific Plan.

Farm Worker Housing
Pursuant to the State Employee Housing Act (Section 17000 of the Health and Safety Code), employee housing for agricultural workers consisting of no more than 36 beds in a group quarters or 12 units or spaces designed for use by a single-family or household is permitted by right in an agricultural land use designation. For properties that permit agricultural uses by right, a local jurisdiction may not treat employee housing that meets the above criteria any differently than an agricultural use. Furthermore, any employee housing providing accommodations for six or fewer employees shall be deemed a single-family structure within a residential land use designation, according to the Employee Housing Act. Employee housing for six or fewer persons is permi tted wherever a single-family residence is permitted. To comply with State law no conditional use permit or variance is required.

The City’s Zoning Code allows, as a permitted use in open space (O -S), agricultural and estate residential zones (R-A and R-E), living quarters for persons employed on the premises in conjunction with authorized agricultural uses. The City will review the Zoning Code to ensure compliance with the Employee Housing Act.

Low Barrier Navigation Centers
Low Barrier Navigation Centers (“LBNC”s) are service-enriched shelters that are focused on moving individuals into more permanent housing. Low Barrier Navigation Centers provide temporary housing while case managers connect individuals experiencing homelessness to shelter, public benefits, and health services. Under the Housing for Homeless Act (2019), local governments are required to allow Low Barrier Navigation Centers by right in areas zoned for mixed-uses and nonresidential zones that permit multi-family uses.

The City amended the Zoning Code with Ordinance 2020-31R to address the provision of LBNC in CG, CN and CP zones where there are mixed-use overlay areas that are zoned for mixed-use and nonresidential zones permitting multi-family uses.

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Housing for Persons with Disabilities
Both the federal Fair Housing Amendment Act ( “FHAA”) and the California Fair Employment and Housing Act direct local governments to make reasonable accommodations (that is, modifications or exceptions) in their zoning laws and other land use regulations when such accommodations may be necessary to afford disabled persons an equal opportunity to use and enjoy a dwelling. The City conducted an analysis of the zoning ordinance, permitting procedures, development standards, and building codes to identify potential constraints for housing for persons with disabilities. The City’s policies and regulations regarding housing for persons with disabilities are described below.

Land Use Controls
Under State Lanterman Developmental Disabilities Services Act (also known as the Lanterman Act), small licensed residential care facilities for six or fewer persons must be treated as regular residential uses and permitted by right in all residential districts. In accordance with State law (Lanterman Developmental Disability Services Act, AB 846, compiled of divisions 4.1, 4.2 and 4.7 of the Welfare and Institutions Code and Title 14 of the Government Code), Escondido allows residential care facilities serving six or fewer persons within all residential zones. Residential care facilities serving more than six persons are conditionally permitted in all residential zones except the mobile-home park zone (R-T). The City does not have a local requirement for proximity between two special needs housing sites.

The City’s Zoning Code provides for transitional/supportive housing as residential care facilities only.

The Zoning Code will be amended to address the provision of these housing types pursuant to State laws (see discussions above).

Definition of Family
Local governments may restrict access to housing for households failing to qualify as a “family” by the definition specified in the Zoning Code. Specifically, an overly restrictive definition of “family” that limits the number of and differentiates between related and unrelated individuals living together could illegally limit the development and siting of group homes for persons with disabilities, but not for housing families that are similarly sized or situated.

The City of Escondido Zoning Code defines a “family” as “one or more persons related by blood, marriage, or adoption, or a group including unrelated individuals living together as a relatively permanent, bona fide, housekeeping unit.” The City’s definition of family does not restrict access to housing.

Building Codes
The Building and Safety Division actively enforces the California Building Code provisions that regulate the access and adaptability of buildings to accommodate persons with disabilities. No unique restrictions are in place that would constrain the development of housing for persons with disabilities. Government Code Section 12955.1 requires that 10% of the total dwelling units in multi -family buildings without elevators consisting of three or more rental units or four or more condominium units subject to the following building standards for persons with disabilities:
• The primary entry to the dwelling unit shall be on an accessible route unless exempted by site impracticality tests.
• At least one powder room or bathroom shall be located on the primary entry level served by an accessible route.

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• All rooms or spaces located on the primary entry level shall be served by an accessible route.

Rooms and spaces located on the primary entry level and subject to this chapter may include but are not limited to kitchens, powder rooms, bathrooms, living rooms, bedrooms, or hallways.
• Common use areas shall be accessible.
• If common tenant parking is provided, accessible parking spaces is required.

Reasonable Accommodation
Both the Federal Fair Housing Act and the California Fair Employment and Housing Act direct local governments to make reasonable accommodations (i.e. modifications or exceptions) in their zoning laws and other land use regulations when such accommodations may be necessary to afford disabled persons an equal opportunity to use and enjoy a dwelling. For example, it may be reasonable to accommodate requests to waive a setback requirement or other standard of the Zoning Ordinance to ensure that homes are accessible for the mobility impaired. Whether a particular modification is reasonable depends on the circumstances.

The City adopted an amendment to the Zoning Code establishing a formal reasonable accommodations procedure in 2001. The Zoning Code gives authority to the Direction of Community Development (or his/her designee) to make decisions regarding reasonable accommodation requests. There is no fee imposed on the request for reasonable accommodation. However, if the project for which the request is being made also requires some other planning permit or approval, then the applicant must file the request together and submit the required fees associated with the related permits.

In determining the reasonableness of a requested accommodation, the Director will consider the following factors:
• Whether the housing which is the subject of the request for reasonable accommodation will be used by an individual protected under the Acts;
• Whether fulfillment of the request is necessary to make specific housing available to an individual protected under the Acts;
• Whether the accommodation will impose an unreasonable financial or administrative burden on the City;
• Whether the accommodation will require a fundamental alteration of the zoning or building laws, policies and/or procedures of the City;
• Whether the accommodation will have any potential impact on surrounding uses; • Physical attributes of the property and structures; and • Any other factor deemed relevant to the determination according to the Acts, as amended.

The requi rement to be compatible with surrounding uses may be considered subjective and potentially constraining development of housing for persons with disabilities.

Permits and Processing
A request for a retrofit of property to increase accessibility would be handled through the building permit process, if the retrofit is of a nature to be governed by the building code. Group homes, with fewer than six persons, are permitted by right in the residential zones. Modifications to the structure Attachment "5"
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would be made through the building permit process, if the modifications proposed are under building code jurisdiction.

Depending on the zone classification of the property, a group home for more than six persons requires either a plot plan or a Conditional Use Permit. There is no standard list of conditions; each site would be reviewed and conditions assigned based on the specifics of the site and proposed project. A plot plan does not require a public hearing. A Conditional Use Permit requires a public hearing by the Planning Commission.

Development Conditions and Fees
Residential developers are subject to a variety of fees and exactions to process permits and provide necessary services and facilities as allowed by State law. In general, these development fees can be a constraint to the maintenance, improvement, and development of housing because the additional cost borne by developers contributes to overall increased housing unit cost. However, the fees are necessary to maintain adequate public services and facilities in the City in concert with adopted Quality of Life Standard thresholds set forth in the General Plan. These fees have not been found to act as a constraint to the development of housing in Escondido.

Planning processing costs are covered in part by applicant fees. Development impact fees are charged to a new development to pay for the local infrastructure needed to serve it. Within the San Diego region, all 18 of the local jurisdictions and the County charge development impact fees. Impact fees can be charged for a variety of public facilities, including utilities, parks, open space, fire stations, libraries, and transportation improvements such as streets, highways, and transit.

Development impact fees enable the City to shift at least part of the capital -financing burden to new development, and synchronize new development with the installation of these new public facilities.

Escondido's impact fees fall within the average when compared to those of the other jurisdictions.

Additionally, the City conducts a periodic review of the fees to insure they reflect the current impacts and necessary improvements for the standard level of service. To facilitate residential development in the Downtown area, the City charges reduced impact fees in the Downtown area.

Table 45 summarizes the most common planning and development impact fees for the City of Escondido and other North County cities located along the State Route 78 corridor. In general, the City’s fees are comparable to developments in other North San Diego communities. Table 46 compares the estimated total fees for typical projects based on a fee survey conducted by the Building Industry Association of San Diego. As shown, fees in Escondido fall within the middle to low end of the spectrum compared to other communities in the region. The fee amounts reported below for the City of Escondido include inflationary adjustments, adopted pursuant to R2020-125 on October 28, 2020, effective on February 22, 2021.

To facilitate residential development in the current economic climate, the City revised its Development Fee Deferral Policy in June 2012. This revision expanded the existing policy to allow residential developers (for projects of five or more units) to defer payment of development fees until occupancy, not to exceed one year from building permit issuance.

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Table 45: Planning and Development Fees Regional Comparison (2020/21) Jurisdiction Escondido* Carlsbad* Oceanside* Vista San Marcos Residential Unit
Type (cost per
unit)
Single
Family
Multi-
family
Single
Family
Multi-
family
Single
Family
Multi-
family
Single
Family
Multi-
family
Single
Family
Multi-
family
Planning Fees
Design Review/
Development
Review
$524.97 - $846.97 varies $7,000 - $10,000 $953.26 $2,470 $3,430 Major Use
Permit/
Conditional Use
Permit
$6,972.97 $4,913 $5,000 $8,064.36 $3,476
Tentative Parcel
Map $3,970.97 $3,678 - $4,169 $3,000 $4,740.73 $2,090
Tentative
Subdivision Map
$6,128.87 -
$12,652.57 $8,193 $8,000 $7,292.45 (5-15 lots)
$10,042.96 (15+ lots) $2,690 + $50/lot
Environmental
Review-Initial
Study/Addendum
$2,565.00 $2,753+ $5,000 $6,930.91+ $200.00
General Plan
Amendment
$5,968.18 -
$6,954.45 $4,677 - $6,747 $10,000 - $15,000 $10,617.25 $2,500 Impact/Capacity Fees
Facilities Fee $4,969 $4,969 $15,423 $9,039 $2,621 $2,621 $1,218 $1,218 N/A N/A Parks Fee $6,986 $6,663 $7,649 $6,190 $4,431 $4,431 $8,086.54 $8,035.77 $6,251 Traffic Impact
Fee $4,191 $2,095 $7,500 $6,000 $1,032 $582 $5,667.86 $4,534.29 $6,747 $4,048 Drainage Fee $1,136 $469 $2,054 $3,589 $2,054 $976 varies $3,625 – $28,261/acre
Other Fees $15,430 $9,148 $16,324 $12,398 $46,330 $8,718 $5,739.67- $6,824.48
$4,131.46-
$4,890.83 $30,083 $15,816
Total per Unit $32,712 $23,344 $49,243 $33,986 $56,468 $17,328 varies varies varies varies Source: City of Escondido (Updated February 23, 2021), City of Carlsbad, City of Oceanside, City of Vista Fees (July 2021), City of San Marcos Adopted 2021-2029 Housing Element.
*The cities of Escondido, Carlsbad, and Oceanside are “full service” cities, whereas Vista and San Marco are not. According to the Institute of Local Governments (2016), a “full service” city is responsible for providing all or most of city services, such as law enforcement, fire suppression, land use planning, parks and recreation, water and wastewater services, solid waste collection, and public works.

Note: City of Oceanside’s discretionary fee costs are base deposit amounts, and vary depending on total amount of time billed toward a project and may exceed initial deposit amount8.

8 City of Oceanside, Planning Fee Schedule, and City of Oceanside Development Services Department and Economic and Community Development Department Policy No. 201101/Policy and Procedure for Development Deposit Account Administration.

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Table 46: Total Fee Comparisons (2019-2020)
Jurisdictions
Per Unit Permit and Impact Fees
Single Family
Townhome
(Type V
Construction)
Condominium
(Type III
Construction)
Apartment
(Type V
Construction)
Carlsbad $42,616.78 $23,012.02 $17,086.21 $16,762.04
Chula Vista $57,167.97 $42,481.32 $38,577.18 $38,596.86 Encinitas $22,932.15 $15,984.48 --- $15,233.65
Escondido $37,044.15 $31,185.86 $29,360.35 $29,360.35
Imperial Beach $15,161.22 $11,262.71 $9,832.14 $21,010.37 La Mesa $27,442.49 $19,242.63 $14,248.72 $12,906.75
Lemon Grove $13,563.65 $6,259.63 $4,870.52 $5,106.55
National City $15,025.99 $5,655.93 $4,175.54 $4,175.54
Oceanside $68,235.30 $25,089.74 $17,254.33 $17,178.01
Poway $26,528.05 $21,194.22 $2,059.13 $20,898.17
San Diego $155,367.00 $103,121.73 $95,731.81 $97,461.70 San Marcos $30,761.34 $25,588.10 $23,410.80 $14,184.14
Santee $78,142.00 $67,667.00 $64,247.00 $57,827.00
San Diego County $21,797.00 $12,793.00 $10,900.00 $11,156.00 Vista $27,546.37 $20,804.79 $23,176.90 $18,608.86
Source: BIA 2019-2020 Fees Study for San Diego County; City of Santee Fee Schedule FY2020-21; Padre Dam Municipal Water District Sewer and Water Capacity Fee Schedule 2021; Santee Elementary School District Developer Fees 2021; Grossmont Union High School District Developer Fees 2021

In 2020, the City conducted a Fiscal Impact Assessment that determined that the cost to serve new residential development generally exceeds the revenue generated from that development. In order to ensure that new residents within the City continue to receive the services at their current level, a Community Facilities District (“CFD”) has been created as one potential mechanism to fund municipal services associated with new residential development. A CFD is special tax levied annually on the property tax bill. Also known as a Mello-Roos, this tax can be used to fund improvements required to support the development of new homes or the ongoing costs to serve new development. In accordance with Resolution No. 2020-44, adopted on May 13, 2020; Ordinance No, 2020-10, adopted on June 3, 2020; and Ordinance No. 2020-24, adopted on October 21, 2020; and as otherwise authorized by the City’s longstanding General Plan policies and authority under State law, new residential development is expected to fund all on-going operational costs of providing municipal services required for the project. Such funding may occur through either an agreement to voluntarily form or annex into a CFD or the establishment of another lawful funding mechanism to offset the impacts to public services associated with the project. With respect to the CFD, for new residential units within the City limits, the FY20/21 adopted special tax rates range from $536 to $783 per dwelling unit.

Although Resolution No. 2020-44, Ordinance No, 2020-10, and Ordinance No. 2020-24 were enacted to protect the health and safety of citizens and further the general welfare, the City will periodically re-examine the aforementioned policies to determine whether, under certain conditions, if they directly or indirectly constitute a barrier to the maintenance, improvement, or development of housing for all income levels. As previously mentioned, this 2021-2029 Housing Element was prepared under Attachment "5"
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the cover of a Housing and Community Investment Study, which among other things identifies all relevant land use controls and their impacts on the cost and supply of housing, including the CFD policies. A Sector Feasibility Study was prepared and shows that the cumulative impacts of standards and policies, including the policy that contemplates new residential development funding the on-going costs of municipal services required by such development, does not impede the ability to achieve maximum allowable densities. Such an examination may reveal that certain policies have a disproportionate or negative impact on the development of particular housing types (e.g., multi-family) or on housing developed for low or moderate income households. However, affordable housing projects and other organizations that meet the requirements of Revenue and Taxation Code section 214 may qualify for a Property Tax Welfare Exemption.

The City will continue to monitor whether ordinances, policies, or practices related to development conditions and fees, such as those covered in this section or those new ly contemplated during this housing element cycle, have the effect of unduly constraining the maintenance, improvement, or development of housing, including but not limited to excluding housing affordable to low - and moderate-income households.

Transparency in Development Process
To increase transparency and certainty in the development application process as required by law (AB 1483), the City has a variety of tools available for developers. The City’s Planning Division website has links to the City’s zoning ordinance, zoning parc el look-up tool, and other resources (https://www.escondido.org/planning.aspx
). Direct links are also provided below:
• Zoning Ordinance: http://www.qcode.us/codes/escondido/view.php?topic=33 • Parcel look-up tool: https://www.escondido.org/parcel-lookup.aspx • Planning Fee schedule:
https://www.escondido.org/Data/Sites/1/media/Planning/FeeSchedule2021- 22Revised12.21.21.pdf
On- and Off-Site Improvements
Infrastructure is already in place in multi-family areas. Development standards vary depending on the land use pattern in the area. Street width requirements (curb to curb) are 36 feet for public and 28 feet for private rural residential streets, 42 for local collectors, 64 for collectors and 82 for major roads.

Full curb and gutter are required, with the standard five-foot wide sidewalk per ADA requirements.

Water and sewer capacity must be adequate to meet normal and emergency situations with a water capacity to provide a minimum of 540 gallons of water per day per household and a sewage capacity to treat a minimum of 250 gallons per day for each residence. The City is also required to comply to NPDES (National Pollution Discharge Elimination System) storm water standards with structural and non-structural methods, such as the use of detention basins, catch basin and filters, and drains.

Requirements for on- and off-site improvements vary depending on the presence of existing improvements, as well as the size and nature of the proposed development. In general, the City requires the following improvements and facilities for new developments:
• Grade Improvements: The City requires developers to grade and improve all land dedicated or to be dedicated for streets or easements, bicycle ways and all private streets and private easements involved in a Final Map or Parcel Map in such manner and with such improvements as are necessary in accordance with the Escondido City standards. • Sewers: The City requires developers to install sewers or sewage disposal systems in accordance with the Private Sewage Disposal Systems ordinance.

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• Water Supply: The City requires developers to provide proof satisfactory to the City Engineer that there exists an adequate potable water supply available to each lot or parcel and that the developer will install or agree to install water supply facilities to the satisfaction of the City Engineer provided that the City Engineer may require such other system or size of water supply pipe as recommended by the water facility serving the project. • Fire hydrants: The City requires developers to install as required by the City Engineer, fire hydrants and connections, which hydrants and connections shall be of a type approved by the Escondido Fire Chief.
• Public Sewer system: When the City Engineer determines that, by reason of the size and shape of the proposed lots, the nature of the terrain to be subdivided, the soil condition of the lots and the development of the area in the vicinity of the proposed subdivision, a public sewer system serving the lots will be required to preserve the public health, or if there is a public sewer main within two hundred (200) feet of the property boundary, the developer shall be required to install or agree to install a public sewer system serving said lots as a condition precedent to the approval of any Final or Parcel Map.
• Undergrounding Utilities : All new and existing utilities distribution facilities, including cable television lines and other communication facilities within the boundaries of any new subdivision or within any property abutting a proposed new subdivision, shall be plac ed underground pursuant to the requirements of Escondido Municipal Code. • Flood Control: The developer is required to install all flood control and drainage improvements in conformance with the drainage policies of the General Plan, the Drainage Master Plan, the Engineering Division Policy for Drainage Studies, and City design standards. • Street Trees: The developer is required to install street trees as required by Escondido City standards pursuant to the landscape standards of the Zoning Code. • Traffic Control Signals: The developer is required to install such traffic control signals as may be required by the City Engineer, Planning Commission or City Council.

Building Codes and Enforcement
The City of Escondido has adopted the 2019 California Building Code. The City has also adopted the 2019 Green Building Standards Code. No amendments have been made that diminish the ability to accommodate persons with disabilities. There are no locally amended universal design elements; the universal design provisions of the California Building Code are enforced. Exceptions or methods of alternative compliance to the requirements of the California Building Code are contained in the code.

The City has no local ability to waive the provisions of the State building codes. However, a mechanism within the building code allows for an appeal process to challenge interpretations of the building code requirements.

The Code Enforcement Division, which is a section of the Community Development Department, enforces applicable building codes. Code enforcement is reactive and prioritized based on risks to health and safety. However, code enforcement remains complaint-based and investigates complaints to determine appropriate steps for correction. Code Enforcement also refers households that may quality for assistance to the City’s rehabilitation programs.

Permits and Processing Times
Government Code section 65943 states that local governments have 30 days after an application for a housing development project is submitted to inform the applicant whether or not the application is Attachment "5"
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complete. If the local government does not inform the applicant of any deficiencies within that 30- day period, the application will be "deemed complete", even if it is deficient. If the application is determined to be incomplete, the local government shall provide the applicant with an exhaustive list of items that were not complete pursuant to the local government’s submittal requirement checklist.

Information not included in the initial list of deficiencies in the application cannot be requested in subsequent reviews of the application.

The processing time needed to obtain development permits and required approvals is commonly cited by the development community as a prime contributor to the high cost of housing. Depending on the magnitude and complexity of the development proposal, the time that elapses from application submittal to project approval may vary considerably.

The Community Development Department is currently preparing a development processing guide with the newcomer to the permit process in mind. It details the steps involved in obtaining a zoning or building permit(s) – from preliminary review through final approval. This information will help people who have had little or no experience with the building permit process. Experienced building professionals will also find information about the required amount of processing time useful for their scheduling and/or seek streamlining opportunities.

Processing Times
Factors that can affect the length of development review on a proposed project include: completeness of the development application submittal, responsiveness of developers to staff comments and requests for information, and projects that are not exempt from the California Environmental Quality Act (“CEQA”), require rezoning or general plan amendment, or are subject to a public hearing before the Planning Commission or City Council.

Certainty and consistency in permit processing procedures and reasonable processing times is important to ensure that the development review/approval process does not discourage developers of housing or add excessive costs (including carrying costs on property) that would make the project economically infeasible. The City is committed to maintaining comparatively short processing times. Total processing times vary by project, but most residential projects are approved in six months. Table 47 provides a detailed summary of the typical processing procedures and timelines of various types of projects in the City.

Table 47: Processing Time by Development Type
Project Type Reviewing
Body
Public
Hearing
Required
Appeal Body
(if any)
Estimated Total
Processing Time
Single-Family Subdivision Planning Commission Yes City Council 3-6 months Multiple-Family Staff/
Administrative No Planning
Commission 12-20 weeks
Multiple-Family (with subdivisions) Planning Commission and City Council Yes None 4-6 months
Mixed-use Planning Commission
and City Council Yes None 4-6 months
For apartment projects, processing periods normally require an administrative review and take approximately 12 to 20 weeks from the time of submittal of a complete application to the time of construction. Below are the required steps in the following order:

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• Submit Plot Plan Application
• Environmental and Plot Plan Review
• Building and Grading Permits Construction Plans Submittal • Resubmit Construction Plans as needed.
• Permits Issued
Other residential development proposals require administrative, Planning Commission, or City Council approval as shown below:

Administrative Approval
Staff review – up to 10 weeks:
• Lot Line Adjustments
• Certificates of Compliance
• Parcel Maps
• Administrative Adjustments
• Accessory Dwelling Units
Planning Commission Approval
Public hearing – up to 16 weeks including environmental review:
• Conditional Use Permits
• Grading Exemptions (for grading exceeding requirements) • Precise Development Plans
• Tentative Subdivision Maps
• Variances
City Council Approval/with Planning Commission Recommendation Public hearing – up to 26 weeks including environmental review:
• Zone Changes (rezones and pre-zones)
• General Plan Amendments
• Extensions of Time for Tentative Subdivision Maps
• Planned Developments
• Specific Plans
• Condominium Permits
• Habitat Loss Permits
• Development Agreements
City Council Approval/with Planning Commission Recommendation The processing time for the most common residential development applications are summarized in Table

48. These applications are often processed concurrently. The City continues to explore ways to streamline Attachment "5"
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the processing of applications and reduce fees for redevelopment/ rehabilitation of affordable, fair market and mixed-use housing. The City also explores ways to encourage development of housing for middle- and high-income households in order to promote a balanced community. The City conducted an evaluation to streamline processes and processing times. Specifically, the City consolidated the Design Review Board into the Planning Commission. In so doing, the City eliminated one step in the review process, thereby shortening the timeframe of review.

Table 48: Processing Time by Process / Permit
Process/Application Time
Conditional Use Permit 3-6 months
Design Review 0 weeks (concurrent review)
General Plan Amendment 4-6 months if no public vote is needed Environmental Impact Reports 9-12 months
Plan Check/
Building Permits
15-20 working days for plan check, or longer depending on resubmitted plan checks and how fast architect responds to corrections
Variance 3-6 months
Zone Change 4-6 months
Source: City of Escondido Planning Department, 2020.

Design Review Process
The design review process is regulated by Municipal Code Chapter 33, Article 64. The purpose of design review is to preserve the natural charm, integrity and quality of the built environment, by regulating the design and appearance of development in order to ensure compatibility with existing development and ensure that new development is consistent with or exceeds the high quality of the development projects currently located in the City.

Design review takes the following into account: site development, circulation, grading, setbacks, exterior appearance of buildings, structures, signs, lighting, street furniture, landscaping and other outdoor appurtenances. The review of plans is done either by City staff or by the Planning Commission in conjunction with other discretionary reviews. Depending on the project approval, Planning staff review the projects for compliance with the design review standards and provides recommendations to the Planning Director regarding administrative projects that require design review, or the Planning Commission. In order to gain approval, the following findings must be made:
• The proposed site plan has been designed in a manner which is compatible with the natural and urban characteristics of the site and the surrounding neighborhood. • The bulk, scale, and architectural design of the proposed structure is compatible with the character of the surrounding neighborhood.
• The project incorporates landscaping, irrigation and screening which is drought tolerant, appropriate for the site, and in compliance with the landscape standards established by the city.
• All grading related to the project conforms to design standards set by Article 55 (grading and erosion control).
• The project incorporates applicable design review standards contained in the Zoning Code and other applicable ordinances into the site layout and building design.

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• The project is consistent with the goals and objectives on the General Plan.

These findings are reasonable and do not constrain housing development in the City. Typical revisions required by staff or the planning commission include: changes to landscape materials; building elevation details / enhancements / articulation; changes to colors; and minor site plan adjustments. Usually, these changes can be accommodated without increasing the costs of development.

Decisions of the Director may be appealed to the Planning Commission by filing a written request to the Planning Division within ten days following the final decision of the Director. Decisions of the Planning Commission may be appealed to the City Council.

Conditional Use Permit
A conditional use permit is a zoning instrument used primarily to review the location, site development or conduct of certain land uses. These are uses which generally have a distinct impact on the area in which they are located, or are capable of creating special problems for bordering properties unless given special attention. The Planning Commission has the authority to grant, conditionally grant or deny a conditional use permit application, with one exception: The decision on whether or not to issue a conditional use permit for residential care facilities for the handicapped lies with the Director of Planning and Building. In order to be approved, the Planning Commission must make the following findings:
• A conditional use permit will be granted upon sound principles of land use and in response to services required by the community.
• A conditional use permit will not be granted if it will cause deterioration of bordering land uses or create special problems for the area in which it is located. • A conditional use permit must be considered in relationship to its effect on the community or neighborhood plan for the area in which it is to be located.

Planning Commission decisions can be appealed to the City Council. Most residential uses are permitted by right in residential zones. Therefore, the CUP process does not serve to constrain housing development.

Environmental and Infrastructure Constraints
A community’s environmental setting affects the feasibility and cost of developing housing.

Environmental issues range from the availability of water to the suitability of land for development due to potential exposure to seismic, flooding, wildfire and other hazards. If not properly recognized and accommodated in residential design, these environmental features could potentially endanger lives and property. This section summarizes these potential constraints on residential development in Escondido.

Soil, Steep Slopes, and Seismic Safety
Regulation of development in areas of steep slopes is directly related to public safety and health, as the degree of slope is related to flood control problems, erosion control, landslides, and fire hazard.

These problems become particularly acute on slopes greater than 25% . Accordingly, many communities, including the County, map slopes greater than 25% , recognizing them as potentially hazardous areas. Similarly, many of the soil compositions that comprise the Escondido Planning Area present difficulties for development in that they cannot support roadways or foundations, are unacceptable for septic systems, and are highly erodible.

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The historical seismicity of the San Diego region is low compared to the rest of Southern California.

This may be due to San Diego’s locatio n on a more stable block or it may only reflect a period of historical record which is too short to be meaningful. San Diego County has experienced strong shaking and damage from several earthquakes, but none of the recent ones have been particularly destructive.

All of the faults which could affect San Diego County are part of the San Andreas system of faults.

The portion of California west of San Andreas fault is part of the Pacific plate and is moving north with respect to the rest of the continent which is part of the North American plate. This movement is distributed among several faults in addition to the main San Andreas Fault. In and near San Diego County these other faults include the San Jacinto, Coyote Creek, Earthquake Valley, Agua Caliente, Elsinore, Rose Canyon, San Miguel (Mexico), Agua Blanca (Mexico), and Coronado Banks (off shore).

The largest fault in the San Diego region, the San Andreas Fault, is at least 800 miles long and is located 27 miles east of Borrego in the Coachella Valley. There is increasing concern that the 85- mile section from north of San Bernardino to the Salton Sea is overdue to rupture, having been “locked” for the last 200 years. Such an event could cause an 8.3 magnitude earthquake - the size of the 1906 San Francisco quake. An 8.3 event on the San Andreas would subject San Diego County of shaking of intensity VII to VIII, enough to cause considerable damage.

East of San Diego the closest active fault is the Elsinore Fault, which passes through the town of Elsinore, along the south side of Palomar Mountain, through Lake Henshaw, Santa Ysabel Indian Reservation, down Banner Canyon east of Julian, and out in the desert near Vallecitos. The Elsinore Fault apparently joins the Laguna Salada Fault on the east side of the Sierra Cocopah in Baja California. The Elsinore Fault is probably capable of generating an earthquake of magnitude 7.4.

Depending upon which segment moved, considerable damage might occur in Escondido, Ramona, Julian, Borrego, and Jacumba. Portions of all of the roads to the east would probably be temporarily closed by landslides.

The Community Protection and Safety Element of the City’s General Plan includes goals, policies, and actions that are designed to reduce the risks of hazards related to soil, steep slopes, and seismic activity, such as the strict enforcement of standards from the Uniform Building Code and the requiring of specific geotechnical reports.

Flood Hazards
There are sections of the City that would be subject to inundation in the event of a 100-year storm.

These areas include northern portions of Reidy Creek north of Rincon Avenue, an area alongside Escondido Creek west of Hale Avenue, along Kit Carson Park Creek north of Via Rancho Parkway, an area straddling Midway Drive north of the Escondido Channel, and an area straddling Valley Parkway between Ash and Citrus.

The Community Protection Element of the City’s General Plan includes policies to designate appropriate land uses to minimize flood related damages and to ensure proper creek and channel maintenance to ensure their water-carrying capacity.

The City maintains floodplain standards to minimize flood risks to existing and proposed developments. Projects built in the floodplain area may be subject to additional findings and risk mitigation, but the floodplain standards do not prohibit or constrain housing developments located within the floodplain. The City has recently approved a 145-unit affordable housing project (Quince Attachment "5"
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Street Senior Apartments) that was partially built within the floodplain. The recent project example demonstrates that flood hazards do not create actual constraints on development.

Hazardous Materials
Hazardous materials represent a potential threat to those who are working with the materials and those who could be affected by its improper or accidental disposal. The cleanup of hazardous wastes from the past and the handling and disposal of newly generated wastes will affect people many generations from now. Site contamination may impair the City’s ability to implement this Plan by increasing the costs of development, requiring certain land use restrictions, and causing delays while necessary cleanups are implemented. The policies presented in the Community Protection Element of the City’s General Plan are intended to protect the public from existing and future hazardous contamination problems.

Ridgeline and Hillside Conservation
One characteristic that distinguishes Escondido from other communities in the region is its location in a series of valleys that are surrounded by visually distinctive hillsides and ridgelines. The varied topography has been identified as one of Escondido’s most important assets – one that has helped create the City’s distinct identity. To protect these assets, the City outlined a series of policies in its Resource Conservation Element that are geared toward controlling development on the hillsides and along the ridgelines.

Water Supply
Water supply for the City stems primarily from two sources: local water, derived from precipitation, and stored in Lakes Henshaw and Wohlford, and imported water transmitted by the San Diego County Water Authority. A master plan, administered by the City ensures the adequacy of these facilities to meet the demands imposed by development projected over the General Plan horizon. Continued urban development will place increasing demands on these supplies. Potential limitations on the availability of supplies require the need to combine long-term planning for water supply with long- term planning for community development in Escondido. Limited areas of the City are provided water service by the Rincon del Diablo Water District.

The 2012 Water Master Plan was prepared at the same time and under the same assumptions as the 2012 Escondido General Plan Update, which identified new growth within the same East Valley area as that contemplated for the East Valley Specific Plan. The General Plan Update considered a range of 3,350 to 5,825 new residential units that would be added to the General Plan’s build-out projection of approximately 67,900 dwelling units. The plan describes a number of capital improvement projects over the next thirty years, including water recycling, demand management measures, and conservation rebates to ensure the availability of water to meet the City’s projected build-out.

Wastewater Capacity
Escondido’s wastewater is treated at the Hale Avenue wastewater treatment plant, conveyed over land, and discharged through an ocean outfall. A Master Plan, administered by the City, ensures the adequacy of these facilities to meet the demands imposed by development projected over the General Plan horizon. Significantly, the availability of sewer service distinguishes between urban Attachment "5"
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development and rural development. Thus, the extension of services and the availability of capacity will influence how much and where Escondido grows.

The Environmental Impact Report ( “EIR”) for General Plan Update concludes that existing wastewater treatment capacity is not adequate to accommodate the growth anticipated under the General Plan Update, which would add over 9,400 units by 2035. The Escondido Water and Wastewater Division (EWWD) updated its sewer master plan to ensure adequate sewage treatment capacity to serve the projected buildout population of the updated General Plan. Wastewater demands in the Escondido service area, resulting from the 2021-2029 Housing Element sites inventory, has already been studied and accommodated by the 2012 Wastewater Master Plan.

Adequate sewage treatment capacity is projected to accommodate the growth allowed under the current General Plan and Sixth Cycle Housing Element.

Priority for Water and Sewer Services
Much of the new housing growth is expected to occur within the EVSP area. Adequate water and sewer services are available to accommodate the City’s projected Regional Housing Needs Assessment. Nevertheless, Senate Bill 1087 (enacted 2006) requires that water and sewer providers develop written policies that grant priority to proposed development that includes housing affordable to lower-income households. The legislation also prohibits water and sewer providers from denying or conditioning the approval of development that includes housing affordable to lower income households, unless specific written findings are made. As the water and sewer service provider, the City will include a policy in this Housing Element to prioritize services. The City will also provide a copy of the adopted Housing Element to the Rincon del Diablo Water District, which serves portions of the City, within 30 days of adoption. The City will continue to coordinate with Rincon to ensure priority service provision to affordable housing developments.

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5. Housing Resources
Regional Housing Needs Assessment
The Regional Housing Needs Assessment (“RHNA”) allocates to each city and county in California a “fair share” of the region’s projected housing needs by household income group. The major goal of the RHNA is to ensure a fair distribution of housing among cities and counties within their respective regions, so that every community provides an opportunity for a mix of housing for all economic segments.

The San Diego Association of Governments (“SANDAG”) adopted its RHNA in July 2020 for the Sixth Cycle Housing Element, which covers an eight-year planning period (April 2021 through April 2029) and addresses housing issues that are related to future growth in the region. The housing allocation targets are not building requirements, but goals for eac h community to accommodate through appropriate planning policies and land use regulations. Allocation targets are intended to ensure that adequate sites and zoning are made available to address anticipated housing demand during the planning period.

Escondido’s share of regional future housing needs is a total of 9,607 new units for the period of April 15, 2021, to April 15, 2029; it is the third highest allocation in the SANDAG region. This allocation is divided into various income categories, as shown in Table 49. The RHNA was distributed to jurisdictions in the region using a formula that accounted for access to public transit and employment. The RHNA al so includes a fair share adjustment, which allocates future need by each income category in a way that meets the State mandate to reduce the overconcentration of lower-income households in one community.

Table 49: RHNA Allocation by Household Income (2021-2029) Above Moderate Moderate Low Very Low Total
4,967 1,527 1,249 1,864 9,607
Note: The City has a RHNA allocation of 1,864 very low income units (inclusive of extremely low income units). Pursuant to State law (AB 2634), the City must project the number of extremely low income housing needs based on Census income distribution or assume 50% of the very low income units as extremely low. Therefore, the City’s very low income RHNA is split into 932 extremely low and 932 very low income units. However, for the purpose of identifying adequate sites for the RHNA, no separating accounting is required.

Credits Toward RHNA
Housing units that are approved, under construction, or developed with building permits issued after June 30, 2020, can be credited toward this Sixth Cycle RHNA. Table 50 summarizes these particular units. Many of these units were achieved through recycling of existing lower -intensity uses in the Downtown and South Centre City Specific Plan areas; some are in single-family subdivisions in more suburban/rural areas of the City.

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Table 50: Credits Toward RHNA
Credits toward RHNA Above Moderate Moderate
Income
Low Income Total
Approved 1,002 90 155 1,247
Entitled or Under Construction (permitted after July 1, 2020) 355 0 0 355 Projects in Review 649 0 371 1,020
Total 2,006 90 526 2,622
Entitled Units
A project converting a vacant golf course began construction prior to July 1, 2020. The project is entitled for 380 total units, and in May 2020 received building permits for 25 units, including model homes. A total of entitled 355 units remain unpermitted as of July 1, 2020, but have since obtained permits or will obtain permits and will begin construction during the Sixth Cycle RHNA planning period.

All of these units are expected to be affordable to above moderate-income households (see Table A- 1 in Appendix A).

Approved Units
Projects that were approved but had not been issued building permits prior to July 1, 2020, are included in the RHNA as credits. The list of approved projects is included in Table A -2 in Appendix A: RHNA Credits. In total, the City has approved 1,247 units (1,002 above moderate units, 90 moderate income units, and 155 low income units) units, which are expected to be constructed during the Sixth Cycle planning period.

Units Undergoing Entitlement
In addition to projects that have already been approved, the City is currently processing entitlements for another 1,020 units, including 371 units expected to be affordable for low income households. The City anticipates that these units will be approved and constructed during the Sixth Cycle planning period. The list of projects undergoing review is included in Table A-3 in Appendix A: RHNA Credits.

Regardless of planned densities, these projects are counted toward the RHNA based on the income/affordability levels proposed by the projects.

Development Trends, Yields, and Realistic Capacity for Housing Much of the future development in Escondido is expected to occur within Downtown Escondido and in the South Centre City and East Valley areas. The Downtown, South Centre City, and East Valley areas of Escondido are characterized by a variety of underutilized commercial development and lower-intensity residential uses. Recognizing the need for additional housing and commercial employment opportunities, the City Council has adopted or is preparing specific plans for each of these areas to attract investment and encourage the production of housing for all income levels. Recently constructed or approved projects demonstrate the potential and likelihood that these areas will continue to see increased levels of housing production at and--with density bonuses for inclusion of affordable housing--above the maximum density allowed under zoning.

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Very High-dDensity (75-100 du/ac)
Escondido’s Downtown Specific Plan was amended in 2012 to allow for residential densities of up to 75 and 100 dwelling units per acre (du/ac) through a majority of the planning area. In recent years, developers have pursued various projects in very high-density areas, including projects that incorporated commercial/mixed-use components as well as affordable and market-rate housing. A review of 14 recent projects found that developments in areas allowing 75 and 100 du/ac had an average residential yield of 80% of the maximum allowed. These trends clearly illustrate that the very high-density residential and mixed-use zoning in Escondido’s Downtown are actively incentivizing residential production at a variety of income levels.

While some of these recent projects were exclusively residential, the City identified nine different mixed- use projects built or proposed on sites with densities of 75 or 100 du/ac. These sites had an average yield of 69% of the maximum. Additionally, one of these projects is a statistical outlier, as it was a small commercial project that included a single unit. Generally, mixed-use developments have trended towards larger projects, and with the single outlier excluded, achieved an average yield of 77% of the maximum allowed on very -high-density sites. The City Council h as authorized the Community Development Department to remove mandatory ground floor commercial requirements from the Downtown Specific Plan. This action is anticipated to be completed in 2021. While the City is already experiencing high development yields in mixed-use projects and zones, the greater zoning flexibility will provide additional opportunities for residential development in Downtown, and likely increase densities beyond historic trends.

Medium-High-dDensity (12-45 du/ac)
The City allows for housing at 12 to 45 du/ac throughout most of the South Centre City Specific Plan, portions of the Downtown Specific Plan, and in R -2 through R-5 zones throughout the City.

Developments at these densities have consisted of mixed-use apartment complexes, affordable housing, and compact townhomes. A review of 15 recent and proposed projects illustrates that many developments are taking advantage of density bonuses and are achieving densities greater than the maximum permitted by the underlying zoning. On average, projects in this density range have been built close to or above the maximum allowed.

The single mixed-use project located in a zone allowing up to 30 du/ac achieved a density of 90% of the maximum allowed by zoning. While the City does not typically require mixed-use development at these densities, and is removing ground floor commercial requirements from the Downtown Specific Plan, the single mixed-use project illustrates that mixed-uses at these densities is feasible and likely to yield close to the maximum residential units allowed.

Lower Density Residential (0-11 du/ac)
The City has approved or is processing a number of lower -density, single-family subdivisions. A review of 24 of these projects found that these properties are developing at approximately 79% of the maximum allowable densities.

Affordable Housing Development
Escondido has seen substantial growth in the affordable housing stock of its Downtown area in recent years, with multiple developments taking advantage of density bonuses to construct additional lower income housing. A review of the recent and proposed affordable housing projects shows that affordable housing developments average approximately 114% of the maximum units allowed by the Attachment "5"
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underlying zoning. This average is skewed down by a single, low-density suburban development that is affordable to seniors, which yielded only 62% of the maximum allowed. Multi -family projects with affordable housing have an average yield of 124% of the maximum allowed by zoning, and have been constructed in zones allowing between 12 and 100 du/ac. Furthermore, affordable housing has been constructed on non-vacant lands, with previous uses including warehouses, small medical facilities, single-family homes, and arterial commercial centers.

Based on recent affordable housing development in the City, it is reasonably expected that new affordable housing will continue to utilize density bonuses and construct more units than the base zone would otherwise permit.

Table 51: Affordable Housing Yields
Project Description Size
(Acres)
Zoning
Density Yield %
SUB 20-0002 - Habitat for Humanity 10 condos at 245 E. El Norte 0.57 12 147% ADM 20-0136 - 664 N. Fig Street 15 apartment units 0.59 18 140% PHG 15-0009 - Solutions for Change
Housing
33 affordable units & 1,120 SF
commercial 0.79 30 140%
PHG 14-0020 - Veterans Village 48 new units (54 total) + 1,500 SF commercial on 1.8 ac. 1.76 30 91%
ADM 20-0070 - 337 E. Valley Pkwy 50-unit affordable housing 0.57 75 118% Touchstone – Ivy 4 story, 95 new units 1.04 75 122%
PHG13-0010 - Meadowbrook 66-unit senior units 24.38 4.36 62% PHG 17-0028 - Quince Senior Housing 145-unit affordable senior housing 1.48 100 98% Source: Escondido Major Development Project Processing List, August 2020.

Small Lot Development and Lot Consolidation
State law requires that sites used to accommodate lower incomes be between 0.5 and 10 acres.

Escondido’s Downtown core generally consists of smaller lots that do not meet the 0.5-acre minimum.

Many of the smaller lots meet the intent of the HCD eligibility guidelines. The density allows projects of 15 or more units on each site, which enables incorporation of affordable housing. The very high densities also create a strong incentive to consolidate smaller parcels. Escondido has many small parcels and consolidation for redevelopment is very common. Lot consolidation is not a significant impediment to housing development in the region or Escondido. It occurs as part of the normal course of the land development process and is common to a significant percentage of development projects. It occurs as part of the market conditions without incentive or subsidy as demonstrated by the projects described below.

The City has seen multiple examples of developers assembling and consolidating smaller lots to create a larger overall project site. The Touchstone - Ivy project at 343 E. 2 nd Avenue, which is being
developed for fully affordable housing, involved the assemblage of six different parcels that were previously developed for a large medical office building (Escondido Surgery Center). The building construction was expensive frame on podium over parking and the site had a very low land-to- improvement ratio of 0.37, demonstrating that the permitted residential density can make consolidation and development of expensive non-vacant sites viable, when the existing uses are no longer viable. The 1.0-acre site has since been purchased by an affordable housing developer that is proposing 95 affordable units (95 du/ac) . The Iwashita Apartments at 322 South Escondido Boulevard involves the consolidation of seven lots with different ownership to construct the 17280- Attachment "5"
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unit 6-story mixed-use apartment complex on a total of 1.28 acres (134 du/ac). The existing lots are between 0.16 acre and 0.32 acre, with previous uses including used car sales, single-family homes, and small medical offices, with land to improvement ratios above 1. Another project at 829 South Escondido Boulevard involves redevelopment of a 1-story small strip commercial building complex on three lots, with sizes ranging from 0.16 acre to 0.32 acre, being consolidated to allow for a 7021- unit apartment complex on 0.66 acres (32106 du/ac), with half several of the units reserved for lower income housing. The three parcels have land to improvement ratios both above and below one (depending on the parcel), illustrating that properties with low existing improvements and high net unit potential are exhibiting trends of redevelopment.

The City has seen many other examples of parcels that have been consolidated to provide a larger site for a housing development. Veterans Village, along South Escondido Blvd. and W. 15th Avenue consolidated six parcels, including several smaller than 0.5 acres, to build 54 -unit affordable apartments on 1.8 acres (30 du/ac) for veterans and their families. Another affordable housing project, Valley Seniors Village at the corner of Valley Parkway and Ivy Street (337 E. Valley Parkway) , aggregated five extremely small lots (each less than 0.2 acres) to provide a 0.41-acre site for a proposed mixed-use building with 20 units (50 unit affordable-housing project ( 49119 du/ac).

Finally, four existing single-family home lots are proposed to be consolidated to create a 1.0-acre site for a 44-unit (44 du/ac) apartment complex at the corner of South Escondido Boulevard and Vermont Avenue in the South Centre City Specific Plan. These recent and proposed projects provide direct evidence that lot consolidation is common and feasible in Escondido and is not a significant constraint, even when providing affordable housing. Lot consolidation for parcels smaller than 0.5 acres has been used frequently and contributed to multiple affordable housing projects. Therefor e, the City expects this trend to continue throughout the sixth cycle and is accounting for lot- consolidation when projecting for the number of potential low-income sites within the sites inventory.

These examples of consolidation of small lots into larger sites for redevelopment are common and the characteristics of the parcels in these examples are typical of the proposed RHNA sites in terms of location, existing or prior land uses, lot size, land -to-improvement ratios, and permitted development density. Additional examples of these RHNA site typologies and recent redevelopment projects with similar characteristics are provided in Appendix B, Sites Inventory . The list of sites includes land use, improvement to land value ratios, age of structures, and the number of units that could be added to a property to help demonstrate the viability of each parcel.

State law requires that sites used to accommodate lower-income RHNA units be between 0.5 and 10 acres. Based on the recent trends of lot consolidation for housing projects, including affordable projects, the City considered adjacent parcels with a cumulative size above 0.5 acres as able to accommodate lower -income units. All properties included for lower -income units either have individual sizes between 0.5 and 10 acres, or cumulative/consolidated sizes between 0.5 and 10 acres. Sites that otherwise would be eligible for lower -income units but that did not meet the size requirement were deemed appropriate for moderate income households. Escondido currently facilitates and expedites lot consolidation through a ministerial process for basic lot consolidation. The City continues to encourage consolidation of lots to facilitate mixed-use and affordable development (see Program 1.1). The City is proposing a program to evaluate incentives to help identify, promote and facilitate lot consolidation and development on small lots.

Realistic Capacity and Development Likelihood Calculations Based on the recent Specific Plan Amendments spurring housing development in the Downtown, South Centre City, and semi -rural areas, there is a strong likelihood that developers will continue to Attachment "5"
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invest in Escondido during the Sixth Cycle planning period. While recent project trends demonstrate the feasibility and likelihood that developers will continue to build at and above the allowed density, the City recognizes that some projects may not be constructed to their maximum potential, or otherwise may not be constructed during the planning period. In response, the City has adjusted its assumptions with respect to the realistic and expected development potential. As explained below, the methodology for projecting the development potential and likely project yields for the proposed East Valley Specific Plan (“EVSP”) differ from those used for the South Centre City and Downtown Specific Plan areas.

East Valley Specific Plan
The EVSP contains mechanisms to ensure that developers build close to the site’s maximum potential. For the mixed-use and urban residential districts, the plan sets both minimum densities and a target production point (“TPP”). Applicants are encouraged to meet and exceed the TPP; in cases where they develop below the TPP, the applicant is required to pay an in-lieu fee. Based on the EVSP’s strong incentives for developing at and above the TPP, s ite capacity in the EVSP was calculated by multiplying the TPP density by the site acreage, and did not include any additional downward adjustments. T he TPP densities shown in Table 52 were utilized when calculating residential potential in the East Valley plan area.

It is important to note that the EVSP also is establishing a Density Transfer Program (“DTP”) to enable the City to transfer densities from undeveloped or underutilized properties (i.e. sending areas) within the EVSP to developing properties (i.e. receiving areas). The program would increase the probability that the anticipated number of dwelling units in the EVSP area could actually be achieved by allowing a developing property to increase its density beyond what current zoning would permit when other properties have underdeveloped to less than the maximum density. The transfer density would be held in a Density Credit Pool until assigned to a particular development project. The EVSP DTP establishes a creative land use strategy reflective of changing needs, resources, and conditions to maintain flexible land use management and to encourage the full build-out of the East Valley area. The EVSP DTP is an optional program - and would allow property owners to re-assign or transfer units only if they wanted to. That is, if a property owner chooses to not maximize their development rights and build-out their site to its full potential, the EVSP DTP allows for the transfer or remaining and unused housing density to another, future project in the EVSP area.

Table 52: Site Capacity Estimation (EVSP)
Land Use
Designation Applicable Zoning Minimum Density
(du/ac)
Maximum Density
(du/ac)
Target Production
Point
Urban IV/V R-5-30 21 30 25
Mixed-use M-U 20 80 45
Note: Nonresidential zones of the EVSP were not considered for housing production.

Source: EVSP Draft Land-Use Scenarios
Areas Outside of the East Valley Specific Plan
RHNA sites located outside the EVSP area are not subject to a TPP, so an alternative method of determining site capacity and development likelihood was used. As noted above, project trends generally indicate that housing throughout the City is being built near the maximum allowed density, and for affordable projects, above the maximum allowed density. While recent production trends indicate that site capacity could reasonably be estimated at the maximum density allowed by zoning, Attachment "5"
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some developments will likely be built at lower densities. Additionally, some of the identified sites may not be developed during the Sixth Cycle planning period, further necessitating a downward adjustment for the realistic capacity. Due to these considerations, the City is estimating that properties with densities of 0 to 45 du/ac will be built to 75% of their maximum allowed, while properties with densities between 46 and 100 du/ac may achieve 62.5%50% of the maximum allowed by the underlying regulations. Recent trends suggest that this assumption is highly conservative, and significantly underestimates the number of units that are likely to be constructed on these very high- density sites during the planning period.

Table 53: Site Capacity Estimation (Non EVSP)
Density Range (du/ac) Assumed Capacity Factor
0-45 75%
46-100 62.5%50%
Property Yield Calculation
The acreage of the property is multiplied by the allowed density and the yield factor to establish the likely number of units that the site could accommodate. This “estimated yield” was then rounded to the nearest integer. The number of existing units (based on 2020 Assessor data) is subtracted from the likely yield to get the number of “net new units” per parcel.

𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑌𝑌𝐸𝐸𝐸𝐸𝑌𝑌𝐸𝐸 = 𝐸𝐸𝐸𝐸𝑠𝑠𝐸𝐸 (𝐸𝐸𝑎𝑎
𝑎𝑎𝐸𝐸𝐸𝐸𝑎𝑎𝐸𝐸) ∗ 𝐸𝐸𝐸𝐸𝑑𝑑𝐸𝐸
𝐸𝐸𝐸𝐸𝑑𝑑 �𝐸𝐸𝑑𝑑 𝐸𝐸𝑎𝑎� � ∗ 𝐴𝐴𝐸𝐸
𝐸𝐸𝑑𝑑𝐸𝐸𝐸𝐸𝐸𝐸 𝐶𝐶𝐸𝐸𝐶𝐶𝐸𝐸𝑎𝑎𝐸𝐸𝐸𝐸
𝑑𝑑 𝐹𝐹𝐸𝐸𝑎𝑎𝐸𝐸𝐹𝐹𝑎𝑎
𝑅𝑅𝐹𝐹𝑑𝑑𝑑𝑑𝐸𝐸
𝐸𝐸𝐸𝐸 𝑌𝑌𝐸𝐸𝐸𝐸𝑌𝑌𝐸𝐸 = 𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸
𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸 𝑌𝑌𝐸𝐸𝐸𝐸𝑌𝑌𝐸𝐸 𝑎𝑎𝐹𝐹
𝑑𝑑𝑑𝑑𝐸𝐸𝐸𝐸𝐸𝐸 𝐸𝐸𝐹𝐹 𝑑𝑑𝐸𝐸𝐸𝐸𝑎𝑎
𝐸𝐸𝐸𝐸𝐸𝐸 𝑤𝑤ℎ𝐹𝐹𝑌𝑌𝐸𝐸 𝑑𝑑𝑑𝑑𝐸𝐸𝑛𝑛𝐸𝐸𝑎𝑎
𝑁𝑁𝐸𝐸
𝐸𝐸 𝑈𝑈𝑑𝑑𝐸𝐸𝐸𝐸𝐸𝐸 = 𝑅𝑅𝐹𝐹𝑑𝑑𝑑𝑑𝐸𝐸
𝐸𝐸𝐸𝐸 𝑌𝑌𝐸𝐸𝐸𝐸𝑌𝑌𝐸𝐸 − 𝐸𝐸𝐸𝐸
𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝐸𝑑𝑑𝑎𝑎 𝑈𝑈𝑑𝑑𝐸𝐸𝐸𝐸𝐸𝐸
Density and Affordability Levels
State law (Assembly Bill 2342/Government Code 65583.2) uses allowed density as a proxy for income/affordability for the sites inventory. Depending on the size and urbanization of the jurisdiction, different default densities are presumed to support lower -income units. Escondido is classified as a “jurisdiction in a metropolitan county,” which has a default density threshold of 30 du/ac for lower - income units.

Generally, single-family homes (0-11 du/ac) are presumed to be affordable to above moderate income households, while townhomes and garden-style apartments (12-29 du/ac) are presumed to be affordable to moderate income households. Properties with densities at 30 du/ac or greater are presumed to be suitable for both low and very low income units per AB 2342. Higher -density properties are also anticipated to be able to support both moderate- and above moderate-income households. All lower-income sites identified in the sites inventory have allowed densities of 30 du/ac or greater.

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Table 54: Affordability by Density
Income Density Range (du/ac)
Above Moderate 0-11
Moderate 12-29
Low 30+
Very Low 30+
Methodology for Identifying Sites to Accommodate the RHNA The City of Escondido has few vacant parcels suitable for residential development, particularly in areas proposed for higher-density housing. The City’s comprehensive General Plan update in 2012, along with updates to the Downtown and South Centre City Spe cific Plans, focus new residential growth into Escondido’s downtown and urbanized core, an area with excellent access to transit, services, employment, and amenities. Due to the complexity of assessing the City’s nearly 29,000thousands of parcels for redevelopment suitability and likelihood, a comprehensive GIS-based analysis was used to identify underutilized sites across the City that are considered likely to redevelop within the Sixth Cycle.

Sites that were included are generally free of environmental constraints and have existing structures and uses that will likely be replaced and redeveloped for housing. Such conditions include large parking areas, older buildings, marginally operating businesses, nonconforming uses, and a capacity for a substantial increase in dwelling units.

General Assumptions
Constraints
Properties with constraints that may preclude development, such as on-site historic structures or being on conserved lands or agricultural preserves, were removed from consideration for the sites inventory.

The City also evaluated the potential for Floodplains to act as a constraint on housing production, particularly in Downtown Escondido and the EVSP. The City currently allows the same development in its 100-Year Floodplain as is allowed in the underlying zoning. While housing projects in the floodplain may require different engineering and construction methods, recent projects have demonstrated that this was not a constraint. For example, the Quince Street Senior Housing, a 145 - unit affordable housing project, achieved a density of 100 du/ac in the floodplain. Based on the City’s standards and recent projects, no additional capacity deduction was implemented in the 100- year floodplain.

Sites within the 100-year floodway (the main channel of flowing water as opposed to the floodplain) are excluded from the sites inventory.

Major Developments and Building Permits
Any parcels that are/were part of a major development or had new commercial or residential building permits issued since 2013 were removed from consideration, as the recent construction would be presumed to be a constraint on near-term redevelopment.

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Existing Land Use
The existing use of a property can create a significant constraint for redevelopment. The City used SANDAG Series 14 Land-Use information to determine the existing use of a property. Sites with the following existing land uses were removed from consideration for the sites inventory:
• Cemetery
• Elementary Schools
• Police/Fire Station
• Jr. College
• Jr. High School
• Dumps/Landfills
• Lakes/Reservoir/Large Pond
• Landscape Open Space (often HOA
Lots)
• Mobile Home Park
• Multi-Family Residential
• Open-Space Parks/Preserves
• Other Group Quarter Facilities
(Congregate Homes/Dorms/etc.)
• Other Transportation Features
• Other University/College
• Railroad Right of Way
• Residential Under Construction
• Road Right of Way
• School Under Construction
• Senior High School

Methods for Identifying Suitable Underutilized/Non-Vacant Sites The vast majority of the sites with General Plan land use designations and zoning for high-density residential development are in older, urbanized areas that are largely developed or used to some degree. There are very few vacant sites in such areas. The following section summarizes the three primary criteria methods used for identifying suitable underutilized, or non-vacant, sites. Each of the three criteria (land-to-improvement ratio, building age, and net new unit ratio) was established at a level that is adequate to qualify a site as underutilizedbased on the single criterion. However, due to the very large number of potentially eligible sites, a minimum of two of the three criteria were used to identify the best sites. This resulted in a total of 888 sites with a total potential of 9,463 units. It is noted that 45% of the sites and 55% of the potential units meet all three of the criteria.

Beyond these criteria for determining underutilized sites, additional site selection criteria and factors were also considered that make the sites excellent candidates for development within the next eight years. The additional criterial include:
• Sites within ½ mile of a transit stop (92%, 8,739 units) • Sites within ¼ mile of services, employment, and community facilities (86%, 8,112 units)
• Sites within a specific plan that includes high density zoning, infrastructure, programs, incentives, and plans and commitments that support housing and improved quality of life (87%, 8,208 units)
• Location within areas exhibiting redevelopment, recycling of non-vacant sites, and construction of new market rate, affordable housing, and mixed-use development (87%, 8,208 units)
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• Low-moderate density lots with capacity to add new units without displacing existing units (14%, 1,365 units)

Land to Improvement Value Ratio
Based on County Assessor provided data, the land to improvement ratio for each parcel was calculated by dividing the assessed land value by the assessed improvement value. A high ratio (1.0 or above) illustrates that the land is more valuable than the improvements on the land, and that the site is likely appropriate for redevelopment due to the low relative value of existing structures.

Properties with land to improvement ratios above 1.0 are considered underutilized and were presumed to have improvements that would not constrain the site for the redevelopment of housing and were included in the inventory. A review of several recent projects (discussed in the Development Trends section above) showed that many properties that were recently redeveloped had land to improvement ratios above 1. While the recent history is not comprehensive, it does illustrate that using the land to improvement value ratio can identify sites that are likely to be redeveloped during the planning period. A land to improvement ratio of 1.0 or greater is a conservatively high factor. It is noted that several recent redevelopment projects included ratios below 1.0. One had a ratio of only 0.37, indicating relatively expensive building improvements. Yet, the value of the development potential permitted by the zoning and promoted by the specific plan still made a relatively expensive site viable for residential development. Furthermore, while the building structures may be valuable, given the current trends of retail and office uses, many of these properties are not generating adequate revenues from rents or business to sustain long-term operations.

Despite this, the City did experience several instances of redevelopment where the previous land to improvement ratio was below one, indicating more substantial and valuable structures while the existing uses are no longer viable.

In many instances, the land to improvement value of a property does not fully capture the site conditions indicating suitability for redevelopment. As noted above, a minimum of two of the three criteria were used to select the best sites. Therefore, sites with land to improvement ratios less than 1.0 were only included if the sites inventory also includes properties with land to improvement values below 1.0, provided that both of the following conditions are met:
• Existing structures are more than 31 30 years old (building age); and • The assumed project yield (new net units ratio), after deductions of 37.5%50% for mixed- use or 25% for residential, are at least five times the number of existing units on the site.

Properties that had no residential units and land to improvement ratios less than 1.0 were included provided the structures were more than 3130 years old and the net new units ratio is above 5, based on the assumption that the permitted residential density will continue to provide a strong incentive for redevelopment. These requirements are described further below.

Building Age
Building age is a strong factor in determining whether a site is underutilized or otherwise ripe for redevelopment. This is particularly true when combined with the land to improvement ratio and/or the net new unit ratio. County Assessor data was used to identify the age of structures throughout the City. For sites with land to improvement ratios below 1.0 (indicating that the improvement is more valuable than the land), the eExisting improvements that aremust be at Attachment "5"
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least 3130 years old, an age which indicate that a site may be suitable for redevelopment. As the natural lifespan of the building ends, the original capital investment has been recovered and maintenance costs increase dramatically. Approximately 50% of the buildings in the inventory are over 50 years old (built before 1970). Almost 70% are over 40 years old (built before 1980).

Escondido City CouncilMarch 22, 2023

Escondido City Council
March 22, 2023