111924 CED Housing Element Resolution Housing Element — City Council - Successor Agency - Housing Authority, November 19, 2024 (part 2 of 2)

1313 Foothill Boulevard Suite 2 | La Canada Flintridge, CA 91011 | 310 395 2580 | www.columbuspacific.com We appreciate your consideration of the Burlington Parcel for inclusion in the HIOZ zoning. Depending on the final regulations that are passed, we believe that having the flexibility to provide housing in this area would benefit the community and help the City of Fullerton meet its regional housing needs . We look forward to doing our part to continually help make Fullerton a more accessible and profitable city.

Sincerely,

RICHARD A. MARGOLIS
[email protected]

P 310 395 2580 ext. 233 C 310 508 7888
___________________________________
23632 Calabasas Road | Suite 107
Calabasas, CA 91302

From: Kayla Asato <[email protected]>
Sent: Friday, June 21, 2024 5:08 PM
To: Eric Levitt <[email protected]>; Daisy Perez <[email protected]>; Kim Chaudhry <[email protected]>; [email protected] Cc: Shana Charles <[email protected]>
Subject: [EXTERNAL MAIL]Kayla Asato - OCEJ Housing Element Notes and Comments

Hello Fullerton City Manager's Office,

I'm not sure who I'm supposed to email regarding my thoughts and comments on the Fullerton Housing Element, so I thought that I'd just email everyone in the City Manager's Office. I can't find the consultant's email so I'm hoping that it's okay to just email all of you.

I've gotten fairly far in the Housing Element document, but not all the way through, so hopefully you're okay with some of my comments and thoughts on the matter.

Included in this document, I provide my thoughts on building new housing (up until section 4.1) and on strategies for tackling homelessness (still combing through section 4.4 unfortunately) from an Environmental Justice lens. I think that the Housing Element is phenomenal, but there are some questions and thoughts that I have regarding safety and environmental health since those seem to be excluded from the conversation (in my opinion)

Kayla Asato
she/they pronouns
OCEJ Political Organizer

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Housing● Building housing○ Helping developers■ (1.4f) host annual workshop with developers to provide education about technical assistance and incentives for larger and smaller rental units with a goal of supporting development for 50 large (3-4 bedroom) units and 100 studio/1-bedroom units● Sounds good to me tbh■ (1.7c) directs the city to issue a competitive Notice of Funding Availability to identify a non-profit affordable housing developer to partner with on new developments in the city and support entitlement of at least 400 subsidized units to affordable to extremely-low, very low, and low-income households● Problem: why include “affordable” in that 400? Why not just 400 low-, very low-, and extremely low-income households with a separate number for “affordable” just to ensure that we have separate goals for this○ (4.2.1.1) Housing Production■ (4.2.1.1a) HIOZ zoning updates allow for property owners to develop more housing and allow for 3647 very low-income, 2115 low-income, and 4341 moderate-income units. The zoning update will take place by December 29, 2024● Problem: are there health and safety standards for HIOZ housing? Assuming that I’m understanding Government Code section 65583.2(h) correctly, it sounds like there are some basic plumbing and utility provisions and if it’s under the jurisdiction of a property manager, it should probably be good for human habitation in terms of pipes and mold. It would probably be good to confirm that by adding something about that into the action though.■ (4.2.1.1b) The city will develop a procedure to track unit count and income/affordability assumed on parcels included in the site inventory to see if it matches up with the RHNA needs. (4.2.1.1c) The city will also check with the individual sites and make a site map public to private or non-profit developers. The goal would be to talk with developers once every six months to ensure sufficient capacity for the development of 3198 very low, 1989 low, 2271 moderate, and 5751 above moderate● Sounds good to me● Problem: If this is for RHNA, why aren’t there any goals for extremely low-income housing if we’re trying to track development?■ (4.2.1.1d) Would amend the zoning code to require by-right approval for housing developments that include AT LEAST 20% affordable to lower-income households by December 31, 2024. ● It sounds like it would require increasing the housing stock for approved projects. And I’m SO SO SO FINE with that if I’m understanding it correctly ○ Reviewing and updating the development review process (4.2.1.2)■ Expedite and improve the review process to streamline things and make it faster. This would also monitor average processing times for new housing projects and permit processes to make sure that things move smoothly● Problem with 4.2.1.2e Streamline the CEQA review process by utilizing exemptions or tiering, particularly for infill development, consistent with State Law: CEQA review processes have been mandated by state law and urged municipalities to look at environmental factors currently impacting the parcel in question AND the impacts that construction would have on it. However, cities across OC have been primarily focusing on the second part and more or less ignoring the first part. ○ Solution: keep everything included there AND include specific parts of the CEQA review process that would urge the city to research the land that they’re developing on AND ensure that that part isn’t exempt. We want to ensure that any infill development is on healthy land so that people don’t get sick when we are building more housing. ESPECIALLY because it’s infill development. This doesn’t mean that we shouldn’t build in areas currently toxic. Just that we need to make it public and start remediation before we develop there● Everything else looks good though○ Facilitating infill development (4.2.1.3)■ Maximize the density potential of limited land by promoting residential densities that allow for dense housing AND put it near high-quality public transit stops (1.3a), monitor land and outreach to homeowners’ and neighborhood associations where there is mostly single-family residential areas AND could be areas of denser housing (1.3b), review development standards to determine effectiveness and update where appropriate (1.3c), provide technical assistance to applicants that want to develop on their land AND prioritizing applicants that support low- and moderate-income housing (1.3d), evaluate commercial parking standards to ensure that it accommodates for housing needs (1.3e), conduct outreach to religious institutions and provide technical assistance to interested parties to develop affordable housing on religious grounds (1.3f)● Sounds good to me● Problem: just make sure that there are CEQA evaluations of the land where the infill is gonna be built. And if there are serious concerns, ask that there be a plan in place AND DIRECT CITY STAFF TO PROVIDE ASSISTANCE BY HIRING ON AN ENVIRONMENTAL JUSTICE STAFFER○ Support the development of a variety of housing types (4.2.1.4)■ This includes ADUs, light-touch density housing, duplexes, triplexes, fourplexes, and missing middle households. Evaluate the city website to ensure compliance with new transparency requirements (1.4a); create a page on the city website with map-based inventory that identifies vacant/nonvacant housing development sites including multi-family residential and mixed-use sites (1.4b); maintain a current inventory of major residential and housing developments on the city website, and promoting new housing developments through social media platforms (1.4c); develop a web-based Housing development toolkit that outlines a step-by-step process for residential development (1.4d); reduce minimum unit sizes and update the zoning code to do so and include housing co-operatives, single-room occupancy, dormitories, tiny homes, and collective home ownership models in the city (1.4e); encourage development of smaller rental and larger rental units in residential and mixed-use developments within the 12 focus areas (1.4f); review the general plan to do those things too (1.4g); prepare a market feasibility report on all of these (1.4h); remove single-family residences as permitted use in the multi-family zones to make sure that if something is multi-family that it stays multi-family (1.4i); reduce parking minimums and garage requirements while preparing parking feasibility studies to assess requirements in consultation with housing developers (1.4j); amend the zoning code to permit manufactured housing (1.4k); encourage developers to build multi-family homeownership by providing flexible development standards (1.4l); partner with CSUF and Fullerton College to develop a plan for off-campus housing (1.4m)● Everything sounds fine except for parking requirements being waived since parking is already a big issue across Fullerton and developers don’t care about the parking requirement issue○ Community Outreach Strategy for Housing (4.2.1.5)■ The city housing game plan will be extensive, have a one-stop shop online portal with speaker series, demographic categories and maps, community participation opportunities, and links to development and housing resources, print media, mailers, speakers’ bureaus, social media, and other ways unique to the City of Fullerton (everything would be multilingual to account for language barriers)● Is there a list for which languages the city will reach out in? I assume that this will be Spanish and Korean, but will there be any other languages? Like Tagalog and Arabic?■ The city will collaborate with service providers, nonprofits, employment-related organizations, teachers, associations, and other agencies to advertise the Housing Game Plan (1.5a); implement a citywide policy to provide services to people with limited English proficiency, particularly Spanish speakers, and analyzed demographic compositions of communities to see if any other languages should be accommodated (1.5b); review city’s outreach methods annually with resident feedback surveys and discussions with community organizations (1.5c)● Honestly looks good to me. I really like the “analyze demographic compositions of communities to see if any other languages should be accommodated” part although I’m wondering if Arabic will be included in that because they still may count as white on the census by the time of these outreach efforts○ ADUs (4.2.1.6)■ City ADU ordinance was last updated in 2022 to incorporate urban lot splits. Monitor ADU distribution to ensure that it is done throughout the city through targeted outreach and if goals are unmet by January 2027, the city will implement ¼ actions (1.6a); develop a virtual 15-minute ADU permit meeting for applicants to streamline the process (1.6b); assist and educate homeowners by posting pre-approved ADU standards on the city website by January 2025 for English and Spanish (1.6c); monitor updates to state ADU law and ensure zoning compliance (1.6d); promote the development of ADUs in high-resource in northern Fullerton (1.6e)● Looks great to me○ Support the production of regulated and affordable housing for all income levels (4.2.1.7)■ The City is committed to maintaining, developing, and monitoring affordable housing and will prioritize low and very-low-income households for development and seek funding opportunities and partnerships from state, federal, and county funds to write down the cost of land for the development of affordable housing. The City will also provide greater permit streamlining, fee reductions, and other possible measures and incentives to support affordable housing development● Problem: why exclude extremely low-income households?■ The City will review a potential Congregational Overlay Zone to allow churches and other faith institutions to build permanent supportive housing and/or deed-restricted affordable housing (1.7a); actively promote sites available for affordable housing to anyone that wants to build, including incentives to CHDOs, but still monitoring them to ensure they actually build (1.7b); acquire funds from local, state, and federal grant opportunities to support the development of affordable housing for special needs and supportive service projects and also partner with the OC Housing Finance Trust (1.7c); pursue development via a competitive Request for Proposals in compliance to recent updates to the Surplus Land Act (1.7d); adopt written policies and procedures for the City of Fullerton Utility Services Department that grants priority to proposed developments pursuant to Government Code Section 65589.7 (1.7e)● Looks great to me. This is just saying that they will support looking for money and pursuing development and written policies ● Problem: will there be CEQA investigations for the actual housing? I know that it would be mentioned in other sections, but I think it would be great to reiterate here too● Improving existing housing○ (3.1a) explore financial incentives for property owners for environmentally friendly building improvements such as solar panels, water efficiency upgrades, induction cooking, outdoor water conservation AND priority given to units that are affordable, lower, and moderate-income households■ Sounds good to me tbh ○ (3.1b) directs the city to create infrastructure project priority checklists to support infrastructure for public transit and active transportation such as walking/biking and prioritizing low- and moderate-resource areas■ Sounds good to me tbh I just feel like we should have checklists for everything when it comes to building affordable housing (including low-extremely low) AND shelter oversight and permanent supportive housing○ Where they are looking at improving housing conditions ● Environmental factors● How much housing○ Intended housing■ Housing for whom?● (2.3) housing for people overpaying (paying over 30% of income to rent/mortgage), housing resulting form overcrowding, housing resulting from population growth, housing from converting existing housing● (2.3) housing for elderly people, large households, persons with disabilities, female-headed households, homeless persons, farm workers, people in need of emergency shelter, and students

○ Projected needs based on population● What kind of housing? Homelessness (Policy action 4.4)● How much housing?○ Problem: Includes the emergency shelter at Bridges (200 beds) and things could absolutely be substantially better there. So we REALLY NEED the oversight stuff■ Is Bridges counted as Anaheim or Fullerton? ■ Is Anaheim counting Bridges in their numbers for open beds? Is Fullerton? We should probably remove Bridges since it mostly services Anaheim. In the FULLERTON housing element, we shouldn’t be counting it if we’re sending people over to Anaheim○ Emergency shelters include places that have a maximum of 50 beds■ Problem: Why 50 beds maximum? Is that a du/ac thing?■ Problem: what are the requirements for safety for the unhoused people? ● Nothing is saying that the emergency shelter/multi-service center needs to have decent drinking water, accessible drinking water throughout the duration of the shelter being open, mold-free walls and pipes, and just generally fit for human habitation (maybe aside from the density requirements)● Are there any requirements for the staff and how they treat members of the unhoused community?○ Is basing the numbers off of the 2022 Point in Time Count■ Problem: that was after the RV ordinance removed a lot of people who would otherwise be in Fullerton. Is that something that we’re okay with?■ Problem: the Point in Time Counts are always inaccurate and often undercount people ESPECIALLY when we consider shelters and people moving from place to place. I get that we don’t have a better metric though. Maybe we should add a bit of a buffer to add numbers to the Point in Time Count???● Problem: PIT count will never be accurate considering it's usually paid to one nonprofit to conduct. For example, City Net is compensated by the county/COC over 500k. It's conducted over what a 1 to 2 day period during the middle of winter. It will always be skewed. They should go off the survey that schools give to parents and students which demonstrates the numbers are exceptionally higher for families/students.

● What kind of housing?○ (4.4a) Pursue federal, state, and regional funds for homeless service providers that operate temporary, permanent, and emergency shelters in the city that assist persons experiencing homelessness and at risk of becoming homeless and directs the city to assist at least 272 people■ Problem: what are the standards and environmental factors taken into account for these temporary, permanent, and emergency shelters? ● Currently in North County, many of the homeless shelters have mold, toxic substances in the water, horrible staff, and more. What are the requirements gonna be for treating people with dignity?● The Continuum of Care (COC) does not use the VI-SPDAT and the TAY triage assessment anymore to determine the vulnerability of each unhoused individual, which is used throughout SoCal. What are they using now to determine the eligibility of whose most at risk and vulnerable for housing?■ Problem: will these permanent shelters be Permanent Supportive Housing?● The shelters need more transparency about how long each individual is staying there. There should be a visible timeline that shows goals. For example, each person should be matched with a voucher in less than 90 days (like LAHSA). ■ Problem: why only 272 people if you’re also taking into account people AT RISK OF BECOMING homeless?● The Point in Time Count looked at around 272 unhoused people in 2022 and those counts are super inaccurate. It could be better to assist at least 300 people currently experiencing homelessness, with intentions to service more if the Point in Time Count numbers are wrong○ (4.4b) directs the city to annually assess and report the capacity to accommodate individuals experiencing homelessness including existing shelter beds, new shelter beds, identify if those shelter beds are available on a year-round or seasonal basis, average number of shelter beds that are used on a monthly basis, and number of those exiting shelter to permanent housing■ Problem: how will you assess if someone is exiting shelter to permanent housing? A lot of the problem with the shelter system is that the staff is corrupt, negligent, and incompetent with providing wrap-around services. ■ Problem: if we are using existing shelter beds, then we are going to be including some negative and punitve environmental factors, so we are gonna need to examine some of those and the environmental justice conditions in some of those shelters■ Suggestion: we need long-term studies on what the unhoused community needs. We need a city Committee or Task Force dedicated to gathering input from the unhoused community regarding environmental factors, availability of resources, intake and PSH programs, treatment by staff, navigating the HMIS system, and the long-term psychological/health impacts of being in the shelter system vs getting PSH● What is the long-term impact of individuals staying in shelters for years? People often get dropped out of the HMIS and have to start all over again. ● People are often matched with the Rapid Rehousing Program which is a short term program for people that can transition into regular housing. Most people who stay long-term in shelters need PSH but are misinformed and take RRH. Then they end up unhoused again ○ (4.4c) Partner with the Illumination Foundation to incentivize property owners/managers with available units to rent to formerly homeless individuals and families■ Problem: Illumination Foundation is pretty notorious for its awful treatment of unhoused people. I think they’re the primary subject of the lawsuit by the ACLU but I could be wrong (yes they are one of the defendents)● So who will be overseeing the transitions of the available units to rent to formerly homeless individuals and families?● Also, what does it mean by “formerly homeless” does this just mean that people would now be housed through this renting program? Kayla just wants to make sure.● Why the Illumination Foundation?○ (4.4f) Directs the city to provide financial support to organizations that provide transitional housing for emancipated transitioned-age foster youth who are homeless or at immediate risk of becoming homeless■ Problem: will we be doing oversight of these organizations too? Who will be doing the oversight? ■ Use TAY TRIAGE assessment for eligibility ■ Could we create a city commission to oversee the shelters and organizations in terms of fiscal oversight AND processes to house people?○ (4.4g) City zoning code would have to change to comply with recent state law including allowing supportive housing with up to 50 units and low barrier navigation centers by-right in zones where multi-family and mixed-uses are permitted■ Sounds good to me tbh○ (3.1) Supportive housing = no limit on length of stay, occupied by target population, provides significant level of onsite or offsite services that assist the resident in retaining the housing, improving health status (including HIV/AIDS and substance abuse), maximizing ability to live, and work in the community■ Problem: uses “his or her” and it could just be more gender-inclusive imo■ Problem: are there any limits on who can enter? Like is there a drug requirement? A “you can’t be housed with your life partner” requirement? A “no pets allowed” requirement? ● What’s the process?● Environmental factors? ○ Problem: No explicit considerations are paid to this. The Fire Department (that the city is contracting out for) is responsible for safety inspections. No additional or specified requirements for what constitutes “toxic and hazardous wastes” OR even any mention of general living conditions about “hazardous mold” or “contaminated drinking and usable water” or general EIR reports (that would HOPEFULLY look at what the status of this unit is in the first place).■ Homebuyer Assistance● What units?○ (2.3a) make funds available to community-based organizations to acquire and rehabilitate abandoned or otherwise lost units and sell them to very low and low-income first-time homebuyers with the objective of assisting 10 very low and low income households■ Problem: what are the standards gonna be for the “rehabilitation” and which units would classify for this? ■ Problem: what would “assisting” mean?○ (4.4b) city expands funding for information and referral services that direct families and individuals to financial resources for housing rental or purchase■ Sounds good to me tbh ○ (4.7a) partner with the county and community orgs and advocates to increase participation in homeownership workshops and assistance programs■ Sounds good to me tbh● What sort of assistance?● Who is overseeing the assistance? Public Outreach (Appendix D)● What was the process? ● How many meetings?

CITY OF FULLERTON
To: Chris Schaefer, Planning Manager Fullerton
(714) 738-6884
[email protected]

From: Curtis Gamble, Activist/Veteran (714) 854-4561 [email protected]

Subject: Revised Draft Housing Element 2021-2029

Dear Mr. Schaefer,

Please, include the following information in the Fullerton Revised Draft Housing Element 2024.

Rapid Rehousing units are an alternative to emergency shelters for the Homeless the Veterans, the CSUF Students, the OCTA Bus Drivers, the Seniors and the Low-Income Community.

Thank you,

Curtis Gamble, Activist Homeless/Veterans

Please read the following:

PROPOSAL..... December 21, 2016

SETTLEMENT AGREEMENT
Legal Aid Society of Orange County Curtis Gamble v. City of Fullerton, et al., No.30-2015-00824970-CU-T- CIC (the "Gamble Action").

2. The City agrees that it will commit the minimum sum of $1 Million to increase the number of Extremely Low Income and Rapid Rehousing units in the City.

Extremely Low Income units are units that are affordable to, and occupied by, persons whose income is at or below 30% ofthe area median income as defined in Health and Safety Code sections 50053(b) and 50106.

Rapid Rehousing units are an alternative to emergency shelter. and are occupied at no rent or subsidized rent for a limited time to allow a household to collect sufficient funds for move-in deposits and moving costs.

The sum shall be expended or committed to be expended by September 30, 2019 only as follows:

a. City shall use this funding to assist with the creation of a combination of at least twenty (20) units of Rapid Rehousing and Extremely Low Income units, which shall include at least ten (10) Extremely Low Income units.

These units shall be secured by an Affordable Housing Agreement and affordability covenants committing the units for Rapid Rehousing and Extremely Low Income occupancy, as applicable, for a term of at least thirty (30) years.

Both the Affordable Housing Agreement and the affordability covenants shall be duly recorded with the office of the Orange County Recorder.

The mix of the Rapid Rehousing and additional Extremely Low Income units beyond ten (10) units shall be determined in the Affordable Housing Agreement.

City shall work with operators of regional emergency shelters to facilitate placement of shelter clients into the Rapid Rehousing units.

The terms of the Affordable Housing Agreement shall be in accord herewith

b. If, (l) at least twenty (20) housing units are not created or contractually committed to be created as described in 2.a. above by December 31 , 2017; or (2) any balance of the $1,000,000.00 funding remains to be committed or expended for the purposes as described in 2.a. above, said remainder or balance shall be applied to assist in the creation of Extremely Low Income units in the City intended to be occupied by two or less persons.

Any such units shall be secured by similar recorded affordability covenants for a term of not less than thirty (30) years as described in 2.a. above.

c. The Court will retain jurisdiction pursuant to Code of Civil Procedure section 664.6, to enforce this section of the Settling Parties' Agreement until the earlier of December 31, 2019 or such time as the $ 1M fund is fully committed to be expended as described in (a) or (b) above with appropriate affordability covenants secured by contract and recordation.

3. The City will pay via check to Legal Aid Society of Orange County in trust for each Plaintiff, the sum of twenty thousand dollars ($20,000) each to Plaintiffs Curtis Gamble and James Mayfield, solely for the purpose of assisting the Plaintiffs to secure permanent housing, within thirty (30) days of the Effective Date.

The Settling Parties explicitly acknowledge and agree that the City has no legal duty to provide housing for Plaintiffs or to assist Plaintiffs with housing placement, and that the Plaintiffs have no legal duty to obtain the City's direction or approval in seeking to secure permanent housing.

Attorneys' Fees and Costs.

Within 30 days of the Effective Date, the City agrees to pay via check to Legal Aid Society of Orange County and Western Center on Law and Poverty} the amount of $475,000 as full satisfaction for Plaintiffs' claims for attorneys' fees and costs in the Actions, except only as othenvise reserved in this Agreement

The sum shall be expended or committed to be expended by September 30, 2019 only as follows:

https://drive.google.com/file/d/1VXAqYmoP5g2zxfLwasiaWobo5mI2fsbx/view?usp=drivesdk

December 21, 2016

SETTLEMENT AGREEMENT

From: Bac Tran <[email protected]>
Sent: Friday, June 21, 2024 1:56 PM
To: Sunayana Thomas <[email protected]>; Chris Schaefer <[email protected]>; Eric Levitt <[email protected]> Cc: Bac Tran <[email protected]>; Kim Tran <[email protected]> Subject: [EXTERNAL MAIL]Request for the 4.0 acres of land to be considered in the Fullerton Housing Element

Hello Chris, Eric and Sunayana,

We have owned the following 4.0 acres of land in Fullerton. We hereby request for these pieces of land to be considered in the Fullerton Housing Element to satisfy part of the SCAG affordable housing requirements.

1. 3.0 Acres, 921 Laguna Road, Fullerton CA 92835 APN: 292-251-17, 292-251-18, 292-251-19, 292-251-20, 292-241-10

2. 1.0 Acre, 931 Laguna Road, Fullerton CA 92835
APN: 292-241-09
Thank you so much for your consideration in this matter.

Sincerely,
Bac Tran

J A N E R E I F E R ⬧ ⬧

July 1, 2024
Chris Schaefer, AICP, Planning Manager
City of Fullerton Community and Economic Development
303 W. Commonwealth Ave.

Fullerton, CA 92832-1775

Re: Fullerton Revised 2021-2029 Housing Element

Dear Mr. Schaefer,

Thank you for the opportunity to comment on the revised draft 2021-2029 Housing Element.

Provide Affordability AND Preserve Unique Environments
Fullerton has a unique feel and characteristics that should be preserved WHILE addressing affordable housing needs. Many older European, African and Central and South American cities restrict new construction to new districts, preventing insensitive structures in the historic and semi- rural areas. Some of the unique attributes are: historic landmarks / districts, historic-age or -eligible resources, Preserve America status, the original townsite, semi -rural areas, vernal as well as year - round creeks and riparian areas, and existing neighborhoods with a mix of cultures and incomes.

Prevent Speculation & Displacement/Incentivize Lower Levels of Housing Affordability The intensity of streamlining will open the city up for speculative housing investors which will accelerate housing costs, so there should be more proposals preserving existing affordable housing and prioritizing incentivizing the lower levels of affordability rather than then the above-moderate levels which continue to pressure prices upward.

When the City has an opportunity to require inclusionary housing or build nonprofit -led higher volumes of majority affordable housing on municipally–owned land, it has often chosen to ignore the option. The Amerige Court project should focus on 100% affordability – not 10% (while retaining historic buildings on Malden and Amerige: Monzon garage/rare cast stone ; Mission Press/ historic freezer-locker; corner former auto dealer; She-She Hair Design/Fullerton notable Shim Masukawa. These are not currently des ignated but are eligible, as documented in my comments on that previous project.)

Opportunities to build affordable high -density development projects for the areas designated in the General Plan have been squandered and poorly coordinated. R ather than building tens of thousands of units , t he Housing Element should prioritize non-profit projects that provide a higher percentage of affordable units or we’ll end up streamlining “too many” above-market units and not enough lower levels of affordability. We should have programs to allow mobile home park residents to buy out their park , resources devoted to new car / camping facilities, SROs and

rehabbing older buildings rather than only building new. There don’t seem to be any policies for assisting renters being displaced as there were with former Redevelopment Agency projects. A new policy to reverse the loss of at-risk housing should be created.

Prevent Significant Changes to City’s Ambience and Significant Impacts on the Environment by Focusing on Truly Affordable Housing, Not Incentivizing Market Rate The City should focus on non -profit assisted affordable housing. Market rate homes don’t need subsidy as they will be built regardless, independently meeting the City’s RHNA requirements.

Address Exceeding GP Buildout and Reduce Significant and Unavoidable Effects Where can the review that determined that the Housing Element is internally consistent be accessed? Also, what are the anticipated proposed General Plan amendments?

Group Homes
The City could devise a new, lower CUP fee structure for large group homes rather than removing the CUP requirement.

Density Bonus Clarification
Do the potential housing unit numbers account for units added by density bonus? If so, what percentage of total units will be at affordable levels?

Public Participation
The public was never noticed about Housing Champion meetings in their initial phase so that group did not get the benefit of public comment at the initial stages. Even if not legally required, it is important to mail notices to residents throughout the city who live in or own property next to new proposed HIOZ zoning. Also, there should be notification of even proposed by-right development activities so the public can provide relevant information. (See paragraph below that lists missed designated historic resources.)

Fullerton Needs More Focus on Integrating Public and Active Transportation Bus, rail, biking, and walking should be considered an essential part of general civic infrastructure.

Asking new developments to pay impact fees to cover the cost of the new demand they induce is an accepted, routine practice for roads, schools, libraries, parks, and parking structures. Transit needs to be a part of the impacts we consider when planning, both for long -term service implementation and short -term construction detours. As part of this standard inclusion, construction projects should discuss th eir potential impacts on the above transportation modes, both during construction and at the completed project. The fees should include the extra money it costs to provide and to communicate detours to the users of the above modes. The Fair Share Policy is a good start.

Fullerton Needs to Do a Better Job of Preserving Natural Areas, Historic Structures and Historic Corridors
Fullerton is a Preserve America city, and prides itself on its historic homes, businesses, and neighborhoods, but it’s stunning to learn how few protections these historic resources have. The vast majority of historic-age and designation-eligible properties in the city could be torn down at any time with a simple demolition permit; this has happened over and over again.

Unfortunately, the majority of historic structures in Fullerton are not designated as such. Worse, the City’s database often does not acknowledge even designated historic structures. Fullerton has missed several of these recently: Bastanchury Creek Greenbelt, which was a designated future city park and a part of pre -history, Euclid Creek at the Pines project, 142 and 144 N. Yale Ave (did not acknowledge preservation zone status), removal of Mariola Apartments character-defining features, ironwork attached and a mural painted on the historic Amerige Block with absolutely no acknowledgment of the building as a historic resource, Pathways of Hope project at 508 -514 W.

Amerige resulting in demolition of historic-age structures adjacent to designated cultural resources (luckily recently preserved), inadequate CEQA analysis of Fox Block cultural resources impact in the infill exemption , and the Amerige Court project’s several designation -eligible buildings on Malden and Amerige.

Also missing is a discussion about viewsheds and adjacent historic properties and districts within an APE. Maps should note historic-age structures so policies can be explored. For example, along Commonwealth and Chapman near the historic downtown neighborhoods, and Harbor Blvd between the downtown and Valencia Mesa Dr. This would also preserve a type of non -official “scenic” corridor / historic vista that currently exists de facto.

Fullerton Needs to Do a Better Job of Preserving Scenic Corridors The city historically ignores its designated scenic corridors and rural streets in most project analyses. Recent examples are the Harbor Complete Streets Project, Hillcrest Park renovations, the Bastanchury Creek Greenbelt development, and the Pines at Sun rise Village. Trees that are part of scenic corridors are routinely removed without assessment.

Themes in Community Input
I’d like to see acknowledgement of the widely held concern about retaining Fullerton’s unique features rather than converting so much of the built env ironment to architecture that’s indistinguishable from other cities. Not all cities need to shift to citywide high-density; some built areas should be a retreat from that, while still addressing housing affordability.

Thank you for your time and attention to these issues,

Sincerely,

Jane Reifer
2 303 W. Commonwealth Ave.

Fullerton, CA 92832
www.cityoffullerton.com

From: Judith A.Kaluzny <j >
Sent: Sunday, June 30, 2024 6:15 PM
To: David Lopez <[email protected]>
Subject: [EXTERNAL MAIL]FW: comment on revised draft housing element

Judith A. Kaluzny
Fullerton, California 92832
714

From: Judith A.Kaluzny [mailto:j ]
Sent: Sunday, June 30, 2024 5:30 PM
To: '[email protected]'
Subject: comment on revised draft housing element

The key thing is recreational space in a city that has high density. As Daniel Burnham said, father of the Chicago plan, every person should live within walking distance of a park. I’ve spent time in Chicago and in Berlin, a high density city, and in Berlin there are many small parks, small playgrounds.

If a crowded city does not have the relief of some nature, people will not be mentally healthy. Like rats crowded in a cage go crazy. We’ll have higher crime and violence rates.

We do want healthy citizens, yes?

jak

Judith A. Kaluzny
Fullerton, California 92832
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THOMAS B. MAYHEW CHARLES J. HIGLEY
September 12, 2024
Via E-Mail
Chris Schaefer
Planning Manager
Community and Economic Development Department
City of Fullerton
303 W. Commonwealth Ave.

Fullerton, California 92832
E-Mail: [email protected]
Re: Draft Housing Element Update for City of Fullerton (June 2024 Draft) Comments of Housing Action Coalition
Dear Mr. Schaefer:

On behalf of the Housing Action Coalition,1 we write to comment on the draft 2021-2029 Housing Element for the City of Fullerton. The draft Housing Element does not meet the City’s obligation to plan and provide for affordable housing. Absent substantial revisions before adoption, it may be found to be in violation of state law.

Below, we identify three significant issues to be addressed as Fullerton continues to work on formulating a valid Housing Element. First, Fullerton has included a number of sites that do not have a realistic likelihood of becoming housing during the next eight years, as required to meet its share of the regional need. Second, Fullerton’s capacity estimates fail to take into account the realistic capacity because they do not adjust for the probability of nonresidential development. Third, Fullerton’s approach of keeping higher density sites away from residential areas through height limits – and therefore siting most of the housing counted towards the lower income categories of the RHNA in industrial parks and lower resourced areas of the city – is also in violation of the obligation to affirmatively further fair housing (“AFFH”). 1 The Housing Action Coalition is a nonprofit that advocates for building more homes at all levels of affordability to alleviate California’s housing shortage, displacement, and affordability crisis.

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A. The Draft Site Inventory Includes Sites That Are Not “Suitable And Available” Because They Do Not Have A “Realistic And Demonstrated Potential” For Redevelopment During The Planning Period To Meet The Need For Housing.

One of the most concrete aspects of any housing element is the inventory of land “suitable and available” for residential development to meet the city’s regional housing need by income level. Government Code § 65583(a)(3); HCD Housing Element Site Inventory Guidebook at p. 1 (https://www.hcd.ca.gov/community-development/housing- element/docs/sites_inventory_memo_final06102020.pdf). The list is a specific means of evaluating whether the City has adequately planned for development of housing for all income levels.

Where nonvacant sites are listed on the sites inventory, there must be a “realistic and demonstrated potential for redevelopment” during the next eight years. Government Code § 65583(a)(3). To address past abuses – including where cities list unrealistic sites in order to avoid required rezoning – the California Legislature created a high standard for listing sites that are currently being used for something other than housing. Where nonvacant sites are used to address over 50% of the need for affordable housing for those with lower incomes, the City must show the realistic and demonstrated potential for redevelopment by making formal findings that the existing use does not impede residential development “based on substantial evidence that the use is likely to be discontinued” during the planning period. Government Code § 65583.2(g)(2) (final sentence). The City must analyze the evidence: existing leases, market demand for the existing uses, and anything else that would indicate whether existing uses will continue.

Government Code § 65583.2(g)(1).

HCD has given guidance on what this requirement means in its June 2020 technical guidance “Housing Element Site Inventory Guidebook.” At page 27, it explains:

The housing element should describe the findings and include a description of the substantial evidence they are based on.

In general, substantial evidence includes facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts. An example of substantial evidence would be a nonvacant site with a grocery store and with a building lease expiring in a year, and evidence that the store has entered into a lease to relocate to another site subsequent to the lease expiring.

Examples of substantial evidence that an existing use will likely be discontinued in the current planning period include, but are not limited to:
- The lease for the existing use expires early within the planning period, - The building is dilapidated, and the structure is likely to be removed, or a demolition permit has been issued for the existing uses, Housing Element
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- There is a development agreement that exists to develop the site within the planning period,
- The entity operating the existing use has agreed to move to another location early enough within the planning period to allow residential development within the planning period.
- The property owner provides a letter stating its intention to develop the property with residences during the planning period.

If multiple sites make up a common existing use and the same factors affect each of the sites, the same findings can be used for each of the sites (e.g., an abandoned shopping mall with sites under common ownership that will not be restored to commercial use located in an area where there is recent residential development).

The “substantial evidence” would indicate the existing use will not impede further residential development or that the existing use will be discontinued during the planning period. In this type of situation, use of the same findings for each of the multiple sites would be appropriate.

However, the same finding for multiple sites in a specific area may not be appropriate if their characteristics widely vary. For example, nonvacant sites with differing existing uses and lacking in common ownership, whether contiguous or located in the same general area, may not rely on a generalized analysis. While the sites may be located in an area with common economic issues, individual owners may not wish to sell their property or redevelop their site with residential uses. In addition, each site’s existing use, e.g., grocery store, retail shop, parking lot, and offices, may have lease agreements of different lengths of time or the owner may not wish to relocate or redevelop the site with a more intensive residential use. In this type of situation, use of the same findings for the multiple sites would not be appropriate.

As explained below, the current draft prepared by Fullerton identifies a number of non- vacant sites that are not realistic, suitable and available for redevelopment. The City relies heavily on the speculative and unlikely assumption that well-established, successful existing uses will cease during the sixth cycle – which now has only five years left – in favor of affordable housing.

1. 512 N. State College: Chapman Avenue Shopping Center (APN 338-101-12)
This 8.02 acre site is described as a “small retail strip” in the site inventory, but that’s not exactly right. In fact, the Chapman Avenue Shopping Center is a busy and successful shopping center at a major intersection near the university, and contains a number of prominent chains, including an Office Depot, a Smart & Final Extra! grocery store, a Panera Bread sandwich shop, a Philz Coffee, a Pieology pizza restaurant, a ShareTea boba place, a Dollar Tree discount store, Housing Element
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an ice cream shop, a skateboard shop, and a Japanese quick-serve restaurant, and some other businesses.

Source: Google StreetView, May 2024 photo; State College side Source: Google StreetView, May 2024 photo; E. Chapman side Fullerton lacks evidence that these existing uses are all likely to discontinue during the sixth cycle. The existing uses are presumed to be an obstacle to meeting the RHNA need.

2. 104, 136, 172 N. Raymond: Grocery Outlet and other businesses (APN 033-212-11, -12, -15, -16)
The shopping center at 104-172 N. Raymond has a Grocery Outlet grocery store, a Planet Fitness gym, and an AutoZone auto-related retail shop. It also contains a popular restaurant (“Polly’s Pies,” part of a regional chain), and a Goodwill store. A pediatric dentist occupies a standalone building in one corner of the lot; a check cashing service the other far corner. The entire center had a major renovation in 2018, when Grocery Outlet (2018) and Planet Fitness (2019) moved in.2 The Housing Element provides no basis for concluding that these existing 2 The building department records show the 18,000+ square feet of plumbing, re-roofing, electrical, and sprinkler work done as the tenant improvements for Grocery Outlet in 2018.

Google StreetView shows the before and after, with January 2019 being the first “after” date for photos, a major upgrade after an earlier grocery store shut down.

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uses are all likely to discontinue during the planning period so that housing could be built to meet the need before 2029.

3. 1930 N. Placentia: Albertson’s and other businesses (APN 339-161-02, -01)
Source: Google Maps, photo dated January 2020
This 10.88 acre shopping center site is anchored by an Albertson’s/Sav-On (photo above), and has several other businesses, including my favorite barbecue restaurant in Fullerton (Brian’s Sports Bar and “Big B’s” BBQ). The BBQ place has been there since 1986; the sports bar for longer. This site should not be listed for two major reasons.

First, there is no sign that Brian’s and Big B’s are going to shut down or move, much less the Albertson’s grocery store/Sav-on Pharmacy. Fullerton lacks evidence that the existing uses are likely to discontinue, and so they are deemed to preclude residential development. (This also includes the new bakery business on the small corner parcel at 1974 N. Placentia, APN 339-161- 01, for 0.74 acres).

Second, under Government Code section 65583.2(c)(2), a site larger than 10 acres is presumed not to be suitable for lower income housing, absent an evidentiary showing that Fullerton’s draft does not attempt to make.

4. 904, 914, and 926 W. Orangethorpe: Food 4 Less and other businesses (APNs 073-310-04, -12, -22, and -23)
At 904, 914, and 926 W. Orangethorpe is a shopping center anchored by a Food4Less supermarket. In the northwest corner, there is an O’Reilly auto parts, a Subway sandwich shop, a laundromat, and a dentist’s office; in the southeast corner is a Chinese restaurant, a pizza/sports bar, a beauty supply, a nail salon, and another dentist. On the eastern edge is another bar.

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Fullerton lacks evidence that all of these existing uses are likely to discontinue before the end of the sixth cycle, just five years from now. Indeed, there is evidence that they are likely to continue beyond that. While HCD’s site inventory guidebook instructs that a lease ending “early in the planning period” with plans by the retailer to relocate would constitute “substantial evidence,” here the current Food4Less lease is publicly reported to run until 2027,3 and Fullerton lacks information about whether there are plans to renew.

5. 1250 E. Chapman: Walgreen’s
(APN 033-211-03)
As City records show,4 the Walgreens pharmacy and store was custom-built for Walgreens in 2006. These kinds of projects require long-term leases to repay the owner for the 3 https://property.compstak.com/914-West-Orangethorpe-Avenue-Fullerton/p/50309 (showing lease from 2006-2027 for Food 4 Less).
4 See, e.g., Building Department permit numbers ZON03-0078 (December 2003: request to demolish existing restaurant and market to construct drive-through pharmacy); PRJ04-00674 (July 2004: commercial building permit to create Walgreens);

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cost of having built the building just for the tenant. Only eighteen years later, it’s very unlikely that anyone plans to have Walgreens move out so that the building can be demolished to build housing; as the City’s own analysis concludes, the useful life of a retail building is considerably longer. Without evidence that the existing use is likely to discontinue, this site should be removed from the inventory.

6. 2501 E. Chapman: “University Office Park”
(APN 338-101-13)
The building named “University Office Park” at 2501 E. Chapman was renovated in 2018 and subdivided in a condominium conversion.5 It now consists of 34 separate parcels, with Assessor Parcel Numbers 933-44-401 through 933-44-434.

Photo source: Google StreetView, May 2024
The building is occupied by a large number of professionals: doctors, lawyers, and real estate agents, many of whom now own their office separately from the other owners of the building.

The City does not attempt to show that the individual owners of condominium units have a joint plan to demolish the office building and replace it with housing in the next five years. Without evidence that the existing uses are likely to discontinue during the planning period, the existing uses are presumed to preclude this property from meeting the need for housing. 5 See, e.g., https://www.rodeore.com/commercial/crm/1021338316/2501-e-chapman- avenue-106-fullerton-ca-92831 (“University Office Park is a 2-story office building built in 1986 and recently renovated in 2018 when it was entitled for office condominium conversion.”).

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7. 4101 and 4201 Bonita: Wine Country Gift Baskets
(APNs 296-202-02 and -04)
Located in a district characterized by large warehouses – the FedEx distribution center is next door – 4201 Bonita and 4101 Bonita fit right in. These two warehouses, sitting on 4.46 and

3.11 acres respectively, are both used by the same business: Houdini, Inc., dba Wine Country Gift Baskets. The company has been here since 1984. Fullerton lacks evidence that the existing use of these two warehouses is likely to discontinue during the next five years.

8. 4111 N. Palm: C&L Refrigeration
(APN 296-203-13)
The large industrial building at 4111 N Palm, on 4.25 acres, is the California headquarters of the privately held and family operated business C&L Refrigeration. The business makes industrial-sized cooling systems (for example, the refrigerated section of grocery stores), and so needs a large industrial space to do its work. The property is majority-owned by an entity named “CL Investments, LLC” (with Ronald Cassell, one of the founders of C&L Refrigeration signing documents for it6): in other words, the family running the business also owns the property, making it less likely that the property owner will change the existing use.

Fullerton lacks evidence that C&L Refrigeration is likely to discontinue use of this site during the next five years.

9. 4141 N. Palm: Adams Rite Aerospace
(APN 296-203-12)
The industrial building at 4141 N Palm is the headquarters of Adams Rite Aerospace.

The company, founded in 1896, makes over 4500 parts for the aviation industry, such as the faucets used for airplane bathrooms, and the latches for their doors. They continue to announce new contracts with major US airlines, and show no signs of going out of business. They recently agreed to a 70% rent increase, and renewed their lease for an additional 75 months (6 years, three months), running well into 2028 at the earliest.7 This is not a case where the lease is expiring early in the planning period and the tenant plans to move out; it’s a case where the lease was renewed early in the planning period and runs almost to the end of it. Fullerton lacks substantial 6 See Exh. 1 (recorded document in 2019, borrowing against rental income, signed by Ron Cassell); and https://www.clrefrigeration.com/company-history (“C&L is founded by Ronald and Jean Cassell”).
7 https://hefnervernickteam.com/4141-n-palm-st-fullerton/ (April 18, 2022 press release:
“The Hefner Vernick Team represented the Lessor, Link Logistics Real Estate, in securing a 75- month lease renewal for the 100,000 sq. ft. manufacturing facility with Adams Rite Aerospace, Inc.”). The press release also notes that the rent increase is effective “14 months in advance of the natural lease expiration,” which may mean that the 75 month term didn’t start until mid- 2023, which would put the lease expiration into mid-to-late 2029.

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evidence that Adams Rite Aerospace is likely to discontinue using its headquarters during the next five years.

10. 1500 E. Walnut
(APN 033-221-08)
The site inventory incorrectly asserts that a warehouse at 1500 E. Walnut was built in 1971. There was in fact a warehouse built in 1971 (visible on Google StreetView as recently as January 2021), but the old one was torn down in late 2021, and a new one constructed in 2022- 2024.8 This is a photo of 1500 E. Walnut as it is today; it has a recently built, brand new warehouse:

Source: Google StreetView, November 2023
8 The demolition permit was finalized by the City of Fullerton Building Department on October 6, 2021. See Permit # DEMOC-2021-0002
(https://easydev.cityoffullerton.com/energov_prod/selfservice#/permit/c9725d01-7757-427f- b8e4-b5143f2ca44b). More recently, the warehouse racks for the new warehouse are being installed, as of June 2024. See Permit # BLDC-2024-0074 (https://easydev.cityoffullerton.com/energov_prod/selfservice#/permit/2f377362-c627-4a78- 96ab-bd683bb84c4b). Loopnet indicates that the warehouse was constructed in 2022:
https://www.loopnet.com/Listing/1500-E-Walnut-Ave-Fullerton-CA/25751733/

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Indeed, the property has already been leased, as of November 2023, to electric vehicle manufacturer Mullen Automotive, which plans to use the “state of the art” facility to manufacture EV batteries, and move operations there from a facility in Monrovia.9 This newly constructed building and new use has three implications for the Housing Element:

1. Fullerton should validate, or perhaps update, its site inventory information. The Fullerton Building Department had the accurate information; it’s unclear whether the mistake here comes from using a site inventory that was drafted early in the process and hasn’t been updated to current conditions, or whether there was some inaccurate source of information used.

2. The site is not likely to redevelop in the next four-and-a-half years, because people don’t usually tear down brand new warehouses, or abandon brand-new manufacturing facilities.

3. This is an example of the fact that there remains demand for uses other than residential for the sites on the inventory, and Fullerton should adjust its capacity numbers to take into account the probability of nonresidential development. See section B below.

11. 2030, 2116, 2200, and 2340 E. Walnut : Walnut Business Center (APNs 269-141-01, -02, -03, and 269-151-09)
The sites listed as 2030 E. Walnut, 2116 E. Walnut, 2200 E. Walnut, and 2340 E. Walnut are operated as a single massive industrial park known as the Walnut Business Center. (It also uses the street addresses 315-340 S. Hale, the small entrance road from Walnut). The industrial park consists of large industrial buildings backing up to the active railroad tracks separating the site from Valencia Road to the rear.

The existing uses are industrial, and ongoing. An air conditioning contractor, in business since 1969 and employee-owned, fronts onto Walnut at 2100 E. Walnut (on parcel 269-141-02, labeled 2116 E. Walnut on the site inventory).10 Further back, in the much larger buildings on the larger parcel APN 269-151-09, are (1) Cove West, a metal wire parts manufacturing facility;11 (2) Cybertech Lighting, a 40+ year old company which makes a range of lighting products from compact fluorescent bulbs and LED bulbs to the “exit” signs seen in commercial 9 See https://news.mullenusa.com/mullen-expands-us-battery-operations-moves-to-solid- state-polymer-pack-testing-as-ev-business-scales.
10 See https://aac-ams.com/about-anderson-air-conditioning/ (describing history of Anderson Air Conditioning L.P., located at this address). 11 See https://covewestusa.com/. The home page has a video of a metal-wire bending machine that is fun to watch. “Custom wire products” manufactured in the facility for a range of applications from irrigation to airplanes are shown here: https://covewestusa.com/custom- products/.

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buildings, and which moved into this facility in 201812; and a radiator manufacturer named OSC Automotive.

The next big parcel over, APN 269-141-03, with a street address of 2200 E. Walnut, is a Nordstrom Design Center in one building, a household appliance wholesaler in another (JB International), a screen printing supply store, and a company that sells highly technical sampling equipment for various chemicals (e.g., bioaerosols, particulates, gases and vapors).

Without evidence that the existing uses are likely to discontinue during the planning period, the existing uses are presumed to preclude this property from meeting the need for housing.

12. 360 S. Acacia: Bimbo Bakeries – Sara Lee USA; Good Water Warehouse (APN 269-131-01)
There are two buildings on APN 269-131-01. One is occupied by Bimbo Bakeries – Sara Lee USA, which supplies various bread and bakery products to local supermarkets; the other is used by Good Water Warehouse, Inc., which sells water softeners, reverse osmosis systems, filters, and other components. The latter was founded by Jim Good, its president, in 1989, and is the headquarters of the company, which has operations in the U.S. and Canada. It appears that Good Water Warehouse has occupied the building continuously since 1989, when a large number of tenant improvements were done.

Without evidence that the existing uses are likely to discontinue during the planning period, the existing uses are presumed to preclude this property from meeting the need for housing.

13. 2251 N. Harbor, 141, 220 and 270 Laguna, 141 and 301 W. Bastanchury:

Medical offices comprising/surrounding The Providence St. Jude Medical Center
(APNs 292-071-04, -08, and -16 (220, 270 Laguna and 301 W. Bastanchury); (APNs 292-072-01 and -07 (2251 N. Harbor, 141 W. Bastanchury) The Providence St. Jude Medical Center, located at the intersection of Bastanchury and N. Harbor, comprises a sprawling hospital and medical office complex. A big hospital like this is often surrounded by medical practices co-located in the neighborhood, and this one is no different. The sites on the inventory that immediately surround the Providence St. Jude Medical Center contain a mix of medical uses that are either part of the Medical Center itself (such as its urgent care, or other doctor’s offices) or from medical professionals that benefit from being close by to other medical care.
12 See http://www.cybertechlighting.com/about-us/
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 The inventory site at 2251 N. Harbor is near the top of the map above, with St. Jude Heritage Medical Group “Urgent Care” at that address.
 The parcel labeled as 141 Laguna on assessor’s records has the street address 101 Laguna (on the map, it’s immediately below the building marked “St. Jude Medical Plaza – Fullerton); this property has a two story building with a sign indicating St. Jude Heritage Medical Center on the outside of the building.
 220 Laguna Road has four buildings named “Sunny Hills Medical Dental Building”; it is labeled “Potter Orthodontics” on the Google map image above.  270 Laguna Road has a three story building with several opthamology practices, including one associated with the Providence St. Jude website.

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 301 W. Bastanchury is located on the left hand side of the map (but not labeled because it doesn’t have St. Jude in its name); it is a sprawling three story medical office building filled with medical practices that looks like this:

Photo Source: Google StreetView, August 2022
 Closer to the hospital, 141 W. Bastanchury has a Wells Fargo branch, a standalone opthamologist building, and a multi-tenant two story building of small offices, including a chiropractor, several dentists, and an endodontics practice. Next door to that, at 105 W.

Bastanchury, almost directly across the intersection from the hospital complex, is a pharmacy.

St. Jude Medical Center is not likely to discontinue use of its own buildings, and the doctors and other medical professionals that surround the hospital are likewise unlikely to discontinue their current uses. The City lacks substantial evidence that the existing uses of these sites are likely to discontinue during the next five years.

14. 2810 E. Imperial Highway: Wendy’s, 7-11, and a dry cleaner (APN 337-082-13)
The 2.07 acre site listed as 2810 E. Imperial Highway contains two buildings: a standalone restaurant building which has contained a Wendy’s fast food restaurant since 1986, and a 7-11 in a strip-mall style building facing Associated Road. Absent evidence that Wendy’s or 7-11 are planning to close or move in the next five years, the existing uses are presumed to impede residential re-development.

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15. 910 S. Euclid: the Subaru/Ford dealership parking lot (APN 073-263-54)
The parking lot at 910 S. Euclid might look at first glance like a good place to build housing: there is no building to demolish or other improvements. But on second look, there’s something interesting about this parking lot: all of the cars in this photo from Google Street view, taken in May 2024, are 2024 model year Subarus.

Source: Google StreetView, May 2024
It’s no coincidence. In fact, there’s a Subaru dealership two doors down. 910 S. Euclid is where the Ocean Subaru car dealership parks its inventory. Without evidence that the Subaru dealership is likely to stop using the parking lot during the sixth cycle,13 Fullerton should not claim that it meets the need for housing.

16. 1751 Hughes: Raytheon
(APN 280-012-10)
This site was once part of Hughes Aircraft, but is now a portion of a major office campus for Southern California’s second largest defense contractor Raytheon, which has occupied the site for decades. Attached in the Appendix as Exhibit 2 is a news article dated September 11, 2023 from the Orange County Business Journal about the site.

The Raytheon campus in Fullerton consists of two parcels: APN 280-012-10 and 280- 012-09 (which surrounds it on three-and-a-half sides). The two parcels were conveyed together to a developer that may be interested in residential or office use in the long-term, but which in the medium term is constrained by Raytheon’s long-term lease. According to the Orange County Business Journal article last year, sources indicate that Raytheon will stay until 2042. (See Exh. 2). We did a title search and located a memorandum of lease (a short form description of terms filed with the County Recorder) and have attached it as Exhibit 3): it has four 5-year extension options. Based on Raytheon’s continued occupancy, it has exercised the first of these, so the lease now runs until a minimum of March 31, 2027; if it exercises all of the options Raytheon can stay, just as the article reports, until March 31, 2042. This is not a situation as provided for in the HCD site inventory guidebook, where “[t]he lease for the existing use expires early within the planning period”; it is instead one where the existing use, including an analysis of the lease, 13 A second row of cars in the photo are all Fords; the Fullerton Ford dealership is less than a mile away.

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show that the existing use is likely to continue, and precludes residential development to meet the 2021-2029 housing need.

B. The Draft Housing Element Does Not Adequately Consider The Probability Of Non-Residential Uses, And Thus Overstates The Capacity Of The Site Inventory To Meet The RHNA.

Fullerton’s primary approach to rezoning to meet the RHNA is the Housing Incentive Opportunity Zone (“HIOZ”), an overlay on existing commercial and industrial zones. Because this approach allows owners to choose between residential and non-residential development, the city is required to assess the probability of non-residential development, and to adjust its capacity numbers to take the non-residential zoning into account. See Government Code § 65583.2(c).

As the HCD site inventory guidebook explains:

Realistic development capacity for nonresidential, nonvacant, or overlay zoned sites
The capacity calculation must be adjusted to reflect the realistic potential for residential development capacity on the sites in the inventory. Specifically, when the site has the potential to be developed with nonresidential uses, requires redevelopment, or has an overlay zone allowing the underlying zoning to be utilized for residential units, these capacity limits must be reflected in the housing element.
. . . For example, if past production trends indicate that two out of three similar sites were developed for residential use, and one out of three similar sites was developed for commercial use, an initial estimate of the proportion of new development which is expected to be residential would be two-thirds, i.e., 0.67.

HCD Site Inventory Guidebook (May 2020) at pp. 19-20.

Unlike many other Housing Elements certified by HCD, Fullerton’s does not address the realistic capacity by providing information about the likelihood of nonresidential development of the sites on the inventory. In doing so, Fullerton should note that many of the industrial sites on the inventory are similar to ones that have recently been redeveloped for industrial uses: for example, a warehouse building being torn down to erect a new more modern warehouse building (see, e.g., 1501 E. Walnut, above).

The city planning department’s online list of current major development projects shows a number of nonresidential re-developments of properties similar to the ones on the inventory, including (1) a new industrial warehouse building at 1901 Via Burton, (2) demolition of a hotel to erect an industrial building and office at 1500 S. Raymond, (3) the “tilt-up speculative warehouse” proposed at 801 S. Acacia (a block away from sites on the inventory), (4) demolition of industrial buildings at 301 S. Acacia to create a truck yard (adjacent to sites on the inventory), and (5) the massive Goodman Logistics project at 2001 E. Orangethorpe, approved by the City Housing Element
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Council in November 2020, which will replace existing industrial uses with a four building, 65 acre logistics campus.14
Meanwhile, the limited discussion in section B.2.7 of non-residential development in commercial zones – specifically, listing five residential/mixed-use projects since 1991 in the C-3 zone – has an important omission. The “Fox Block” project in the downtown (the “Fox Block” is bounded by Harbor, Ellis, Pomona, and Chapman) will demolish several small retail buildings and parking lots to build new retail/restaurant uses and a multi-story parking structure. This project is in the C-3 zoning designation The City Council chose to develop city land (which comprises a portion of the project) with nonresidential uses even though residential is a permitted use in the C-3 zone, and even though there was public comment in favor of considering a residential use. This significant nonresidential project within the C-3 zone, as with the industrial zone projects listed in the prior paragraph, shows that there is continued demand for non- residential uses in Fullerton, even for sites where the zoning designation permits both residential and non-residential uses.

In order to properly assess the realistic capacity of the HIOZ sites, Fullerton therefore should determine the probability that re-development of HIOZ sites could be non-residential instead of residential. The current draft does not do this. See Housing Element draft June 2024 at B.2.7 (discussing ratio of residential to retail in mixed-use projects, but not likelihood of non- residential development).

C. The Draft Housing Element Does Not Affirmatively Further Fair Housing.

A six lane highway (State Highway 90, known as the Imperial Highway) separates single-family houses from an industrial park in the far northern portion of Fullerton. Measured from the intersection of the Imperial Highway and North Palm Street (where the site inventory suggests high density housing could be built), the industrial zone stretches over a mile north to Euclid in La Habra, and over a mile south to Brea Creek in Brea.

Source: Google Maps
14 See https://www.cityoffullerton.com/government/departments/community-and-economic- development/planning-zoning/development-activity

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Not a single Fullerton resident lives north of the Imperial Highway. But under Fullerton’s Housing Element proposed site inventory, hundreds of the lower income units to meet the RHNA would be built in this industrial park. As described in section A, this is unrealistic to expect during the sixth cycle: the companies that use this industrial zone, like Wine Country Gift Baskets, Adams Rite Aerospace, and C&L Refrigeration, aren’t likely to discontinue using the large warehouse and industrial buildings where they are headquartered.

And as described in section B, the Housing Element fails to adjust for the probability that even if the sites here were redeveloped, they could be redeveloped for another industrial use. Indeed, no one has proposed or built high density residential in this part of Fullerton, or any residential housing at all.

But there is yet another legal problem with the heavy reliance on these sites in the Housing Element: proposing to put the lower income housing in an industrial park does not affirmatively further fair housing. If the sites are built as projected, Fullerton would have succeeded in creating a neighborhood consisting entirely of lower income housing, separated from the rest of Fullerton by a six lane highway, and given the lack of any through street connecting it to the city’s street grid (because of the drainage canal and east-west ridge a few hundred yards to the south), one that can’t even reach the rest of Fullerton without first leaving the city. The “neighborhood” is low resource, see Housing Element June 2024 Draft at H-E-95, but it might be more accurate to say that as a neighborhood of Fullerton it lacks any residential resources at all. While the HCD site inventory guidebook instructs that a city should consider the availability of services in siting lower income units, here the inventory proposes a significant number of lower income units in an industrial zone isolated from literally every other part of the city. Instead of decreasing patterns of segregation, this plan would create an entirely new lower income neighborhood.

Meanwhile, Fullerton proposes to retain a zoning code that keeps affordable apartments away from the high and highest resource single-family residential neighborhoods. As HCD has commented and the draft acknowledges, Fullerton’s special height limits near single-family zones constrain production of multi-family housing and can render it infeasible. Because single- family zones are closely correlated with high resources, this law has the direct effect of limiting lower income housing (even under the Mullen law of 30 units/acre), including in particular in a Racially Concentrated Area of Affluence (the high resource, mostly white, Byerrum Park neighborhood, which has only a few small sites on the inventory). Fullerton’s own consultant has concluded that the densities that are realistic for properties near the single-family zones (22 du/ac) are unlikely to be built. In its memorandum proposing the HIOZ program, Dudek reiterated its past recommendation that 45 du/ac is a “minimum density to achieve affordability,” and that it “may limit the affordability yield under the HIOZ program.”15 Yet, in the Housing Element, the City proposes to continue maintaining its height limits near residential, constraining realistic yields to 20 du/ac (for most parcels on the inventory) and 35 du/ac (for many others).

See, e.g., Draft Housing Element June 2024 at H-3-6 (“Development Standards”); id. at H-3-8, 15 Available here: https://fullertonobserver.com/wp-content/uploads/2023/10/HIOZ-Initial- Study_Public-.pdf. Quotes are from page 4 of the April 2023 Dudek memo, at p. 96 of the pdf.

Housing Element
September 12, 2024

Page 18 ends

Table 3-3 (height limits under HIOZ are one story within 50 feet of R-1 property, and 2 stories if within 100 feet); H-3-25 (explaining that this rule leads to density assumptions for the site inventory of 20 du/ac for sites within 100 feet [sic] of R-1, and 35 du/ac for sites less than one acre within 100 feet of R-1). Fullerton should consider changing this law, at least for properties in the HIOZ, to allow more housing affordable to those with lower incomes to be built in more parts of the city.
* * *
Based on the analysis above, Fullerton’s draft Housing Element does not comply with state law, because it proposes to meet more than 50% of the need for affordable housing with sites that are not vacant, and does so without substantial evidence that many of the sites are likely to be redeveloped. Second, the capacity analysis fails to account for the ongoing demand for non-residential uses. Finally, the Housing Element appears to violate the obligation to affirmatively further fair housing.

Given the substantial need for suitable, available, and realistic housing sites zoned to meet Fullerton’s share of the regional need, we suggest that additional sites will need to be identified and potentially rezoned to ensure compliance with state housing law, and that Fullerton should reconsider its constraints that limit affordable apartment construction near single-family zones. Such changes could avoid the possibility that the Housing Element will be invalidated in the event that HCD or a court agrees with the arguments above.

Respectfully submitted,
Thomas B. Mayhew
Charles J. Higley
36615\17040988.1

4111 N Palm St, Fullerton, CA 92835-1025
APN: 296-203-13

Orange County Data as of: 08/28/2024

Owner Information
Location Information
Last Transfer / Conveyance - Current Owner
Last Market Sale
Prior Sale Information
Property Characteristics
Site Information
Tax Information
Property Detail Report
Owner Name: CL Investments LLC
Vesting:

Mailing Address: 4111 N Palm St, Fullerton, CA 92835-1025 Occupancy: Owner Occupied Legal Description: P Bk 56 Pg 28 Par 12 County: Orange, CA APN: 296-203-13 Alternate APN: Census Tract / Block: 001404 / 1034 Munic / Twnshp: Twnshp-Rng-Sec: Legal Lot / Block:

Subdivision: Tract #: Legal Book / Page: 56 / 28
Neighborhood: School District: Fullerton Joint Union High School District Elementary School: Sierra Vista Eleme... Middle School: Washington Middle... High School: Sonora High School Latitude: 33.91905 Longitude: -117.92517
Transfer / Rec Date: 01/15/2019 / 01/18/2019 Price: Transfer Doc #: 2019.17998 Buyer Name: CL Investments LLC /
Mparent Investments LLC Seller Name: Cassell JR Ronald J Deed Type: Quit Claim Deed Sale / Rec Date: Sale Price / Type: Deed Type:

Multi / Split Sale: Price / Sq. Ft.: New Construction:
1st Mtg Amt / Type: 1st Mtg Rate / Type: 1st Mtg Doc #: N/A 2nd Mtg Amt / Type: 2nd Mtg Rate / Type: Sale Doc #: N/A Seller Name:

Lender: Title Company:

Sale / Rec Date: Sale Price / Type: Prior Deed Type:
1st Mtg Amt / Type: 1st Mtg Rate / Type: Prior Sale Doc #: N/A Prior Lender:

Gross Living Area: Total Rooms: 0 Year Built / Eff:

Living Area: Bedrooms: Stories:

Total Adj. Area: Baths (F / H): Parking Type:

Above Grade: Pool: Garage #:

Basement Area: Fireplace: Garage Area:

Style: Cooling: Porch Type:

Foundation: Heating: Patio Type:

Quality: Exterior Wall: Roof Type:

Condition: Construction Type: Roof Material:

Land Use: Industrial (NEC) Lot Area: 185,061 Sq. Ft. Zoning:

State Use: Lot Width / Depth: # of Buildings: 1
County Use: 4 - Industrial Usable Lot: Res / Comm Units:

Site Influence: Acres: 4.248 Water / Sewer Type:

Flood Zone Code: X Flood Map #: 06059C0041J Flood Map Date: 12/03/2009 Community Name: City Of Fullerton Flood Panel #: 0041J Inside SFHA: False Assessed Year: 2024 Assessed Value: $10,538,787 Market Total Value:

Tax Year: 2023 Land Value: $8,590,612 Market Land Value:

Tax Area: 03-032 Improvement Value: $1,948,175 Market Imprv Value:

Property Tax: $120,954.98 Improved %: 18.49% Market Imprv %:

Exemption: Delinquent Year:
© 2024 First American Financial Corporation and/or its affiliates. All rights reserved. NYSE: FAF PAGE 1 OF 1 Reference ID: 36615
Disclaimer: This report: (i) is not an insured product or service or an abstract, legal opinion or a representation of the condition of title to real property, and (ii) is issued exclusively for the benefit of First American Data Tree LLC (Data Tree) customers and may not be used or relied upon by any other person. Estimated property values are: (i) based on available data; (ii) are not guaranteed or warranted; (iii) do not constitute an appraisal; and (iv) should not be relied upon in lieu of an appraisal. Data Tree does not represent or warrant that the information is complete or free from error, and expressly disclaims any liability to any person or entity for loss or damage caused by errors or omissions in the report. If the "verified" logo (
) is displayed, or a record is designated "verified," Data Tree's algorithm matched fields from two or more data sources to confirm source data.

School information is copyrighted and provided by GreatSchools.org.

1/3
September 11, 2023
Raytheon’s Fullerton Campus Sells for $77M
ocbj.com/real-estate/raytheons-fullerton-campus-sells-for-77m Real Estate
By
Katie Murar
September 11, 2023
Raytheon has been the sole occupant of the Fullerton campus for decades The 34-acre Raytheon campus in Fullerton has traded hands for nearly $77 million, in a deal that could ultimately result in a sizeable commercial or residential redevelopment for one of the larger office campuses in North Orange County.

A venture between Hines and Oaktree Capital Management LP sold the property—which includes two large office buildings totaling more than 405,100 square feet and several smaller industrial and research buildings—that has been entirely occupied by the Arlington, Va.-based defense contractor for nearly three decades.
2/3
Records indicate the buyer is Prime Enterprises LLC, an affiliate of San Gabriel-based Diamond Development Group, which counts other area properties including the Diamond Jamboree shopping center in Irvine.

Raytheon is expected to remain in the facility through 2042, sources indicate, at which point the new owner may redevelop the site into different uses, such as education or housing.

The recent sale marks a nearly 113% premium over Hines’ reported investment in the site. Hines had been considering a redevelopment of its own for the property, but those plans never moved forward.
“This was a great opportunity to acquire a rare office campus in Orange County with an existing Fortune 500, investment grade tenant, with attractive redevelopment options in the long term,” Jeff Cole, executive vice chairman for the capital markets team of Cushman & Wakefield, told the Business Journal.

Cole and Nico Napolitano from Cushman & Wakefield represented Hines in the deal; the buyer’s agent was undisclosed.

Long-Term Tenant
Hines in 2012 bought the buildings for a reported $18 million, then paid an additional $18 million in 2016 to buy the ground lease for the property, bringing its total investment to $36 million.

The investor, which has made several sizeable investments in North OC over the past decade, had once eyed redeveloping the site into different uses, but was unable to buy out Ratheon’s lease, sources indicate.

The Raytheon campus was built in 1986 at 1801 Hughes Drive, located about a mile north of the Riverside (91) freeway.

The site is nestled in the corner of what formerly was a larger complex used by Hughes Aircraft Co.; Raytheon has had operations in Fullerton since acquiring Hughes Aircraft in 1997.

The firm is Orange County’s second-largest aerospace and defense contractor, with an estimated 2,000 local employees.

Retail Focus
Upon Raytheon’s lease expiration in 2042, the buyer may demolish the campus to make way for different commercial uses, such as universities, to keep up with growing demand from local schools, or single-family housing, sources note.
3/3
The site is currently zoned for industrial. It backs up against Sunny Hills High School and Fullerton Chinese School, and is largely surrounded by residential uses. It’s about 5 miles west of California State University, Fullerton’s main campus.

Diamond Development is headed by Alethea Hsu, a doctor by trade who now owns several retail centers in OC and Los Angeles with an Asian focus.

The Diamond Jamboree shopping center, an H Mart-anchored mall along Alton Parkway, is among the company’s most notable retail holdings, and is one of the busiest Pan-Asian shopping centers in the county.

The 114,000-square-foot mall is the third in the Diamond Development portfolio.

The Fullerton deal is the largest reported buy for Hsu.

A housing or education-focused redevelopment would mark a shift of sorts for the commercial real estate firm, whose last reported area investment was in 2017, when it paid $12.4 million for land underneath the Newport Beach Tennis Club.

Office Conversion
Office campuses have been a source for new industrial developments in recent years, with investors favoring the logistics sector in the wake of pandemic-induced work-from-home trends.

Hines and Oaktree in 2021 sold off the 12.5-acre Volt Campus in Orange to Rexford Industrial Realty Inc. (NYSE: REXR) for $70 million; Rexford is in the process of redeveloping the office campus into an industrial hub.

Hines is moving ahead on plans for a separate redevelopment project elsewhere in the county on behalf of South Coast Plaza; it recently submitted plans alongside the Segerstrom family to redevelop the South Coast Plaza Village shopping center into The Village Santa Ana, a mixed-use project that proposes homes, office and retail.

The Raytheon sale is the largest office transaction for Hines since it sold the Intersect office campus in June 2022 for $235.3 million; that sale is tops for the OC office market since 2021.

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1 Lilly Rudolph
Subject: RE: [EXT] Re: Housing Incentive Overlay - Letter of Support Request From: Sam Swabb < >
Sent: Friday, November 8, 2024 12:26 PM
To: Sunayana Thomas <[email protected]> Cc: Michael Theil < >
Subject: [EXTERNAL MAIL]Re: Housing Incentive Overlay - Letter of Support Request

Hi Sunayana,

Thank you for the information. We are pleased to know that our site is included in the Housing Incentive Overlay Zone.

Sam

On Tue, Nov 5, 2024 at 5:14 PM Sunayana Thomas <[email protected]> wrote:

Hi Sam,
I was given your contact information from Amy at Hines.

We’re preparing for the Housing Element adoption hearing with the City Council on November 19th, and I wanted to reach out to ensure you’re informed. Based on our selection criteria for sites and our previous conversations, your site is included in the proposed Housing Incentive Overlay Zone (HIOZ).

You may have received notices about this over the past year, and you’ll be receiving another notification this week. To summarize, the HIOZ designation would allow residential development on the site through an administrative process, provided that it meets a minimum 10% affordability requirement. If this aligns with your interests for potential uses in the future, a letter of support as the property owner to include your site in the HIOZ would be greatly appreciated.

Please feel free to reach out if you have any questions or would like to discuss further. I would also welcome the opportunity to catch up on any recent updates on your end.

I look forward to hearing from you.

Thank you,
CAUTION: BE CAREFUL WITH THIS MESSAGE
This email came from outside City of Fullerton. Do not open attachments, click on links, or respond unless you expected this message and recognize the email address.

2 Sunayana Thomas
Community & Economic Development Director

p: 714.738.6837
e: [email protected]

303 W. Commonwealth Ave.

Fullerton, CA 92832
www.cityoffullerton.com

The City of Fullerton is closed on alternating Fridays. View City Calendar Here.

Disclaimer: This electronic transmission, and any documents attached hereto, may contain confidential and/or legally privileged information. The information is intended only for use by the recipient named above. If you have received this electronic message in error, please notify the sender and delete the electronic message. Any disclosure, copying, distribution, or use of the contents of information received in error is strictly prohibited.

--
Sam Swabb
Executive Vice President
Diamond Development Group
1300 E Green St. | Pasadena, CA 91106
Office: (626) 285-5550 | Fax: (626) 285-0003
Cell:
www.diamonddg.com
www.diamond-jamboree.com

Appendix H-E: Housing Element H-E-1
Appendix H-E:

Affirmatively Furthering Fair Housing (AFFH)
NOTE: Appendix H-E: Affirmatively Furthering Fair Housing replaces former Appendix H-E Assessment of Fair Housing dated November 2021. As such, this section contains no markups or highlights to improve readability.

E Affirmatively Furthering Fair Housing (AFFH)
E.1 Introduction and Overview
In 2018, the California State Legislature passed Assembly Bill (AB) 686 to expand upon the fair housing requirements and protections outlined in the federal Fair Employment and Housing Act. The law requires all State and local public agencies to facilitate deliberate action to explicitly address, combat, and relieve disparities resulting from past patterns of segregation to foster more inclusive communities. AB 686 created new requirements that apply to all housing elements due for revision on or after January 1, 2021.

The passage of AB 686 ensures that California Cities affirmatively further fair housing.

AB 686 defined “affirmatively further fair housing (AFFH)” to mean “taking meaningful actions, in addition to combat discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity.” AB 686 added to the Housing Element requirements an assessment of fair housing which includes the following components:
• A summary of fair housing issues and assessment of the City’s fair housing enforcement and outreach capacity
• An analysis of segregation patterns and disparities in access to opportunities • An assessment of contributing factors
• An identification of fair housing goals and actions.
1 The analysis identified patterns of racial and economic segregation between the neighborhoods in northern Fullerton and southern Fullerton, as well as concerns over displacement, fair housing enforcement, and access to public transportation and resources. This chapter identified actions to address these issues such as promoting integration and development in areas with high resources and tools to combat displacement and discrimination.

E.1.1 Approach to Analysis
This AFFH analysis has been prepared consistent with the California Department of Housing and Community Development (HCD)’s Affirmatively Furthering Fair Housing Guidance for All Public Entities and for Housing Elements which provides guidance on the preparation of housing elements and ensures statutory requirements are satisfied, pursuant to Government Code Section 65583(c)(10).

1 Housing and Community Development (HCD). 2021. https://www.hcd.ca.gov/community-development/affh/index.shtml

H-E-2 Appendix H-E: Housing Element
City of Fullerton
Housing Element
This AFFH analysis evaluates fair housing issues on the following topics:
• Fair Housing Enforcement and Outreach Capacity
• Integration and Segregation Patterns and Trends
• Racially and Ethnically Concentrated Areas of Poverty • Disparities in Access to Opportunity
• Disproportionate Housing Needs
• Other Relevant Factors, including historical disinvestment, lack of infrastructure improvements, and presence of older affordable housing units that may be at risk of conversion to market-rate housing.

For the purposes of this analysis, the city is divided into 33 neighborhoods (Figure E-1). These neighborhoods are based on the Census block group delineations, as well as local knowledge from City staff. Most of the geographic analysis of fair housing issues in Fullerton is based on the HCD AFFH Data Viewer. The Data Viewer relies on information provided by the Census and other data sources at the census tract and block group level. This AFFH addresses impediments through AFFH-specific goals, and actions based on the contributing factors for each identified fair housing issue.

For reference, the E Imperial Hwy/N Harbor Blvd neighborhood is comprised of entirely commercial and industrial uses and does not contain any residential units. However, several sites within this neighborhood have been identified for the Housing Incentive Overlay Zone (HIOZ), which requires a set aside for affordable housing in exchange for increased density. Additionally, the neighborhood of California State University Fullerton (CSUF) is the location of the California State University Fullerton campus, which is adjoining E Chapman Ave/State College Blvd. The large number of students in this area likely factors into the data provided for this neighborhood.

E.1.2 Fair Housing Methodology
The California Government Code Section 65583 (10)(A)(ii) requires Cities and Counties to analyze areas of segregation, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs, including displacement risk.

To conduct this analysis, the City utilized data from a variety of sources, including:
• The HCD AFFH Data Viewer
• Urban Displacement Project (UDP)
• U.S Department of Housing and Urban Development (HUD) • CalEnviroScreen
• California Tax Credit Allocation Committee (TCAC)
• County of Orange 2020 – 2024 Five-Year Housing and Community Development Plan (Consolidated Plan)
• The Regional Analysis of Impediments (AI) to Fair Housing Choice for FY 2020-25 for Orange County • Comprehensive House Affordability Strategy (CHAS)
• US Census American Community Survey (ACS)
Additionally, the analysis includes a discussion of historic land use and segregation patterns and input from sources of local knowledge, including advocates for people with special needs, housing development and advocacy organizations, housing and social services providers, and low-income residents.

Appendix H-E: Housing Element H-E-3
City of Fullerton
Housing Element
Figure E-1 Fullerton Neighborhoods

H-E-4 Appendix H-E: Housing Element
City of Fullerton
Housing Element
E.1.3 Housing and Community Development’s AFFH Viewer
The AFFH Data Viewer is a tool developed by HCD that features census block group and tract level data from an expansive collection of sources including ACS, HUD, TCAC, UDP, and CHAS. The Data Viewer tool serves as a resource for local and regional governments and provides the ability to explore spatial data patterns concerning fair housing enforcement, segregation and integration, racially and ethnically concentrated areas of poverty, and disparities in access to opportunities and housing. The Data Viewer is intended to assist in the creation of policies that alleviate disparities, combat discrimination, and increase access to safe and affordable homes.

E.1.4 Urban Displacement Project (UDP)
The UDP was developed to track neighborhood change and identify areas that are vulnerable to gentrification and displacement in California. Indicators of gentrification and displacement are measured at the census tract level based on data from the 2015 ACS. UDP indicators examine census tracts to identify areas that qualify as disadvantaged neighborhoods. Additionally, census tracts identified as disadvantaged neighborhoods by UDP’s criteria are further analyzed to explore changes in the percentage of college educated residents, white, non-Hispanic population, median household income, and median gross rents over time to determine levels of gentrification and displacement risk.

E.1.5 CalEnviroScreen
The California Office of Environmental Health Hazard Assessment developed a screening methodology to identify communities disproportionately burdened by multiple sources of pollution. This tool, called the California Communities Environmental Health Screening Tool (CalEnviroScreen), utilizes existing environmental, health, and socioeconomic data to rank census tracts based on 20 distinct indicators. In general, if a community has a high score for that indicator, it is more likely to have greater degree of pollution burden and a higher rate of residents vulnerable to the effects of that pollution exposure as compared to census tracts statewide. Designated disadvantaged communities are those with CalEnviroScreen percentile scores of 75 or higher, meaning that they scored within the highest 25 percent of census tracts for pollution and other social and economic burden indicators across California.

E.1.6 California Tax Credit Allocation Committee (TCAC) To assist fair housing analysis, HCD and the TCAC created the California Fair Housing Task Force to provide research, evidence-based policy recommendations, and other strategic recommendations to HCD and related state agencies/departments to further the fair housing goals.2 The California Fair Housing Task Force created Opportunity Maps to identify resource levels across the state to accompany new policies aimed at increasing access to high opportunity areas for families with children. Opportunity mapping is a way to measure and visualize place-based characteristics linked to critical life outcomes, such as educational attainment, earnings from employment, and economic mobility. 2 Opportunity Maps reflect
composite scores of three different domains made up from a set of indicator data shown in Table E-1.

2Office of The State Treasurer (STO). 2021. https://www.treasurer.ca.gov/ctcac/opportunity/2020-tcac-hcd-methodology.pdf

Appendix H-E: Housing Element H-E-5
City of Fullerton
Housing Element
Table E-1 Domains and List of Indicators for Opportunity Maps Domain Indicator
Economic Poverty, Adult Education, employment, Job proximity, median home value Environmental CalEnviroScreen 3.0 pollution indicators and values Education Math proficiency, reading proficiency, high school graduation rates, student poverty rates Source: California Fair Housing Task Force, Methodology for the 2020 TCAC/HCD Opportunity Maps, December 2020 E.1.7 2020-2024 Five-Year Housing and Community Development Strategic Plan for Orange County (Consolidated Plan)
The HUD Consolidated Plan is used by the federal government, states, and local jurisdictions to assess affordable housing and community development needs and is a required document for jurisdictions to be eligible for federal HUD grant programs. Orange County is required to submit a federally mandated Consolidated Plan every five years and submit an Annual Action Plan in order to receive its annual Community Development Block Grant (CDBG) entitlement grant. The Consolidated Plan assesses Orange County’s affordable housing and community development needs through a housing market analysis; articulating priorities, goals, and strategies to address identified needs; and describing the actions that need to be taken to implement strategies for housing and community development including public services and city infrastructure. Orange County’s Consolidated Plan comprises of four priority needs:

Affordable Housing Needs, Quality of life, Public Services, and Planning and Administration. The Consolidated Plan was approved on June 23, 2020. As identified by HUD, Fullerton received $1,312,305 in CDBG funds and $576,341 in Home Investment Partnerships (HOME) funds. These amounts represent the approximate annual allocation that the City of Fullerton receives for general administration, community development, and affordable housing development.

E.1.8 2020 Orange County Regional Analysis of Impediments to Fair Housing Choice (AI) As part of the CDBG program certification process and prior to HUD’s reinstatement of the AFFH standards in 2020, participating jurisdictions prepared an analysis of impediments to fair housing choice every five years. The Orange County Regional Analysis of Impediments to Fair Housing Choice (AI) was a countywide effort to pool resources and combine efforts to identify discrimination and increase fair housing choices for residents across the county. It was produced in collaboration by Orange County jurisdictions, including the City of Fullerton. The AI addresses fair housing issues on both a countywide level and in each jurisdiction.

The AI provides an assessment of the regional laws, ordinances, statutes, and administrative policies, as well as local conditions that affect the location, availability, and accessibility of housing. It also analyzes the conditions in the private market and public sector that may limit the range of housing choices or impede a person’s access to housing and provides solutions and measures to mitigate or remove identified impediments.

E.1.9 HUD Comprehensive Housing Affordability Strategy (CHAS) Data Each year, HUD receives custom tabulations of ACS data from the U.S. Census Bureau. This data, known as the "CHAS" data (Comprehensive Housing Affordability Strategy), demonstrates the extent of housing problems and housing needs, particularly for low-income households. CHAS data is estimated by the number of households that have certain housing problems and have income low enough to qualify for HUD’s programs (primarily 30, 50, and 80 percent of median income). It is also important to consider the

H-E-6 Appendix H-E: Housing Element
City of Fullerton
Housing Element
prevalence of housing problems among different types of households, such as seniors, people with disabilities, minorities, and different household types.

E.1.10 AllTransit
AllTransit is an online database that details transit opportunities for communities. The website explores metrics that reveal the social and economic impact of transit, specifically looking at connectivity, access to jobs, and frequency of service. The AllTransit performance score explores metrics that reveal the social and economic impact of transit, such as connectivity, access to jobs, and frequency of service.

E.2 Analysis of Impediments Findings
The AI provides a demographic profile of Orange County, assesses the extent of housing needs among specific income groups, and evaluates the availability of a range of housing choices for residents. The AI addresses disparities in housing needs, existing patterns of segregation and racially/ethnically concentrated areas of poverty (R/ECAPs) and contributing factors to fair housing impediments.

Regional Trends
The AI identifies the following impediments to fair housing in Orange County:
• Residential segregation between white residents and non-white residents has increased between 2010 and 2020.
• Supply of affordable housing is insufficient to meet the county’s housing needs. • Affordable housing and accessible housing for people with disabilities is concentrated in the central and northern portions of the county, particularly in the cities of Anaheim, Garden Grove, Irvine, and Santa Ana.
• White, non-Hispanic residents exhibit the highest exposure to educational opportunity and non- Hispanic Asians as the second-highest. Hispanics have the lowest access to these opportunities, with Black, non-Hispanic residents in between.
• White, non-Hispanic residents exhibit the highest access to environmentally healthy neighborhoods. All other racial/ethnic groups obtain lower environmental health access scores: Hispanic resident score lowest, followed by Black, non-Hispanic residents, Asian/Pacific Islander non-Hispanic residents, and Native American, non-Hispanic residents.
• There are significant disparities in economic opportunity scores across racial/ethnic groups. White, non-Hispanic residents have the greatest access to economic opportunity. Asian and Pacific Islander residents, Native Americans, and Black residents have lower economic opportunity scores. Hispanic residents have the lowest access to economic opportunity of all racial and ethnic groups in Orange County.
• Areas with high access to opportunity tend to have predominant populations of white and Asian, non- Hispanic residents. Areas with low access to opportunity tend to have higher percentages of Black and Hispanic residents.
• Black and Hispanic residents are more likely to have at least one housing problem, which includes overcrowding, severe overcrowding, cost burden, and severe cost burden. White and Asian and Pacific Islander residents have slightly lower rates of housing problems.

Appendix H-E: Housing Element H-E-7
City of Fullerton
Housing Element
• No public housing is located in the county In the broader Southern California Association of Governments (SCAG) region, which includes Imperial, Los Angeles, Orange, Riverside, San Bernardino and Ventura Counties, public housing is concentrated in the cities of Long Beach and Los Angeles, particularly in South East Los Angeles.
• Communities with higher concentrations of persons with disabilities are more likely to be areas that are also more racially and ethnically diverse such as the northern portion of the county, than they are in the less diverse southern portion of the county.
• Overcrowding in Orange County is very high, with 9.5 percent of all households being overcrowded, compared to the state average of 8.2 percent. The rate of overcrowding is highest among Hispanic households.
• Community opposition to affordable housing is prevalent throughout Orange County. • White mortgage applicants are more likely to have their loan applications result in originated loans.

White and Asian borrowers are least likely to be given a high-cost loan. Meanwhile, Black residents are nearly twice as likely to receive subprime loans than white, non-Hispanic residents and Hispanic residents are nearly 2.5 times more likely.

Concentrations of Lower- and Moderate-Income Earning Populations HUD defines a Lower and Moderate Income (LMI) area as a census tract or block group where over 51 percent of the population earn an income that is considered lower or moderate relative to the area median income (AMI).For Orange County, the AMI is $ 127,800 for a household of four residents. In Fullerton, households with low and moderate incomes are concentrated in the southern portion of the city.

Language Barriers
A language barrier can be an impediment to accessing housing. Those who do not speak English may face discrimination, communication challenges while trying to obtain housing, and barriers to accessing services and information. According to the AI, 20 percent of city residents aged five and older in Fullerton had Limited English Proficiency (LEP), with Spanish being the most commonly spoken language other than English, followed by Korean, Chinese, and Vietnamese. This is comparable to the LEP percentage in Orange County (21 percent).

Lending by Race/Ethnicity
The Fair Housing Act prohibits discrimination when obtaining a mortgage. However, in Fullerton the lending pool is not representative of the demographics of a community and disparities in loan approvals are an impediment to fair housing.

Limiting Community Opposition
Communities play a significant role in the development of housing in the city. According to the AI, opposition towards multifamily housing and housing for the homeless and affordable housing contributes to disproportionate housing needs in Fullerton and Orange County.

H-E-8 Appendix H-E: Housing Element
City of Fullerton
Housing Element
E.3 Fair Housing Resources
E.3.1 Enforcement and Outreach Capacity
Fair housing enforcement and outreach capacity is the ability of a local jurisdiction and fair housing agencies to provide fair housing and tenants’ rights information to community members. Enforcement and outreach capacity also includes the ability to address compliance with fair housing laws, such as investigating complaints, resolving issues, and conducting fair housing testing.

Regional Resources
Orange County contracts with The Fair Housing Council of Orange County (FHCOC), a private non-profit fair housing group, to administer a wide variety of fair housing services to residents of Orange County, including residents in Fullerton.

The FHCOC provides the following services to Orange County residents:
• Serving as a fair housing resource for the region, including implementation of an affirmative fair housing marketing plan, testing, and complaint verification • Responding to all citizen complaints regarding violation of fair housing laws • Providing tenant-landlord counseling to all inquiring citizens • Promoting community awareness of tenant-landlord rights and responsibilities • Reporting monthly on complaint processing
• Providing fair housing education to residents, County staff, community organizations, agencies, and service providers
• Increasing the supply of affordable housing in high opportunity areas • Preventing displacement of low- and moderate-income residents, seniors, and people with disabilities • Increasing community integration for persons with disabilities • Ensuring equal access to housing for persons with protected characteristics who are disproportionately likely to be lower-income and to experience homelessness • Expanding access to opportunities for protected classes During the 2015-2019 reporting period, the FHCOC staff received 363 allegations of housing discrimination and opened 179 cases where the allegations seemed sufficiently meritorious to warrant further investigation and/or action. FHCOC also conducted 362 systemic onsite tests, 51 tests occurring in the jurisdiction, and 215 other testing activities. FHCOC held 32 training sessions for rental property owners/managers and presented 16 fair housing seminars and 70 general fair housing workshops. On a regional basis, activities provided by FHCOC included assisting 7,664 unduplicated households addressing 24,766 issues, disputes and/or inquires.

The FHCOC ensures that the City’s fair housing practices are consistent with State law and that residents have the tools and resources they need to address fair housing issues appropriately. The City relies on the FHCOC to track, monitor, and investigate fair housing cases as well as hold training sessions for property owners/managers.

Appendix H-E: Housing Element H-E-9
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Housing Element
In addition to the FHCOC, there are several agencies that have historically provided fair housing services in Orange County, listed in Table E-2. These organizations and provide the following services:
• Fair housing testing and complaints
• Fair housing counseling and education
• Tenant/landlord counseling and mediation
• Homeless prevention program
• Rental assistance program
• Rent/deposit grant program
• Homeseeking services
• Shared housing counseling placement
• Homebuyers’ education learning program
Table E-2 Fair Housing Service Providers Active in Orange County Organization1 Website Phone Number
Lutheran Social Services of Southern California https://www.lsssc.org/ (714) 685-1800 Korean Resource Center https://www.krcla.org/ (714) 869-7624 GreenPath Financial Wellness https://greenpath.com/ (833)344-0606 Neighborworks Orange County https://nwoc.org/ (714) 490-1250 Homeownership OC https://www.homeownershipoc.org/ (714) 204-2314 Fair Housing Council of Orange County https://www.fairhousingoc.org/ (714) 569-0823 Orange County Community Housing Corporation https://www.occhc.org/ (714) 558-8161 Habitat for Humanity of Greater Los Angeles https://www.habitatla.org/ (310) 323-4663 Consumer Credit Counseling Service of Maryland and
Delaware, Inc.
https://cccsmd.org/ (800) 642-2227
Fair Housing Foundation https://fhfca.org/ (800) 446-3247 Source: HUD Exchange Housing Counseling Agency search tool Local Resources
The City of Fullerton maintains a contract with the non-profit organization Fair Housing Foundation (FHF), a regional non-profit fair housing agency. FHF assists residents with fair housing counseling services, counseling for landlords and tenants, rental housing counseling, provides education and outreach. In addition, FHF screens fair housing complaints, investigates through testing, and will engage in conciliation or mediation efforts or refer the complaints to the appropriate administrative agencies where appropriate.

The City allocates CDBG funds to FHF's fair housing services with the goal of assisting residents and landlords by providing fair housing counseling and education.

H-E-10 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Compliance with Existing Fair Housing Laws
The City of Fullerton is subject to state and federal laws related to fair housing. These laws include the following:
• California Fair Employment and Housing Act (FEHA) (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2)
• FEHA Regulations (California Code of Regulations (CCR), title 2, sections 12005-12271) • Government Code section 65008 covers actions of a city, county, city and county, or other local government agency, and makes those actions null and void if the action denies an individual or group of individuals the enjoyment of residence, landownership, tenancy, or other land use in the state because of membership in a protected class, the method of financing, and/or the intended occupancy. o For example, a violation under Government Code section 65008 may occur if a jurisdiction applied more scrutiny to reviewing and approving an affordable development as compared to market-rate developments, or multifamily housing as compared to single family homes. o Government Code section 65008, subdivision (e), authorizes preferential treatment of affordable housing
• Government Code §8899.50 requires all public agencies to administer programs and activities relating to housing and community development in a manner to affirmatively further fair housing and avoid any action that is materially inconsistent with its obligation to affirmatively further fair housing. • Government Code §11135 et seq. requires full and equal access to all programs and activities operated, administered, or funded with financial assistance from the state, regardless of one’s membership or perceived membership in a protected class.
• Density Bonus Law (Gov. Code, §65915.)
• Housing Accountability Act (Gov. Code, § 65589.5.)
• No-Net-Loss Law (Gov. Code, § 65863)
• Least Cost Zoning Law (Gov. Code, § 65913.1)
• Excessive subdivision standards (Gov. Code, § 65913.2.) • Limits on growth controls (Gov. Code, § 65302.8.)
• Housing Element Law (Gov. Code, § 65583, esp. subds. (c)(5), (c)(10).) The City of Fullerton complies with these laws through the City’s daily operations. The City complies with the California Fair Employment and Housing Act (FEHA), prohibiting discrimination based on marital status, ancestry, source of income, sexual orientation, and arbitrary discrimination in addition to the groups protected under federal fair housing legislation. The City does not have local ordinances that relate to fair housing.

E.4 Ability to Address Complaints
Initiated by the Department of Justice’s Civil Rights Division in 1991, fair housing testing is a technique used to uncover evidence of discrimination in rental housing. Fair housing testing involves one or more individuals who pose as prospective renters for the purpose of determining whether a landlord is complying with local, State, and federal fair housing laws. Enforcement actions may be taken when

Appendix H-E: Housing Element H-E-11
City of Fullerton
Housing Element
investigations yield evidence of a pattern or practice of illegal housing discrimination. Testing may be initiated following the filing of a specific housing discrimination complaint or, as is the case when testing for discrimination against a specific class, as part of an overall effort to determine whether the discrimination is happening in a consistent systemic pattern in a city or region. In Orange County, fair housing testing is used to identify unlawful housing discrimination practices based on the real or perceived race, ethnicity, color, religion, gender identity or expression, national origin, disability, familial status, marital status, age, ancestry, sexual orientation, and source of income of prospective renters.

FHF Housing is funded to provide the full range of fair housing enforcement services to local renters and conducts fair housing testing of rental properties to assess how well rental properties conform to fair housing laws. In cases when evidence of deferential treatment is found, the property owners and managers are encouraged to attend fair housing workshops, which provide training and educational resources aimed at ending fair housing discrimination. Between 2015 and 2020, a total of 1,128 individuals participated in fair housing workshops, trainings, or counseling hosted by FHF.

HUD’s Office of Fair Housing and Equal Opportunity (FHEO). Based on data provided by HUD, 30 FHEO inquiries were reported in Fullerton between 2013 and 2021. These inquiries are not considered official cases; however, they indicate a potential basis for discrimination in the city. Four of these inquiries were based on disability, and the remainder did not provide a basis.

E.5 Segregation and Integration Patterns and Trends
To inform priorities, policies, and actions, the housing element must include an analysis of integration and segregation, including patterns and trends. Integration generally means a condition in which there is not a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a particular type of disability in a specific geographic area. Segregation generally means the opposite condition, in which there is a high concentration of the characteristics described above in a specific geographic area. To adequately assess the patterns of integration and segregation, this section identifies trends at the regional scale (Orange County and the broader Southern California region) and at the local scale (City of Fullerton). To identify socio-economic and demographic spatial trends across these jurisdictions, this analysis utilizes HCD’s AFFH Data Viewer, which provides an expansive collection of data from sources including the 2015-2019 ACS, HCD, HUD, UDP, the Center for Disease Control and Prevention (CDC), and other regional and federal agencies. In its AFFH guidance document published in April 2021, HCD describes the importance of segregation and integration analysis in relation to fair housing:

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

Past and present discriminatory policies and practices, including long-term disinvestment, have resulted in neighborhoods with concentrated poverty and poor housing stock, limited access to opportunity, unsafe environmental conditions, underfunded schools, dilapidated infrastructure, and other disproportionately experienced problems. In addition, governmental policies have subsidized the development of segregated, high-resourced suburbs in metropolitan areas by constructing new highway systems—often through lower income communities of color— to ensure access to job opportunities in urban centers. This physical and

H-E-12 Appendix H-E: Housing Element
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Housing Element
policy infrastructure supports patterns of discrimination and high levels of segregation that continue to persist in California and across the country. All of these conditions persist despite the over 50-year-old obligation to prohibit discrimination and affirmatively further fair housing.3 E.5.1 Race and Ethnicity
The ethnic and racial composition of a region relates to fair housing concerns such as household size, locational preferences, and economic opportunity. Historic exclusionary governmental policies, biased mortgage lending practices, and other tactics have caused racial and ethnic segregation and spatial inequities.

Regional Trends
Regionally, the northern and central areas of Orange County, including the Cities of Buena Park, Santa Ana, and Westminster contain populations with the highest percentage of non-white residents. These areas have at least 80 percent of non-white residents, as shown in Figure E-2. Comparatively, the western and southeastern areas of Orange County have higher percentages of white alone populations, particularly near the less urbanized areas of the county and along the coast, which contain areas with 80 percent or more white residents. Orange County has the one of the lowest percentage of people of color in the SCAG region, second only to Ventura County. However, a large portion of the unurbanized areas of the county are designated a Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP), or national forest lands. The Cleveland National Forest makes up the majority of the southeastern corner of the county. As a result, little to no permanent housing exists in these areas.

HUD utilizes the racial/ethnic dissimilarity index to measure segregation levels across a defined geographic boundary. The racial/ethnic dissimilarity index ranges from 0-100, where 0 represents perfect integration between racial groups and 100 representing perfect segregation.4 According to the AI, Orange County experiences moderate levels of segregation, with significant variances in some individual jurisdictions. The Non-White/White value is 44.71, Black/White 46.98, Hispanic/White 52.82, and Asian or Pacific Islander/White is 43.19. Areas in central Orange County, particularly the cities of Orange, Santa Ana, and Tustin, have the highest Dissimilarity Index values for their populations. Black and Hispanic residents are particularly segregated in these jurisdictions. Racial/ethnic segregation has increased significantly since 2010.

3 HCD 2021. https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf 4 HUD, 2020. https://www.hud.gov/sites/dfiles/FHEO/documents/AFFH-T-Data-Documentation-AFFHT0006-July-2020.pdf

Appendix H-E: Housing Element H-E-13
City of Fullerton
Housing Element
Figure E-2 Percentage Total Non-White Population (Orange County)

Source: AFFH Viewer

H-E-14 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Local Trends
According to the 2020 Census, Hispanic/Latino residents comprised the largest racial/ethnic group in Fullerton, followed closely by White residents. Table E-3 shows the population by racial category for Fullerton in 2010 and 2020 and compares the 2020 population to the composition of the SCAG region in 2020.

Fullerton’s racial composition has a higher percentage of white, non-Hispanic, Asian American/Pacific Islander, and “Other or Multiple Races” than the Southern California region, and a lower percentage of residents who identified as Hispanic and Black/African American. Generally, Fullerton’s population has become more diverse during the past decade. However, as shown in Figure E-3, there are several neighborhoods scattered throughout the city that have low-medium levels of segregation and several neighborhoods with high segregation. The neighborhoods of high POC segregation include Emery Park, Amerige Heights, La Habra South, Sunny Hills, E Imperial Hwy/N Harbor Blvd, and Acacia Park. These neighborhoods are predominantly Asian and are concentrated in the northeastern portion of the city. The neighborhood of Byerrum Park, located in the center of the city, has high white segregation. Areas with low-medium levels of segregation are Artesia Blvd/N Gilbert St, Valencia Park, Gilbert Park, Independence Park, Woodcrest Park, Santa Fe District/SoCo, Rancho La Paz, The Fox Block, Brea West, Craig Park, and Artisan Walk.

Table E-3 Population by Racial Group, City of Fullerton and the Southern California Region

Fullerton
(Percent of Population)
Southern California Region
(Percent of Population)
Race 2010 2020 2020
Hispanic/Latino 34.4 37.7 46.7
White 53.8 37 30.3
Black/African American 2.3 2.2 6.2
Asian American/Pacific Islander 22.7 26.9 13.5
Other or Multiple Races 20.1 33 3.1
Source: US Census, 2020. Census State Redistricting Data, Table P1 and P2; SCAG. Racial Equity Baseline Conditions Report. 2022. https://scag.ca.gov/sites/main/files/file-attachments/2022racialequitybaselineconditionsreport_final.pdf According to the most recent HUD data, Fullerton has higher levels of racial integration than segregation levels than the Los Angeles-Long Beach-Anaheim region (as defined by HUD), and the state overall. The racial/ethnic dissimilarity index ranges from 0-100, where 0 represents perfect integration between racial groups and 100 representing perfect segregation. Over the past three decades, the racial/ethnic segregation index score in Fullerton fluctuated, with slight increases and decreases (Table E-4). Since 2010, segregation between non-White/White residents and Black/White residents increased, and segregation between Asian American/Pacific Islander and Hispanic/Latino/White residents decreased. Although racial/ethnic segregation has increased in the city, segregation levels between all groups remain low compared to the Los Angeles-Long Beach-Anaheim region.

Appendix H-E: Housing Element H-E-15
City of Fullerton
Housing Element
Table E-4 Racial Dissimilarity Index Values for Segregation (Fullerton and Los Angeles-Long Beach- Anaheim Region)
Fullerton Los Angeles-Long Beach-Anaheim Region
Race 1990 2000 2010 Current 1990 2000 2010 Current
Non-White/White 25.53 31.16 30.52 34.31 55.32 55.50 54.64 56.94 Black/White 30.60 31.84 26.53 38.26 72.75 68.12 65.22 68.85 Hispanic or Latino/White 33.72 39.98 38.28 35.48 60.12 62.44 62.15 63.49 Asian or Pacific
Islander/White

30.41 33.48 35.24 31.01 43.46 46.02 45.77 49.78
Source: HUD, 2023, Table 3 – Racial/Ethnic Dissimilarity Trends Figure E-5 shows the predominance of white, Hispanic/Latino, and Asian American/Pacific Islander populations in the city. The southern portion of the city has a sizable or predominant proportion of Hispanic/Latino residents, particularly the neighborhoods of Woodcrest Park and Rancho La Paz. The AFFH Data Viewer also shows the neighborhood of E Imperial Hwy/N Harbor Blvd in northern Fullerton as also having a predominant proportion of Hispanic Latino residents; however, this data is based on the residential units within the neighboring cities of La Habra and Brea. The portion of this census tract located within the City of Fullerton is comprised of entirely commercial and industrial uses and does not contain any residential units. The western section of the city, particularly in Emery Park, has a predominant Asian American/Pacific Islander population. The central and northern portions of the city have a sizable white majority population.

Areas with higher percentages of non-white residents are primarily located on the outer edges of the city, particularly within the south and western portions of the city (Figure E-4). These are also the densest areas of the city, with smaller lot sizes and more commercially zoned areas. Neighborhoods in northeastern and central Fullerton has higher percentages of white, non-Hispanic populations compared to other areas of the city. The northeastern and central portions of the city are less dense than the southern area of the city, and contain several golf courses and the Robert E. Ward Nature Preserve, which does not contain any housing.

H-E-16 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-3 Neighborhood Segregation (Fullerton)

Source: AFFH Viewer, 2022

Appendix H-E: Housing Element H-E-17
City of Fullerton
Housing Element
Figure E-4 Percent of Total Non-White Population (Fullerton)

Source: AFFH Viewer, 2022.

H-E-18 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-5 Predominant Populations (Fullerton)

Source: AFFH Viewer, 2021

Appendix H-E: Housing Element H-E-19
City of Fullerton
Housing Element
E.5.2 Persons with Disabilities
For persons with disabilities, fair housing choice and access to opportunity include access to accessible housing and housing in the most integrated setting appropriate to an individual’s needs as required under federal civil rights law, including equitably provided disability-related services that an individual needs to live in such housing. For example, persons with disabilities who are unable to use stairs or need a zero-step shower may not have actual housing choice if there are not sufficient housing units with these accessibility features.5
High spatial segregation of persons with disabilities may indicate fair housing issues related to not only physical needs, but also economic disparities. According to the 2020 Annual Report on People with Disabilities in America, more than 25 percent of persons with disabilities (including physical, intellectual, and developmental; sensory; and other disability categories) live below the Census Bureau-designated poverty line, which is 14.5 percentage points higher than people without a disability.6 Persons with disabilities may be more reliant than persons without disabilities on fixed incomes or access to public transit.

Regional Trends
According to 2021 ACS estimates, 276,827 Orange County residents had one or more disabilities, or 8.8 percent of the total population. Figure E-7 shows the percentage of the population living with one or more disabilities throughout Orange County. The northwestern area of the county and the urban centers of cities had higher concentrations of persons living with one or more disabilities than other areas of the county.

Local Trends
Approximately 13,617 residents (nearly 10 percent) of Fullerton’s population live with one or more disabilities. According to 2021 ACS estimates shown in Figure E-6, independent living difficulty was the most common disability reported by Fullerton residents.

5 HCD, 2021. https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf 6 Annual Disability Statistics Compendium, 2020. https://disabilitycompendium.org/annualreport

H-E-20 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-6 Disability by Type (Fullerton)

Notes: These disabilities are counted separately and are not mutually exclusive, as an individual may report more than one disabilit y. These counts should not be summed.

Source: U.S. Census Bureau, American Community Survey 1-Year Estimates (2021), Table S1810 Figure E-8 shows the percentage of the population living with one or more disabilities in the city by census tract. The percentage of residents reporting living with one or more disability ranged between zero and 20 percent. The neighborhoods in the city where disability ranged between 10 to 20 percent include Artesia Blvd/N Gilbert St, Valencia Park, Gilbert Park, W Commonwealth Ave/N Basque Ave, S Woods Ave/W Orangethorpe Ave, Sunny Hills, E Imperial Hwy/N Harbor Blvd, Bastanchury Rd/Fairway Isle Dr, Byerrum Park, Nutwood Ave/N Mountain View Pl. These neighborhoods are scattered throughout the city. The remainder of the city has less than 10 percent of residents reporting a disability. The neighborhood with the highest percentage of residents reporting a disability is S Woods Ave/W Orangethorpe Ave, located south of Valencia Drive and north of State Route 91, between Euclid Avenue and Richmond Avenue. This area is primarily comprised of low-density residential uses.

2.4%

1.6%

4.1% 4.0%

2.4%

5.0%

0.0%

1.0%

2.0%

3.0%

4.0%

5.0%

6.0%
With a hearing
difficulty
With a vision
difficulty
With a cognitive
difficulty
With an
ambulatory
difficulty
With a self-care
difficulty
With an
independent living
difficulty
Percentage of Adult Population Reporting Disability

Appendix H-E: Housing Element H-E-21
City of Fullerton
Housing Element
Figure E-7 Percent of Population with a Disability (OrangeCounty)

Source: AFFH Viewer, 2022

H-E-22 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-8 Percentage of Population with One or More Disabilities (Fullerton)

Source: AFFH Viewer, 2021

Appendix H-E: Housing Element H-E-23
City of Fullerton
Housing Element
E.5.3 Familial Status
Familial status refers to the presence of children under the age of 18 and the martial status of the head of the household. Families with children may face housing discrimination by landlords who fear that children will cause property damage. Examples of differential treatment include limiting the number of children in an apartment complex or confining households with children to a specific location are potentially discriminatory. Single parent households are protected by fair housing law. A 2016 HUD study studied the effects of housing discrimination based on familial status. The study found that landlords presented households with children fewer housing options, and the units shown were generally larger, and as a result, slightly more expensive to rent.7 Additionally, female-headed households with children require special consideration and assistance because of generally greater needs for affordable housing and accessible day care, health care, and other supportive services.

Regional Trends
Orange County had 1,057,592 households in 2021. According to 2017-2021 ACS estimates, households with children present comprise 23 percent of the total households in Orange County. Tenure by household type and presence of children is shown in Table E-5. Married couple families with children comprise the largest share of owner- and renter-occupied households with children. Single-parent, female-headed households comprised approximately eight percent of renter-occupied households, but only two percent of owner-occupied households.

Table E-5 Tenure by Household Type and Presence of Children (Orange County) Household Type
Owner-
Occupied
Percent of
Total Owner-
Occupied
Renter-
Occupied
Percent of
Total Renter-
Occupied
Married Couple Family, with Children Present 146,405 24.3% 97,736 21.5% Single-Parent, Male Householder, no Spouse Present 6,933 4.3% 14,628 3.2% Single Parent, Female Householder, No Spouse Present 13,116 2.1% 37,771 8.2% Total Households with Children Present 166,454 27.6% 80,831 17.8% Total Households 602,440 100% 455,152 100%
Source: U.S. Bureau of the Census, ACS Table B25115 Tenure by Household Type (Including Living Alone) and Age of Householder, 2017-2021 Estimates.

The majority of Orange County has a relatively low percentage of households characterized as female- headed, single-parent households, as shown in Figure E-9. There are small pockets with higher proportion of households with children who reside in female-headed, single-parent households, such as portions of the cities of Laguna Woods, Newport Beach, Irvine, and Orange. The urban areas in the northwest portion of the county tend to have higher proportions of female headed households than the southeastern part of the county. The patterns amongst married couple households with children are very similar, as shown in Figure E-10.The urban areas in the northwest portion of the county tend to have lower proportions of married couples with children under 18 than the southeastern part of the county.

7 HUD. 2016. https://www.huduser.gov/portal/sites/default/files/pdf/HDSFamiliesFinalReport.pdf.

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City of Fullerton
Housing Element
Local Trends
According to 2017-2021 ACS estimates, households with children present comprised 30 percent of the total number of households in Fullerton, which was higher than the county. An overview of household tenure by type for households with children present is provided in Table E-6. Similar to regional trends, married-couple families in Fullerton comprised the largest share of households with children present, and married-couple families were more likely to own than rent. Single-parent, female-headed households comprised nine percent of renter-occupied households and only one percent of owner-occupied households. The homeownership rate for single-family, female-headed households is slightly lower in Fullerton (1.2 percent) than the county (2.1 percent).

Table E-6 Tenure by Household Type and Presence of Children (Fullerton) Household Type
Owner-
Occupied
Percent of
Total Owner-
Occupied
Renter-
Occupied
Percent of
Total Renter-
Occupied
Married couple family, with Children Present 6,060 24.6% 4,447 20.4% Single-Parent, Male householder, no spouse present 350 1.4% 950 4.4% Single-Parent, Female householder, no spouse present 297 1.2% 1,849 8.5% Total Households with Children Present 6,707 27.2% 7,246 33.2% Total Households 24,629 100% 21,805 100%
Source: U.S. Bureau of the Census, ACS Table B25115 Tenure By Household Type (Including Living Alone) and Age of Householder, 2017-2021 Estimates.

Appendix H-E: Housing Element H-E-25
City of Fullerton
Housing Element
Figure E-9 Female-Headed Households with Children Present, No Spouse/Partner Present (Orange County)

Source: AFFH Viewer, 2022

H-E-26 Appendix H-E: Housing Element
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Housing Element
Figure E-10 Children in Married-Couple Households (Orange County)

Source: AFFH Viewer, 2021.

Appendix H-E: Housing Element H-E-27
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Housing Element
Figure E-11 shows the percentage of children residing in single-parent, female-headed households in Fullerton, which ranges from less than 20 percent to less than 40 percent. The neighborhoods that have a higher percentage of children residing in single-parent, female-headed households compared to the rest of the city include La Habra Southeast, Independence Park, W Valencia Dr/Courtney Ave, California State University Fullerton, and Bradford Park. These neighborhoods are scattered throughout the city. However, none of the neighborhoods in Fullerton have an extremely high percentage of single, female-headed households.

Figure E-12 shows the percentage of children in married-couple households across Fullerton. Most census tracts in the city had over 60 percent of children living in married-couple households, according to 2015- 2019 ACS estimates. Several of the areas that have the highest percentage of married couple households overlap with the areas with a predominant white, non-Hispanic or Asian American population. These include the neighborhood of West Coyote Hills, Emery Park, Amerige Heights, Sunny Hills, The Fox Block, Acacia Park, Brea West, Nutwood Ave/N Mountain View Pl, and Craig Park. Additionally, the neighborhoods of Gilbert Park, W Oak Ave/Lambert Dr, and Nicolas Park have high percentage of married couple households with children. The area with the lowest percentage of married-couple households with children is the neighborhood of Artesia Blvd/N Gilbert St .

Neighborhoods that have lower rates of children in married-couple households are more likely to contain higher density residential development, smaller lot sizes, and industrial and commercial land uses compared to neighborhoods with higher rates of children in married-couple households.

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Figure E-11 Female-Headed Households with Children Present, No Spouse/Partner Present (Fullerton)

Source: AFFH Viewer, 2022

Appendix H-E: Housing Element H-E-29
City of Fullerton
Housing Element
Figure E-12 Children in Married-Couple Households (Fullerton)

Source: AFFH Viewer, 2021

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Housing Element
E.5.4 Household Income
Household income is directly connected to the ability to afford housing. Higher-income households are more likely to own rather than rent housing. 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. To achieve fair housing objectives, people in low-income households must have actual choice in housing opportunities—that is, when they are able to locate units that are affordable and well maintained in all parts of a jurisdiction and region.

This section identifies household income disparities using data based on median household income and low or moderate income (LMI) geographies. HUD defines an LMI area as a census tract or block group where over 51 percent of the population is LMI. The definition of low or moderate income is based on HUD income definitions of up to 80 percent of the AMI.

Regional Trends
According to 2021 ACS estimates, Orange County has a median household income of $100,559, which is much higher than the SCAG regional income of $77,430 Figure E-13 displays median household income by block group for Orange County using 2015-2019 ACS estimates. However, there are some gaps in data across the county (as shown in white), which may skew the median income ranges within the county.

Median household income tends to be higher in communities located in southwest Orange County.

Generally, households in the urban core of cities, such as Santa Ana, Westminster, Placentia, and Anaheim have a lower income than rural or suburban areas. Communities with the lowest median household incomes are concentrated in the urban areas in the northwest portion of the county.

LMI populations by census tract for Orange County are displayed in Figure E-14. Census tracts within the cities of Santa Ana, Fullerton, and Anaheim contain the highest percent of LMI populations in Orange County. LMI populations are in communities with a relatively greater percentage of children living in single- parent, female-headed households (Figure E-9) and a greater percentage of non-white populations (Figure E-11).

Local Trends
Geographically, median household income varies throughout Fullerton. According to 2021 ACS estimates, Fullerton has a median household income of $95,431, which is approximately five percent lower than the median income for Orange County but 19 percent higher than the SCAG region’s median income of $77,430. Fullerton’s median income is slightly lower to other cities in northern Orange County, such as Buena Park, Orange City, and Brea ($101,346, $103,045, and $108,721 respectively) Figure E-15 provides an overview of median household income by block group in the city. The lowest median household income areas are in the southern portion of the city. The block group with the lowest median household income is the location of California State University Fullerton. It is likely that the prevalence of students in this neighborhood lowers the median household income.

In contrast, the neighborhoods of West Coyote Hills, Amergie Heights, Sunny Hills, E Las Palmas Dr/N Sunnywood Dr, Craig Park, The Fox Block, Byerrum Park, and Acacia Park neighborhoods in the central and northern areas of Fullerton have higher median household incomes. These areas also have predominant Asian and White, non-Hispanic residents, as shown in Figure E-16. The neighborhood with the highest median income is Sunny Hills with a median income of $184,018.

Appendix H-E: Housing Element H-E-31
City of Fullerton
Housing Element
LMI populations in Fullerton are concentrated in the southern portion of the city, as shown in Figure E-17.

The Rancho La Paz, Woodcrest Park, and Valencia Park neighborhoods had a higher percentage of LMI populations (between 75 and 100 percent of the population). In contrast, neighborhoods in the center and northern portion of the city tend to have lower percentages of LMI populations. West Coyote Hills, Acacia Park, Byerrum Park, and Nutwood Ave/N Mountain View Pl have the lowest percentage of LMI populations (less than 25 percent of the population). Neighborhoods with higher rates of LMI populations tend to overlap with areas of the city that have predominantly Hispanic/Latino populations.

Poverty rates in Fullerton have shifted slightly over time. Poverty rates increased from 12 percent in 2019 to 13 percent in 2021. This is on par with the poverty rates in the larger Southern California region (13 percent). Figure E-18 displays the percentage of the population earned an income that was below the poverty line.

H-E-32 Appendix H-E: Housing Element
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Figure E-13 Median Household Income (Orange County)

Source: AFFH Viewer, 2022

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Figure E-14 Low and Moderate Income Population (Orange County)

Source: AFFH Viewer, 2022

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Figure E-15 Median Household Income (Fullerton)

Source: AFFH Viewer, 2022

Appendix H-E: Housing Element H-E-35
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Figure E-16 Median Household Income and predominant Racial/Ethnic Population (Fullerton)

Source: AFFH Viewer, 2022

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Figure E-17 Low to Moderate Income Population (Fullerton)

Source: AFFH Viewer, 2022

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Figure E-18 Poverty Status (Fullerton)

Source: AFFH Viewer, 2022

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Table E-7 displays income level by household type. According to 2017-2021 ACS data, married-couple families within Fullerton have significantly higher incomes than nonfamily households, which consist of people who live alone or share a residence with unrelated individuals. Given the location of California State University Fullerton, many of the nonfamily households within Fullerton may be comprised of students, which may impact the median incomes of that household category. Approximately 63 percent of married couple families make above $100,000 per year, compared to 25 percent of nonfamily households and 47 percent of total households.

Table E-7 Income Level by Household Type (Fullerton)
Income Level Total Households Married-Couple Families Nonfamily Households Less than $10,000 4.4% 0.9% 10.7%
$10,000 to $14,999 2.8% 1.0% 6.0%
$15,000 to $24,999 4.4% 1.9% 6.3%
$25,000 to $34,999 6.0% 4.1% 8.1%
$35,000 to $49,999 9.0% 6.5% 12.0%
$50,000 to $74,999 15.1% 11.9% 20.0%
$75,000 to $99,999 11.1% 10.3% 12.2%
$100,000 to $149,999 19.1% 22.5% 12.8%
$150,000 to $199,999 12.5% 17.3% 6.4%
$200,000 or more 15.6% 23.6% 5.4%
Median income $92,718 $129,862 $58,271
Source: U.S. Bureau of the Census, ACS Table S1901, Income in the Past 12 Months (Inflation-Adjusted Dollars), 2017-2021 Estimates E.5.5 Racially and Ethnically Concentrated Areas of Poverty To identify racially and ethnically concentrated areas of poverty (known as R/ECAPs), HUD developed thresholds based on racial and ethnic concentration and income level. The threshold for racial and ethnic concentration is a non-white population of 50 percent or more in metropolitan or micropolitan areas. The income threshold is based on areas of “extreme poverty,” where 40 percent or more of households earn incomes at or below the federal poverty line, or where the poverty rate is three times the average poverty rate in the metropolitan area, whichever is less. An area that meets both thresholds for racial or ethnic concentration and “extreme poverty” is considered a R/ECAP.

E.5.6 Poverty and Segregation
Regional Trends
In Orange County, R/ECAPs are present in neighborhoods in the urban cities in the northern portion of the county, including in Costa Mesa, Santa Ana, Garden Grove, Anaheim, and Placentia. These areas are shown with hash marks in Figure E-19.

Appendix H-E: Housing Element H-E-39
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Figure E-19 Areas of High Segregation and Poverty (Orange County)

Source: AFFH Viewer, 2021

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Housing Element
Local Trends
While R/ECAPs were not identified within Fullerton, there are areas where lower household income and racial and ethnic concentration overlap. The neighborhoods of Woodcrest Park, California State University Fullerton, and Deepark Dr/Sherwood Ave had the highest poverty rates within the city. However, the high percentage of students surrounding CSUF likely affects at least some of this data. The southern portion of the city had higher percentage of the population below the poverty line than the northern portion of the city, with the majority of neighborhoods south and immediately north of Commonwealth Avenue having between 10 and 20 percent of the population below the poverty line. The neighborhood of Woodcrest Park has a poverty rate between 20 and 30 percent.

E.5.7 Concentrated Areas of Affluence
While R/ECAPs have long been the focus of fair housing policies, racially concentrated areas of affluence (RCAAs) must also be analyzed. RCAAs are defined as affluent, white communities.8 According to a policy paper published by HUD, white residents are the most racially segregated group in the United States typically more affluent than majority non-white communities. RCAAs have not been studied extensively, nor has a standard definition been adopted by HCD or HUD. Therefore, this assessment uses the percent white population and median household income as thresholds to identify potential RCAAs. In addition to having a higher median income, areas of affluence experience less overcrowding, less housing cost burden on renters, and are generally less susceptible to displacement compared to LMI areas, as described in Section 4.4, Household Income.

Regional Trends
The areas characterized as RCAAs in Orange County are shown in Figure E-20, which are concentrated in the southeastern portion of the county and along the coast, such as Laguna Beach, San Clemente, Newport Beach, and non-urbanized areas. Generally, cities with higher median incomes such as the Laguna Beach and San Clemente have relatively larger concentrations of white residents compared to jurisdictions with lower median incomes such as the cities of Anaheim, Santa Ana and Buena Park, as shown in Figure E-2 and Figure E-13.

Local Trends
Similar to trends occurring in Orange County, areas with higher median incomes are associated with a larger proportion of white residents compared to census tracts with lower median incomes.

Neighborhoods in the northeast corner of Fullerton had a predominately white population and the highest median income levels in the city, as shown in Figure E-21. In Fullerton, the neighborhoods of E Las Palmas Dr/N Sunnywood Dr, Craig park, Sunny Hills, Bastanchury Rd/Fairway Isles Dr, Acacia Park, and Byerrum Park are defined as RCAAs.

Most RCAA designated neighborhoods in northeast Fullerton are comprised primarily of single-family homes. Less than 10 percent of structures are comprised of two or more units. This is much less than the neighborhoods in the southern half of the City, where between 20 and 35 percent of the housing stock is comprised of multifamily homes in most areas. Bastanchury Rd/Fairway Isles Dr, Acacia Park, and Byerrum Park neighborhoods have a lower percentage of older units than other neighborhoods in the city, with less

8 Goatz, Damanio and Williams, 2019. https://www.huduser.gov/portal/periodicals/cityscpe/vol21num1/ch4.pdf

Appendix H-E: Housing Element H-E-41
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than 20 percent built before 1960. In the neighborhoods of E Las Palmas Dr/N Sunnywood Dr and Craig Park, between 20 and 40 percent of units were built prior to 1960. This is much lower than the southern portion of the city, where between 40 and 80 percent of units were built prior to 1960. RCAAs in Fullerton have lower rates of overcrowding. Most residents in RCAAs do not have walkable access to High Quality Transit Stops.

A survey conducted in May 2024 to gather stakeholder input provided local knowledge on the patterns of RCAA designated neighborhoods in northeastern Fullerton. Five survey respondents indicated that RCAAs are characterized by large parcels, large single-family homes, greater setbacks, and hilly terrain. The large, single-family homes are affordable to higher-income residents who are typically well-educated professionals. The area also has abundant parkland and high performing schools. It was noted that RCAAs in Fullerton have minimal multifamily zoning and opportunities for diverse housing typologies, which limits opportunities for low or moderate-income households. It was also noted that while some residents in RCAAs may support constructing an ADU for a family member, they are generally opposed to additional density, citing infrastructure constraints. The lack of diverse housing opportunities in RCAAs has created and perpetuated racial and economic segregation within the city.

While most of the RCAAs are built out, the City has prioritized strategies to increase density and diversify housing types in these areas:
• Providing adequate sites for housing development, targeting higher density development in northeastern Fullerton (Policy Action 3.1)
• Facilitating infill development in high resource areas, particularly on religious sites (Policy Action 3.3) • Targeting ADU outreach in high resource areas (Policy Action 3.6) • The Site Inventory identifies 1,008 housing units in RCAAs, including 368 lower-income units and 311 moderate-income units, to provide diverse housing opportunities and increase opportunities for economic integration. The City will also implement Policy Action 3.4 to support the development of a variety of housing types and greater densities, as well as Policy Action 3.6 to support ADU development in northern Fullerton.

H-E-42 Appendix H-E: Housing Element
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Figure E-20 Racially Concentrated Areas of Affluence (Orange County)

Source: AFFH Viewer, 2022

Appendix H-E: Housing Element H-E-43
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Figure E-21 Racially Concentrated Areas of Affluence (Fullerton)

Source: AFFH Viewer, 2022

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Housing Element
E.6 Disparities in Access to Opportunities
According to HCD guidance, land use policies and urban planning impact the ability of residents to access neighborhoods of opportunity, with high-performing schools, greater availability of jobs that afford entry to the middle class, and convenient access to transit and services. The limits on housing choice and access experienced by people within protected classes, such as race, sexual orientation, or disability, have far- reaching impacts on access to job opportunity, quality education, and mental and physical health.9 This section analyzes the following place-based characteristics linked to opportunity indicators: quality education, employment, transportation, and healthy environment. The primary objective is to understand the disparity between communities in terms of access to real and potential economic benefits and quality of life.

HUD’s Opportunity Indices were created to inform communities about racial/ethnic segregation and disparities in access to opportunity.10 Table E-8 provides opportunity indicator index scores (ranging from 0-100, with 100 representing the most positive outcomes) for Fullerton for each race/ethnicity, as described by the AI. Measured at the neighborhood level, the index scores are intended to inform communities about segregation and disparities in access to opportunity in their jurisdiction and compare the opportunity indicators rankings across racial/ethnic groups. Generally, higher index scores are indicative of greater access to opportunity. For example, the “low poverty index” captures the poverty rate within a given neighborhood; the higher the index score means the less exposure to poverty. A higher “jobs proximity” score means that residents have greater accessibility to employment locations within the larger region.
11 Each index is measured using the following variables:
• Economic Opportunity Index: a composite of poverty rate by census tract, percentage of adults with a bachelor’s degree, percentage of adults employed, and number of jobs for persons without a bachelor's degree that fall within a given radius of each census tract. • Environmental Opportunity Index: exposure to pollution burden shown in CalEnviroScreen. • Educational Opportunity Index: the percentage of fourth-grade students testing proficient in reading and math within three miles of a census block group.
• Low Transportation Cost Index: the cost of transportation and proximity to public transportation by neighborhood.
• Transit Index: How often low-income families in a neighborhood use public transportation.

In Fullerton, Asian/Pacific Islander and white, non-Hispanic residents have greater accessibility to areas with greater economic opportunity, lower environmental pollutants, educational opportunity, lower transportation costs. In comparison, Hispanic/Latino residents and, Black/African-American and Hispanic/Latino populations had greater access to public transit, but lower economic and educational opportunities, and the greatest exposure to environmental health concerns. Most opportunity scores were lower for residents earning an income below the federal poverty level compared to the total population in Fullerton.

9 HCD. 2021. https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf 10 HUD, 2020. https://www.hud.gov/sites/dfiles/FHEO/documents/AFFH-T-Data-Documentation-AFFHT0006-July-2020.pdf 11 Urban Institute, 2018. https://www.urban.org/sites/default/files/publication/98674/place_and_opportunity_brief_3.pdf

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Residents who earned an income below the poverty level in Fullerton had lower economic and education opportunities, greater exposure to environmental health concerns, but lower transportation costs.

Black/African American, Hispanic/Latino and Asian/Pacific Islander residents earning below the poverty line had greater access to public transit.

Table E-8 Opportunity Indicators by Race/Ethnicity (Fullerton) Total Population
Economic
Opportunity
Index
Environmental
Opportunity
Index
Educational
Opportunity
Index
Low
Transportation
Cost Index
Transit
Index
White, Non-Hispanic 55.78 26.03 58.12 38.56 36.36
Black, Non-Hispanic 43.93 23.39 50.62 43.17 39.78
Hispanic 37.14 20.28 43.05 41.48 39.47
Asian or Pacific Islander, Non-Hispanic 64.09 25.70 65.77 35.43 35.37 Native American, Non-Hispanic 42.61 22.90 48.14 41.21 38.35 Population Below Federal Poverty Line
White, Non-Hispanic 42.62 23.49 50.72 45.41 10.98
Black, Non-Hispanic 26.27 20.02 37.49 50.76 44.32
Hispanic 29.84 19.52 38.35 43.06 41.15
Asian or Pacific Islander, Non-Hispanic 57.70 27.73 64.75 42.01 39.39 Native American, Non-Hispanic 43.26 22.70 51.35 38.76 34.99 Source: County of Orange AI, 2020
An overview of opportunity indicators for Orange County is provided in Table E-9. According to the AI, compared to Orange County, Fullerton scored slightly lower for economic opportunity and educational opportunity, and had significantly greater exposure to environmental health concerns. Fullerton scored higher for transportation costs and proximity to public transit compared to Orange County as a whole.

Across Orange County, residents earning an income below the poverty level scored slightly lower for environmental health concerns, and economic and educational opportunities compared to the total population.

H-E-46 Appendix H-E: Housing Element
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Housing Element
Table E-9 Opportunity Indicators by Race/Ethnicity (Orange County) Total Population
Economic
Opportunity
Index
Environmental
Opportunity
Index
Educational
Opportunity
Index
Low
Transportation
Cost Index
Transit
Index
White, Non-Hispanic 59.36 53.88 58.61 33.84 27.43
Black, Non-Hispanic 45.85 45.21 45.63 39.68 36.21
Hispanic 31.86 41.02 30.86 41.80 41.28
Asian or Pacific Islander, Non-Hispanic 49.36 46.78 52.50 37.48 36.11 Native American, Non-Hispanic 46.39 48.19 45.07 37.47 33.02 Population Below Federal Poverty Line
White, Non-Hispanic 51.70 51.01 52.13 39.18 32.26

36.25 36.25 40.42 37.29 40.77 35.60
Hispanic 22.65 39.02 23.81 45.65 46.35
Asian or Pacific Islander, Non-Hispanic 38.9 46.38 48.32 41.97 39.51 Native American, Non-Hispanic 35.89 38.62 40.92 40.15 40.17 Source: County of Orange AI, 2020
E.6.1 Transit Access and Walkability
Reliable public transit access and active transportation options such as walking and biking are imperative for low-income residents and/or persons with disabilities to connect to employment opportunities. Lack of transportation options can impede fair housing choice and continue to reinforce barriers for low-income communities in accessing housing and employment opportunities.

Regional Trends
Orange County generally has widespread access to public transit. Accessible transportation infrastructure includes the Orange County Transportation Authority (OCTA), Metrolink, and Amtrack. OCTA provides a variety of bus services and OC Flex, an on-demand curb-to-curb shuttle service. Amtrak operates the Pacific Surfliner, which runs along the 351-mile Los Angeles – San Diego – San Luis Obispo Rail Corridor (LOSSAN Corridor) through Orange County. The Surfliner stops at stations in Fullerton, Anaheim, Santa Ana, and Irvine.

Transit use is higher where investment in transit service has been made. Almost all major employment centers in Orange County are served by some form of public transit. However, having regional access to jobs by means of public transit does not necessarily translate into stable employment. Some residents with unique needs, such as households with children, have unique travel patterns that may prevent them from obtaining work far from home due to childcare needs, access to schools, and other considerations.

Orange County received an average AllTransit performance score of 4.2 which equates to a low combination of trips per week and number of jobs accessible by transit, enabling relatively few people to take transit to work.
12 The land uses within Orange County do not support transit ridership. Throughout much of the county, residential uses are low density and spread out. The streets were not designed with walkability in mind. Additionally, bus service is focused on a select number of hubs, and on a few key

12 AllTransit.Org, 2023. https://alltransit.cnt.org/

Appendix H-E: Housing Element H-E-47
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corridors, mostly within the northern part of the county. As a result, there can be barriers between a commuter’s transit stop and their home. Of the six SCAG counties, Orange County’s AllTransit score ranks third, below Los Angeles County (6.8) and San Bernadino (4.4), but above Imperial County (0.1), Riverside (3.3), and Ventura (3.4).

Local Trends
The City of Fullerton is not very accessible by public transit. According to AllTransit, only 2.7 percent of workers in Fullerton take public transportation to work. The city has an AllTransit Performance Score of 4.8, which is higher than the county as a whole but still results in few people taking transit to work.

Metrolink’s Orange County line and 91-Perris line run through Fullerton, as well as Amtrak’s Surfliner, with a stop at the Fullerton Transit Station. There are also several bus lines operated by OCTA.

Figure E-22 illustrates transit access within a quarter-mile of transit stops for both bus routes and Metrolink. A significant portion of the city is within a quarter-mile access of a transit stop, particularly within the southern half of the city. The northern half of the city has less access to transit. The neighborhoods of Acacia Park, West Coyote Hills, Emery Park, and Amerige Heights have limited access to transit.

Fullerton has some neighborhoods with high walkability. Walk Score is a private company that offers a walkability index on its website, that measures the pedestrian friendliness of a given location by analyzing walking routes to nearby amenities and examining population density and road metrics, including block length and intersection density.13 According to Walk Score, Fullerton has a walk score of 54 out of 100, which is categorized as “Somewhat Walkable.”14 Downtown Fullerton has a Walk Score of 97, which is categorized as “Walker’s Paradise.”
The Environmental Protection Agency (EPA) also has a walkability index, that ranks block groups according to their relative walkability.
15 The EPA walkability map, shown in Figure E-23, shows that most of the city has a walkability score above that national average. The highest walkability scores are generally located in the southern portion of the city, although there are pockets of high walkable neighborhoods scattered throughout the city. Neighborhoods located in the northern area of Fullerton have lower walkability scores compared to the rest of the city.

13 Walk Score, 2022. https://www.walkscore.com/methodology.shtml 14 Walk Score, 2022. https://www.walkscore.com/CA/Fullerton 15 EPA, 2021. https://www.epa.gov/smartgrowth/national-walkability-index-user-guide-and-methodology

H-E-48 Appendix H-E: Housing Element
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Figure E-22 Access to Transit Within a Quarter-Mile (Fullerton)

Source: City of Fullerton, County of Los Angeles, 2022.

Appendix H-E: Housing Element H-E-49
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Figure E-23 Walkability Index (Fullerton)

Source: National Walkability Index, 2022.

H-E-50 Appendix E: Affirmatively Furthering Fair Housing (AFFH) City of Fullerton
Housing Element
E.6.2 Access to Quality Education
Economics literature has consistently found about a 10 percent increase in wages/salary with each additional year of education.16 Therefore, educational attainment is directly linked to housing opportunities. To assess educational opportunities by geography, this analysis uses TCAC education domain scores, which incorporate a variety of indicators including math and reading proficiency scores, high school graduation rates, and student poverty rates at the census tract level.

Regional Trends
An overview of education outcomes across Orange County is illustrated in Figure E-24. Educational outcomes varied across Orange County, In general, urban areas in the northwest portion of the county had less positive education outcomes compared with the rest of the county, particularly in Santa Ana, Anaheim, and Placentia. Additionally, the neighborhood of Great Park in Irvine had low educational outcomes compared to the county, however there are limited residential uses in this neighborhood. According to Kidsdata.org, a data compilation program of the Lucile Packard Foundation for Children's Health, Orange County high school graduation rates were highest among Asian-American and Filipino students (95 percent) and white, non-Hispanic students (94 percent). American Indian/Alaska Native students (86 percent) and Hispanic/Latino students (87 percent) had lower graduation rates. 17 Local Trends
Fullerton’s youth are served by the Fullerton School District (FSD) and Fullerton Joint Union High School District (Fullerton JUSD). FSD serves kindergarten through eighth grade students in the City of Fullerton.

FSD operates 15 elementary schools, two K-8th campuses, and three junior high schools.18 Fullerton JUSD operates five high schools in Fullerton and serves the City of Fullerton and the cities of La Habra, La Habra Heights, Buena Park, and small sections of Brea and Whittier. The City of Fullerton is also served by 11 private schools that serves kindergarten students through high school.19 Figure E-25 shows Fullerton’s TCAC scores for education outcomes at the census tract level. In general, the southern areas of the city had the lowest degree of positive education outcomes, particularly in the neighborhood of Rancho La Paz. This area also has a high percentage of LMI population, predominant Hispanic majority, and lower median income. The northern portion of the city has more positive educational outcomes. These areas also have high percentages of Asian American and non-Hispanic White residents, higher incomes, and a lower percentage of LMI residents.

16 Annual Disability Statistics Compendium, 2020. https://disabilitycompendium.org/annualreport 17 Kids Data. 2021. All Data: Orange County. https://www.kidsdata.org/region/365/orange-county/results#ind=&say=&cat=18 18 Fullerton School District. https://www.fullertonsd.org/domain/6 19 City of Fullerton. Private Schools. https://www.cityoffullerton.com/residents/schools/private-schools

Appendix H-E: Housing Element H-E-51
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Figure E-24 TCAC Opportunity Areas – Education Outcomes (Orange County)

Source: AFFH Viewer, 2022

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Figure E-25 TCAC Opportunity Areas - Education Outcomes (Fullerton)

Source: AFFH Viewer, 2022

Appendix E: Affirmatively Furthering Fair Housing (AFFH) H-E-53 City of Fullerton
Housing Element
E.6.3 Economic Outcomes
Housing opportunities are directly related to economic opportunities. Access to high quality employment close to desired and affordable housing results in more housing opportunities and shorter commute times.

The analysis for economic opportunities uses TCAC economic indicators, employment participation data from the ACS and the HUD Jobs Proximity Index.

TCAC economic opportunities are measured by census tract. They consider poverty, adult education, employment, job proximity, and median home values. A higher economic index score reflects more positive economic outcomes. The HUD Jobs Proximity Index assesses the accessibility to job opportunities at the census block group level.

Regional Trends
Economic outcomes vary across Orange County as shown in Figure E-26. Areas with more positive economic outcome scores were identified along the coastal communities and in the southern and eastern portions of the county. Conversely, similar to educational outcomes, the urban areas in the northwestern portion of the county had less positive economic outcomes, particularly in Santa Ana, Anaheim, Fullerton, and Buena Park.

According to ACS estimates, Orange County has an employment rate of 60 percent, a decrease of three percent from 2019. Table E-10 shows employment status by disability status estimates for Orange County for ACS 2015-2019 and 2017-2021. Overall, the percent of all employed residents age 16 remained the same, but unemployment increased slightly.

Table E-10 Employment Status by Disability Status (Orange County) Disability Status
Employed
2015-2019
Unemployed
2015 -2019
Employed
2017-2021
Unemployed
2017-2021
No Disability 1,445,013
(96.7%)
65,384
(91.9%)
1,435,544
(96.3%)
77,022
(91.8%)
With a Disability 48,800
(3.2%)
5,723
(8.0%)
54,620
(3.6%)
6,819
(8.1%)
Total 1,493,813
(74.7%)
71,107
(3.5%)
1,490,164
(74.4%)
83,841
(4.1%)
Source: U.S. Bureau of the Census, ACS Table C18120 Employment Status by Disability Status, 2015-2019, 2017-2021 Estimates.

Local Trends
The TCAC opportunity maps help to identify patterns of negative and positive economic, educational and environmental outcomes across the state. Census tracts are ranked from low (negative outcomes) to highest resource (positive outcomes) based on TCAC’s Opportunity Maps analysis. TCAC economic outcome scores vary across neighborhoods in Fullerton, as shown in Figure E-27.

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City of Fullerton
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Figure E-26 TCAC Opportunity Areas - Economic (Orange County)

Source: AFFH Viewer, 2022.

Appendix H-E: Housing Element H-E-55
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Figure E-27 TCAC Opportunity Areas – Economic (Fullerton)

Source: AFFH Viewer, 2022

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Generally, lower economic outcomes are located in the southern part of the city south of Commonwealth Avenue. However, the neighborhood California State University Fullerton in the east of the city also has less positive economic outcomes, likely due to the prevalence of students. The E Imperial Hwy/N Harbor Blvd neighborhood is characterized as having less positive economic outcomes, but no residential units are located in this neighborhood. Areas with more positive economic outcomes were in the central and northern portions of Fullerton. Generally, areas with lower economic outcome scores were in neighborhoods with a higher percent of Hispanic/Latino residents, whereas areas with higher economic outcomes had a predominately non-Hispanic white or Asian-American population.

Employment status by disability status estimates is provided in Table E-11. The labor participation rate of residents age 16 and older decreased by one percent, slightly more than the county’s rate of change. The number of employed residents with a disability increased slightly in Fullerton, while employment for residents without a disability decreased. The total unemployment rate (5.6 percent) in 2021 is higher than the county (4.1 percent), but lower than the SCAG region (9.3 percent).

Table E-11 Employment Status by Disability Status (Fullerton) Disability Status
Employed
2015-2019
Unemployed
2015 -2019
Employed
2017-2021
Unemployed
2017-2021
No Disability 62,864
(96.5%)
4,206
(93.2%)
61,918
(95.8%)
4,768
(93.2%)
With a Disability 2,234
(3.4%)
305
(6.7%)
2,648
(4.1%)
346
(6.7%)
Total 65,098
(72.0%)
4,511
(4.9%)
64,566
(71.0%)
5,114
(5.6%)
Source: U.S. Bureau of the Census, ACS Table C18120 Employment Status by Disability Status, 2015-2019, 2017-2021 Estimates.

According to TCAC, census tracts with a designation of “High Resource” indicate that the census tract has strong educational and economic opportunities for current and future residents. The majority of Fullerton is comprised of moderate to high resource areas. The highest resource areas are concentrated in the central and northern portion of the city. Several neighborhoods in the city are characterized as low resource, including Gilbert Park, Woodcrest Park, and Rancho La Paz. E Imperial Hwy/N Harbor Blvd in the northern tip of the city also is characterized as low resource, but this neighborhood is comprised of commercial and industrial uses and does not contain any residential units.

Access to employment opportunities has a significant impact on the type and size of housing a household can afford. HUD’s Jobs Proximity Index utilizes origin-destination employment statistics to examine the distance from a given neighborhood to all job locations in the Southern California Region and assess the accessibility to job opportunities at the census block group level. Because the size of employment centers and the supply of labor differ across the SCAG region, the distance from any single job location is positively weighted by the size of employment (job opportunities) at that location and inversely weighted by the labor supply (competition) to that location.
20 Accessibility to employment opportunities differs across Fullerton is shown in Figure 5-28. Neighborhoods with the highest access to employment opportunity are concentrated in the eastern area of the city, primarily east of Harbor Boulevard, which is closest to the industrial zoned areas of northeastern Anaheim.

20HUD, 2020. https://www.hud.gov/sites/dfiles/FHEO/documents/AFFH-T-Data-Documentation-AFFHT0006-July-2020.pdf

Appendix H-E: Housing Element H-E-57
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Generally, accessibility to jobs decreases relative to the distance from that area, with the lowest scores in the western and southern areas of the city. Neighborhoods with the lowest job proximity scores in the southwestern area of the city are primarily comprised of single-family homes with pockets of commercial, and no industrial uses. Although it may appear counter-intuitive, there are some neighborhoods with higher proximity to jobs, such as Rancho La Paz that the lowest TCAC economic outcome scores and higher rates of LMI populations compared to other areas of the city with lower proximity to jobs. Despite being in close proximity to employment, residents in this area of Fullerton may not benefit from high proximity to job centers, as this area has low TCAC economic outcome scores and a high share of LMI populations.

E.6.4 Healthy and Safe Housing Environment
Healthy Environment in AFFH addresses disparities in access to environmentally healthy neighborhoods by protected class groups. An assessment of environmentally healthy neighborhoods can include air and water quality, safety, environmental hazards, social services, and cultural institutions. Recent California laws— Assembly Bill (AB) 1550, Senate Bill (SB) 535 and SB 1000 emphasize the importance of environmental justice as a fair housing issue. Environmental Justice, according to HUD, means ensuring that people have equal access to safe and healthy housing. HUD requires all entitlement jurisdictions to conduct reviews under the National Environmental Protection Act to determine if a proposed project creates adverse impacts due to environmental conditions. It furthers the requirement that human health deserves equal protection for all people regardless of race, color, national origin, or income. Under Executive Order 12898, Federally assisted projects may also target funding to communities that have disproportionately high and adverse human health impacts on minority and low-income populations due to environmental conditions. 21 The California Office of Environmental Health Hazard Assessment developed CalEnviroScreen, a mapping tool that uses spatial data collected by various regulatory agencies (e.g., air quality indicators from South Coast Air Quality Management District, water quality indicators from Orange County Water District, monitored chemical releases into the air or water table from Environmental Protection Agency, HUD socio- economic indicators, etc.). The dataset uses a methodology to identify communities disproportionately burdened by exposures to pollution, environmental effects of existing pollutants in communities, among other indicators of sensitive populations or socioeconomic factors. Residents in census tracts with high CalEnviroScreen scores as compared to other California census tracts (shown as percentiles) are disproportionately burdened by pollution and are more vulnerable to related effects.

21 HUD, 2022. https://www.hudexchange.info/programs/environmental-review/environmental-justice/

H-E-58 Appendix E: Affirmatively Furthering Fair Housing (AFFH) City of Fullerton
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Figure 5-28 Job Proximity Index (Fullerton)

Source: AFFH Viewer, 2022

Appendix E: Affirmatively Furthering Fair Housing (AFFH) H-E-59 City of Fullerton
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Regional Trends
The CalEnviroScreen map for Orange County identifies the degree to which communities are considered burdened by pollution. Figure E-29 shows that generally, the more urbanized, northwestern portions of the county have less positive environmental outcomes, most notably near the industrial areas in the cities of Buena Park, Stanton, Fullerton, Anaheim, Garden Grove, and Santa Ana.

Local Trends
As shown in Figure E-30, pollution burden varies across Fullerton communities. In general, the northern portion of the city, particularly the neighborhoods of Sunny Hills and Acacia Park, has more positive environmental outcomes than areas south. The neighborhood of E Imperial Hwy/N Harbor Blvd, which contains several distribution centers with high truck traffic, and the neighborhood of Woodcrest Park, which contains large, big box commercial areas that generate car trips, have the worst environmental outcomes within the city. Areas with high pollution tend to have a greater percentage of industrial or commercial land uses. Areas with higher pollution burden are also areas that that had higher percentages of Hispanic/Latino residents, as shown in Figure E-30.

According to TCAC, environmental outcome scores vary across the city. Figure E-31 shows that higher environmental health scores are concentrated in western and northeastern Fullerton. Similarly, TCAC shows that the neighborhoods of Sunny Hills and Acacia Park have the highest environmental outcomes in the city. These areas have a high proportion of open space and public lands, and a majority white, non- Hispanic population. Conversely, the neighborhoods with the heavier pollution burden are concentrated in the southeastern portion of the city and have a higher percentage of Hispanic/Latino residents.

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Figure E-29 CalEnviroScreen 4.0 Percentile Scores (Orange County)

Source: AFFH Viewer, 2022

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Figure E-30 CalEnviroScreen 4.0 Percentile Scores and Predominant Racial/Ethnic Populations (Fullerton)

Source: AFFH Viewer, 2022

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Figure E-31 TCAC Opportunity Areas – Environment (Fullerton)

Source: AFFH Viewer, 2022

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E.7 Disproportionate Housing Needs
Disproportionate housing needs refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need, or the total population experiencing that category of housing need in the applicable geographic area. To analyze the extent of disproportionate housing needs in Fullerton, this section reviews data on housing cost burden and severe housing cost burden, overcrowding, homelessness, and substandard housing conditions.

Information for this section relies on the HUD CHAS data.

E.7.1 Housing Cost Burden
Housing cost burden is defined as the proportion of a household’s total gross income spent on housing costs. Households that spend at least 30 percent of their total gross income on housing costs (rent, mortgage, utilities, and other housing-related costs) are considered “cost burdened,” and households spending over 50 percent on housing costs are considered “severely cost burdened.” The higher the housing cost burden, the more likely residents are to live in overcrowded and substandard conditions and are less likely to afford to relocate. Low-income households and persons in protected classes disproportionately experience severe housing problems.

Regional Trends
Figure E-32 shows areas of Orange County where renter households experienced housing cost burden (spending more than 30 percent of household income on housing costs). As shown, paying more than 30 percent of gross income on rent is widespread across most of Orange County, where a significant portion of the county have between 40 and 80 percent of renter households pay more than 30 percent or more of household incomes on rent. There are a few census tracts in the county where over 80 percent of renter households pay more than 30 percent or more of household incomes on rent, particularly within the urbanized northern portion of the county including within the cities of Yorba Linda, Placentia, Orange, and Fountain Valley. Additionally, the less urbanized coastal community of Laguna Niguel has high levels of overpayment. Overpayment amongst homeowners is also widespread across the county, as shown in Figure E-33. Housing cost burden among homeowners is most prevalent in the northwestern area of the county, especially in the cities of Placentia, Anaheim, Westminster, and Santa Ana.

Local Trends
Similar to Orange County, housing cost burden among renters varies across Fullerton. As Shown in Figure E-34, most neighborhoods in Fullerton have between 40 and 80 percent of renters experiencing housing cost burden, according to 2017-2021 ACS estimates. The neighborhoods with higher rates of cost burden (60 and 80 percent of renters) include Brea West, Craig Park Artisan Walk, California State University, and Bradford Park, located in the northeast of the city, and Valencia Park, W Valencia Dr/Courtney Ave, S Woods Ave/W Orangethorpe Ave, located in the southwest of the city. The neighborhood with the lowest rates of overpayment by renters (less than 20 percent) is West Coyote Hills.

Housing cost burden among owner-occupied households varies across the city. An overview of housing cost burden for owner-occupied households is provided in Figure E-35. In most of the city, between 20 and 60 percent of owner-occupied households are cost burdened. The neighborhood of Emery Park has the highest percentage of cost burdened households within the city (between 60 and 80 percent). Areas with the highest cost burden generally have higher percentages of Asian American, non-Hispanic, and

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Hispanic/Latino populations. The California State University Fullerton neighborhood has between 40 and 60 percent of owner-occupied households are cost burdened; however, this neighborhood also has a significantly lower percentage of owner-occupied units than the city as a whole (13 percent, compared to 50 percent for the entire city).

Nine neighborhoods within Fullerton contain between 60 and 80 percent of cost burdened renters. As shown in Figure E-36, three of these neighborhoods have a majority non-Hispanic white population, and six of these neighborhoods had a majority Hispanic/Latino population. The lowest rate of overpayment by renters was in the West Coyote Hills neighborhood in the northwest corner of the city, which is predominantly Asian American.

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Figure E-32 Overpayment by Renters (Orange County)

Source: AFFH Viewer, 2022

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Figure E-33 Overpayment by Homeowners (Orange County)

Source: AFFH Viewer, 2022

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Figure E-34 Overpayment by Renters (Fullerton)

Source: AFFH Viewer, 2022

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Figure E-35 Overpayment by Homeowners (Fullerton)

Source: AFFH Viewer, 2022

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Figure E-36 Overpayment by Renters and Predominant Racial/Ethnic Populations (Fullerton)

Source: AFFH Viewer, 2022

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E.7.2 Overcrowding
Overcrowding is defined as housing units with more than one person per room (including dining and living rooms but excluding bathrooms and kitchen) while severe overcrowding refers to more than 1.5 persons per room. Overcrowding is a measure to understand the needs of large families, defined as five or more persons per household. Generally, large households have special housing needs due to lower per capita income and the need for housing with three or more bedrooms.

Some large households may not be able to accommodate high-cost burdens for housing and accept housing with too few rooms. Potential fair housing issues emerge if non-traditional households are discouraged or denied housing due to a perception of overcrowding. Household overcrowding reflects various living situations, including housing units that are inadequately sized to meet a household’s needs; the necessity or desire to have extended family members reside in an existing household; or unrelated individuals or families that share a single housing unit.

Not only is overcrowding a potential fair housing concern, but it can also potentially strain electrical systems in older housing that have not been updated or contribute to a perceived shortage of parking. As a result, some property owners/managers may be more hesitant to rent to large households, thus making access to adequately sized housing even more difficult. According to local fair housing service providers and property managers, addressing the issue of large households is complex as there are no set of guidelines for determining the maximum capacity for a unit. Fair housing issues may arise from policies aimed to limit overcrowding that have a disparate impact on specific racial or ethnic groups with different preferences for housing size and/or ability to pay according to the household size standards identified.

Regional Trends
Orange County has 144,734 large households; approximately 13 percent of total households. Owner- occupied households comprise a larger share than renters of the total number of large households in the county. Overcrowding remains low overall in the county, compared to the statewide average, but there is a disproportionate impact of overcrowding in households primarily occupied by non-white racial/ethnic groups. According to ACS 2021 estimates, three percent of white, non-Hispanic households are overcrowded (more than one occupant per room), compared to 22 percent of Hispanic/Latino, eight percent of Asian, and four percent of Black/African American households. According to the California Department of Health and Human Services data shown in Figure E-37, overcrowded housing is most prominent in the northwestern area of Orange County, mainly in urban centers such as the cities of Santa Ana, Garden Grove, Orange, Anaheim, Buena Park, La Habra, Costa Mesa, and Westminster. There are also pockets of overcrowding int the southern area of Orange County near the cities of Laguna Niguel and Mission Viejo.

Local Trends
According to ACS 2017-2021 data, Fullerton has 6,651 large households; approximately 14 percent of the total households. Renter occupied large households comprise of 52 percent of the total number of large Fullerton households. Additionally, 10.8 percent of households in Fullerton are overcrowded, slightly higher than 8.6 percent for the county as a whole. Fullerton has an average of 2.87 persons per household in 2021, a decrease from 2011, when the city had an average of 3.00 persons per household. As shown in Figure E-38, neighborhoods with a higher degree of overcrowded households are generally located in the southern area of the city.

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Figure E-37 Overcrowded Households (Orange County)

Source: AFFH Viewer, 2022

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Figure E-38 Overcrowded Households (Fullerton)

Source: AFFH Viewer, 2022

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The neighborhood with the highest percentage of overcrowding is Woodcrest Park (more than 20 percent).

The predominant population in this area is Hispanic/Latino. Neighborhoods with 10 to 15 percent overcrowding include Artesia Blvd/N Gilbert St, Valencia Park, W Oak Ave/Lambert Dr, E Wilshire Ave/N Raymond Ave, Rancho La Paz. The AFFH Data Viewer also shows the neighborhood of E Imperial Hwy/N Harbor Blvd in northern Fullerton as having high levels of overcrowding; however, this data is based on the residential units within the neighboring cities of La Habra and Brea. The portion of this census tract located within the City of Fullerton is comprised of entirely commercial and industrial uses and does not contain any residential units. Neighborhoods with low levels of overcrowding are generally located in the central and northern portion of the city.

According to the 2017-2021 ACS estimates shown in Figure E-39, overcrowding is a more common housing issue for residents of Fullerton who identified as American Indian/Alaskan Native, Hispanic/Latino, and those of “other race or multiple races” than for people who identified as white, non-Hispanic, Black/African American, or American Indian/Alaska Native.

Figure E-39 Overcrowding by Race in Fullerton

Notes: The Census Bureau does not disaggregate racial groups by Hispanic/Latino ethnicity. However, data for the white racial group is also reported for white householders who are not Hispanic/Latino. Since residents who identify as white and Hispanic/Lati no may have very different experiences within the housing market and the economy from those who identify as white and non-Hispanic/Latino, data for multiple white sub-groups are reported here. The racial/ethnic groups reported in this table are not all mutually exclusive. Therefore, the data should not be summed as the sum exceeds the total number of occupied housing units for this jurisdiction. However, all groups labelled “Hispanic and Non- Hispanic” are mutually exclusive, and the sum of the data for these groups is equivalent to the total number of occupied housing units. *Hispanic and non-Hispanic
Source: U.S. Census Bureau, American Community Survey 5-Year Data (2017-2021), Table B25014A-I 9%
21%
11%
0%
23% 22%
2% 3%
0%
5%
10%
15%
20%
25%PERCENT OF HOUSEHOLDS
MORE THAN 1.0 OCCUPANTS PER ROOM

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E.7.3 Housing Problems
HUD considers housing units to be “standard units” if they are in compliance with local building codes.

Many federal and State programs use the age of housing as a factor to determine a community’s housing rehabilitation needs. Housing age can be an important indicator of housing condition in 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. Typically, housing over 30 years old is more likely to have rehabilitation needs that may include replacing plumbing, roof repairs, foundation work, and other repairs. Housing units built before 1978 may have health risks such as lead-based paint and asbestos. Housing issues prompted by disrepair such as mold may elevate health conditions such as asthma.

Regional Trends
Housing problems are defined as units having incomplete kitchen facilities, incomplete plumbing facilities, more than one person per room, and households with a cost burden greater than 30 percent. Severe housing problems are defined as all of the above and with a cost burden greater than 50 percent.22 Approximately 44 percent of total households in Orange County experience housing problems, and another 26 percent of total households experience severe housing problems. According to the AI, more than half of Hispanic/Latino (63 percent) households experience housing problems compared to white, non-Hispanic residents. Housing problems are significantly higher among large households, as nearly 65 percent of large households experience housing problems compared to 39 percent of households comprising less than five persons.

A housing unit is considered substandard by the ACS if it lacks complete plumbing or kitchen facilities.

According to the 2017-2021 ACS, 0.2 percent of all occupied housing units in Orange County lack complete plumbing facilities and 1.3 percent lack complete kitchen facilities.

Fifty-six percent of Orange County’s housing stock was built prior to 1980. These units are potentially in need of repair and modernization improvements. Additionally, lead-based paint was banned from residential uses in 1978. All houses constructed before 1978 are therefore considered at risk for containing lead-based paint.

Local Trends
According to the 2015-2019 CHAS data, 46 percent of households in Fullerton experience at least one housing problem, similar to the rate for Orange County. According to the AI, Hispanic/Latino, Asian/Pacific Islanders, and Black/African-American households experience the highest rate of housing problems at 63, 48, and 45 percent, respectively. In comparison, 36 percent of white, non-Hispanic households experienced housing problems. According to the 2017-2021 ACS, 0.3 percent of all occupied housing units in Fullerton lack complete plumbing facilities and 2.2 percent lacked complete kitchen facilities, slightly higher than the county as a whole. Over 74 percent of the city’s current housing stock is greater than 40 years old.

Additionally, 71 percent of large households (five or more persons) in the city experience housing problems compared to 42 percent of households of five persons or less, as referenced in the AI.

22 HUD, 2021. https://www.huduser.gov/portal/datasets/cp/CHAS/bg_chas.html

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Respondents to a survey conducted in May 2024 to gather stakeholder input noted the neighborhoods of Independence Park, Artesia Blvd/N, Gilbert Park, W Commonwealth Ave/N Basque Ave; Valencia Park, as well as the neighborhoods south of Commonwealth Ave, and areas near downtown and the train station have a concentration of units in need of rehabilitation.

E.7.4 Persons Experiencing Homelessness
Regional Trends
The 2022 Orange County Everyone Counts Point-in-Time (PIT) Summary is the most recent evaluation of people experiencing homelessness in the county. According to the 2022 PIT count, there were 5,718 people experiencing homelessness in Orange County (sheltered and unsheltered), which was a decrease of 1,142 people (16.7 percent) from 2019 (latest available comparable year). There were 3,961 individuals who were observed as being unsheltered in the county, a decrease of 904 people from 2019.

Fifty-five percent of unsheltered individuals, and 38 percent of sheltered individuals in Orange County were chronically homeless (individual has a disabling condition and has had four episodes of homelessness in the past three years or has been continuously homeless for one year or longer). Twenty-eight percent of sheltered individuals reported suffering from a mental health issue, 20 percent reported a substance abuse issue, and 11 percent were fleeing domestic and dating violence. Three percent had HIV/AIDS, and one percent had a developmental disability. Sheltered individuals were more likely to be male (51.4 percent) and most likely to be older than the age of 25 (72.6 percent). Approximately 4.7 percent were young adults between the ages of 18 and 24, and 22.6 percent were younger than 18 years of age.

White, non-Hispanic residents had the largest overrepresentation in terms of percent of sheltered individuals respective of county population share (77 percent of sheltered individuals versus 43 percent share of population). Asian Americans were the most underrepresented for sheltered individuals respective of city population share (4 percent of sheltered individuals versus 22 percent of population share). Other racial/ethnicity groups of sheltered individuals were closer to their respective city population shares.

State law (Section 65583(a)(7)) requires municipalities to address the special needs of persons experiencing homelessness within their boundaries. “Homelessness,” as defined by HUD, describes the condition of an individual, who is not imprisoned or otherwise detained, who:
• Lacks a fixed, regular, and adequate nighttime residence; and • Has a primary nighttime residence that is:
o 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);
o An institution that provides a temporary residence for individuals intended to be institutionalized; or
o A public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings.

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Local Trends
The 2024 PIT count reported that 434 individuals were experiencing homelessness in Fullerton, including 226 sheltered and 208 unsheltered. This represents an increase of 162 individuals experiencing homelessness compared to the 2022 PIT count. The City established a Homeless Plan Committee in 2019 to create a comprehensive strategic plan to address homelessness. This plan was published in January 2020.

The report indicated that the top four causes of homelessness in Fullerton are:

1. Lack of housing affordable to very low-income residents;

2. Lack of Permanent Supportive Housing for individuals living with mental illness;

3. Growing numbers of opioid addicted individuals reduced to living on the streets; and

4. Lack of jobs with sufficient pay to afford food and shelter in our community. 23 A survey conducted in May 2024 to gather stakeholder input provided local knowledge on the patterns of people experiencing homelessness in Fullerton. Five survey respondents indicated a concentration of people experiencing homelessness in the neighborhoods of Santa Fe District/SOCO, Independence Park, and S. Woods Ave/W Orangethorpe Ave, Craig Park, and Chapman Park. Individuals experiencing homelessness are also found along major arterials, including Lemon Street, Orangethorpe Avenue, under the State Route (SR) 57 freeway, Hillcrest Park, and in the shopping centers and at bus depots. In terms of trends among homeless residents, respondents noted that older women appear to be a growing population of residents experiencing homelessness.

The majority of the areas where there is a concentration of people experiencing homelessness are located in southern Fullerton, most of which has transit access within a quarter mile of a transit stop, as shown in Figure E-22. The Fullerton Transportation Center, located at E Santa Fe Avenue and S Lemon Street in the Rancho La Paz neighborhood, is served by Amtrak's Pacific Surfliner and Southwest Chief trains, as well as Metrolink's 91/Perris Valley Line and Orange County Line trains. It is also a major bus depot for the OC Bus system and is one of the major transportation hubs of Orange County. The Fullerton Transportation Center is located in short proximity (walking distance) from the major arterials where people experiencing homelessness are likely to congregate, is less than 30 minutes’ walk or bus ride from Independence Park and Hillcrest Park, and is two blocks from the Women’s Transitional Living Center.

The Fullerton Navigation and Recuperative Care Center at 3535 West Commonwealth Avenue is in the Artesia Boulevard/N Gilbert Street neighborhood and is 20 minutes via bus from the Fullerton Transportation Center and the neighborhoods where people experiencing homelessness are likely to congregate.

A number of organizations located in southern Fullerton provide services to unhoused persons and families. Several emergency shelters, food distribution centers, religious institutions, and organizations provide emergency services for people experiencing homelessness are in close proximity (within 20 minutes’ walk or bus ride) from areas where people experiencing homelessness are likely to congregate, including:
• Women’s Transitional Living Center: 210 N Pomona Avenue in the Santa Fe District/SOCO neighborhood
• Armory shelter: Brookhurst Street and W Valencia Drive in the W Oak Avenue/Lambert Park neighborhood

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• New Vista Shelter: 514 W Amerige Avenue in the Independence Park neighborhood • Hub of Hope Food Bank: 611 S Ford Avenue in the Woodcrest Park neighborhood • INCO Relief USA: 505 E Commonwealth Avenue in the Santa Fe District/SOCO neighborhood • Pathways of Hope: 1231 Chapman Avenue in the Byerrum Park neighborhood • OC United: 418 W Commonwealth Avenue in the Independence Park neighborhood • Lutheran Social Services: 247 E Amerige Avenue in the Santa Fe District/SoCo neighborhood • Inter Community Action Network: 4128 Commonwealth Avenue in the Artesia Boulevard/North Gilbert Street neighborhood
• Young Lives Redeemed: 1105 Commonwealth Avenue in the E Willshire Avenue/North Raymond Avenue neighborhood
• Food for Christ at the Rock Food Distribution Center: 101 E Orangethorpe Avenue in the Santa Fe District/SoCo neighborhood
• Calvary Community Church Food Distribution Center: 1465 W Orangethorpe Avenue in the Nicolas Park neighborhood
• New Wine Church Food Distribution Center: 1425 S Brookhurst Road I the Gilbert Park neighborhood • Fullerton Seventh Day Adventist Church Food Distribution Center: 2355 W Valencia Drive in the Valencia Park neighborhood
• Saint Philip Benizi Church - Society of Saint Vincent de Paul Food Distribution Center: 235 S Pine Drive in the W Valencia Drive/Courtney Avenue neighborhood
• Dolphin Market Pacific Drive Elementary Food Distribution Center: 1501 W Valencia Drive in the W Commonwealth Avenue/N Basque Avenue neighborhood
• ICNA Relief USA Food Distribution Center 505 E Commonwealth Avenue in the 212 E Wilshire Avenue in the Santa Fe District/SoCo neighborhood
• Heart of Downtown Food Co-op: 212 E Wilshire Avenue in the Santa Fe District/SoCo neighborhood • First Lutheran Church Food Distribution Center: 215 N Lemon Street in the Santa Fe District/SoCo neighborhood
• Fullerton Community Center Food Distribution Center: 340 W Commonwealth Avenue in the Independence Park neighborhood
• Saint Mary’s Church Food Distribution Center: 400 W Commonwealth Avenue in the Independence Park neighborhood
Through ongoing outreach and canvassing efforts, the City continues to identify individuals experiencing homelessness in key areas, including transportation hubs (such as train stations), parks, and washes. The City played a pivotal role in developing a comprehensive, synchronized system of care through the establishment of the Hope Center. This multi-city, multi-disciplinary partnership aims to streamline and standardize homeless outreach and engagement by centralizing resources, coordinating responses, and integrating data. A key component of this system is the management of an Outreach Grid, which tracks and responds to reports of homelessness. Calls are dispatched to outreach workers and city-funded Homeless Liaison Officers (HLOs), including Police Officers, who respond in real-time and check the availability of shelter beds.

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The HLO Unit partners with local organizations including the Orange County Mental Health Agency, the Fullerton Navigation and Recuperative Care Center run by Illumination Foundation, Placentia Navigation Center run by PATH, Buena Park Navigation Center run by Mercy House, and the Anaheim Bridges Shelter run by Mercy House to conduct weekly outreach to persons experiencing homelessness. The HLO Unit has a clinician from the Orange County Mental Health Agency in the patrol vehicle of an officer two to three days of the week to assist persons experiencing homelessness and those experiencing mental health issues.

In addition, all police officers in Fullerton are trained on how to assist individuals experiencing homelessness.
24 The City has taken a number of actions to address homelessness through services in the community. These efforts include hiring a dedicated Homeless Outreach Case Manager, who is responsible for performing case management, outreach, intervention services and assistance in obtaining resources from community partners to individuals deemed homeless residents of the City of Fullerton. The Case Manager utilizes Homeless Management Information System (HMIS) to collect client-level data and data on the provision of housing and services to individuals and families at risk of experiencing homelessness. The City also recently filled the Housing Manager position to implement programs to address the homeless population and those at risk of becoming homeless.

The Homeless Case Manager program employs an outreach coordinator to ensure the City’s homeless residents are receiving individualized care. The now full-time position was filled in 2024 and is stationed at the Hope Center. The position works with the County’s Continuum of Care, which was not occurring with City Net. The City provided CDBG-CV funds for the construction costs of Project HOPE (Homeless Outreach Proactive Engagement). The Hope Center opened in 2022 and provides a hub for Homeless Case Managers, Mental Health Specialists, paramedics and social workers working together to provide whole person care.

Additionally, in 2024-25, HOME-ARP funds are used to assist the homeless and at risk of homelessness populations.

The City continues to support various non-profit organizations that provide homeless services including Mercy House (homeless shelter), Pathways of Hope (transitional housing, life skills training), Lutheran Social Services of Southern California (victims of domestic violence, at risk of homelessness) and the Women's Transitional Living Center (victims of domestic violence, at risk of homeless). Orange County Health Care Agency provides linkage to mental health services and refers homeless into emergency shelters.

Other partner agencies are assisting Fullerton in reducing homelessness. St. Jude Medical Center assists homeless individuals who visit the Emergency Room through their Community Care Navigators who provide case management and linkage to services when needed to help prevent another visit. Chrysalis provides job training and opportunities to individuals who walk-in or are connected to the emergency shelters. OC United’s “Jobs for Life” program is offered at emergency shelters as a life skills and job readiness class.

The City partners with the 13 cities of the North Service Planning Area (SPA) on a Memorandum of Understanding that have resulted in the development of two homeless navigation centers providing a total of 250 beds serving the North Orange County homeless population. The City financially supports emergency shelter/navigation beds for Fullerton homeless individuals at the Buena Park 150-bed

24 Fullerton Police Department. 2024. Homeless Outreach. https://www.cityoffullerton.com/government/departments/police/police -services/homeless- outreach

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navigation center and Placentia 100-bed shelter that provides comprehensive housing services. Since 2020, 164 persons have been referred to the Buena Park Navigation Center from Fullerton.25 The City has a partnership with Illumination Foundation that established a 150-bed facility in Fullerton that not only provides navigation center beds with wrap-around services but also provides recuperative care beds, which provide care for homeless patients after a hospital stay or emergency room visit. Bridges at Kramer Place operated by Mercy House is a 200-bed year-round shelter for single adults in North Orange County. Bridges is a 24-hour emergency homeless shelter facility in the City of Anaheim that is ADA Accessible and serves homeless single men and single women in the North Orange County area. The shelter’s primary focus is assisting program participants with creating a housing plan, making connections to housing resources and ending their homelessness as soon as possible. The City of Fullerton assisted in funding the shelter and is allowed access for Fullerton homeless clients.26 The City partners with the nonprofit organization City Net to provide street outreach, in-reach, and case management to those experiencing homelessness in Fullerton. The City also partners with the OC Health Care Agency, which serves individuals who are homeless or on the verge of becoming homeless. Services are offered to individuals of all ages with behavioral health conditions ranging. Staff frequent known gathering places for the homeless including food banks, shelters, and public areas such as parks/libraries in order to identify individuals and screen for program eligibility. The team responds to community referrals and collaborates with various community partners in support of an individual’s recovery.

The City of Fullerton Five-Year Consolidated Plan reflects a unified vision for providing decent housing, addressing homelessness issues, and taking community development actions as determined by a collaborative effort of the community. The plan outlines three basic goals set by the Department of Housing and Urban Development: to provide decent housing; to provide a suitable living environment; and to expand economic opportunities for low/moderate income individuals.

The City plans to continue partnerships with non-profit organizations and regional agencies to provide outreach and services for persons experiencing homelessness during the planning period and as described in Policy Action 3.15 in Chapter 4, Housing Plan. The outreach and services will continue to be targeted to the geographic areas in the city where people experiencing homelessness tend to congregate and preventative services targeted to the populations most at risk of homelessness.

E.7.5 Displacement
Displacement, as defined by HCD, is used to describe any involuntary household move caused by landlord action or market changes. Shifts in neighborhood composition are often framed and perpetuated by established patterns of racial inequity and segregation. Movement of people, public policies, and investments, such as capital improvements and planned transit stops, and flows of private capital can lead to displacement. Displacement is fueled by a combination of rising housing costs, rising income inequality, stagnant wages, and insufficient market-rate housing production. Decades of disinvestment in low-income communities, coupled with investor speculation, can result in a rent gap or a disparity between current rental income of the land, and potentially achievable rental income if the property is converted to its most profitable use. These processes can disproportionally impact people of color, as well as lower income

25 Mercy House. June 2024 report.
https://cms7files1.revize.com/buenaparkca/departments/Community%20Services/Homeless%20Services/Navigation%20Center/Buena%20Pa rk%20Monthly% 20Report%20-%20June%202024.pdf
26 City of Fullerton. 2024. Draft HUD Action Plan. https://www.cityoffullerton.com/home/showpublisheddocument/8740/6385604822730 30000

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households, persons with disabilities, large households, and persons at-risk or experiencing homelessness.27
Regional Trends
As shown in Figure E-40, the majority of Orange County has a lower risk of displacement, but there are several cities in the northwestern portion of Orange County (primarily the cities of Anaheim, Placentia, Buena Park, Garden Grove, Westminster, Santa Ana, Stanton, and Orange) that are at risk of displacement.

Local Trends
The majority of Fullerton is at lower risk of displacement, but there are several neighborhoods in southern Fullerton at risk of displacement, as shown in Figure E-41. These include the neighborhoods of Artesia Blvd/N Gilbert, Valencia Park, Woodcrest Park, Rancho La Paz, and California State University Fullerton.

Vulnerable areas in Fullerton had higher poverty rates, higher percentage of LMI residents, overcrowded households and were more likely to have a higher percentage of Hispanic/Latino residents. Fullerton has the highest number of rent-based eviction filings in all of Orange County.28 E.8 Local Area Knowledge
E.8.1 Historic Patterns of Segregation
Regional
Patterns of racial segregation are the byproduct of local and federal policies, private housing discrimination, and community prejudice. To understand present challenges to fair housing, it is necessary to review the history of actions that have led to regional patterns of segregation.

The first people to live in Orange County were the Shoshonean-speaking people, the ancestors of the tribes we know today as the Juaneño and the Gabrielino. Spanish missionaries were established in the area in 1770s. In 1810, the first land grant in what is now Orange County was established east and south of the Santa Ana River. The area was dominated by cattle ranches. The Gold Rush of 1849 brought tens of thousands of new settlers to California. By 1850, the future Orange County comprised the southern tip of Los Angeles County. By late 1800s, residents had mobilized enough political support to pass the secession measure despite opposition by Los Angeles County in the State Legislature. Orange County was given jurisdictional autonomy on March 11, 1889.

27 HCD. 2021. https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf 28 United Way. 2023. Orange County Evictions Report. https://www.unitedwayoc.org/wp-content/uploads/2023/04/OC-Evictions-Spring23_final.pdf, accessed August, 2023

Appendix H-E: Housing Element H-E-81
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Figure E-40 Estimated Displacement Risk (Orange County)

Source: AFFH Viewer, 2022

H-E-82 Appendix H-E: Housing Element
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Figure E-41 Estimated Displacement Risk (Fullerton)

Source: AFFH Viewer, 2022

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Much of Orange County’s growth in the first half of the 20th Century was fueled by new forms of transportation. Between 1904 and 1910, the Pacific Electric Railway built three branches to serve Orange County with its “big red cars.” The coast line spurred development from Seal Beach to Corona del Mar. The Santa Ana line prompted the founding of Cypress and Stanton. And the La Habra line ran all the way down to the new community of Yorba Linda. Freeway construction began in the 1950s with the opening of the Santa Ana (I-5) Freeway and continued almost unabated into the 1970s. During World War II, a number of important military bases were established in Orange County. At the end of the war, many veterans decided to settle in Southern California, and the region began to grow at an unprecedented rate.

By the mid-1950s, Orange County’s farms were being replaced by single-family tract housing. South Orange County began to grow in the 1960s, with master planned communities such as Irvine, Mission Viejo, and Laguna Niguel. Aliso Viejo, Rancho Santa Margarita, Ladera Ranch, and others followed in the 1980s and 1990s.

Until the 1940s, Orange County's economy was based largely on agriculture. With the rapid southward expansion of Los Angeles' population and industrial development, Orange County's economy began to change rapidly, particularly in the northern parts of the county. In 1940, twice as many workers were employed in agriculture as in manufacturing. Orange County's demographic explosion began with the onset of the military build-up for the Second World War and continued with the post-war expansion of California.

Between 1940 and 1960, Orange County's population grew from 130,000 to more than 700,000, transforming the county into a major suburban outpost for Los Angeles.

By 1960, manufacturing employed three times as many workers as the agricultural industry. Aerospace and other high-tech industries began moving into the area, bringing with them growing affluence. Between 1950 and 1960, Orange County's median income grew from the 20th highest of California's 58 counties to the third highest, behind only the Bay Area suburbs of Contra Costa and Marin Counties. By the mid-1990s, Orange County's high-tech and information industries were among the most dynamic in the United States.

Today, Orange County comprises 34 cities and has a population of approximately three million residents.

The unincorporated territory, consisting of approximately 321 square miles, is geographically diverse with unincorporated areas spread throughout the County. The largest portion of unincorporated territory is found in southern Orange County and includes a number of planned communities such as Coto de Caza, Las Flores and Ladera Ranch as well as large portions of undeveloped territory south of Ortega Highway.

In the late 1800s, Santa Ana was one of the only cities in Orange County with a Chinatown neighborhood.

These Chinese immigrants were recruited to meet the demands of labor in farming, railroads, and construction and worked for low wages to send to their families back in China. The area was burned down by the City in 1906 based on claims of mitigating the spread of disease. Residents were relocated to land along the Santa Ana River, but by 1912, most Chinese residents had left Santa Ana to reside in nearby Anaheim.

In the 1920s, Anaheim was home to members of the racist “white power” entity known as the Ku Klux Klan (KKK). In 1924, Anaheim elected four KKK affiliated candidates to city council, and KKK membership in Anaheim expanded. They spread prejudices until 1925, when they were recalled after residents were alerted of their KKK affiliations. In 1930s, most citrus laborers in Orange County were immigrants from Mexico, who formed the Federation of Agricultural Workers Unions of America (FAWUA). Strikes for better working conditions were met with state-sponsored violence.

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The 1930s and 40s was a time of public segregation across the nation. Orange County participated in upholding racial hierarchies based on racist notions of white superiority. Various Orange County swimming pools had separate days for ethnic groups. Xenophobia was rampant. In 1942, President Roosevelt issued Executive Order 9066 which allowed local military commanders to designate military areas as “exclusion zones” from which any or all person may be excluded. Accordingly, 127,000 US residents of Japanese ancestry, most of them US Citizens were removed from the Pacific Coast and were sent to internment camps.29 At the end of their internment, many Japanese Americans struggled to find housing due to poverty, restrictive covenants, and racism.30
Starting in the 1930s, parts of Orange County were subject to redlining, which is the practice of federally sanctioned discriminatory mortgage lending that either steered or opted against providing loans to borrowers based on the racial or socioeconomic status of the neighborhood in which a property is located.

Redlining, a government-sponsored system of denying mortgage loans and services to finance the purchase of homes in specific areas, served as a tool to limit homeownership opportunities, as federally insured and long-term mortgages were routinely denied to often non-white persons seen as “undesirable.” Redlining directed both public and private capital to white households and away from Black/African American, non- white, immigrant, and Jewish households. As homeownership is one of the most significant means of intergenerational wealth building in the United States, these redlining practices had long-term effects in creating wealth inequalities. Additionally, many of the housing deeds in Orange County included prohibitions against Black, Hispanic/Latino, Asian, and Native American people, permitting them only if they were gardeners, servants, or nannies.
31 In 1971, the OC Human Relations Commission was created by advocates for civil rights who were upset with police brutality against non-white residents, housing discrimination, lack of affordable health care, and discrimination in education. The Commission was intended to eliminate prejudice, intolerance, and discrimination based on race, religion, ethnicity, national origin, gender, sexual orientation, marital status, socio-economic status, and age.32 The OC Human Relations Commission, Fair Housing Council, League of Women Voters, Legal Aid Society, and other housing advocates formed the Housing Coalition to advocate for the development of Affordable Housing. In addition, the Hate Crime Network was established in 1991 to respond to hate crime and build relationships between police and diverse communities within Orange County.

Local
In early 1887, the California Central Railroad, a subsidiary of Santa Fe, sent George H. Fullerton, president of the Pacific Land and Improvement Co., to purchase land for railroad right-of-way. Brothers George and Edward Amerige learned that a likely site for a town was located north of Anaheim. With George Fullerton's assurance that the area north of Anaheim would be included, the Ameriges purchased 430 acres and Fullerton was established.

29 Japanese-American Internment During World War II. U.S. National Archives. https://www.archives.gov/education/lessons/japanese-relocation 30 For Japanese Americans, Housing Injustices Outlived Internment, New York Times, 2020. https://www.nytimes.com/2020/08/20/magazine/japanese- internment-end-wwii-trailer-parks.html
31 Fullerton Observer. 2020. A Brief History of Housing Discrimination in Fullerton and North Orange County. https://fullertonobserver.com/2020/07/27/a- brief-history-of-housing-discrimination-in-fullerton-and-north-orange-county/ 32 Fullerton Observer. 2020. A Brief History of Housing Discrimination in Fullerton and North Orange County. https://fullertonobserver.com/2020/07/27/a- brief-history-of-housing-discrimination-in-fullerton-and-north-orange-county/

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Historically, the city was a center of agriculture, notably groves of Valencia oranges and other citrus crops.

Drilling for petroleum began in 1880 with the discovery of the Brea-Olinda Oil Field, which started a boom that peaked in the 1920s.

Anecdotal evidence suggests Fullerton was a “sundown town,” which is a city, county or region that was intentionally “all white” by forcing out anyone considered non-white by force, law, or custom. In 1919, hundreds of residents protested at a city council meeting after they learned that the Santa Fe Railroad planned to build housing for its Mexican workers near the company’s tracks.33 There were widespread racist civic and housing policies throughout Orange County, including Fullerton, that prevented minorities from accessing housing. According to anecdotes, the only neighborhood where minorities were allowed to rent or own homes was on the south side of the train tracks in the Truslow neighborhood.34 Today, the Truslow Avenue neighborhood has some of the lowest median incomes in and the highest percentage of non-white residents in the city.

Racial covenants were prevalent within Fullerton. Fullerton is the home of the Bernal House, which is the subject of one of the leading anti-discrimination cases in 1943 known as “Doss v. Bernal.” The Sunnyside Addition was established in 1923 and by the time the Bernals moved in, it had become a predominantly lower middle-class community occupied exclusively by whites. The Bernals, a Mexican family, purchased a home on Ash Avenue in the Sunnyside neighborhood of Fullerton with a deed restriction attached to the house, that supported residential segregation in housing covenants. Neighbors filed a lawsuit against the Bernals, but they refused to leave. The case was successfully argued under the equal protection clause of the 14
th Amendment and the Bernals were able to keep their home.35 Terrorism of Black/African American residents was widespread in the area. Just outside Fullerton in Placentia, the first African American family to move into the neighborhood in 1956 was firebombed and their home was vandalized.36 Redlining was a practice in Fullerton. By the 1970s, national fair housing laws were created; however, Black/African American residents still faced discrimination in buying and renting.37 While redlining does not occur today, land uses and differences in predominant populations between neighborhoods reflect old policies that promoted racial segregation.

California State University Fullerton was established in 1957 as Orange County State College. The majority of the campus was developed throughout the 1960’s. The campus has grown rapidly since the early 1990s and the first decade of the 2000s.

Downtown Fullerton serves as the commercial center of the city and is clustered with over 70 historic buildings dating as far back as the early 1900s.

33 Fullerton Observer. 2020. Recognizing the History Behind the Bernal House. https://fullertonobserver.com/2020/06/11/recognizing-the-history-behind-the- bernal-house/
34 Fullerton Observer. 2020. A Brief History of Housing Discrimination in Fullerton and North Orange County. https://fullertonobserver.com/2020/07/27/a- brief-history-of-housing-discrimination-in-fullerton-and-north-orange-county/ 35 Fullerton Observer. 2020. Recognizing the History Behind the Bernal House. https://fullertonobserver.com/2020/06/11/recognizing-the-history-behind-the- bernal-house/
36 OC Weekly. 2019. Remembering When the Home of Placentia’s First African American Family Was Firebombed. https://www.ocweekly.com/remembering - when-someone-firebombed-placentias-first-african-american-family/ 37 Fullerton Observer. 2020. A Brief History of Housing Discrimination in Fullerton and North Orange County. https://fullertonobserver.com/2020/07/27/a- brief-history-of-housing-discrimination-in-fullerton-and-north-orange-county/

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E.9 Stakeholder and Community Input
E.9.1 Homes for All Initiative
The City of Fullerton participated in the Homes for All initiative, which is a coalition of family members and non-profit organizations who are working together to get more affordable homes built in their respective cities (Garden Grove, Lake Forest, and Fullerton). The Homes for All collaborative coalition is comprised of The Kennedy Commission, Welcoming Neighbors Home, Tapestry, a Unitarian Universalist Congregation, Hope Community Services, People for Housing OC, and Hope Through Housing Foundation/Amplify Communities (National CORE). As part of the Homes For All Initiative, People For Housing OC utilized a questionnaire provided by the Kennedy Commission to collect responses from a select sample of residents in impacted neighborhoods to capture conditions. The questionnaire contained 30 questions designed to capture measures of rent burden, overcrowding, demographics, public health, and civic engagement.

Public for Housing OC received 90 responses to the questionnaire, with a high percentage of Hispanic mothers and families due to the ties of the organizations they are a part of. The survey made several conclusions:
• The majority of the people surveyed are renters who have lived in Fullerton for six or more years. Rents are regularly increasing and are outpacing monthly incomes, increasing the risk of displacement for long-term residents.
• The average family size of respondents is 5.5 people per household. Apartments are not big enough to meet the needs of large families. Larger-sized apartments are needed in affordable developments. • Residents are concerned about habitability of housing and deterioration of housing stock. The City’s code enforcement efforts and results need to be improved.

E.9.2 Study Sessions
The City held two Planning Commission study sessions on January 19, 2022 and February 15, 2023, and one City Council study session on September 20, 2023 to review and discuss the Housing Element. Overall, community members showed support for affordable housing development in the city and requested additional information on the Housing Incentive Overlay Zone (HIOZ) and continued public participation in the Housing Element update process. The HIOZ received both support and disapproval from community members. The following comments were provided during the Planning Commission and City Council study sessions:
• General support and disapproval for establishing the HIOZ • Need for housing for homeless residents, low-income residents, and affordable housing for seniors • Recommendation the City increase affordability percentage requirements for the HIOZ and Religious Surplus Land
• Support for an inclusionary housing program
• Concern over the effects of increased density in the city E.9.3 Stakeholder Survey
Following HCD comments received on May 9, 2024 , the City emailed a survey to interested parties to obtain local knowledge on fair housing issues and patterns. More specifically, the City asked for input on the differences between northeast Fullerton, characterized as “racially concentrated areas of affluence”

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and other areas of the city. Questions explored whether City policies have historically provided diverse housing opportunities in these affluent neighborhoods and what measures could enhance housing availability, with options including ADUs, multifamily housing on commercial sites, and multiple-unit housing. Additionally, the survey sought information on neighborhoods where people experiencing homelessness tend to congregate, including their access to transportation and services. It also asked about recent trends among the homeless population. Finally, the survey requested identification of neighborhoods with housing in poor physical condition needing rehabilitation or repairs. The City received responses from five survey participants. The survey revealed several patterns:
• RCAAs are characterized by large parcels, single-family homes, greater setbacks, hilly terrain, abundant parkland, and high-performing schools. RCAAs have minimal multifamily zoning and limiting housing opportunities for low or moderate-income households. The lack of diverse housing in RCAAs perpetuates racial and economic segregation.
• Residents may support constructing ADUs for family members but generally oppose additional density due to infrastructure constraints. To increase housing opportunities in RCAAs, respondents suggested encouraging ADU construction, allowing multifamily and mixed-use housing, and developing affordable housing on religious institutional sites.
• Respondents also supported an ordinance to streamline affordable housing development on land owned by religious institutions and remove the prevailing wage requirement. • Homelessness trends noted concentrations of homeless individuals in Santa Fe District/SOCO, Independence Park, S. Woods Ave/W Orangethorpe Ave, Craig Park, and Chapman Park, as well as along major arterials, under the SR 57 freeway, Hillcrest Park, shopping centers, and bus depots. A growing population of older women among the homeless was noted. • Areas in need of housing rehabilitation or repair include Independence Park, Artesia Blvd/N, Gilbert Park, W Commonwealth Ave/N Basque Ave, Valencia Park, neighborhoods south of Commonwealth Ave, and areas near downtown and the train station.

E.10 Other Relevant Factors
E.10.1 Fair Housing Capacity
The most recent Orange County AI analyzed fair housing enforcement capacity in the county. The City of Fullerton does not have its own Impediments to Fair Housing report. The identified fair housing issues include:
• Limited resources for regional fair housing organizations • Lack of local public fair housing enforcement
• Limited loan opportunities for home rehabilitation
• Racial discrepancies in loan origination rates
• Lack of affordable housing and segregation of existing affordable housing assets Although Orange County is served by two high-quality private, non-profit fair housing organizations, they are underfunded and understaffed in comparison to the total need for their services. Victims of discrimination would be more able to exercise their rights, thus deterring future discrimination, if the capacity of existing organizations grew to meet the scale of the problem. Additionally, the size of the

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federal Fair Housing Initiatives Program, the primary funding program for fair housing organizations, has failed to keep up with inflation, making Congress’s appropriations worth less over time. In order to meet the needs of residents of a large and diverse county, local fair housing agencies and organizations require greater levels of resourcing.

There are no local public entities that conduct fair housing outreach and enforcement, with the California Department of Fair Employment and Housing and HUD constituting the only public enforcement bodies that operate in Orange County. Advocates across Orange County and the state of California have reported issues with the timeline of the California Department of Fair Employment and Housing’s investigations and the standards that it applies in making probable cause determinations. A local public enforcement agency, if created, would have the potential to be more responsive to victims of discrimination in Orange County than either the state or HUD.

Given the scarcity of affordable rental housing and high cost of living within Orange County, loan opportunities for home improvement, purchase, and refinancing are important tools for moderate and low-income households. The Home Mortgage Disclosure Act (HMDA) data shows there is a racial discrepancy of loan approval rates, with white residents most likely to have their applications result in originated loans.

With respect to the location of affordable housing, at a high level, there is relatively little such housing in coastal areas, hillside communities, or in the southern portion of the county, all areas that are disproportionately White and have relatively low Hispanic population concentrations. Within some cities that have patterns of segregation, affordable housing is concentrated in particular areas that tend to be more heavily Hispanic. In Fullerton, affordable housing is more concentrated in the disproportionately Hispanic southern portion of the city. With respect to the role of the type of affordable housing in causing fair housing issues, the total lack of public housing in Orange County, which tends to be more accessible to members of protected classes than do Low Income Housing Tax Credit developments, may play a role in perpetuating segregation.

E.10.2 Land Use and Zoning
Most of the city’s housing stock was built in the post-war era between the 1940s and 1970s. The city’s current form and character was defined during this era, when over half of the city’s current housing stock was constructed. Most of the housing built before and during the post-war era was built in southern and central Fullerton in the neighborhoods near Orangethorpe Avenue, Commonwealth Avenue, and E.

Chapman Avenue. The neighborhoods with the highest percentage of housing stock built prior to 1960 (60 to 80 percent of the housing stock) are Independence Park, S Woods Avenue/W Orangethorpe Avenue, W Valencia Drive/Courtney Avenue, W Oak Ave/Lambert Drive, Byerrum Park, and E Wilshire Avenue/N Raymond Avenue. These neighborhoods are more likely to have housing stock in need of repair.

Today, single-family detached housing comprises 54 percent of the city’s housing stock, higher than Orange County (51 percent) and other areas of Southern California such as Los Angeles County (49 percent). Today, most of the city’s residentially zoned areas are designated for single-family homes.

E.10.3 Demographic Trends
Fullerton’s demographics have reflected regional migratory trends. Southern California has one of the highest foreign-born populations in the nation, with half of residents born in Latin American countries, and an increasing share from Asian countries. As a result, the city has become much more diverse over the last

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several decades. Southern California has also been impacted by out-bound domestic migration trends. In each year since 2014, an average of 91,000 people have left the region than the number of those who have arrived. High housing costs are often cited as a reason for leaving.38 Additionally, the median age in the region has steadily increased in the past two decades, changing the ratio of working age population to seniors, and increasing the need for housing for seniors and assistance to help seniors stay in their homes. While the region has experienced tremendous job growth, moderate- income households within the region have been declining since 2000.39 E.10.4 Student Housing
The California State University, Fullerton (CSUF) is located in the eastern portion of the city and enrolls approximately 41,000 students. The University provides approximately 2,000 students with on-campus housing. As a result, there is a significant need for off-campus housing within the city and surrounding communities. The large student population creates a unique need for student-friendly affordable housing.

The influx of students adds significant pressure to the existing housing stock within the city. A survey of student housing needs found that the average rental cost for a studio or one-bedroom off-campus in Fullerton was $19,206 per year (May 2022 costs), higher than the average cost for the same type of housing for all CSU campuses ($14,857 per year). Additionally, only four percent of all CSUF students resided in on-campus housing.
40 E.10.5 Access To Transportation for Persons with Disabilities Fullerton’s main public transportation systems are operated by OCTA and Metrolink light rail service. OCTA operates nine bus lines that extend throughout Fullerton and Orange County. To assist persons with disabilities, OCTA busses are equipped with accessibility improvements. Paratransit service is available through OC Flex and OC ACCESS. It is available for people unable to use fixed-route bus service because of functional limitations caused by a disability. While most areas of Fullerton are within a quarter-mile of a OCTA bus route, or the Metrolink line (see Figure E-22), there are segments of the city that are not in close proximity to existing transit service, including the West Coyote Hills, and most of Emery Park, Amerige Heights, Acacia Park, and E Las Palmas Dr/N Sunnywood Dr neighborhoods. Residents with disabilities residing in these areas may have limited access to transportation as the Acacia Park and E Las Palmas Dr/N Sunnywood Dr are located in census tracts that contain a slightly higher rate of persons with disabilities, compared to other areas of Fullerton.

E.10.6 Access to Home Ownership
As previously mentioned, governmental constraints enacted throughout the 20th century impacted homeownership opportunities for non-white populations.

To understand current racial/ethnic disparities among homeownership opportunities, this analysis reviews mortgage application filing and acceptance by race and ethnicity using the latest available data from the Federal Financial Institutions Examination Council (FFIEC). As shown in Table E-12, there were 12,138 mortgage applications filed in Fullerton in 2021. Race and ethnicity data is unknown for more than one- quarter of loan applicants and the analysis on race and ethnicity for loan applications may not be fully

38 SCAG. Connect SoCal. 2020. https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal-plan_0.pdf?1606001176 39 Ibid.
40 Cal State University Business and Finance. 2022. 2022 CSU Systemwide Housing Plan. https://www.calstate.edu/impact-of-the-csu/government/Advocacy- and-State-Relations/legislativereports1/Legislative-Report-CSU-Systemwide-Housing-Plan.pdf

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complete. Of the known racial/ethnic categorization of mortgage applications, most were filed by Asian American/API residents and by white, non-Hispanic residents. In comparison, Hispanic/Latino applicants comprised 22 percent, Black/African-American applicants comprised one percent, and American Indian or Alaskan Native applicants comprised less than 1 percent of total mortgage loan applications. Non-Hispanic white residents were the only racial population that was representative for mortgage applications relative to proportion of population (36 percent of applications, 37 percent of population). Asian American residents underrepresented for mortgage applications (16 percent of applications, 27 percent of population), as were Black/African American residents (1 percent of applications, 2 percent of population), Hispanic/Latino residents (22 percent of applications, 37 percent of population), and American Indian/Alaska Native (less than 1 percent of applications, 1 percent of population).

Table E-12 Mortgage Applications and Acceptance by Race, 2021 Racial/
Ethnic Group
Application
Approved
but Not
Accepted
Application
Denied
Application
Withdrawn
by
Applicant
File Closed for
Incompleteness
Loan
Originated
Other
Action
Total
Applications
American Indian or
Alaska Native, Non-
Hispanic
0 0 3 0 5 0 8
(<1%)
Asian American/API,
Non-Hispanic
32 166 286 62 1,331 58 1,935
(16%)
Black/African-American,
Non-Hispanic
2 11 14 1 54 2 84
(1%)
Non-Hispanic White, 50 206 301 98 1,596 2,111 4,362
(36%)
Hispanic/Latino 37 154 175 83 783 1,386 2,618
(22%)
Unknown 60 217 292 149 1,338 1,075 3,131
(26%)
Total 181 754 1,071 393 5,107 4,632 12,138
(100%)
Notes: “Loan originated” means that the application was accepted a loan was made by a financial institution to the applicant. “File incomplete or withdrawn” means a loan was not originated because the application was withdrawn before a credit decision was made or the file was closed for incompleteness. “Application denied” means a loan was not originated because the financial institution did not approve the mortgage application. “Application approved but not accepted” means the financial institution approved the loan application but the applicant did not complete the transaction and a loan was not originated. Other categories of application actions were not included in this analysis, such as purchased loan, preapproval request denied, and preapproval request approved but not accepted. For the purposes of this graph, the “Hispanic or Latino” racial/ethnic group represents those who identify as having Hispanic/Latino ethnicity and may also be members of any racial group. All other racial categories on this graph represent those who identify with that racial category and do not identify with Hispanic/Latino ethnicity.

Source: Federal Financial Institutions Examination Council's (FFIEC) Home Mortgage Disclosure Act loan/application register (LAR) files As shown in Figure E-42, approximately 71 percent of Asian American/API and white, non-Hispanic mortgage applicants had their loans originated, compared to 64 percent of Hispanic/Latino and 66 percent of Black/African American applicants. American Indian/Alaskan Native applicants had the lowest rates of denied applications, but also the lowest number of total applications. Black/African American and Hispanic/Latino applicants had the highest denial rate at 13 percent.

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Figure E-42 Mortgage Rates and Acceptance by Race (Fullerton)

Source: Federal Financial Institutions Examination Council's (FFIEC) Home Mortgage Disclosure Act loan/application register (LAR) files E.11 Subsidized Housing
The Orange County Housing Authority (OCHA) operates several housing programs. The Housing Choice Voucher (HCV) program provides financial assistance to rent-burdened residents. The Family Self- Sufficiency program helps HCV program participants access employment. The Non-Elderly Disabled program provides HCVs for non-elderly disabled families with demonstrated need for supportive services.

Additionally, the Veterans Affairs Supportive Housing (VASH) program, run jointly through the Department of Housing and the Department of Veteran Affairs, provides HCVs and wraparound services to homeless veterans.

Figure E-43 shows the percent of housing units that accept HCVs. Most HCV households are located in southern Fullerton, which is considered low resource and has a higher percentage of multifamily homes. 9% 13% 9% 13% 11%
38% 15% 17% 13% 14% 14%
7% 7%
63% 71% 66% 71% 64% 65%
0%
20%
40%
60%
80%
100%
120%
Application Approved but Not Accepted Application Denied Application Withdrawn by Applicant File Closed for Incompleteness Loan Originated

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Figure E-43 Housing Choice Vouchers (Fullerton)

Source: AFFH Viewer, 2021

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E.12 Housing Site Inventory Analysis
This portion of the AFFH analyzes the relation between the housing opportunity sites and AFFH-related issues. Government Code Section 65583(c)(10) requires the housing opportunity sites to be analyzed with respect to AFFH to ensure that sites designated for low-income households are dispersed equitably throughout the county rather than concentrated in areas of high segregation and poverty or low-resource areas that have historically been underserved, and conversely, that sites designated for above moderate- income households are not concentrated in areas of high resources. By comparing the Site Inventory to the fair housing indicators in this assessment, this section analyzes whether the sites included in the Housing Element Site Inventory improve or exacerbate fair housing conditions, patterns of segregation, and access to opportunity.

The housing opportunity sites are designated by income category—whether the sites could accommodate housing appropriate for low-, moderate-, or above moderate-income households. The “appropriateness” of sites for various affordability levels is dictated by state housing element law and HCD guidance and includes allowable density, size of site, realistic capacity, existing use(s), and other factors. More information about the sites and income designations is available in Chapter 4, Housing Resources.

A portion of the City’s RHNA will be satisfied by planned and approved projects that will develop 2,558 units. This analysis only considers the 11,346 units of capacity identified on housing opportunity sites on vacant land and potential rezone sites.

E.12.1 Housing Sites by TCAC Opportunity Area
For purposes of evaluating fair housing, resource levels designated by TCAC/HCD denote access to economic and educational opportunities such as low-cost transportation, jobs, and high-quality schools and the quality of environmental factors in the area such as proximity to hazards and air quality. TCAC has a composite opportunity score for each census tract. The majority of northern Fullerton is designated “Highest Resource” and “High Resource,” while southern Fullerton is mostly designated “Moderate Resource and “Low Resource.”
Figure E-44, Figure E-45, Figure E-46, Figure E-47, Figure E-48, Figure E-49, Figure E-50, and Figure E-51

show the location of the Housing Element opportunity sites by TCAC-designated resource area. Most of the housing opportunity units are in Highest, High, or Moderate-Resource areas: 3,872 units (34 percent) are located in Highest-Resource and High-Resource areas and 5,527 units (49 percent) are in Moderate- Resource areas. 1,947 units (17 percent) are located in Low-Resource areas.

The housing opportunity sites will add the following units to Low-Resource areas:
• 909 lower-income units (18 percent of total lower-income units) • 403 moderate-income units (17 percent of total moderate-income units) • 635 above moderate-income units (16 percent of total above moderate-income units) The housing opportunity sites will add the following units to Moderate-Resource areas in the city:
• 2,452 lower-income units (47 percent of total lower-income units) • 1,177 moderate-income units (50 percent of total moderate-income units) • 1,898 above moderate-income unit (49 percent of total above moderate-income units)

H-E-94 Appendix H-E: Housing Element
City of Fullerton
Housing Element
The planned and approved projects and the housing opportunity sites will add the following units to high- and highest-resource areas:
• 1,759 lower-income units (34 percent of total lower-income units) • 769 moderate-income units (33 percent of total moderate-income units) • 1,344 above moderate-income units (35 percent of total above moderate-income units) The housing opportunity sites will add mo st of the lower-income units in moderate-, high-, and highest- resource areas (81 percent). Similarly, a higher percentage of low-, moderate-, and above moderate- income units will be included in High- and Highest-Resource areas (34, 33, and 35 percent, respectively), than Low-Resource areas (18, 17, and 16 percent, respectively). Therefore, overall housing development during the planning period will not increase patterns of segregation and will increase integration by household income in terms of access to opportunity.

E.13 Sites by Income Population
The percentage of Low to Moderate Income (LMI) households vary across the city. Census tracts with more than 50 percent LMI households are located primarily in the southwestern area of the city. The communities with the highest percentage of LMI residents are Independence Park and Woodcrest Park in the south-central portion of the city (79 percent LMI).

As shown in Figure E-52, Figure E-53, Figure E-54, Figure E-55, Figure E-56, Figure E-57, Figure E-58, and Figure E-59
, a majority of the housing opportunity sites are located in communities with greater than 50 percent of LMI populations (6,877 or 61 percent of all units). The Site Inventory assumes that the areas of the city with greater than 50 percent LMI households could accommodate 3,124 units appropriate for low- income households (61 percent of the total lower-income units), 1,488 units for moderate-income households (63 percent of the total moderate-income units) and 2,305 units for above moderate-income households (59 percent of the total above moderate-income units). The Site Inventory assumes the areas of the city with less than 50 percent LMI households could accommodate 1,996 units appropriate for lower-income households, 901 units appropriate for moderate-income households, and 1,572 units for above moderate-income households. Lower-income areas in Fullerton will benefit from the mix of households of differing income levels and additional housing options. Without private investment in areas like Independence Park and Woodcrest Park, it is unlikely that these areas would revitalize in ways that advance housing equity in Fullerton.

E.14 Sites by Overcrowded Households
The majority of northern Fullerton has low levels of overcrowding (less than five percent of households), while southern Fullerton has higher rates of overcrowding (5 to 22 percent of households). The communities with the highest percentage of overcrowded households are Independence Park and Woodcrest Park in the south-central portion of the city (22 percent overcrowded). Figure E-60, Figure E-61, Figure E-62, Figure E-63, Figure E-64, Figure E-65, Figure E-66, and Figure E-67 show the Site Inventory by overcrowded households.

The Site Inventory assumes that areas with lower levels of overcrowding (less than 10 percent) could accommodate 7,390 units (65 percent of the city’s total Site Inventory), including 3,300 units appropriate for lower-income households (65 percent of the total lower-income units), 1,521 units for moderate- income households (82 percent of the total moderate-income units) and 2,569 units for above moderate-

Appendix H-E: Housing Element H-E-95
City of Fullerton
Housing Element
income households (66 percent of the total above moderate-income units). The Site Inventory assumes that areas with higher levels of overcrowding (greater than 10 percent) could accommodate 3,956 units (35 percent of the Site Inventory), including 1,820 units appropriate for lower-income households, 828 units appropriate for moderate-income households, and 1,308 units for above moderate-income households.

The Site Inventory will not exacerbate overcrowding conditions but will add new housing opportunities across all income levels throughout the city, which will lessen the concentration of overcrowded households in southern Fullerton.

H-E-96 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-44 Housing Opportunity Sites by TCAC Opportunity Score (Craig Park, Acacia Park, Artisan Walk, Deerpark Dr/ Sherwood Ave)

Appendix H-E: Housing Element H-E-97
City of Fullerton
Housing Element
Figure E-45 Housing Opportunity Sites by TCAC Opportunity Score (E Imperial Hwy/N Harbor Blvd, La Habra Southeast, Sunny Hills, El Las Palmas Dr/N Sunnywood Dr)

H-E-98 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-46 Housing Opportunity Sites by TCAC Opportunity Score (West Coyote Hills, Amerige Heights, La Habra South, W Commonwealth Ave/N Masque Ave, Independence Park, Sunny Hills, Santa Fe Distric/SoCo)

Appendix H-E: Housing Element H-E-99
City of Fullerton
Housing Element
Figure E-47 Housing Opportunity Sites by TCAC Opportunity Score (Artesia Blvd/N Gilbert St, Valencia Park, W Valencia Dr/Courtney Ave, Gilbert Park, W Commonwealth Ave/N Basque Ave, W Oak Ave/Lambert Dr, Nicolas Park)

H-E-100 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-48 Housing Opportunity Sites by TCAC Opportunity Score (Nutwood Ave/N Mountain View Pl, California State University Fullerton, Bradford Park, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-101
City of Fullerton
Housing Element
Figure E-49 Housing Opportunity Sites by TCAC Opportunity Score (The Fox Block, Byerrum Park, Rancho La Paz, Nutwood Ave/N Mountain View Pl, Chapman Park, California State University Fullerton)

H-E-102 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-50 Housing Opportunity Sites by TCAC Opportunity Score (W Commonwealth Ave/N Basque Ave, Nicolas Park, Independence Park, S Wood Ave/W Orangethorpe Ave, Woodscrest Park, Rancho La Paz, Santa Fe District/SoCo)

Appendix H-E: Housing Element H-E-103
City of Fullerton
Housing Element
Figure E-51 Housing Opportunity Sites by TCAC Opportunity Score (Sunny Hills, Santa Fe District/SoCo, Bastanchury Rd/Fairway Isles Dr, The Fox Block)

H-E-104 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-52 Opportunity Sites by Income Population (Craig Park, Acacia Park, Artisan Walk, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-105
City of Fullerton
Housing Element
Figure E-53 Opportunity Sites by Income Population (E Imperial Hwy/N Harbor Blvd, La Habra Southeast, Sunny Hills, El Las Palmas Dr/N Sunnywood Dr)

H-E-106 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-54 Opportunity Sites by Income Population (West Coyote Hills, Amerige Heights, La Habra South, W Commonwealth Ave/N Masque Ave, Independence Park, Sunny Hills, Santa Fe Distric/SoCo)

Appendix H-E: Housing Element H-E-107
City of Fullerton
Housing Element
Figure E-55 Opportunity Sites by Income Population (Artesia Blvd/N Gilbert St, Valencia Park, W Valencia Dr/Courtney Ave, Gilbert Park, W Commonwealth Ave/N Basque Ave, W Oak Ave/Lambert Dr, Nicolas Park)

H-E-108 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-56 Opportunity Sites by Income Population (Nutwood Ave/N Mountain View Pl, California State University Fullerton, Bradford Park, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-109
City of Fullerton
Housing Element
Figure E-57 Opportunity Sites by Income Population (The Fox Block, Byerrum Park, Rancho La Paz, Nutwood Ave/N Mountain View Pl, Chapman Park, California State University Fullerton)

H-E-110 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-58 Opportunity Sites by Income Population (W Commonwealth Ave/N Basque Ave, Nicolas Park, Independence Park, S Wood Ave/W Orangethorpe Ave, Woodscrest Park, Rancho La Paz, Santa Fe District/SoCo)

Appendix H-E: Housing Element H-E-111
City of Fullerton
Housing Element
Figure E-59 Opportunity Sites by Income Population (Sunny Hills, Santa Fe District/SoCo, Bastanchury Rd/Fairway Isles Dr, The Fox Block)

H-E-112 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-60 Housing Opportunity Sites by Overcrowded Households (Craig Park, Acacia Park, Artisan Walk, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-113
City of Fullerton
Housing Element
Figure E-61 Housing Opportunity Sites by Overcrowded Households (E Imperial Hwy/N Harbor Blvd, La Habra Southeast, Sunny Hills, El Las Palmas Dr/N Sunnywood Dr)

H-E-114 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-62 Housing Opportunity Sites by Overcrowded Households (West Coyote Hills, Amerige Heights, La Habra South, W Commonwealth Ave/N Masque Ave, Independence Park, Sunny Hills, Santa Fe Distric/SoCo)

Appendix H-E: Housing Element H-E-115
City of Fullerton
Housing Element
Figure E-63 Housing Opportunity Sites by Overcrowded Households (Artesia Blvd/N Gilbert St, Valencia Park, W Valencia Dr/Courtney Ave, Gilbert Park, W Commonwealth Ave/N Basque Ave, W Oak Ave/Lambert Dr, Nicolas Park)

H-E-116 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-64 Housing Opportunity Sites by Overcrowded Households (Nutwood Ave/N Mountain View Pl, California State University Fullerton, Bradford Park, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-117
City of Fullerton
Housing Element
Figure E-65 Housing Opportunity Sites by Overcrowded Households (The Fox Block, Byerrum Park, Rancho La Paz, Nutwood Ave/N Mountain View Pl, Chapman Park, California State University Fullerton)

H-E-118 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-66 Housing Opportunity Sites by Overcrowded Households (W Commonwealth Ave/N Basque Ave, Nicolas Park, Independence Park, S Wood Ave/W Orangethorpe Ave, Woodscrest Park, Rancho La Paz, Santa Fe District/SoCo)

Appendix H-E: Housing Element H-E-119
City of Fullerton
Housing Element
Figure E-67 Housing Opportunity Sites by Overcrowded Households (Sunny Hills, Santa Fe District/SoCo, Bastanchury Rd/Fairway Isles Dr, The Fox Block)

H-E-120 Appendix H-E: Housing Element
City of Fullerton
Housing Element
E.14.1 Sites by Overpayment by Renters
The average housing overpayment rate for renter households in all census tracts in the city is 54 percent.

Overpayment is lowest in the northwestern communities of West Coyote Hills and La Habra South (less than 20 percent of renter households), and highest in the southern communities of Valencia Park and W Oak Ave/Lambert Dr (60 to 80 percent of renter households).

The housing opportunity sites will provide housing opportunities for a mix of income levels in areas with both high and low rates of overpayment by renters, as shown in Figure E-68, Figure E-69, Figure E-70, Figure E-71, Figure E-72, Figure E-73, Figure E-74, and Figure E-75. In areas with rates of overpayment by renters at or above 54 percent, the Site Inventory assumes capacity for 4,524 units (40 percent of the total inventory), including 2,035 units appropriate for low-income households (40 percent of the total lower- income units), 957 units for moderate-income households (41 percent of the total moderate-income units) and 1,532 units for above moderate-income households (40 percent of the total above moderate-income units). The Site Inventory assumes the areas of the city with rates of overpayment by renters below 54 percent could accommodate 6,822 units (60 percent of the city’s total Site Inventory), including 596 units appropriate for lower-income households, 1,392 units appropriate for moderate-income households, and 2,345 units for above moderate-income households.

According to the UDP, new market-rate construction in gentrifying areas neither worsens nor eases rates of people moving out of the area.41 It increases rates of people moving to an area across all socio-economic groups, particularly high-socio-economic residents. The mix of lower-, moderate, and above moderate- income housing units in areas with high overpayment rates will provide affordable housing options for existing lower-income residents as well as encourage higher-income households to move into the area. The Site Inventory will add new rental housing opportunities which may alleviate high costs due to lack of availability.

E.15 Sites by Areas of Integration and Segregation
The northwestern and southeastern areas of the city are the most racially and ethnically diverse, with the highest percentage of non-white residents (between 80 and 100 percent), compared to the center and northeastern areas of the city, which are predominantly white.

The Site Inventory proposes 1,179 housing units (10 percent of the total inventory) in communities where non-white residents exceed 75 percent of the population, including 547 lower-income units (11 percent of total lower-income units), 246 moderate income units (10 percent of total moderate-income units), and 386 above moderate-income units (10 percent of total above moderate-income units). Figure E-76, Figure E-77, Figure E-78, Figure E-79, Figure E-80, Figure E-81, Figure E-82, and Figure E-83 show the housing opportunity sites by percent of the population comprised of non-white residents. Ninety percent of the total Site Inventory units are located in areas with less than 75 percent non-white residents. The Site Inventory will not contribute to segregation based on race/ethnicity.

Additionally, the neighborhoods of Sunny Hills, El Las Palmas Dr/N Sunnywood Dr, Bastanchurty Rd/Fairway Isles Dr, Craig Park, Acacia Park, and Byerrum Park are designated as RCAAs. As shown in Figure E-84, Figure E-85, Figure E-86, Figure E-87, Figure E-88, Figure E-89, Figure E-90, and Figure E-91 , the Site Inventory
identifies 1,372 housing units in these areas, including 635 lower-income units, 280 moderate-income

41 Chapple, Hwang, Jeon, Zhang, Greenberg, and Kumar. New Development for Whom? How New Housing Production Affects Displacement and Replacement in the San Francisco Bay Area. 2022. https://www.urbandisplacement.org/wp-content/uploads/2022/03/IGS_1_New-Production_Brief_03.01.22.pdf, accessed August, 2023.

Appendix H-E: Housing Element H-E-121
City of Fullerton
Housing Element
units, and 457 above moderate-income units. The addition of housing units in these areas will further integrate households of varied incomes within the city.

E.16 Sites by Communities Vulnerable to Displacement
While most of Fullerton is at lower risk of displacement, there are several communities in southern Fullerton that are considered vulnerable to displacement, including the neighborhoods of Artesia Blvd/N Gilbert St, Valencia Park, Woodcrest Park, Rancho La Paz, California State University Fullerton, and Bradford Park. These neighborhoods also have higher poverty rates, higher percentage of LMI residents, overcrowded households and were more likely to have a higher percentage of Hispanic/Latino residents.

Figure E-92, Figure E-93, Figure E-94, Figure E-95, Figure E-96, Figure E-97, Figure E-98, and Figure E-99

show the housing opportunity sites in relation to the location of areas that are at risk of displacement. The majority of the housing opportunity sites identified by the Site Inventory are located in areas with lower displacement risk. Seventeen percent of the Site Inventory is located in areas considered at risk of displacement, including 867 low-income units, 430 moderate-income units, and 684 above moderate- income units. Additional lower-income and moderate-income units in areas of displacement risk will provide affordable housing options for existing low- and moderate-income residents, allowing residents to remain in their communities, and additional moderate- and above moderate-income units may provide housing mobility options and opportunities for home ownership to increase neighborhood stabilization.

E.17 Sites by CalEnviroScreen Score
The majority of the city has low or moderate CalEnviroScreen scores. However, there are a few neighborhoods that are subject to high CalEnviroScreen scores. In general, the northern portion of the city, particularly the neighborhoods of Sunny Hills and Acacia Park, has more positive environmental outcomes than areas south. Higher CalEnviroScreen scores (associated with negative environmental outcomes) are located within the southeastern portion of the city. Figure E-100, Figure E-101, Figure E-102, Figure E-103, Figure E-104, Figure E-105, Figure E-106, and Figure E-107 show the housing opportunity sites by CalEnviroScreen score.

The average CalEnviroScreen score for census tracts in the city is 72. Approximately 61 percent of the housing units proposed by the Site Inventory are proposed in census tracts with a CalEnviroScreen score higher than 75. The remaining 39 percent of housing units are in a census tract with a CalEnviroScreen score lower than 75. Of the units located in areas with higher CalEnviroScreen scores, 3,104 units are appropriate for low-income residents (61 percent of the low-income units), 1,425 units are appropriate for moderate-income residents (61 percent of the moderate-income units), and 2,383 units appropriate for above moderate-income residents (61 percent of the above moderate-income units).

H-E-122 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-68 Housing Opportunity Sites by Overpayment by Renters (Craig Park, Acacia Park, Artisan Walk, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-123
City of Fullerton
Housing Element
Figure E-69 Housing Opportunity Sites by Overpayment by Renters (E Imperial Hwy/N Harbor Blvd, La Habra Southeast, Sunny Hills, El Las Palmas Dr/N Sunnywood Dr)

H-E-124 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-70 Housing Opportunity Sites by Overpayment by Renters (West Coyote Hills, Amerige Heights, La Habra South, W Commonwealth Ave/N Masque Ave, Independence Park, Sunny Hills, Santa Fe Distric/SoCo)

Appendix H-E: Housing Element H-E-125
City of Fullerton
Housing Element
Figure E-71 Housing Opportunity Sites by Overpayment by Renters (Artesia Blvd/N Gilbert St, Valencia Park, W Valencia Dr/Courtney Ave, Gilbert Park, W Commonwealth Ave/N Basque Ave, W Oak Ave/Lambert Dr, Nicolas Park)

H-E-126 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-72 Housing Opportunity Sites by Overpayment by Renters (Nutwood Ave/N Mountain View Pl, California State University Fullerton, Bradford Park, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-127
City of Fullerton
Housing Element
Figure E-73 Housing Opportunity Sites by Overpayment by Renters (The Fox Block, Byerrum Park, Rancho La Paz, Nutwood Ave/N Mountain View Pl, Chapman Park, California State University Fullerton)

H-E-128 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-74 Housing Opportunity Sites by Overpayment by Renters (W Commonwealth Ave/N Basque Ave, Nicolas Park, Independence Park, S Wood Ave/W Orangethorpe Ave, Woodscrest Park, Rancho La Paz, Santa Fe District/SoCo)

Appendix H-E: Housing Element H-E-129
City of Fullerton
Housing Element
Figure E-75 Housing Opportunity Sites by Overpayment by Renters (Sunny Hills, Santa Fe District/SoCo, Bastanchury Rd/Fairway Isles Dr, The Fox Block)

H-E-130 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-76 Housing Opportunity Sites by Total Non-White Population (Craig Park, Acacia Park, Artisan Walk, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-131
City of Fullerton
Housing Element
Figure E-77 Housing Opportunity Sites by Total Non-White Population (E Imperial Hwy/N Harbor Blvd, La Habra Southeast, Sunny Hills, El Las Palmas Dr/N Sunnywood Dr)

H-E-132 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-78 Housing Opportunity Sites by Total Non-White Population (West Coyote Hills, Amerige Heights, La Habra South, W Commonwealth Ave/N Masque Ave, Independence Park, Sunny Hills, Santa Fe Distric/SoCo)

Appendix H-E: Housing Element H-E-133
City of Fullerton
Housing Element
Figure E-79 Housing Opportunity Sites by Total Non-White Population (Artesia Blvd/N Gilbert St, Valencia Park, W Valencia Dr/Courtney Ave, Gilbert Park, W Commonwealth Ave/N Basque Ave, W Oak Ave/Lambert Dr, Nicolas Park)

H-E-134 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-80 Housing Opportunity Sites by Total Non-White Population (Nutwood Ave/N Mountain View Pl, California State University Fullerton, Bradford Park, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-135
City of Fullerton
Housing Element
Figure E-81 Housing Opportunity Sites by Total Non-White Population (The Fox Block, Byerrum Park, Rancho La Paz, Nutwood Ave/N Mountain View Pl, Chapman Park, California State University Fullerton)

H-E-136 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-82 Housing Opportunity Sites by Total Non-White Population (W Commonwealth Ave/N Basque Ave, Nicolas Park, Independence Park, S Wood Ave/W Orangethorpe Ave, Woodscrest Park, Rancho La Paz, Santa Fe District/SoCo)

Appendix H-E: Housing Element H-E-137
City of Fullerton
Housing Element
Figure E-83 Housing Opportunity Sites by Total Non-White Population (Sunny Hills, Santa Fe District/SoCo, Bastanchury Rd/Fairway Isles Dr, The Fox Block)

H-E-138 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-84 Housing Opportunity Sites by Racially Concentrated Areas of Affluence (Craig Park, Acacia Park, Artisan Walk, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-139
City of Fullerton
Housing Element
Figure E-85 Housing Opportunity Sites by Racially Concentrated Areas of Affluence (E Imperial Hwy/N Harbor Blvd, La Habra Southeast, Sunny Hills, El Las Palmas Dr/N Sunnywood Dr)

H-E-140 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-86 Housing Opportunity Sites by Racially Concentrated Areas of Affluence (West Coyote Hills, Amerige Heights, La Habra South, W Commonwealth Ave/N Masque Ave, Independence Park, Sunny Hills, Santa Fe Distric/SoCo)

Appendix H-E: Housing Element H-E-141
City of Fullerton
Housing Element
Figure E-87 Housing Opportunity Sites by Racially Concentrated Areas of Affluence (Artesia Blvd/N Gilbert St, Valencia Park, W Valencia Dr/Courtney Ave, Gilbert Park, W Commonwealth Ave/N Basque Ave, W Oak Ave/Lambert Dr, Nicolas Park)

H-E-142 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-88 Housing Opportunity Sites by Racially Concentrated Areas of Affluence (Nutwood Ave/N Mountain View Pl, California State University Fullerton, Bradford Park, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-143
City of Fullerton
Housing Element
Figure E-89 Housing Opportunity Sites by Racially Concentrated Areas of Affluence (The Fox Block, Byerrum Park, Rancho La Paz, Nutwood Ave/N Mountain View Pl, Chapman Park, California State University Fullerton)

H-E-144 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-90 Housing Opportunity Sites by Racially Concentrated Areas of Affluence (W Commonwealth Ave/N Basque Ave, Nicolas Park, Independence Park, S Wood Ave/W Orangethorpe Ave, Woodscrest Park, Rancho La Paz, Santa Fe District/SoCo)

Appendix H-E: Housing Element H-E-145
City of Fullerton
Housing Element
Figure E-91 Housing Opportunity Sites by Racially Concentrated Areas of Affluence (Sunny Hills, Santa Fe District/SoCo, Bastanchury Rd/Fairway Isles Dr, The Fox Block)

H-E-146 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-92 Housing Opportunity Sites by Displacement Risk (Craig Park, Acacia Park, Artisan Walk, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-147
City of Fullerton
Housing Element
Figure E-93 Housing Opportunity Sites by Displacement Risk (E Imperial Hwy/N Harbor Blvd, La Habra Southeast, Sunny Hills, El Las Palmas Dr/N Sunnywood Dr)

H-E-148 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-94 Housing Opportunity Sites by Displacement Risk (West Coyote Hills, Amerige Heights, La Habra South, W Commonwealth Ave/N Masque Ave, Independence Park, Sunny Hills, Santa Fe Distric/SoCo)

Appendix H-E: Housing Element H-E-149
City of Fullerton
Housing Element
Figure E-95 Housing Opportunity Sites by Displacement Risk (Artesia Blvd/N Gilbert St, Valencia Park, W Valencia Dr/Courtney Ave, Gilbert Park, W Commonwealth Ave/N Basque Ave, W Oak Ave/Lambert Dr, Nicolas Park)

H-E-150 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-96 Housing Opportunity Sites by Displacement Risk (Nutwood Ave/N Mountain View Pl, California State University Fullerton, Bradford Park, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-151
City of Fullerton
Housing Element
Figure E-97 Housing Opportunity Sites by Displacement Risk (The Fox Block, Byerrum Park, Rancho La Paz, Nutwood Ave/N Mountain View Pl, Chapman Park, California State University Fullerton)

H-E-152 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-98 Housing Opportunity Sites by Displacement Risk (W Commonwealth Ave/N Basque Ave, Nicolas Park, Independence Park, S Wood Ave/W Orangethorpe Ave, Woodscrest Park, Rancho La Paz, Santa Fe District/SoCo)

Appendix H-E: Housing Element H-E-153
City of Fullerton
Housing Element
Figure E-99 Housing Opportunity Sites by Displacement Risk (Sunny Hills, Santa Fe District/SoCo, Bastanchury Rd/Fairway Isles Dr, The Fox Block)

H-E-154 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-100 Housing Opportunity Sites by CalEnviroScreen Score (Craig Park, Acacia Park, Artisan Walk, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-155
City of Fullerton
Housing Element
Figure E-101 Housing Opportunity Sites by CalEnviroScreen Score (E Imperial Hwy/N Harbor Blvd, La Habra Southeast, Sunny Hills, El Las Palmas Dr/N Sunnywood Dr)

H-E-156 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-102 Housing Opportunity Sites by CalEnviroScreen Score (West Coyote Hills, Amerige Heights, La Habra South, W Commonwealth Ave/N Masque Ave, Independence Park, Sunny Hills, Santa Fe Distric/SoCo)

Appendix H-E: Housing Element H-E-157
City of Fullerton
Housing Element
Figure E-103 Housing Opportunity Sites by CalEnviroScreen Score (Artesia Blvd/N Gilbert St, Valencia Park, W Valencia Dr/Courtney Ave, Gilbert Park, W Commonwealth Ave/N Basque Ave, W Oak Ave/Lambert Dr, Nicolas Park)

H-E-158 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-104 Housing Opportunity Sites by CalEnviroScreen Score (Nutwood Ave/N Mountain View Pl, California State University Fullerton, Bradford Park, Deerpark Dr/Sherwood Ave)

Appendix H-E: Housing Element H-E-159
City of Fullerton
Housing Element
Figure E-105 Housing Opportunity Sites by CalEnviroScreen Score (The Fox Block, Byerrum Park, Rancho La Paz, Nutwood Ave/N Mountain View Pl, Chapman Park, California State University Fullerton)

H-E-160 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Figure E-106 Housing Opportunity Sites by CalEnviroScreen Score (W Commonwealth Ave/N Basque Ave, Nicolas Park, Independence Park, S Wood Ave/W Orangethorpe Ave, Woodscrest Park, Rancho La Paz, Santa Fe District/SoCo)

Appendix H-E: Housing Element H-E-161
City of Fullerton
Housing Element
Figure E-107 Housing Opportunity Sites by CalEnviroScreen Score (Sunny Hills, Santa Fe District/SoCo, Bastanchury Rd/Fairway Isles Dr, The Fox Block)

H-E-162 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Sites Analysis Summary Data
Table E-13 summarizes the Site Inventory by development priority area, sites, number of units by income level, and census tract characteristics.

E.18 Contributing Factors and Meaningful Actions
State law (AB 686) requires identification and prioritization of contributing factors to fair housing issues based on all the previously required analysis. This identification and prioritization must give highest priority to factors that limit or deny fair housing choice or access to opportunity or negatively impact fair housing or civil rights. AB 686 also requires identification of metrics or quantified objectives and milestones for determining what fair housing results will be achieved. Meaningful actions must be taken in concert with each other and address the following:
• Significant Disparities in Housing Needs and in Access to Opportunity • Replacing Segregated Living Patterns with Truly Integrated and Balanced Living Patterns • Transforming R/ECAP into Areas of Opportunity
• Fostering and Maintaining Compliance with Civil Rights and Fair Housing Laws42 This section lists contributing factors that create, perpetuate, or increase the severity of one or more fair housing issues that were identified in the AI, community outreach, and the analysis in this document.

Table E-14 summarizes the identified fair housing issues, contributing factors to these issues, and meaningful actions the City will undertake to affirmatively further fair housing for special needs, racial/ethnic minority, and low-income residents.

E.18.1 Fair Housing Enforcement and Outreach Capacity
The following contributing factors to inadequate fair housing enforcement and outreach include:
• Lack of local private fair housing outreach and enforcement • Lack of local public fair housing enforcement
• Lack of resources for fair housing agencies and organizations to conduct more rigorous testing and audits, outreach, training, public education campaigns. • Lack of funding for consumer rights and responsibility education on Fair Lending practices and identification of predatory lending practices.
• Lack of language access
Although Fullerton residents are served by the Fair Housing Foundation, fair housing resources are limited due to available funding. Additionally, as stated in the AI, the size of the federal Fair Housing Initiatives Program, the primary funding program for fair housing organizations, has failed to keep up with inflation, reducing the capacity of fair housing organizations over time. In order to meet the needs of residents of a large and diverse county, local fair housing agencies and organizations require greater levels of resourcing.

42 HCD. 2021. Affirmatively Furthering Fair Housing: Guidance for All Public Entities and for Housing Elements. April 2021 Update. https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf

Appendix H-E: Housing Element H-E-163
City of Fullerton
Housing Element
Table E-13 Site Inventory by Census Tract Characteristics

Neighborhood
and Census Tract
Number of
Existing
Households
Site Inventory Capacity (Units) AFFH Indicators
Low-
Income
Moderate-
Income
Above
Moderate-
Income
Percent
Non-
White
Median
Household
Income
Percent LMI
Households
TCAC
Opportunity
Area
Percent
Overpayment by
Renters
Percent
Overcrowded
Households
Displacement
Sensitivity
CalEnviroScreen
Percentile
Acacia Park
6059001602 1,701 77 29 47 41.12 % $137,869 19.94% Highest Resource

51.1% 0.59% Lower Risk 29.33
Amerige Heights
6059001704 2,411 256 102 155 94.11% $137,202 34.57% Highest Resource

49.9% 3.28% Lower Risk 55.61
Artesia Blvd/N Gilbert St
6059001801 1,659 258 104 162 75.53% $56,169 70.21% Low
Resource
60% 11.51% At Risk 90.45
Artisan Walk
6059011707 2,437 124 50 76 41.76% $92,593 39.02% Highest Resource

61.2% 1.07% Lower Risk 66.63
Bastanchury Rd/Fairway Isles Dr
6059001601 1,559 33 40 69 51.25% $105,801 34.74% Highest Resource

56.8% 3.85% Lower Risk 90.09
Bradford Park
6059011711 2,425 84 39 63 86.61% $64,961 70.33% High
Resource

63.9% 6.93% At Risk 60.16
Brea West
6059001503 1,811 30 17 29 46.43% $98,157 40.82% High
Resource

60.5% 5.58% Lower Risk 93.06
Byerrum Park
6059011402 979 2 13 24 38.36% $127,847 19.7% High
Resource

31.4% 1.23% Lower Risk 48.39

H-E-164 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Neighborhood
and Census Tract
Number of
Existing
Households
Site Inventory Capacity (Units) AFFH Indicators
Low-
Income
Moderate-
Income
Above
Moderate-
Income
Percent
Non-
White
Median
Household
Income
Percent LMI
Households
TCAC
Opportunity
Area
Percent
Overpayment by
Renters
Percent
Overcrowded
Households
Displacement
Sensitivity
CalEnviroScreen
Percentile
California State University Fullerton
6059011504 1,795 139 69 112 59.36% $46,992 70.91% Moderate Resource

79.3% 3.90% 1 Income Group
Displacement

61.84 Chapman Park
6059011502 1,633 495 218 345 65.70% $76,458 67.46% High Resource

52.9% 7.23% Lower Risk 95.26
Craig Park
6059001505 2,349 30 21 36 53.68% $132,932 36.79% High
Resource

63.8% 8.05% Lower Risk 62.60
Deerpark Dr/Sherwood Ave
6059011708 1,695 21 7 14 59.70% $82,614 61.28% Moderate Resource

54.2% 6.73% Lower Risk 57.62
E Imperial Hwy/N Harbor Blvd
6059001404 997 273 109 169 66.58% $81,602 70.47% Low
Resource

42.5% 12.14% Lower Risk 95.00
E Wilshire Ave/N Raymond Ave
6059011403 1,922 903 397 630 60.96% $85,481 63.68% Moderate Resource

57.3% 11.55% Lower Risk 95.83
Gilbert Park
6059001903 885 49 22 36 66.26% $98,819 42.9% Low
Resource

51.2% 9.72% Lower Risk 80.49
Independence Park
6059011200 1,667 681 306 496 57.18% $96,964 41.94% Moderate Resource

42.8% 5.28% Lower Risk 58.95

Appendix H-E: Housing Element H-E-165
City of Fullerton
Housing Element
Neighborhood
and Census Tract
Number of
Existing
Households
Site Inventory Capacity (Units) AFFH Indicators
Low-
Income
Moderate-
Income
Above
Moderate-
Income
Percent
Non-
White
Median
Household
Income
Percent LMI
Households
TCAC
Opportunity
Area
Percent
Overpayment by
Renters
Percent
Overcrowded
Households
Displacement
Sensitivity
CalEnviroScreen
Percentile
Nicolas Park
6059011101 1,339 85 57 97 67.25% $98,165 49.54% Moderate Resource

42.9% 8.44% Lower Risk 70.82
Nutwood Ave/N Mountain View Pl
6059011503 553 30 17 29 44.46% $107,102 16.56% High
Resource

37.7% 4.52% Lower Risk 48.46
Rancho La Paz
6059011602 1,760 296 128 199 68.68% $65,192 75.97% Low
Resource

53.5% 12.22% At Risk 99.69
S Woods Ave/W Orangethorpe Ave
6059011102 1,188 24 17 30 71.47% $111,524 52.61% Moderate Resource

60.2% 6.82% Lower Risk 72.97
Santa Fe District/SoCo
6059011300 2,030 134 56 206 57.96% $92,604 40.72% High
Resource

48.2% 2.86% Lower Risk 89.50
Sunny Hills
6059001706 1,331 461 187 301 57.30% $184,018 25.2% Highest Resource

48.5% 3.98% Lower Risk 34.60
The Fox Block
6059011401 663 1 4 7 55.81% $138,625 36.97% High
Resource

42.9% 3.62% Lower t Risk 48.62
Valencia Park
6059001802 2,248 57 50 79 77.44% $61,354 76.8% Moderate Resource

66.1% 13.75% At Risk 85.65

H-E-166 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Neighborhood
and Census Tract
Number of
Existing
Households
Site Inventory Capacity (Units) AFFH Indicators
Low-
Income
Moderate-
Income
Above
Moderate-
Income
Percent
Non-
White
Median
Household
Income
Percent LMI
Households
TCAC
Opportunity
Area
Percent
Overpayment by
Renters
Percent
Overcrowded
Households
Displacement
Sensitivity
CalEnviroScreen
Percentile
W Commonwealth Ave/N Basque Ave
6059011000 2,521 541 270 433 67.59% $81,033 50.63% Moderate Resource

44.7% 0.67% Lower Risk 83.95
6059011101 1,339 85 57 97 66.64% $98,165 49.54% Moderate Resource

42.9% 8.44% Lower t Risk 70.82
W Valencia Dr/Courtney Ave
6059001901 850 1 4 7 59.84% $106,630 44.09% Moderate
Resource

70.2% 2.94% Lower Risk 59.76
Woodcrest Park
6059011601 2,240 33 40 69 78.12% $65,789 79.36% Low
Resource

68.1% 21.88% At Risk 96.58
Total 5,120 2,349 3,877

Appendix H-E: Housing Element H-E-167
City of Fullerton
Housing Element
There are no local public entities that conduct fair housing outreach and enforcement in Fullerton. The city provides links to the Fair Housing Foundation and upcoming fair housing workshops. A local agency contracted by the City would have the potential to be more responsive to discrimination complaints.

According to the AI, 20 percent of city residents have Limited English Proficiency (LEP), with Spanish being the most commonly spoken language other than English, followed by Korean, Chinese, and Vietnamese.

Residents with LEP may have a harder time understanding fair housing laws and increased difficulty in accessing fair housing resources. Fair housing outreach must be inclusive of multiple languages to accommodate LEP residents.

E.18.2 Segregation and Integration
Contributing factors to segregation and integration patterns in Fullerton include:
• Location, type, and supply of affordable housing
• Land use and zoning laws
• Displacement of residents due to economic pressures
• Racial discrepancies in loan origination
Fullerton is an ethnically diverse city with a high degree of integration. As previously mentioned, most areas of Fullerton have a three-group neighborhood mix consisting of Asian American, Hispanic/Latino, and non-Hispanic white residents, and several neighborhoods have a four-racial group mix. No singular racial/ethnic group is segregated within Fullerton, but there several neighborhoods with predominant racial gaps (gap greater than 50 percent), with a predominantly Asian American population in the eastern area of the city and a predominantly Hispanic/Latino population in the southwestern area of the city.

Economic disparities have been intensified by the high cost of housing in recent years in Fullerton and Orange County as a whole, which have resulted in displacement of low-income residents. These disparities have been worsened by the limited growth of low- and moderate-income housing in the city and have resulted in significant segregation by race and ethnicity and income levels.

Zoning patterns exacerbate patterns of segregation by concentrating higher density residential zoning and industrial zoning in southern and southeast portion of Fullerton and low-density residential and open space zoning in the northern portion of the city. The majority of the multifamily homes are located in the southern neighborhoods with a predominant Hispanic/Latino population that are at risk of displacement.

Recent new multifamily development within the city is also concentrated in southern Fullerton, while new single-family development and open space preservation is concentrated in high resource areas in northern Fullerton. While recent new developments have increased the availability of housing in areas that need it, the dichotomy in development patterns further segregates the city by incomes and race. Further, the majority of the existing subsidized housing stock is located in proximity to the industrial zoned areas in the city in the neighborhoods of Woodcrest Park and Rancho La Paz, which exacerbates economic segregation and subjects lower-income residents to poorer air quality.

Disparities in mortgage origination is a contributing factor to fair housing issues in Fullerton. Asian American and white, non-Hispanic mortgage applicants had their loans originated at higher rates compared to other races. Black/African American and Hispanic/Latino applicants had the highest loan denial rate. This may be due to disparities in income and mortgage education across races.

H-E-168 Appendix H-E: Housing Element
City of Fullerton
Housing Element
E.18.3 Significant Disparities in Housing Needs and Access to Opportunity The following contributing factors to disparities in access to opportunities in Fullerton include:
• The availability, type, frequency, and reliability of public transportation • Location of environmental health hazards
• Location, type, and supply of affordable housing
• The availability of affordable units in a range of sizes Access to Opportunity
According to HCD, access to opportunity is a concept to approximate place-based characteristics linked to critical life outcomes. Neighborhoods located in the southeastern central area of the city are generally associated with lower access to opportunity in terms of environmental health determinants, housing, and economic opportunities. The neighborhoods with the lowest outcomes across all opportunity areas include Woodcrest Park and Rancho La Paz. Conversely, the northern portion of the city has greater access to educational, economic, and environmental opportunities than the southern half of the city.

Neighborhoods in southern Fullerton, such as Woodcrest Park, E Wilshire Ave/N Raymond Ave, Chapman Park, and Rancho La Paz, have higher levels of exposure to particulate matter from truck and vehicle emissions due to the proximity of industrial and commercial uses. These neighborhoods have the highest housing density within the city, with the majority of multifamily homes concentrated in these areas.

Subsidized housing units are also concentrated in this area of the city. As a result, there is a high percentage of lower-income, non-white residents that are exposed to greater environmental hazards, compared to the wealthier communities in northern Fullerton that are primarily comprised of single-family homes.

In general, the disproportionately white and Asian American northern half of the city, which tends to have greater access to opportunities, is primarily comprised of single-family homes, contributing to higher housing costs. Increasing housing affordability and the availability of different housing types in these areas would make it easier for low-income households, which disproportionately are associated with Hispanic/Latino and Black/African American households, to access the types of services and amenities that further social mobility.

Transit Access
The lack of service routes for public transportation in northern Fullerton impacts fair housing issues in the city. The southern half of the city is more heavily serviced with more bus routes than the northern half of the city. Households that rely on public transit are pressured to reside in southern Fullerton, which has a higher degree of pollution exposure, a lower median household income, and a higher percentage of Hispanic/Latino and Black/African-American residents than northern Fullerton. Therefore, lack of transit options in northern Fullerton reinforces existing patterns of segregation and lack of access to opportunity.

Housing Needs
Overcrowding, as defined by HUD, in Fullerton is higher than Orange County. Broken down by race, overcrowding was a more common housing issue for residents of Fullerton who identified as American Indian/Alaskan Native, Hispanic/Latino, and those of other race or multiple races than for people who identified as white, Black/African American, or American Indian/Alaska Native. According to the AI, the

Appendix H-E: Housing Element H-E-169
City of Fullerton
Housing Element
majority of subsidized housing units, includng Project-Based Section 8 units, other multifamily assisted units, and HCV units are comprised of studios and one-bedroom units. As a result, low-income households, especially those with multiple children, may have difficulty finding adequately sized affordable housing.

E.19 Meaningful Actions to Address Fair Housing Issues
This assessment of fair housing issues identifies factors that contribute to fair housing issues in Fullerton, identified in Table E-14. The meaningful actions are incorporated into programs and actions in Chapter 4, Housing Policy Plan. Based on community feedback and data analysis, it was determined that high-priority issues in the city are lack of affordable housing, displacement, and segregation of low-income residents.

Fair housing enforcement and outreach are determined to be medium priority. Additionally, several programs included in Chapter 4, Housing Policy Plan, affirmatively further fair housing by the action areas determined by HCD.

H-E-170 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Table E-14 Meaningful Actions to Address Fair Housing Issues

Identified Fair Housing
Issue Contributing Factors Meaningful Actions Metrics and Timeline Fair housing
enforcement and
outreach
• Lack of local private
fair housing outreach
and enforcement
(Priority: high)
• Lack of public fair
housing enforcement
(Priority: medium)
• Lack of resources for
fair housing agencies
to conduct more
rigorous testing and
audits, outreach,
training, public
education campaigns
(Priority: high).
• Lack of funding for
consumer rights and
responsibility
education on Fair
Lending practices and
identification of
predatory lending
practices. (Priority:
medium)
• Lack of language
access (Priority: high)
Fair Housing Services and Education:
• Provide informational seminars to area residential real estate agents and brokers on fair housing laws and regulations; • Work with tenants, tenant advocates to identify violations of fair housing federal and State fair housing laws and support prospective and existing tenants who are experiencing
discrimination;
• Provide trainings for property owners/managers on the requirements of federal and State fair housing laws to prevent discrimination. (Policy Action 3.13-a)
Provide trainings to at least 15 real estate agents
and brokers annually.

Provide trainings to at least 15 property owners
and managers annually.

Report the number of complaint-based testing
efforts and number of resulting complaints filed
with HUD or CRD annually.

With the Fair Housing Foundation, support an annual Fair Housing Audit Report that assesses typical or timely market-based suspected areas of discrimination. (Policy Action 3.13-e) Consult with the Fair Housing Foundation to
review methodology for a Fair Housing Audit by
January 2025.

Affordable Rental Housing Counseling Services: Provide funding for information and referral services that direct families and individuals with financial resources for housing rental or purchase, locating suitable housing, and obtaining housing with special needs facilities such as disabled-accessible units. (Policy Action 3.13-b) Beginning in 2025, hold at least four informational
events during the planning period to disseminate
informational materials or provide trainings to
residents, prioritizing communities sensitive to
displacement (Artesia Blvd/N Gilbert, Valencia
Park, Woodcrest Park, Rancho La Paz, and
California State University Fullerton). Assist at
least 50 residents and landlords with fair housing
services annually.

Create a Language Access Plan based on HUD guidelines and publish on the City’s website: The goal of the Language Access Plan is to survey, maintain and publish a list of multi-lingual staff- capacity at City Hall so that staff may respond to the needs of Limited English Proficiency households. (Policy Action 3.5-b) Create a Language Access Plan by January 2025.

Maintain multilingual staff capacity at City Hall to
respond to the needs of Limited English
Proficiency households and ensure that all
residents may participate fully and equally in the
housing market.

Appendix H-E: Housing Element H-E-171
City of Fullerton
Housing Element
Identified Fair Housing
Issue Contributing Factors Meaningful Actions Metrics and Timeline Ensure that local housing programs respond to the needs of a culturally diverse community that includes multi-generational families, a variety of living arrangements, and Limited English Proficiency households. Plans should ensure collaboration with community groups, including faith-based and nonprofit
organizations, to provide outreach on housing resources to all types of households and those households with Limited English Proficiency. (Policy Action 3.13-c)
Review the existing fair housing marketing plan
every two years ensure compliance with current
City policy to Affirmatively Further Fair Housing
and make necessary changes within six months.

Fair Lending: Work to promote fair lending practices throughout the city:
• Ensure that low-income and minority residents have fair access to capital resources needed to acquire and maintain housing. • Prevent predatory lending through information and referrals to the Fair Housing Foundation. (Policy Action 3.13-f)
Annually conduct and publish third party review of
City or regional HMDA data to identify areas of
need regarding fair access to lending.

Add information on fair housing laws and resources on the City’s website regarding housing programs in several languages. (Policy Action 3.13-g)
Update website content with updated information
on fair housing services and programs by January
2025.

Seek opportunities to expand outreach and public education strategies on available tenant protection, fair housing services, and homeownership education to reach vulnerable households by offering information in multiple languages, targeted social media efforts, combining information with other assistance programs, distributing resources through local schools and colleges, and partnering with community-based organizations. (Policy Action

3.13-h)
Partner with three new schools or community-
based organizations during the planning period to
disseminate materials and provide trainings to
residents, prioritizing services in communities
sensitive to displacement within southern
Fullerton, including Artesia Blvd/N Gilbert St,
Valencia Park, Woodcrest Park, Rancho La Paz,
California State University Fullerton, and Bradford
Park.

H-E-172 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Identified Fair Housing
Issue Contributing Factors Meaningful Actions Metrics and Timeline Concentration of
minority and low-income
residents in southern
Fullerton; displacement
of residents
• Location, type, and
supply of affordable
housing (Priority: high)
• Land use and zoning
laws (Priority:
medium)
• Displacement of
residents due to
economic pressures
(Priority: high)
• Racial discrepancies in
loan origination
• The availability, type,
frequency, and
reliability of public
transportation
(Priority: medium)
Develop an outreach strategy in multiple languages for property owners who own fewer than 10 residential units (either in single- family or multi-family rental housing) to assess needs and connect them with resources, such as housing unit rehabilitation and financing programs. The intent of this program is to preserve Naturally Occurring Affordable Housing (i.e., not currently regulated with affordability restrictions), particularly in the neighborhoods of Woodcrest Park and Rancho La Paz. The program will seek to prioritize communities vulnerable to displacement, generally in the southern areas of the city, a focus on neighborhoods with lower median income. (Policy Action 3.14-a)
Develop an outreach strategy for “mom and pop”
property owners by January 2026. After the
strategy is adopted, conduct outreach to at least
15 property owners with less than 10 units and
assist at least 5 property owners with a combined
total of 20 units or more by December 2029.

Implement changes to the in-lieu fee structure and the desire and ability of developers to contribute to an affordable housing trust fund. Adopt incentives such as increased densities, increased height limits, reduced parking standards, and ministerial review for projects that incorporate increased affordable units or deeper levels of affordability. (Policy Action 3.14-b)
Complete a feasibility study on in-lieu payments to
a Housing Trust Fund by January 2026. If feasible,
amend the municipal code to allow for an in-lieu
fee structure by December 2027 and implement
an Inclusionary Housing Ordinance by December
2029.

Facilitate the development of housing for persons with disabilities (including developmental disabilities) through incentives for affordable housing development with services, resources, and assistance. (Policy Action 3.17-a)
Develop 25 housing units for special needs
households during the planning period.

Increase participation in homeownership education and assistance programs for historically underrepresented residents in the homeownership market. (Policy Action 3.18-a)
Partner with the County and/or community-based
organizations to facilitate homeownership
workshops, counseling, and/or education
campaigns by January 2025. Organizations may
include teachers’ associations, school districts,
and community-based service providers to
increase awareness of, and access to, housing
resources and financial planning services during
the planning period.

By October 31, 2029, connect at least 30 residents
to education on homeownership-related topics in
the neighborhoods of Artesia Blvd/N Gilbert,
Valencia Park, Woodcrest Park, Rancho La Paz,
and California State University Fullerton.

Appendix H-E: Housing Element H-E-173
City of Fullerton
Housing Element
Identified Fair Housing
Issue Contributing Factors Meaningful Actions Metrics and Timeline Review the City’s Tenant-Based Rental Assistance program with input from tenants and property owners/managers, ensuring representation across the economic spectrum, and update as appropriate. Outreach to be conducted to all vulnerable communities during the update process and after final adoption in 2027.

Fill any gaps between Section 8 assistance and rent, or to aid those who may not qualify for Section 8 but need one-time emergency assistance, to provide relief to tenants to avoid the displacement in vulnerable communities. (Policy Action 3.14-c)
Update the City’s Tenant-Based Rental Assistance
program by January 2027.

Prepare and present a report on
recommendations for programs that would
provide relief to tenants and landlords to avoid
the displacement in vulnerable communities by
December 2026. If a rental assistance program is
approved and implemented as a result, the
program will assist at least 10 lower income renter
households annually.

Evaluate existing State and federal “just cause for eviction” (AB 1482; 2019-Chiu) and other similar legislation with provisions to determine if additional protections through a local ordinance is warranted. (Policy Action 3.16-c)
In consultation with fair housing service providers
and community-based organizations, assess if
additional protections are needed, by January
2026. If warranted, recommend adoption of a
local tenant protection ordinance to City Council
by December 2026.

Provide financial support to organizations that provide supportive housing for emancipated foster youth (ages 18-21) who are homeless or at immediate risk of becoming homeless. (Policy Action 3.15-f)
Assist at least 10 foster youth with supportive
housing during the planning period by December
2029.

In compliance with recent updates to the Surplus Land Act (AB 1255, 2019-Rivas; AB 1486, 2019-Ting), identify City-owned land for the development of affordable housing. If surplus properties are identified, pursue development via a competitive Request for Proposals or other processes. (Policy Action 3.7-d)
Report on identified surplus land in Housing
Element Annual Progress reports. Annually, assess
the list of surplus sites and solicit development via
a competitive RFP process or other forms of
partnership such as land lease agreements.

Acquire funds from local, state, and federal grant opportunities, including the HCD Infill Infrastructure Grant Program, to support the development of affordable housing, housing for special needs, and support service projects. When a critical mass of state (various HCD programs) and/or federal (CDBG, HOME) funding is available, the City will issue a competitive Notice of Funding Availability with objective criteria to transparently identify the best non-profit affordable housing developer to partner with on new affordable housing developments in the city.

Partner with at least one nonprofit housing
developer biennially throughout the planning
period and support the entitlement of at least 400
subsidized housing units affordable to extremely
low-, very low-, and low-income households in the
city during the planning period.

Conduct feasibility study for an affordable housing
trust fund by January 2027.

H-E-174 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Identified Fair Housing
Issue Contributing Factors Meaningful Actions Metrics and Timeline Partner with Orange County Housing Finance Trust to secure funding for affordable housing in Fullerton. (Policy Action 3.7-c) Develop a web-based Housing Development Toolkit that outlines a step-by-step process for residential development, including identifying steps in the entitlement and building permit process, detailed information on development incentives, and funding programs and resources for affordable housing development. (Policy Action 3.4-d)
Publish Housing Development Toolkit on City’s
website by December 2026.

Review the General Plan, applicable Specific Plans, and Zoning Code and Zoning Map to evaluate opportunities for removing barriers to housing production such as adding housing capacity and
accommodating a greater mix of dwelling types and sizes in High and Highest Resource areas identified by the California Tax Credit Allocation Committee (TCAC), focusing efforts in northeastern and northwestern Fullerton. Recommend amendments, as necessary, to accommodate added housing capacity in these areas.

Additionally, review the Zoning Code to identify opportunities to increase and encourage a greater mix of dwelling types and sizes, specifically housing types that may accommodate moderate- income households (e.g., duplexes, triplexes, fourplexes, townhouses, courtyard buildings), in lower-density residential areas and mixed-use zones citywide and amend the Zoning Code as needed (i.e., implementation of LTD). (Policy Action 3.4-g) Review the General Plan, applicable Specific Plan,
and Zoning Code and Zoning Map by June 2025
and implement any changes by January 2026.

Following adoption of zoning code changes,
monitor at least 1,801 moderate-income units and
2,238 lower-income units to be constructed
annually in High and Highest Resource areas as
designated by TCAC. Permit the development of at
least 150 moderate-income dwelling types in the
neighborhoods of E Las Palmas Dr/N Sunnywood
Dr, Craig Park, Sunny Hills, Bastanchury
Rd/Fairway Isles Dr, Acacia Park, and Byerrum Park
(Racially Concentrated Areas of Affluence) by the
end of 2029.

Identify and advertise housing opportunity sites within one-quarter mile of public transit stops in northern Fullerton. Educate developers on the Transit Oriented Development (TOD) Housing Program, and/or pursue funding to increase transit infrastructure in northern Fullerton. (Policy Action 3.14-d)
On an ongoing basis, consult with interested
developers on the TOD Housing Program. Conduct
a study with OCTA to identify capital projects to
increase transit infrastructure by 2026. Apply for
TOD Housing Program funds as NOFA becomes
available.

Partner with Cal State Fullerton to develop a plan to address the need for off-campus affordable housing for students. (Policy Action

3.4-m)
Develop a city-wide student housing plan by
December 2029.

Appendix H-E: Housing Element H-E-175
City of Fullerton
Housing Element
Identified Fair Housing
Issue Contributing Factors Meaningful Actions Metrics and Timeline Monitor lot splits and two-unit developments under SB 9, provide technical assistance to homeowners, and develop or adjust development standards as needed. Provide easily accessible information and resources about SB 9 on the City website. Conduct outreach to homeowners’ associations in the neighborhoods of E Las Palmas Dr/N Sunnywood Dr, Craig Park, Sunny Hills,
Bastanchury Rd/Fairway Isles Dr, Acacia Park, and Byerrum Park, and the neighborhoods in northwest Fullerton, and provide information on SB 9 (Policy Action 3.3-b)
Beginning in 2025, meet with at least one
homeowners’ association annually in the areas of
northwest Fullerton and the neighborhoods of E
Las Palmas Dr/N Sunnywood Dr, Craig Park, Sunny
Hills, Bastanchury Rd/Fairway Isles Dr, Acacia Park,
and Byerrum Park to provide education on SB 9
implementation. Amend the Zoning Code to
comply with SB 9 by December 2025.

Conduct outreach to religious institutions and provide technical assistance for interested parties to develop affordable housing on sites zoned religious institution (Policy Action 3.3-f).

Starting in 2025, annually mail or email resources
on developing affordable housing to all religious
institutions in the city with underutilized land.

Conduct follow up calls with institutions with sites
that hold the most potential based on location
and size, prioritizing potential sites in the
neighborhoods of E Las Palmas Dr/N Sunnywood
Dr, Craig Park, Sunny Hills, Bastanchury
Rd/Fairway Isles Dr, Acacia Park, and Byerrum Park
since they are Racially Concentrated Areas of
Affluence. By December 2026, present
information during at least one meeting with the
board and/or members of OC United. By the end
of 2027, provide technical assistance for the
potential development of at least one affordable
housing development on a religious institution
site.

H-E-176 Appendix H-E: Housing Element
City of Fullerton
Housing Element
Identified Fair Housing
Issue Contributing Factors Meaningful Actions Metrics and Timeline Conduct outreach to people experiencing homelessness with the Illumination Foundation and the OC Health Care Agency, focusing efforts in areas where there is a high concentration of homeless individuals in the neighborhoods of Independence Park, Santa Fe District/SoCo, and Gilbert Park, and along arterial boulevards and commercial centers. Provide resources to connect individuals with shelter space in Fullerton and as needed, to services in surrounding cities (Policy Action 3.4-i).

Annually allocate funding and City resources to
support outreach efforts in coordination with the
Illumination Foundation and the OC Health Care
Agency to provide information and resources to
those experiencing homelessness. Annually fund
the Fullerton Police Department’s Homeless
Liaison Officer Unit, and as funding is available and
based on need, increase the number of officers to
provide services for residents experiencing
homelessness.

Adopt an ordinance for new development standards to allow additional ADUs that meet basic setbacks and square footage requirements on properties exceeding one acre in the R-1 and R-2 zoning districts. The ordinance shall allow at least two ADUs on qualifying properties if such properties can safely accommodate two ADUs (e.g., that the properties have adequate sewer/septic and water capacity, can construct the ADUs in compliance with all building code and fire prevention requirements, and can meet parking requirements) (Policy Action 3.3-g).

Adopt the ordinance by July 2025.

Reduce minimum unit sizes and update the Zoning Code, as necessary, to accommodate alternative housing types such as housing co-operatives, Single-Room Occupancy (SROs), dormitories, tiny homes, and collective home ownership models in more areas of the city, including religious sites and publicly owned land.

Stakeholder outreach shall include discussions with for-profit and non-profit housing developers. (Policy Action 3.4-e)
Amend the Zoning Code by July 2025. Conduct
stakeholder outreach with developers and
community groups and service providers on
alternative housing at least once by January 2026,
with the goal of achieving 30 units of alternative
housing types by the end of 2029, with at least
half of those units in the neighborhoods of E Las
Palmas Dr/N Sunnywood Dr, Craig Park, Sunny
Hills, Bastanchury Rd/Fairway Isles Dr, Acacia Park,
and Byerrum Park since they are Racially
Concentrated Areas of Affluence.

Appendix H-E: Housing Element H-E-177
City of Fullerton
Housing Element
Identified Fair Housing
Issue Contributing Factors Meaningful Actions Metrics and Timeline Encourage the development of both smaller rental and owner units (studio and one-bedroom) and larger rental units (3 to 4- bedroom units) in residential and mixed-use development. In consultation with developers, identify and provide incentives and reduction of constraints to encourage the construction of these housing types and develop a work plan to implement any proposed changes to development standards, City programs, and so forth. (Policy Action

3.4-f)
Develop incentives and mitigations to constraints
by July 2025. Starting in 2025, hold an annual
workshop with developers and provide education
about technical assistance and incentives for
larger and smaller rental units, with a goal of
supporting the development of 50 large (3-4-
bedroom) units and 100 studio/1-bedroom units
by December 2029. At least 50 percent of large
and small rental units should be in neighborhoods
of greater degrees of overcrowding, including
Woodcrest Park, Artesia Blvd/N Gilbert St,
Valencia Park, W Oak Ave/Lambert Dr, E Wilshire
Ave/N Raymond Ave, Rancho La Paz.

Improving place-based
strategies to encourage
Community conservation
and revitalization
• Location of
environmental health
hazards (Priority: high)
• Lack of investment in
community-based
infrastructure and
services (Priority: low)
• Lack of access to
housing mobility
(Priority: medium)
Prioritize public health, education, economic, and safety programs in lower resource areas as defined by TCAC in coordination with area public health entities. school districts, workforce development groups, and the police department. Identify addresses and compile mailing list and email addresses to focus outreach to
neighborhoods with higher concentrations of low-income and minority residents to prioritize services in these areas. (Policy Action 3.14-e)
Increase participation in the City’s first-time
homebuyer seminars and owner-occupied housing
rehabilitation grant program 5 percent annually
from lower income and minority concentration
areas through the planning period (data collection
via surveys conducted at the seminars).

Assess potential preference policy for affordable housing opportunities, land use, transportation, urban design, public facilities and services, and economic development strategies. The City will seek involvement from community organizations and advocates, business councils, and residents to further refine program scope. (Policy Action 3.14-f)
Establish a community working group that meets
annually to prioritize funding for community
investments.

Apply for funding and coordinate with the OCTA Safe Routes to School program to establish at least one partnership in the city for active transportation projects and/or safety education campaign, prioritizing school routes within and from the neighborhood of E Imperial Highway and N Harbor Boulevard. (Policy Action 3.14-h)
Establish partnership for Safe Routes to School
and apply for grant funding by the end of 2025.

Initiate at least one project or campaign by the
end of the planning period.

H-E-178 Appendix H-E: Housing Element
City of Fullerton
Housing Element
This page intentionally left blank.

Appendix H-F: Housing Element H-F-1
Appendix H-F:

Glossary of Housing Terms
Above-moderate Income Household. A household with an annual income usually greater than 120 percent of the area Median Family Income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available eligibility limits established by the U.S. Department of Housing and Urban Development (HUD) for the Section 8 housing program.

Apartment. An apartment is one (1) or more rooms in an apartment house or dwelling occupied or intended or designated for occupancy by one (1) family for sleeping or living purposes and containing one (1) kitchen.

Assisted Housing. Generally multi-family rental housing, but sometimes single-family ownership units, whose construction, financing, sales prices, or rents have been subsidized by federal, State, or local housing programs including, but not limited to federal Section 8 (new construction, substantial rehabilitation, and loan management set-asides), federal Sections 213, 236, and 202, federal Section 221(d)(3) (below-market interest rate program), federal Section 101 (rent supplement assistance), CDBG, FmHA Section 515, multi- family mortgage revenue bond programs, local redevelopment and in lieu fee programs, and units developed pursuant to local inclusionary housing and density bonus programs.

Below-market-rate (BMR). Any housing unit specifically priced to be sold or rented to low or moderate income households for an amount less than the fair market value of the unit. Both the State of California and the U.S. Department of Housing and Urban Development set standards for determining which households qualify as “low income” or “moderate income.” The financing of housing at less than prevailing interest rates.

Build-out. That level of urban development characterized by full occupancy of all developable sites in accordance with the General Plan; the maximum level of development envisioned by the General Plan.

Build-out does not assume that each parcel is developed to include all floor area or housing units possible under zoning regulations.

Community Development Block Grant (CDBG). A grant program administered by the U.S. Department of Housing and Urban Development (HUD) on a formula basis for entitlement communities and by the State Department of Housing and Community Development (HCD) for non-entitled jurisdictions. This grant allots money to cities and counties for housing rehabilitation and community development, including public facilities and economic development.

Condominium. A structure of two or more units, the interior spaces of which are individually owned; the balance of the property (both land and building) is owned in common by the owners of the individual units. (See “Townhouse.”)
Covenants, Conditions, and Restrictions (CC&Rs). A term used to describe restrictive limitations that may be placed on property and its use, and which usually are made a condition of holding title or lease.

Deed. A legal document that affects the transfer of ownership of real estate from the seller to the buyer.

H-F-2 Appendix H-F: Housing Element
City of Fullerton
Housing Element
Density Bonus. The allocation of development rights that allow a parcel to accommodate additional square footage or additional residential units beyond the maximum for which the parcel is zoned; usually in exchange for the provision or preservation of an amenity at the same site or at another location.

Density, Residential. The number of permanent residential dwelling units per acre of land. Densities specified in the General Plan may be expressed in units per gross acre or per net developable acre.

Developable Land. Land that is suitable as a location for structures and that can be developed free of hazards to, and without disruption of, or significant impact on natural resource areas.

Down Payment. Money paid by a buyer from his own funds, as opposed to that portion of the purchase price that is financed.

Duplex. A detached building under single ownership that is designed for occupancy as the residence of two families living independently of each other.

Dwelling Unit (du). A building or portion of a building containing one or more rooms, designed for or used by one family for living or sleeping purposes, and having a separate bathroom and only one kitchen or kitchenette. See Housing Unit.

Emergency Shelter. A facility that provides immediate and short-term housing and supplemental services for the homeless. Supplemental services may include food, counseling, and access to other social programs. (See “Transitional Housing.”)
Extremely-low Income Household. A household with an annual income less than 30 percent of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available eligibility limits established by the U.S. Department of Housing and Urban Development (HUD) for the Section 8 housing program.

Fair Market Rent. The rent, including utility allowances, determined by the United States Department of Housing and Urban Development for purposed of administering the Section 8 Existing Housing Program.

Family. (1) Two or more persons related by birth, marriage, or adoption [U.S. Bureau of the Census]. (2) An Individual or a group of persons living together who constitute a bona fide single-family housekeeping unit in a dwelling unit, not including a fraternity, sorority, club, or other group of persons occupying a hotel, lodging house or institution of any kind [California].

General Plan. A comprehensive, long-term plan mandated by State Planning Law for the physical development of a city or county and any land outside its boundaries which, in its judgment, bears relation to its planning. The plan shall consist of seven required elements: land use, circulation, open space, conservation, housing, safety, and noise. The plan must include a statement of development policies and a diagram or diagrams illustrating the policies.

Goal. A general, overall, and ultimate purpose, aim, or end toward which the City will direct effort.

Green Building. Green or sustainable building is the practice of creating healthier and more resource- efficient models of construction, renovation, operation, maintenance, and demolition. (US Environmental Protection Agency)
Group Quarters. Group quarters include nursing homes, orphanages, and prisons. Non-institutional group quarters include dormitories, shelters, and large boarding houses.

Appendix H-F: Housing Element H-F-3
City of Fullerton
Housing Element
Historic Preservation. The preservation of historically significant structures and neighborhoods until such time as, and in order to facilitate, restoration and rehabilitation of the building(s) to a former condition.

Historic Property. A historic property is a structure or site that has significant historic, architectural, or cultural value.

Household. All those persons—related or unrelated—who occupy a single housing unit. (See “Family.”) Housing and Community Development Department (HCD). The State agency that has principal responsibility for assessing, planning for, and assisting communities to meet the needs of low and moderate income households.

Housing Element. One of the seven state-mandated elements of a local General Plan. It assesses the existing and projected housing needs of all economic segments of the community, identifies potential sites adequate to provide the amount and kind of housing needed, and contains adopted goals, policies, and implementation programs for the preservation, improvement, and development of housing. Under State law, Housing Elements must be updated every five years.

Housing Payment. For ownership housing, this is defined as the mortgage payment, property taxes, insurance, and utilities. For rental housing this is defined as rent and utilities.

Housing Ratio. The ratio of the monthly housing payment to total gross monthly income. Also called Payment-to-Income Ratio or Front-End Ratio.

Housing Unit. The place of permanent or customary abode of a person or family. A housing unit may be a single-family dwelling, a multi-family dwelling, a condominium, a modular home, a mobile home, a cooperative, or any other residential unit considered real property under State law.

Housing and Urban Development, U.S. Department of (HUD). A cabinet-level department of the federal government that administers housing and community development programs.

Impacted Areas. Census tracts where more than 50 percent of the dwelling units house low and very-low income households.

Implementing Policies. The City’s statements of its commitments to consistent actions.

Implementation. Actions, procedures, programs, or techniques that carry out policies.

Infill Development. The development of new housing or other buildings on scattered vacant lots in a built- up area or on new building parcels created by permitted lot splits.

Jobs-Housing Balance. A ratio used to describe the adequacy of the housing supply within a defined area to meet the needs of persons working within the same area. The General Plan uses the Southern California Association of Government’s definition, which is a job total equal to 1.2 times the number of housing units within the area under consideration.

Land Use Classification. A system for classifying and designating the appropriate use of properties.

Live-Work Units. Buildings or spaces within buildings that are used jointly for commercial and residential purposes where the residential use of the space is secondary or accessory to the primary use as a place of work.

H-F-4 Appendix H-F: Housing Element
City of Fullerton
Housing Element
Low Income Household. A household with an annual income usually no greater than 51 percent-80 percent of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available eligibility limits established by the U.S. Department of Housing and Urban Development (HUD) for the Section 8 housing program.

Low Income Housing Tax Credits. Tax reductions provided by the federal and State governments for investors in housing for low income households.

Manufactured Housing. Residential structures that are constructed entirely in the factory, and which since June 15, 1976, have been regulated by the federal Manufactured Home Construction and Safety Standards Act of 1974 under the administration of the U. S. Department of Housing and Urban Development (HUD). (See “Mobile Home” and “Modular Unit.”)
Mixed-use. Properties on which various uses, such as office, commercial, institutional, and residential, are combined in a single building or on a single site in an integrated development project with significant functional interrelationships and a coherent physical design. A “single site” may include contiguous properties.

Moderate Income Household. A household with an annual income usually no greater than 81 percent-120 percent of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available eligibility limits established by the U.S. Department of Housing and Urban Development (HUD) for the Section 8 housing program.

Modular Unit. A factory-fabricated, transportable building or major component designed for use by itself or for incorporation with similar units on-site into a structure for residential, commercial, education, or industrial use. Differs from mobile homes and manufactured housing by (in addition to lacking an integral chassis or permanent hitch to allow future movement) being subject to California housing law design standards. California standards are more restrictive than federal standards in some respects (e.g., plumbing and energy conservation). Also called Factory-built Housing and regulated by State law of the title.

Monthly Housing Expense. Total principal, interest, taxes, and insurance paid by the borrower on a monthly basis. Used with gross income to determine affordability.

Multiple-Family Building. A detached building designed and used exclusively as a dwelling by three or more families occupying separate suites.

Ordinance. A law or regulation set forth and adopted by a governmental authority, usually a city or county.

Overcrowding Housing Unit. A housing unit in which the members of the household, or group. Are prevented from the enjoyment of privacy because of small room size and housing size. The U.S. Bureau of Census defines an overcrowded housing unit as one that is occupied by more than one person per room.

Parcel. A lot or tract of land.

Persons with Disabilities. Persons determined to have a physical impairment or mental disorder expected to be of long or indefinite duration. Many such impairments or disorders are of such a nature that a person’s ability to live independently can be improved by appropriate housing conditions.

Appendix H-F: Housing Element H-F-5
City of Fullerton
Housing Element
Planning Area. The area directly addressed by the General Plan. A city’s planning area typically encompasses the city limits and potentially annexable land within its sphere of influence.

Policy. A specific statement of principle or of guiding actions that implies clear commitment, but is not mandatory. A general direction that a governmental agency sets to follow, in order to meet its objectives before undertaking an action program. (See “Program.”)
Poverty Level. As used by the U.S. Census, families and unrelated individuals are classified as being above or below the poverty level based on a Poverty Index that provides a range of income cutoffs or “poverty thresholds” varying by size of family, number of children, and age of householder. The income cutoffs are updated each year to reflect the change in the Consumer Price Index.

Program. An action, activity, or strategy carried out in response to adopted policy to achieve a specific goal or objective. Policies and programs establish the “who,” “how” and “when” for carrying out the “what” and “where” of goals and objectives.

Redevelop. To demolish existing buildings; or to increase the overall floor area existing on a property; or both; irrespective of whether a change occurs in land use.

Regional. Pertaining to activities or economies at a scale greater than that of a single jurisdiction, and affecting a broad geographic area.

Regional Housing Needs Assessment (RHNA). A quantification by the Southern California Association of Government of existing and projected housing need by household income group, for all localities within a region.

Rehabilitation. The repair, preservation, and/or improvement of substandard housing.

Residential. Land designated in the General Plan and Zoning Ordinance for building of dwelling units. May be improved, vacant, or unimproved. (See “Dwelling Unit.”) Residential Care Facility. A facility that provides 24-hour care and supervision to its residents.

Residential, Multiple-Family. Usually three or more dwelling units on a single site, which may be in the same or separate buildings.

Residential, Single-Family. A single dwelling unit on a building site.

Retrofit. To add materials and/or devices to an existing building or system to improve its operation, safety, or efficiency. Buildings have been retrofitted to use solar energy and to strengthen their ability to withstand earthquakes, for example.

Rezoning. An amendment to the map to effect a change in the nature, density, or intensity of uses allowed in a zoning district and/or on a designated parcel or land area.

Second Unit. A self-contained living unit, either attached to or detached from, and in addition to, the primary residential unit on a single lot. “Granny Flat” is one type of second unit.

H-F-6 Appendix H-F: Housing Element
City of Fullerton
Housing Element
Section 8 Rental Assistance Program. A federal (HUD) rent-subsidy program that is one of the main sources of federal housing assistance for low income households. The program operates by providing “housing assistance payments” to owners, developers, and public housing agencies to make up the difference between the “Fair Market Rent” of a unit (set by HUD) and the household’s contribution toward the rent, which is calculated at 30 percent of the household’s adjusted gross monthly income (GMI). “Section 8” includes programs for new construction, existing housing, and substantial or moderate housing rehabilitation.

Senior Citizen. A person 62 years of age or older, or 55 years of age or older in a senior citizen housing development. (California Civil Code §51.3.b.1)
Shared Living. The occupancy of a dwelling unit by persons of more than one family in order to reduce housing expenses and provide social contact, mutual support, and assistance. Shared living facilities serving six or fewer persons are permitted in all residential districts by §1566.3 of the California Health and Safety Code.

Single-family Dwelling, Attached. A dwelling unit occupied or intended for occupancy by only one household that is structurally connected with at least one other such dwelling unit. (See “Townhouse.”) Single-family Dwelling, Detached. A dwelling unit occupied or intended for occupancy by only one household that is structurally independent from any other such dwelling unit or structure intended for residential or other use. (See “Family.”)
Single Room Occupancy (SRO). A single room, typically 80-250 square feet, with a sink and closet, but which may require the occupant to share a communal bathroom, shower, and kitchen.

Subsidize. To assist by payment of a sum of money or by the granting to terms or favors that reduces the need for monetary expenditures. Housing subsidies may take the forms of mortgage interest deductions or tax credits from federal and/or State income taxes, sale or lease at less than market value of land to be used for the construction of housing, payments to supplement a minimum affordable rent, and the like.

Substandard Housing. Residential dwellings that, because of their physical condition, do not provide safe and sanitary housing.

Target Areas. Specifically designated sections of the community where loans and grants are made to bring about a specific outcome, such as the rehabilitation of housing affordable by very-low and low income households.

Tax Increment. Additional tax revenues that result from increases in property values within a redevelopment area. State law permits the tax increment to be earmarked for redevelopment purposes but requires at least 20 percent to be used to increase and improve the community’s supply of very-low and low income housing.

Tenure. A housing unit is “owned” if the owner or co-owner lives in the unit, even if it is “mortgaged or not fully paid for. All other occupied units are classified as “rented,” including units rented for cash rent and those occupied without payment of cash rent.

Townhouse. A townhouse is a dwelling unit located in a group of three (3) or more attached dwelling units with no dwelling unit located above or below another and with each dwelling unit having its own exterior entrance.

Appendix H-F: Housing Element H-F-7
City of Fullerton
Housing Element
Transitional Housing. Shelter provide to the homeless for an extend period, often as long as 18 months, and generally integrated with other social services and counseling programs to assist in the transition to self-sufficiency through the acquisition of a stable income and permanent housing. (See “Emergency Shelter.”)
Undevelopable. Specific areas where topographic, geologic, and/or superficial soil conditions indicate a significant danger to future occupants and a liability to the City are designated as “undevelopable” by the City.

Very-low Income Household. A household with an annual income usually no greater than 50 percent of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available eligibility limits established by the U.S. Department of Housing and Urban Development (HUD) for the Section 8 housing program.

Acronyms Used
ACS American Community Survey
BMPs: Best Management Practices
CalHFA: California Housing Finance Agency
CALTRANS: California Department of Transportation
CCRC: California Community Reinvestment Corporation
CDBG: Community Development Block Grant
CEQA: California Environmental Quality Act
CIP: Capital Improvement Program
CMP: Congestion Management Plan
DIF: Development Impact Fee
DU/ac: Dwelling units per acre
EDD: California Employment Development Department
FAR: Floor Area Ratio
FEMA: Federal Emergency Management Agency
GDP: General Development Plan
HCD: California Department of Housing and Community Development HOA: Homeowners Association
HUD: U.S. Department of Housing and Urban Development
LAFCO: Local Agency Formation Commission

H-F-8 Appendix H-F: Housing Element
City of Fullerton
Housing Element
LIHTC: Low Income Housing Tax Credit
MFI: Median Family Income
NPDES: National Pollutant Discharge Elimination System OCHA: Orange County Housing Authority
PRD: Planned Residential Development
RHNA: Regional Housing Needs Assessment
RTP: Regional Transportation Plan
SCAG: Southern California Association of Governments
SF: Summary File (U.S. Census)
SOI: Sphere of Influence
SPA: Sectional Planning Area
SPD: Specific Plan District
SRO: Single Room Occupancy
STF: Summary Tape File (U.S. Census)
TOD: Transit-Oriented Development
TDM: Transportation Demand Management
TSM: Transportation Systems Management
WCP: Water Conservation Plan

Chapter 2: Housing Revised May 5, 2015 31
Chapter 2
Housing
Fullerton will be a city which has an increasing choice of accessible, affordable and desirable housing options which enables our children, workforce families and young professionals to make their homes here, and for our seniors to remain here. -The Fullerton Vision
Introduction
In planning for the provision of housing for all present and future Fullerton residents, the City’s primary role is to provide for a variety of housing types in an atmosphere conducive to the well‐being of City residents, and particularly to provide for an adequate supply of housing ranging in cost to meet the demand of all income groups and the special needs populations.

State law requires that the Ci
ty evaluate its Housing Element periodically
to determine its effectiveness in achieving the City’s and the State’s housing agenda. The City adopted the updated and revised Housing Element in May 2015.

The Housing Element provides a detailed an alysis of the City’s demographic, economic, and housing characteristics as required by State Law. The Housing Element also evaluates the City’s progress in implementing the previous document’s policy program and actions related to housing production, preservation, conservation, and rehabilitation. The full Housing Element is provided in Appendix H.

The following goal and polic
y actions are provided to achieve the Fullerton
Vision as it pertains to Housing.

Overarching Policies
OAP1. Comply with State and Federal laws and regulations while maintaining local control in decision‐making.

OAP2. Pursue Federal, State and local funding options to support implementation of The Fullerton Plan.

OAP3. Leverage the advantages and advances of technology.

OAP4. Seek opportunities for increased efficiency and effectiveness.

Purpose
The purpose of the Housing
Element is to address housing
opportunities for current and future
residents of Fullerton.

This Element is required per
California Government Code
Section 65302.

The 2013-2021 Housing Element was
adopted under separate cover on
May 5, 2015. This Chapter contains a
summary of the adopted Housing
Element policy program. The policy
program contains “policy actions”
that encompass the City's policies
and implementation actions for
matters relating to housing.

Refer to the full Housing Element for
additional information. The full
Housing Element is included in
Appendix H.

32 G

3.1:

GOAL
Provision of Adequate Sites for Housing
Development
An important component of meeting the housing
needs of all segments of the community is
promoting and supporting the development of
adequate sites to facilitate the development of all
types, sizes, and affordability of housing. Providing
an adequate supply and diversity of housing
accommodates the changing housing
needs and
desires of residents, based on
household size and
living arrangements, incomes, and physical
accessibility. As described in Chapter 2, Fullerton's
assigned housing need for the 2021-2029 period is
13,209 units. The City's existing land use plans and
regulations do not identify sufficient sites with
appropriate zoning to accommodate the City's
assigned share of regional housing need for the
6th planning period (see Appendix H-B). The City
is committed to ensuring adequate capacity to
meet the City's RHNA, pursuant to Government
Code section 65583.2 through rezoning sites and
amendments to the Zoning Code. Rezoning of the
sites is anticipated in January 2025 and other
zoning amendments will be adopted concurrently
with the Housing Element or as described in the
actions below.
3: A suppl
meet th
Poli
Adopted by the City on May 5, 2015 - Updated September 2024 ly of safe
he needs
Ho
cy Actions
Revised May 5, 2015 - Updated September 2024
e housing
of all se
ousing

3.2:

3.3:
s
g rangin
egments
ng in cost
of the co
Review and Update the Development
Review Process
federal laws intended to facilitate residential
development. The City also takes into
consideration the needs and desires of the
community as it undertakes such policy updates.

The City also continues to improve the efficiency
of the development review process. As a response
to the state housing crisis, Senate Bill 35 (SB 35;
2017-Wiener) made changes to Housing Element
law to limit local discretion for qualified housing
projects. Amendments to Government Code
Section 81560 changed the Permit Streamlining
Act by creating a more ministerial, rather than
discretionary, two-step application process. The
City will continue to identify efficiencies for the
development process in line with Government
Code Section 81560 and further streamline the
permit process. The City will also coordinate with
developers to ensure a timely application and
development process.

Chapter
t and typ
ommunit
2: Housing
pe to
ty.

Facilitate Infill Development
The built-out nature of the City requires infill
development. Infill development facilitates
residential development in proximity to goods,
services, and transit. This increases transit
ridership, supports local businesses, and provides
opportunities for affordable housing
development. It also benefits seniors, persons
with disabilities, and less mobile residents.

The City must regularly evaluate and update its
development review and permitting policies,
standards, and practices in response to State and
Chapter 2: Hous
GOA
sing
AL 3:

Support the Development of a Variety of
Housing Types
Although the City does not build housing, the
City can ensure that there is sufficient capacity
for development through its zoning framework.

Cities also do not control local market realities
but can provide greater access to information
that developers need, remove barriers, and
increase incentives for housing development.

Providing development opportunities for a
variety of housing types promotes diversity in
housing price, style, and size, and contributes to
neighborhood stability by offering more
affordable and move-up homes and
accommodating a diverse income mix. The City
will also support housing for the "missing
middle" - households that earn too much
annual income to qualify for traditional
affordable housing, but not enough to afford
market-rate rents. The City will review
applicable plans and the City's Zoning Code to
support the development of housing types at
higher densities in lower-density
neighborhoods, utilizing such methods as light-
touch density (LTD) housing, which includes
detached single-family housing with ADU,
duplexes, triplexes, and fourplexes.

To provide connections with jobs, housing, and
transportation, the City shall continue to
encourage mixed-use development, which
could be either "vertical" (i.e., residential on
upper floors above non-residential uses) or
"horizontal" (i.e., adjacent residential and non-
residential uses in the same development area).

A sup
meet
P
pply of sa
the need
Ho
Policy Actio
afe hous
ds of all
ousing

3.5:
ons
ing rang
segment
ging in co
ts of the
Key focus areas shall include the City's primary
activity centers, including the downtown area. The
Fullerton Plan, adopted in 2012, identifies 12 focus
areas in which development character is either in
transition or desired. Within 11 of these areas,
residential development is established as an
appropriate use. The Fullerton Plan further
includes density parameters for each focus area,
establishing maximums ranging from 30 to 80
units per acre, and creates two additional land use
designations for mixed-use developments. Other
locations in addition to General Plan focus areas
may also be appropriate for vertical or horizontal
mixed-use development. The City will pursue a
community-based planning process to implement
these general plan policies on parcels, including
pursuing City-initiated general plan and zoning
amendments as required.

Comprehensive Community
Outreach Strategy
for Housing
One of the most effective tools to inform and
educate the community about the City’s housing
programs,
policies, and resources is through direct
outreach. To ensure the Fullerton community is
provided the highest level of access to
information, the City has established a
comprehensive community outreach strategy and
multi-faceted plan called the Housing Game Plan.

The one-stop shop online portal helps to inform
the community on housing fundamentals through
Speaker Series videos, interactive demographic
categories and maps, community participation
opportunities and will include links to
ost and t
commun
33 type to
nity.

3.4:

Revised May 5, 2015 - Updated September 2024
Adopted by the City on May 5, 2015 - Updated September 2024 34 G

3.6:

GOAL 3:
development opportunities, and links to
affordable housing opportunities and
resources. The City will continue to utilize this
tool and various methods of delivery including
print media, mailers, speaker's bureaus, social
media, and other methods that consider
economic and cultural considerations unique to
the City of Fullerton. The City will ensure all
outreach materials are multilingual to account
for language barriers.

Accessory Dwelling Units
Accessory dwelling units (ADUs) provide
affordable housing options for singles and
small households including the elderly, young
adults and caregivers. The City of Fullerton
prioritizes and encourages the development of
ADUs as opportunities for infill housing and in
support of various state laws encouraging their
construction (AB 68, 2019-Ting; AB 670, 2019-
Friedman; AB 881, 2019-Bloom; SB 13, 2019-
Wieckowski). ADUs are an innovative approach
to adding more housing, particularly in single-
family residential neighborhoods. ADUs can
also offer a reliable source of income for
moderate to lower income homeowners. The
City aims to reduce barriers to the development
of ADUs and will explore options
including fee
waivers and expediting the process for ADU
permitting. The City has seen an increase in
ADU production in recent years. In recent years,
multiple bills have added requirements for local
go
vernments related to ADU permitting and
requirements. The City’s ADU ordinance was
last updated in 2022 to incorporate regulations
A suppl
meet th
Poli
ly of safe
he needs
Ho
cy Actions
e housing
of all se
ousing

3.7:
s
g rangin
egments
m
ng in cost
of the co
m
for urban lot splits. The City will continue to
monitor the extent of ADU production to ensure
that ADU-related policies and procedures are
successful and that the Housing Element goals
and RHNA production can be met.

Support Production of Regulated Affordable
Housing for All Income Levels
The City is committed to maintaining, developing,
and monitoring affordable housing and will
continue to prioritize housing for very low- and
low-income households in the development of
additional housing stock. The City will continue to
support the development of housing appropriate
for extremely low-income households and seek
new funding opportunities and partnerships.

High construction and land costs and inadequacy
of public affordable housing subsidies and
burdensome regulations have created challenges
to building new affordable housing. In addition to
Zoning Code changes, the City will work with
developers to facilitate affordable housing
development and seek to provide gap financing as
a local match to State, federal, and other public
funding sources. When possible, the City will
utilize State, federal, and local funds to write down
the cost of land for the development of affordable
housing. The City will also provide greater permit
streamlining, fee reductions, and other possible
measures and incentives to support affordable
housing development.

Where feasible, the City shall support the
development of affordable housing units and
provide first right of refusal to Community
Housing Development Organizations (CHDOs)
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3.8:

Housing Rehabilitation
Deferred maintenance of existing housing plays
a primary role in the incidence of substandard
housing. To address the issues of deferred
maintenance, the City shall continue to
proactively identify areas in the City that exhibit
a prevalence of substandard conditions. Based
upon this identification, the City shall prioritize
the allocation of rehabilitation funding resources
to address those areas with the highest level of
identified need. The City shall conduct ongoing
review and identify specific
neighborhood focus
sing
AL 3:
and other affordable housing developers in
accordance with Government Code Section
54222. Additionally, the City will provide in-kind
assistance and funding for qualified CHDOs to
develop affordable housing.

Preservation of Historic Residential Resources
The City values its historic residential resources.

To ensure the continued preservation of historic
residential structures, the City shall encourage
the conservation, preservation and
enhancement of the City’s historic residential
neighborhoods while accommodating
additional residential units consistent with State
law and City policy. The City shall consult with
organizations, such as Fullerton Heritage, and
investigate the appropriateness and feasibility
of additional General Plan policies that further
encourage the preservation and enhancement
of historic residential resources in the City.

Additionally, the City shall periodically update
the City’s Historic Building Survey.

3.9:

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Affordable Housing Acquisition and Rehabilitation3.10:
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areas to establish strategies, programs, and
improvements to address deferred maintenance,
overcrowding, infrastructure deficiencies, and
other issues that affect neighborhood quality. The
City shall aggressively pursue local, State, and
federal funding to assist in the improvement of
identified neighborhoods.

The City shall assist affordable housing developers
in the acquisition of existing market-rate units for
rehabilitation and conversion to affordable units.

An energy-efficient buildings program is necessary
to keep providing resources and support to
developers engaging with sustainable design and
energy-efficient building construction methods. The
City shall continue to encourage housing developers
to maximize energy conservation through proactive
site, building and building systems design,
materials, and equipment. The City’s goal is to
provide the development community the
opportunity to exceed the provisions of Title 24 of
the California Building Code. The City shall continue
to support energy conservation through
encouraging the
use of Energy Star®- rated
appliances, other energy-saving technologies and
conservation. To enhance the efficient use of energy
resources, the City shall review the potential of
offering incentives or other strategies that
encourage energy
conservation.
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Support Climate Change Resiliency in Buildings
and Neighborhoods
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3.11:

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3.12:

GOAL 3:

Additionally, the City aims to build community
resilience to prepare for and adapt to the
impacts of climate change, including the
reduction of greenhouse gas (GHG) emissions,
by investing in infrastructure to support active
and public transportation. The City developed a
Climate Action Plan (CAP) in 2012, which
provides a framework for reducing GHG
emissions and
is included in the Fullerton Plan.

In 2015 and again in 2023, the City adopted a
simplified procedure for certain types of
residential solar systems to increase
access to
this technology. This streamline permitting
process benefits homeowners with shorter wait
times between contract
signing, installation,
inspection, and saving on their electricity bill.

The City will expand and prioritize resources for
property owners
to implement environmentally
friendly improvements and will prioritize active
and public transportation
infrastructure for
historically underfunded neighborhoods and

neighborhoods with higher percentages of
low-income households.

Continued Monitoring and Preservation of
Housing Units At-Risk of Converting to
Market Rate
The City shall monitor existing deed-restricted
units that will have expiring affordability
covenants during the planning period (see
Appendix H-C). To encourage the preservation
of these deed-restricted affordable
units, the
City shall conduct targeted outreach to owners
of these units to encourage the extension and/
or renewal of deed restrictions and/or
covenants.

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There are 101 units at risk of conversion in Amerige Villas Apartments, which are the only units at risk of having
expiring affordability covenants during the planning
period. Amerige
Villas Apartments Property Management
staff informed
the City that it is extending the existing
project-based contract with the Department of Housing
and Urban Development (HUD) beyond the expiration
date of January 2025. The City shall develop a
preservation strategy that is ready for implementation
should owners of these units do not extend affordability.

The preservation strategy shall identify non-profit
agencies that
the City can partner with to preserve the
units and available funding sources. As part of this
strategy, the City shall ensure compliance with noticing requirements and conduct tenant education.

Fair Housing Services
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The City currently contracts with the Fair Housing
Foundation, which provides community education,
individual counseling, mediation, and low-cost advocacy with the expressed goal of eliminating housing
discrimination and guaranteeing the rights of all people to freely choose the housing for which they qualify in the area they desire. The City refers all inquiries for these services to the Fair Housing Foundation and similar
agencies and maintains literature and informational
brochures at City Hall available for public distribution.

The City will continue the provision of fair housing
assistance including landlord/tenant counseling,
homebuyer assistance, and amelioration or removal of
identified impediments through a partnership with the
Fair Housing Foundation or a similar agency for these
services and facilitate fair housing outreach, including educational workshops or presentations.
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3.13:

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Affirmatively Furthering Fair Housing
AB 686 requires each city to administer its
programs and activities related to housing in a
manner that affirmatively furthers fair housing.

The City will take actions to overcome patterns of
segregation, address disparities in housing needs
and access to opportunity, and foster inclusive
communities. Appendix E, Affirmatively
Furthering Fair Housing (AFFH), summarizes the
fair housing issues and concerns in Fullerton
based on findings of the Regional Analysis of
Impediments (AI) to Fair Housing Choice for FY
2020-25 for Orange County (AI) and additional
research conducted as part of this Housing
Element update. Programs under this goal are
designed to affirmatively reduce barriers to
housing and increase equitable conditions across
neighborhoods, addressing issues such as
historic and existing racial and economic
inequities, housing mobility and access,
community investment and engagement, and
environmental health. The findings of the AFFH
analysis were used to develop meaningful
actions and metrics and milestones that promote
inclusive communities, increase housing
opportunities, and address racial/ethnic and
economic disparities in the city. The actions for
this program are separated under the headers of
each AFFH identified housing issue.

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3.16:
ging in co
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As the cost of housing increases, low-income renters
and other vulnerable populations are
disproportionately at risk of displacement.

Displacement
risk is highest in neighborhoods of
Artesia Blvd/N Gilbert, Valencia Park, Woodcrest Park,
Rancho La Paz, and California State University
Fullerton. Areas vulnerable to displacement have
higher
rates of low- and moderate-income
households and overcrowded households.

Displacement could result directly from development
(and removal of lower cost housing) or indirectly from
rising
rents, evictions, Notices to Vacate,
condominium conversions, and other activities which
result in tenants losing their homes. The Orange
County Housing Authority (OCHA) currently
administers the Section 8 Rental Assistance program
on
behalf of the City. Based on future congressional
appropriations, the OCHA will apply for
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continuing to explore new opportunities to identify
new housing resources and expand services. The City
partners with the nonprofit organization City Net to
provide street outreach and case management to
those experiencing homelessness in Fullerton. The
City also partners with the OC Health Care Agency,
which serves individuals who are homeless or on the
verge of becoming homeless. Pursuant to the
provisions of State law, the City will continue to
facilitate the establishment of emergency shelters,
low barrier navigation centers, transitional housing
and supportive housing. To ensure that development
standards and procedures continue to encourage
these uses, a Code amendment will be processed to
revise emergency shelters and transitional housing
development standards.

Tenant Protections and Support
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The 2022 Point-in-Time count identified 272
people experiencing homelessness in the city. The
City is committed to preserving existing initiatives,
while

3.14:

Homelessness Prevention and Housing 3.15:

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3.17: Housing for Persons with Special Needs
GOAL
additional funding, which will enable it to
administer additional certificates for families,
elderly, and
persons with disabilities over the
Housing Element Planning Period. The City will
continue to provide referral services and
information to the City’s residents.
3: A suppl
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The City of Fullerton is a diverse community with
many residents who have special housing needs.

Government Code Sections 65583 and 65583.2
require the housing element to address the
needs of specific groups with special housing
needs, including extremely low-income
residents, seniors, persons with disabilities, large
families, female-headed households with
children, and persons experiencing
homelessness. Persons with special needs may
require special housing facilities and services to
meet their daily housing needs. The City shall
consider the specialized needs of persons with
physical and mental disabilities as well as large
family households (including multi-generational
households), single parent households, the
elderly, and other groups requiring specialized
services or facilities when developing housing
within Fullerton. The City shall continue to
encourage private and non-profit housing
developers to incorporate specialized housing in
new construction and substantial rehabilitation
of existing housing and evaluate current needs
and investigate regulatory incentives and other
concessions to further encourage the production
of housing for special needs groups.

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3.18: Support Homeownership Opportunities
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The City recognizes that homeownership allows
households to gain housing security and build
wealth through equity and can serve to strengthen
and stabilize neighborhoods. There are several
organizations
that offer homebuyer counseling and
host homebuyer education workshops. The City
will support participation in these programs by
Fullerton
residents, prioritizing outreach to
residents
in vulnerable communities.

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City Council - Successor Agency - Housing AuthorityNovember 19, 2024

City Council - Successor Agency - Housing Authority
November 19, 2024