081826 CED Housing Opportunities Recommendations Report — City Council - Successor Agency

RECOMMENDATIONS
REPORT

ADMINISTRATIVE DRAFT
AUGUST 2026
City of Fullerton:

REAP 2.0 Technical Assistance Project

ABOUT SCAG
SCAG is the nation’s largest metropolitan planning organization (MPO), representing six counties, 191 cities and more than 19 million residents. SCAG undertakes a variety of planning and policy initiatives to encourage a more sustainable Southern California now and in the future.

VISION
Southern California’s Catalyst for a Brighter Future

MISSION
To foster innovative regional solutions that improve the lives of Southern Californians through inclusive collaboration, visionary planning, regional advocacy, information sharing, and promoting best practices.

TABLE O F CONTEN TS
REAP 2.0 TECHNICAL
ASSISTANCE PROJECT:

1. Executive Summary .............................................................................5

1.1 Purpose of the study..............................................................................6

1.2 Public Outreach ....................................................................................6

1.3 Key Findings ...........................................................................................6

2. Site Selection Summary .....................................................................11

2.1 Site Identification Process ...................................................................12

2.2 Comparative Analysis of Candidate Sites.............................................12

2.3 Relevant State Legislation ....................................................................22

2.4 Final Site Selection Rationale ...............................................................23

3. Conceptual Site Plans .........................................................................25

3.1 Financial Feasibility Evaluation ............................................................26

3.2 2200 W. Orangethorpe Ave .................................................................33

3.3 118 W. Santa Fe Avenue ......................................................................39

3.4 122 Pomona Ave ..................................................................................47

3.5 401 Harbor Ave. ...................................................................................55

3.6 125 Chapman Ave. ...............................................................................63

3.7 Financial Feasibility Takeaways. ...........................................................71

4. REAP Metrics .....................................................................................73

5. Regulatory Compliance Memorandum ...............................................75

5.1 How to Use This Memo .......................................................................82

5.2 Key Screening Factors .........................................................................82

5.3 Compliance Pathways ..........................................................................83

5.4 Opportunity Sites.................................................................................88

5.5 Key Findings and Takeaways ...............................................................90

5.6 Applying this Framework to Future Sites ............................................90

6. Implementation and Policy Recommendations ..................................93 AUGUST 2026

FULLERTON

1.1 Purpose of the study..............................................................................6

1.2 Public Engagement ...............................................................................6

1.3 Key Findings ...........................................................................................6 1 EXECUTIVE

SUMMARY
6 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
densities. Each entitlement option also includes a
CEQA clearance strategy, with more detail provided
in Section 5 of this report.

Based on these analyses, the report provides a
set of actionable recommendations to position
the city for near-term implementation. These
include prioritizing City actions on certain sites,
potential zoning and policy updates, and ongoing
communications with religious properties. Together,
these recommendations establish a clear and
practical pathway for moving from concept to
project delivery.

1.2 PUBLIC ENGAGEMENT
Public engagement for this effort included a
workshop with the property owners of religious
institutions across the City. This workshop took
place on April 30, 2026, at City Hall and was attended
by approximately twenty people. Advertising for the
workshop included direct emails to property owners,
as well as advertising on social media, the City
website, and other platforms. The City presented
an overview of SB 4 and the opportunity it offers for
religious properties and the City to get affordable
housing built. National Core, an affordable housing
developer, did a presentation highlighting their
previous affordable housing projects on religious
properties. They provided detailed information on
how the entitlement process works, minimum site
size, the property owner’s role, and the types of
agreements between the developer and property
owner. PlaceWorks then shared a conceptual site
plan and rendering for one of the church properties
to illustrate the process for identifying the right
location for housing on the site, addressing parking
for both the church and residential uses, and
considering the surrounding context. City staff
encouraged property owners to reach out if they are
interested in exploring this opportunity.

1.3 KEY FINDINGS
Based on the comprehensive site screening,
conceptual design phase, and pro forma financial
analysis, the evaluation yielded several critical
findings regarding housing feasibility in Fullerton:
• New Housing Pipeline Identified: The evaluation
identified five priority underutilized sites—

1.1 PURPOSE OF THE STUDY
This report presents the findings and
recommendations from a targeted planning effort
to expand housing development opportunities
within the City of Fullerton. This effort was funded
by SCAG through the Regional Early Action Planning
Grant Program (REAP 2.0) and was managed
by the Orange County Council of Governments
(OCCOG). This report is intended to inform both
Planning Commission and City Council on additional
housing opportunities above and beyond Housing
Element sites, and to support more formal actions
to advance the recommended strategies and site-
specific opportunities.

The City of Fullerton was selected to receive REAP

2.0 technical assistance to identify and evaluate
underutilized sites within the downtown core, City-
owned surplus properties, and religious properties
that may have land available for housing. Through
a structured evaluation process of eight properties,
five priority sites were identified based on physical
characteristics, development potential, existing
zoning, and the potential application of State
Housing Laws. None of the five selected sites were
included in the City’s current Housing Element,
therefore representing future potential sites to help
satisfy the next round of RHNA.

Conceptual development plans were prepared
for each site to illustrate potential land use
configurations, development intensity, and site
design. These concepts are supported by three-
dimensional renderings to communicate massing,
potential architectural character, and design context
within the surrounding area. Through an iterative
process, the final site concepts demonstrate
a range of financially and physically feasible
housing typologies and highlight opportunities to
increase residential capacity in key areas of the
City. An overarching objective of this work was
to find development solutions that work in the
current and near-term Orange County real estate
market, while accommodating as much affordable
housing as possible.

The recommendations for each site outline
the regulatory pathways available to support
implementation, including the use of state housing
laws to streamline entitlement and achieve higher
CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 7 ranging from downtown parcels and municipal
land to religious institutional properties—that
are not currently included in the City’s Housing
Element. These sites represent potential
additional housing capacity that the City could
evaluate for future Housing Element and RHNA-
cycle planning. They also provide a useful
indicator of what may be possible on smaller infill
lots elsewhere in the City.
• Transit Proximity is a Catalyst for Feasibility:

Sites closest to the Fullerton rail station offer
the strongest overall development potential.

Although some of these parcels include physical
or cost constraints, such as demolition of existing
parking structures, their transit adjacency may
allow projects to use state transit-oriented
housing provisions, density bonus incentives,
and parking reductions that help offset initial
capital barriers.
• Higher Density is Essential to Overcome Current
Market Headwinds: Under current market
conditions, including elevated interest rates and
high construction costs, baseline multifamily
densities around 60 dwelling units per acre
generally do not produce sufficient feasibility
on the sites studied. The analysis indicates that
densities closer to 100 units per acre or more
are generally needed to support market-resilient
development returns.
• Layering State Legislation is Critical for Viability:

In addition to local zoning updates, project
feasibility depends heavily on the strategic
application of state housing laws to streamline
entitlements, reduce parking burdens, and
achieve realistic densities. For market-rate and
mixed-income development, pairing SB 79,
once applicable in Orange County, with the
State Density Bonus Law and AB 2097 parking
reductions can help generate the project scale
needed for financial feasibility.
• SB 4 Unlocks Potential on Religious Properties:

The study found that SB 4 could provide a
streamlined pathway for 100% affordable
housing on qualifying faith-based lands.

Outreach conducted with local religious

8 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
institutions on April 30, 2026, revealed initial
interest from property owners, suggesting that
active SB 4 engagement could expand the City’s
long-term affordable housing opportunities,
provided that minimum project scale can be
achieved and traditional affordable housing
financing sources are available.
• Strategic Site Consolidation Yields Stronger
Returns (page 70): The financial modeling
indicates that coordinated entitlement strategies
can increase housing production and reduce
the need for direct municipal subsidy. A unified
approach linking a market-rate project with a
dedicated affordable housing site could generate
a stronger financial yield than developing the
parcels individually, while also increasing the
number of affordable units delivered. This
strategy would require careful phasing, legal
structuring, and financing coordination to ensure
that both components are implemented.

Financial Feasibility for Fully BMR Housing
The process to evaluate financial feasibility differs
significantly between a fully below-market-rate
(BMR) housing project and a market-rate (MR)
development. While a market-rate developer must
secure private equity by demonstrating a threshold
rate of return on investment, an affordable housing
developer typically relies upon a complex layering of
public and private capital.

A standard BMR project requires three primary
funding sources:

1. Conventional Debt: Bank financing sized to what
can be can be repaid with the project’s restricted
rental net operating income.

2. Low-Income Housing Tax Credits (LIHTC):

Federal and State tax credits competitively
awarded by the California Tax Credit Allocation
Committee (TCAC) each year.

3. Supplemental Public Funding: A package of
local, state, or federal grants and other soft-debt
sources to bridge any remaining capital gaps.

Consequently, feasibility for an affordable developer
is not measured by investor return, but by how
competitively a project scores under TCAC’s funding
criteria and its ability to secure supplemental grants.

Because these programs are highly competitive,
securing a full allocation of tax credits can easily
take two to three years of iterative applications.

Furthermore, what constitutes a competitive project
can shift annually based on state funding priorities
and the pool of competing applications.

Fiscal Impacts
While a comprehensive fiscal impact analysis of
new development is beyond the scope of this
report, Table 1.3-A identifies three key municipal
revenue sources that can be directly estimated from
this study’s conceptual models to provide helpful
fiscal context:
• Building Permit Application Fees: The City
charges fees for services covering plan checks,
inspections, and issuance of certificates of
occupancy. Across the evaluated scenarios, initial
building permit application fees are estimated to
range from $71,145 to $1,262,100.
• Development Impact Fees for Parks: The
financial feasibility models incorporate an
overall average Development Impact Fee (DIF) of
$19,945 per unit, with the park fee representing
the largest component of this total. These
revenues help fund capital improvements for
parks citywide, with projected DIF revenues
estimated between $432,720 and $1,262,100.
• General Fund Property Tax Revenue: In the
first full year of occupancy, the evaluated
development scenarios are each estimated to
generate between $20,301 and $38,955 in new,
annual property tax revenue directly for the
City’s General Fund.

These estimates represent a baseline for revenue
potential. Should the City move forward with
soliciting developer proposals for its city-owned
surplus properties, final fiscal terms and public
benefits can be negotiated during the land
disposition process. However, given the strong
financial viability of transit-oriented projects utilizing SB 79 densities and parking exemptions, private
developers are highly likely to pursue independent
infill development within a half-mile of the rail
station. Accordingly, the City may want to consider
conducting a more detailed, citywide fiscal impact
analysis of potential downtown redevelopment.

TABLE 1.3-A Executive Summary Table
118 W

SANTA FE
122 N
POMONA
125 W

CHAPMAN
401 N
HARBOR
125 CHAPMAN
/ 401 HARBOR

JOINT PROJECT
2200 W

ORANGETHROPE
Site Area (sq. ft.) 19,698 30,000 42,968 28,340 71,308 23,000 Site Area (acres) 0.45 0.69 0.99 0.65 1.64 0.53
Building Permit Fee ($) 87,554 134,105 196,596 104,868 - 71,154 Park DIF ($) 721,200 1,202,000 1,262,100 781,300 - 432,720 SB 79 DEVELOPMENT SCENARIOS
EXTREMELY LOW INCOME (7%)
Total Number of Units 57 100 99 65 157 -
Final Density (du/acre) 126.0 145.2 100.4 99.9 95.9 -
Leverage Yield (8% threshold) 9.3% 8.8% 7.8% 8.1% 8.5% - Feasibility Gap (Land Value Reduction to be Feasible) - - -11% - - - Annual General Fund Property Tax @15.76% 29,590 32,007 37,653 21,351 79,146 - VERY LOW INCOME (10%)
Total Number of Units 60 100 105 65 157 -
Final Density (du/acre) 132.7 145.2 106.4 99.9 95.9 -
Leverage Yield (8% threshold) 9.6% 8.8% 8.0% 8.2% 8.5% - Feasibility Gap (Land Value Reduction to be Feasible) - - - - - - Annual General Fund Property Tax @15.76% 30,408 31,326 38,955 21,001 79,146 - LOW INCOME (13%)
Total Number of Units 57 100 99 65 157 -
Final Density (du/acre) 126.0 145.2 100.4 99.9 95.9 -
Leverage Yield (8% threshold) 9.3% 8.6% 7.6% 7.9% 8.5% - Feasibility Gap (Land Value Reduction to be Feasible) - - -26% -6% - - Annual General Fund Property Tax @15.76% 28,473 30,250 35,629 20,301 79,146 - SB 4 SCENARIO
MIXED LOWER-INCOME (100%)
Total Number of Units - - - - - 36
Final Density (du/acre) - - - - - 68.2

2.1 Site Identification Process ...................................................................12

2.2 Comparative Analysis of Candidate Sites.............................................12

2.3 Relevant State Legislation ....................................................................22

2.4 Final Site Selection Rationale ...............................................................23 2 SITE SELECTION

SUMMARY
12 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

2.2 COMPARATIVE ANALYSIS OF

CANDIDATE SITES
Following the scoring rubric, the project team
conducted side-by-side comparative analysis of the
candidate sites to evaluate their key trade-offs. For
example, some parcels offered favorable zoning
and high development potential but carried higher
physical or financial challenges.

The summarized scorings are shown on the facing
page. A more detail breakdown and comparison of
the properties are shown on the following pages.

2.1 EVALUATION AND SELECTION

OF CANDIDATE SITES
The initial phase of this study involved a collaborative site-identification process to assemble and evaluate
potential multifamily housing opportunity sites
throughout Fullerton. Working in close coordination
with City staff, the project team utilized interactive
GIS-based software to map and inventory a broad
range of parcels for consideration. This initial search focused largely on the downtown core targeting City-
owned surplus land, Housing Incentive Overlay Zone
(HIOZ) properties, and religious institutional sites.

To ensure the screening was grounded in real-world
economics, the evaluation was further informed by
local real estate economics and developer interviews
to verify the types of housing products and price
points the local market could actively support.

Eight sites were ultimately chosen by the City for
further analysis with the intent to study some of the
more challenging City-owned infill properties not
included in the HIOZ.

To provide a data-driven basis for prioritizing
development opportunities, a detailed evaluation
rubric was established to score and screen
the initial candidate sites. This methodology
assessed each parcel across a range of physical,
regulatory, and logistical metrics, divided into two
primary categories:
• Yield Constraints: This category evaluated
factors that could limit the efficiency and
density potential of a project. Key criteria
included the site’s physical geometry, underlying
zoning context, and compatibility with
adjacent land uses.
• Development Constraints: This category
assessed potential physical and logistical
constraints that could add high cost or
complexity to a project. Key criteria included
topographic and grading challenges, the potential
capital costs of demolishing existing structures,
and the need to accommodate existing or
required parking.

Each criterion was evaluated and scored on a scale
from 1 (Challenged) to 5 (Workable), resulting in a
cumulative “Net Score” for each parcel. This scoring
system provided the City with a clear framework to
comparatively rank the sites into a Top 5 for deeper
analysis, which is covered in Section 4 of this report.

Gilbert Park
S Gilbert St
S Pine Dr
Iris Ct
W Porter Ave
W Gage Ave
W Orangethorpe Ave
W Orangethorpe Ave
APN: 071-461-30
Site 1: 2200 W ORANGETHORPE AVE
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
Parks and Open Space
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

CITY OF FULLERTON
Site Information
APN: 071-461-30
Address: 2200 W ORANGETHORPE
AVE
Parcel Area (ac.): 2.13
Parcel Area (Sq ft.): 92,683.48
I/L Ratio: 2.01
General Plan Designation: Religious
Use
Zoning Designation: R-1-7.2 One-
Family Residential (7,200 SF min. lot
size)
Current FAR: 0.08
GP FAR: Up to 0.50 FAR
Opportunity Site Identified by City:

Yes, Religious Site
Notes: Original rough proposal
submitted to me was to place units on
the west side of the church on the
vacant lot. Plan wasn’t good. Church
wanted the area in front of the
sanctuary to not be built upon so that
it was visible from the street.

E Ellis Pl
NHa
rbor
Blvd
E Chapman AveW Chapman Ave
APN: 032-212-15
Site 5: 125 W CHAPMAN AVE
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

CITY OF FULLERTON
Site Information
APN: 032-212-15
Address: 125 W CHAPMAN AVE
Parcel Area (ac.): 1.20
Parcel Area (Sq ft.): 52,418.58
I/L Ratio: 0.00
General Plan Designation: Downtown
Mixed Use
Zoning Designation: C-3 Central
Business District Commercial
Current FAR: 0.00
GP FAR: 0.90 to 2.0 FAR
Opportunity Site Identified by City:

Yes, Parking Lot
Notes: City-owned parking lot.

Request for this site would be to
replace any ground level parking in
addition to parking required for units.

Political appetite for this site would
only allow for 3 story building.

Fern Drive
Park
WFernDr
NBasqueAve
King Pl
W Jacaranda Pl Eliz
abeth
Way
CarhartAve
Johnson Pl
Carhart Cir
W Brookdale Pl
W Malvern Ave
APN: 281-151-19
Site 2: 1601 W MALVERN AVE
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
Parks and Open Space
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

CITY OF FULLERTON
Site Information
APN: 281-151-19
Address: 1601 W MALVERN AVE
Parcel Area (ac.): 3.46
Parcel Area (Sq ft.): 150,673.48
I/L Ratio: 2.25
General Plan Designation: Religious
Use
Zoning Designation: R-1-7.2 One-
Family Residential (7,200 SF min. lot
size)
Current FAR: 0.09
GP FAR: Up to 0.50 FAR
Opportunity Site Identified by City:

Yes, Religious Site
Notes: Original rough proposal
submitted was to place units on the
south side of the site, along Malvern
Avenue. Plan wasn’t good. Church
wanted the site to be fenced so that
there wouldn’t be pedestrian traffic
through the site from street to park in
rear.

W Whiting Ave
N Harbor Blvd
NHar
borBlv
d
W Chapman Ave
APN: 032-222-29
Site 6: 401 N HARBOR BLVD
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

CITY OF FULLERTON
Site Information
APN: 032-222-13
Address: 401 N HARBOR BLVD
Parcel Area (ac.): 1.46
Parcel Area (Sq ft.): 63,434.11
I/L Ratio: 0.96
General Plan Designation: Downtown
Mixed Use
Zoning Designation: C-3 Central
Business District Commercial
Current FAR: 0.69
GP FAR: 0.90 to 2.0 FAR
Opportunity Site Identified by City:

Yes, Parking Lot/Bank of America Site
Notes: Identified by City - Parking lot
and Bank of America, 401 N Harbor
Blvd.

Union
Pacific
Park
W Truslow Ave
W Santa Fe Ave
Walnut Ave
Malden Ave
W Walnut Ave E Walnut Ave
E Santa Fe Ave
S Malden Ave
W Commonwealth Ave
S Harbor Blvd
S Harbor Blvd
E Commonwealth Ave
APN: 032-243-20
Site 3: 118 W SANTA FE AVE
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
Parks and Open Space
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

CITY OF FULLERTON
Site Information
APN: 032-243-20
Address: 118 W SANTA FE AVE
Parcel Area (ac.): 0.55
Parcel Area (Sq ft.): 23,893.14
I/L Ratio: 3.27
General Plan Designation: Industrial
Zoning Designation: M-G
Manufacturing, General
Current FAR: 0.55
GP FAR: Up to 1.0 FAR
Opportunity Site Identified by City:

Yes, Vacant
Notes: Vacant land in front of city-
owned parking lot. Request for this
site would have ground floor retail
and residential units above. Political
appetite for this site would allow for 5
or 6 story buildings.

E Walnut Ave
W Santa Fe Ave
E Santa Fe Ave
S Harbor Blvd
S Harbor Blvd
APN: 033-030-14
Site 7: 120 E SANTA FE AVE
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

CITY OF FULLERTON
Site Information
APN: 033-030-14
Address: 120 E SANTA FE AVE
Parcel Area (ac.): 0.91
Parcel Area (Sq ft.): 39,485.91
I/L Ratio: 0.35
General Plan Designation: Fullerton
Transp Cntr Specific Plan
Zoning Designation: SPD Specific Plan
District
Current FAR: 0.00
GP FAR: Based on Specific Plan
Opportunity Site Identified by City:

Yes, Parking Lot
Notes: Identified by City - Old
Spaghetti Factory Parking Lot Site
E Santa Fe Ave
Pomona Ave
SPomo
naAve
E Commonwealth Ave
APN: 033-032-04
Site 4: 122 N POMONA AVE
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

CITY OF FULLERTON
Site Information
APN: 033-032-04
Address: 122 N POMONA AVE
Parcel Area (ac.): 0.59
Parcel Area (Sq ft.): 25,719.76
I/L Ratio: 3.36
General Plan Designation: Fullerton
Transp Cntr Specific Plan
Zoning Designation: SPD Specific Plan
District
Current FAR: 1.01
GP FAR: Based on Specific Plan
Opportunity Site Identified by City:

Yes, Parking Lot
Notes: Garage on Santa Fe in the
Fullerton Transportation Ctr, across
the OCTA Bus Terminal. It is an
underutilized parking garage that
could be better as a residential or
mixed use
Fullerton
Municipal GC
Rolling Hills Dr
Arroues Dr
Puente
St
APN: 293-154-37
Site 8: 799 ROLLING HILLS DR
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
Parks and Open Space
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

CITY OF FULLERTON
Site Information
APN: 293-154-37
Address: 799 ROLLING HILLS DR
Parcel Area (ac.): 2.49
Parcel Area (Sq ft.): 108,484.80
I/L Ratio: 0.00
General Plan Designation: Low-
Density Residential
Zoning Designation: R-1-20 One-
Family Residential (20,000 SF min. lot
size)
Current FAR: 0.00
GP FAR: Up to 0.35 FAR
Opportunity Site Identified by City:

Yes, Parking Lot
Notes: SOCO garage site in the Long
Range Management Plan in
Downtown. A surplus site , there are
grade challenges there and the
neighbors don't like any changes in
that area but a modest project could
potentially be feasible.

Net Score 15 Net Score 15
Net Score 13
Net Score 12
Net Score 8
Net Score 14
Net Score 13
Net Score 11
799 Rolling Hills Dr.
120 E. Santa Fe Ave.
118 W. Santa Fe Ave.401 N. Harbor Blvd.
1601 W. Malvern Ave.
125 W. Chapman Ave.
122 Pomona Ave.220 W. Orangethorpe Ave.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 13 EXHIBIT 2.2-A Locations of the evaluated sites
Gilbert Park
S Gilbert St
S Pine Dr
Iris Ct
W Porter Ave
W Gage Ave
W Orangethorpe Ave
W Orangethorpe Ave
APN: 071-461-30
Site 1: 2200 W ORANGETHORPE AVE
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
Parks and Open Space
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

YIELD CONSTRAINTS

DEVELOPMENT CONSTRAINTS

DEVELOPMENT CONSTRAINTS
Evaluation Rubric
Challenged (1) Workable (5)
3 Challenged (1) Workable (5)
5 Challenged (1) Workable (5)
5 Challenged (1) Workable (5)
2 Existing buildings and/or parking requirementsContext and adjacent zoning TopographySite geometry
Net Score
15 2200 ORANGETHORPE AVENUE
Fern Drive
Park
WFernDr
NBasqueAve
King Pl
W Jacaranda Pl Eliz
abeth
Way
CarhartAve
Johnson Pl
Carhart Cir
W Brookdale Pl
W Malvern Ave
APN: 281-151-19
Site 2: 1601 W MALVERN AVE
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
Parks and Open Space
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 15

YIELD CONSTRAINTS

DEVELOPMENT CONSTRAINTS

DEVELOPMENT CONSTRAINTS
Evaluation Rubric
Challenged (1) Workable (5)
2 Challenged (1) Workable (5)
2 Challenged (1) Workable (5)
2 Challenged (1) Workable (5)
2 Existing buildings and/or parking requirementsContext and adjacent zoning TopographySite geometry
Net Score
8 1601 W. MALVERN AVENUE
Union
Pacific
Park
W Truslow Ave
W Santa Fe Ave
Walnut Ave
Malden Ave
W Walnut Ave E Walnut Ave
E Santa Fe Ave
S Malden Ave
W Commonwealth Ave
S Harbor Blvd
S Harbor Blvd
E Commonwealth Ave
APN: 032-243-20
Site 3: 118 W SANTA FE AVE
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
Parks and Open Space
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

YIELD CONSTRAINTS

DEVELOPMENT CONSTRAINTS

DEVELOPMENT CONSTRAINTS
Evaluation Rubric
Challenged (1) Workable (5)
4 Challenged (1) Workable (5)
4 Challenged (1) Workable (5)
3 Challenged (1) Workable (5)
2 Existing buildings and/or parking requirementsContext and adjacent zoning TopographySite geometry
Net Score
13 118 SANTA FE AVENUE
E Santa Fe Ave
Pomona Ave
SPomo
naAve
E Commonwealth Ave
APN: 033-032-04
Site 4: 122 N POMONA AVE
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

YIELD CONSTRAINTS

DEVELOPMENT CONSTRAINTS

DEVELOPMENT CONSTRAINTS
Evaluation Rubric
Challenged (1) Workable (5)
4 Challenged (1) Workable (5)
5 Challenged (1) Workable (5)
5 Challenged (1) Workable (5)
1 Existing buildings and/or parking requirementsContext and adjacent zoning TopographySite geometry
Net Score
15 122 N. POMONA AVENUE
E Ellis Pl
NHa
rbor
Blvd
E Chapman AveW Chapman Ave
APN: 032-212-15
Site 5: 125 W CHAPMAN AVE
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

Yes, Parking Lot
Notes: City-owned parking lot.

Request for this site would be to
replace any ground level parking in
addition to parking required for units.

Political appetite for this site would
only allow for 3 story building.
18 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

YIELD CONSTRAINTS

DEVELOPMENT CONSTRAINTS

DEVELOPMENT CONSTRAINTS
Evaluation Rubric
Challenged (1) Workable (5)
3 Challenged (1) Workable (5)
3 Challenged (1) Workable (5)
5 Challenged (1) Workable (5)
2 Existing buildings and/or parking requirementsContext and adjacent zoning TopographySite geometry
Net Score
13 125 W. CHAPMAN AVENUE
W Whiting Ave
N Harbor Blvd
NHar
borBlv
d
W Chapman Ave
APN: 032-222-29
Site 6: 401 N HARBOR BLVD
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

Yes, Parking Lot/Bank of America Site
Notes: Identified by City - Parking lot
and Bank of America, 401 N Harbor
Blvd.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 19

YIELD CONSTRAINTS

DEVELOPMENT CONSTRAINTS

DEVELOPMENT CONSTRAINTS
Evaluation Rubric
Challenged (1) Workable (5)
2 Challenged (1) Workable (5)
5 Challenged (1) Workable (5)
5 Challenged (1) Workable (5)
2 Existing buildings and/or parking requirementsContext and adjacent zoning TopographySite geometry
Net Score
14 401 N. HARBOR BOULEVARD
E Walnut Ave
W Santa Fe Ave
E Santa Fe Ave
S Harbor Blvd
S Harbor Blvd
APN: 033-030-14
Site 7: 120 E SANTA FE AVE
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

Yes, Parking Lot
Notes: Identified by City - Old
Spaghetti Factory Parking Lot Site
20 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

YIELD CONSTRAINTS

DEVELOPMENT CONSTRAINTS

DEVELOPMENT CONSTRAINTS
Evaluation Rubric
Challenged (1) Workable (5)
2 Challenged (1) Workable (5)
3 Challenged (1) Workable (5)
5 Challenged (1) Workable (5)
1 Existing buildings and/or parking requirementsContext and adjacent zoning TopographySite geometry
Net Score
11 120 E. SANTA FE AVENUE
Fullerton
Municipal GC
Rolling Hills Dr
Arroues Dr
Puente
St
APN: 293-154-37
Site 8: 799 ROLLING HILLS DR
Source: City of Fullerton, 2026; PlaceWorks, 2026
Legend
HIOZ Sites
Parks and Open Space
0 250125
Scale (Feet)

HOUSING INCENTIVE OVERLAY ZONE - OPPORTUNITY SITES

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 21

YIELD CONSTRAINTS

DEVELOPMENT CONSTRAINTS

DEVELOPMENT CONSTRAINTS
Evaluation Rubric
Challenged (1) Workable (5)
2 Challenged (1) Workable (5)
2 Challenged (1) Workable (5)
3 Challenged (1) Workable (5)
5 Existing buildings and/or parking requirementsContext and adjacent zoning TopographySite geometry
Net Score
12 799 ROLLING HILLS DRIVE
22 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

2.3 RELEVANT STATE

LEGISLATION
The California State Legislature continues to adopt
new legislation or refine existing legislation to
remove local barriers to housing development.

For purposes of this study, the application of the
following laws, where relevant, was modeled as part
of the site concepts and financial feasibility analysis.

Senate Bill (SB) 79, the “Abundant and Affordable
Homes Near Transit Act”. This law goes into
effect on July 1, 2026 and is intended to accelerate
transit-oriented housing production by making
qualifying housing projects an allowed use on sites
zoned for residential, mixed-use, or commercial
development, along with additional development
incentives. SB 79 requires housing development to
dedicate a percentage of their units to affordable.

Developers can choose one of three affordability
levels: 7% Extremely Low, 10% Very Low, or 13% Low
income. SB 79 requires each metropolitan planning
organization to develop and maintain an official
SB 79 “Stops, Zones, and Tiers Map” for its region.

This map identifies qualifying transit stops and
corresponding TOD zones that permit taller heights
and higher densities regardless of local zoning.

Although Orange County is currently not designated
as an urban transit county and therefore subject to
the provisions of SB 79, once the OC Streetcar opens,
the County will meet the threshold and qualify as an
urban transit county. The OC Streetcar is currently
scheduled to open in 2026.

Of the five sites studied, four were evaluated under
the SB 79 provisions associated with Tier 2 transit.

These provisions allow between a maximum of
55-65 feet in height and 80-100 dwelling units per
acre, depending on the distance to the station. An
additional height of 20 feet also applies to the 122
Pomona Avenue site because it qualifies as adjacent
to a Tier 2 facility.

Assembly Bill (AB) 2097. This law went into effect
in 2022 and prohibits public agencies from imposing
a minimum automobile parking requirement for
most projects located within a half-mile radius
of a major transit stop. This includes residential,
commercial, and industrial projects but excludes
hotels, motels, bed-and-breakfast inns, and other
transient lodging. Local agencies may impose
minimum parking requirements in limited instances,
based on findings detailed in the legislation. Major
transit stops include existing rail or bus rapid transit, the intersection of two or more major bus routes
with a frequency of service interval of 15 minutes
or less during morning or afternoon peak commute
periods. AB 2097 does not prohibit a developer from
voluntarily providing parking to meet the needs of
the project’s future users.

Of the five sites studied, four were evaluated using
the parking provisions of AB 2097 to improve the
financial feasibility of a project.

Senate Bill (SB 4), the “Affordable Housing on Faith
Lands Act”. Signed into law in 2023, this legislation
allows faith-based institutions and non-profit
colleges to build affordable, multi-family homes
on their own land by streamlining the permitting
process and overriding local zoning restrictions. The
legislation requires that 100% of the units, exclusive
of manager units, in a housing development project
must be affordable to lower-income households. Up
to 20% of the units may be for moderate-income
households. Residential is allowed by right, and
a local government may apply objective planning
standards. Parking requirements are limited to one
space per unit, unless a state law or local ordinance
provides for a lower standard of parking. Proposed
projects are also eligible for a density bonus,
incentives, concessions, or waivers. Construction
workers on SB 4 projects with over 10 homes must
be paid prevailing wages.

Of the five sites studied, one site is a church property with available land for potential housing. The future
application of SB 4 to other religious institutions
within the City was promoted through a public
workshop, as further described on page 6.

California’s Density Bonus Law (Government Code
Sections 65915-65918). Requires local municipalities
to grant developers significant increases in
residential density, reduced parking requirements,
and other development concessions in exchange
for affordable housing. The density increase is
based on a sliding scale ranging on the amount and
level of affordable units. Projects within a half-mile of a major transit stop can qualify for unlimited
density. Additional concessions or incentives, such
as reductions in development standards, are also
allowed based on the level of affordability. The state legislature continually updates the law to further
incentivize affordable and transit-oriented housing.

Of the five sites studied, four sites were evaluated
assuming the use of density bonus law in conjunction
with SB 79 to improve financial feasibility.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 23

2.4 FINAL SITE SELECTION

RATIONALE
Following the comparative analysis in Section 2.2,
which scored and ranked candidate sites based
on physical yield and development constraints,
the consultant team and City staff conducted a
collaborative review to finalize the five sites for
conceptual study. While the initial scoring identified
some physical and financial hurdles for several
transit-adjacent parcels—such as demolition and
site-preparation costs, the final selection rationale
shifted strategically when factoring in emergent and
existing state legislative frameworks intended to
accelerate housing production.

Specifically, the anticipated implementation
of Senate Bill 79 factored strongly in the final
selections. Although some of the selected sites
scored lower on physical “Development Constraints”
due to upfront capital costs, their proximity to the
Fullerton rail station makes them highly eligible for
the transit-oriented density bonuses offered under
SB 79. When layered with the State Density Bonus
Law and the parking exemptions of Assembly Bill
2097, the regulatory incentives of SB 79 generate
the scale and efficiencies needed for developers to
financially absorb those initial physical site barriers.

Similarly, the strategic opportunity presented by
Senate Bill 4 favored the inclusion of a religious
institutional property. This allowed the team
to evaluate and demonstrate the viability of a
100 percent affordable housing project using
streamlined, by-right permitting to bypass local
zoning constraints.

Ultimately, the final five sites were selected not
merely on comparative analysis scores, but on each
site’s strategic ability to maximize legislative tools to deliver financially feasible housing for the City.

3.1 Financial Feasibility Evaluation ............................................................26

3.2 2200 W. Orangethorpe Ave .................................................................33

3.3 118 W. Santa Fe Avenue ......................................................................39

3.4 122 Pomona Ave ..................................................................................47

3.5 401 Harbor Ave. ...................................................................................55

3.6 125 Chapman Ave. ...............................................................................63

3.7 Financial Feasibility Takeaways. ...........................................................71

CONCEPTUAL SITE
PLANS
3 26 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

3.1 FINANCIAL FEASIBILITY

EVALUATION
Understanding the real potential to expand housing
development opportunities in Fullerton requires an
evaluation of the development’s financial feasibility.

Simply put, a financial feasibility analysis determines whether a developer can afford to purchase
the land and construct the buildings based on
expected rents or sale values. Conceptual plans and
supportive zoning standards do little to accelerate
housing production if it is not financially feasible
for developers.

Basics of Financing for Development
While much of this project focuses on development
aspects important to the City and the community—
such as the scale and appearance of buildings or
the fiscal impacts on the City’s general fund—
the financial feasibility evaluation examines
each site from the developer’s perspective. In
a typical development process, the developer
obtains a construction loan to pay for the costs of
development. If the new housing or non-residential
buildings are going to be sold and owner-occupied,
the proceeds paid by purchasers as individual units
close escrow are used to pay off the construction
loan. If the new housing or non-residential buildings
are to be offered for rent, the developer takes out
a permanent loan at the end of construction and
stabilization, uses it to pay off the construction loan, and then uses tenant rent payments to repay the
permanent loan over time.

As with a home mortgage, though, banks do
not lend the full amount for a construction loan.

The developer is required to contribute money
to the project to cover the gap. The money the
developer puts into the project is referred to as the
equity investment. Currently, due to tighter credit
market conditions, a typical construction loan may
cover approximately 60 to 65 percent of the total
development cost (a 60–65 percent Loan-to-Cost, or
LTC, ratio), with the developer’s equity investment
funding the remaining 35 to 40 percent. In most
cases, developers cannot obtain construction
financing until the project has received the necessary
planning and development approvals (entitlements).

Consequently, the developer’s pre-development
equity investment typically covers the full cost of
securing those entitlements.

For developments of the size and scale considered
for the sites in this project, the developer typically
does not provide all the equity investment. Rather,
the developer obtains a majority of the equity
investment from out-side investors, such as
institutional private equity funds, family offices,
and high-net-worth individuals. Such investors use
the expected rate of return (described below) to
weigh whether to invest in a development project in
downtown Fullerton versus development projects in
other cities and states. Part of a developer’s job is to at-tract that investment to Fullerton rather than to
competing markets.

Key Parameters for Evaluating
Financial Feasibility
A financial feasibility analysis lays out the various
costs of development and the expected project
income after development in a table or a series of
tables. The tables are collectively referred to as a pro forma, and the overall financial feasibility analysis
is called a pro forma analysis. The detailed pro
formas for this project are provided in the Appendix
to this report.

Although there are many assumptions and
considerations embedded in any pro forma, there
are a few key variables that serve as the primary
drivers of feasibility.

Return on Investment
The most important parameter in a financial
feasibility analysis is the return on investment.

The entire purpose of a pro forma is to determine
whether the projected revenue can support the
expected return. Because a developer must make a
substantial equity investment in the development
project, the return is measured directly against that
cash equity. There are two primary ways the real
estate industry measures this return, depending
on whether the project is designed to be for-
sale or for-rent.

For-Sale Return: Internal Rate of Return
The internal rate of return (IRR) measures the
development project’s monthly inflow and outflow
of cash from the date money begins to be spent
on entitlement until the final units are sold and all
payments are completed. Technically speaking, the
IRR is the discount rate at which the net present
value of all cash flows equals zero. In practical terms, the IRR accounts for the time value of money by
measuring not just how much profit is made, but
how fast that profit is returned to investors.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 27 The standard industry threshold for a for-sale
residential project to be considered financially
feasible is a 15 to 18 percent leveraged IRR. For a
developer to attract outside equity investment, they
must demonstrate to potential investors that the
project can meet or exceed this target.

For-Rent Return: Leveraged
Cash-on-Cash Yield
For a rental development project, the leveraged
cash-on-cash yield (or simply “the yield”) measures
the project’s cash flow in the first full 12 months
of operations and occupancy as a percentage of
the equity investment. The cash flow is estimated
after allowing for annual costs for operations and
maintenance, vacancies, and debt service on the
permanent loan. Unlike IRR, the yield provides
a more intuitive measure of direct prof-it. The
developer will also realize additional profit when the
project is eventually sold, but that is not factored
into this initial yield.

The threshold for a for-rent project to be considered
financially feasible is a leveraged cash-on-cash yield
of 8 percent or higher. Typically, a for-rent project
will be held by the original developer for about five
years and then sold, as certain tax depreciation
benefits tend to become less valuable after five
years. Because of this five-year holding period,
for-rent projects tend to attract a different set of
investors than do build-to-sell projects.

Residual Land Value
Another use for a development pro forma is to
determine how much developers can afford to pay
to purchase a site after accounting for expected
costs of development and project sales value or
income and given the threshold rate of return. This
is often referred to as the residual land value, which
is the value of the underlying land give how much
development the current land use standards and
regulations allow.

The City’s Housing Element identifies land prices in
the range of $60 to $110 per square foot. Based on a
review of publicly available data the analysis assumes
that the cost of land in the downtown area would be
$85 per square foot, which is within the range from
the Housing Element. The initial financial feasibility
analysis uses this land value to determine the rate of
return, and for development scenarios that are not
feasible, it provides an estimate in the land price that would make a scenario financial feasible.

Permanent Financing
Similar to the construction loan, banks providing
permanent financing do not finance to the full value
of the new development. Instead, the maximum
size of the permanent loan is strictly limited by what
can be repaid using a portion of the property’s Net
Operating Income (NOI).

Lenders measure this risk using the Debt Service
Coverage Ratio (DSCR), which divides the property’s
NOI by its annual mortgage payments. In this
analysis, a DSCR of 1.43 is applied, meaning that the
mortgage payment is limited to approximately 70
percent of the project’s stabilized income.

In some cases, expected market-rate rents are not
sufficient to support a permanent loan large enough
to pay off the outstanding construction loan. When
this cash gap cannot be bridged, the development
scenario is flagged as unfeasible, and no return on
investment is calculated.

A Conservative, Stress-Tested Methodology
Real estate financial feasibility can be measured
through several metrics. While some long-range
models rely on un-leveraged Yield-on-Cost
(YOC) to evaluate a project’s intrinsic physical
value independent of interest rates, this report
intentionally evaluates capacity sites using Leveraged
Cash-on-Cash (CoC) yield.

This methodological choice directly reflects the
challenging realities of today’s capital markets. The
macroeconomic consensus is that the era of near-
zero interest rates has permanently ended. In this
“new normal,” developers do not have the luxury
of ignoring borrowing costs. To successfully secure
capital and break ground, they must demonstrate
strong, immediate cash returns to investors who
now have high-yield, low-risk alternatives.

This report evaluates feasibility based on the strict
metrics developers actually face today, and includes
a higher 8% Year 1 CoC target and a more restrictive
lending parameter like a 1.43 DSCR as part of the
modeling. It ensures the City is recommending
density increases that will actively unlock housing
production in the real world, rather than relying
on an idealized future where borrowing costs
eventually decline.
28 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
Affordable Housing and
Density Bonuses
Income Tiers for Affordable Housing
Affordable housing is a term applied to housing units
that are restricted to being occupied by households
with lower incomes. The specific income levels are
defined as a percentage of the area median income
(AMI), which is calculated each year at the county
level. Currently, the AMI for a four-person household
in Orange County is $136,600, and Table 3.1-A
provides the affordable housing income tiers that are
relevant to this project.

The income limits vary based on the number of
people in the household. Regardless of the income
range, the rent paid by each household and the
average utility costs must not exceed 30 percent of
their household income. The affordable rent does
not vary by the type of unit or size; it is based solely on the income of the household and the number of
people in the household.

Fully Below Market Rate Housing
One common way that affordable housing is
developed is when an affordable housing developer
constructs a project in which all of the units
are offered at below-market rates (BMR units)
and restricted to occupancy by lower-income
households. Affordable developers most often
obtain federal Low-Income Housing Tax Credits
(LIHTC), which are distributed by the state, and
pull in other sources of grants to make up for
the difference between the affordable rents and
the costs of development. What is feasible for
an affordable developer is dependent upon the
amount of outside funding and the competition
for that funding, rather than the standard return-
on-investment metrics used by market-rate real
estate investors.

For this report, one site was studied as a fully
below-market-rate housing project: the 2200 W.

Orangethorpe Avenue site. While this site has not
been run through a traditional market-rate return
model, its scale, parcel size and current use are
well-aligned with the criteria required to secure
affordable housing funding.

INCOME CATEGORY GENERAL INCOME RANGE UPPER INCOME LIMIT , ORANGE COUNTY , 4-PERSON HOUSEHOLD
Extremely low-income (ELI) households Less than 30% of AMI $50,750 Very low-income (VLI) households 30% to 50% $84,600
Low-income (LI) households 50% to 80% of AMI $135,350
Moderate-income (MI) households 80% to 120% of AMI $163,900 TABLE 3.1-A Affordable Housing Income Tiers
VERY LOW INCOME (VLI) LOW INCOME (LI) MODERATE INCOME (MI)*

PERCENTAGE

OF UNITS

AFFORDABLE

DENSITY
BONUS

PERCENTAGE

OF UNITS

AFFORDABLE

DENSITY
BONUS

PERCENTAGE

OF UNITS

AFFORDABLE

DENSITY
BONUS
Minimum Required 5% 20% 10% 20% 10% 5%
Maximum Density
Required 15% to 99% 50% 24% to 99% 50% 44% to 99% 50%
Fully MBR Bonus 100% 80% 100% 80% 100% 80%
TABLE 3.1-B Basic Density Bonuses, California Density Bonus Law * Moderate-income affordable housing only earns a density bonus if the units are offered for sale.

Source: California Government Code, sections 65915 (f) (1), (2), and (4).

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 29 Density Bonus Housing
California law allows residential development
projects that provide some housing units restricted
to occupancy by income-qualified households to
exceed the local zoning code’s and general plan’s
maximum densities (California Government Code,
sections 65915 – 65918). The intention is that, by
allowing developers to construct more units than
otherwise allowed, developers will be able to lease
or sell some of the units at a reduced cost. This is
known as the California Density Bonus Law, and it
was first adopted in 1979.

The increased density allowed by the Density
Bonus Law varies by the percentage of the units
and the income tier to which the affordable units
are restricted. Density bonuses are provided for VLI
households (which would include extremely low-
income households) and LI households. Density
bonuses are also provided for MI households, but
only for units that are sold for owner occupancy,
not for rentals. The range of density bonuses are
provided in Table 3.1-B.

There are other benefits for residential projects
that provide some affordable housing units, such
as reduced parking requirements and waivers from
some development standards. These are more
important to the physical design of residential
development projects and are discussed in
conjunction with the conceptual site plans.

SB 79
The density bonuses described above are based on
the maximum density allowed under a jurisdiction’s
general plan and zoning code. SB 79, the Abundant
and Affordable Homes Near Transit Act (Government
Code Sections 65912.155 through 65912.162)
provides a minimum base density that supersedes
any maximum density in local plans and codes for
certain types of transit-oriented development.

Although the provisions of SB 79 do not yet apply
in Orange County, it is anticipated that once the
OC Streetcar begins full operations in 2026, Orange
County will have the required number of passenger
rail stations to be designated an urban transit
county. At that point, SB 79’s housing development
provisions will apply to qualifying residential
projects within one-quarter or one-half mile of the
downtown Fullerton rail station.

Generally, the highest residential density currently
allowed in Fullerton is 60 dwelling units per acre.

The State Density Bonus Law (SDBL) allows new
residential development to exceed that density if the
project provides dedicated affordable housing units.

Once SB 79 becomes applicable in Orange County,
the statutory framework will shift:
• New Base Density: Qualified sites in proximity
to the rail station will see their base densities
increase to 80 or 100 units per acre, depending
on proximity to transit for a Tier 2 station.
• With Density Bonus: Applying a maximum 50%
density bonus on top if this new base density
yields a maximum allowable density of 120 to
150 dwelling units per acre.
• Affordability Qualifications: To qualify for these
SB 79 density provisions, residential projects
must dedicate at least 7% of units for extremely
low-income, 10% for very low-income, or 13% for
low-income households.

Development Scenarios
This report evaluates the financial feasibility
of several development scenarios for each site
(excluding the 2200 W. Orangethorpe Ave site, which
was considered as a fully BMR development under
SB 4). The development scenarios are:

SB 79: ELI (7%)
• Base density of 80 or 100 units per acre
• 7 percent of the units would be restricted to
extremely low-income households
• Density bonus of 25% (per density bonus law)
• Ultimate density up to 100 or 125 units per acre
SB 79: VLI (10%)
• Base density of 80 or 100 units per acre
• 10 percent of the units would be restricted to
very low-income households
• Density bonus of 33% (per density bonus law)
• Ultimate density up to 106 or 133 units per acre
30 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
SB 79: LI (13%)
• Base density of 80 or 100 units per acre
• 13 percent of the units would be restricted to
low-income households
• Density bonus of 25% (per density bonus law)
• Ultimate density up to 100 or 125 units per acre
Density Bonus Law Only: VLI (20%)
• Base density of 60 units per acre
• 20 percent of the units would be restricted to
very low-income households
• Density bonus of 50%
• Ultimate density up to 90 units per acre
Density Bonus Law Only: LI (20%)
• Base density of 60 units per acre
• 20 percent of the units would be restricted to
low-income households
• Density bonus of 35%
• Ultimate density up to 81 units per acre
For the SB 79 scenarios, the percentage of affordable
housing units is based on the minimum requirements
in the law. The base density of 80 or 100 units per
acre is determined by each of the four evaluated
sites’ proximity to the rail station. The specific base density for each location is detailed alongside the
conceptual site plans in Section 4 of this report.

For the State Density Bonus Law scenarios, the
base density is determined by the existing zoning
for three of the evaluated sites. For the purpose of
evaluating financial feasibility, the analysis assumes
that the general plan designation and zoning for the
118 W. Santa Fe Avenue site would be changed to
allow a base development density of 60 units per
acre. The 20 percent affordability requirement in the
scenarios reflects the general inclusionary housing
requirements outlined in the City’s Housing Element,
as well as the standard requirements applied
to Housing Incentive Overlay Zone (HIOZ) sites
elsewhere in Fullerton.

Financial Feasibility General Observations
Interest Rates
Currently, interest rates are elevated as the Federal
Reserve keeps borrowing costs high to combat
inflation. The general consensus among economists
at the time this report was prepared is that rates will remain restrictive over the next two years and could
increase slightly in 2026.

These elevated interest rates limit development
because construction relies on borrowed money. For
ownership housing, high rates reduce what buyers
can afford, lowering the prices that developers can
charge. For rental housing, the interest accrued
during construction is ultimately rolled into the
permanent loan; thus, high interest rates hit twice
and raise ongoing operating costs.

For each site, one or more development scenarios
would become feasible if interest rates were
one percentage point lower. The findings of the
financial feasibility evaluation must be understood
in this context: projects that do not pencil out
today could become viable in a few years as rates
decline, assuming construction costs and market
rents remain stable.

Density Bonus Projects Challenging
In the financial analyses conducted for this project,
none of the Density Bonus Law scenarios proved
feasible. In part, this results from high interest rates.

However, the bigger challenge is that it is difficult for a developer to subsidize a twenty percent affordable
housing requirement using only the standard
density bonus to offset the lower rents. Because
the discount required on those affordable units is
so steep, the extra market-rate units allowed by the
bonus do not generate enough revenue to cover
the financial gap.

In fact, the analysis suggests that even if interest
rates were to decline, a 20% affordability
requirement would still be very difficult to make
work financially. Because standard density bonus
projects face these steep economic hurdles, utilizing
statutory overrides like SB 79 near the transit station represents a much more viable path forward.

By offering a significantly higher base density
alongside lower, more manageable affordability
requirements, SB 79 represents the path of
least resistance to successfully expand housing
opportunities in Fullerton.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 31 Page intentionally left blank
CASE
STUDY
2200 W.

ORANGETHORPE
AVENUE

CASE
STUDY
2200 W.

ORANGETHORPE
AVENUE
2200

ORANGETHORPE
AVENUE
34 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

3.2 2200 W. ORANGETHORPE AVE

LOCATION AND CONTEXT
This site is occupied by a church and comprises just
over two acres. The land is currently organized with
the church building occupying roughly half of the
property along the Orangethorpe Avenue frontage,
while the remaining half is maintained as a large
lawn. Church parking is provided in a surface lot
located toward the rear of the property, adjacent
to Gilbert Park. The site is bordered by the Gilbert
Community Center to the east, a low-scale retail
strip center to the west, and single- and multi-family
residential uses in the surrounding area.

TABLE

CATEGORY YIELD NOTES
Site Area 0.52 ac development area 2.13-acre site may or may not require a lot split
Residential 36 units Affordable mix to be determined
by developer
Building Height up to 50 feet
(includes top of elevator core)
Setbacks
Front – N/A (building is at back of lot)
Side – 5 feet
Rear – 5 feet
Parking 36 spaces
TABLE 3.2-A Site 1 Development Yield

SITE CONCEPT
The development concept for the site utilizes the
existing parking lot at the rear of the property to
accommodate a new SB 4-qualified residential
building on approximately half an acre. There are
approximately 60 existing church parking spaces
which would be relocated on a one-to-one basis to a
new surface lot in the area currently occupied by the
lawn immediately east of the church. This maintains
the church’s visibility along Orangethorpe Avenue
while improving direct access from the street.

As illustrated in Exhibit 3.2-B, right, the proposed
residential building would consist of three stories of
wood-frame construction over one level of at-grade
parking, providing approximately 36 affordable or
senior housing units with onsite services, outdoor
amenities, and excellent access to Gilbert Park.

Access to the building would be from the entrance
drive on the east side of the church, separate from
the access drive to the new parking lot.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 35 85’85’
290’290’
Orangethorpe Ave.

Gilbert Park
Gilbert St.
23,000 sf / 0.52 ac
Apartments
Leasing
Private Open Space
EXHIBIT 3.2-A Existing Site 1 Location
EXHIBIT 3.2-B Site 1 Massing Diagram
36 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
N0 10 50 100
EXHIBIT 3.2-C Conceptual Site Plan
EXHIBIT 3.2-D Conceptual Rendering
CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 37

DEVELOPMENT PATHWAYS AND

RECOMMENDATIONS
The property is currently zoned R-1 (One-Family
Residential), which ordinarily limits development to
low-density single-family homes. To accommodate
the proposed density of 69 du/ac and a four-story
building, the site concept relies on the development
standards established by SB 4 together with the
additional incentives available under the State
Density Bonus Law (SDBL). For qualifying projects,
SB 4 establishes a minimum allowable residential
density of 30 du/ac, superseding the underlying R-1
density limitation. The developer may then apply the
State Density Bonus Law to this baseline to obtain
additional density and height waivers necessary to
construct the proposed 36-unit project.

Because qualifying SB 4 projects are approved
through a ministerial process, they are not subject
to CEQA. As a result, no CEQA exemption or
environmental document, including a Class 32
Categorical Exemption, is required.

However, if the City were to solicit developer
interest, two key operational and design challenges
should not be overlooked:
• The Parking Strategy: Because this site is located
outside the half-mile transit radius under SB
4, the City retains the authority to require
up to one parking space per residential unit.

Developers can comfortably accommodate
these required residential spaces within the
proposed at-grade podium parking level directly
underneath the three-story building. To protect
the church’s 60-space surface parking lot from
resident overflow, the City’s RFP should strictly
enforce this one-space-per-unit requirement
and mandate a binding shared-use agreement
that restricts residents to the podium level and
preserves the surface lot exclusively for church
operations. The City should also be willing to
work with Church property to identify and right-
size the amount of parking that is required for
Church patrons.
• Fire Apparatus Access: The site concept occupies
the back portion of the property and relies on a
one-way entrance drive to access the residential
building. To comply with California Fire Code
(CFC) standards for multi-story residential
structures over 30 feet in height, this access
road must maintain a 26-foot clear width to
accommodate aerial ladder truck operations.

City staff must ensure the developer’s design
maintains this 26-foot width, as this constraint
may directly impact the physical building
footprint and site plan relationships.
118 W.

SANTA FE AVENUE

118 W.

SANTA FE AVENUE
118 W. SANTA FE
AVENUE
40 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

3.3 118 W. SANTA FE AVENUE

LOCATION AND CONTEXT
This property is a city-owned, 0.45-acre parcel
located just west of Harbor Boulevard along W.

Santa Fe Avenue in the downtown area. The land is a
vacant, linear strip directly fronting the SOCO District Downtown Fullerton Parking Structure, as shown
in Exhibit 3.3-A. The parking structure serves the
Fullerton Transit Station, which is located just east
of Harbor Boulevard. Across the street from the
property, on the north side of W. Santa Fe Avenue
is a mix of restaurants, service commercial, and
light industrial. To the west is a five-story mixed-
use development called Malden Station by Windsor
Apartments. South of the site are the train tracks.

SITE CONCEPT
The development concept comprises two six-
story, single-loaded residential buildings flanking
the front of the municipal parking structure. Units
are accessed via a corridor running parallel to the
structure, with all units oriented toward Santa Fe
Avenue. The buildings are configured to preserve
the existing vertical circulation towers and avoid
obstructing existing pedestrian access points into the
garage, as shown in Exhibits 3.3-B and 3.3-C.

Designed to maximize residential density utilizing
5-over-1 construction, the site concept includes
4,500 square feet of ground-floor retail and
restaurant space. This commercial area incorporates
an expanded, publicly accessible central plaza
intended to support outdoor dining. Ground-floor
residential units along the remainder of the frontage
are set back from the sidewalk and positioned
five feet below grade to expand private patios
and maximize daylight access while maintaining
full ADA accessibility. This configuration increases
residential density while reducing the building’s
perceived height and massing along the street edge.

All resident parking is assumed to be accommodated
within the adjacent municipal parking structure.

TABLE

CATEGORY YIELD NOTES
Site Area .45 acres (19,698 sf) -
Vacant land fronting parking structure
The project would require a lot split with
the city-owned parking structure
Residential
60 units with application of State
Housing Laws
Up to 133 du/ac
See feasibility analysis for affordable and
market-rate housing scenarios
Commercial 4,500 sf, not including outdoor patio
Building Height Up to 65 feet
(includes top of elevator core)
Setbacks
Front – 10 feet
From Driveways – 10 feet
From Parking Structure – 0 feet
Parking 0 spaces on-site
Parking for the project could be provided
in the adjacent city-owned parking
structure
TABLE 3.3-A Development Summary
CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 41 58’58’
218’218’
12,468 sf 7,230 sf
146’146’
55’55’
Santa Fe Ave.

Malden Ave.

Harbor Blvd.

EXHIBIT 3.3-A Existing Site
EXHIBIT 3.3-B Conceptual Program and Massing
Apartments
Leasing
Amenity Deck
Private Open Space
Retail / Commercial
Public Plaza
42 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

SANTA FE AVESANTA FE AVE

SOCO SOCO

PARKING STRUCTUREPARKING STRUCTURE
EXHIBIT 3.3-C Conceptual Site Plan
EXHIBIT 3.3-D Conceptual Rendering
0 10 50 100 N
CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 43

DEVELOPMENT PATHWAYS AND

RECOMMENDATIONS
Because the property is currently zoned General
Industrial (M-G), residential uses are entirely
prohibited. To transition this city-owned site to
housing, the City must first initiate and approve a
General Plan Amendment (GPA) and a concurrent
Rezone to establish residential development
standards. Once this legislative change is initiated,
several regulatory pathways are available to a
developer. While the CEQA implications of each
pathway are analyzed in Section 5, as the City
prepares to move this site toward development,
three key operational considerations remain:
• OCTA Parking Management & Lease
Negotiations: Under AB 2097, the City cannot
enforce residential parking minimums due to
the site’s adjacency to the transit station. While
the conceptual plan assumes residents will use
the existing parking structure—a key driver
of the site’s financial viability—the City must
navigate the OCTA Parking Management Plan
that governs a portion of the facility. The Plan
identifies transit-user parking as the structure’s
primary purpose, while also recognizing support
for mixed-use transit-oriented development
and reasonable joint use when appropriate
and validated by a parking demand analysis.

Accordingly, the City or selected developer may
need to coordinate with OCTA to determine
whether a dedicated block of spaces, shared-use
arrangement, or other parking access agreement
is feasible. The terms, costs, availability, and
duration of any such arrangement would be
material to developers as they model long-term
operating expenses and project feasibility.
• Mechanized Lower Garage Ventilation
Requirement: Physically flanking the front of
the existing open-air parking structure with two
six-story residential buildings will obstruct its
natural, passive cross-ventilation. To comply with
building and safety codes, the developer may
be required to design and install a mechanical
ventilation system for the lower levels of the
parking garage. This may represent a substantial
capital cost that should be highlighted in an RFP
so that developers’ expectations and garage
operations are fully aligned.
• Active Retail Programming & Frontage
Expectations: To deliver the active, programmed
streetscape expected by the City, the upcoming
RFP should require developers to detail
programming the proposed 4,500 square
feet of ground-floor commercial space. The
conceptual design directly supports this goal by
incorporating an expanded, publicly accessible

PATHWAYS TO

ENTITLEMENT

APPLICATION TO DEVELOPMENT

CONCEPT NOTES ON ENTITLEMENT
Zone Change
and General Plan
Amendment
Requires a zone change to allow mixed-use.

Zone change to C-3 or inclusion in FTC SP
with a designation of MU-B. Limit of 60 du/
ac or 27 units. Can use density bonus to
increase units
Discretionary action by Council.

High degree of uncertainty.

Housing Incentive
Overlay Zone
(HIOZ)
Currently not in the HIOZ. Option for City
to include it. Same 60 du/ac limit applies.

Need to use density bonus to increase unit
count/feasibility
Project must meet affordable housing requirements
per the HIOZ, or 20%. This achieves up to 41 units,
with density bonus.

SB 79*
Not eligible, given existing zoning. If City
rezoned, the site is within ¼ mile from Tier
2 transit; allows 65’ max. height, 100 du/ac
and 3.0 FAR
Would need to apply for density bonus as part of SB
79 application to reach the potential of 133 du/ac
with affordable housing.

AB 2097
Site qualifies for no minimum parking
requirements, and no parking is provided
within the site concept
If parking is provided in the adjacent structure, a
parking agreement with the City for the use of the
parking structure will be needed.

TABLE 3.3-B Development Pathways
*SB 79 does not currently apply to Orange County. County is expected to qualify once the OC Streetcar opens later in 2026. 44 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
central plaza optimized for outdoor dining and
community gathering. Developer proposals
should be evaluated based on a clear leasing
strategy and a demonstrated track record of
securing high-quality, transit-supportive tenants
(such as cafes, specialty markets, or local
eateries) to ensure a vibrant, pedestrian-oriented
street frontage.

Financial Feasibility Summary
A unique attribute of this conceptual development
is that parking could be allocated within the existing
SOCO parking structure, eliminating the need
for a developer to construct costly new parking
facilities. Additionally, a developer would only need
to purchase sufficient land to accommodate the
proposed residential and commercial building space.

Removing these substantial capital cost items from
the project budget makes this site significantly more
financially resilient, from a developer’s perspective,
than the other sites in this report.

Development Scenarios
To evaluate the financial feasibility of the conceptual site plan, this analysis looks at six development
scenarios, including a fully market-rate scenario for
baseline context. Because the current industrial
zoning does not permit residential uses, the site
requires a General Plan Amendment (GPA) and
Rezone to establish a baseline residential density
of 60 dwelling units per acre (du/ac). Once this
residential framework is established, the site
becomes eligible to leverage transit-oriented state
legislation. Specifically, because the site is less than a quarter-mile from the rail station, the 60 du/ac
baseline would be superseded by an SB 79 base
density of 100 du/ac once the law becomes active
in Orange County. The resulting densities and unit
counts for each of the six scenarios are detailed in
Table 3.3-C on the next page.

The financial feasibility for each development
scenario, measured by the leveraged cash-on-
cash yield, is detailed in Table 3.3-D. Under these
parameters, the three SB 79 development scenarios
are financially feasible, each generating a yield
exceeding 8 percent. Among these, the Very Low
Income (VLI 10%) scenario generates the highest
overall yield, making it the most financially resilient option for a developer to pursue on this site.

In contrast, the Density Bonus Law scenarios (60 du/
ac) are not financially feasible under current market
conditions. While the VLI (20%) and fully market-rate
scenarios approach the feasibility threshold, they
ultimately fall short.

This outcome highlights a key policy consideration
for the City. Even when a project completely avoids
the capital cost of constructing structured parking,
a base density of 60 du/ac is mathematically
insufficient to absorb the cost of providing deeper
(20 percent) affordable units under the standard
Density Bonus Law. Consequently, achieving the
higher density levels evaluated under the transit-
oriented SB 79 scenarios is the primary mechanism
available to the City to unlock the site’s capacity
and make the integration of affordable housing
financially viable.

Conclusion
Because the SB 79 development scenarios
comfortably exceed the target threshold yield of 8.0
percent, the City possesses negotiating leverage to
secure additional public and financial benefits during
the disposition process.

These negotiated benefits could include:
• Lease or Use Payments: Charging the developer
for long-term use of the adjacent municipal
parking structure, generating a new revenue
stream for the City’s general fund.
• Land Premium: Securing a higher acquisition
price for the site.
• Additional Community Benefits: Requiring on-
site public amenities, enhanced streetscapes, or
deeper affordability targets.

Furthermore, the strong yield margins in these
higher-density scenarios provide the project with a
built-in cushion to absorb ongoing capital-market
and interest-rate volatility. Because this site avoids
the immense capital cost of constructing structured
parking, it represents the most financially resilient
and immediately viable development opportunity of
the five sites evaluated in this report.

If the City’s goal is to rapidly accelerate housing
production on city-owned land, the 118 W. Santa Fe
Avenue site is the ideal catalyst project to initiate
the process. In the City’s forthcoming Request
for Proposals (RFP), staff should structure the
evaluation criteria to score developers not only on
their land acquisition bid, but also on the specific,
binding public benefits and design enhancements
they commit to deliver.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 45 SB 79 PROJECT DENSITY BONUS LAW PROJECT
DEVELOPMENT SCENARIOS: ELI (7%) VLI (10%) LI (13%)
FULLY
MARKET
RATE
VLI (20%) LI (20%)
Site area (sq. ft.) 19,698 19,698 19,698 19,698 19,698 19,698 Site area (acres) 0.45 0.45 0.45 0.45 0.45 0.45
Base density 100 du/acre 100 du/acre 100 du/acre 60 du/acre 60 du/acre 60 du/acre Number of units, base density 45 45 45 27 27 27
Percent affordable 7% 10% 13% 0% 20% 20%
Number of affordable units 4 5 6 0 6 6
Density bonus percentage 25% 33% 25% 0% 50% 35%
Density bonus (increase in MR units) 12 15 12 0 14 10
Total number of units 57 60 57 27 41 37
Total market rate units 53 55 51 27 35 31
Total affordable units 4 5 6 0 6 6
Final Density 126 du/acre 133 du/acre 126 du/acre 60 du/acre 91 du/acre 82 du/acre TABLE 3.3-C Unit Counts and Densities by Development Scenario; 118 W. Santa Fe Avenue Source: PlaceWorks, 2026.

SB 79 PROJECT DENSITY BONUS LAW PROJECT
DEVELOPMENT SCENARIOS: ELI (7%) VLI (10%) LI (13%)
FULLY
MARKET
RATE
VLI (20%) LI (20%)
Net operating income after
debt service 803,000 866,000 805,000 380,000 519,000 457,000 Equity investment 8,630,000 8,990,000 8,630,000 4,820,000 6,600,000 6,100,000 Leveraged yield (target 8%) 9.3% 9.6% 9.3% 7.9% 7.9% 7.5% Feasibility gap none none none -3% -6% -22%
TABLE 3.3-D Financial Feasibility Summary by Development Scenario; 118 W. Santa Fe Avenue Note: Feasibility gap represents the reduction in land price required for the development scenario to be feasible.

Source: PlaceWorks, 2026.
122

POMONA AVENUE

122

POMONA AVENUE
122 POMONA
AVENUE
48 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

3.4 122 POMONA AVENUE

LOCATION AND CONTEXT
This property is located at the northeast corner of
Santa Fe Avenue and Pomona Avenue, across from
the Fullerton Transit Station. The approximately

0.69-acre lot is owned by the City of Fullerton and is
currently occupied by a four-level parking structure.

The structure serves the Fullerton Transportation
Center, which includes the OC Bus terminal to the
west and the Transit Station to the south.

East of the property are low-scale light industrial
buildings. To the north, across a shared alley, are
a four-story affordable housing building, several
smaller single-story commercial properties, and
a USPS office immediately adjacent to the study
site. The property is regulated by the Fullerton
Transportation Center Specific Plan, which
establishes a transit-oriented mixed-use district
and promotes higher-density residential and
commercial development around walkability and
multimodal connectivity.

SITE CONCEPT
The site would require demolition of the existing
parking structure to allow redevelopment of the
entire site. The structure lacks adequate lighting,
has access constraints and maintenance needs, and
presents accessibility and safety concerns. Sufficient
parking for the Fullerton Transportation Center
would continue to be provided by the SOCO District
Parking Structure and other nearby parking options.

Given the property’s location adjacent to the
Fullerton Transportation Center, the site is well
positioned to support higher-density residential
use with a reduced parking profile. The concept
envisions a five-story apartment building with
approximately 100 units, capitalizing on the site’s
transit-oriented setting and prominent corner
location at Santa Fe Avenue and Pomona Avenue.

The proposed building would include one level of
parking located partially below grade, balancing
parking needs with development feasibility by
limiting excavation, reducing construction cost
and complexity, and allowing the garage to remain
naturally ventilated where possible.

Active building uses, including the residential
lobby and leasing office, would be oriented toward
the corner of Santa Fe and Pomona avenues to
establish a clear project identity and improve the
pedestrian experience. Because the residential
podium and parking level would likely sit above
the adjacent sidewalk grade, lobby access would
be provided through stairs and an ADA-compliant
ramp, allowing the building frontage to address the
street while accommodating grading and parking
design requirements.

TABLE

CATEGORY YIELD NOTES
Site Area .69 acres
Residential up to 100 dwelling units,
145 du/acre
Exceeds maximum density of 60 dwelling
units/acre allowed in the General Plan
Commercial None Specific Plan requires storefronts along Pomona
Building Height
65 feet
5 stories, not including ground-level
parking
Under the maximum allowed in the
Specific Plan or 6 floors, 80 feet maximum
Setbacks
Street Frontage – 8 feet provided for
podium screening, Side – 5 feet,
Alley – 5 feet
0’ frontage setback required under FTC SP
Parking 0.7 spaces per unit, including guest
parking
TABLE 3.4-A Development Summary
CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 49 EXHIBIT 3.4-A Existing Site
EXHIBIT 3.4-B Conceptual Massing and Program
Apartments
Leasing
Amenity Deck
143’143’
215’215’ Santa Fe Ave.

Fullerton Station
Pomona Ave.
30,000 sf / 0.68 ac
50 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
EXHIBIT 3.4-C Conceptual Site Plan
EXHIBIT 3.4-D Conceptual Rendering
N0 10 50 100
Santa Fe Ave.

Pomona Ave.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 51

DEVELOPMENT PATHWAYS AND

RECOMMENDATIONS
The property is currently zoned Mixed-Use B within
the Specific Plan, offering several development
options. To establish a clear pathway for project
approval, the following section provides a
financial evaluation of each regulatory approach,
recommends the optimal zoning strategies, and
details the corresponding CEQA implications,
summarized in Table 3.4-B.

However, because the financial feasibility of this site is highly sensitive to upfront site-preparation costs,
two key parameters should be addressed before the
City solicits development proposals:
• Active Sewer Realignment & Easement
Coordination: The Public Works Department has
identified an active sewer line running north-
south along the east side of the existing parking
structure. While the conceptual site design and
financial analysis did not factor in this utility
alignment, future development will require
the line to be physically relocated. To manage
this constraint, the City could coordinate with
Public Works to define the necessary adjacent
easements and relocation costs prior to issuing
an RFP . Providing this critical data directly in
the RFP would de-risk the site for bidders,
accelerate the project timeline, and secure more
competitive land bids.
• Mitigating the Demolition Capital Hurdle: The
existing four-story parking structure requires
complete demolition, adding an estimated $1.36
million in non-value-add, upfront capital costs. To
make this site financially viable, the conceptual
plan incorporated several design flexibilities to
compensate. The City should expect developers
to take a similar approach by building smaller,
efficient one- and two-bedroom units, omitting
ground-floor retail to maximize housing space,
and using parking reductions to target a low ratio
of 0.70 spaces per unit.

Development Scenarios
To evaluate the financial feasibility of the conceptual site plan, six development scenarios are analyzed,
including a fully market-rate scenario provided for
baseline context.

The site’s current zoning allows a maximum
residential density of up to 60 dwelling units per
acre. Because the site is adjacent to the rail station, the analysis also evaluates a high-density scenario
of 145 du/ac under the anticipated framework of

PATHWAYS TO

ENTITLEMENT

APPLICATION TO DEVELOPMENT

CONCEPT NOTES ON ENTITLEMENT
Zone Change
and General Plan
Amendment
Option to amend the FTC Specific Plan to
increase base density.

Discretionary action by Council.

High degree of uncertainty.

Housing Incentive
Overlay Zone
(HIOZ)
Currently not in the HIOZ. Option for CIty to
include within the overlay. Limit of 60 du/
ac or 41 units. Need to use density bonus to
increase unit count and feasibility.

Project must meet affordable housing requirements
per the HIOZ, or 20%. This yields up to 62 units with
a density bonus.

SB 79*
Site is adjacent to Tier 2 transit; allows 85’
max. height, 140 du/ac and 4.0 FAR. An
additional height bonus of 20 feet applies
given proximity to the station.

Unit mix could be adjusted to achieve 140 du/ac (a
reduction of 7 units, which may impact feasibility).

Or, project can use a density bonus as part of SB 79
application to achieve concept density.

AB 2097 Site qualifies for no minimum parking
requirements.
70 spaces included in the financial feasibility
analysis.

TABLE 3.4-B Development Pathways
*SB 79 does not currently apply to Orange County. County is expected to qualify once the OC Streetcar opens later in 2026. 52 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
SB 79. The base density utilized in the scenarios is
calibrated lower so that the final density —including
any affordable housing bonus units—remains
within the maximum threshold for cost-effective
wood-frame construction. The densities and unit
counts for each of the six scenarios are provided
in Table 3.4-C.

The financial feasibility for each development
scenario, measured as the leveraged cash-on-cash
yield, is detailed in Table 3.4-D. The three SB 79
development scenarios (145 du/ac) are financially
feasible, each generating a yield slightly in excess
of 8 percent. The VLI (10%) scenario would
generate the highest yield and, from a developer’s
perspective, be the most financially resilient option
to pursue on this site.

In contrast, the Density Bonus Law scenarios (60
du/ac) are completely unfeasible. Even if the land
were provided to a developer at zero cost, the net
operating income at stabilized occupancy would
not be sufficient to secure a permanent loan to
repay the development costs, which include the
demolition cost of the existing parking structure.

Conclusion
New housing development on this site will be
structurally constrained by the $1.36 million cost to
demolish the existing four-story parking structure.

To compensate, the conceptual development plan
purposely utilizes cost-saving planning flexibilities—
specifically, omitting ground-floor commercial space,
reducing parking ratios, and focusing on smaller,
highly efficient one- and two-bedroom units.

Under the high-density SB 79 framework (145 du/
ac), these cost-saving measures are successful in
bringing the project into financial feasibility. While
the VLI (10%) scenario generates a slightly higher
return than the ELI (7%) scenario, the difference is
marginal and essentially disappears when rounding
the financial values. While the SB 79 development
scenarios generate a yield above the 8.0 percent
feasibility threshold, this margin is exceptionally
narrow. In today’s volatile capital market, a
developer must retain this minor yield cushion as
a vital risk buffer against interest rate fluctuations
and construction contingencies. Consequently, the
City should expect nominal land value bids for this
site, as any attempt by a developer to bid up the
acquisition price would instantly push the project
back into unfeasibility.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 53 SB 79 PROJECT DENSITY BONUS LAW PROJECT
DEVELOPMENT SCENARIOS: ELI (7%) VLI (10%) LI (13%)
FULLY
MARKET
RATE
VLI (20%) LI (20%)
Site area (sq. ft.) 30,000 30,000 30,000 30,000 30,000 30,000 Site area (acres) 0.69 0.69 0.69 0.69 0.69 0.69
Base density 116 du/acre 109 du/acre 116 du/acre 60 du/acre 60 du/acre 60 du/acre Number of units, base density 80 75 80 41 41 41
Percent affordable 7% 10% 13% 0% 20% 20%
Number of affordable units 6 8 11 0 9 9
Density bonus percentage 25% 33% 25% 0% 50% 35%
Density bonus (increase in MR units) 20 25 20 0 21 15
Total number of units 100 100 100 41 62 56
Total market rate units 94 92 89 41 53 47
Total affordable units 6 8 11 0 9 9
Final Density 145 du/acre 145 du/acre 145 du/acre 60 du/acre 90 du/acre 81 du/acre TABLE 3.4-C Unit Counts and Densities by Development Scenario; 122 Pomona Avenue Source: PlaceWorks, 2026.

SB 79 PROJECT DENSITY BONUS LAW PROJECT
DEVELOPMENT SCENARIOS: ELI (7%) VLI (10%) LI (13%)
FULLY
MARKET
RATE
VLI (20%) LI (20%)
Net operating income after debt
service 1,361,000 1,365,000 1,327,000 478,000 666,000 601,000 Equity investment 15,470,000 15,470,000 15,440,000 8,630,000 10,860,000 10,340,000 Leveraged yield (target 8%) 8.8% 8.8% 8.6% 5.5% 6.1% 5.8% Feasibility gap none none none n/a n/a n/a
TABLE 3.4-D Financial Feasibility Summary by Development Scenario; 122 Pomona Avenue Note: Feasibility gap represents the reduction in land price required for the development scenario to be feasible. The Density Bonus Law scenarios would not generate sufficient revenue to obtain permanent financing, even with a zero land cost.

Source: PlaceWorks, 2026.
401

HARBOR AVENUE

401

HARBOR AVENUE
401 N. HARBOR
AVENUE
56 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

3.5 401 HARBOR AVENUE

LOCATION AND CONTEXT
This site is located west of Harbor Boulevard and
fronts Chapman Avenue along its northern property
line. The 1.45-acre site is divided between an
existing brick commercial building, occupied by Bank
of America, and an adjacent surface parking lot.

The property sits at the western edge of the
downtown area and is within walking distance of
Fullerton Downtown Plaza. The surrounding context
includes medium-density residential apartments and
various commercial buildings to the south fronting
Whiting Avenue, with low- to medium-density
residential properties to the west. Together, these
uses reflect the site’s location within a transitional
area between the downtown core and nearby
residential neighborhoods.

SITE CONCEPT
The development concept would divide the existing
property into two functional areas, preserving the
Bank of America building on the eastern portion of
the site while redeveloping the adjacent surface
parking lot with a new residential building. The
concept envisions a 65-unit apartment building with
three stories of residential units over one level of
podium parking. Existing surface parking located
behind the commercial building would be retained
to serve the bank’s parking needs.

The proposed building would establish a more
continuous frontage along Chapman Avenue while
orienting a south-facing residential courtyard
toward Whiting Avenue. The building would be
generously set back from both the street and
adjacent properties to provide a buffer from
surrounding uses and reinforce the site’s transitional
setting between downtown commercial activity
and lower-scale residential neighborhoods to
the west. Along Chapman Avenue, ground-floor
residential units with street-facing patios would be
buffered from the public right-of-way by planter
walls, creating a residential edge that is active but
appropriately separated from the street.

At the eastern edge of the new building, the ground-
floor lobby and leasing office would line the parking
podium and help create an active corner and paseo
condition where the residential building faces the
retained Bank of America building. This frontage
strategy allows the project to screen and activate
the podium while improving pedestrian experience
through the site. Overall, the concept uses building
placement, setbacks, patios, landscaping, and active
ground-floor uses to mediate the transition from the
existing commercial use on the property to the more
residential context west of the site.

TABLE

CATEGORY YIELD NOTES
Site Area 1.45-acre site, concept shown on 0.65
acres
Site currently occupied by Bank
of America, lot split required.

Residential 65 units, 100 du/ac
Commercial None. However, active ground-floor
uses are proposed
Current zoning (C-3) requires
commercial to be part of the
development
Building Height Up to 55 feet
Setbacks Front - Varies, Side - 5 feet,
Rear - 5 feet
No front setback required with
C-3 zoning
Parking 40 spaces Qualifies for no minimum
parking under AB 2097
TABLE 3.5-A Development Summary
CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 57 EXHIBIT 3.5-A Existing Site
EXHIBIT 3.5-B Conceptual Massing and Program
131’131’
215’215’
28,340 SF / .65 AC
104’104’
170’170’
Chapman Ave.

Whiting Ave.

Harbor Blvd.

Malden Ave.

Apartments
Leasing
Amenity Deck
58 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
EXHIBIT 3.5-C Conceptual Site Plan
EXHIBIT 3.5-D Conceptual Rendering
N0 10 50 100
Whiting Ave.

Chapman Ave.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 59

DEVELOPMENT PATHWAYS AND

RECOMMENDATIONS
This site consists of an existing surface parking lot
with few, if any, physical constraints that would
add substantial costs to potential new housing
development. Unlike other parcels in this study, this
site is privately owned rather than city-owned. It is
included in this analysis to illustrate how the City’s
zoning policies can successfully incentivize private
landowners to redevelop underutilized commercial
land into housing.

Because this parcel is privately owned, the transition
to housing relies entirely on market interest rather
than a city-led RFP process. To successfully catalyze
development, the City must navigate two key
private-ownership challenges:
• Private Ownership Challenges: Without land
control, the City cannot dictate project timelines.

If the owner is content holding the property as
a low-maintenance parking lot, development
will stall. To overcome this inertia, the City can
authorize high-density zoning and leverage
SB 79 to make redevelopment significantly
more financially attractive than maintaining
the status quo.
• Proactive Landowner Engagement: Because
the City cannot force a sale, staff can act as
facilitators. Proactively educating the owner
on the increased land value and development
potential unlocked by new zoning can motivate
them to either partner with a residential builder
or sell the parcel on the open market.

Development Scenarios
To assess the financial feasibility of the conceptual
site plan, this analysis examines six development
scenarios, including a fully market-rate scenario for
baseline context. The site’s current zoning allows a
maximum residential density of up to 60 dwelling
units per acre.

Because of its close proximity to—but not immediate
adjacency to—the rail station, the analysis also
evaluates a base scenario of 80 du/ac under the
anticipated framework of SB 79.

For comparison purposes, the baseline density
for the VLI (10%) scenario was adjusted slightly
downward so that all three SB 79 scenarios yield a
consistent building scale and total unit count. This
allows for a direct, “apples-to-apples” comparison

PATHWAYS TO

ENTITLEMENT APPLICATION TO DEVELOPMENT CONCEPT NOTES ON ENTITLEMENT Zone Change
and General Plan
Amendment
Option to seek a zone change to a higher density
residential zone (R-5) to achieve concept density
and height.

Discretionary action by Council. High degree
of uncertainty.

Housing Incentive
Overlay Zone
(HIOZ)
Currently not in the HIOZ. Option for City to include
it within the Overlay. Limit of 60 du/ac or 39 units.

Need to use density bonus to increase unit count
and feasibility.

Project must meet affordable housing
requirements per the HIOZ, or 20%.

AB 2097 Site qualifies for no minimum parking
requirements.
40 spaces included in the financial feasibility
analysis.

TABLE 3.5-B Site 4 Development Pathways
*SB 79 does not currently apply to Orange County. County is expected to qualify once the OC Streetcar opens later in 2026. 60 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
of how different affordable housing requirements
impact project returns. The resulting densities and
unit counts for each of the six scenarios are detailed
in Table 3.5-C, next page. To maximize layout
efficiency, the development scenarios focus on a mix
of one- and two-bedroom units.

Feasibility Summary
The financial feasibility for each development
scenario, measured as the leveraged cash-on-
cash yield, is detailed in Table 3.5-D, next page.

Under these parameters, both the ELI (7%) and VLI
(10%) SB 79 scenarios would be financially feasible
to develop. Of the two, the VLI (10%) scenario
represents the most financially resilient option to
pursue on this site.

The remaining four scenarios do not meet standard
feasibility requirements. However, because this site
is free of major physical development constraints,
these remaining scenarios can achieve financial
feasibility through a private land-cost adjustment.

To bridge the cash flow gap and hit the required 8.0
percent yield, the necessary discount on the land’s
acquisition price ranges from a 10 percent reduction
for the LI (13%) scenario to a moderate 52 percent
reduction for the LI (20%) scenario
Conclusion
It is financially feasible for a developer to purchase
this privately owned site at its estimated market
value and execute the SB 79 development plan.

The projected 8.2 percent yield—sitting just above
the target threshold—provides a sufficient financial
cushion to absorb ongoing interest rate uncertainty,
making it a highly viable candidate for new housing.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 61 SB 79 PROJECT DENSITY BONUS LAW PROJECT
DEVELOPMENT SCENARIOS: ELI (7%) VLI (10%) LI (13%)
FULLY
MARKET
RATE
VLI (20%) LI (20%)
Site area (sq. ft.) 28,340 28,340 28,340 28,340 28,340 28,340 Site area (acres) 0.65 0.65 0.65 0.65 0.65 0.65
Base density 80 du/acre 76 du/acre 80 du/acre 60 du/acre 60 du/acre 60 du/acre Number of units, base density 52 49 52 39 39 39
Percent affordable 7% 10% 13% 0% 20% 20%
Number of affordable units 4 5 7 0 8 8
Density bonus percentage 25% 33% 25% 0% 50% 35%
Density bonus (increase in MR units) 13 16 13 0 20 14
Total number of units 65 65 65 39 59 53
Total market rate units 61 60 58 39 51 45
Total affordable units 4 5 7 0 8 8
Final Density 100 du/acre 100 du/acre 100 du/acre 60 du/acre 91 du/acre 81 du/acre TABLE 3.5-C Unit Counts and Densities by Development Scenario; 401 Harbor Blvd.

Source: PlaceWorks, 2026.

SB 79 PROJECT DENSITY BONUS LAW PROJECT
DEVELOPMENT SCENARIOS: ELI (7%) VLI (10%) LI (13%)
FULLY
MARKET
RATE
VLI (20%) LI (20%)
Net operating income after debt
service 843,000 854,000 829,000 478,000 693,000 606,000 Equity investment 10,450,000 10,450,000 10,450,000 7,120,000 9,650,000 8,820,000 Leveraged yield (target 8%) 8.1% 8.2% 7.9% 6.7% 7.2% 6.9% Feasibility gap 0% 0% -10% -49% -43% -52%
TABLE 3.5-D Financial Feasibility Summary by Development Scenario; 401 Harbor Blvd.

Note: Feasibility gap represents the reduction in land price required for the development scenario to be feasible.

Source: PlaceWorks, 2026.
125

CHAPMAN AVENUE

125

CHAPMAN AVENUE
125 CHAPMAN
AVENUE
64 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
TABLE

3.6 125 CHAPMAN AVENUE

LOCATION AND CONTEXT
This site is just under one acre in size and is owned
by the City of Fullerton. The property is currently
maintained as a surface parking lot. It is located
just west of Harbor Boulevard and fronts Chapman
Avenue along its southern property line.

The site is bordered to the east by an event center
that currently relies on the surface lot for parking.

To the west are low-scale commercial buildings
with restaurant tenants. Brea Creek is located north
of the site, with neighborhoods zoned as medium
density residential beyond the creek. South of
the site, across Chapman Avenue, is a commercial
property occupied by Bank of America.

TABLE

SITE CONCEPT
The development concept proposes a five-story
apartment building over a two-level parking
podium. The building is organized in a C-shaped
configuration, with the central amenity courtyard
oriented north toward Brea Creek. This massing
strategy allows the building to step back visually
from the creek edge and reduces the amount of
continuous building frontage facing the residential
neighborhood to the north. By breaking the
building into two wings rather than creating a single
uninterrupted frontage, the concept helps reduce
perceived scale and visual impacts when viewed
from across the creek.

Along Chapman Avenue, the podium would be
lined with active residential and building-support
uses rather than ground-floor retail, which may be
less viable in this location due to limited pedestrian
activity, retail continuity, and market demand.

Street-level residential units would be set slightly
above sidewalk grade and accessed by individual
stoops, providing a more human-scaled edge while
maintaining privacy for residents. The leasing
office and resident amenity spaces would also face
Chapman Avenue, adding visibility, activity, and
visual interest along the frontage.

CATEGORY YIELD NOTES
Site Area 1.2 acres (52,481 sq. ft.)
Boundary includes Break Creek,
which reduces development area
to 0.99 acres
Residential up to 105 units, 107 du/ac Exceeds maximum density of 60 du/ac of General Plan
Commercial None. However, active ground-floor
uses are proposed
Current zoning (C-3) requires
commercial to be part of the
development
Building Height 70 feet, 5 stories above 2 levels of
parking podium
Exceeds maximum height of 60
feet per C-3 zoning
Setbacks Font - 10 feet, Side - 5 feet,
Rear - 5 feet
No front setback required with
C-3 zoning
Parking 1.6 spaces per units, including guest
parking
In this scenario, the existing
public parking will not be
replaced in-site
TABLE 3.6-A Development Summary
CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 65 EXHIBIT 3.6-A Existing Site
EXHIBIT 3.6-B Conceptual Massing and Program
167’167’
223’223’
42,968 SF / .98 AC
252’252’
200’200’
Chapman Ave.

Harbor Blvd.

Malden Ave.

Apartments
Leasing
Amenity Deck
Parking Podium
66 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
TABLE
EXHIBIT 3.6-C Conceptual Site Plan
EXHIBIT 3.6-D Conceptual Rendering
Chapman Ave.

Harbor Blvd.

N0 10 50 100
CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 67

DEVELOPMENT PATHWAYS AND

RECOMMENDATIONS
The 125 W. Chapman Avenue site is currently
utilized as a city-owned surface parking lot. While
the parcel itself is physically flat and presents few
site-preparation hurdles, City staff must consider
some key constraints prior to preparing an RFP:
• The Events Center Parking Replacement
Penalty: A major programmatic challenge is the
City’s desire to replace and accommodate the
existing on-site parking currently serving the
adjacent events center. To preserve this public
parking capacity alongside a new residential
development, the project would necessitate
constructing a below-grade parking level.

Subterranean parking introduces substantial
capital costs that severely curtail project
economics. In future RFP solicitations, the City
must weigh the operational benefit of this public
parking against the potential impact it will have
on developer interest and land bid values.
• Lower Transit-Oriented Density Allowances:

Because this site is located farther from the rail
station, it does not qualify for the maximum
transit-oriented density allowances analyzed
for the City’s transit-adjacent parcels. Under the
anticipated SB 79 framework, the site’s density
TABLE 3.6-B Development Pathways
is capped at a lower threshold of 80 du/ac.

This lower density limit means the project has
fewer residential units over which to spread any
increase in costs, making it much more difficult
for a developer to absorb the high expense of a
subterranean parking garage.

Development Scenarios
To evaluate the financial feasibility of the conceptual site plan, this analysis evaluates six development
scenarios, including a fully market-rate scenario
provided for baseline context. The site’s current
zoning allows a maximum residential density of
up to 60 dwelling units per acre. Because of its
proximity to—but not immediate adjacency to—
the rail station, the analysis also evaluates a base
density scenario of 80 du/ac under the anticipated
framework of SB 79. The densities and unit
counts for each of the six scenarios are detailed in
Table 3.6-C, next page. To serve a broad range of
local housing needs, the development scenarios
incorporate a diverse mix of family-friendly one-,
two-, and three-bedroom units.

Feasibility Summary
The financial feasibility for each development
scenario, measured as the leveraged cash-on-cash
yield, is detailed in Table 3.6-D, next page.

PATHWAYS TO

Discretionary action by Council. High degree
of uncertainty.

Housing Incentive
Overlay Zone
(HIOZ)
Currently not in the HIOZ. Option for City to include
it within the Overlay. Limit of 60 du/ac or 58 units.

Need to use density bonus to increase unit count
and feasibility.

Project must meet affordable housing
requirements per the HIOZ, or 20%. This
achieves up to 89 units with density bonus.

SB 79* Site is within 1/2 mile of Tier 2 transit; allows 55’ max. height, 80 du/ac and 2.5 FAR
Would need to apply for a density bonus
as part of the SB 79 application to reach
potential of 107 du/ac. The density bonus
law also allows for concessions that could be
applied to increase the height limit.

AB 2097 Site qualifies for no minimum parking
requirements.
170 spaces included in the financial feasibility
analysis
*SB 79 does not currently apply to Orange County. County is expected to qualify once the OC Streetcar opens later in 2026. 68 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
Due to the site’s lower maximum SB 79 density
threshold (80 du/ac), the project lacks the
economies of scale seen on higher-density transit-
adjacent parcels. Consequently, only the VLI (10%)
scenario is immediately financially feasible under
current market conditions, precisely meeting the 8.0
percent target threshold.

However, the remaining five scenarios could achieve
financial feasibility through land-cost adjustments.

To bridge the feasibility gap, the required reductions
in estimated land acquisition costs range from 11
percent for the ELI (7%) scenario to a substantial 82
percent for the LI (20%) scenario.

This variance provides the City with a clear blueprint
of the financial trade-offs and potential public land
write-downs required to incentivize deeper levels of
affordability on this site.

Conclusion
Under standard market conditions, it is financially
feasible for a developer to purchase this site at its
estimated market value and successfully execute the
high-density SB 79 development plan.

However, given ongoing capital market volatility and
interest rate uncertainty, developers are likely to
approach near-term acquisitions with heightened
caution. If the City intends to move forward with a
formal solicitation for this property and mandate
the inclusion of deed-restricted affordable units, the
City should expect developers to request a land sale
priced below the estimated market rate to offset
their financing risk.

When drafting a future RFP for this site, the City
might utilize a flexible pricing structure. Rather
than enforcing a rigid minimum land bid, the RFP
evaluation criteria could allow developers to trade
a portion of the land purchase price in exchange for
delivering deeper, guaranteed community benefits
and deed-restricted affordable housing units.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 69 SB 79 PROJECT DENSITY BONUS LAW PROJECT
DEVELOPMENT SCENARIOS: ELI (7%) VLI (10%) LI (13%)
FULLY
MARKET
RATE
VLI (20%) LI (20%)
Site area (sq. ft.) 42,968 42,968 42,968 42,968 42,968 42,968 Site area (acres) 0.99 0.99 0.99 0.99 0.99 0.99
Base density 80 du/acre 80 du/acre 80 du/acre 60 du/acre 60 du/acre 60 du/acre Number of units, base density 79 79 79 59 59 59
Percent affordable 7% 10% 13% 0% 20% 20%
Number of affordable units 6 8 11 0 12 12
Density bonus percentage 25% 33% 25% 0% 50% 35%
Density bonus (increase in MR units) 20 26 20 0 30 21
Total number of units 99 105 99 59 89 80
Total market rate units 93 97 88 59 77 68
Total affordable units 6 8 11 0 12 12
Final Density 100 du/acre 106 du/acre 100 du/acre 60 du/acre 90 du/acre 81 du/acre TABLE 3.6-C Unit Counts and Densities by Development Scenario; 125 Chapman Avenue Source: PlaceWorks, 2026.

SB 79 PROJECT DENSITY BONUS LAW PROJECT
DEVELOPMENT SCENARIOS: ELI (7%) VLI (10%) LI (13%)
FULLY
MARKET
RATE
VLI (20%) LI (20%)
Net operating income after debt
service 1,427,000 1,542,000 1,387,000 785,000 1,159,000 982,000 Equity investment 18,320,000 19,240,000 18,320,000 12,760,000 16,730,000 15,480,000 Leveraged yield (target 8%) 7.8% 8.0% 7.6% 6.2% 6.9% 6.3% Feasibility gap -11% 0% -26% -83% -58% -82%
TABLE 3.6-D Financial Feasibility Summary by Development Scenario; 125 Chapman Avenue Note: Feasibility gap represents the reduction in land price required for the development scenario to be feasible.

Source: PlaceWorks, 2026.
70 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
Alternative Approach for 125 W. Chapman
Avenue and 401 N. Harbor Boulevard
To maximize local housing production, the feasibility
analysis evaluated an alternative joint-venture
strategy. Under this approach, a master developer
would acquire and consolidate both the 125 W.

Chapman Ave. and 401 N. Harbor Blvd. sites under
a single, unified SB 79 entitlement. This divides the
program into two distinct projects:
• Dedicated Affordable Site: A 100% affordable
housing project (52 units) built on the 0.65-acre
Harbor Blvd. parcel.
• Market-Rate Site: A high-density, fully market-
rate project built on the 0.99-acre Chapman Ave.
parcel, utilizing the massive density bonuses
generated by the adjacent affordable units.

Development Scenario
The combined development scenario leverages the
physical capacity of both sites to maximize efficiency:
• 401 N. Harbor Blvd. (0.65 acres): A base SB
79 density of 80 dwelling units per acre; this
parcel could accommodate up to 52 affordable
housing units.
• 125 W. Chapman Ave. (0.99 acres): At a base
density of 80 dwelling units per acre, this
parcel establishes a baseline of 79 market-
rate housing units.

Combining these programs yields a consolidated
baseline of 131 units. Because the 52 affordable
units represent 39 percent of this total, the unified
project easily qualifies for the maximum state-
allowable 50 percent density bonus (equal to 66
additional market-rate units).

This bonus allows the site at 125 W. Chapman
Avenue to accommodate up to 145 market-rate
units. However, to maintain the realistic physical
building envelope established in the conceptual site
plan, the feasibility model conservatively evaluates
this site with 105 market-rate units (resulting in
a final density of 106.4 du/ac). Further study of
this site may reveal a more optimized envelope to
accommodate the higher-density scenario.

Feasibility Summary
Under this joint structure, the market-rate developer
acquires both sites, funds the initial site work,
and then transfers the Harbor Blvd. parcel to an
affordable housing partner. The master developer’s
financial feasibility is measured by the return
generated solely on the Chapman Ave. site.

As shown in Table 3.6-E, lower left, this combined
approach projects a 8.5% Leveraged Cash-on-Cash
yield, which exceeds the yields of the two separate,
stand-alone SB 79 development scenarios. This
demonstrates that joint-venture consolidation is
highly viable and financially superior for both the
City and the developers.

Conclusion
This scenario is financially viable because the
affordable developer utilizes Low-Income Housing
Tax Credits and other outside funding to construct
the affordable units. This approach also yields
significantly more affordable housing—52 units,
compared to the 10 to 13 units that two separate
SB 79 projects would produce. Finally, the higher
expected yield provides the market-rate developer
with a larger financial cushion to absorb interest
rate uncertainty.

One important challenge is ensuring the affordable
housing portion is actually developed. It may take
two or more years for an affordable developer
to secure funding and be awarded tax credits. A
market-rate developer would likely be unwilling to
purchase the site and delay their own construction
while waiting for the affordable phase to
be fully funded.

Net operating income after debt service 1,828,000
Equity investment 21,600,000
Leveraged yield (target 8%) 8.5%
Feasibility gap 0%
Note: Feasibility gap represents the reduction in land price required for the development scenario to be feasible.

Source: PlaceWorks, 2026.

TABLE 3.6-E Financial Feasibility Summary for Alternative 125 W. Chapman Ave. and 401 N. Harbor Blvd. Approach
CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 71

3.7 FINANCIAL FEASIBILITY

TAKEAWAYS
118 W. Santa Fe Avenue: The
Near-Term Catalyst
From a financial feasibility perspective, the most
financially resilient site and scenario in this study is the 118 W. Santa Fe Avenue transit-oriented (SB 79)
scenario, utilizing a 10 percent Very Low-Income
(VLI) affordability tier. Because this site completely
avoids parking construction costs, the analysis
suggests it is highly positioned to attract strong
developer interest in the near term, whereas other
sites may need to wait until the macroeconomic
outlook and interest rates stabilize.
122 N. Pomona Avenue: Overcoming
Demolition Hurdles
The conceptual site plan for 122 N. Pomona Avenue
features the highest density (140 du/ac) and lowest
parking ratio (0.70 spaces/unit) of the studied
sites. These aggressive planning flexibilities are
mathematically necessary to offset the $1.36 million
upfront cost of demolishing the existing four-story
parking structure.

While the site is financially feasible under the
proposed plan, any municipal push to lower the
density or increase parking requirements will break
the project’s economics. If the City desires a lower-
density or higher-parking project on this site, it
must consider demolishing the parking structure
at municipal expense prior to issuing a Request for
Proposals (RFP).
125 W. Chapman Avenue & 401 N.

Harbor Boulevard: Managing Land
Value Expectations
While both the 125 W. Chapman Avenue and 401
N. Harbor Boulevard sites are financially feasible
under the conceptual plans, ongoing interest rate
volatility remains a challenge. In the near term,
developers bidding on these sites may request land
write-downs below the estimated market value to
offset financing risk. If the City is unwilling to accept lower land bids, it may choose to defer soliciting
development proposals for these sites until capital
markets stabilize.

The Joint-Venture Alternative: Maximizing
Affordable Delivery
Alternatively, the City could solicit the 125 W.

Chapman Avenue and 401 N. Harbor Boulevard
sites as a single, unified joint-venture project. This
structures a market-rate project (with density
bonuses) on the Chapman site to subsidize a
100% affordable project on the Harbor site. While
coordinating the non-profit funding timeline will
require patience, this unified approach has the
potential to deliver a substantially higher yield of
affordable housing units (52 units) and the possibility of reducing direct public land write-downs or
municipal financial subsidies.

Limits of the Density Bonus Law: The Need
for High Density
None of the baseline Density Bonus Law (60 du/
ac) scenarios evaluated across the study sites are
financially feasible under current market conditions.

The primary barriers are the 20 percent affordability
requirement, current interest rates, and estimated
land acquisition costs.

While separate analyses of the Housing Incentive
Overlay Zone (HIOZ) sites may yield different results,
these findings strongly suggest that little to no
housing production will occur under standard 60 du/
ac density limits until interest rates decline. Even in a lower-rate environment, a 20 percent affordability
mandate will remain highly challenging, and further
study of those sites may be necessary.

4 REAP METRICS
74 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

4.1 REAP METRICS
As part of all the SCAG-funded projects using
the REAP 2.0 program dollars, a series of metrics
needed to be used to evaluate project outcomes.

Through coordination with OCCOG and City staff,
several appropriate metrics were identified for the
City of Fullerton work effort that focused on three
main categories: Accelerating Supply, Choice, and
Affordability; Affirmatively Furthering Fair Housing
(AFFH); and Reducing Vehicle Miles Traveled (VMT).

Below are the descriptions and approach associated
with each metric. Table 4.1-A and Table 4.1-B on the
following pages present the baseline and project
outcome REAP metrics.

Accelerating Supply, Choice, Affordability
Metric 1: Increase in housing development potential
through process improvements and streamlining,
resulting in reduced time to entitlements and
building permits.

Approach (Baseline): For this metric baseline
data was sourced from the City’s 5th Cycle Annual
Progress Report and analyzed to determine
the current development rate (units/year) by
building type, as documented during the 5th cycle
Housing Element.

Approach (Outcomes): Our project findings were
used to determine the increased construction
rate and the number of housing units that can
be built as a result of implementing the project
recommendations. Data for this metric was sourced
from PlaceWorks development capacity and pro
forma analysis which showed an Infill Construction
Rate Increase in the project area from 0 to 366
(units/year) and total development rate in the
jurisdiction from 274 to 652 (units/year).

Metric 2: Increase in available sites for housing.

Approach (Baseline): For this metric, PlaceWorks
gathered the Housing Element sites (from the 5th
cycle) to determine the current development rate
(units per year)as the baseline data.

Approach (Outcomes): Data for this metric was
sourced from PlaceWorks development capacity and
pro forma analysis which showed a new residential
unit capacity of 366 units based on the proposed
housing projects.

Affirmatively Furthering Fair Housing (AFFH)
Metric 8: Increased capacity to achieve affordable
housing in high or higher opportunity zones.

Approach (Baseline): The baseline data collected
included the number of affordable buildings and
units completed during the 5th planning cycle, and
the development rate of affordable units by building
size during the 5th planning cycle.

Approach (Outcomes): Data for this metric was
sourced from PlaceWorks development capacity and
pro forma analysis which showed an increase in the
number of affordable low-income buildings from 13
to 14 and an increase in low-income units per year
from 11 to 59 units/yr in high/higher opportunity
zones. A new multifamily housing typology was also
added to the study area as part of this study.

Metric 11: Direct dollars invested in areas of
concentrated poverty, including planning projects
and capital dollars.

Approach (Baseline): Through direct coordination
with the City (City Manager’s office, Public Works,
Community Services) PlaceWorks compiled data on
the local annual investment rate for FYI 2026-27 and
analyzed which planning and capital improvement
project or portions of the project were directly
invested in low resource areas according to California
Housing and Community Development’s 2026
Neighborhood Opportunity layer data.

Outcomes (Approach): Of the five housing sites
included in this report, only 2200 Orangethorpe
Ave. is located within a Low Resource area, as
identified by the California Department of Housing
and Community Development’s Neighborhood
Opportunities data. However, a portion of the funds
acquired through the development process can be
used for capital improvements in any part of the city.

See Exhibit 4.1 to understand how the project sites
relate to Low Resource areas.

At full buildout, development of the five sites
included in this report is estimated to generate
approximately $4,399,320 in Park Development
Impact Fees. These revenues would be collected as
the individual projects are permitted and developed,
rather than as a single upfront or annual payment.

The City proposes to direct 100 percent of the Park
DIF revenues generated by these developments
to eligible park capital improvement projects in
Lower Resource areas. This brings the total annual
CIP investments in lower resource areas from
$12,709,677 to $17,108,997.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 75 Reducing Vehicle Miles Traveled (VMT)
Metric 12: The number of residential units within a ¼
and ½ mile of transit and other mobility options as a
proxy for VMT reduction.

Approach (Baseline): For the baseline, we used GIS
to collect data on the number of existing units within
¼ and ½ mile of transit stops, and the number of
units within ¼ mile of mobility connections.

Approach (Outcomes): For the outcome metric GIS
was used to collect data on the number of new units
proposed to be developed for the project within
¼ and ½ mile of transit stops, and the number of
new units within ¼ mile of mobility connections.

The same analysis area was used to gather both the
existing and proposed unit counts. See tables 4.1-A
and 4.1-B for details.

Metric 13: The number of land uses and number
of easily accessed mobility options in and around
the project area.

Approach (Baseline): For the baseline, GIS was
used to identify, the number of distinct land uses
around the project sites (within ¼ mile) and 23
distinct zoning classifications around the 5 sites. The number of housing units within ¼ mile of mobility
connections was determined to be 5,101 units.

Approach (Outcomes): GIS was used to evaluate
the potential changes in distinct land use categories
based on project outcomes and since no new distinct
land uses were adopted as part of this project, no
change was reported. The number of housing units
within ¼ mile of mobility connections increased from
5,101 to 5,467 units.

EXHIBIT 4.1-A Low Resource Areas
76 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
TABLE 4.1-A Baseline Metrics

TARGET OUTCOME DESCRIPTION METRIC BASELINE

ACCELERATING INFILL DEVELOPMENT

1. Increase infill housing
development.

Collect the current
development rate (units
per year).

Total Development Rate
in Jurisdiction 274 units/year
Total Development Rate
in Project Area 0

2. Increase in number of
units served.

Collect the current
development rate (units
per year).

Total Development Rate
in Jurisdiction 274 units/year
Total Development Rate
in Project Area 0

AFFIRMATIVELY FURTHERING FAIR HOUSING (AFFH)

8. Increase capacity
to achieve affordable
housing.

Number of units served
by existing utility and/or
infrastructure capacity.

Number of affordable
buildings/units by
HE Annual Report
Categories
VLI: 6 buildings, 28 units
LI: 13 buildings, 35 units
MI: 4 buildings, 20 units
AMI 153 buildings, 738 units
The development rate of
affordable units.

Development rate
(units/year) for the 5th
Planning Cycle
VLI: 9 units/year
LI: 11 units/year
MI: 3 units/year
AMI: 38 units/year
Number of ADU, Missing
Middle, MF units
available.

ADU, Missing Middle
and MF units available
ADU: 120 units
Missing Middle: 41 units
MF: 641 units

11. Direct $ invested in
lower resource and lower
income areas.

Current local rate of
annual investment $
per year.

Local rate of investment
($/year)
Local rate of annual investment in
lower resources areas for FY2026/27
is $17,108,977

REDUCING VEHICLE MILES TRAVELED (VMT)

12. Increase in the
number of residential
units located in 1/4 and
1/2 of transit and other
mobility options as a
proxy for VMT reduction.

The existing number of
units in the project area
and within ¼ and ½ mile
of a transit stop.

Housing units in project
area and within ¼ to ½
mile of transit stops
Housing units in project area: 0
Housing units within ¼ mile of transit
stops: 32,209 units
Housing units within a ½ mile of
transit stops: 57,357 units
The existing number of
units within ¼ mile of
mobility connections.

Housing units within
¼ mile of mobility
connections
5,101 units

13. Increase in the
number of land uses
and the number of
easily accessed mobility
options in and around the
project area.

The number of existing
distinct land uses in and
around (within ¼ mile)
the project area.

Number of Distinct
Zoning Code
Classifications within ¼
mile of Project Area
23 distinct zoning classifications
around the 5 sites
Existing number of
housing units within
¼ mile of mobility
connections (walking,
biking routes, transit
routes in and within ¼
mile of the project area).

Housing units within
¼ mile of mobility
connections
5,101 units
CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 77 TABLE 4.1-B Outcome Metrics

TARGET OUTCOME DESCRIPTION METRIC OUTCOMES

ACCELERATING INFILL DEVELOPMENT

1. Increase infill
housing development.

Collect the current development rate
(units per year).

Increased Infill
Construction Rate
(Units/Year)
640 units/year
Total Development
Rate in Jurisdiction 640 units
Total Development
Rate in Project Area 366 units
Increased Residential
Capacity 366 units

2. Increase in number
of units served.

Collect the current development rate
(units per year).

New Residential Unit
Capacity 366 units
New Infrastructure
Capacity (units) 366 units
New Public Facilities
Planned or Developed 0

AFFIRMATIVELY FURTHERING FAIR HOUSING (AFFH)

8. Increased capacity
to achieve affordable
housing and/or
housing choices
in High or Higher
Opportunity Zones.

Increase in development capacity
for new Affordable Housing in infill,
including, but not limited to, in
relatively higher opportunity or higher
income areas and in low-income
communities;
1) Number of affordable buildings
possible (organized by HE annual
report categories); or
2) New affordable housing
development rate; or
3) Increased housing choices (e.g.,
ADU, missing middle, multifamily).

Number of affordable
buildings possible VLI: 6 buildings
Affordable Housing
Development Rate
(units/year)
VLI: 9 units/year
Number of new
housing typologies
available
Multifamily: 1

11. Direct $ invested
in lower resource and
lower income areas.

Increases in planning for Housing-
supportive infrastructure and services
in areas of concentrated poverty or
similar areas.
1) The estimated amount of funding
investments in infrastructure
resulting from the project; and
When available:
2) The amount of dollars invested
in neighborhood stabilization in
areas experiencing high rates of
displacement.

Infrastructure
Investments ($)
Local rate of annual
investment in lower
resources areas for
FY2026/27 that includes
investments related to
planned housing projects is:
$12,709,677
Neighborhood
Stabilization
Investments ($)
City data not available at
the time of this reporting.
78 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

TARGET OUTCOME DESCRIPTION METRIC OUTCOMES

REDUCING VEHICLE MILES TRAVELED (VMT)

12. Increase in the
number of residential
units located in ¼
and ½ of transit and
other mobility options
as a proxy for VMT
reduction.

Expected units, new and/or preserved
in the area and in ¼ and ½ mile of
transit stop, and
New units within ¼
mile of Transit Stop 366 units
New units within ½
mile of Transit Stop 366 units
Expected number of housing units
that will be generated within ¼ mile of
mobility connections (walking, biking
routes, transit routes).

Preserved units within
¼ mile of Transit Stop 32,575 units
Preserved units within
½ mile of Transit Stop 57,723 units

13. Increase in the
number of land uses
and the number
of easily accessed
mobility options in and
around the project
area.

Reduction in parking
requirements on or
near project sites.

Number of distinct land uses in and
around the project areas, number
of mobility connections, off street
parking limits/reductions.
1) Number and type of change(s)
adopted; or
2) New distinct land uses adopted
in and around (within ¼ mile) the
project area; and
When available:
3) Expected number of housing
units that will be generated within
¼ mile of mobility connections
(walking, biking routes, transit
routes).

Land Use Changes
Adopted (#) 0
Type of land use
changes adopted None
Expected housing
units within ¼ mile of
mobility connections
366 units
TABLE 4.1-B Outcome Metrics (continued)
CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 79 Page intentionally left blank

5 REGULATORY

COMPLIANCE

MEMORANDUM

5.1 How to Use This Memo .......................................................................82

5.2 Key Screening Factors .........................................................................82

5.3 Compliance Pathways ..........................................................................83

5.4 Opportunity Sites.................................................................................88

5.5 Key Findings and Takeaways ...............................................................90

5.6 Applying this Framework to Future Sites ............................................90 82 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

5.1 HOW TO USE THIS MEMO
This memo helps City of Fullerton staff quickly
identify which streamlined CEQA compliance
pathways may apply to a proposed housing
site. As examples, this memo covers five
opportunity sites evaluated as part of the REAP

2.0 Technical Assistance Project and provides a
reusable framework for evaluating future sites.

A glossary of terms and definitions is included in
Appendix A, Glossary.

Follow these four steps:

1. Gather site characteristics: size, zoning, General
Plan designation, transit proximity, affordability
targets, and known environmental constraints.
(biological, historical, cultural, etc.)

2. Compare against the Staff Screening Tool in
Appendix B, Staff Screening Tool for Future
Housing Opportunity Sites, to identify which CEQA
streamlining pathways appear eligible.

3. Use this memo to understand the
requirements and tradeoffs for each potentially
applicable pathway.

4. Confirm eligibility through project-level
environmental review and technical studies before
making a formal CEQA determination. 1
¹ Important: This memo is a screening tool, not a formal CEQA determination. Final applicability must be confirmed based on specific project design, applicable regulations at the time of review, and site-specific environmental conditions.

FACTORS THAT LIMIT OPTIONS
y Environmental constraints.

Presence of historic resources, hazardous
materials (Cortese List), biological
resources, or unusual site conditions can
disqualify a site from categorical and
statutory exemptions.
y Entitlement complexity.

Sites requiring General Plan amendments,
rezoning, or other discretionary approvals
face more CEQA scrutiny and have fewer
available shortcuts.

FACTORS THAT EXPAND OPTIONS
y Transit Proximity.

Within ¼ to ½ mile of a qualifying transit
stop or high-quality transit corridor (HQTC),
depending on the requirements of the
applicable streamlining tool. This single
factor is the strongest predictor of eligibility
for most tools.
y Affordability.

Projects targeting low-, very low-, or
moderate-income households qualify for
more pathways than market-rate projects.
y GP and Zoning Consistency.

Sites already zoned for residential or
mixed-use development face fewer barriers
and have access to the widest range of
streamlining tools.
y Infill Location.

Sites substantially surrounded by urban uses
on previously developed land.

5.2 KEY SCREENING FACTORS
Six factors determine whether a site qualifies
for most CEQA exemptions and streamlining
provisions. Understanding these upfront helps
focus the screening.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 83

5.3 CEQA COMPLIANCE

PATHWAYS
California law provides four categories of CEQA
compliance options for qualifying housing projects.

Each is described below with eligibility criteria and
common disqualifiers side by side.

EXEMPTION AUTHORITY ELIGIBILITY CRITERIA COMMON DISQUALIFIERS Affordable
Housing
Exemption
CEQA
Guidelines
§15194 / Public
Resources Code
§21159.23
• Site is less than 5 acres.
• Located within an urbanized area.
• 100 or fewer residential units.
• Units affordable to low-income households.
• Project qualifies as infill development.
• All base criteria in §15192 are met.
• More than 100 units.
• Units not affordable to qualifying
low-income households.
• Site does not qualify as infill.
• Failure to satisfy any base criteria
in §15192.

Residential
Infill
Exemption
(Article 12.5)
CEQA
Guidelines
§15195 / Public
Resources Code
§21159.24
• Site is less than 4 acres.
• Each building level is less than 100,000 sq. ft.
• Within ½ mile of a major transit stop.
• 100 or fewer residential units.
• Affordable to moderate-, low-, or very low-
income households.
• All base criteria in §15192 are met.
• More than 4 acres or more than
100 units.
• Not within ½ mile of a major
transit stop.
• Units not affordable to qualifying
income levels.
• Failure to satisfy any base criteria
in §15192.

Housing
Development
Project
Exemption
AB 130 / Public
Resources Code
§21080.66.
• Site is less than 20 acres.
• Located within an urbanized area or
incorporated municipality.
• At least 75% of the site perimeter adjoins
parcels with urban uses (or at least 3 of 4
sides developed with urban uses and ≥67%
perimeter adjoins urban uses).
• Consistent with applicable General Plan and
zoning.
• Density is at least ½ of the applicable density
in Government Code §65583.2(c)(3)(B).
• Meets requirements of Government Code
§65913.4(6)(a).
• Site requires demolition of a
historic structure.
• Not in an urbanized area or
incorporated municipality.
• General Plan or zoning
inconsistency.
• Density below the minimum
threshold.
100%
Affordable
Housing
Exemption
Sunset
Date: This
exemption is
not available
after January
1, 2033.

AB 1449
/ Public
Resources Code
§21080.40
• Project consists primarily of multifamily
residential uses.
• All residential units (excluding manager’s
units) restricted to lower-income households.
• Complies with prevailing wage and labor
requirements.
• Within an urbanized area and near qualifying
transit or amenities.
• Long-term affordability restriction recorded
through a California Tax Credit Allocation
Committee (CTCAC) regulatory agreement.
• Existing utilities and public services available
to serve the project.
• Exemption also covers related rezoning, GP
amendments, and public financing.
• Site is on environmentally
sensitive or hazardous lands listed
in the statute.
• Units are not fully restricted to
lower-income households.
• Labor or prevailing wage
requirements not met.
• Project is proposed after January
1, 2033.
�

STATUTORY EXEMPTIONS
Statutory exemptions are established by the
California Legislature. When a project meets
all qualifying criteria, CEQA review is not
required. These provide the most definitive
protection from CEQA obligations but have strict
threshold requirements.

TABLE 5.3-A Statutory Exemptions
84 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

CATEGORICAL EXEMPTION
Categorical exemptions cover classes of projects
the California Secretary for Natural Resources has
determined generally do not result in significant
environmental effects. Unlike statutory exemptions,
categorical exemptions are subject to the exceptions
set forth in CEQA Guidelines Section 15300.2.

Among these exceptions, a categorical exemption
may be precluded when there is substantial evidence
that unusual circumstances are present and that the
project may result in a significant environmental
effect due to those unusual circumstances.

Of the 33 CEQA categorical exemption classes, Class
32 is by far the most relevant for the types of infill
housing projects evaluated here.

Class 32: In-Fill Development Projects
Authority: CEQA Guidelines §15332
Best suited for small-to-medium urban infill housing
on previously developed sites that are already
consistent with existing planning and zoning
regulations. This is often the simplest and most
widely applicable exemption for qualifying urban
housing projects.

SB 131 - Near Miss Rule Condition
Authority: Public Resources Code §21080.1(b)
Allows a project to retain eligibility for a CEQA
exemption when it “nearly” qualifies, by disregarding
a single disqualifying condition while requiring
compliance with all remaining exemption criteria.

TABLE 5.3-B Categorical Exemptions
• Project otherwise satisfies all requirements of a
statutory or categorical exemption.
• Only one disqualifying condition prevents use
of the exemption.
• No other independent basis exists to
require CEQA review.

If a project is ineligible for an exemption due to
only a single disqualifying condition, the lead
agency prepares a focused CEQA document (Initial
Study, Negative Declaration, Mitigated Negative
Declaration, or EIR, as appropriate) that evaluates
only the environmental effects caused solely by
that condition. All other environmental issue
areas otherwise covered by the exemption are not
subject to CEQA analysis. If an EIR is required, it
is not required to analyze alternatives or growth-
inducing impacts.

CEQA STREAMLINING

PROVISIONS
Streamlining provisions do not exempt a project
from CEQA, but allow the lead agency to limit
environmental review to issues not already analyzed
in a prior certified EIR. These are most useful where
a robust prior EIR exists for the applicable General
Plan, specific plan, or program.

EXEMPTION AUTHORITY ELIGIBILITY CRITERIA COMMON DISQUALIFIERS Class 32:

In-Fill
Development
Projects
CEQA
Guidelines
§15332
• Consistent with the applicable General Plan
designation, General Plan policies, zoning
designation, and zoning regulations
• Site is within city limits, no larger than 5
acres, and substantially surrounded by urban
uses
• Site has no value as habitat for endangered,
rare, or threatened species
• Project would not result in significant effects
on traffic, noise, air quality, or water quality
• Site can be adequately served by required
utilities and public services
• More than 100 units.
• Units not affordable to qualifying
low-income households.
• Site does not qualify as infill.
• Failure to satisfy any base criteria
in §15192.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 85 Tiering off a Prior EIR
Authority: CEQA Guidelines §15152
Allows a project to rely on analysis from a broader
program-level EIR and limit new analysis to project-
specific effects not previously covered.
y Project is consistent with General Plan
designations and zoning (rezoning is permitted).
y Project is consistent with or is being carried out
pursuant to a program, plan, policy, or ordinance
with a certified EIR.

Use of an EIR from an Earlier Project
Authority: CEQA Guidelines §15153
Allows reliance on a certified EIR prepared for a
substantially similar prior project.
y Project is essentially the same in terms of
environmental impacts and circumstances as the
project described in a prior certified EIR.

Program EIR
Authority: CEQA Guidelines §15168(c)
Allows individual projects within a program to rely
on the program-level EIR if they are consistent
with the program and no new significant impacts
are identified.
y Project is consistent with land use type, density,
geographic area, and infrastructure described in
the Program EIR.
y Project incorporates applicable feasible mitigation
measures from the Program EIR.
y No subsequent or supplemental environmental
review is required under CEQA Guidelines §15162.

Specific Plan Consistency
Authority: CEQA Guidelines §15182
Projects that are consistent with a specific plan for
which an EIR has been certified may be approved
without additional environmental review, except as
required by CEQA Guidelines Section 15162.
y Project is consistent with an adopted specific plan
for which an EIR has been certified.
y Environmental effects of the project were
adequately addressed in the certified EIR for
the specific plan.
y No subsequent or supplemental environmental
review is required pursuant to CEQA
Guidelines Section 15162.

Community Plan or Zoning Consistency
Authority: CEQA Guidelines §15183
Projects that are consistent with the development
density established by existing zoning, community
plan, or general plan policies for which an EIR was
certified may be approved without additional
environmental review, except as necessary to
examine project-specific effects that are peculiar to
the project or site.
y Project is consistent with the development
density established by applicable zoning,
community plan, or general plan policies.
y An EIR was certified for the applicable zoning,
community plan, or general plan.
y Any effects that are peculiar to the project or site, and were not adequately addressed in the prior
EIR, must be evaluated.
y Infill Streamlining.

Authority: CEQA Guidelines §15183.3
y Project qualifies as infill development.
y Consistent with applicable General Plan
designations, zoning, density, building intensity,
and adopted policies.
y Located in an urban area with prior environmental
review of the applicable planning framework.

COMMON DISQUALIFIER FOR ALL CEQA

STREAMLINING PROVISIONS
y Project is inconsistent with the prior
certified EIR, program EIR, specific plan, or
zoning framework relied upon.
y Project would result in new or substantially
more severe significant impacts not
previously analyzed.
y Substantial changes in the project,
surrounding circumstances, or new
information trigger additional review under
CEQA Guidelines §15162.
86 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

COMMON DISQUALIFIER FOR ALL NON-

CEQA LAWS
y Hazardous materials constraints or
environmentally sensitive site conditions.
y Affordability levels do not meet the
qualifying threshold for the specific law.
y Site is not within the required
transit distance.
y Site does not qualify as urbanized
or urban infill.
y Inconsistency with applicable General Plan
or zoning, where required by the law.

NON-CEQA HOUSING

STREAMLINING LAWS
California has enacted several housing laws that
reduce entitlement risk or create ministerial approval
pathways. Ministerial approval means the decision
is based on objective standards only, with no
discretionary judgment, which typically eliminates
CEQA applicability.

Two notes:
y SB 4 and AB 2162 create ministerial approval
pathways, which may reduce or eliminate CEQA
applicability, but neither provides a standalone
CEQA exemption. Projects may also qualify for
other CEQA pathways.
y AB 2097 removes parking requirements near
transit but does not eliminate CEQA review.

Table 5.3-C, Non-CEQA Housing Streamlining Laws
— Key Requirements, compares key eligibility
requirements for each law.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 87

LAW WHAT IT DOES SITE SIZE AFFORDABILITY

REQUIREMENT

TRANSIT

REQUIREMENT KEY LIMIT
SB 4 (2023)
Ministerial approval
on faith/higher-ed
lands
Any 100%
lower-income None
Religious/edu
ownership
required
Implemented primarily through Government Code § 65913.16.

SB 6 (2022)
Allows housing in
retail/office/parking
zones
Any Varies None required Must be in
urbanized area
Implemented primarily through Government Code § 65852.24.

SB 35
Ministerial approval
for affordable
housing
Any 10–50%
affordable None required
Only in RHNA-
noncompliant
jurisdictions
Implemented primarily through Government Code § 65913.4.

SB 79
Transit-oriented
development
streamlining
≥5 units / ≥30 du/
ac Varies ½ mile of
qualifying transit
Effective July
1, 2026; local
implementation
procedures
are still being
developed in
some jurisdictions
Implemented primarily through Government Code § 65912.155–65912.162.

SB 375
CEQA streamlining
for transit priority
projects
<8 ac ≥25% very
low-moderate
<½ mi rail / <¼ mi
HQTC
<200 units; <75k
sq ft per floor
Implemented primarily through Government Code §§ 65912.155–65912.162 AB 2011
(2022)
Housing in
commercial zones <20 ac All affordable or
13–30% BMR None
Commercial
zone; 50-ft street
frontage
Implemented primarily through Government Code §§ 65912.110–65912.124.

AB 2097 Removes minimum
parking requirements Any None ½ mile of major
transit
Does not
eliminate CEQA
review
Implemented primarily through Government Code § 65863.2.

AB 2162
Ministerial approval
for supportive
housing
Any 100%
lower-income None
≥25% or 12
units must be
supportive
Implemented primarily through Government Code §§ 65650–65656 (and related amendments to section 65583).

TABLE 5.3-C Non-CEQA Housing Streamlining Laws — Key Requirements 88 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

5.4 OPPORTUNITY SITES
The City identified five opportunity sites for
potential affordable housing development. Four
are underutilized parking structures or surface
lots within the downtown core; one is a religious
institutional site.

Table 5.4-A, Opportunity Sites Overview, provides an
overview of each site. Key observations:
y All five sites are within an urbanized area, making
most pathway size thresholds achievable.
y Sites with existing residential or mixed-use zoning
have the clearest CEQA pathways.
y The religious institutional site is the only one
potentially eligible for SB 4.
y Sites requiring General Plan amendments or
rezoning face greater entitlement risk and fewer
streamlining options.

SITE LOCATION USEABLE

ACREAGE

GENERAL PLAN
& ZONING EXISTNG USE PROPOSED USE TANSIT PROXIMITY KEY CONTRAINTS/

STRENGTHS
1 2200 W
Orangethorpe
Ave, Anaheim,
CA 92803

0.52 REL, R-1 Religious uses
36 units;
44,700gsf; 100%
affordable
Less than 100 feet from
OCTA Orangethorpe/Gilbert
bus stop and less than 700
feet from the Orangethorpe-
Courtney bus stop.

No major transit stop
within 0.5 mile.
2 118 W Santa Fe
Ave, Fullerton,
CA 92832

0.45 IND, M-G
Vacant, abutting
parking
structure
60 units;
55,200gsf;
Mixed-Use;
up to 4,500sf
commercial
Less than 150 feet from the
OCTA Harbor Boulevard/
Santa Fe Avenue bus stop
and less than 350 feet from
the Amtrak and Metrolink
Fullerton Transportation
Center.

Zone change and General
Plan amendment required.
3 122 N Pomona
Ave, Fullerton,
CA 92832

0.69 FTC, SPD
Fullerton
Transportation
Center Parking
structure
100 units
85,000gsf
Within the Amtrak and
Metrolink Fullerton
Transportation Center
campus.

Acceptable distance from
major transit stop.
4 401 N Harbor
Blvd, Fullerton,
CA 92832

0.65 DWN, C-3 ROD Bank, parking lot 65 units;
66,280gsf
Appx. 0.35 mile from
the Metrolink Fullerton
Transportation Center
campus.

Acceptable distance from
major transit stop.
5 125 W Chapman
Ave, Fullerton,
CA 92832

0.99 DWN, C-3 ROD Parking lot 105 units;
125,000gsf
Appx. 0.38 mile from
the Metrolink Fullerton
Transportation Center
campus.

Acceptable distance from
major transit stop.

TABLE 5.4-A Non-CEQA Housing Streamlining Laws — Key Requirements Notes: REL = Religious; IND = Industrial; DWN Downtown Mixed Use; FTC = Fullerton Transportation Center Specific Plan; R-1 = One Family Residential; M-G = Manufacturing, General; SPD = Specific Plan District; C-3 = Central Business District Commercial; ROD = Restaurant Overlay District. 90 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

5.5 KEY FINDINGS AND

TAKEAWAYS
Transit access is the strongest predictor of
eligibility. Sites near qualifying transit, particularly within ½ mile of a rail station or HQTC, had access
to substantially more streamlining options, including
SB 79, SB 375, AB 2097, and the Residential Infill
Exemption (§15195).

Zoning consistency matters most. Sites already
zoned for residential or mixed-use development
have the clearest CEQA pathways and the lowest
entitlement risk. Sites requiring GP amendments
or rezoning face greater scrutiny regardless of the
pathway attempted.

Affordable and mixed-income projects have the
most options. Projects targeting low- or very low-
income households qualify for the broadest set of
exemptions and streamlining tools, particularly the
AB 1449 exemption (before 2033) and the Affordable
Housing Exemption (§15194).

Some tools apply broadly; others are highly
site-specific. Class 32 and the Affordable Housing
Exemption can apply across multiple site types. SB 4
(faith/education lands), SB 6 (commercial zones), and
AB 2162 (supportive housing) are limited to narrowly
defined contexts.

Coordinated strategies may unlock otherwise non-
viable sites. Sites that do not individually qualify
for streamlining may become viable through
public-private partnerships, land write-downs,
structured affordability programs, or consolidation
of adjacent parcels.

The “Near Miss” provision. This provides an
additional pathway for projects that narrowly miss
an exemption. Where only one condition precludes
use of a statutory or categorical exemption, SB 131
allows CEQA review to focus solely on that issue
rather than requiring comprehensive environmental
review, reducing both the scope and complexity of
the CEQA process.

5.6 APPLYING THIS FRAMEWORK

TO FUTURE SITES
The screening framework in this memo and the Staff
Screening Tool in Appendix B can be applied to any
future housing opportunity site the City considers.

Prioritize sites that are:
y Publicly owned or underutilized.
y Located near qualifying transit.
y Capable of accommodating the required
residential density.
y Free of major environmental constraints.
y Already zoned or General-Plan-designated for
residential or mixed-use development.

Conversely, sites requiring substantial discretionary
entitlements, constrained by environmental
limitations, or lacking sufficient development
intensity present greater implementation risk
and may not be worth prioritizing for near-term
housing production.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 91 Page intentionally left blank

6 IMPLEMENTATION
& POLICY

RECOMMENDATIONS
94 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

IMPLEMENTATION & POLICY

RECOMMENDATIONS
Advancing these conceptual site plans from planning
concepts to viable development opportunities will
require deliberate City action. The City can support
implementation by preparing priority sites for
disposition or public-private development, updating
local standards, completing targeted due diligence,
and creating clearer pathways for private and
nonprofit housing developers.

The following recommendations identify near-term
actions and longer-term policy tools to help Fullerton
facilitate housing production while maintaining local
priorities for design quality, public access, parking
management, and neighborhood compatibility.

ADVANCE NEAR-TERM CATALYST SITES

To build momentum, the City should prioritize
sites most likely to attract developer interest and
demonstrate a clear public benefit. This should
begin with City-owned sites, while also evaluating
opportunities to coordinate with privately owned
parcels where doing so could increase housing
production or affordability.

Complete Site-Control and Surplus Land Steps

Before issuing solicitations for City-owned land,
the City should determine the appropriate site-
control or disposition strategy for each property.

This may include sale, ground lease, exclusive
negotiating agreement, disposition and development
agreement, or another public-private structure.

Where applicable, the City should also complete the
required Surplus Land Act process before releasing
an RFP or entering into negotiations.

Clarifying the disposition pathway early will reduce
uncertainty for developers and help the City align
each site with its housing, fiscal, public-realm, and
economic development goals.

Issue a Strategic RFP for 118 W. Santa Fe Avenue

The 118 W. Santa Fe Avenue site should be
positioned as a near-term catalyst opportunity.

After completing any required Surplus Land Act or
site-control steps, the City should issue an RFP that
clearly communicates the site’s transit-adjacent
location, development potential, and role in
advancing downtown housing production.

The RFP should identify the City’s preferred public-
realm outcomes, including active ground-floor
uses, frontage design, and plaza or gathering-space
opportunities, while allowing development teams to
propose financially feasible solutions.

The RFP should also disclose key implementation
assumptions and constraints, including parking
access, shared-use or lease requirements, parking-
structure improvements, and any mechanical,
operational, or management requirements that
could affect project costs. If use of an adjacent
parking structure is contemplated, the City should
clarify whether parking would be leased, reserved,
shared, or otherwise managed.

Evaluate a Unified Chapman/Harbor Strategy
For the 125 W. Chapman Avenue and 401 N. Harbor
Boulevard sites, the City should evaluate whether a
unified solicitation, development agreement, or
phased covenant structure could support delivery of
both market-rate and affordable housing. This
approach could increase affordable housing
production while concentrating higher-density
development near transit and existing services.

Because the Harbor site is privately owned, this
strategy would require coordination with the
property owner and careful partnership structuring.

The City should also account for the longer financing
timeline often required for affordable housing. Any
unified approach should include clear phasing
requirements, delivery safeguards, and legal
mechanisms to ensure that the affordable
component is not indefinitely delayed.

Disclose Constraints at 122 N. Pomona Avenue

The 122 N. Pomona Avenue site should be marketed
with a clear understanding of its physical and
infrastructure constraints. Any future RFP should
disclose the cost and complexity of demolishing the
existing parking structure, along with known utility,
easement, access, or site-preparation issues.

If confirmed through Public Works or engineering
review, the RFP should also identify any active utility constraints, including potential sewer relocation
requirements or easements that could affect building
placement, construction phasing, or predevelopment
timelines. Early disclosure will help developers
prepare realistic bids and reduce later renegotiation.

CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 95

PREPARE FOR SB 79 AND

TRANSIT-ORIENTED GROWTH

Once Orange County qualifies for SB 79 transit-
oriented provisions, Fullerton should be prepared for
increased interest in high-density housing near the
Fullerton Transportation Center. Because SB 79 may
allow qualifying projects to exceed existing local
density limits, the City should proactively update its
General Plan, Zoning Code, downtown planning
documents, and design standards.

This approach would help Fullerton retain as much
local influence as state law allows while directing
growth toward appropriate sites, protecting sensitive
transitions, and setting clear expectations for
project design.

Adopt Objective Design Standards

The City should adopt Objective Design Standards for
high-density, transit-oriented housing. Clear, non-
discretionary standards are one of the City’s most
important tools for shaping by-right and ministerial
projects, particularly with respect to massing,
frontage design, setbacks, materials, upper-story
transitions, open space, parking access, and
neighborhood compatibility.

These standards should be measurable, enforceable,
and easy for both staff and applicants to apply. They
should avoid subjective terms and focus on the
physical outcomes most important to Fullerton’s
downtown character and pedestrian environment.

Evaluate a TOD Alternative Plan

The City should evaluate whether a state-compliant
Transit-Oriented Development Alternative Plan could
help guide where future housing capacity is
concentrated. If available and appropriate, this tool
could help shift capacity away from sensitive parcels
and toward more suitable commercial, municipal, or
transit-adjacent sites.

This effort should be coordinated with General Plan
and zoning updates so the City can shape a local
framework for where higher-density housing should
occur and what public benefits it should provide.

Update Local Plans and Development Standards

The City should review its General Plan, Zoning Code,
downtown planning documents, parking standards,
and infrastructure requirements to identify
inconsistencies with emerging state housing law. This
review should remove unnecessary barriers to
housing production while preserving clear
expectations for design quality, public access,
infrastructure capacity, and
neighborhood compatibility.

MANAGE PARKING AND

INFRASTRUCTURE PROACTIVELY

As state law reduces residential parking
requirements near transit, and as City-owned
parking lots are considered for redevelopment, the
City should manage parking as a shared downtown
resource rather than a parcel-by-parcel requirement.

Commission a Downtown Parking Utilization Study

The City should commission a Downtown Parking
Utilization Study to establish a data-driven baseline
of parking supply, occupancy, turnover, and shared-
use opportunities. The study should evaluate public
lots, private lots, on-street spaces, transit-user
parking, commercial demand, evening and weekend
conditions, and district-wide management options.

This study would help the City manage public parking
assets, negotiate shared-use or transit-user parking
arrangements, protect downtown commercial
access, and make informed decisions about
redeveloping existing surface lots.

Complete Infrastructure Due Diligence
Before Solicitation

For City-owned sites, the City should complete
targeted infrastructure due diligence before issuing
RFPs. This should include review of utility locations,
sewer and storm drain capacity, fire access,
easements, parking replacement needs,
environmental conditions, and site-preparation costs
that could affect feasibility.

Completing this work upfront will improve developer
responses and reduce the likelihood of major
changes after award.
96 SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS

CREATE A CEQA

STREAMLINING STRATEGY

To accelerate housing production, the City should
identify early which projects may qualify for
ministerial review, statutory exemptions, categorical
exemptions, or other streamlined environmental
review pathways.

Use SB 4 Ministerial Pathways Where Applicable

Qualifying SB 4 projects on eligible religious or
nonprofit-owned sites may proceed through a
ministerial approval process and would not require
discretionary CEQA review, provided all statutory
criteria are met. The City should establish an internal process for reviewing SB 4 eligibility, confirming
applicable objective standards, and identifying
site-specific issues.

This process would be especially useful for faith-
based landowners that may be interested in
affordable housing but are unfamiliar with
development procedures, financing requirements,
and entitlement pathways.

Evaluate Class 32 Infill Exemptions

For qualifying infill projects, the City should evaluate the use of Class 32 Categorical Exemptions where
projects can demonstrate consistency with
applicable plans, adequate utility and service
capacity, and no significant traffic, noise, air quality, or water-quality impacts. Applicants should provide
the technical studies needed to support the
exemption early in the process.

Prepare Early Technical Studies

To support environmental streamlining, the City
should consider preparing or requiring early
technical studies for priority sites, including traffic screening, noise analysis, air quality screening, utility capacity review, hazardous materials assessment,
and tribal or cultural resources screening
where applicable.

Early technical review can identify constraints before
the City issues solicitations or applicants make major
design commitments.

CONTINUE FAITH-BASED

HOUSING ENGAGEMENT

Following the April 30, 2026 public workshop, the
City has established initial momentum with local
religious institutions. To build on this outreach, City staff should create a streamlined intake process for
faith-based landowners interested in SB 4 or other
affordable housing pathways.

The intake process should help property owners
understand eligibility criteria, site-planning
considerations, parking and access issues, affordable
housing financing, and partnership models. The City
can also help connect faith-based landowners with
experienced affordable housing developers,
nonprofit partners, and technical
assistance resources.

For site-specific opportunities, future solicitations or negotiations should address fire access, replacement
parking, shared-use parking, continued institutional
operations, and the long-term needs of the
religious institution.

INTEREST RATES AND MARKET TIMING

The City should also monitor interest-rate conditions
as part of its implementation strategy. The feasibility evaluation found that several development scenarios
that are not financially feasible under current
conditions could become feasible if interest rates
decline by approximately one percentage point,
provided that development costs and market rents
remain generally proportional. This finding suggests
that some sites may not require permanent subsidy
or major policy changes, but instead may benefit
from strategic timing, early due diligence, and
readiness to issue solicitations when financing
conditions improve. By preparing RFP materials, site
constraints, parking strategies, and objective
standards in advance, the City can be positioned to
act quickly when market conditions
become more favorable
CITY OF FULLERTON: REAP 2.0 TECHNICAL ASSISTANCE PROJECT RECOMMENDATIONS REPORT 97 Page intentionally left blank
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City Council - Successor Agency - Housing AuthorityAugust 18, 2026

City Council - Successor Agency - Housing Authority
August 18, 2026