Highland City Council
January 25, 2022

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Table 7. Household Income in the City
Household Income
2018
Number Percent
Less than $ 25, 000 3, 505 22%
25, 000 — $ 49, 999 3, 250 20. 4%
50, 000— $ 74, 999 2, 724 17. 1 %
75, 000 — $ 99, 999 1, 466 9. 2%
100, 000 — $ 149, 999 2, 724 17. 1 %
150, 000 — $ 199, 000 1, 209 7. 6%
200, 000 or more 1, 052 6. 6%
Total 15, 932 100%
Median Income 59, 3951
ource: US Census Bureau
In 2018 Inflation -Adjusted Dollars.
3 Housing Profile
This section describes and evaluates housing characteristics to identify existing trends and potential needs. These characteristics include housing growth, housing age and condition, housing prices and rents, tenure, and vacancy. Understanding housing trends can indicate the City' s ability to meet future housing needs.

3. 1 Housing Growth
The amount and type of housing available within a community reflect the existing housing stock' s ability to serve expected population growth and a range of incomes, lifestyles, and family types and sizes.

The City' s housing stock was shaped by the City' s history as an agricultural area. In the 1940s, large citrus groves gave way to suburban neighborhoods in west Highland. Housing growth moved east, eventually stopping at City Creek. Housing development east of City Creek primarily occurred decades later, spurred by the development of the East Highlands Ranch community in the 1980s. This pattern of housing growth resulted in essentially two " Highlands": the west side has established neighborhoods and the east side has master - planned communities.

Recent housing growth primarily consists of single- family neighborhoods in planned unit developments.

Housing growth to meet the needs of various income levels and household sizes in the City is currently not met by the predominant single-family housing type stock. Infill development opportunities are located in west Highland. Larger development opportunities are generally on the east side. A Specific Plan and several planned developments in progress on the east side will offer a range of housing types, from singlefamily detached homes to multifamily units.

As shown in Table 8, Composition of the Housing Stock in the City, according to SCAG estimates, the City had an estimated total of 16, 578 units in 2010. In 2018, the total of estimated units grew to 16, 845, representing a 1. 6 percent increase. All of the City' s housing growth occurred in single- family detached and attached units, with a total of 267 units. The largest portion of the City' s overall housing stock consists

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of single- family detached units, comprising 78. 6 percent of the City' s housing stock, which is higher than the 61. 7 percent share in the SCAG region.

Table 8. Composition of the Housing Stock in the City
2010 2020
Percent Change Number Percent Number Percent
Single -Family 12, 969 78. 2% 13, 236 78. 6% 2. 1 %
Detached 12, 670 76. 4% 12, 866 76. 4% 1. 5%
Attached 299 1. 8% 370 2. 2% 23. 7%
Multifamily 2, 654 16. 0% 2, 654 15. 8% 0. 0%
2- 4 Units 678 4. 2% 678 4. 0% 0. 0%
5+ Units 1, 976 11. 9% 1, 976 11. 7% 0. 0%
Mobile Homes 955 5. 8% 955 5. 7% 0. 0%
Total 16, 578 100% 16, 845 100%
ource: SCAG Local Housing Data

3. 2 Age of the Housing Stock
Providing safe and attractive housing improves quality of life for residents. One measure of housing condition is age. As shown in Table 9, Age of Housing Stock in the City, the City experienced a boom in housing construction from the 1980s through the 1990s.

Units constructed 30 years ago often require minor rehabilitation to comply with new safety standards and repair signs of inadequate maintenance. Housing units over 50 years of age are more likely to be in need of substantial rehabilitation. According to Census estimates, 12 percent of the City' s housing stock was built within the last 20 years, almost 40 percent was built between 20 to 40 years ago, and almost half was built over 40 years ago. Based on the City' s west -to -east development pattern, it can be assumed that these older units are primarily in west Highland.

Table 9. Age of Housing Stock in the City
Year Built Number Percent
2014 or later 71 0. 4%
2010 to 2013 88 0. 5%
2000 to 2009 1, 799 10. 7%
1990 to 1999 3, 373 20. 0%
1980 to 1989 3, 226 19. 1 %
1970 to 1979 1, 917 11. 3%
1960 to 1969 2, 414 14. 3%
1950 to 1959 2, 209 13. 1 %
1940 to 1949 972 5. 8%
1939 or Earlier 822 4. 9%
otal 16, 891 100%
Source: US Census Bureau, 2018.

3. 3 Housing Condition
The structural age of a building may be an indicator of housing condition because older buildings are more likely needed to be repaired or replaced. Major rehabilitation projects that come with older building may include roof replacements, foundation repair, and plumbing updates. Highland is a relatively newer City.

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Therefore, only 38 percent of housing in the City is older than 1970 as shown in Table 9. Structural age however, cannot be the only indicator that units may need rehabilitation or replacement.

Substandard housing is an indicator that a building should be rehabilitated or replaced because it poses a risk to the health and physical well- being of its occupants, neighbors, and visitors or it lacks essential amenities that diminishes the quality of life. Table 10, Substandard Housing in Highland shows the number of units in the City that have a contributing factor to poor housing conditions. This may include a lack of telephone service, lack of plumbing facilities, and lack of complete kitchen facilities. In some cases these facilities may be illegally built. Other factors that are not included are a lack of heating and health risks such as mold.

Local data shows that the City averages approximately 100 rehabilitation permits peryear, which has been increasing as more investors take advantage of the increase in rental rates and demand for rental units in the Inland Empire. - Based on consultation with the City' s Code Enforcement Officers and Building Official it is estimated that approximately 3, 500 housing units ( or approximately 20 percent% of the housing stock) are in need of some level of rehabilitation. However, approximately 20 units are estimated to be in need of replacement. - Rehabilitation is necessary to improve the condition of substandard housing that is often more affordable to lower -income homeowners, older adults, and disabled persons. Substandard housing is addressed in Program 2, Residential Rental Enchantment and Rehabilitation Program in which property owners are required to submit a checklist prior to the issuance of a business license certificate to ensure the property is free from health and safety hazards. The program will also ensure that rental properties are maintained and that landlords have access to resources they need to ensure the property remains safe for tenants. Additionally, through Program 3, Code Enforcement, the City will bring properties into compliance by conducting a windshield survey within neighborhoods identified to receive Community Development Block Grant funding and identify substandard housing that may violate the zoning or building codes.

Table 10. SubstandaYri Hn _}sing in Hiohland ( 20181
Factor Units Percent of Total Units
No Telephone Service Available 1. 22%
Lacking Plumbing Facilities 0. 19%
Lacking Complete Kitchen Facilities 1. 00%
Source: SCAG 2020, ACS 5- Year Estimate 2014- 201 P
343ATenure and Vacancy
Ownership rates reflect the ability of the housing stock to meet the needs of households looking for investment or those not ready for the responsibilities, cost, or permanence of home ownership.

As shown in Table 1. , Occupied Units in the City, homeownership rates decreased, and the share of renters increased by 3 percent between 2010 and 2018. During the 1990s, owner -occupancy rates in the City increased as more single-family homes were built. This development trend resulted in a relatively high percentage of owner -occupied units. Although the type of housing primarily developed in High the City favors homeownership, in recent years the single- family detached housing stock has begun to provide renter opportunities in the form of homes available for lease. Investors purchasing homes with the intention to lease them results in single- family housing renter opportunities. However, an increase in

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investor -owned homes reduces the likelihood for housing turnover and may further burden renters who are unable to secure housing at a more appropriate size and cost. Overall, the number of renter -occupied units in the City increased by almost 900 between 2010 and 2018; however, the share of renters in the City is lower than in the SCAG region overall, with 47. 5 percent renters.

Table 1 . Occupied Units in the City
Tenure
2010 2018
Number Percent Number Percent
Owner - Occupied 10, 014 68. 2% 10, 382 65. 2%
Renter - Occupied 4, 675 31. 8% 5, 550 34. 8%
Total 14,689 100% 15, 932 100%
ource: US Census Bureau
The vacancy rate is a strong indicator of the housing market and the ability for the housing stock to accommodate changing housing needs. A high vacancy rate can contribute to more affordable housing, while a low vacancy rate indicates that housing demand exceeds supply, leading to a tighter market with fewer opportunities. In general, an optimal vacancy rate is 2 percent for owner -occupied housing and 7 to 8 percent for rental units in a mature community, which indicates a stable housing market. A vacancy rate above 12 percent is considered to be high. Healthy levels of vacancy are considered when ensuring sufficient residential mobility and housing choice while providing adequate financial incentive for landlords or owners to maintain and repair their homes.

According to 2018 American Community Survey estimates, 5. 7 percent of all units were vacant in the City.

The overall homeowner vacancy rate was 0. 4 percent, and the overall rental vacancy was 5 percent, making up nearly a third of the City' s total vacant units. This vacancy rate signifies a low vacancy rate and is much lower than the 2010 rental vacancy rate of 10. 3 percent following the 2008 Great Recession.

According to the Department of Finance, the 2020 overall vacancy rate in the City remained at 5. 7 percent.

In comparison, San Bernardino County had a much higher vacancy rate ( 11. 6 percent). 433Housing Price and Affordability
The City' s housing costs for ownership and rental units fluctuated greatly over the last two decades.

Housing costs for ownership and rental units at the end of the 2000s underwent unprecedented changes that improved the affordability of housing for low-, moderate-, and above moderate -income residents.

Between 2000 and 2021, typical home value in the City fluctuated greatly, as shown in the Figure 1, Average Home Value In Highland. Overall, typical home value increased from $ 140, 530 in 2000 to 396, 000 in 2021. The following describes the affordability of the City' s housing.

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450, 000
400, 000
350, 000
300, 000
250, 000
200, 000
150, 000
100, 000
Average Home Value in Highland
O - 1 N M d' Ln CD n W M O .-- 1 fV M -; t Ln lD r` W M O

O O O O O O O O O O O O O O O O O O O O O O

N N N N N N N N N N N N N N N N N N N N N N
Average Home Value in Highland
Figure 1. Average Home Value in Highland
Source: Zillow Home Value Index, 2020
R 4-13. 5. 1 Home Purchase Price
Historically, the City has attracted residents for its quality and affordable housing prices and rents. In the City, much like other cities in the Inland Empire, there was a period in the early 2000s when housing prices soared. Much of the appreciation was due to rising housing demand throughout the region, the availability of lower interest loans, and the desirability of new housing products on the market. However, with the downturn in the California economy and collapse of the housing market, home sales prices bottomed out in 2012 to reflect the oversupply of single- family detached homes and shortage of qualified buyers.

According to Zillow' s Home Value Index, median home sales price for existing homes was as low as 178, 088 in 2012. As the economy recovered, low interest rates and a growing economy enabled more people to buy a home, yet home building was slow to recover following the 2008 recession, leading to a limited increase in supply. Overall, demand outpaced supply and median home sales price steadily rose 93 percent to $343, 000 by 2018. According to Zillow estimates, the median home value in Highland was 357, 000 in January 2020.

According to Core Logic, the median sales price of single- family residences and condos, as well as new homes, in October 2020 was $ 397, 500, similar to the median home price of $400, 000 for San Bernardino County. These median home sales prices and how they compare to a year prior are shown in Table 12-1, Home Sales Prices October 2020. '
Table 1 Home Sales Prices October 2020
County/City Median Price' Change Since 2019
City of Highland 397, 500 13. 6%
County of San Bernardino 400, 000 14%
ource: Corel- ogic, October2020.

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Single -Family Detached and Condos

3. 4.23. 5. 2 Housing Affordability
The affordability of housing is determined by market prices and current residents' ability to pay. To facilitate the analysis of income distribution among households in communities, the California Department of Housing and Community Development ( HCD) groups households into categories by income. Income categories are determined as a percentage of the area median income ( AMI) and then adjusted for household size in the following manner:

Extremely Low Income — less than 30% of the AMI
Very Low Income — 31% to 50% of the AMI
Low Income — 51% to 80% of the AMI
Moderate Income — 81% to 120% of the AMI
Above Moderate Income — greater than 120% of the AMI
Collectively, extremely low-, very low-, and low- income households are referred to as lower -income households ( up to 80 percent AMI). According to SCAG' s data for Household Income Distribution Based on County Annual Median Income, 42 percent of the City' s households are lower -income households, 15. 5 percent are moderate -income households, and 42. 5 percent are above moderate -income households.

Table 132, Maximum Affordable Price and Rent, shows maximum affordable rent and purchase price.

Maximum affordable purchase prices by income category for two- and four -person households were calculated based on 2020 State income limits. The figures shown in Table 132 are meant as a guideline to compare to the current market. Based on the 2020 median sales price of single- family residences and condos, a household would have to have an annual income of roughly $ 72,000 to afford to purchase a home in the City. Meaning that only two -person, above moderate -income families and four -person, moderate- and above moderate - income families could afford a home in the City based off the estimated maximum affordable purchase price in Table 1 .

Table 1 . Maximum Affordable Price and Rent
Household Income Category Annual Income Maximum Affordable Rent Maximum Affordable Purchase Price
Person
Extremely Low 18, 100 453 66, 739
Very Low 30, 150 754 145, 806
Low 48, 200 1, 205 264, 242
Median 60, 250 1, 506 343, 307
Above Moderate 72, 300 1, 808 418, 374
Person
Extremely Low 26, 200 655 98, 704
Very Low 37, 650 941 139, 057
Low 60, 250 1, 506 329, 716
Median 75, 300 1, 883 432, 058
Above Moderate 90, 350 2, 259 520, 809
Source: 2020 HCD State Income Limits, Guidestone. org Mortgage Calculator ote: Annual income limits based on California State income limits for 2020; acceptable expenditure for rental housing calculated as 30 percent of income divided y 12 months assumes set -asides for utilities; acceptable expenditure for ownership housing was calculated as 30 percent of income and includes 10 percent own payment provided by the owner and assumes set -asides for utilities, real estate taxes, and homeowners insurance. Various local, State, and Federal housing rograms may require different calculations of maximum affordable rent or purchase prices.

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344 3. 5. 3__ COVID- 19 Impact on Home Prices
Due to the seriousness of the public health crisis resulting from COVID- 19, there is a lot of economic uncertainty. Southern Californians, challenged by a pandemic, bought the fewest homes in any June on record, while record -low mortgage rates helped push the median selling price to an all- time high.

Based on the CoreLogic Home Price Insights report, annual home price growth accelerated to its fastest rate in nearly 2 years in July 2020 in response to strong purchase demand and sudden wave of relocations made possible by remote work and historically low mortgage rates falling below 3 percent.

However, the number of sellers remained low in the summer of 2020, while the pool of prospective buyers expanded. Without homes for sale, the uneven buyer -seller dynamic led to an extremely competitive and challenging market for homebuyers.

The research team at Realtor. com listed Riverside —San Bernardino County as one of the five counties with the greatest recovery based on the Housing Market Recovery Index. The index uses the January 2020 preCOVID- 19 pace as a baseline. The Inland Empire ( Riverside and San Bernardino Counties) housing market could see a rise in demand and home sales going into 2021, as buyers relocate from the more crowded and pricier coastal markets. However, whether the volume of new listings continues to improve remains to be seen, as sellers face political, economic, and health -related uncertainties heading into 2021.

On a nationwide level, the national Housing Price Index Forecast shows annual home price growth slowing through the middle of 2021, reflecting the anticipated elevated unemployment rates. This could lead to an increase of distressed - sale inventory as continued financial pressures leave some homeowners unable to make mortgage payments, especially as forbearance periods come to a close.

3. 4.43. 5. 4 Rental Prices
According to Census data estimates, the nation' s renter population has surpassed 100 million, and is the largest it' s been since 1960. On a national level, renting has become exceedingly popular in the last decade. Since 2010, the number of renters increased two times faster (+ 9. 1 percent) than the number of homeowners (+ 4.3 percent), signaling that many Americans, from young families to older adults, have been forced to shift away from homeownership, potentially minimizing housing stability and the ability to build equity.

Rental housing serves many needs, such as young adults not ready for the cost or responsibilities of homeownership, older adults seeking less costly and lower maintenance dwellings, families who benefit from the lower cost of rental housing and on -site amenities, and very low- income families who are often on fixed incomes. Overall, the rental market provides affordable housing opportunities to a great range of household sizes and incomes.

According to RentCafe rental marketplace, the average rent for an apartment in the City was $1, 317 as of February 2020, a 9 percent increase compared to the previous year, when the average rent was $ 1, 208.

Table 1 , Highland Rent, and Figure 2, Highland Rent 2018, show Census estimates for median gross rent by bedroom.

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According to the data presented in Table 1 , only housing units consisting of only one room and no bedroom, such as a one -room efficiency apartment, would be affordable to extremely low- income, two - or four -person households. One -bedroom housing units would be affordable to very low- income two - person households that are able to expend slightly more than 30 percent of their income on housing.

To avoid overcrowding, a four -person household would need a unit with at least two bedrooms. Based off Census estimates in Table 1 , units with more than one bedroom would be unaffordable to extremely low- and very low- income, four -person households. These estimates show that the rental housing stock in the City is generally only affordable to moderate- and above moderate - income households, and some low- income households.

Highland Rent 2018
2, 500
2, 000
1, 500
1, 000
500 $;
0 1, 980
17C
No Bedroom 1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom 5 Bedroom Median Gross Rent
Figure 2. Highland Rent 2018
Table 1 . Highland Rent 2018
Unit Size Median Gross Rent'
No Bedroom 280
1 Bedroom 806
2 Bedroom 1, 019
3 Bedroom 1, 441
4 Bedroom 1, 980
5 Bedroom 1, 770
Average 1, 093
ource: Census B25031
2018 rents are expressed in 2020 Inflation -Adjusted Dollars.

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3-- 53. 6Overcrowding
A household is considered overcrowded if there is more than one person per one room in the housing unit and serves as a useful tool for identifying a lack of supply in affordable housing in an area. In this definition, " rooms" include living rooms, dining rooms, and bedrooms. While some families with low incomes may opt for overcrowding to reduce spending, many lower -income residents often have no choice but to live in overcrowded housing. These overcrowded housing units place a strain on physical facilities and does not provide a satisfying living environment.

According to the American Community Survey, there are approximately 1, 455 overcrowded units in the City, representing 9. 1 percent of all households, with 2. 7 percent of all households having more than 1. 5 occupants per room, which meets the American Community Survey definition for severe overcrowding.

In the City, overcrowding is more prevalent in renter households; 17. 9 percent of renter households compared to 4. 4 percent of owner households meet the definition of overcrowded. The existing rental housing stock may not meet the unit size and affordability needs of a portion of the City' s lower -income households. See Ssection 3. 8-7. 4, Large and Single -Parent Families, for additional discussion.

3. 7Overpayment and Cost Burden
he of lev.fer iReeme, with thp h, -1k Af this categery being these with ML-d! Rn f;;Mhiy *RGOMeS that are in the pFegrams-. It is essential that Housing Elements analyze the number of cost burdened lower -income households that are overpaying for housing. More specifically, cost burden is defined as paying more than 30 percent of household income for housing. Per HCD requirements, local governments must identify households that are considered to be extremely low- income, as further analyzed in Section 3. 8. 7 Extremely Low -Income Households. Extremely low- income households are those households whose incomes do not exceed 30 percent of the county median family income according to HUD' s income limits The households that are included in this category typically represent the lowest wage earners in a community. Table 15, Households Income Category by Tenure in Highland, breaks down household income by tenure in 444h4prdthe City. It is revealed that as median family income increases the number of owner -occupied units increase. About 41 percent of households in A4g44a4the City are considered to be of lower income, with the bulk of this category being those with median family incomes that are in the 30 percent to 50 percent income category. Extremely low- income households make up 23 percent of renter -occupied units, and iust under 7 percent make up owner -occupied units. Extremely low- income

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households are the most vulnerable to rent changes and overall housing costs. With most lower —income households making up the majority of the rental market, it is necessary to advocate for rental assistance programs
Table . Households Income Category by Tenure in Highland ( 2018) Income Category
Owner -Occupied Renter -Occupied Total Households
Owner Percent Renter Percent Number Percent
Extreme) Low 30% MFI or less 705 6. 8% 1, 285 23. 1% 1, 990 12. 5% Very low > 30% to 50% MR) 735 7. 0% 1, 605 28. 9% 2, 340 14. 7% Low > 50% to 80% MFI 1, 200 11. 6% 950 17. 1% 2, 150 13. 5% Moderate or Above over 80% MFI 7, 740 74. 6%
1 1, 715 30. 9% 9, 455 59. 3%
Total 10, 380 1 100% 1 5, 550 1 100% 1 15, 930 1
100%
Source: Department of Housing and Urban Development ( HUD) Comprehensive Housing Affordability Strategy ( CHAS), 2014- 2018 MFI = median family income
Tame-XX
It iS S119-0.0A thi-A FeRtP_F eeeupied heusehelds make abeut $ 30, 000 less than the City Fnedian heuseheld AP Fly Table 16, Median Household
Income by Tenure, provides the median household income for the City and County, as well as by tenure in the City. It is shown that renter - occupied households make about $ 30 000 less than the City median household income, followed by the County which is almost $ 35, 000 less, and significantly less than owner - occupied households which is nearly $ 60, 000 less than renter -occupied households.

Table Median Household Income by Tenure ( 2019)
Jurisdiction 2019 Median Income
C4 of Highland 64, 868
Owner - Occupied Households 91, 758
Renter -Occupied Households 31, 613
San Bernardino County 67, 903
Source: 2019 ACS 5- Year Estimates S2503
1 able 17, Housing Cost as a Percentage of Household Income, provides the number of households in each income range and the cost of housing as the percentage of their income, filtered by tenure. It is shown that lower —income homeowners and renters alike are spending more than 30 percent of their income on housing.

Table 17. Housing Cost as a Percentage of Household Income ( 2019) Owner Occupied Units
Income Range
Total
Households
of Total
Households

0. 20% of
Household Income
20- 29% of
Household Income
30- 34+% of
Household Income
SO- 19 999 763 4. 7% 112 0 651
20 000- 34 999 771 4. 8% 173 121 477
35 000- 49 999 837 5. 2% 286 169 382
S50 000 + 8, 246 51. 1 % 1 4, 199 2, 335 1
1 712
Subtotal 10 797 66. 9% 1 4 770 2, 625 3, 222
Renter -Occupied Units
Income Range
Total
Households
of Total 0- 20% of
Households I Household Income

20. 29% of
Household Income
30- 34+% of
Household Income

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0- 19 999 1, 263 7. 8% 9 28 1, 226
20 000- 34 999 1, 403 8. 7% 19 81 1 303
35 000- 49 999 576 3. 6% 44 175 357
50 000 + 1, 879 11. 6% 754 831 294
Subtotal 5, 341 33. 1 % 826 1, 115 3180
Total 16138 100% 1 5, 596 1 3, 740 6, 402
Source: U. S. Census American Community Survey B25106.

Note! Some households are not accounted for: therefore figures may differ slightly for other U. S Census estimates for total households An important factor in determining existing housing need is the affordability of housing. One measure of housing affordability is the percentage of a household' s gross income needed to meet monthly mortgage payments. According to HCD and the United States Department of Housing and Urban Development HUD), housing costs should not exceed 30 percent of a household' s gross income.

Households spending more than 30 percent of gross income for housing are considered housing cost burdened, thus limiting their ability to afford other important expenses. This may cause a series of related financial problems, which may result in a deterioration of housing stock because costs associated with maintenance must be sacrificed for more immediate expenses such as food, clothing, health care, and utilities. It may also result in the selection of inappropriately sized units that do not suit the space or amenity needs of the household.

Lower income households become cost burdened when affordable housing options are limited and difficult to find. As a result, problems may arise in regard to repayment, deferred maintenance, or overcrowding. While overpayment is defined as spending more than 30 percent of household income on housing costs, severe overpayment is more than 50 percent of household income spent on housing costs.

Table 18, Households by Proportion of Income Spent on Housing Costs X-X shows the proportions of income spent on housing costs by AMI in 2018. It is shown that the vast majority of extremely low- income households ( earning 30 percent or less of AMI) are severely overpaying for housing as opposed to other income groups.

According to the Census Bureau data used by HUD in the Comprehensive Housing Affordability Strategy CHAS) data, 57. 8 percent of renter households and 29 percent of owner households spend 30 percent or more of gross income on housing. Of these households that are cost burdened, 58. 6 percent of renters 34 percent of all renter households) and 37 percent of homeowners experience " severe cost burden," spending 50 percent or more of their income on housing. Ownership households generally have higher incomes and equity for loans that enable them to expend less of their annual income on housing.

Table 18iX. Households by Proportion of Income Spent on Housing Costs (2018) Household
Income
30% of Income
Spent on Housing
30%- 50% of Income Spent on
Housing ( Overpayment)
50% of Income Spent on
Housing (Severe Overpayment)
30% AMI 395 130 1, 465
30%- 50% AMI 375 920 1, 045
50%- 80% AMI 940 850 360
80%- 100% AMI 1, 050 335 100
100% AMI 7, 165 730 75
Total 9, 925 2, 965 3, 045
Source: Department of Housing and Urban Development ( HUD) Comprehensive Housing Affordability Strategy ( CHAS), 2014- 2018 AMI = area median income

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Table 19. Percent Income Spent on Rent in Highland, XX shows the 2019 distribution of renter households by the percent of income they spend on rent. The largest percentage of renters at 34 percent ( 1, 820) spend more than 50 percent of gross income on housing costs. This is followed by 20 percent ( 1, 115) of renters who spend 20 percent to 30 percent of their gross income on housing costs.

Table ^ " e'"". Percent Income Spent on Rent in Highland ( 2019) Percent of Income Spent Number of Households Percent of Total Renter Households 20% 826 15. 5%
20%- 30% 11115 20. 9%
30%- 40% 622 11. 6%
40%- 50% 738 13. 8°%
50% 1, 820 34. 1 %
Not Computed 1 220 4. 1 %
Source: 2019 ACS 5- Year Estimates B25070
Based on the average rent of an apartment in the City in 2020 and median household income of renter occupied households, the typical renter will spend closely to SO percent of their income on housing. At this price point, the average renter will not be able to easily afford a unit with more than two bedrooms.

This also means that very low- income households will be unable to afford apartments with one or more bedrooms without overpaying. This may lead to increased likeliness of overcrowding in units. Rental prices are further discussed in Section 3. 5. 4, Rental Prices. 4, 73. Kpecial Needs Groups
Individuals and families in certain subpopulations face significant challenges to finding decent, affordable housing. Finding units of adequate size, location, and design can be especially difficult for subpopulations with any special housing needs, such as older adults; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. Therefore, in accordance with State law, California Government Code Section 65583( a)( 7), this section provides an analysis of the special housing needs of these groups.

3. 8. 1 Persons with Disabilities
Persons with disabilities often have special housing needs with regard to accessibility, location, and transportation. Persons with disabilities often face employment hardships, and many may rely on fixed incomes, therefore reducing their ability to afford adequate housing. The breadth and variety of disabilities presents a range of challenges for meeting the needs of persons with disabilities, including persons with developmental disabilities. Mountain Breeze Villas in the City provides a number of units as a project -based apartment for adults and older adults who are experiencing homelessness or at risk of experiencing homelessness and receive clinical services from the Department of Behavioral Health.

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According to the 2018 Census, approximately 9. 7 percent of City residents had a disability. The Census estimates report on six disability types: hearing difficulty, vision difficulty, cognitive difficulty, ambulatory difficulty, self -care difficulty, and independent living difficulty, as described below:

Hearing difficulty: deaf or having serious difficulty hearing.

Vision difficulty: blind or having serious difficulty seeing, even when wearing glasses.

Cognitive difficulty: because of a physical, mental, or emotional problem, having difficulty remembering, concentrating, or making decisions.

Ambulatory difficulty: having serious difficulty walking or climbing stairs.

Self -care difficulty: having difficulty bathing or dressing.

Independent living difficulty: because of a physical, mental, or emotional problem, having difficulty doing errands alone such as visiting a doctor' s office or shopping.

The 2018 Census identified 5, 299 individuals in the City with one or more disabilities. Persons with ambulatory and/ or cognitive difficulties represent the largest share of people with disabilities in the City, as shown in Figure 3, Disability Type.
3, 000
2, 500
Disability by Type
2, 464
2, 361
2, 000 1, 832
1, 500
1, 199
1, 057
1, 000
500
F
1, 357
Independent Living Self - care r Ambulatory Cognitive Vision Hearing Figure 3. Disability by Type
Understanding the employment status of people with disabilities may also be an important component in evaluating specialized housing needs, as show in Table 20-14, Disability by Employment Status. In the City,

36. 2 percent of the population with a disability is employed, compared to 68. 9 percent of the non - disabled population.

Table . Disability by Employment Status
With a Disability Percent of Total No Disability Percent of Total Employed 1, 063 36% 21, 073 1 69%

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Table . Disability by Employment Status
With a Disability Percent of Total No Disability Percent of Total Unemployed 139 5% 2, 369 8%
Not in Labor Force 1, 736 59% 7, 121 23%
Total 2, 938 30, 563
Source: SCAG Local Housing Data; American Community Survey 2014- 2018 5- Year Estimates.

3. 73.8. 2 Persons with Developmental Disabilities
There are also disabilities that are not tracked by the Census. For example, the Census does not record persons or households affected by developmental disabilities, including autism spectrum disorder. Senate Bill 812 requires counties to include the needs of individuals with a developmental disability within the community in the special housing needs analysis. According to Welfare and Institutions Code Section 4512, a " developmental disability" means a disability that originates before an individual attains age 18 years; continues, or can be expected to continue, indefinitely; and constitutes a substantial disability for that individual. According to SCAG' s 2020 Local Housing Data, 628 of the City' s residents 0 to 17 years and 296 residents 18 years and older have a developmental disability.

The Centers for Disease Control and Prevention' s Autism and Developmental Disabilities Monitoring Network estimates that about 1 in 54 children have been identified with an autism spectrum disorder.

The City' s population under 18 years of age estimate for 2018 is 16, 142, indicating that there could be approximately 300 children with an autism spectrum disorder in the City.

Some residents with developmental disabilities may live comfortably without special accommodations, but others require a supervised living situation, such as group housing or an assisted living facility. City residents with developmental disabilities can seek assistance from the Autism Society Inland Empire in Corona or at the Inland Regional Center in San Bernardino, the largest regional developmental disability support center in the State of California. Some people with disabilities may require modifications that allow freedom of movement to/ from and within a housing unit. Table 2144, Development Disability by Type of Residence in the City, provides information about the place of residence for persons with a developmentally disability in the City.

Table . Developmental Disabilities by Type of Residence in the City Residence Number or Persons With Disability
Home of Parent/ Family/ Guardian 501
IndependenUSupported Living 26
Community Care Facility 37
Intermediate Care Facility 49
Foster/ Family Home 10
Other 5
Source: SCAG Local Housing Data; CA DDS consumer count by CA ZIP, age group and residence type for the end of June 2019.

The Federal Fair Housing Act of 1998 and the Americans with Disabilities Act (ADA) are Federal laws that are intended to assist in the provision of safe and accessible housing. These regulations were codified in Title 24, Part 2, known as the California Building Code, and apply to newly constructed multifamily

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dwelling units in buildings with three or more units, or in condominium projects with four or more units.

California Code of Regulations Title 24 sets forth accessibility and adaptability requirements for public buildings. However, as these standards are not mandatory for single- family homes, in -home accessibility can be an issue for people with disabilities.

It is the policy of the City, pursuant to the Federal Fair Housing Amendments Act of 1988, to provide people with disabilities reasonable accommodation in rules, policies, practices, and procedures that may be necessary to ensure equal access to housing. The City has adopted specific procedures in the Zoning Code for processing reasonable accommodation for persons with disabilities seeking equal access to housing under the Federal Fair Housing Act and the California Fair Employment and Housing Act in the application of zoning laws and other land use regulations, policies, and procedures. In order to make specific housing available to persons with disabilities, a request for reasonable accommodation may be made by any person with a disability, their representative, or any entity when the application of a zoning law or other land use regulation, policy, or practice acts as a barrier to fair housing opportunities. A request for reasonable accommodation may include a modification or exception to the rules, standards, and practices for the siting, development, and use of housing or housing -related facilities that would eliminate regulatory barriers and provide a person with a disability equal opportunity to housing of their choice.
3- 7..33. 8. 3 Older Adults
Older adults often seek housing based on affordability, proximity to services, proximity to public transportation, and accessibility. Older adult households may reside on fixed incomes, resulting in limited housing opportunities and sensitivity to market increases in housing costs. According to Census estimates, of the City' s renter households, 568 are 65 years and over ( 10. 2 percent of all renters). An estimated 2, 239 older adult households owned their homes ( 21. 6 percent of all owners).

Disabilities also create special housing needs for older adults. On average, social security disability benefits are lower than social security benefits, which means a lower fixed monthly income. Limited mobility or sensory abilities make accessible, barrier -free housing and proximity to public transportation a priority for some older adult households. According to the 2018 Census, 35. 3 percent of all City residents aged 65 years and over suffer from one or more disability. Ambulatory difficulties ( 21. 5 percent of City older adults) and independent living difficulties (16 percent of City older adults) are particularly prevalent in the City, making senior care housing an important need. Moreover, older adult residents seeking to remain independent benefit from programs that help them rehabilitate and improve their home. The reasonable accommodation ordinance in the City' s Zoning Code provides older adults with disabilities a clear process for removing impediments to fully accessible housing.

Jeffrey Court provides 60 very low- income and 124 low- income apartments to older adults. For older adults requiring assisted care, the City has five residential care facilities for older adults serving 139 residents and 10 adult residential care facilities with the capacity to serve 52 residents. The Highland Senior Center and Highland District Council on Aging Inc. provide older adults with social events, planned trips, enrichment classes, transportation assistance, and a visitors and phone pal program for homebound older adults.

In addition to the existing resources, two new developments are expected to be completed during the planning period that will serve the needs of the City' s older adults. One development is a 60- unit senior

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assisted living development, which was entitled by the City in 2018 ( Resolution 2018- 008). The site is located on Base Line Street east of Sterling Avenue next to the Mountain Breeze Villas a 168- unit affordable housing apartment complex. The second anticipated project is an approximately 90- unit affordable senior apartment development on two parcels owned by the Housing Authoritv located on Central Avenue. See Section 4. 2, Planned, Approved and Prospective Projects in Appendix E } Sites Analysis and Inventory, for additional details.

The City will continue to aid older adults with affordable housing and care services. This can be accomplished through various program, such as Program 5, Impact Fees which may reduce fees for proposed affordable housing developments; Program 6, Density Bonus which will include a provision of a bonus for senior housing and affordable developments; Program 12, Accessory Dwelling Units which will develop an incentive for the production of ABUsccessory dwelling units that may be offered as affordable; and Program 17, Housing for Persons with Disabilities which may provide relief to older adults with disabilities by alleviating land use, zoning, or building laws, rules, policies practices and/ or procedures. This program also provides resources and increased in -home accessibility for older adults who have limited mobility. Program 18, Residential Care Facilities further addresses older adults who may require residential care by establishing and permitting facilities that serve six or fewer persons by right in all residential zones.

3.- 43. 8. 4 Large and Single -Parent Families
Increasing living costs have placed an additional hardship on lower- and moderate -income large families, defined as five or more members. Large families are considered a special needs group due to the limited supply of housing adequately sized to accommodate a large family without overcrowding. Single - parent households also face additional challenges. Typically, single -parent households have lower incomes than two -parent households since the household may only rely on one income and must also be able to afford housing and childcare. Based on income statistics, female -headed households and female single parents are considered to have a special housing need due to relatively low incomes.

According to Census estimates, there were 12, 720 families in the City with an average family size of 3. 9 in 2010. Of those families, 3, 548, or 27. 9 percent, had five or more people. In 2018, there were 15, 932 households with a slightly smaller average size of 3. 4. As shown in Figure 4, Households by Household Size, of those households, 3, 561 had five or more people, representing 22. 4 percent of all households.

According to the 2019 ACS Census data, about 41 percent of large families ( 5 or more persons) are below the poverty level.

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Households by Household Size

30. 00 %

25. 00%

24. 3%
0 22. 4%
W1

19. 8 %
u 20. 00% 17. 8° " T
N 16. 7% 16. 9%
N
a 15. 00%, ` 13. 5° 13. 0°

11. 3°
v 9. 6%
t
0 10. 00%
cu
7 r4
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2 5. 00% -

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1 2 3 4 5+
Number of People per Household
Renter a Owner Total
Figure 4. Households by Household Size
Due to the limited supply of adequately sized units to accommodate large- familv households. large families face an above -average level of difficulty in locating adequately sized affordable housing. Even when large units are available, the cost is generally higher than that of smaller units. The lack of supply, compounded with the lower income of larger families, results in many large families living in overcrowded conditions. According to the Census ACS estimates, the total number of overcrowded households has decreased in the last decade. As presented in Table 22, Large Households by Tenure, there were 3, 554 households in the City in 2019 with at least five persons, representing 22 percent of the households in the City. In 2011, there were 3, 815 households in the City with at least five persons, representing 25 percent of thr- ? otal hog izeholds in the City at th '- time.

Table . Large Households by Tenure ( 2019)
Number of Persons in Unit Owner Occupied Renter Occupied Total Five 1, 350 764 2, 114
Six 390 318 708
Seven or More 378 354 732
Total 2, 118 1, 436 3, 554
Source: U. S. Census, 2014- 2019 ACS B25009
According to Census ACS estimates, approximately 16 percent ( 2, 706 units) of the City' s total housin units had four rooms and approximately 73 percent ( 12, 426 units) had five or more rooms in 2019. Of the City' s renter -occupied housing units, approximately 24 percent ( 1, 297 units) had four or more rooms including 416 units with six or more rooms. Based on the number of housing units available with five or more rooms, there is an adequate supply of large units. Meanwhile, there is less renter -occupied units

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with four or more rooms. However, based on the median monthly rent estimates discussed in Section

3. 5. 4, Rental Prices, the median monthly rent for a unit with five or more bedrooms would be $ 1 770 and the median monthly rent for a unit with four bedrooms would be $ 1, 980. Table 23 Median Family Income by Family Size lists the median income by the size of the family. Based on rental prices a 5- person family should be able to afford a unit with 5 bedrooms. However, this is dependent on the number of household earners and number of available units of that size.

Table 23. Median Family Income by Family Size (2019)
Family Size Number Median Income
2- Person Families 4, 027 72, 228
3- Person Families 3, 062 67. 982
4- Person Families 2, 663 70, 881
5- Person Families 1, 757 73, 580
6- Person Families 648 56, 786
7- or- More Person Families 665 75, 625
Source: 2019 ACS 5- Year Estimates S1903
The City will continue to provide accommodations for larger households by implementing various programs that seek to reduce overcrowding units and increase the number of affordable units. This includes Program 7, Housing Choice Voucher Referrals will connect residents to available resources that can assist in the cost of housing. Program 13, Homeowner Assistance Programs may provide large households with opportunities for housing or relief so that they can gain access to better sizeable homes.

Program 16, Affordable Housing Preservation Program protects large households from risks e# v associated with expiration of affordability agreements. Program 22 Collaborative Partnerships may provide financial assistance for large families who seek resources and rental assistance.

R753. 8. 5 Female -Headed Households
Statute requires analysis of specialized housing needs, including female -headed households, in an effort to ensure adequate childcare or job training services. Based on 2018 Census estimates, there were 2, 690 female - headed households in the City, 16. 9 percent of the City' s total households. Of the total -female headed households, 46. 6 percent of the female -headed households were owners and 53. 4 percent were renters.

Of the City' s 15, 932 total households, 10. 1 percent are female -headed households with children under the age of 18, and 1. 3 percent are female -headed with children under 6. In 2018, the number of both male- and female -headed single -parent households with children under the age of 18 was 2, 246, representing 14. 1 percent of the City' s households. Single -parent household incomes tend to be lower than their two -parent counterparts, potentially because the parent may have to take part time employment due to childcare needs.

Single- family detached rentals and multifamily housing with child -oriented amenities, such as playgrounds and on -site childcare, would help meet the housing needs of the City' s large -family and single -parent households. Affordable attached housing, such as condominiums, can also help meet the needs offemale - headed and single -parent households in the City.

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63. 8. 6 Farmworkers
The economy in Highla4d—the City was once driven by the citrus industry. As orchards turned into neighborhoods, the number of farmworkers employed in the City decreased. According to the Bureau of Labor Statistics, in 2017, approximately 152 City residents reported employment in agricultural, forestry, fishing, or hunting industries in other cities, and none reported having agricultural or related employment located in the City.

According to SGAG local housing data, there were 82 farmworkers by occupation ( 41 full- time, year- round jobs) and 117 residents ( 76 full-time, year- round jobs) who were employed in the agricultural industry in City in 2018. Farmworkers have special housing needs because they generally move based on seasons, earn lower incomes, and are known to live in overcrowded households in order to afford housing. In agriculture -dependent areas, affordable seasonal or permanent housing is an important component of the special needs housing stock. With less than 1 percent ofthe farmworker job market held by residents, the need for designated farmworker housing is minimal in the City; however, farmworkers are essential to the region' s economy and food supply.

3. 7. 73. 8. 7 Extremely Low -Income Households
Extremely low- income households earn annual incomes that are 30 percent or less of the area median income. Based on State income limits for 2020, a four -person, extremely low- income household earns no more than $ 26, 200 and can afford $ 655 per month for rent ( expending 30 percent of annual income on housing). These households are generally living paycheck -to -paycheck and could be at risk of homelessness in the event of unemployment or a large expense such as medical treatment.

Households with extremely low incomes often experience severe overpayment and overcrowding.

Although median gross rent is relatively more affordable in the City ($ 1, 059) compared to median gross rent in San Bernardino County ($ 1, 275) according to the 2018 Census estimates, extremely low- income households typically spend more than 30 percent of their income on housing.

Using American Community Survey 2016 data, HUD' s Comprehensive Housing Affordability Strategy estimates that there were 2, 189 extremely low-income households in the City ( 14. 2 percent of all households). Of those households, 71 percent were renters. Housing the extremely low- income population can be especially challenging. Small, extremely low-income households can often be accommodated through second units and single -room -occupancy units; however, large, extremely lowincome households may face greater difficulty in finding affordable housing. Subsidized housing appropriate for extremely low-income families can be provided in many forms, including affordable rental multifamily units, townhomes, or condominiums. Higher -density multifamily projects may serve as a future resource for the City' s extremely low-income population.

Table 24-16, Extremely Low -Income Housing Needs in the City, provides a breakdown of extremely lowincome households by race and ethnicity. The race/ ethnicity with the highest share of extremely lowincome households in the City is the Black, non -Hispanic population ( 20. 7 percent compared to 14. 2 percent of total population), followed closely by the Hispanic race/ ethnicity population, with the second highest share.

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Table 2446. Extremely Low -Income Housing Needs in the City Race/ Ethnicity Total Households Households Below 30% HAMFII Share Below 30% HAMFII White, non - Hispanic 6, 155 475 7. 7%
Black, non - Hispanic 1, 421 294 20. 7%
Asian and other, non -Hispanic 1, 627 210 12. 9%
Hispanic 6, 265 1, 210 19. 3%
Total 15, 468 2, 189 14. 2%
Renter - Occupied 5, 575 1, 560 28. 0%
Owner - Occupied 9, 910 635 6. 4%
Total 15, 485 2, 195 14. 2%
Source: SCAG Local Housing Data, 2020; HUD Comprehensive Housing Affordability Strategy, 2012- 2016. 1 HAMFI refers to Housing Urban Development Area Median Family Income.

Per HCD' s requirements, local governments may calculate the projected need for extremely low- income households by presuming that 50 percent of very low- income households qualify as extremely low- income households. Therefore, based on the City' s very low-income RHNA of 619 units, there is a projected need of 309 extremely low- income units.

The City will continue to provide services that will aid lower income households and seek developmental opportunities for affordable housing units. The City will do so through the implementation of several programs which include Program 4, Inclusionary Housing, which requires that all new housing development provide affordable units on site or off site, or to pay an in -lieu fee that goes into the City' s affordable housing preservation and construction fund. This provides lower income households with increased housing security. Program 6, Density Bonus, provides an incentive to developers to exceed the maximum allowable development on a property that may help to achieve goals of affordable units for extremely low-income households. Program 7, Housing Choice Voucher Referrals directly help lowincome households by offsetting monthly housings costs by paving rental subsidies directly to property owners. Program 15, Fair Housing Mediation aims to provide fair housing across all households including extremely low-income households. Program 16, Affordable Housing Preservation Program focuses on assisting homeowners who may be at risk of foreclosure and ensures that low- income households maintain ownership of their properties. Program 20, Affordable Housing Partnerships and Program 22 Collaborative Partnerships both provide a creative framework to partner with advocacv groups and housing service providers which seek to benefit lower income households.

3. 7..93. 8. 8 Persons Experiencing Homelessness
People experiencing homelessness are the community' s most vulnerable residents. People experiencing homelessness often face chemical dependency, mental health problems, domestic violence, and other life -threatening conditions. Individuals and families experience homelessness for a variety of reasons, and therefore a population experiencing homelessness may have a variety of needs. A person experiencing homelessness may need medical care, childcare assistance, credit counseling, substance abuse treatment, job training, and/ or English language education, among other services.

The San Bernardino County 2020 Homeless Count and Subpopulation Survey includes a point -in -time count of people experiencing homelessness and an evaluation of the homeless population and their needs through peer interviews. Based off the results, there were a total of 78 unsheltered adults in the City. This

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represents approximately 2. 5 percent of San Bernardino County' s homeless population. Of the 78 persons counted, volunteers were able to administer 50 surveys. The point -in -time survey reported that 35 of the surveyed adults were male and 15 were female. The majority of the unsheltered adults were between the ages of 25 of 39 ( 40 percent), followed by those ages 55 to 61 ( 20 percent) and 40 to 49 ( 15 percent).

Due to a limited rental market with few affordable vacancies and income restrictions, extremely lowincome families and individuals are potentially at risk of homelessness. There are a variety of emergency and transitional housing service providers in the City area to address a range of needs ( see Table 2544, Local Resources for Homeless and At -Risk of Homeless Persons). Facilities in the City provide airconditioned rest areas in dangerously hot weather, emergency food provisions, employment assistance, marriage counseling, psychiatric evaluation and counseling, and transitional housing. City records identified two transitional housing facilities in the City. One of the facilities, located on Elmwood Road, is a six -bed facility for ages 18 to 26. The other facility, located on Newcomb Street, is a six -bed transitional home for people experiencing homelessness. Other nearby communities offer additional resources for people experiencing homelessness and transitional housing facilities.

Table . Local Resources for Homeless and At -Risk of Homeless Persons Name Location Services Target Population
Patton State Hospital Senior Highland Air- conditioned facilities during All Center dangerously hot weather
Saint Adelaide Catholic Church Highland Emergency food, employment, and All marriage counseling
Vista Guidance
Highland
Psychiatric evaluation and
All
Centers of Highland counseling and referral
services
Family Services Association Redlands Motel vouchers, emergency food, All clothing, counseling, rental
assistance, housing advocacy, basic
life skills training, and case
management
Church on the Hill Redlands Emergency food All
Knotts Family Agency Redlands Transitional housing Youth Salvation Army Redlands Emergency food, counseling, and All utility assistance
Catholic Charities San Bernardino
Casework, counseling, motel
vouchers, emergency food, and All
utility assistance
Central City Lutheran Mission San Bernardino Casework, transitional and Varies per program emergency housing, home repairs,
motel vouchers, food, clothing,
healthcare, counseling, utility
assistance, showers and laundry,
workforce development, men' s
homeless shelter, youth programs
Children' s Fund San Bernardino Emergency food, shelter, Youth transportation, medical and
dental care, education, clothing,
beds, school supplies, hygiene
products, and furniture
Community Action San Bernardino No -cost home weatherization All Partnership of San services and utility assistance
Bernardino County Energy
Conservation Program

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Table . Local Resources for Homeless and At -Risk of Homeless Persons Name Location Services Target Population
Community Action Partnership of San Bernardino
Motel vouchers, rental Families
San Bernardino County Family assistance, food, Development Program miscellaneous family selfsufficiency supportive
services
Community Action San Bernardino
Emergency food
All
Partnership of San
Bernardino County Food
Bank
Cornerstone Compassion Center San Bernardino
Emergency food and clothing,
All
health clinic
Department of Behavioral Health San Bernardino Supportive permanent housing and Mentally ill persons Homeless Program counseling services
Frazee Community Center San Bernardino Emergency and transitional All supportive services and assistance.

Hase and Associates Systems San Bernardino Prevention education, Hispanic All Inc. outreach program, outpatient
substance abuse treatment,
employment assistance, and
DUI program
Hernandez Community Center San Bernardino Food distribution and youth activities All Inland AIDS Project San Bernardino Emergency, transitional, and Persons with permanent housing; emergency HIV/ AIDS
rent and utility assistance; and
residential care for chronicallyill
Inland Behavioral and Health
San Bernardino
Case management and various
All
Services emergency services
Mary' s Mercy Center San Bernardino Emergency food, clothing, and All showers
New House Women with Children San Bernardino Substance abuse rehabilitation Women with children New House Inc. San Bernardino Substance abuse rehabilitation Individuals 39 beds
Operation Grace San Bernardino Emergency and transitional Female individuals shelter
Our Lady of Fatima San Bernardino Emergency food All
Our Lady of Hoe San Bernardino Emergency food and clothing All Priscilla' s Helping Hand San Bernardino Case management and housing, Emancipated foster education, and employment youths
assistance
Rolling Start Inc. San Bernardino Advocacy, housing and personal Disabled persons assistance referrals, and
independent living skills training
Salvation Army San Bernardino Emergency shelter ( 70 beds) All Salvation Army ARC San Bernardino Alcohol abuse treatment program Individual males 65 beds), transitional housing
San Bernardino City Mission San Bernardino Emergency food, clothing, and All hygiene items
San Bernardino County San Bernardino Assistance with benefits and Veterans and Department of Veterans Affairs pension claims dependents San Bernardino Sexual Assault San Bernardino Counseling, hospital, and court Victims of sexual assault Services accompaniment
Set Free Christian Fellowship San Bernardino Substance abuse transitional living Individuals 35 beds

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Table . Local Resources for Homeless and At -Risk of Homeless Persons Name Location Services Target Population
Veterans Alcoholic Rehab
Program VARP Harris House
San Bernardino Substance abuse rehabilitation and
transitional housing
Veterans
VARP Gibson House for Men San Bernardino Substance abuse rehabilitation and transitional housing
Male veterans
VARP Gibson House for Women San Bernardino Substance abuse rehabilitation and transitional housing
Female veterans
Veronica' s Home of Mercy San Bernardino Christian transitional housing ( 14 beds)
Youth and pregnant
women
San Bernardino Vet Center San Bernardino Individual and group counseling Veterans Victory Outreach San Bernardino Substance abuse rehabilitation ( 10 beds
All
Vista Guidance Center San Bernardino Drop -in center with clothing and laundry facilities
All
Source: Community Action Partnership of San Bemardino County 2020. 943.9Affordable Housing
At -risk affordable projects are those that could convert to market rents within 10 years from the planning period. State law requires that the City identify, analyze, and propose programs to preserve existing multifamily rental units that are eligible to convert to non -low-income housing uses due to termination of subsidy contract, mortgage prepayment, or expiring use restrictions during the next 10 years.

3. 8. 13. 9. 1 Assisted Housing Developments at Risk
Government Code Section 65583( a)( 8) requires an analysis of existing assisted multifamily housing developments for low- income renters that are eligible to change to market -rate units during the next 10- year period due to termination of subsidy contracts, mortgage prepayment, or expiration of restrictions on use. The analysis must inventory each development by project name and address, the type of government assistance received, the earliest possible date of change from low-income use, and the total number of senior and non -senior units that could be lost from the local low- income housing stock. In addition, the analysis is required to assess the conversion risk and displacement of low- income tenants, estimate and analyze the costs of replacement versus preservation of at -risk units, identify entities qualified to preserve at -risk units, and identify financing and subsidy resources.

After extensive research of all assisted units in San Bernardino County, it was determined that all the affordable developments in the City are not currently at risk of conversion, with a " Low -Risk" designation, as shown in Table , Assisted Units At Risk of Conversion.

Table . Assisted Units At Risk of Conversion
Name and Address Housing Type
Affordable
Total Units Program
Risk
Units Level
Jeffrey Court Seniors Senior ( Age 55+) 184 185 LIHTC Low 7367 Central Avenue
Mountain Breeze Villas Non - Targeted 167 168 LIHTC; HUD; Low 25942 E Baseline Street CalHFA
Sterling Village Large -Family 79 80 LIHTC Low
7360 Sterling Avenue

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Sources: California Housing Partnership Corporation, 2020; Office of the State Treasurer All Active California Tax Credit Allocation Committee Projects, 2019; HUD Office of Policy Development and Research, 2019 LIHTC = Low -Income Housing Tax Credit; CalHFA = California Housing Finance Agency Affordable units may convert to market rate prices due to prepayment of HUD mortgages, opt -outs, expiration of Section 8 contracts, and expiration dates established by other funding sources. According to City records, no projects are at risk of converting to market rate during the planning period.

The County of San Bernardino currently owns and operates 12 public housing units in the City. There is no expiration date for the affordability of these units. The County Housing Authority also issues approximately 394 Housing Choice Vouchers in the City. Program participants may use their vouchers throughout San Bernardino County. There are no project -based Section 8 buildings in the City.

While Jeffrey Court Seniors is identified as low risk, the development is eligible to opt -out of affordability control since it was placed in service in 1999. The City will continue to monitor the development through subsequent Housing Element updates. In the event of affordability expiration, the City may pursue subsidizing the units, purchasing and placing a long- term affordability covenant on the units, or constructing replacement units. If the property owner does not extend the affordability covenant, the City will reach out to numerous qualified entities determined by HCD as having the ability to purchase and manage the property for continuous affordable housing.

3. 9. 2 Costs Analysis
To maintain the existing affordable housing stock, the City works to preserve the existing affordable units.

The financial cost of preserving rental units compared to allowing them to be converted to market -rate depends on the rent for the apartment and the income level of the tenant. Typically, the amount of subsidy needed is the difference between what a household can afford to pay ( no more than 30 percent of annual income) and the fair market rent for the unit. As of January 2021, the average rent for a one - bedroom unit in Highland was $ 1, 364. Given San Bernardino County' s 2020 State Income Limit was 48, 200 for a low- income, two -person household, two -person household renters earning 80 percent of the median family income for the area would pay approximately 34 percent of earnings on rent. A subsidy of approximately $ 159 per month ($ 1, 908 per year) would be required to meet the 30 percent limit. This number would reflect a lower -income level and would be higher for very low- income and extremely lowincome households. Such trends in rental housing prices in the City indicate that market rental units will not be affordable to lower -income households throughout the planning period. Further, if the units were improved and rents were significantly increased, a financial resource would be necessary to pay the difference between the higher rents and the market rents to maintain affordability.

Another option is new construction. The final cost of constructing deed -restricted affordable housing units depends on whether the developer needs to purchase land or whether the City can transfer the land at a subsidized price, and how well the private developer' s initial financial contribution can be leveraged with other funding sources. As no units have been identified as at -risk during the planning period, there is no further analysis regarding preservation and construction costs.

43. 9. 3 Preservation Resources
The City is committed to working with affordable housing property owners for solutions to prevent the expiration of affordability covenants. The City will develop relationships with property owners of existing

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affordable housing and with local affordable housing entities in an effort to attract interest and resources for preserving and constructing affordable housing units. Qualified entities are housing nonprofits that have been approved by the Community Development and Housing Department. To qualify, an entity must be able to manage the project, maintain affordability for at least 30 years or the remaining term of assistance, preserve the existing occupancy profile, maintain rents at a predetermined level of affordability, and agree to renew subsidies if available. Here are some local housing developers and managers that the City may contact:

BRIDGE Housing Corporation
California Housing Partnership Cooperation
Jamboree Housing Corporation
LINC Housing
Mercy Housing
Neighborhood Housing Services of the Inland Empire
National Core
There are a number of programs to assist the City and County of San Bernardino in increasing and improving their affordable housing stock. The following paragraphs discuss available programs that provide financial resources for affordable housing units.

The City is a member of the San Bernardino County Urban County Consortium and participates in countywide efforts to receive federal housing and community development funds. These funds are potential resources for affordable housing construction, rehabilitation, and preservation. The San Bernardino County Consolidated Plan is an assessment of existing affordable housing and community development needs that informs HUD, as part of a Federal fund awarding process granted to participating jurisdictions like the City, to create and rehabilitate affordable housing for lower -income households. The assessment evaluates investments from the Community Development Block Grant, HOME Investment Partnerships ( HOME), and Emergency Solution Grant programs. The Community Development Block Grant program was designed to improve low- and moderate -income communities through funding capital improvement and public services projects. The HOME funds are the primary funding available for the development of affordable housing. HOME funds are administered by the County of San Bernardino through a Notice of Funding Availability. Emergency Solution Grant programs assist individuals and families experiencing a housing crisis or homelessness to regain stability in permanent housing through No Place Like Home and California Emergency Solutions and Housing funding, and housing and legal assistance through the Housing and Disability Advocacy Program.

The Low -Income Housing Tax Credit program is the most significant financial resource to preserve and create new affordable housing by issuing tax credits for the acquisition, rehabilitation, or new construction of rental housing targeted to lower -income households. The California Tax Credit Allocation Committee oversees the application and allocation process for all Low -Income Housing Tax Credit projects. Applicants compete for the funds, which are prioritized based on location, affordability terms, housing needs, and project amenities.

A shorter -term solution to affordable housing stock limitation is the County San Bernardino' s Housing Choice Voucher program, which provides rent subsidies to extremely low- and very low- income households with a housing cost burden, or who are at risk of becoming homeless or being displaced.

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Voucher recipients rent housing from private rental owners and pay a portion of their income toward rent usually up to 30 percent of their income). The San Bernardino County Housing Authority subsidizes the difference in monthly payments to the owner. The waiting list for this program is often closed and only opens every several years because the Federal government only provides funding to serve a certain number of households. New households are assisted as households currently in the program move off the program. Serving families through attrition causes long wait times even if a family may be eligible.

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Appendix C: Constraints and Zoning Analysis
Table of Contents
HOUSING CONTRAINTS................................................................................................................................. 3 1 Governmental Constraints.................................................................................................................... 3

1. 1 General Plan.................................................................................................................................. 3

1. 2 Land Use and Development Code................................................................................................. 4

1. 3 Permitting Process........................................................................................................................ 7

1. 3. 1 Single -Family Homes............................................................................................................. 7

1. 3. 2 Accessory Dwelling Units...................................................................................................... 7

1. 3. 3 Multifamily Housing.............................................................................................................. 8

1. 3. 4 Mobile/ Manufactured Housing............................................................................................ 8

1. 4 Special Needs Housing.................................................................................................................. 9

1. 4. 1 Residential Care Facility........................................................................................................ 9

1. 4. 2 Boarding or Rooming Houses.............................................................................................. 10

1. 4. 3 Senior Housing.................................................................................................................... 10

1. 4. 4 Emergency Shelters, Transitional Housing, and Permanent Supportive Housing .............. 11

1. 4. 5 Single - Room -Occupancy Units............................................................................................ 13

1. 5 Facilitating Affordable Housing............................................................................................... 1443

1. 5. 1 Residential High Density Special ( HDS) Overlay and Greenspot Village & Marketplace SpecificPlan.................................................................................................................................... 1444

1. 5. 2 Lot Consolidation Incentives............................................................................................... 14

1. 5. 3 Inclusionary Housing Ordinance......................................................................................... 14

1. 5. 4 Density Bonus..................................................................................................................... 15

1. 6 Residential Development Standards........................................................................................... 16

1. 6. 1 Parking Requirements......................................................................................................... 21

1. 6. 2 Building Codes..................................................................................................................... 22

1. 6. 3 On- and Off -Site Improvements.......................................................................................... 22

1. 7 Development Fees...................................................................................................................... 23

1. 8 Permit Approval Process............................................................................................................. 25

1. 8. 1 Staff Review Permit......................................................................................................... 2624

1. 8. 2 Minor Design Review.......................................................................................................... 27

1. 8. 3 Major Design Review...................................................................................................... 292$

1. 8. 4 Conditional Use Permit.................................................................................................... 30

1. 8. 5 General Plan Amendment/ Zone Change........................................................................ 3234

1. 8. 6 Processing Time.................................................................................................................. 32

1. 8. 7 Special Business License Provisions: Crime Free Multiple Family Rental Housing Program 33 1. 9 Housing for Persons with Disabilities.......................................................................................... 34

1. 9. 1 Reasonable Accommodation.......................................................................................... 3534

1. 9. 2 Residential Care Facilities............................................................................................... 363§

1. 9. 3 Senior Housing and Facilities.......................................................................................... 363-5

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2 Market Constraints......................................................................................................................... 3736

2. 1 Availability of Financing.......................................................................................................... 3736

2. 1. 1 Construction Financing................................................................................................... 3736

2. 1. 2 Mortgage Financing........................................................................................................ 383.7

2. 2 Construction Costs and Construction Labor Shortage............................................................ 3939

2. 3 Land Costs............................................................................................................................... 4039

2. 4 Requests for Housing Developments at Reduced Densities................................................... 4039

2. 5 Length of Time between Project Approval and Applications for Building Permits ................ 4139 3 Environmental Constraints............................................................................................................. 424. 1

3. 1 Environmental Features.......................................................................................................... 424. 1

3. 1. 1 Biological Resources........................................................................................................ 424. 1

3. 1. 2 Archaeological Resources............................................................................................... 424-1

3. 1. 3 Water Resources............................................................................................................. 4241

3. 1. 4 Energy Conservation....................................................................................................... 4342

3. 2 Environmental Hazards........................................................................................................... 4342

3. 2. 1 Flooding........................................................................................................................... 4443

3. 2. 2 Landslides/ Slope Instability............................................................................................ 4443

3. 2. 3 Earthquake...................................................................................................................... 4443

3. 2. 4 Liquefaction.................................................................................................................... 4443

3. 2. 5 Wildfire............................................................................................................................ 4443

3. 3 Adequate Infrastructure Capacity........................................................................................... 4544

3. 3. 1 Dry Utilities...................................................................................................................... 4544

3. 3. 2 Sewer System.................................................................................................................. 4544

3. 3. 3 Water System.................................................................................................................. 464-5 4 Analysis of Local Efforts to Remove Constraints and Facilitate Affordable Housing ...................... 4746 5 Quantified Objectives..................................................................................................................... 5049 Tables
Table 1. Residential General Plan Land Uses................................................................................................ 3 Table 2. Residential Uses Permitted by Zoning District................................................................................ 5 Table 3. Residential Development Standards............................................................................................. 17 Table 4. Residential Parking Standards....................................................................................................... 21 Table 5. Residential Development Fees...................................................................................................... 24 Table 6. Permit Processing Times........................................................................................................... 3332 Table 7. Disposition of Home Loans ( 2019)............................................................................................ 38-.w Table 8. Summary of Quantified Objectives for 6th Cycle ( 2021- 2029)................................................. 5049

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HOUSING CONTRAINTS
Various factors influence the ability of the City of Highland ( City) to meet its housing goals. These include governmental constraints, such as land use regulations, and nongovernmental constraints, such as market and environmental factors. This appendix provides the requisite analysis of potential and actual market, governmental, and environmental constraints to the production, maintenance, and improvement of housing pursuant to State law.
1 Governmental Constraints
The General Plan Land Use Element sets forth land use designations to guide the location, type, and intensity or density of permitted uses of land. The Land Use and Development Code implements the General Plan by providing specific direction and development standards within each of the use categories. These land use controls can facilitate or limit certain types of development.

1. 1 General Plan
State law requires that each city have a General Plan that establishes policy guidelines for future development. The City of Highland General Plan is a long- range policy document that lays out the framework for all future growth and development within the City. The City of Highland adopted a comprehensive update of its General Plan in 2006. The Land Use Element describes the land use policies and designations used to guide physical development of the City through the location, distribution, and density of uses. Predominately a residential community, almost 60 percent of the City' s 11, 948 acres of land is planned for residential development.

As shown in Table 1, the Land Use Element describes seven land uses allowing housing, including a historic preservation district and one mixed commercial, office, and residential land use designation. The Planned Development ( PD) designation allows flexibility in development standards to encourage creativity and site -specific design. The Planned Development (PD) district is an opportunity for master planning without a Specific Plan, potentially providing a cost savings to the developer, buyer, and renter.

Table 1. Residential General Plan Land Uses
Land Use Designation Acres Description
Agricultural/ Equestrian 504 Rural and equestrian - oriented residential development at a maximum density of 2 units per acre.

Low Density 2, 500 Single- family detached homes, including mobile homes, at a maximum density of 6 units per acre.

Small -lot single-family detached or attached housing, mobile Medium Density 177 homes, and multifamily housing at a maximum density of 12 units per acre.

High Density 46 Multifamily housing at a maximum density of 18 units per acre.

High Density Special 58 Multifamily housing from 20 to 30 units per acre.

Historic Village Residential 32 Low -density residential development within the Historic Village District at a maximum density of 6 units per acre.

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Table 1. Residential General Plan Land Uses
Land Use Designation Acres Description
Mixed Use 54 Horizontal and vertical mixed -use housing types at a maximum density of 18 units per acre.

Planned Development 3, 708 Specific Plan areas in which housing types and densities may vary, but typically range from 5 to 12 units per acre.

Total 7, 079
The program provided by the General Plan Land Use Element establishes 15 goals for future development within the City. These goals are intended to do the following:

Plan for future growth
Provide clarity in land use guidance
Maintain a mix of development with urban, suburban, and rural character Create places for people to live, shop, work, learn, and recreate Protect and enhance Highland' s neighborhoods
Provide new housing opportunities
Strengthen commercial opportunities
Expand the employment base
Ensure land use compatibility
Preserve natural resources
The land use controls provided in the General Plan and Land Use and Development Code guide the development of new housing to meet existing and future needs, maintain the existing character, and improve neighborhoods and the housing stock.

1. 2 Land Use and Development Code
Zoning regulations are intended to ensure that development does not negatively affect community health, safety, and welfare. The City' s Land Use and Development Code regulates housing opportunities by establishing permitted uses and development standards. Several zoning districts respond to specific existing conditions, such as compatibility with the historic development in the original Highland Townsite, and appropriate design for busy transportation corridors.

Residential uses allowed in Highland are listed by Zoning District in Table 2. Uses permitted by right are indicated by the " P," conditionally permitted are indicated by the " C," and permitted uses that may require approval by the Community Development Director or designee are indicated by " SR." All permit types are defined in the Permit Approval Process Section.

New residential zoning districts, the Residential High -Density District ( R- 4), and the Residential High - Density Special Overlay ( HDS) were established in the City' s Land Use Development Code in 2011. These districts allow densities of 20 to 30 units per acre to facilitate the development of higher -density multifamily housing as part of a larger mixed -use community.

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1. 3 Permitting Process
Development review is the primary way to ensure that the construction of projects contributes in a positive manner to the community and quality of life. Residential development projects typically undergo several types of approvals. This section outlines the development review process for various types of housing (see Section 1. 8. 6, Processing Time, for average processing times for various project applications and reviews).

1. 3. 1 Single -Family Homes
Single- family detached homes are the most common housing type in Highland, making up approximately three-quarters of the entire housing stock. Single- family detached housing is permitted by right in four zoning districts ( A/ EQ, R- 1, VR, and EHV), and permitted following staff review in two districts ( R- 2 and R- 2C) and in separated multiple use projects in the MU District. Single- family attached housing, such as condominiums, is permitted in the R- 2 zone with a Conditional Use Permit ( CUP) and permitted in the R2C and R- 3 zones with a Staff Review Permit. Large single- family detached and single- family attached projects that require tract maps are ultimately reviewed by the Planning Commission. In 2009, the City merged the former Design Review Board with the Planning Commission in order to reduce the amount of time spent on design issues and to streamline the project approval process without diminishing quality. The Planning Commission now performs design review at the same time as other reviews that may be necessary depending on the permit at hand.

The City' s Planning Division coordinates a pre -application meeting between a project' s applicant and the Project Review Committee to provide applicants an early opportunity to present their project to the City before submitting a development application( s). This initial step has proven to be successful in the past because it discloses infrastructure or other issues that are more cost- effective to address early in the project design phase. Identifying potential issues prior to submitting a development application saves developers a significant amount of time and money. After the Planning Division determines the applications to be complete, they are routed to the Project Review Committee for their formal review and comments. Applications are also routed to utility companies and outside responsible agencies that have requested to be notified.

Once a project' s environmental review and public comment process have been completed, the Planning Division provides a copy of all the comments to the applicant for review and discussion with the City' s Project Review Committee. Once the comments have been reviewed by all parties, a public hearing before the City' s Planning Commission is scheduled. The applicant is provided with a copy of the public hearing notice and staff report with condition and findings of facts for their review. The conditions clearly outline all the requirements needed to record a final map, as well as any conditions related to the construction of the housing units that are necessary to ensure adequate public health, safety, and welfare.

1. 3. 2 Accessory Dwelling Units
Accessory dwelling units ( ADUs) may be detached from or attached to the primary single- family dwelling unit. ADUs are capable of providing housing below market prices, and often meet the special needs of young persons, older adults, and people with disabilities. In accordance with Assembly Bill 1866 Government Code Section 65852. 2), the City amended the Land Use and Development Code to make permitting ADUs in single- family zones a ministerial action that does not require public notice, public

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hearing, or discretionary approval. Understanding that ADUs provide opportunities for affordable housing without changing the City' s small- town character, Highland facilitates the development of attached and detached ADUs by permitting them in all residential zones.

Most recently, the City amended the Accessory Dwelling Units and Junior Accessory Dwelling Units Ordinance ( Section 16. 44. 180 of the City' s Land Use and Development Code) in 2021 to comply with several updates consistent with State law, Government Code Section 65852. 2. As part of Program 12 Accessory Dwelling Units, of the Housing Element, the City will submit the updated ordinance to the State Department of Housing and Community Development ( HCD) for their review and will incorporate amendments, as required by HCD. Further, the City will develop and adopt a program that incentivizes and promotes the creation of ADUs that can be offered at an affordable rent for extremely low, very low, low, or moderate - income households or households with special needs ( AB 671, 2019).

From 2015 to 2020, the City approved eight ADUs. Additionally, one ADU permit was placed on holder and another ADU permit expired. Based on this record, the City assumes that two ADUs per year could be permitted during the planning period. As the City' s older adult and college -age population increases, as is projected for the planning period, ADUs could help to provide housing for these populations as they can be an important housing resource for small, lower -income households.

1. 3. 3 Multifamily Housing
Multifamily housing, referred to as multiple -family, attached housing, makes up approximately 16 percent of the City' s housing stock. Multifamily housing is currently conditionally permitted in the three multifamily zones ( R- 2, R- 2C, R- 3) and in attached mixed -use structures in the MU District. Multifamily housing is permitted following staff review in separated multiple use projects in the MU District, and permitted by -right in the R- 4 zone and High -Density Special Overlay (HDS) subject to the City' s Staff Review Permit. The CUP process is the City' s opportunity to ensure compatibility with surrounding uses.

The CUP process can occur concurrently with a Design Review ( see Section 1. 8, Permit Approval Process). Multifamily housing projects in the R- 4 and HDS Districts are not subject to a CUP; however, they do require Major Design Review. The design review process considers the compatibility with design standards, such as setbacks, landscaping, and other basic aspects of project design, to ensure high - quality design.

The permitting procedure for a multifamily housing project is similar to that for a large, single-family detached or attached project. In the case of a hypothetical 50- unit multifamily project, the City' s Planning Division will coordinate a pre -application meeting between the applicant and the Project Review Committee to identify potential issues that should be considered early in the planning and design process.

1. 3. 4 Mobile/ Manufactured Housing
Single mobile home units placed on a permanent foundation, certified under the National Mobile Home Construction and Safety Standards Act of 1974 and constructed after October 1976, may be permitted

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on individual lots in the A/ EQ, R- 1, R- 2, and R- 3 zones, as specified in the City' s Land Use and Development Code ( Section 16. 40. 180, Mobile Home and Modular Home Requirements), following staff review approved by the Community Development Director. The review ensures that the units comply with State and local standards of the underlying zoning district. Mobile home subdivisions are permitted under staff review in the A/ EQ and R- 1 zones, and conditionally permitted in the R- 2 and R- 3 zones, while mobile home parks are conditionally permitted in the R- 1, R- 2, and R- 3 zones.

Pursuant to California Government Code Sections 65852. 3 and 65852. 7, certified mobile homes manufactured homes) on a permanent foundation that are built to the United States Department of Housing and Urban Development Code are considered the same as single- family dwellings and are permitted on all lots zoned for single- family homes. Such housing is subject to the same requirements e. g., planning, permitting, reviews) as site -built homes, except for certain architectural requirements.

The Government Code specifies that a mobile home park shall be deemed a permitted land use on all land planned and zoned for residential land use as designated by the applicable general plan, provided, however, that a city may require a use permit. Program 21, Mobile Home Preservation, requires a report detailing relocation and displacement for any proposed conversion or closure of a mobile home park.

The Highland Land Use and Development Code defines manufactured housing as a structure, transportable in one or more sections, which is built on a permanent chassis and is designed for use with or without a permanent foundation when connected to the required utilities, including travel trailers for floodplain management purposes, and provides guidelines for single mobile homes and modular homes or manufactured dwelling units within the City' s Land Use and Development Code, including design feature requirements consistent with California Government Code Section 65852. 3. The permitted uses table for residential districts in the Land Use and Development Code includes mobile home subdivisions and mobile home parks.

1. 4 Special Needs Housing

1. 4. 1 Residential Care Facility
State law prevents cities from imposing overly restrictive regulations on community care facilities. The Health and Safety Code ( Sections 1500 et seq.) requires that group homes serving six or fewer persons be ( 1) treated the same as any other residential use and shall be considered a residential use of property by a single family; (2) allowed in all residential zones; and ( 3) be subject to the same development standards, fees, taxes, and permit procedures as those imposed on the same type of housing in the same zone, and no CUP, zoning variance, or other zoning clearance shall be required that is not required of a family dwelling of the same type in the same zone. Local agencies must allow these licensed care facilities in any area zoned for residential use, and may not require licensed residential care facilities for six or fewer persons to obtain conditional use permits or variances that are not required of other family dwellings. Large residential care facilities ( those with seven or more residents) are subiect to local land use regulations and other restrictions such as conditional use permit requirements.

According to the City' s Land Use and Development Code, a residential care facility is a State -authorized, certified, or licensed facility that provides non -medical residential care, day treatment, therapeutic rehabilitative care, and adult day care, residential care for the elderly, transitional housing placement, substance abuse recovery or treatment facility, or foster family agency services for children or adults.

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According to the permitted uses table in the Land Use and Development Code, residential care facilities serving seven or more persons, called " Board and Care Facilities" in the uses table, are conditionally permitted in all multifamily zones ( R- 2, R- 2C, R- 3, R- 4, and HDS) and commercial zones ( CG, NC, PC, VC).

The CUP process is outlined in Section 1. 8.4, Conditional Use Permit. Requirements for discretionary permits may pose constraints to development but may be necessary for certain uses which could have an effect on the existing community. For example, Residential Care Facilities provide in- house treatment or rehabilitation programs on a 24- hour basis. These include drug and alcohol rehabilitation and recovery facilities. These facilities require a CUP in residential zones, as they are often a source of fear and concern for community members. The Planning Commission will only deny a CUP if the required findings cannot be met. Program 18, Residential Care Facilities, of the Housing Element includes an objective to amend the Zoning Code to permit residential care facilities serving six or fewer persons by right in all residential zones in accordance with the Welfare and Institutions Code Section 5116 and permit those serving seven or more in at least one zone without discretion.

To comply with the intent of fair housing laws and ensure clarity in the permitting process, the Housing Element Program 18, Residential Care Facilities, will update the Zoning Code to differentiate between residential care facilities serving six or fewer residents and those serving seven or more residents. The program will create separate definitions and permitting processes for the two types of residential care facilities, a4 r permit those serving six or fewer persons in all residential zones in which single-family homes are permitted, and permit those serving seven or more in at least one zone without discretion.

This will ensure that licensed facilities ( group homes/ residential care facilities) are allowed in residential zones consistent with State law.'^ r ^" ^
or ,^ r
heme ( six nr fe eF) and with a CUP f r i- b faeffilities

1. 4. 2 Boarding or Rooming Houses
Although a boarding or rooming house may provide housing to unrelated individuals, it is not considered a residential care facility. Highland' s Land Use and Development Code defines a boarding or rooming house as a building containing a dwelling unit where lodging is provided with or without meals for compensation for seven or more persons. For six or fewer occupants, the City defers to requirements in the State' s guidelines. A boarding or rooming house does not provide on- or off -site supportive services.

Boarding or rooming houses are conditionally permitted in the R- 2, R- 2C, R- 3, R- 4, and HDS residential zones, and may not be located within 500 feet of the same use. Furthermore, to prevent a concentration of parolees, no more than one Federal, State, or juvenile justice parolee shall be allowed to live in boarding or rooming house at any one time, except if a boarding or rooming house has 10 or more dwelling units, then there may be one additional Federal, State, or juvenile justice parolee for every 10 dwelling units. The location and parolee restrictions were enacted in response to public concerns about boarding and rooming housing affecting community safety and welfare.

1. 4. 3 Senior Housing
With Highland' s growing older adult population, it is important that a range of housing types located in well- resourced areas ( e. g., near transit, jobs, parks) are available to serve their special needs. These can include housing such as smaller and more affordable units ( including second dwelling units), senior housing, and various forms of care housing. Care housing that assists the special needs of older adults include senior independent living projects, residential care homes for older adults, congregate care, and convalescent care. Senior independent living projects are permitted with a Staff Review Permit in the

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A/ ECG, R- 1, VR, and EHV zones, and conditionally permitted in multifamily zones ( R- 2, R- 2C, R- 3, R- 4, and HDS) and the mixed use zone ( MU). Congregate care and convalescent care homes are conditionally permitted in multifamily, mixed use, and commercial zones. Residential care facilities, which can include residential care facilities for older adults per the City' s definition, serving seven or more persons, are conditionally permitted in multifamily zones ( R- 2, R- 2C, R- 3, R- 4, and HDS).

1. 4. 4 Emergency Shelters, Transitional Housing, and Permanent Supportive Housing
California Senate Bill ( SB) 2 ( Cedillo) was approved in 2007 with the goal to remove zoning barriers for emergency shelters and transitional and supportive housing, and provides direction in the ways in which local governments address housing for those experiencing homelessness or those at risk of homelessness. SB 2 is intended to strengthen existing Housing Element requirements to provide for the development of emergency shelters and transitional and supportive housing.

Emergency shelters are the first step in a continuum of care program designed to allow people experiencing homelessness a temporary place of stay. As defined by subdivision ( e) of Section 50801 of the Health and Safety Code, emergency shelter means housing with minimal supportive services for persons experiencing homelessness that is limited to occupancy of 6 months or fewer by a person experiencing homelessness, and where no individual or household may be denied emergency shelter because of an inability to pay.

SB 2 requires jurisdictions to identify a zone where emergency shelters are a permitted use without a CUP or other discretionary action. The identified zone( s) must have sufficient capacity to accommodate the needs, regardless of the demonstrated need, and have sufficient capacity to permit at least one year- round emergency shelter. State law ( Government Code Section 65583( a)( 4)) limits the development standards and locational restrictions that can be applied to emergency shelters.

Emergency shelters may only be subject to those development and management standards that apply to residential or commercial development within the same zone except that a local government may apply written, objective standards that include all of the following:
the maximum number of beds or persons permitted to be served nightly by the facility; sufficient parking to accommodate all staff working in the emergency shelter, provided that the standards do not
require more parking for emergency shelters than other residential or commercial uses within the same zone;
the size and location of exterior and interior onsite waiting and client intake areas; the provision of onsite management;
the proximity to other emergency shelters, provided that emergency shelters are not required to be more than
300 feet apart;
the length of stay;
lighting; and
security during hours that the emergency shelter is in operation.

Emergency shelters serving 25 persons or fewer are permitted in the business park ( BP) employment zone subject to approval of a Staff Review Permit application. The BP designation allows for light

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industry, research and development, office uses, and business and commercial uses that support the employees and clients of the area, and commercial uses requiring large parcels. Should an emergency shelter be provided in the BP district, residents would benefit from access to public transit, retail uses, and regional employment growth in nearby businesses. Residents will also be connected to other areas of the community and adjacent cities by buses. The local bus transit service provider, Omnitrans, operates two routes that serve this area ( Route 3 and Route 15). As outlined above, jurisdictions are permitted to limit the maximum number of beds or persons per shelter under State law. Regulating the number of beds or persons permitted, can potentially help prevent crowded shelter conditions. The importance of this was seen early in the Coronavirus ( COVID- 19) pandemic. Communities saw rapid transmission of COVID- 19 in homeless shelters particularly in congregate settings where people shared living and sleeping spaces, sometimes in beds, cots, or bunks that were very close to one another'.

Further, as fully analyzed below, the 25 person limit does not constrain the City' s ability to demonstrate that the zone where emergency shelters are allowed by right includes sufficient capacity to accommodate the need for emergency shelter identified in the most recent point -in -time count conducted before the start of the planning period.

There are approximately 270 acres in the City designated as BP, generally located along the southwestern City boundaryg A total of 116 acres in the BP designation are vacant with an average parcel size of 0. 74 acres. Given the development standards in the BP zone, including the minimum parcel size requirement, there are approximately 25 vacant sites that The average lat site is tely 20, 1509 SgUaFe feet and could potentially accommodate a multi -service facility. As discussed above, all of the sites are within a half mile of public transit lines and near existing commercial and business uses, providing access to opportunities. Taking into account the 25- person limit for emergency shelters, the 25 sites still provide a potential capacity for approximately 625 beds. Based on the 2020 point -in -time count described in Appendix B, Community Profile, there were a total of 78 unsheltered adults in the City, meaning that the City theoretically has more than sufficient capacity of sites to accommodate the need for emergency shelter.

As defined in California Government Code Section 65582( j), transitional housing includes buildings configured as rental housing developments but operated under program requirements that require the termination of assistance and recirculating of the assisted unit to another eligible program recipient at a predetermined future point in time that shall be no fewer than 6 months from the beginning of the assistance. Supportive housing is defined by California Government Code Section 56682(f) as housing with no limit on length of stay, that is occupied by the target population,' and that is linked to an on -site or off -site service that assists the supportive housing resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community.

Chapter 16.06, Definitions, of the City' s Land Use and Development Code defines " supportive housing" and " transitional housing" per the definitions provided above. However, according to the permitted uses table in the Land Use and Development Code, supportive and transitional housing are permitted with a 1 https // www urban ore/ urban- wire/ winter- here- covid- 19- limiting- shelter- capacity- what- will- it- mean- people- experiencing- homelessness 2 " Target population" means persons with low incomes who have one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health condition, or individuals eligible for services provided pursuant to the Lanterman Developmental Disabilities Services Act ( Division 4. 5, commencing with Section 4500, of the Welfare and Institutions Code) and may include, among other populations, adults, emancipated minors, families with children, older adults, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, and people experiencing homelessness.

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Staff Review Permit in the A/ EQ, R- 1, VR, and EHV zones and conditionally permitted in multifamil zones ( R- 2. R- 2C. R- 3. R- 4. and HDSI.

Gens* stent w " To remove or mitigate constraints that may exist related to zoning or permits for supportive and/ or transitional housing and to comply with Government Code Section 65583, transitional housing and supportive housing shall be considered a residential use of property and shall be subject to the same development standards and permitting processes as the same type of housing in the same zone and in compliance with the occupancy limitations of Title 24 of the California Code of Regulations.

Under California Assembly Bill ( AB) 2162, supportive housing meeting specific standards shall be a use by right in all zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses. Additionally, no minimum parking may be required for units occupied by supportive housing residents if the development is located within 0.5 miles of a public transit stop.

The City updated its Land Use and Development Code in 2013 to comply with State law; however, there have been several updates to State law, as outlined above. As such, the Housing Element includes Program 19, Emergency Shelters, Transitional Housing, and Permanent Supportive Housing, to permit transitional and supportive housing consistent with State laws and to amend the City' s Emergency Shelters Ordinance ( Section 16. 44. 270, Emergency Shelters) to comply with parking requirements set forth by AB 139, Quirk -Silva. Program 28, Low Barrier Navigation Centers, includes an update to the Land Use and Development Code to provide, by -right, approvals exempt per the California Environmental Quality Act ( CEQA) to Low -Barrier Navigation Centers3 meeting specific standards in areas zoned for mixed uses and nonresidential zones permitting multifamily uses, consistent with AB 101' s requirements for Low -Barrier Navigation Centers.

1. 4. 5 Single -Room -Occupancy Units
Another potential source of housing for people experiencing homelessness or formerly experiencing homelessness are single -room -occupancy units. Single -room -occupancy units are very small, attached units intended for no more than one or two people. An agency or organization generally oversees the project and provides ongoing supportive services to promote self- sufficiency.

The City' s Land Use and Development Code does not currently permit single - room occupancy units.

Through Program 19, Emergency Shelters, Transitional Housing, Permanent Supportive Housing and Single Room Occupancy, the City will amend the Zoning Code to identify a process by which single -room occupancies ( SRO) can be permitted to further increase housing opportunities for extremely -low income households.

Low Barrier Navigation Center" is defined as a housing first, low -barrier, service -enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing.

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1. 5 Facilitating Affordable Housing

1. 5. 1 Residential High Density Special ( HDS) Overlay and Greenspot Village & Marketplace Specific Plan
The City established a Residential High Density Special ( HDS) Overlay in 2011 on approximately 52 acres zoned as Planned Development (PD). The HDS Overlay allows the permitting of up to 650 multifamily units at a minimum density of 20 units per acre and a maximum density of 30 units per acre. The HDS Overlay area is generally bound by Greenspot Road on the south, Eucalyptus Avenue on the north, Boulder Avenue on the east, and the City Creek wash basin on the west. The 52 acres is now located entirely within the Greenspot Village & Marketplace Specific Plan area, adopted in 2013.

The Greenspot Village & Marketplace Specific Plan is a master - planned, mixed - use development located within the area identified in the City' s General Plan Land Use Element as the " Golden Triangle Community Policy Area." The Specific Plan consists of three planning areas. Planning Area 1 allows for commercial uses; Planning Area 2 allows for residential uses; and Planning Area 3 permits a mix of residential, commercial, entertainment, governmental, and professional office uses. The total number of dwelling units between Planning Areas 2 and 3 may not exceed 800. Planning Areas 2 and 3 allow development at density ranges of 20 to 30 and 18 to 40 dwelling units per acre and permit 500 to 700 units and 100 to 300 units, respectively; within that limit, dwelling units may be transferred between Planning Areas 2 and 3. As of November 2021, there are approximately 37 acres of vacant land within Planning Areas 2 and 3, providing a generous amount of land available for residential development As fully discussed in Appendix E, Sites Analysis and Inventory, the available vacant land coupled with the higher densities permitted, purely residential uses and range in housing types allowed and flexibility in standards and requirements afforded by the Specific Plan, remove and reduce constraints for residential uses and aim to facilitate affordable housing development.

1. 5. 2 Lot Consolidation Incentives
Lot consolidation can increase the efficiency of land use and create the critical mass needed for a quality multifamily housing project. The City has identified numerous vacant and underutilized parcels that have the potential to accommodate multifamily projects. Their development potential could be improved through lot consolidation.

Although the development community is aware of the inherent benefits of acquiring larger sites, the City seeks to promote this process. Through the implementation of Program 23, Lot Consolidation Incentive, of the Housing Element, the City is committing to providing expedited processing for the consolidation of lots identified in Appendix E, Sites Analysis and Inventory, as having the potential to accommodate lower -income households.

1. 5. 3 Inclusionary Housing Ordinance
The City' s Land Use and Development Code' s Inclusionary Housing Ordinance aims to facilitate the development and availability of housing affordable to a broad range of households with varying income levels within the City. It provides guidelines for the production of affordable housing at moderate-, low-, and very low- income levels; payment of an in -lieu fee; or dedication of land for affordable housing.

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All new residential development projects within the City must dedicate at least 15 percent of the units for affordable housing. Restricted, for sale units must be sold to low- and moderate -income households.

Rental projects must rent at least 10 percent of the units to very low- income households, with the remaining 5 percent of affordable units rented to low- or moderate - income households. In exchange for the construction of affordable units, the City allows unit size reduction and different interior finishes for affordable units, as long as they are of durable quality and consistent with the current California Building Code.

In lieu of constructing all or any affordable units on site, a developer may pay an affordable housing in - lieu fee of $3, 750 per unit to the City. In lieu of building inclusionary units, the developer may also choose to dedicate land within the City to the City. Dedicated parcels must be suitable for the construction of inclusionary units and equivalent or greater in value than what would be produced by applying the City' s in -lieu fee to the project. All in -lieu fees are deposited in an inclusionary housing fund to be spent on affordable housing development and programs.

The City provides regulatory relief for developers of sites that cannot accommodate affordable units. If the City determines that providing on -site inclusionary housing is infeasible, the developer may construct affordable units on another site within the City prior to or concurrently with construction of the on -site project. Should a developer provide more affordable units than required by the inclusionary ordinance, the developer may transfer credit for those affordable units to their next project in Highland or to another developer. However, the Inclusionary Housing Ordinance provides requirements that are inconsistent with the minimum density bonus and incentives outlined in the State' s Density Bonus Law.

Program 4, Inclusionary Housing, of the Housing Element includes a program to continue the City' s Inclusionary Housing Ordinance to provide funding for affordable housing preservation, rehabilitation, and construction.

During the 2014- 2021 Housing Element cycle, no inclusionary housing units were constructed. In lieu of construction, developers opted to pay the affordable housing in -lieu fee of $3, 750 per unit. As of January 2021, the current balance from in -lieu fees is $ 569,000, and the funds have not yet been used for preservation or construction of affordable housing. However, the City plans on using the funds to construct new affordable units at the Housing Authority' s property at 7433 Central Avenue. The anticipated proposal will develop approximately 90 to 110 affordable dwelline units on 3. 75 acres.

1. 5. 4 Density Bonus
A density bonus is an entitlement to build additional residential units above the maximum number of units allowed per the Municipal Code in exchange for providing affordable housing specified by as Government Code Sections 65915- 65918.

For projects consistent with the applicable affordable requirements, jurisdictions must grant one density bonus, and, if requested by the applicant, incentives or concessions, and waivers or reductions of development standards depending on the percentage of affordable units. Concessions and incentives include reductions in site development standards or a modification of Zoning Code or architectural design requirements, such as a reduction in setback or minimum square footage requirements, approval of mixed -use zoning, or other incentives or concessions that result in actual cost reductions. In accordance with State law, projects that meet the minimum criteria for a density bonus are entitled to

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at least one concession and may be entitled to as many as four concessions depending on the amount of affordable housing provided.

The City' s Land Use and Development Code ( Section 16.40. 090, Development Density) outlines the density bonuses and incentives or concessions that are available to affordable housing and qualifying residential projects; however, the City' s Density Bonus Ordinance, approved in 2013, is no longer in compliance with the State' s latest Density Bonus Law.

Under AB 2345 amending code Section 35915, which took effect on January 1, 2021, the maximum available density bonus for projects not composed exclusively of affordable housing increased from 35 to 50 percent. To receive the top bonus, a project must comply with unit replacement requirements and set aside at least 24 percent of units for low- income households, 15 percent of units for very low- income households, or 44 percent of for -sale units for moderate -income households. Bonuses between 35 and 50 percent will be granted on a sliding scale, while current affordability requirements to obtain a lesser bonus will remain unchanged. The City' s Density Bonus Ordinance does not meet the current State law maximum density bonus of 50 percent.

Program 6, Density Bonus, will update the City' s Density Bonus Ordinance to comply with the current State Density Bonus Law, including the provision for an increased bonus for 100 percent affordable developments and student affordable housing.

1. 6 Residential Development Standards
The General Plan Land Use Element establishes the maximum density for housing and where it can generally be located within Highland. The Land Use and Development Code provides more specific residential development standards that determine building height, density, setbacks, parking, and other requirements. Development standards tailored to each zoning district and certain specific uses are provided to ensure quality design to protect the health, safety, and welfare of the public, as well as enhance the appearance of the community. Development standards improve the quality and livability of housing development in Highland.

Table 3 lists the minimum acceptable standards for development within the City' s residential districts to ensure safe and attractive development without hindering the production of housing.

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1. 6. 1 Parking Requirements
Parking requirements must relate to the housing type to provide adequate and appropriately located parking facilities. Adequate parking for residential projects contributes to the value of a project, the safety of residents, its appearance, and livability. However, excessive parking standards that do not reflect actual parking demand can unduly increase development costs by reducing the potential land availability for additional units or project amenities. Cities statewide are also finding that parking is a contributing constraint to building affordable housing, reflective in the cost of one parking space.

Reductions in parking requirements are currently made possible through parking studies for senior housing types, and the Community Development Director may approve reduced parking requirements for projects that incorporate affordable units but do not qualify for density bonus incentives.

Additionally, Program 33, Reduced Parking Requirements, will provide a process by which parking requirements can be reduced for religious institutions in exchange for housing development. Table 4 displays City residential parking requirements.

Table 4. Residential Parking Standards
Use Minimum Off -Street Requirements
Single -Family Detached' Resident parking: 2 enclosed garage spaces Guest parking: If guest parking is not permitted on the street, then one visitor space per unit is required within 100 feet of each unit' s frontage and cannot be tandem Second Units Resident parking: 1 additional off-street parking space, tandem allowed, allowed in the front yard setback
Single -Family Attached Resident Parking
and Multifamily ( R- 2, R- Studio: 1 covered or garage space assigned to each unit 2c, R- 3) 2, 3 1 bedroom: 1 covered or garage space, and . 5 uncovered space 2 or more bedrooms: 1 covered or garage space and 1 uncovered space Guest parking: On -street parking can count for visitor parking if the spaces are within 250 feet of each unit' s frontage, otherwise 0. 5 uncovered space per unit is required Multifamily ( R-4) 4,5 Resident Parking
Studio and 1 bedroom: 1. 5 per unit (at least 1 space within a garage or carport) 2 bedrooms: 1. 9 per unit
3 bedrooms: 2. 1 per unit
4 bedrooms: 2.4 per unit
Guest parking: 0.3 spaces per unit
Senior Housing Resident parking: 1 covered space per unit Guest parking: 0. 25 space per unit can be uncovered
Senior Congregate Cares Resident parking: 0. 5 covered spaces per unit or as determined by the Planning Commission. For multiple -family units, the parking shall be within 150 feet of the dwelling it serves Guest parking: 0.25 space per unit (can be uncovered)
Mobile Home Parks and Resident parking: 2 spaces per unit, tandem allowed Subdivisions Guest parking: 1 space for each 5 units or fraction thereof Model Home 3 spaces per model home plus 1 space per salesperson Com lexes7
Source: City of Highland Land Use and Development Code, 2020. 1: Within the VR district, no more than a two -car space and no less than a one -car space shall be provided within a garage, and the exterior garage door shall be a minimum of 45 feet from the front property line. 2: For R- 2 and R- 2C districts, covered spaces may be required to be in enclosed garage. If it is not adjacent, the garage shall be within 150 feet of the unit being served.
3: Covered spaces for apartment buildings are garage spaces. 4: Minimum of one parking space shall be covered within a garage or carport. 5: Guest spaces may be uncovered.

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6: Applicant shall submit a parking study for reduced parking standards. 7: On -street parking adjacent to the model home complex may be counted toward the parking requirement if it is found that on -street parking will not impact residential parking and will not obstruct traffic flow.

1. 6. 2 Building Codes
Building and safety codes regulate construction and design methods to protect public health, safety, and welfare. However, these codes have the potential to constrain the development of housing. Highland has adopted and enforces the 2019 California Building Code. Except for seismic standards and some additional requirements for fire hazards, the City' s building codes do not impose additional requirements that would materially raise the cost of housing. These types of improvements are common for all cities in San Bernardino County.

Code enforcement is a critical component of retaining quality neighborhoods and residential structures.

The City employs full-time building inspectors and code enforcement officers to examine properties. As part of the City' s residential rental enhancement program, the owner or occupant of any residential rental unit may request that the City conduct both an interior and exterior inspection of said residential rental unit( s). Inspections may be based upon, but are not limited to, receipt of complaints from occupants, local agencies, or other third parties.

The City' s rental inspection program includes a self -certification inspection process conducted by the owner of a residential rental unit, and subsequent right- of-way inspection from the public right- of-way to certify that health and safety, building code, and fire code violations do not exist on the rental unit.

The program ensures rental housing is well -maintained, safe, and adequate for habitation. Program 2, Residential Rental Enhancement and Rehabilitation, will continue to educate landlords and property owners about compliance with applicable City codes, procedures of the Residential Rental Enhancement Program, and how to notify code enforcement of any violations. The City will continue to provide this program to ensure that rental properties are maintained and that landlords have the resources they need to ensure their properties remain safe for tenants. The City will also add to tenant screening training to provide guidance on fair housing to ensure that tenant screenings do not have a disproportionate negative effect on protected groups.

1. 6. 3 On- and Off -Site Improvements
The City of Highland requires that adequate access, landscaping, lighting, water, and sewer improvements accompany residential development or the expansion of existing residential projects.

Typical off -site improvements include curb, gutter, and sidewalk installation, and the undergrounding of existing overhead utility lines. As a condition of approval, the City may require the dedication of improvements, such as rights -of -way, easements, and the construction of reasonable on- and off -site improvements, to serve the project. These types of improvements are common for all cities in San Bernardino County. Therefore, these on- and off -site improvement standards would not make it less financially feasible to build housing in one jurisdiction over another.

1. 6. 3. 1 Streets
All residential projects must provide appropriate roadways consistent with the City' s Circulation Element and adopted road standards.

Collector streets require a minimum 40 feet wide curb -to -curb and are, generally, 44 feet, curb -to -curb, within 66- foot rights -of -way. Residential local streets generally require a 36- foot- wide right- of-way. The City does not require infill projects to provide road improvements beyond those necessary for safe access. This reduces the cost of infill housing development, a savings that may be passed on to the

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future buyer or renter. For any area of the City, additional improvements, easements, and other dedications may be identified during Site Plan Review.

1. 6.3. 2 Curbs, Gutters, and Sidewalks
While much of west Highland is developed with curbs, gutters, and sidewalks, there are some infill sites without such amenities.

Greenfield sites on the east side are also often in need of such improvements. All new residential development is required to provide a public sidewalk system with curbs and gutters unless deemed unnecessary by the Planning Commission. Public sidewalks are adjacent to public streets and have a minimum width of 5 feet.

Interior walkway systems may have varying widths, with a minimum width of 4 feet inincumbered. The cost of these improvements increases development costs but are necessary to facilitate pedestrian access and movement in urban areas of the City, and to enhance the safety of pedestrian traffic.

1. 6.3. 3 Water, Sewer, and Storm Drains
Consistent with State law, MS4 Permits._San _Bernardino County Hvdrology Manual criteria, or local drainage master plan, as applicable, all projects must demonstrate the ability to meet water, sewer, and drainage requirements consistent with San Bernardino Flood Control District' s Comprehensive Storm Drain Plan. Fees and infrastructure requirements are established by the East Valley Water District EVWD) and similar for all communities in the region. Careful site design and location can reduce or mitigate the associated cost of these improvements. For example, vacant land in an infill area could provide affordable housing where there is existing and adequate water, sewer, and drainage infrastructure.

1. 7 Development Fees
A variety of fees and assessments are charged by the City and other agencies to cover the cost of processing development permits and providing local services. These fees are necessary to ensure quality project review and to cover costs associated with the impact of new housing. Development fees and exactions increase the cost of development. These costs are passed down to the homeowner and renter, reducing the affordability of housing.

Community development and engineering fees are established to cover the cost of staff review. Without entitlement processing fees, the City would be unable to provide quality review of each project, resulting in inappropriate or inadequate development. These fees offset the City' s development review costs and are not designed to increase the cost of development. The affordable housing fee is a per -unit fee that may be paid by the applicant in lieu of providing affordable housing, as discussed in Section

1. 5. 3, Inclusionary Housing Ordinance.

When processing a Major Design Review and CUP concurrently, the City provides relief to the applicant by only charging one deposit up -front. The City only takes a deposit for the CUP and applies any unused funds from the CUP deposit to cover the design review. This prevents the applicant from spending a financial resource earlier than necessary.

Development impact fees are charged on a per -unit basis to provide funds to offset the anticipated impacts of population growth. New housing, and therefore more residents, may result in an increase in vehicle trips, park usage, school enrollment, and emergency service calls. Development impact fees are carefully created to ensure that quality services and facilities are provided to Highland residents without

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unduly burdening development. The City annually reviews its development impact fees to ensure the fees are fair and adequate. Table 5 shows fees charged for new housing projects in Highland.

Table 5. Residential Development Fees
Fee Single -Family Attached Single -Family Attached/
Multifamily
Minor Project (three or fewer dwelling units)
Community Development Fees
Inclusiona Housing 3, 750. 00 3, 750. 00
Staff Review Permit 45. 00 45. 00
Minor Design Review — Fixed Fee 3, 450. 00 3, 450. 00
Minor Conditional Use Permit — Fixed Fee 1, 425. 00 1, 425. 00 Community Development Fees/ Deposit Per Unit 8, 670. 00 Engineering Fees'
Parcel Map Review 54 lots 2 $ 5, 300. 00 $ 5, 300. 00
Impact Fees
Law Enforcement 276. 23 436. 83
Fire Suppression 981. 10 318. 42
Local Circulation System 4, 582. 61 3, 058. 86
Regional Circulation System 13, 289. 35 8, 872. 35
Regional Flood Control 1, 068. 24 457. 13
General Facilities, Vehicles, and Equipment 1, 224. 67 1, 224. 67 Library 1, 126. 68 1, 084. 50
Community Center 1, 404. 31 1, 351. 22
Park Land Acquisition & Park Facilities Development 4, 573. 40 4, 400. 64 Total Fees Per Unit 3 37, 196. 64 29, 874. 61
Major Project ( more than three units)
Community Development Fees
Inclusiona Housing 3, 750. 00 3, 750. 00
Major Design Review Deposit 2, 4 8, 500. 00 8, 500. 00
Major Conditional Use Permit Deposit 2, 4, 5 11, 100. 00 11, 100. 00 5 Community Development Fees/ Deposit Per Unit 23, 350. 00 Engineering Fees'
Parcel Map Review 54 lots 2 5, 300. 00 5, 300. 00
Final Tract Map Review >_ 5 lots) 2, 4 15, 300. 00 15, 300. 00 Impact Fees
Law Enforcement 276. 23 436. 83
Fire Suppression 981. 10 318. 42
Local Circulation System 4, 582. 61 3, 058. 86
Regional Circulation System 13, 289. 35 8, 872. 35
Regional Flood Control 1, 068. 24 457. 13
General Facilities, Vehicles, and Equipment 1, 224. 67 1, 224. 67 Library 1, 126. 68 1, 084. 50
Community Center 1, 404. 31 1, 351. 22
Park Land Acquisition & Park Facilities Development 4, 573. 40 4,400. 64 Total Fees Per Unit 3 72, 476. 64 65, 154. 61

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Source: City of Highland Planning Division, 2020.

1. Some engineering fees not included, such as grading plan check and grading inspection, because fee is based on project specifics such as a dollar amount per cubic yard of soil moved.

2. RCS fully burdened hourly rate for all personnel involved, plus any out- of-pocket expenses for contract personnel, special equipment or supplies, other State or county fees applicable against an initial deposit.

3. Total fees per unit, including community development fees/ deposit per unit, engineering fees, and impact fees listed in this table.

4. For projects that are deemed to be less complex after review by the DRC, the amount of the initial deposit can be reduced accordingly by the Community Development Director.

5. Major Conditional Use Permit Review Deposit will not be needed for projects on multifamily sites identified in the Housing Element as having potential to accommodate the lower -income Regional Housing Needs Allocation.

1. 8 Permit Approval Process
Highland' s permitting process is designed to ensure high -quality and aesthetically pleasing development that is compatible with adjacent uses and the City' s rural charm. Development and design review fees, as well as the time these processes take, increase the cost of constructing new housing or rehabilitating existing units. To ensure that the permit approval process is not overly burdensome, the City established the " Come Home to Highland" program, which commits the City to being an active partner in providing housing. This program serves as an action plan for City staff to follow when reviewing all commercial and residential development projects. The program is intended to do the following:

Improve and enhance Highland through the promotion of its residential lifestyle and family - oriented community
Encourage housing maintenance, rehabilitation, development, and occupation Encourage cooperation between City government, local service providers, and residents in facilitating responsible growth
The City of Highland is committed to the following action plan to facilitate and streamline the development review process:

The fees to process entitlement should be deposit, and an accounting of time by which staff processes the entitlement shall be provided to the project applicant within 30 calendar days of the project' s conclusion.

Pre -application meetings should be offered free of charge.

Upon acceptance of an application for an entitlement, the Community Development Department and Public Works Department shall bring the application before the appropriate reviewing body within 90 days of acceptance, barring special environmental, traffic, or similar technical report requirements.

Fixed fees for plan checking and inspection services upon the issuance of permits.

First plan check shall take no more than 2 weeks, and if determined to take longer, staff shall notify applicant as to the reasons for the delay.

Three levels of decision -making bodies in the City govern the development review process: The Community Development Department, the Planning Commission, and the City Council.

Applicants are encouraged to submit a pre -application to meet with City staff to discuss a project prior to submitting a formal application. This process provides the applicant with an opportunity to make changes that will ultimately save time and money by having a complete application from the start. When an application is determined complete (within 30 days, as required by the Permit Streamlining Act), the Planning Division indicates whether or not a use requires discretionary review. The " Come Home to Highland" program guarantees that any request for an entitlement that requires approval by the Planning Commission be presented to the necessary body within 90 days of the application being deemed complete ( excluding time for CEQA review). Limiting processing time reduces the impact of

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design review and other forms of discretionary review. There are several types of review necessitated by certain project characteristics, as described below.

1. 8. 1 Staff Review Permit
A Staff Review Permit is a review of the project use to ensure compatibility with the City' s land uses and development standards. Approval is determined by the Community Development Director or their designee ( typically the City' s Planning Technician). The Staff Review Permit is processed concurrently with the Minor Design Review process, when applicable. Following a review of the application, the Community Development Director shall prepare a written decision which shall contain the findings of fact upon which said decision is based. A Staff Review Permit application may be approved in whole or in part, with or without conditions, if the following findings can be made:

1. The proposed use will be arranged, designed, constructed and maintained to be compatible with the character of the area as intended by the general plan, and is consistent with the goals objectives, policies and programs of the general plan;

2. The proposed use is permitted within the applicable district, or specific plan, and complies with all applicable zoning provisions;

3. The proposed use, together with applicable conditions, will not be detrimental to the public health, safety or welfare or materially incurious to properties or improvements in the vicinity;

4. The architecture and landscaping proposed observe community standards as described in the adopted general plan, ensuring visual relief protecting the character of adjacent development and providing an attractive environment for the public' s enjoyment;

5. The proposed use would not result insignificant impact to the environment;

6. All other state and federal permits have been obtained; and

7. The site is reasonably safe from flooding.

In approving a Staff Review Permit, the Community Development Director shall require that the use and development of the property conform with the approved site plan, architectural drawings and statements submitted in support of the application. Such conditions may include, but are not limited to the following:

1. Setbacks, yard area and open spaces;

2. Fences, walls, and screening;

3. Parking, parking areas and vehicle ingress and egress;

4. Landscaping and maintenance of landscaping and grounds;

5. Regulation of signs;

6. Control of noise, vibration, odor and other potentially dangerous or obiectionable elements;

7. Limits on hours of operation;

8. Time period for compliance with conditions of approval;

9. Perimeter roads and properly maintained fuel modification areas with fire hazard zones I and II• and

10. Other conditions as may be determined to assure that development will be in accordance with the intent and purposes of this title.

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Modification or revision of an approved Staff Review Permit may be requested by the applicant. A modification or revision to an approved staff review permit may include, but shall not be limited to, change in conditions, expansion, intensity, or hours of operation. The requested modification or revision shall be processed in the same manner as the on_ginal Staff Review Permit.

The Staff Review Permit approval by the Community Development Director or designee is final unless appealed to the Planning Commission. The Planning Commission' s determination is appealable to the City Council.

The Staff Review Permit process is not found to be a constraint to development. It provides an objective and necessary process to ensure consistency with the City' s General Plan and Zoning Ordinance and the public health, safety and welfare.

1. 8. 2 Minor Design Review
The Planning Division provides this forme minor review administratively for permitted housing projects with three or fewer units to ensure compliance with City' s land use and development standards. The Planning Division makes standard findings regarding project design, which include compliance with adopted residential design standards and consistency with the City' s General Plan Land Use Element and Community Design Element.
appealed W the olaa.-... ing Gemmissien. The G-A-I llmlunity Develop Rt DiFerA,." Fnay -. I t h• h eF
tier efe F des , to the Dl-, R Ding r'^..•.missi^., for ae-tie.m The WaRning COMMOSSuAR' l; dPtPrm; R;#; An ran then be appealed te the City CeunEil.

An application for minor design review is required for residential projects with three or fewer dwelling units, commercial, industrial and institutional projects not subject to design review which involve the issuance of a building permit for construction or reconstruction of a structure which meets one or more of the following criteria:

1. Structural additions which do not result in an increase of more than 50 percent of the floor area of the existing building;

2. The construction and/ or placement of silos, satellite dishes, antennas, private water tanks, roof - or ground -mounted equipment visible from the public street or similar structures and equipment on existing developed properties as determined by the community development director;

3. Signs as required by Chapter 16. 56 HMC;

4. Residential construction involving three or fewer dwelling units; or

5. Landscape plans for proiects requiring minor design review.

The Community Development Director is authorized to approve or deny applications for design review and to impose reasonable conditions upon such approval, subject to the right of appeal. Conditions may include, but shall not be limited to, requirements for open spaces, screening and buffering of adjacent properties, fences and walls; requirements for installation and maintenance of landscaping and erosion control measures, regulation of vehicular ingress and egress, and traffic circulation; regulation of signs; grading requirements; regulation of hours of operation; establishment of development schedules or time limits for performance or completion of improvements; and such other conditions as the Community Development Director may deem necessary to ensure compatibility with surroundine uses:

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to preserve the public health, safety and welfare; and to enable the Community Development Director to make the findings necessary for approval. The Community Development Director may at his or her option refer any minor design review to Planning Commission for action. Any determination of the community development director may be appealed to the planning commission within 10 calendar days of the community development director action.

Design Review and Minor Design Review Criteria
The criteria for major and minor design review is based on the following:

1. The design and layout of the proposed development is consistent with the applicable elements of the general plan; any city design guidelines which may be established; and any adopted architectural criteria for specialized areas such as designated historic districts, theme areas specific plans or planned developments.

2. The design and layout of the proposed development will not unreasonably interfere with the use and enjoyment of neighboring existing or future developments, and will not create a traffic or pedestrian hazard.

3. The design of the proposed development is compatible with the character of the surrounding neighborhood and will maintain a harmonious, orderly and attractive development.

4. The design of the proposed development would provide a desirable environment for its occupants and visiting public as well as its neighbors through good aesthetic use of materials texture and color that will remain aesthetically appealing and will retain a reasonably adequate level of maintenance.

Design Review and Minor Design Review Findings
The Plann;^^ (;^^,^^ m« i^^ 9F the Community Development Director shall make the following findings before approving a d ^^ Fev* ew^ F minor design review application:

1. That the proposed project is consistent with the general plan or specific plan;

2. That the proposed use is in accordance with the obiectives of this title, and the purposes of the land use district in which the site is located;

3. That the proposed use is in compliance with city design and landscape standards and criteria; and

4. That the proposed use, together with the conditions applicable thereto, will not be detrimental to the public health, safety, or welfare or will not be materially incurious to properties or improvements in the vicinity of the site.

Adjacent property owners shall be notified by mail of the date, time and nature of the design review at least 10 days prior to the public meeting. Any determination of the Community Development Director may be appealed to the Planning Commission within 10 calendar days of the Community Development Director action.

These findings are consistent with those permitted in accordance with 65589. 5( d) and are necessary to ensure consistency with the City' s General Plan and Zoning Ordinance. Through Program 30, Objective Design Standards, the City will ensure that any newly developed design standards are objective, consistent with the requirements of SB 330, 2019. Further, through Program 8, By -Right Development on Previously Identified Sites, the City will permit eligible developments without discretionary action.

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Further, as detailed in Program 19, Emergency Shelters, Transitional Housing, and Permanent Supportive Housing, and Program 28 Low -Barrier Navigation Centers, the City will ensure that these uses are permitted as detailed, without discretionary action.

1. 8. 3 Major Design Review
Major Design Review applies to new housing projects consisting of four or more units. Major Design Review is performed by the Planning Commission. Major Design Review provides the Planning Commission with an opportunity to assess a project for consistency with the applicable elements of the City' s General Plan and design guidelines, and identify potential design issues that may detract from the aesthetics, health, and safety of neighborhoods. These projects will be reviewed for consistency with the design and development standards provided in the Land Use and Development Code, General Plan Land Use Element, and Community Design Element. Planning Commission review takes place during the time period the development application is routed for agency comments and/ or the CEQA process, thus minimizing overall processing time for the project. Planning Commission approval is final unless appealed to the City Council.

An application for design review by Planning Commission is required for all commercial, industrial institutional, and residential projects of four or more dwelling units involving the issuance of a building permit for construction or reconstruction of a structure which meets the following criteria:

1. New construction on vacant property;

2. Structural additions which are equal to 50 percent or more of the floor area of existing on -site buildings;

3. Reconstruction projects which are equal to 50 percent or more of the floor area of existing buildings;

4. Signs as required by the sign regulations, Chapter 16. 56 HMC;

5. Proiects involving a substantial change or intensification of land use, such as the conversion of an existing residential structure to an office or commercial use;

6. Outdoor storage areas;

7. Landscape plans for projects requiring design review; or

8. Maior public works projects, as feasible.

Planning Commission is authorized to approve or deny applications for design review, and to impose reasonable conditions upon such approval, subject to the right of appeal. Conditions may include, but shall not be limited to, requirements for open spaces, screening and buffering of adjacent properties, fences and walls; requirements for installation and maintenance of landscaping and erosion control measures, regulation of vehicular ingress and egress, and traffic circulation; regulation of signs; grading requirements; regulation of hours of operation; establishment of development schedules or time limits for performance or completion of improvements; and such other conditions as Planning Commission may deem necessary to ensure compatibility with surrounding uses; to preserve the public health, safety and welfare; and to enable Planning Commission to make the findings necessary for approval.

The Planning Commission shall make the following findings before approving a major design review application:

1. That the proposed project is consistent with the general plan or specific plan;

2. That the proposed use is in accordance with the objectives of this title, and the purposes of the land use district in which the site is located;

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3. That the proposed use is in compliance with city design and landscape standards and criteria; and

4. That the proposed use, together with the conditions applicable thereto, will not be detrimental to the public health, safety, or welfare or will not be materially incurious to properties or improvements in the vicinity of the site.

Property owners within 300 feet of the project shall be notified by mail of the date, time and nature of the design review at least 10 days prior to the public meeting.

These findings are consistent with those permitted in accordance with California Government Code Section 65589. 5( d) and are necessary to ensure consistency with the City' s General Plan and Zoning Ordinance.

No housing development application has ever been denied in the City as a result of the City' s design review process, and the City has not found the process to pose any constraints on housing supply and affordability in the City, including the required findings as outlined above. However, T through Program 30, Objective Design Standards, the City will ensure that any newly developed design standards are objective, consistent with the requirements of SIB 330, 2019. Further, through Program 8, By -Right Development on Previously Identified Sites, the City will permit eligible developments without discretionary action. Further, as detailed in Program 19, Emergency Shelters, Transitional Housing, and Permanent Supportive Housing and Program 28 Low -Barrier Navigation Centers, the City will ensure that these uses are permitted as detailed. without discretionary action.

1. 8. 4 Conditional Use Permit
The CUP process is the City' s opportunity to ensure compatibility with surrounding uses, and this review can occur concurrently with Major Design Review. The existing Land Use and Development Code requires a CUP for multifamily projects, with the exception of single- family attached duplex, triplex, and fourplex housing in the R- 3 and R- 2C zones permitted by Staff Review Permit; multifamily attached projects in the R- 4 or HDS districts; and multifamily uses on multifamily sites identified in the Housing Element. In the case of the R- 4 and HDS, only a Design Review Process is required.

The Planning Commission is responsible for reviewing all applications that require a CUP and the design review of a project. Typical findings for CUP approval include consistency with the goals, policies, and objectives of the General Plan; suitability of the site for the proposed use or development; and adequacy of water, sanitation, and utilities. Following a review of the application, the Planning Commission shall prepare a written decision which shall contain the findings of fact upon which such decision is based. The Planning Commission, or City Council on appeal, may approve a conditional use permit application in whole or in part, with or without conditions, only if all of the following findings of fact can be made in an affirmative manner:

1. The proposed use is permitted within the subject district pursuant to the provisions of this section, and complies with all of the applicable provisions of this title; and is consistent with the goals, policies, and obiectives of the Highland general plan, and with the applicable development policies and standards of the city;

2. The proposed use would not impair the integrity and character of the district in which it is to be established or located;
1 The site is suitable for the type and intensity of use or development which is proposed;

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4. There are adequate provisions for water, sanitation, and public utilities and services to ensure public health and safety;

5. The roposed use will not be detrimental to the public health, safety, or welfare, or materially incurious to properties and improvements in the vicinity; and

6. The proposed use would not result in a significant effect on the environment.

In granting a conditional use permit, the Planning Commission, or the City Council on appeal, shall require that the use and development of the property conform with a site plan, architectural drawings, or statements submitted in support of the application, or with such modifications thereof as may be deemed necessary to protect the public health, safety, and general welfare and to secure the objectives of the general plan. The Planning Commission, or the City Council on appeal, may also impose such other conditions as may be deemed necessary to achieve these purposes, including, but not limited to, the following matters:

1. Requirements for setbacks, yard areas, and open spaces.

2. Fences, walls, buffers, and screening.

3. Parking, parking areas, and vehicular ingress and egress in addition to the minimum requirements of Chapter 16. 52 HMC.

4. Landscaping and maintenance of landscaping and grounds.

5. Regulation of signs.

6. Control of noise, vibration, odors, and other potentially dangerous or objectionable elements.

7. Limits on hours of operation or duration of approval.

8. Time period within which the proposed use shall be developed.

9. Requirements for street improvements and dedications.

10. Building design and elevations.

11. Such other conditions as may be determined to assure that development will be in accordance with the intent and purposes of this title.

12. Reasonable guarantees of compliance with required conditions, such as a deed restriction or requiring the applicant to furnish securitv in the form of money or surety bond in the amount fixed by the administering agency.

13. Requirements for periodical review by the planning commission, and such other conditions as the planning commission may deem necessary to ensure compatibility with surrounding uses, to preserve the public health, safety, and welfare, and to enable the commission to make the findings required by this subsection.

Revisions or modifications of conditional use permits may be requested by the applicant and shall be processed in the same manner as the original conditional use permit. Further, the Planning Commission may periodically review, modify, or revoke a conditional use permit to ensure that it is being operated in a manner consistent with conditions of approval or in a manner which is not detrimental to the public health, safety, or welfare, or materially incurious to properties in the vicinity. If, after review, the commission deems that there is sufficient evidence to warrant a full examination, then a public hearing date shall be set. At such public hearing, the planning commission may modify or revoke the permit pursuant to the provisions of Section 16. 08. 220, Revocation of Permits, of the Land Use and Development Code.

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Design review is based on criteria included within the General Plan Land Use Element and Community Design Element. The CUP ( with Major Design Review) process typically takes 9 to 12 weeks, not including the time required by CEQA if an Environmental Impact Report is necessary.

1. 8. 5 General Plan Amendment/ Zone Change
Projects requiring a General Plan Amendment or zone change require review by the Planning Commission and approval by the City Council, regardless of proposed use. However, the City typically reduces the timeframe for this legislative step by processing, where feasible, the discretionary permits at the same time. Alternatively, the City provides a process for a variance, which may reduce any unnecessary hardships related to requests to deviate from current zoning requirements. Approval to grant a variance is determined by the Community Development Director. A variance may be granted based on the following findings:

1. That strict or literal interpretation and enforcement of the specified regulation would result in practical difficulty or unnecessary hardship not otherwise shared by others within the surrounding area or vicinity;

2. That there are exceptional or extraordinary circumstances or conditions applicable to the property involved or to the intended use of the property which do not apply generally to other properties in the vicinity and under the same zoning classification;

3. That the strict interpretation and enforcement of the specified regulation would deprive the applicant of privileges enjoyed by the owners of other properties in the vicinity and under the same zoning classification;

4. That the granting of the variance will not constitute a grant of special privilege inconsistent with the limitations on other properties in the vicinity and under the same zoning classification;

5. That the granting of the variance will not be detrimental to the public health, safety or welfare or materially incurious to properties or improvements in the vicinity; and

6. That the granting of the variance is consistent with the objectives and policies of the general plan and the intent of this title.

In approving a variance, reasonable conditions of approval may be imposed. The following conditions of approval for a variance may include, but shall not be limited to:

1. Requirements for open spaces, fences, walls, and screening buffers; requirements for landscaping and erosion control measures, including maintenance thereof;

2. Requirements for dedications and street improvements;

3. Regulation of vehicular ingress and egress and traffic circulation; and

4. Regulation of hours of operation, and such other conditions deemed necessary to ensure compatibility with surrounding uses, to preserve the public health, safety, and welfare, and to enable the reviewing authority to make all the findings required above.

The City' s variance process is not found to be a constraint, and instead provides for equity in use of property and can prevent unnecessary hardships that might result from a strict or literal interpretation and enforcement of certain zoning regulations.

1. 8. 6 Processing Time
Developmental review is the primary way to ensure that new residential projects reflect the community' s goals and contribute to improving local quality of life. The time it takes to obtain permits

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from the City can affect overall project cost, and therefore impact the cost of housing and the success of development in the community.

Highland values the time and money of its development applicants. The City reduced its processing times through enforcement of the " Come Home to Highland" program, which commits the City to establishing fixed fees for several forms of review, and ensures that a discretionary permit application is brought to the appropriate review body within 90 days of the application completeness determination.

Table 6 shows the average processing times for various project applications and reviews.

Table 6. Permit Processing Times
Type of Application Timeframe ( days)
Zone Change 90
Tentative Tract or Parcel Map 90
Conditional Use Permit 90
Variance Review 45
Lot Line Adjustment 60
Staff Review ( Design/Use 5- 10
Minor Design Review 45
Major Design Review 60- 90

1. 8. 7 Special Business License Provisions: Crime Free Multiple Family Rental Housing Program
The Crime Free Multi - Housing Program is a partnership with property managers, owners. landlords and residents. The program is run by the San Bernardino County Sheriff' s Department with the goal of reducing crime through community partnerships and pro -active steps to improve the quality of life for the community. The programs consist of three phases towards making a property a safer living environment for the tenants. The phases must be completed under the supervision of the local sheriff' s station. Property managers and owners can become individually certified after completing training in each phase and the property can become certified when all phases are completed. The program applies to any property that contains four or more rental units that are being rented out for residential dwelling purposes.

The program aims to increase community participation, provide accountabilitv for propertv owners, and lower maintenance costs. The program phases improve public safety for tenants, property owners and the community. Phase I of the program includes free classroom instruction, which includes establishing fair screening and the legal rights and responsibilities of owners and managers. Phase II of the program includes a property survey. Staff from the local sheriff' s station conducts an inspection of the property using Crime Prevention Through Environmental Design ( CPTED) principles. CPTED is a nationally accepted multi -disciplinary approach to deterring criminal behavior through environmental design. The roperty survey is strictly an on -premise inspection.

As outlined in Section 5. 34.020 of the Highland Municipal Code ( Special business license provisions — Crime free multiple -family rental -housing program),. P prior to obtaining a valid City business license, the owners or operators of any property that contains four or more rental units ( or rental spaces) that are being rented out for residential dwelling purposes must comply with all of the following crime free multiple -family rental -housing program requirements:

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Complete a crime free multiple -family rental - housing program seminar to be provided by the Highland police department (" seminar"); and
Include a crime free lease or rental agreement addendum (" addendum") or clause in the lease or rental agreement similar to the crime free lease or rental agreement addendum in any leases or rental agreements that are executed, modified or extended after the effective date of the ordinance codified in this chapter. The city clerk shall maintain a sample addendum form for use by businesses subject to the provisions of this chapter.

When a property that is subject to the program is transferred to a new owner, the new owner or operator shall complete the seminar within three months after the transfer of the rental property, or as soon as the seminar is conducted, whichever time is later.

When a property that is subiect to the provisions of the program changes operators, the new operator shall complete the seminar within three months after the transfer of operations, or as soon as the seminar is conducted, whichever time is later. Any owner or operator of property with four or more units that are being rented out for residential purposes shall complete the seminar once every three years.

The crime free multiple -family rental -housing program is a crime prevention program designed to reduce crime, drugs, and gang activities on the subject rental properties. At the seminar, the program coordinator shall provide, at no cost, samples of the addendum and, if applicable, shall review any clauses within actual leases with the city attorney' s office to determine if the clause is similar to the addendum provisions designed to make criminal activity a lease or rental agreement violation. The owner or operator shall have the authority under the clause or addendum to initiate an eviction proceeding as specified in California state law.

Through Program 2, Residential Rental Enhancement and Rehabilitation Program, the Citv will continue to provide health and safety hazard checks for landlords, ensuring that tenants are not subject to substandard housing and the City will also continue to provide landlord trainings to ensure property safety measures are taken. Program 2 further enhances upon this existing program to incorporate fair housing training for landlords. This will expand upon the City' s Crime -Free Multiple -Family Rental Housing Program, to ensure that this program is implemented through the lens of fair housing providing fair housing services for residents and landlords.

1. 9 Housing for Persons with Disabilities
Effective on January 1, 2002, SB 520 amended Housing Element law and Government Code Section 65008 to require localities to analyze the constraints on housing for persons with disabilities. The City' s adopted building codes ( including the 2019 California Building Code, California Existing Building Code, and California Residential Code [ Title 24]) require that new residential construction comply with the Federal Americans with Disabilities Act ( ADA). Highland has the authority to enforce state accessibility laws and regulations ( California Code of Regulations Title 24) when evaluating new construction requests. ADA provisions include requirements for a minimum percentage of units in new development to be fully accessible to people with physical disabilities. Compliance with provisions of the Federal ADA is assessed and enforced by Highland' s Building Official. Program 17 of the Housing Element will provide resources for information on home retrofits and accessibility in ADUs to increase the supply of units available for people with disabilities.

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1. 9. 1 Reasonable Accommodation
The City of Highland understands the importance of reducing barriers to provide adequate housing for persons with disabilities. Chapter 16. 40 in the Land Use and Development Code provides a formal process for requesting reasonable accommodations for persons with disabilities seeking equal access to housing under the Federal Fair Housing Act and the California Fair Employment and Housing Act in the application of zoning laws and other land use regulations, policies, and procedures. A reasonable accommodation refers to actions that a city takes to modify land use and zoning regulations affecting housing for people with disabilities. A reasonable modification is typically a structural change made to existing premises so that a person with a disability can fully use the premises.

Requests for a reasonable accommodation are submitted on an application provided by the Community Development Department, or in the form of a letter. Requests are reviewed by the Director of Community Development and written determination is provided by the director of their designee within 45 days that either grant, grant with modifications, or deny a request for reasonable accommodation.

Written determinations to grant or deny a request for reasonable accommodations shall be based on the following findings:
a. Whether the housing, which is the subiect of the request, will be used by an individual with disabilities under the Federal Fair Housing Act and the California Fair Employment and Housing Act.
b. Whether the request for reasonable accommodation is necessary to make specific housing available to an individual with a disability under the Federal Fair Housing Act and the California Fair Employment and Housing Act.
c. Whether the requested reasonable accommodation would impose an undue financial or administrative burden on the city.
d. Whether the requested reasonable accommodation would require a fundamental alteration in the nature of a city program or law, including but not limited to land use and zoning. e. Potential impact on surrounding uses.
f. Physical attributes of the property and structures.

Wig. Alternative reasonable accommodations which may provide an equivalent level of benefit.

In granting a request for reasonable accommodation, the reviewing authority may impose any conditions of approval deemed reasonable and necessary to ensure that the reasonable accommodation would comply with the findings outlined above. A determination by the reviewing authority to grant or deny a request for reasonable accommodation may be appealed to the Planning Commission in compliance with Section 16. 08. 210, Appeals, the Land Use and Development Code.

These findings are not found to be a constraint and are necessary to ensure consistency with the CitVs General Plan and Zoning Ordinance. Through Program 17, Housing for Persons with Disabilities, of the housing Element, the City will continue to provide a process by which relief from land use, zoning, or building laws, rules, policies, practices, and/ or procedures can be alleviated for those with disabilities, including persons with developmental disabilities. Furthermore, the City will promote this procedure by providing information on its website that is easily accessible.

The City Land Use and Development Code' s handicapped parking requirements are established by, and intended to be identical to, the requirements established by the State of California. Residential projects

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providing handicapped spaces are required to locate the spaces as close to building entrances as possible and to follow Citywide regulations in terms of size, striping, and signage. Handicapped parking standards for residential uses are not different from parking standards for other uses.

1. 9. 2 Residential Care Facilities
Group homes, boarding houses, and residential care facilities are often a resource for persons with a disability in need of special care. Large residential care facilities serving seven or more persons, called Board and Care Facilities" in the uses table, are conditionally permitted in multifamily zones ( R- 2, R- 2C, R- 3, R- 4, and HDS), and conditionally permitted in commercial zones ( CG, NC, PC, VC). The City does not have any occupancy restrictions based on relatedness or family ties in any land uses or zoning designations. See additional use details in Section 1. 4. 1, Residential Care Facility.

Program 18, Residential Care Facilities, is proposed to amend the Zoning Code to permit residential care facilities serving six or fewer persons by right in all residential zones in accordance with the Welfare and Institutions Code Section 5116 and permit those serving seven or more in at least one zone without discretion. te define .;;Ad- spec;ify that FeSffid-e-A.Wal e-are far--Aitie-q - are allewed by right in G-A—A-S. S# P—At VVith State IaW f9F small greup hernes ( six eF feweF) and- vVith a Use PeFrnit feF large fardlitaer seven „

1. 9. 3 Senior Housing and Facilities
Other forms of housing that may assist persons with a disability include senior independent living projects, residential care homes for older adults, congregate care, and convalescent care. Senior independent living projects are permitted with a Staff Review Permit in the A/ EQ, R- 1, VR, and EHV zones, and conditionally permitted in multifamily zones ( R- 2, R- 2C, R- 3, R- 4, and HDS) and the mixed use zone ( MU). Congregate care, assisted living, and convalescent care homes are conditionally permitted in multifamily, mixed use, and commercial zones. Residential care facilities, which can include residential care facilities for older adults per the City' s definition, serving seven or more persons, are conditionally permitted in multifamily zones ( R- 2, R- 2C, R- 3, R- 4, and HDS).

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2 Market Constraints
This section identifies those non -governmental market factors and other financial factors that maV affect the cost of new housing. Market constraints to the development of residential housing include the cost of land, the cost of construction, and financing. Changes in the financial markets, changes in construction material costs, and other factors all affect the feasibility of developing new housing in the City. This section discusses land costs, construction costs, and financing issues. Although these factors may create barriers to building housing, the City has less control over but can influence or help support the production of affordable housing. While the City was unable to identify additional factors subject to local control directly related to land, labor, or material costs and/ or financing that would significantly reduce the cost for housing, the City will continue to implement the InclusionarV Housing Ordinance through implementation of Program 4, Inclusionary Housing, of the Housing Element, and will identify affordable housing preservation, rehabilitation, and construction opportunities for the expenditure of acquired funds, especially for funding opportunities of housing for extremely low- income households and households with special needs. In addition, the CitV recognizes that land use incentives, such as the State Density Bonus law zoning designations that offer higher allowable densities, and lot consolidation incentives, can aid in reducing development costs and support the production of affordable housing. See Section 4, Analysis of Local Efforts to Remove Constraints and Facilitate Affordable Housing, for further analysis related to policies and programs set forth in the 6th Cycle Housing Element that aim to incentive development and address potential non -governmental constraints.

Furthermore, the City is committed to continue participating in and promoting regional and State programs that address non -governmental market constraints bV providing a range of financing options for low- and moderate - income homebuVers and owners. Program 13, Homeowner Assistance Programs, of the Housing Element commits the City to promoting the County homeowner assistance programs and resources on the City' s website, and through Program 1, Homeowner Rehabilitation Program, the City will promote the homeowner rehabilitation repair loan opportunities offered through the Neighborhood Partnership Housing Services and strive to improve coordination with the County to identify opportunities for increased funding for homeowner rehabilitation.

2. 1 Availability of Financing

2. 1. 1 Construction Financing
Construction financing costs affect the feasibility of building new housing. During the housing boom of the late 1980s, it was not uncommon for developers to receive construction loans for 100% or more of a project' s estimated future value. Following the housing market downturn of the early 1990s, however, financial institutions tightened regulations for construction loans, often requiring developers to put up at least 25 percent of the project value. These trends continue today, meaning that developers must usually supply at least 25 percent of the project value upfront, and perhaps more if the total cost is more than 75 percent of the estimated value of the project.

Although there is no hard threshold for how much required upfront equity is too much before a residential project would be infeasible, the higher the proportion of equity required, the more unlikely that a developer would proceed with the project. Not only would it require more up -front cash, but higher equity contribution means a project must be able to achieve an even higher value at completion in order to generate the cash flow needed to meet acceptable cash - on -cash returns. These trends are anticipated to continue during the planning period.

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2. 1. 2 Mortgage Financing
Although recent economic conditions have seen housing prices increase and interest rates remain low, buying a house or refinancing a mortgage is getting tougher, as banks raise requirements such as minimum credit score. Loan applicants with short credit history, lower incomes, self-employment incomes, or other unusual circumstances have had trouble qualifying for loans or are charged higher rates. This economic barrier could disproportionately affect lower -income, non-White borrowers, making it harder for them to close on a loan, especially as a result of the Corona virus pandemic and resulting economic fallout. The economic fallout has resulted in the unemployment rate increase in the City from 3. 8 percent in 2019 to 8 percent as of November 2020, making it more difficult for unemployed, underemployed, lower -income borrowers, and other groups who historically have found it the most difficult to get a loan to get a fair loan.

The Home Mortgage Disclosure Act requires many financial institutions to maintain, report, and publicly disclose loan - level information about mortgages. This requirement applies to all loan applications for home purchase, improvements, and refinancing, whether financed at market rate or with government assistance. These data help show whether lenders are serving the housing needs of their communities, they give public officials information that helps them make decisions and policies, and they shed light on lending patterns that could be discriminatory.

Table 7 summarizes the disposition of loan applications submitted to financial institutions in 2019 for home purchase, refinance, and home improvement loans in Highland. The loan outcome information in the table includes the proportion of applications that were approved, were denied, or were incomplete or withdrawn by the applicant.

Table 7. Disposition of Home Loans ( 2019)
Loan Type Total Applicants Percent Approved' Percent Denied Percent Other' Government - Backed Purchase 426 74. 9% 8. 5% 16. 7%
Conventional Purchase 661 73. 4% 7. 3% 19. 4%
Refinance 1, 845 58% 16% 25. 9%
Home Improvement 182 35. 2% 51. 1 % 13. 7%
Total 3, 114 62. 3% 15. 2% 22. 5%
Source: 2019 Home Mortgage Disclosure Act Lending Activity MSAIMD by Census Tract Data 1 Approved includes loans approved by the lenders whether or not accepted by the applicant. 2 Other includes loan applications that were either withdrawn or closed for incompleteness.

2. 1. 2. 1 Nome Purchase Loans
In 2019, a total of 426 households applied for government -backed loans ( Federal Housing Administration, Farm Service Agency/ Rural Housing Service, and Department of Veterans Affairs) in Highland. Of those applications, 75 percent were approved, and 8 percent were denied. More households applied for conventional loans to purchase homes in Highland, with a total of 661 applications. A total of 73 percent of the conventional loan applications were approved, and 7 percent were denied.

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2. 1. 2. 2 Refinance Loans
The highest number of applications received were for refinance loans, likely because many homeowners are looking to swap out their old mortgages for new loans at record -low rates. A total of 1, 845 households in Highland applied for a home refinance loan in 2019. Of those applications, only 58 percent were approved, 16 percent were denied, and 26 percent were either withdrawn or closed for incompleteness.

2. 1. 2. 3 Home Improvement Loans
In 2019, a total of 182 household applied for home improvement loans in Highland. This is the lowest number of applications, but had the highest percentage of applications denied. Of the total applications, 51 percent of home improvement loans were denied by lending institutions and 35 percent were approved. One of the most important factors that lenders evaluate when reviewing an application is the applicant' s debt -to -income ratio, which indicates how much income the monthly debt takes up. Most home improvement loans applicants may have high debt -to -income ratios from their mortgage loan, which may explain why it is harder to qualify for the additional financing.

2. 2 Construction Costs and Construction Labor Shortage Residential construction continues to face limiting factors, including concerns over regulatory cost burdens, an ongoing labor skills shortage, and higher costs and longer delivery times for building materials. Factors that affect the cost of building a house include the type of construction, materials, site conditions, finishing details, amenities, structural configuration, and project characteristics, such as the type and quality of the unit.

On average, 60 percent of the final cost of a single-family home is attributed to construction costs.

According to the U. S. Census Bureau' s Annual Characteristics of New Housing Survey, the average contract price per square foot of new contractor -built single- family houses averages approximately $ 158 per square foot.

One indicator of construction costs is building valuation data compiled by the International Code Council. The unit costs compiled by the International Code Council include foundation work, structural and nonstructural building components, electrical, plumbing, mechanical, and interior finish material.

The data is a national average and does not take into account any regional cost differences, nor include the price of the land upon which the building is built, so it should be taken into account that these national averages are lower than those in California, and that high construction costs lead to higher rents and home prices in the State, which are also some of the highest in the nation. According to the latest building valuation data release in 2019, the national average for development costs per square foot for apartments and single-family homes in 2019 were as follows:

Type I or II, R- 2 Residential Multifamily: $ 148. 82 to $ 168. 94 per square foot Type V Wood Frame, R- 2 Residential Multifamily: $113. 88 to $118. 57 per square foot Type V Wood Frame, R- 3 Residential One- and Two -Family Dwelling: $ 123. 68 to $ 131. 34 per square foot
R- 4 Residential Care/ Assisted Living Facilities generally range from $ 143. 75 to $199. 81 per square foot
In general, construction costs can be lowered by increasing the number of units in a development, until the scale of the project requires a different construction type that commands a higher per -square -foot cost. Apartments of three stories or fewer achieve an economy of scale, provided that the building has

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typical amenities and no structured parking. Mobile homes are significantly less expensive, as are precision or factory -built housing products.

Labor costs also greatly contribute to construction costs. They are generally two to three times the cost of construction materials. A 2019 study for Smart Cities Prevail found that California lost about 200, 000 construction workers since 2006. Many lost their job during the recession and found work in other industries. Pre -pandemic, the industry already faced this historic shortage of skilled labor, and the labor gaps might get even larger, especially in states like California.

2. 3 Land Costs
The cost of raw, developable land creates a direct impact on the cost for a new home and is considered a possible constraint. Land costs, when compared with projected rents and sales prices of housing, affect the feasibility of construction. A higher cost of land raises the price of a new home, which typically makes the cost of land a major factor in determining the cost of developing housing. Land costs are influenced by many variables, including supply, demand, location, site constraints, and the availability of public utilities and other infrastructure. Based on available land for sale as of January 2021, the average cost of undeveloped land in Highland is approximately $ 167, 000 per acre for single- family zoned developable parcels and $ 440, 000 per acre of multifamily zoned developable parcels.

In addition to the basic cost of land, the holding cost is also a consideration in the price of housing.

Holding costs vary depending on interest rates for acquisition and development loans. Interest rates are beyond the control of local jurisdictions. However, land holding costs can be lessened by reducing processing times for building permits in most jurisdictions. Therefore, developers sometimes seek to obtain approvals for the largest number of lots allowable on a parcel of land.

2. 4 Requests for Housing Developments at Reduced Densities State law requires the Housing Element to include an analysis of requests to develop housing at densities below those anticipated in the sites inventory. The realistic capacity for sites identified as appropriate to accommodate lower -income units in the sites inventory were calculated based on minimum densities permitted and can therefore be reasonably anticipated to be developed at densities above those anticipated in the sites inventory. However, after considering topographical constraints and addressing potential environmental mitigation requirements, the City' s development review team proactively and upon request evaluates potential parking and/ or landscape coverage reductions to help increase density. When appropriate, Planned Development documents and Specific Plans are also promoted as a means of increasing density with the benefit of increasing amenities, such as park and recreation facilities. In addition, the viability of a Density Bonus application is also considered as a means to increase the density of potential projects in the City.

As identified in Program 25, No Net Loss, the City will monitor development activity compared to remaining capacity identified in the Sites Inventory and the City' s remaining Regional Housing Needs Allocation ( RHNA) throughout the 6th Cycle to ensure there are adequate sites to accommodate the RHNA.

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2. 5 Length of Time between Project Approval and Applications for Building Permits
State law requires an analysis of the length of time between receiving approval for housing development and submittal of an application for building permit. On average, the time is between 45 to 90 days for the approval for a housing development entitlement of 4 or more units, after submittal of a completed application and plans for building permits which comply with all applicable regulations it takes approximately 1 % months to obtain a building permit. On average, the time is between 5 to 10 days for the design review approval of smaller in -fill projects of 3 or less units, and after the submittal of a completed application and plans for building permits it takes approximately 1 month to obtain a building permit.

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3 Environmental Constraints
Environmental constraints can limit or affect the type of housing and density of housing development in a community. These constraints can include natural resources, hazards, or lack of sufficient infrastructure capacity. However, Highland is an urbanized community with the majority of the City' s infrastructure already in place. Environmental and infrastructure constraints do not pose a significant constraint to housing production.

3. 1 Environmental Features

3. 1. 1 Biological Resources
Due to urbanization and growth, habitat is limited to the undisturbed areas of the northeast. Native habitats within the developed part of the City are few and include annual grasslands with nonnative grasses, disturbed areas with spare amounts of native species, and landscaped areas. There are plant and wildlife communities within the City, many associated with the watercourses that traverse the City and drainage in the canyons of the foothills and mountains. The City is located north of the Upper Santa Ana River Wash Habitat Conservation Plan; however, the City itself is not within a Habitat Conservation Plan area or other plan area protecting biological resources. Biological resources are regulated and protected by Federal ( U. S. Fish and Wildlife Service) and State ( California Department of Fish and Wildlife) regulations, and the County of San Bernardino. Federal and State regulations require environmental review of proposed discretionary projects. Costs, resulting from fees charged by local governments and private consultants needed to complete the environmental analyses, and from delays caused by mandated public review periods, also add to the cost of housing. However, the presence of such regulations is required to preserve the environmental and ensure environmental quality for Highland residents.

3. 1. 2 Archaeological Resources
There are several sites north of the City and specific areas that have been designated as archaeologically sensitive areas with a high probability for discovery of archeological resources if disturbed by development. One of the Native American tribes closely associated with the City of Highland is the San Manuel Band of Mission Indians. To preserve archaeological resources and the history of the San Manuel Band of Mission Indians, the City' s approach to preservation is through a site -by -site analysis using the development review process. Such analysis is required by State law through CEQA and involves archival research, field reconnaissance/ survey, and preparation of a Cultural Resources Report. If resources are identified within areas of proposed housing developments, the individual project applicant would work with the City and a qualified archaeologist to determine the proper mitigation for the site in question. As with biological resources, such analysis would add to the cost of housing; however, it is required to avoid significant impacts to archaeologically sensitive sites.

3. 1. 3 Water Resources
Water is provided to Highland by the EVWD through groundwater, surface water, and imported water.

Water providers in Southern California face the challenge of growing demand and uncertainty of supply.

The Urban Water Management Plan Act requires water providers to evaluate supplies during normal year, single dry year, and multiple dry year scenarios; existing baseline water use; targets for future water use; demand management measures implemented or planned for implementation; water shortage contingency planning; and notification with other water agencies. It is estimated that the EVWD would experience a 7 percent increase in demand from 2020 to 2030. Assuming conservation

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behaviors continue among the population, and the EVWD continues to identify new, cost- effective ways to supply water, Highland should be able to supply the water needed for the City' s anticipated growth.

3. 1. 4 Energy Conservation
Rising energy costs, dependence on fossil fuels, and increasing evidence of the adverse impacts of climate change have provoked the need in California and nationwide to improve energy management strategies. Although California has always been a leader in energy conservation, recent regulations specifically target energy independence and greenhouse gas emissions. In 2006, the State Legislature adopted the Global Warming Solutions Act of 2006, which created the first comprehensive, State regulatory program to reduce greenhouse gas emissions to 80 percent below 1990 levels by 2050.

Promoting energy conservation has become a consistent theme in California' s regulations.

Highland understands that energy efficiency can greatly reduce the impact of residential development and provide cost savings for its residents. On a regulatory level, the City enforces the State Energy Conservation Standards ( California Code of Regulations Title 24). These standards incorporated into the City' s Building Code provide a great deal of flexibility for individual builders to achieve a minimum energy budget" with various performance standards. These requirements apply to all new residential and commercial construction and to remodeling and rehabilitation construction only where square footage is added. Compliance with Title 24 of the California Administrative Code on the use of energy - efficient appliances and insulation has reduced energy demand stemming from new residential development.

Residential development in Highland is evaluated for energy efficiency during the plan review process.

Every residential project must submit calculations per model showing compliance with Title 24. The applicant must describe the type of heating system and maximum capacity, and provide the make, size, and model number for all air conditioning units, furnaces, and water heating equipment. More energy efficiency could be encouraged through an incentives program.

The City of Highland educates the development community and residents through informative materials made available in public buildings, the City' s website, and the General Plan Open Space and Conservation Element. Part of this effort is promoting energy efficiency in existing structures through rehabilitation and appliance replacement, and in new development through incentive programs provided by utility companies. The City also has policies that encourage energy conservation and housing objectives. For example, infill development discussed in the Housing Element and Land Use Element encourages housing development opportunities without creating sprawl. The 2014- 2021 Housing Element updated the Land Use and Development Code to include the Residential HDS Overlay, permitting such multifamily units by -right. Additionally, multifamily housing types within the R- 4 zone is permitted by -right. The HDS and R- 4 zoning are located within urbanized portions of the City. These development types are consistent with State goals to encourage compact, walkable, and energy - efficient neighborhoods.

3. 2 Environmental Hazards
Environmental hazards affecting housing development and resident safety include extreme heat, flooding, geologic hazards ( landslides/ slope instability, earthquakes, and liquefaction), and wildfires.

These hazards provide the greatest threat to the built environment. Development should be carefully controlled in potentially hazardous areas. The City of Highland Safety Element, which provides policy guidance about environmental constraints, was updated in 2021 and covers all of the areas within the land inventory.

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3. 2. 1 Flooding
Flood risk is dispersed across Highland but is most centralized in the southern portion of East Highland just south of Greenspot Road and along City Creek. This area has a 1 percent chance of flooding annually, which is also known as a 100- year flood zone. Much of the area south of Greenspot Road and along City Creek is zoned as Open Space and Agricultural/ Equestrian. This aids in allowing for natural drainage during extreme rain events. Highland has adopted special standards, such as minimum building elevations, flood proofing, and anchoring, for development in flood -prone areas. Any housing sites identified in the Housing Element that may be located in a 100- or 500- year floodplain, or other flood hazard zone, will be developed in accordance with strict regulations to properly mitigate flooding hazards in accordance with the floodplain management standards of the Highland Municipal Code Chapter 16. 76).

3. 2. 2 Landslides/ Slope Instability
Steep slopes can experience landslides, debris flows, mudslides, and erosion. These effects impact where development can occur throughout the City and can result in damages to existing development.

Areas at high risk of landslides include the northern and eastern areas due to their proximity to steep slopes and the rock strength in these areas. The City has regulations in place to reduce the potential for slope failure, erosion, and mudslides when new development is proposed in areas subject to geological risks.

3. 2. 3 Earthquake
Like the entire Southern California region, the City of Highland is within an area of high seismic activity.

It can be expected, therefore, that a significant seismic event will occur in the City. The timing and magnitude of such an event cannot be predicted, although planning efforts for emergency response must be predicated on the certainty of such an event. North and south branches of the San Andreas Fault, a known active fault, run through Highland. The San Jacinto Fault is approximately 4.5 miles southwest of the City. The City' s Safety Element requires residential development to be set back a minimum of 50 feet from active and potentially active fault lines. The Safety Element includes other policies to increase mitigation measures and further study possible geologic- and seismic -related hazards.

3. 2. 4 Liquefaction
Liquefaction may damage structures on saturated, granular soils, such as silt or sand, during an earthquake. These geologic conditions are typical in valley regions within Highland. Areas at risk of liquefaction due to soil composition and heightened exposure to runoff cover nearly all of southeastern Highland, as well as western Highland. Detailed soils engineering investigations would be necessary in those areas where future development is proposed within liquefaction areas in order to further evaluate the liquefaction potential, and to further define the potentially affected areas of the City. However, because of the site -specific nature of geologic hazards, existing geologic conditions are not expected to adversely impact development within Highland. In addition to existing building codes and regulations, site -specific geologic reports would recommend any necessary mitigation measures, if required, to reduce potential hazards associated with liquefaction.

3. 2. 5 Wildfire
The City of Highland' s building codes require new housing to include fire sprinkler systems to protect residents and property. Wildland fires are a present threat, as there are large expanses of undeveloped

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hillsides in and adjacent to Highland. Most of the City of Highland is built in fire -risk areas due to the proximity to forestland to the north and east of City limits. The most northeastern portions of Highland are located in very high fire risk areas, while much of the central and southern portions of Highland are high fire risk areas. Precautions, such as fuel modification zones and vegetation maintenance, help protect Highland' s natural and developed areas from wildfire. The California Department of Forestry and Fire Protection provides fire prevention and suppression services to the City and unincorporated areas east of the City. Additional wildland fire protection services are provided by the U. S. Forest Service on National Forest lands adjacent to the City.

3. 3 Adequate Infrastructure Capacity
The City of Highland contains both developed and largely undeveloped residentially zoned areas. In developed areas, the existing infrastructure system is sufficient to support Highland' s population, but water and sewer are limited in undeveloped areas within the City. However, infrastructure in currently unserved areas will be planned and constructed as necessary to serve new development. These improvements are typically dedicated to the City, which is then responsible for maintenance and/ or improvement.

Future housing growth is focused in commercial areas around existing bus stops that are served by existing sewer and water lines. All development plans in Highland must be coordinated with the EVWD to meet wastewater disposal and treatment requirements established by the California Department of Health Services. Development impact fees will allow the water and wastewater districts to provide necessary connections and services.

3. 3. 1 Dry Utilities
The California Public Utilities Commission is responsible for regulating the electric, natural gas and telecommunication industries excepting cable television. Southern California Edison provides electricity to the City. Southern California Edison has a local office in the City of Redlands and operates a substation in the City. Electrical facilities are expected to keep pace with anticipated demand in the City.

The Southern California Gas Company provides natural gas to the City. The Southern California Gas Company has local offices in the City of San Bernardino and the City of Redlands. The availability of natural gas is based on current conditions of gas supply and regulatory policies. The Southern California Gas Company has no current plans for significant improvement or expansion plans for the City and anticipates that an ample supply of natural gas can be provided to the City. Important telecommunication systems are available to the City' s residents, including cable, high- speed Internet, and wireless communication. Refer to the City' s Public Services and Facilities Element of the General Plan for additional information.

There is sufficient existing or planned dry utilities supply capacity, including electricity, natural gas cable, and telephone, to accommodate the City' s regional housing need and sites identified for the planning period ( see Appendix E for Sites Inventory details).

3. 3. 2 Sewer System
The EVWD provides sewer services to the City and has a joint powers agreement with the City of San Bernardino to accept all sewage generated by the City. Although the sewer system is adequate for existing development in Highland, continued growth has the potential to impact the capabilities of the sewer system. Developers must coordinate with the EVWD to meet sewer requirements. The EVWD has adopted the 2019 Sewer System Management Plan. As required by Order No. 2006- 0003, Statewide

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General Waste Discharge Requirements, the Sewer System Management Plan will undergo review and revisions through internal audits every 2 years. The Statewide General Waste Discharge Requirements also require an agency to have a System Evaluation and Capacity Assurance Plan. This component involves preparing and implementing a Capital Improvement Program that will provide the hydraulic capacity of key sewer systems for dry -weather peak -flow conditions, as well as appropriate design storm or wet -weather events. The 2019 Sewer Master Plan identifies projects in prioritized order for pipelines showing capacity deficiency in the future planning horizon. After completing the projects identified in the 2019 Sewer Master Plan, the City' s sewer system will operate with adequate capacity.

The sewage from the City flows in a general direction from northeast to southwest toward the San Bernardino Water Reclamation Plant located at 299 Blood Bank Road in the City of San Bernardino. This plant is operated by the San Bernardino City Municipal Water Department, Water Reclamation Division.

The plant processes an average sewage flow of approximately 26 to 27 million gallons per day ( mgd) from the City of San Bernardino, the City, and other areas. The plant has a total sewage capacity of 33 mgd. Expansion or construction of a new wastewater treatment facility to meet the demands of the 2021- 2029 Housing Element update is not required.

3. 3. 3 Water System
The City' s water supply sources are local groundwater, surface runoff from natural watershed and drainage areas, and imported water. The EVWD manages the water supply through a system of pipelines, wells, reservoirs, pumping stations, and a treatment plant. This system includes approximately 19 active wells, 2 inactive wells, 18 reservoirs, and 26 booster stations all located on 39 different plant sites.

The water distribution and transmission network varies considerably throughout the City. Transmission lines ( 16 to 24 inches in diameter) transport large quantities of water from one area to another. Major transmission lines are located in parts of Victoria Avenue, Sterling Avenue, Del Rosa Drive, Tippecanoe Avenue, Church Street, Weaver Street, 9th Street, Base Line, Pacific Street, Highland Avenue, and 5th Street. Distribution lines ( 3/ 4 inches to 20 inches in diameter) deliver water to individual dwelling units.

Major streets have the larger distribution lines whereas secondary or local streets have progressively smaller lines.

The 2019 Water System Master Plan provides guidance for the expansion of the current water system based on planned development. Potential infill growth resulting from new zoning and land use regulations would be accounted for in future Water System Master Plan updates. Additionally, the 2019 Water System Master Plan evaluates the existing distribution system and its facilities to size future improvements. A water supply analysis was performed to determine whether available water sources are sufficient to meet water demand for the EVWD under normal and emergency operations. It was determined that EVWD will have a total deficiency of approximately 18. 0 mgd of storage capacity and

13. 44 mgd for supply under the build -out demand. Improvement projects identified would address system deficiencies and increased water demands.

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4 Analysis of Local Efforts to Remove Constraints and Facilitate Affordable Housing
During the 5th Cycle Housing Element planning period, the City made strides to reduce constraints to development that are within the City' s purview since the Housing Element was last updated in 2013.

Reductions to constraints during the 5th Cycle planning period were as follows:

Updates to the Land Use and Development Code to comply with State law regarding transitional and supportive housing.

The Greenspot Village & Marketplace Specific Plan adoption in 2013, providing a generous amount of land available for residential development, including up to 800 residential units, and a mix of residential, commercial, entertainment, governmental, and professional office uses.

Amended the Land Use and Development Code to make permitting ADUs in single- family zones a ministerial action that does not require public notice, public hearing, or discretionary approval.

During the 6th Cycle review of governmental and non -governmental constraints, the following areas were identified as imposing potential constraints to housing development, including housing affordable to lower -income households and for special needs groups including persons with disabilities.

Updates to State Law
Most recently, the City amended the Accessory Dwelling Units and Junior Accessory Dwelling Units Ordinance ( Section 16. 44. 180 of the City' s Land Use and Development Code) in 2021 to comply with several updates consistent with State law, Government Code Section 658S2. 2. As part of Program 12, Accessory Dwelling Units, of the Housing Element, the City will submit the updated ordinance to HCD for their review and will incorporate amendments, as required by HCD. Further, the City will develop and adopt a program that incentivizes and promotes the creation of ADUs that can be offered at an affordable rent for extremely low, very low, low, or moderate -income households or households with special needs ( AB 671, 2019). Other areas in the Land Use and Development Code which may pose a constraint to development as they are not up to date with current State law include, Emergency shelter parking requirements, by -right approvals for Low -barrier Navigation Centers, and density bonus requirements for affordable housing. However, through Program 19, Emergency Shelters, Transitional Housing, and Permanent Supportive Housing, the City will permit transitional and supportive housing consistent with State laws and amend the City' s Emergency Shelters Ordinance ( Section 16. 44. 270, Emergency Shelters) to comply with parking requirements set forth by AB 139, Quirk -Silva. Through Program 28, Low Barrier Navigation Centers, the City will update the Land Use and Development Code to provide, by -right, approvals exempt per the California Environmental Quality Act ( CEQA) to Low - Barrier Navigation Centers meeting specific standards in areas zoned for mixed uses and nonresidential zones permitting multifamily uses, consistent with AB 101' s requirements for Low -Barrier Navigation Centers. As mentioned, the City' s Density Bonus Ordinance, approved in 2013, is no longer in compliance with the State' s latest Density Bonus Law. Program 6, Density Bonus, will update the City' s Density Bonus Ordinance to comply with the current State Density Bonus Law, including the provision for an increased bonus for 100 percent affordable developments and student affordable housing.

Residential Care Facilities

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Another potential governmental constraint identified is related to the development of residential care facilities. While the City' s Land Use and Development Code includes a definition and permit requirements for residential care facilities serving seven or more persons, called " Board and Care facilities" it does not differentiate or include provisions for residential care facilities for 6 persons or fewer. This is a constraint to the development of residential care facilities for 6 or fewer persons as local agencies must permit these facilities as follows: ( 1) the same as any other residential use and shall be considered a residential use of Property by a single family; ( 2) allowed in all residential zones: and ( 3) be subject to the same development standards, fees, taxes, and permit procedures as those imposed on the same type of housing in the same zone.

Another potential constraint is the development of residential care facilities for seven persons or more.

According to the permitted uses table in the Land Use and Development Code ( see Table 2), a residential care facility for seven persons or more ( Board and Care Facilities) are conditionally permitted in all multifamily zones (R- 2, R- 2C, R- 3, R- 4, and HDS) and commercial zones ( CG, NC, PC, VC). Requirements for discretionary permits may be necessary for certain uses which could have an effect on the existing community; however, they may also pose constraints to development. As such, Program 18, Residential Care Facilities, of the Housing Element includes an objective to amend the Zoning Code to permit residential care facilities serving six or fewer persons by right in all residential zones in accordance with the Welfare and Institutions Code Section 5116 and permit those serving seven or more in at least one zone without discretion.

Cot Consolidation
The City has identified numerous vacant and underutilized parcels that have the potential to accommodate multifamily projects, as detailed in Appendix E. To mitigate potential constraints that may exist related to lot consolidation for development projects relying on multiple lots to create one site, the City will provide a permit expedite incentive for lot consolidation for multifamily development on sites identified in the Housing Element as having the potential to accommodate lower- or moderate -income units, including those sites with potential for extremely low-income development and development to meet the needs of those with special needs, through implementation of Program 23, Lot Consolidation Invective, of the Housing Element.

Single Room Occupancies ( SROs)
Another potential governmental constrain is related to the development of SRO units which impact extremely low- income households. The Land Use and Development Code does not currently permit SRO units. As such, through Program 19 of the Housing Element, the City is committing to amend the Zoning Code to identify a process by which SRO units can be permitted to further increase housing opportunities for extremely low- income households.

Market Constraints
Non -governmental constraints are generally market driven and outside the control of local government; nonetheless, the City can take action to help alleviate some of these constraints in the form of regulatory relief and increased certainty in the development process. For example, Programs 21, Affordable Housing Partnerships, and Program 25, No Net Loss, are related to market demand and promoting developer interest to build affordable housing. Through Program 21, Mobile Home Preservation, the City will require a report detailing relocation and displacement for any proposed conversion or closure of a mobile home park. This ensures that residents of mobile homes, which are typically lower -income households,

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are not displaced from the City and that housing stock for lower -income households remains in the City.

Through Program 25, No Net Loss, the City will monitor development activity compared to remaining capacity identified in the Sites Inventory and the City' s RHNA to ensure there is adequate capacity for lower -income households. Similarly, through Program 1, Homeowner Rehabilitation Program, the ON will partner with the County to refer residents to a loan available to eligible households earning below 80 percent of the Area Median Income in the Inland Valley which provides up to $25, 000 per households to be used for financing home improvements, including health and safety repairs and energy efficiency upgrades. This helps ensure the longevity of the City' s housing stock.

Other programs in the Housing Element aimed to incentive development and address potential nongovernmental constraints include:

Program 4, Inclusionary Housing, which requires that all new housing developments provide affordable units on site or off site, or to pay an in -lieu fee that goes into the City' s affordable housing preservation and construction fund.

Program 8. By -Right Development On Previously Identified Housing Sites, will permit sites in the Sites Inventory, that were previously identified in accordance with the specifications of Housing Element law, to be developed by right where 20 percent of the total housing units in the development will be affordable to lower -income households consistent with State Assembly Bill AB) 1397 ( See Section 3. 3, Sites Identified in Previous Housing Elements, of Appendix E, for additional details).

Program 20, Affordable Housing Partnerships, the City will support creative models of affordable property ownership and affordable housing preservation through methods such as community land trusts.

Program 22, Collaborative Partnerships, the City will contact local affordable housing service providers to discuss partnering and will continue to seek financial assistance from other agencies.

Program 31, Surplus Lands, the City will identify and prioritize local surplus lands available for housing development affordable to lower -income households, including extremely low-income households and households with special needs.

Program 31, Increased Transparency, the City will maintain information on the City' s website that is applicable for housing development project proposal requirements, including a current schedule of fees, exactions, applicable affordability requirements, all zoning ordinances, development standards, and annual fee reports or other relevant financial reports to ensure the development process is clear.

Further details can be found in the Housing Element, Program Implementation subsection.

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S Quantified Objectives
Based on the City' s needs, resources, constraints, and programs outlined in the Housing Element Table 8, Summary of Quantified Objectives for 6th Cycle ( 2021- 2029) summarizes the quantifiable objectives for the 6th Cycle. The quantified objectives estimate the number of units likely to be constructed rehabilitated, or conserved/ preserved by income level during the planning period. The quantified objectives do not represent a ceiling on development, but rather set a target goal for the Citv to achieve.

Quantified Cycle ( 2021- 2029)
Income Catego 5th Cycle RHNA New Construction Rehabilitation Conservation/
Preservatin-,
Extremely Low 309 309 0 0
VerV Low 310 310 0
Low 409 409
Moderate 4? 1 471
Above Moderate 1, 014
TOTALS

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Appendix D: Affirmatively Furthering Fair Housing
Analysis
Contents

1. Introduction.......................................................................................................................................... 1

2. Analysis of Impediments to Fair Housing Choice.................................................................................. 2

3. Housing Element Outreach................................................................................................................... 2

4. Assessment of Fair Housing.................................................................................................................. 3

4. 1. Fair Housing Enforcement and Outreach Capacity....................................................................... 3

4. 2. Segregation and Integration......................................................................................................... 5

4. 2. 1. Race and Ethnicity................................................................................................................. 6

4. 2. 2. National- Origin.................................................................................................................... 12

4. 2. 3. Language............................................................................................................................. 12

4. 2. 4. Household Income.............................................................................................................. 12

4. 2. 5. Familial Status..................................................................................................................... 20

4. 2. 6. Persons with Disabilities..................................................................................................... 29

4. 2. 7. Neighborhood Segregation................................................................................................. 29

4. 3. Racially and Ethnically Concentrated Areas of Poverty.............................................................. 34

4. 3. 1. Racial Concentrations in Areas of Affluence....................................................................... 37

4. 4. Patterns Over Time..................................................................................................................... 37

4. 4. 1. Mortgage Loan Access........................................................................................................ 38

4. 4. 2. Demographic Trends........................................................................................................... 39

4. 5. Disparities in Access to Opportunity........................................................................................... 39

4. 5. 1. Access to Education............................................................................................................ 44

4. 5. 2. Access to Economic Opportunity........................................................................................ 49

4. 5. 3. Access to Transportation.................................................................................................... 54

4. 5. 4. Access to a Healthy Environment....................................................................................... 57

4. 5. 5. Access to Opportunity for Persons with Disabilities........................................................... 66

4. 6. Disproportionate Housing Needs and Displacement Risk.......................................................... 67

4. 6. 1. Housing Affordability.......................................................................................................... 68

4. 6. 2. Housing Conditions............................................................................................................. 75

4. 6. 3. Overcrowding...................................................................................................................... 75

4. 6. 4. Displacement...................................................................................................................... 80

4. 7. Other Relevant Components...................................................................................................... 87

4. 7. 1. Demographic Trends........................................................................................................... 87

4. 7. 2. Public Assistance................................................................................................................. 87

5. Sites Inventory Analysis Consistency.................................................................................................. 90

5. 1. Improved and Exacerbated Conditions....................................................................................... 90

5. 1. 1. Segregation and Integration............................................................................................... 93

5. 1. 2. R/ ECAPs............................................................................................................................... 93

5. 1. 3. Disparities in Access to Opportunity................................................................................... 94

5. 1. 4. Disproportionate Housing Needs, Including Displacement Risk......................................... 94 Page I i City of Highland Affirmatively Furthering Fair Housing Analysis -143-

6. Summary of Fair Housing Issues......................................................................................................... 94

7. Contributing Factors to Fair Housing Issues and Strategies for Affirmatively Furthering Fair Housing 95 7. 1. Prioritization of Contributing Factors and Actions Designed to Meaningfully Address ContributingFactors............................................................................................................................... 96 Figures
Figure 1A. Race and Ethnic Distribution....................................................................................................... 8 Figure 1B. Race and Ethnic Distribution in the Region................................................................................. 9 Figure2A. Diversity Index........................................................................................................................... 10 Figure3A. Median Income.......................................................................................................................... 14 Figure4A. Poverty Status............................................................................................................................ 16 Figure 5A. Low to Moderate Income.......................................................................................................... 18 Figure 6A. Children in Single -Mother Headed Households........................................................................ 21 Figure 7A. Children in Married Couple Households.................................................................................... 23 Figure8A. Adults Living Alone.................................................................................................................... 25 Figure 10A. Population with a Disability..................................................................................................... 30 Figure 11A. Neighborhood Segregation...................................................................................................... 32 Figure 12A. R/ ECAP and Segregation and Poverty..................................................................................... 35 Figure13A. Opportunity Map..................................................................................................................... 42 Figure 14A. Opportunity for Education....................................................................................................... 47 Figure15A. Economic Outcomes................................................................................................................ 50 Figure 16A. Jobs Proximity Index................................................................................................................ 52 Figure 17. Automobile Ownership Rates.................................................................................................... 55 Figure18. Access to Transit........................................................................................................................ 56 Figure 19A. Opportunity for a Healthy Environment.................................................................................. 58 Figure 20A. CalEnviroScreen 3. 0................................................................................................................. 60 Figure21A. Healthy Places Index................................................................................................................ 63 Figure22. Parks........................................................................................................................................... 65 Figure 23A. Percent of Renter -Occupied Housing Units............................................................................. 69 Figure 23B. Percent of Renter -Occupied Housing Units in the Region....................................................... 70 Figure 24A. Renter Cost Burden................................................................................................................. 71 Figure 25A. Homeowner Cost Burden........................................................................................................ 73 Figure 26A. Any Four Severe Housing Problems......................................................................................... 76 Figure27A. Overcrowding.......................................................................................................................... 78 Figure 28A. Communities Sensitive to Displacement................................................................................. 81 Figure29. Fire Hazards................................................................................................................................ 84 Figure30. Flood Hazards............................................................................................................................. 85 Figure31. Seismic Hazards.......................................................................................................................... 86 Figure 32A. Housing Choice Vouchers........................................................................................................ 88 Figure33. Sites Inventory Map................................................................................................................... 91 Page I ii City of Highland Affirmatively Furthering Fair Housing Analysis -144-

1. Introduction
Fair housing occurs when individuals of similar income levels have the same range of housing choice available to them in the same housing market regardless of their characteristics as protected under local, State, and Federal laws. It is important to the City of Highland ( City) that its citizens have fair housing choice, free from discrimination on the basis of race/ ethnicity, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act, California Government Code Section 65008, and other State and Federal fair housing and planning laws. In 2018, Assembly Bill 686, Affirmatively Further Fair Housing, amended Sections 65583 and 65582. 2 of the California Government Code to require a public agency to administer its programs and activities relating to housing and community development in a manner to affirmatively further fair housing.

From freeway expansion to discriminatory housing loan practices, historically underserved communities across the nation have experienced decades of housing disinvestment and infrastructure underinvestment. Many racially and ethnically segregated communities have been left with higher rates of air pollution, poverty, unemployment, educational attainment, and health risks. State and Federal laws, such as the Fair Housing Act, have established pathways for local jurisdictions to create more diverse and equitable communities, but reversing decades of discriminatory policies at all levels of the public and private sectors is complex, and many challenges to equitable development remain. The Housing Element seeks to affirmatively further fair housing by identifying segregated living patterns and barriers to fair housing, designating sites for affordable housing in areas of opportunity, and implementing programs that aim to replace segregated living patterns and transform racially and ethnically concentrated areas of poverty. Siting lower -income housing in high -resource areas is only part of the solution to improve fair housing. Cities must also plan for the needs of lower -income individuals and households through methods such as accessibility of jobs, transportation, educational opportunities, and health services.

This section serves as an assessment of fair housing practices in the City pursuant to California Government Code Section 65583( c)( 9). Housing Elements are required to include the following:

A summary of fair housing issues in the jurisdiction and an assessment of the jurisdiction' s fair housing enforcement and outreach capacity
An analysis of available Federal, State, and local data and knowledge to identify integration and segregation patterns and trends, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs within the jurisdiction, including displacement risk
An assessment of the factors that contribute to the fair housing issues identified in the analysis An identification of the jurisdiction' s fair housing priorities and goals, giving highest priority to the greatest contributing factors that limit or deny fair housing choice or access to opportunity, or negatively impact fair housing or civil rights compliance Measurable strategies and actions to implement the fair housing priorities and goals in the form of programs to affirmatively further fair housing

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2. Analysis of Impediments to Fair Housing Choice
The City intends to affirmatively further fair housing choice and promote equal housing opportunity in accordance with requirements in State Fair Housing and Housing Element law and Federal law. To achieve this, the City identifies impediments to fair housing choice and works to remove these impediments through this Affirmatively Furthering Fair Housing Analysis. In addition, in March 2015, the County of San Bernardino € 4' adopted the County of San Bernardino Analysis of Impediments to Fair Housing Choice.

The Analysis of Impediments presents a demographic profile of the region, assesses the extent of housing needs among specific income groups, and evaluates the availability of a range of housing choices for residents. The Analysis of Impediments also analyzes the conditions in the private market and the public sector that could limit the range of housing choices or impede a person' s access to housing.

3. Housing Element Outreach
While outreach and community engagement have always been important, in recent years significant strides have been made in technology and level of effort regarding engagement. Past engagement may not always have had multiple forms of media, meaning that in -person public meetings were the primary form of engagement, with surveys and stakeholder interviews and other types of engagement taking a back seat. In -person public meetings are not always the most accessible for multiple reasons. If a meeting is at only one specific time, or if it is only offered in English, it can create participation barriers for those who may be unable to attend at the specified time or location, or people without proficiency in English.

Engagement related to the Housing Element has attempted to be comprehensive while in the context of the COVID- 19 pandemic. An online survey was used to engage residents on local housing needs and concerns. Stakeholder interviews were conducted via telephone, where public meeting participants were invited to share their thoughts in a one- on- one setting. Results of the interviews provided a better understanding of housing needs, priorities, opportunities, and constraints. All virtual meetings were held in English and Spanish to foster participation across demographics, as 34. 7 percent of the population is Spanish- speaking. Virtual meetings were open to the public and were recorded and made available for public viewing after the event as well. Because the virtual meetings were conducted to allow participants to practice social distancing, participants had the option of joining through their computers or tablets, or using a call -in number if they did not have access to the internet. Virtual meetings were also streamed onto Facebook, which allowed for post -meeting comments to be submitted. In addition, the outreach was held in the evenings, outside of working hours. An extensive outreach process contributes to a set of meaningful goals, policies, and programs that will reflect the City' s housing needs and the priorities and needs of all of those in the City, including those with special needs and lower -income populations.

Please refer to Appendix F, Community Engagement Summary and Results, for a full summary of outreach material and outreach conducted as part of the Housing Element update.

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4. Assessment of Fair Housing

4. 1. Fair Housing Enforcement and Outreach Capacity
This section discusses the fair housing services available to residents in the City of Highland and the corresponding organizations that provide fair housing services available to both providers and consumers of housing, as well as the nature and extent of fair housing complaints received by the fair housing provider. In general, fair housing services include investigating and resolving housing discrimination complaints; discrimination auditing and testing; and education and outreach, such as disseminating fair housing information through written materials, workshops, and seminars.

The City ^' coordinates with the Inland Fair Housing and Mediation Board ( IFHMB' s) to provide fair housing services for its residents. F^,„— heusing Services provided by IFHMB include is providing information as it relates to fair housing, investigation, education, conciliation, and/ or referral of housing discrimination complaints free of charge to individuals. It also involves fair housing workshops that are offered year- round to educate housing providers, tenants, homeowners, and financial and lending institutions on the key aspects of fair housing laws.

According to the California Department of Employment and Fair Housing, between the calendar years of 2013 and 2021, there were a total of wee-3 housing cases in the City. One of these was filed based on discrimination to national origin. Of the 3 cases, 2 were documented as failure to respond and 1 was documented as no valid issue. None of the cases filed in the City were based on sSex orientation, disability, race, familial status, religion, and color had iter^ he-, iRg rases filed iR the Gity. There are no known fair housing lawsuits in the City. Through this contract with the IFHMB, the City is able to effectively disseminate fair housing issues, provide resources and educational material through community outreach and other fair housing services provided to the residents of the City.

At the County level, there were 12 total cases in 2020. Of these 12 cases submitted to the Office of Fair Housing and Equal Opportunity (FHEO), 2 were for racial bias, 8 were for disability, and 1 forfamilial status.

Information regarding the validity of the cases or resolution count is not available.

Additional organizations that offer fair housing services and are available to the residents of the City include the following:

U. S. Department of Housing and Urban Development ( 4U4;4 California Department of Fair Employment and Housing ( DF€ H) Housing Authority of the County of San Bernardino -Qs
Inland Fair Housing and Mediation Board
Inland Counties Legal Services, Inc.

The IFHMB is a private nonprofit agency that serves the County and parts of Riverside and Imperial Counties. IFHMB is funded by grants and awards and serves as an intermediary to assist individuals in resolving issues related to housing discrimination, homeownership, rental complaints, and disputes in court. Other services include foreclosure prevention counseling and senior services. IFHMB also provides fair housing outreach materials for public and private agencies' use in English, Spanish, and Chinese. These resources provide individuals with definitions and examples of housing discrimination, fair housing as it

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relates to sex discrimination, and a social media fair housing toolkit. Their website also provides online resources such as links to COVID- 19 housing and food resources, rental assistance, and eviction moratorium updates.

The Housing Authority of the County of San Bernardino ( HACSB) provides rental assistance to low- income families by housing families in HACSB- owned or managed properties or through subsidized housing assistance to a landlord who rents their home to an assisted family. According to HACSB, they serve over 25, 000 persons most of whom are seniors, individuals with disabilities, veterans, and children. In addition to housing, HACSB provides resources such as food assistance, education for youth, senior resources a family self-sufficiency program, and a landlord participation incentive program.

Inland Counties Legal Services, Inc. ( ICLS) is a nonprofit organization providing legal services to low- income persons residing in the County and Riverside County. ICLS' s housing work focuses on both increasing affordable and quality housing, and helps people stay in their homes. In addition to their housing and legal services, ICLS also offers educational workshops such as small business assistance.

Specific to the City, the City will make all reasonable modifications to policies and programs to ensure that people with disabilities and or special needs groups, including low- income groups, have an equal opportunity to eniov all of its programs, services, and activities. In addition, the following resources are available to the City' s residents:

CA COVID- 19 Rent Relief - Housing Is Key. Will help income -eligible households pay rent and utilities, both for past due and future payments. The federal Consolidated Appropriations Act of 2021 provides funding to support the program and tenant (renter) protection laws signed by the current Governor, Governor Newsom.

Emergency Housing Voucher Program. This new program is available to families in the County and Riverside County who are experiencing homelessness or at risk of being homeless; are fleeing domestic or dating violence, sexual assault. Applicants must be referred by a partner agency in the continuum of care or the county' s Coordinated Entry System. Inland Counties Legal Services, Inc. website provides more information and resources related to this program.

California Free Legal Answers. This program is offered by LaWHelpCA. org and is available to California residents. Residents may submit a legal question relating to COVID- 19 and receive guidance from a lawyer free of cost.

Operation Grace. This program provides housing including rental assistance, emergency shelter and permanent supportive housing as well as programs to families at risk of losing their housing.

They also work with housing partners to provide homeless prevention services.

Housing Element Programs
The City is in compliance with existing fair housing laws and regulations. The City recognizes the effect that discrimination has in limiting housing choice and equal opportunity in renting, selling, and financing housing. The City offers fair housing information and links to the IFHMB and additional housing resources on the City' s website, Housing Programs webpage.

Through programs in the housing element, the City will continue to provide resources to fair housing enforcement and outreach, as well continue to partner with IFHMB for fair housing enforcement in the City (Program 15, Fair Housing Mediation).The City is committed to furthering fair housing and in addition

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to providing services for enforcing fair housing related issues, the City will also continue to actively participate in the Analysis of Impediments to Fair Housing to evaluate discriminatory practices in the County. Through Program 26, Fair Housing Analysis, the City is making a diligent effort to address fair housing issues in the City by evaluating the need to establish an Ad Hoc Fair Housing committee to provide Policy recommendations to guide policies and programs in a manner that furthers fair housing. Through Program 2, Residential Rental Enhancement and Rehabilitation Program, the City will provide outreach services and incorporate fair housing training for landlords. The City will administer all programs and activities related to housing and community development in a manner to Affirmatively Further Fair Housing.

Crime Free Multi -Housing Program
The Crime Free Multi -Housing Program is a partnership with property managers, owners, landlords and residents. The program is run by the San Bernardino County Sheriffs Department with the goal of reducing crime through community partnerships and pro -active steps to improve the quality of life for the community. The programs consist of three phases towards making a property a safer living environment for the tenants. The phases must be completed under the supervision of the local sheriffs station.

Property managers and owners can become individually certified after completing training in each phase and the property can become certified when all phases are completed. The program applies to anv Property that contains four or more rental units that are being rented out for residential dwelling purposes.

The program aims to increase community participation, provide accountability for property owners, and lower maintenance costs. The program phases improve public safety for tenants, property owners, and the community. Phase I of the program includes free classroom instruction, which includes establishing fair screening and the legal rights and responsibilities of owners and managers. Phase II of the program includes a property survey. Staff from the local sheriff' s station conducts an inspection of the property using Crime Prevention Through Environmental Design ( CPTED) principles. CPTED is a nationally accepted multi -disciplinary approach to deterring criminal behavior through environmental design. The property survey is strictly an on -premise inspection.

This program' s main point of focus and concern is regarding the safety of tenants and safety issues across the board of all projects over four rental units that are being rented out for residential dwelling purposes.

Therefore, the City has determined that implementation of the Crime -Free Ordinance Program does not constitute a constraint on providing housing for all income levels throughout the community, and does not have an implication on affirmatively furthering fair housing in the City because it is not targeting specific groups or classes. Refer to Section 1. 8. 7 of Appendix C — Constraints and Zoning Analysis, for additional euidelines and reauirements.

4. 2, Segregation and Integration
Patterns of segregation have been commonly linked to poorer life outcomes in income, housing equity, educational attainment, and life expectancy, according to research from the University of California,

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Berkeley.' Affirmatively furthering fair housing involves overcoming and reversing patterns of segregation. And taking meaningful actions that foster inclusive communities.

4. 2. 1. Race and Ethnicity
Like much of Southern California, u' the City is becoming more racially and ethnically diverse. The population of the CityNigh4aad is primarily White and/ or Hispanic. As of 2018, HighlandCity residents who reported being White were the majority. Non -Hispanic White residents made up 41. 7 percent of uc.. w
the Cit s population in 2000, and only made up 27. 6 percent of the population in 2018. In regard to ethnicity, the number of Hispanic residents of any race increased significantly from 2000 to 2018, going from 36. 6 percent of the population to now more than half the population. Residents of African American/ Black or Asian race do not make up the majority of the population in any of the City' s Census tracts, but there are over 4, 000 African American/ Black residents and Asian residents each within the City. From 2000 to 2018, the non -Hispanic African American/ Black population has reduced from 11. 7 percent of the population to 8. 1 percent. The non -Hispanic Asian population has increased from 5. 9 percent in 2000 to 9 percent in 2018. These changes could be attributed to several factors, including migration and childbearing, and trends can be complicated to discern when considering many individuals can be multiple races, and ethnicity is not exclusive of race. As shown in Figure 1A Race and Ethnic Distribution, the proportion of the Hispanic population in Highlaq4Lhe City is primarily in western Highland. The non -Hispanic White population is primarily in eastern Highland, with Boulder Avenue as the boundary distinguishing the eastern and western portions of Highland. The Hispanic majority in eastern Highland is sizeable or predominant for most of western Highland, whereas the White majority in eastern Highland is slimmer compared to the next predominant population. When compared to the broader region, Figure 113, Race and Ethnic Distribution in the Region, it is revealed that the split in demographics continues east and west of the City. Fontana, Ontario, and San Bernardino which are located west of the City are predominantly Hispanic, whereas Redlands and Yucaipa which is located east of the City is predominantly White in population.

Generally, the average racial composition and number of people of different races or ethnicities in neighborhoods differs depending on location. To further examine this distribution, this assessment relies on a calculation of the average racial composition of neighborhoods experienced by members of each racial group. These are sometimes referred to as " exposure indices." This is because they show the exposure a given race group experiences with members of their own and other races ( as a percentage of 100) in an average neighborhood of the city ( or metropolitan area) being examined. In the City --of mod, Hispanic residents are exposed to 42. 7 percent Hispanic residents and 35 percent White residents. On the other hand, White residents are exposed to 30. 7 percent Hispanic residents and 48. 9 percent White residents. 2 This shows that White residents are more likely to be exposed to other White residents, and Hispanic residents are more likely to be exposed to other Hispanic residents. This is true to varying degrees for all races and ethnicities examined in Highlaq4the City. Figure 2A Diversity Index, displays the levels of diversity across the different neighborhoods within the City. Higher diversity is seen Menedian, S., and S. Gambhir. 2018. " Racial Segregation in the San Francisco Bay Area," Othering & Belonging Institute, UC BERKLEY. https:// belonging. berkeley. edu/ study- finds- strong- correlations- between- segregation- andlife- outcomes- sf- bay- area. 2 Frey, W. H., and D. Myers. n. d. Segregation: Neighborhood Exposure by Race. CensusScope. https:// www. censusscope. org/ us/ s6/ p36448/ chart—exposure. html.

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in the predominantly Hispanic resident western core, whereas lower diversity is seen in eastern Highland.

From 2010 to 2018, the diversity of neighborhoods in Highland improved slightly across the City. Figure 213, Regional Diversity Index, shows that neighboring San Bernardino and other cities west of Highland are also higher in diversity. Diversity becomes lower moving eastward in the region.

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Another measure of segregation between two groups is the dissimilarity index ( DI). The DI measures the degree to which two spsEifi-Gracial or ethnic groups are distributed across a geographic area. The DI varies between 0 and 100 and measures the percentage of one group that would have to move across neighborhoods to be distributed the same way as the second group. A dissimilaFity i DI of 0 indicates conditions of total integration under which both groups are distributed in the same proportions across all neighborhoods. A di65iF ilaFit • ' DI of 100 indicates conditions of total segregation such that the members of one group are located in completely different neighborhoods than the second group. This is a helpful metric because it can show which race or ethnicity is the most segregated. Generally, the City of Highland is moderately segregated. Highland received an index rating of 36.2 when comparing White and Hispanic populations, indicating that roughly 36. 2 percent of Hispanic households are not distributed the same way as White households in the City. When comparing White and African American/ Black populations, Highland has a similar score of 33. 8. And when comparing White and Asian populations, Highland has a lower score of 18. 4. Since the other ethnic/ racial groups within the City have a small population percentage, the DI may be high even if the group is evenly distributed throughout the area.

Thus, this assessment only compares White, Hispanic, African American, and Asian populations.'

4. 2. 2. National -Origin
The proportion of foreign -born population is consistent with San Bernardino County at 21 percent.$ Those born in Latin America make up 70 percent of the foreign -born population in Highland and the second largest subset are those born in Asia at 25 percent of the foreign -born population. This is a significant portion of the population and should be given consideration for fair housing outreach and education.

4. 2. 3. Language
In the City and across the region, approximately 42 percent of residents speak languages other than English at home. 9 Individuals who do not speak English as their primary language and who have limited ability to read, speak, write, or understand English have limited English proficiency. Language barriers can increase the discrimination that immigrant populations may face in access to housing. Generally, immigrants with limited resources often face difficulty in acquiring adequate housing as they adjust to their new surroundings and obtain employment. As a result, housing problems such as overcrowding and overpayment are often more prevalent among those populations that recently immigrated.

4. 2. 4. Household Income
Household income is the most important factor determining a household' s abilityto balance housing costs with other basic life necessities, although economic factors that affect a household' s housing choice are not necessarily a fair housing issue. Fair housing issues occur when relationships among household income, household type, race/ ethnicity, and other factors create misconceptions, biases, and differential treatments. Discriminatory housing practices of the past, such as redlining, restrictive zoning, urban renewal, and steering, while illegal today, have led to a disproportionate gap in household wealth based on race and ethnicity.

Frey, W. H., and D. Myers n. d. Segregation: Dissimilarity Indices. CensusScope. https:// www. censusscope. org/ us/ s6/ p33588/ chart—dissimilarity. htmi. 8 U. S. Census Bureau. 2019. Demographic Trends. American Community Survey (ACS) 2014- 2019. 9 U. S. Census Bureau. 2019. Demographic Trends. ACS 2014- 2019.

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Within the City in 2019, the " Asian Alone" group had the highest poverty rate of any race or ethnicity at

22. 6 percent. The Hispanic population has the next highest poverty rate for a racial or ethnic group in the City at 21. 8 percent. A total of 17.9 percent of the Black, non -Hispanic population in the City were below the poverty level in 2019. The White, non -Hispanic population was far more fortunate, with only 9 percent of residents below the poverty level for 2019. 10
Household income in the City is displayed in Figures 3A through 5A at the local level, and Figures 3B through 513 at the regional level. Figure 3A Median Income, shows that the lowest median income in the City is found in the western core. All communities east of Palm Avenue have median household incomes at or above the State average of $87, 100. Figure 313, Median Income in the Region, shows that the -lower median income households in west Highland are+s similar to that of the adjacent C- ity of San Bernardino.

Throughout the entire region, median income varies. However, the FAea o„ ncame-;, likely„,- ehp oA,. e State aveFaRe inthe uirhha., ree. resof ea&h ,.i% Much ofthe same western area has over 30percent of residents in poverty, as can be seen in Figure 4A Poverty Status. The farthest southwest portion of the City has over 40 percent of residents inpoverty. Areas tothe east ofthis concentration of poverty have the next lowest incomes and percentages of people in poverty. Poverty for the most part is below 30 percent for much of the region, apart from Riverside and San Bernardino, as shown in Figure 4B Poverty Status in the Region. Figure 5A Low to Moderate Income, displays the percent ofthe population with low or moderate income, furthering the points made within this section. Additionally, Figure 513, Low to Moderate Income inthe Region, illustrates that most populated tracts inthe Inland Empire cities have low to moderate income populations that are more than 25 percent. 10 U. S. Census Bureau. 2019. Poverty Status in the Past 12 Months. 2019 ACS 5-Year Estimates. Page 113 City of Highland Affirmatively Furthering Fair Housing Analysis -157-
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4. 2. 5. Familial Status
Family structure is something that impacts the care of children, type of housing needed, financial needs, and more. Single - parent households require more time to take care of children than married or cohabitating couples, which can impact the jobs available to parents, income levels, and the amount of support afforded to children. Family structure is something that has evolved over time in the United States, with fewer couples marrying, and cohabitation occurring more often. Families with children, especially those who are renters, may face discrimination or differential treatment in the housing market.

For example, some landlords or property owners may charge larger households a higher rent or security deposit. According to the American Community Survey ( ACS) 2014- 2019, there were 4, 209 family households with married couples and 2, 410 single -parent households in the City. Figure 6A, Children in Single -Mother Headed Households, shows that single -mother headed households are more prevalent in the westernmost portions of the City. At the regional level, Figure 613, Children in Single -Mother Headed Households in the Region, show that the number of single -mother headed households in dthe City are as low as many places in the region. Figure 7A, Children in Married Couple Households, shows that the farthest southeast portion of the City has the highest proportion of children in married couple households. Needs of single -parent households include affordable housing and proximity to schools, childcare centers, transportation, recreation, employment, and other opportunities. Figure 713, Children in Married Couple Households in the Region, illustrate that the City has comparable percentages of children in married couple households to other cities. The trend follows where suburban areas tend to have a higher percentage than the urban core.

The household living structure of adults also can be examined for potential fair housing issues. Housing is much more affordable when costs and responsibilities are shared with a spouse. Areas with high rates of adults living alone can cause people to pursue the most affordable living situation possible, which can lead to overcrowded living situations or substandard housing. Figure 8A, Adults Living Alone, shows that there are not many adults in the City who live alone. Likewise, Figure 813, Adults Living Alone in the Region reveals that not many adults live alone throughout the Inland Empire. The cost of living in the region may be too high for households of single income. Figure 9A Adults Living with a Spouse, shows the lowest rates of adults living with a spouse was in western Highland. The highest rates of adults living with a spouse are in northern Highland. Furthermore, Figure 913, Adults Living with a Spouse in the Regions shows that northern Highland has one of the highest rates of adults living with a spouse in general when compared to the region.

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4. 2. 6. Persons with Disabilities
Fair housing choice for persons with disabilities can be compromised based on the nature of a person' s disability. Persons with physical disabilities may face discrimination in the housing market because of the need for wheelchairs, home modifications to improve accessibility, or other forms of physical assistance.

A major barrier to housing for people with mental disabilities is opposition based on the stigma of mental disability. Landlords or property owners might refuse to rent to tenants with a history of mental illness.

Further, neighbors may object when a house becomes a group home for persons with mental disabilities.

According to population disability data available through ACS 2014- 2019, 6. 5 percent of the population in the City under 65 years of age have some type of disability. In general, many persons with disabilities have lower incomes since the disability often affects their ability to choose from a range of employment opportunities. The cost of housing may also be greater for persons with disabilities as there are additional costs when retrofitting for ADA improvements which can have a significant impact on a person' s income especially lower -income groups. Thus, persons with disabilities often have a greater need for affordable housing, as well as supportive services. Persons with disabilities are relatively evenly spread throughout the City, with higher concentrations falling within tracts outside of the central core, as seen in Figure 10A Population with a Disability. Similarly, Figure 10B, Population with a Disability in the Region, shows that persons with disabilities is evenly spread throughout the region as well.

4. 2. 7. Neighborhood Segregation
As previously mentioned, residents in highly segregated neighborhoods often experience poorer life outcomes. The typologies in Figure 11A Neighborhood Segregation, identify which race/ ethnicity populations have more than 10 percent representation within the given tract. Figure 11A demonstrates a relatively diverse mix of ethnic/ racial groups within a given tract. The City is primarily " Latinx- White" in the east and " 3 Group Mix" in the west. Both figures identify a concentration of non- White groups in the western portion of the City. The more diverse areas are also associated with a higher concentration of renters and poverty status. Figure 11B, Neighborhood Segregation in the Region, illustrates that much of the Inland Empire have tracts that are either predominantly Latinx- White or 3- 4 Group Mix. As with eastern Highland, much of the eastern region is primarily Latinx- White. Highland is one of the few cities in the region with a tract that is primarily Black- Latinx, along with Moreno Valley, Rialto, and San Bernardino.

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4. 3. Racially and Ethnically Concentrated Areas of Poverty Racially or ethnically concentrated areas of poverty ( R/ ECAPs) are neighborhoods with concentrations of both poverty and singular races or ethnicities. These are generally Census tracts with a majority of nonWhite residents and a poverty rate of 40 percent and higher in the City, or three times the average tract poverty rate for San Bernardino County. In addition to highlighting historic discrimination, R/ ECAPs also have lower economic opportunity in the present day. Figure 12k., R/ ECAP and Segregation and Poverty, shows the three Census tracts considered R/ ECAPs in the City are concentrated in areas near the City of San Bernardino to the west. The farthest west R/ ECAP tract is Census Tract 65, the middle R/ ECAP tract is Census Tract 74.07, and the upper R/ ECAP tract is Census Tract 76. 01. These are also near areas of high segregation and poverty identified by the California Tax Credit Allocation Committee ( TCAC). This is consistent with the concentration of R/ ECAP parcels in the City that are near the City of San Bernardino.

R/ ECAPs are uncommon throughout the region, as shown in Figure 12B, R/ ECAP and Segregation and Poverty in the Region, and are mainly found in the cities of Ontario, Riverside, and San Bernardino.

These R/ ECAPs contain approximately 17. 4 percent of the City' s population, which amounts to about 9, 500 people. Two of the three R/ ECAPs are primarily residential areas, while the farthest west of the three is more of a mix between commercial and residential. According to 2019 U. S. Census data, each of the three R/ ECAPs contain more than 10 percent above the rate of the Hispanic population for the overall City. Additionally, the central R/ ECAP tract has more than double the proportion of African American/ Black residents than the City overall. All three R/ ECAP tracts have significantly higher levels of poverty than the City' s total, with the farthest west R/ ECAP having the highest poverty rate at 48. 7 percent ofthe population. The west and middle R/ ECAPs have nearly three times as many renters as homeowners, and the northernmost R/ ECAP is consists of approximately half renters and half homeowners.

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4. 3. 1. Racial Concentrations in Areas of Affluence
In addition to an analysis of R/ ECAPs, this Affirmatively Furthering Fair Housing analysis considers racially concentrated areas of affluence ( RCAA). Scholars at the University of Minnesota Humphrey School of Public Affairs have created the RCAA metric to tell the story of segregation in the United States more fully.

Based on their research, RCAAs are defined as Census tracts where:
80 percent or more of the population is White, and
the median household income is $ 125, 000 or greater ( slightly more than double the national the median household income in 2016).

While this is a useful measure nationwide, the California Department of Housing and Community Development ( HCD) has adjusted the RCAA methodology to better reflect California' s relative diversity.

HCD' s RCAA data is not yet available, but Figures ifs, and 31':, above, provide a preliminary analysis that displays the areas where the White population exceeds 50 percent of the population and where the median household income is $ 125, 000 or greater. The tracts with the highest proportion of the White population are Census Tracts 060710111. 01 and 060710115. 00, which overlap within Highland but are primarily located outside of the City' s boundary. The block groups where the median income exceeds 125, 000 are Block Group 2, Tract 79. 01 and Block Group 3, Tract 79. 04.

4.4. Patterns Over Time
Historically in the United States, housing discrimination ( both explicit and covert) has occurred through land use policy and zoning, mortgage lending practices, landlord or property owner decisions on rental applications, and patterns of public and private investment and disinvestment. These trends have resulted in residential segregation based on race, ethnicity, income, disability, and other characteristics, and has limited housing choices and access to opportunities for many Americans, especially for communities of color.

Significant historical events in the City that influenced early land use patterns include the forced relocation of the San Manuel Band of Mission Indians to a reservation in 1891, followed by settlements along Base Line and Palm Avenue then Palm Avenue and Pacific Street during westward expansion. The growth of the citrus industry in the early and mid- 1900s gave rise to large farms and packing houses throughout the City.

In 1942, Norton Air Force Base began operation, and the surrounding Highland neighborhoods experienced significant development of small and mid -sized tract homes with corresponding commercial development along Base Line and other east/ west corridors.

In the 1980s, developer Mobile Oil purchased approximately 1, 800 acres in the eastern portion of the City and received approval from the County of San Bernardino to construct a new community with multiple housing types, common areas, and amenities. The establishment of this " new community" is the defining event that led to the perceived split in the City between east/ west, new/ old, and more/ less affluent. The construction of the 210 Foothill Freeway exacerbated this perception, along with the division of school districts along similar boundaries.

The City was incorporated in 1987 and derived its early land - use policy from the County of San Bernardino.

In 1991, the City formed a Redevelopment Agency that identified a target area of lower -income

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neighborhoods, vacant and underutilized land, and areas in need of basic infrastructure. The Redevelopment Agency adopted goals and policies to " increase, improve and preserve the quality of low/ moderate income housing throughout the project areas and the City." Housing needs goals included securing long- term affordability covenants, creating rehabilitation programs for rental units and singlefamily homes, providing a down payment assistance program, working with the County of San Bernardino Department of Housing, identifying funding programs and housing needs, and identifying inclusionary and replacement housing. The Redevelopment Agency was successful in many of its endeavors, including the construction of 184 low-income apartment units, rehabilitation of several hundred single-family homes, a new 17- acre park, a community center, a library, a police station, and miles of infrastructure almost wholly on the west side of the City. The Redevelopment Agency was dissolved by the State of California in 2012.

During the 4th and 5th Cycle Housing Elements, the City rezoned numerous properties to permit medium - and high -density housing by right, and rezoned properties mid -block along Base Line from commercial to residential. Properties in the vicinity of Interstate 210, with excellent access to bus lines, were rezoned Mixed Use to allow a variety of housing types in conjunction with a new pharmacy, grocery store, retail, and restaurant. The City has engaged several affordable housing developers to construct a lower -income senior housing project on Housing Authority property on Central Avenue, south of Base Line.

Public participation is of the utmost importance as the City continues to modify and improve its housing policy. The City follows all public noticing policies, has a newly updated website, social media accounts on several platforms, and easily accessible staff. Public outreach has occurred at the City' s Community Center, Library, City Hall, Chamber of Commerce events, and remotely via computer applications.

4. 4. 1. Mortgage Loan Access
A key aspect of fair housing choice is equal access to credit for the purchase or improvement of a home.

Lending policies and requirements related to credit history, current credit rating, employment history, and the general character of applicants permit lenders to use a great deal of discretion, and in the process, deny loans even though the prospective borrower would have been an acceptable risk. Despite the illegality of discriminatory practices in the housing credit system, patterns of inequality still exist.

Discriminatory practices in home mortgage lending have evolved in the past five to six decades. In the 1940s and 1950s, racial discrimination in mortgage lending was easy to spot. From government - sponsored racial covenants to the redlining practices of private mortgage lenders and financial institutions, ethnic minorities were denied access to home mortgages in ways that severely limited their ability to purchase a home. During the recent rise of the subprime loan market, 31 discriminatory lending practices became more subtle. By employing high- pressure sales practices and deceptive tactics, some mortgage brokers pushed minority borrowers into high - cost subprime mortgages that were not well - suited to their needs and led to financial problems.

Conventional and Government -Backed Financing
According to the Federal Financial Institutions Examination Council ( FFIEC) data for 2016, approximately 48, 209 households ( for a total of $ 13, 388, 132) applied for conventional loans in the Metropolitan 31 TD Bank Corp. 2007. A Primer on the U. S. Sub -Prime Market. April 30, 2007. The subprime mortgage market ballooned in 2005 and 2006 to 20 percent- 25 percent of all new mortgages, capturing more than twice the market share seen over the prior 10 years.

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Statistical Area of (MSA) of Riverside —San Bernardino —Ontario, California. Among all applications received that year, 25, 573 loans were originated and 3, 469 where denied. The population of White persons participated at the highest level, submitting 27, 278 conventional loan applications. The Hispanic population, the second highest participants, provided the market with 12, 921 loan applications. Even though the Hispanic population make up 50 percent of the total population within the MSA, they only accounted for 27 percent of all loan applications submitted. The African American population submitted just 296 applications in 2016, which was the lowest participation rate amongst the four largest populations. There was no significant variance in rate of denial amongst racial/ ethnic groups.

According to the FFIEC data, approximately 35, 874 households (for a total of $9, 823, 136,000) applied for government -backed loans in the MSA of Riverside —San Bernardino —Ontario, California. Among all applications received in 2016, the number of loans originated was 25, 573, and the number of percentage of applications denied was approximately 10 percent. When broken down by race and ethnicity, participation in the market varied. The population of White persons once again had the highest participation levels, similar to conventional loans, submitting 27, 278 government - backed loan applications, amounting to $7, 251, 363, 000. The population of African American persons were the lowest participants in government -backed loans, with only 296 applications submitted in 2016, for a total amounting to $80, 132, 000. With all racial/ ethnic groups denial rates being within 4 percent of each other as well as the MSA area as a whole, there was no significant variance in rate of denial.

Subprime Lending
According to the Federal Reserve, prime mortgages are offered to persons with excellent credit and employment history, and income adequate to support the loan amount. Subprime loans are loans to borrowers who have less -than -perfect credit history, poor employment history, or other factors, such as limited income. Subprime lenders generally have interest rates that are higher than those in the prime market and often lack the regulatory oversight required for prime lenders because they are not owned by regulated financial institutions. Although subprime lending cannot in and of itself be equated with predatory lending, studies have shown a high incidence of predatory lending in the subprime market. The FFIEC data does not provide information on which loans were subprime loans. As such, analysis on this topic is difficult. It will be important to monitor lending institutions with high loan approval rates in the City, should any be discovered.

4. 4. 2. Demographic Trends
Patterns developed over time in the City are apparent in the demographic, household, and housing characteristics. Between 2000 and 2019 the median age of the population has increased by 4.5 percent, the proportion of the Hispanic population increased by 16 percent. Overpayment of homeowners declined in nearly all tracts across the city between the 2010- 2014 period and the 2015- 2019 period and overpayment by renters saw similar declines in many tracts across the City_during the same period. The Needs Assessment, provided in Appendix B, Community Profile, provides additional data and analysis of the demographic patterns within the City. The effects of the previously discussed historical patterns over time can be seen through the current demographic makeup of the City. 4, S Disparities in Access to Opportunity
Neighborhoods with high access to opportunity are places that result in strong economic, environmental, health, and educational outcomes for residents. Lower -income households and racially segregated

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communities are more highly concentrated in distressed and disadvantaged areas with low access to opportunity where residents are disproportionately exposed to crime, environmental hazards, and a lack of investment, resulting in poorer physical and mental health outcomes. Disadvantaged areas tend to have less access to quality employment opportunities, leaving lower -income households at a greater risk of remaining financially insecure.

When affordable housing is located in high- opportunity/ high- resource areas, this increases access to resources such as quality schools, employment, transportation, low poverty exposure, and environmentally healthy neighborhoods. Research indicates that among various economic and social factors, being in proximity to certain amenities can encourage positive critical life outcomes. 32 When affordable housing is dispersed throughout new development in high -resource residential areas, as opposed to being concentrated in existing areas of poverty, research consistently shows that residents of such affordable housing developments have increased quality of life, better access to opportunity and prosperity, and higher school performance. For example, a study by the Urban Institute' s Metropolitan Housing and Communities Center found that lower -income residents who reside in mixed -income communities report an increased sense of neighborhood safety; improved employment prospects; improved job readiness and job promotions; better emotional, mental, and physical health; and significant improvements in children' s academic performance.

Federal and State agencies have shown an increased focus in promoting increased access in high - opportunity areas. This trend is evident in the States' allocation of Low -Income Housing Credit dollars, the primary subsidy that is available for developing and preserving affordable housing. To allocate these credits, the California Housing Finance Agency (CaIHFA) develops a competitive scoring system. In recent years, the scoring system has been adjusted to promote investment in affordable housing in areas with access to opportunity. Several agencies, including the Department of Housing and Urban Development and the HCD in coordination with TCAC, have developed methodologies to assess and measure geographic access to opportunity ( including education, poverty, transportation, and employment) in areas throughout California. The Opportunity Map created by TCAC and HCD ( using data from 2020) is used to identify areas in the region whose characteristics are shown by research to support positive economic, educational, and health outcomes for families — particularly long- term outcomes for children. Further, this section will review access to opportunity in relation to education, economic development, environment, transportation, and access to opportunities for persons with disabilities.

High -resource areas are those areas, according to research, that offer low- income children and adults the best chance at certain positive life outcomes: economic advancement, high educational attainment, and good physical and mental health. The Opportunity Map plays a critical role in shaping the future distribution of affordable housing in areas with the highest opportunity. The 2021 TCAC/ HCD Opportunity Map identifies the areas east of Boulder Avenue as high -resource areas ( Figure 13A Opportunity Map).

To the areas west of Boulder Avenue, tracts are identified as high segregation and poverty, low resource, and moderate resource. The high segregation and poverty area aligns with the R/ ECAP zones identified in previous sections. Economic, educational, and environmental indexes show low scores in the identified R/ ECAP areas. In contrast to the opportunity areas shown in the map, many of the City' s resources related 32 Freddie Mac and the National Housing Trust. 2020. Spotlight on Underserved Markets: Opportunity Incentives in Low -Income Housing Credit Qualified Allocation Plans.
https:// www. sahfnet. org/ sites/ defau It/ files/ uploads/ resources/ opportunity_ incentives_ in_ li htc_ qualified_ allocation_ plans. pdf.

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to commercial and governmental services, such as mental health facilities, mass transit access, parks and recreational facilities, food access, and other commercial services, are located in the eastern portions of the City. At a regional scale, Figure 13B, Regional Opportunity Map, illustrates a pattern of highest resources being concentrated in suburbs and foothill communities, which may explain why nthe u;^" City' s highest resources are to the northeast part of the City.

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4. 5. 1. Access to Education
Access to quality education is one aspect of opportunity. The City is served by the Redlands Unified School District and the San Bernardino City Unified School District. 3s 36 The boundaries for the Redlands Unified School District encompasses the eastern portion of the City until City Creek. The San Bernardino City Unified School District encompasses the western portion of the City.

Redlands Unified School District encompasses 147 square miles and serves the communities of Redlands, Loma Linda, Mentone, Forest Falls, and portions of San Bernardino and the City. The Redlands Unified School District consists of 15 elementary schools, 4 middle schools, and 4 high schools. Current enrollment in grades K- 12 is 21, 333 students. The ethnicity of the student population is consistent with the City' s population of various ethnic/ racial backgrounds (31. 6 percent White and 45 percent Hispanic). The district serves 1, 965 English -language learners ( 9. 2 percent). Thirty separate languages comprise the home languages of these students. The Redlands Unified School District reportedly ranks 8/ 10 in testing, ranking above the Statewide average in both math and reading proficiency, and spends $ 11, 364 per student each year.

The San Bernardino City Unified School District consists of 50 elementary schools, 11 middle schools, and 10 high schools. Enrollment in K- 12 is 53, 037 students. According to the 2019/ 2020 district summary, there are 20. 8 percent English -language learners, and 89. 4 percent of students are considered socioeconomically disadvantaged. The student population is predominately Hispanic ( 77. 7 percent). The San Bernardino City Unified School District offers dual immersion programs at several elementary schools, spends $ 12, 604 annually per student, and provided 1, 330 student -earned scholarship/ grants in 2018/ 2019. The San Bernardino City Unified School District reportedly ranks 3/ 10 in testing and falls below the Statewide averages for both math and reading proficiency.

Table 1, California Assessment of Student Performance and Progress — Science ( 2018- 2019), compares the standardized test scores for grades 5, 8, and high school in science by race/ ethnicity for both districts.

Table 1: California Assessment of Student Performance and Progress — Science ( 2n18- 2m ql Student Total Number Percent Percent Not FPercent Met
Group Enrollment Tested Tested Tested xceeded
San Bernardino City Unified School District
All 11, 725 11, 405 97. 27% 2. 73% 19. 32%
Black or 1, 282 1, 229 95. 87% 4. 13% 12. 61%
African
American
American 45 44 97. 78% 2. 22% 13. 64%
Indian or
Alaska Native
Asian 187 185 98. 93% 1. 07% 48. 11%
Filipino 50 48 96. 00% 4. 00% 50. 00%
Hispanic or 9, 180 8, 947 97. 46% 2. 54% 18. 18%
Latino
31 Redlands Unified School District. n. d. Schools Boundary Map. https:// www.redlandsusd. net/ Page/ 114. 36 San Bernardino City Unified School District. 2021. School Boundaries. https:// sbcusd. com/ cms/ One. aspx? portaIId= S99S3& pageId= 13414SO.