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CITY OF LAGUNA HILLS
Supplemental Agenda Material Memo
Supplemental Agenda Materials related to an item on a City Council Agenda submitted to the City Council after distribution of the agenda packet will be available for public inspection in the City Clerk’s Office located at: 24035 El Toro Road, Laguna Hills, California, during normal business hours. In addition, such materials will be made available for public review on the City’s website at: https://www.lagunahillsca.gov/supplementalagenda and at the respective public meeting.
DATE: March 26, 2024
TO: City Council
City Staff
FROM: Larry Longenecker, Community Development Director SUBJECT: City Council Regular Meeting Agenda Item 6.1 – Housing Element/Rezone Program/Objective Design Standards – Revision to project Addendum to the General Plan Program EIR (Exhibit 2 of Attachment A)
Staff has added a statement to the proposed project Addendum (Exhibit 2 of Attachment A in Agenda Item 6.1), to clarify that the General Plan Program EIR as modified by the Addendum is not intended to act as the sole environmental analysis for future housing projects. The added statement is as follows:
“This Addendum is intended solely to analyze the impacts of the proposed Housing Element Update / Rezoning / Objective Development Standards at a programmatic level. It is not intended to serve as the environmental analysis for later, site-specific projects.” The statement has been added to Section 3 (Environmental Approach and Analysis) on
City of Laguna Hills
Addendum to the General Plan Final Program EIR for the
2021-2029 Housing Element Update, Rezoning Program, and Objective Design Standards Project Environmental Approach and Analysis 3-1
3 ENVIRONMENTAL APPROACH AND ANALYSIS
This analysis has been prepared to determine whether the proposed Project could result in any new significant impacts or a substantial increase in the severity of previously identified significant impacts in the General Plan Final PEIR. This review is limited to evaluating whether the Project would trigger further environmental analysis beyond the General Plan Final PEIR. This Addendum is intended solely to analyze the impacts of the proposed Housing Element Update / Rezoning / Objective Development Standards at a programmatic level. It is not intended to serve as the environmental analysis for later, site-specific projects.
This analysis is based on the CEQA Guidelines Appendix G Checklist and provides a summary of impacts in the General Plan Final PEIR and the potential impacts associated with the Project. This comparative analysis provides the City with the factual basis for determining whether the Project would require additional environmental review such as the preparation of a Subsequent EIR or Supplemental EIR.
1 Subject: FW: Mill Creek Drive Proposed Development
From: Mike Chambers <[email protected]>
Sent: Tuesday, March 26, 2024 2:34 PM
To: Larry Longenecker <[email protected]>
Subject: Mill Creek Drive Proposed Development
Dear Director Longenecker,
I have been a home owner in Laguna Village for 15 years. I love it here primarily for the beautiful, quiet environment and wildlife refuge adjacent to my home. I know the City of Laguna Hills is mandated to add residential density to our city. Which falls on your shoulders. I perused through the city documents and made myself aware of the new proposed development at the Mill Creek Drive area. You did a great job of highlighting that area as a good area to develop. However, I see that a developer wants to add 800 Units to that area. I believe we are talking about 12 acres. I read in the City's documents that the default density for housing units per acre is 30 units per acre. In using that calculation it would mean 360 units would the maximum default. Therefore, I believe a proposed 800 units for that area would extremely overwhelm the density of this beautiful area of Laguna Hills. Not only would the air quality, traffic, and sound level adversely affect the residents in the area, but the sensitive wildlife adjacent to the new development would suffer as well.
I strongly recommend you consider these things as you move forward.
Thank you for your service to our city,
Sincerely,
Michael Chambers
22212 Caminito Escobedo,
Laguna Hills
92653
Public Comments
March 26, 2024
Item No. 6.1
1 Subject: FW: For Public Record: 3/26/24 City Council Public Hearing Agenda Item 6.1 Attachments: 2024-03-25_WNH to Laguna Hills re HE Amendments Submitted.pdf From: Rona Henry <[email protected]>
Sent: Monday, March 25, 2024 4:10 PM
To: Dave Wheeler <[email protected]>; Joshua Sweeney <[email protected]>; Don Caskey <[email protected]>; Janine Heft <[email protected]>; Erica Pezold <[email protected]>; Public Comments <[email protected]>
Cc: Larry Longenecker <[email protected]>; Jarad Hildenbrand <[email protected]>; Kent Doss <[email protected]>; Denise Legters <[email protected]>; Ann Owens <[email protected]>; Kate Van Camp <[email protected]>; Jose Ayala <[email protected]>; Housing Elements <[email protected]>; Cesar Covarrubias <[email protected]>; Julian Gutierrez <[email protected]> Subject: For Public Record: 3/26/24 City Council Public Hearing Agenda Item 6.1 Please see the attached public comment from Denise Letgers, Ann Owens, Kate Van Camp, Rev Kent Doss and myself related to agenda item 6.1 General Plan Amendment.
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Rona Henry
Chair, Welcoming Neighbors Home Initiative
Tapestry, a Unitarian Universalist Congregation
[email protected] 609-216-1784
Public Comments
March 26, 2024
Item No. 6.1
March 25, 2024
Dear Mayor Wheeler, Mayor Pro Tem Sweeney and Councilmembers Caskey, Heft, and Pezold, We understand that at the March 26th City Council meeting that the Council will consider the following:
(A) General Plan Amendment No. RZNE-0010-2024 to (1) amend the General Plan Housing Element to incorporate technical changes and clarifications reflected in the Amended 2021- 2029 Housing Element Update and (2) amend the General Plan Land Use Element to implement Implementation Program H-11 of the Amended 2021-2029 Housing Element Update by specifying that designated sites may be developed at residential densities between 20 and 50 dwelling units per acre; (B) Zoning Text Amendment and Zoning Map Amendment No. RZNE-0011-2024 to implement Implementation Programs H-7 and H-11 of the Amended 2021-2029 Housing Element Update by ( 1) modifying the development standards applicable to high density residential uses in the City's Mixed Use (MXU) Zoning District (see exhibit on opposite page), (2) establishing a Housing (H) Overlay Zone (see exhibit on opposite page) and related provisions and development standards, and (3) modifying the City's official Zoning Map to apply the Housing (H) Overlay Zone to specified properties; and (C) Zoning Text Amendment No. RZNE-0012-2024 to implement Implementation Program H-9 of the Amended 2021-2029 Housing Element Update by establishing citywide objective design standards for multi-family residential and mixed-use projects.
We commend the City for all the work that went into developing the Objective Design Standards. When we talk to people who are familiar with these standards, we have been told they are fairly consistent with what other cities have approved. We urge the city to continue to monitor them against actual project proposals and make adjustments to the standards as needed to enable the development of the most affordable housing that is possible.
We remain concerned that the upzoning that is proposed in the Housing Element, with density at 50 units/acre, in the absence of meaningful programs to ensure the inclusion of affordable housing, will result in market rate housing without progress being made to meet the City’s lower income RHNA requirements. Even if developers use the State Density Bonus, which requires certain levels of low-income housing, the City should have more rigorous requirements. We urge the City to immediately begin to fulfill the commitment made in the updated Housing Element – under Program H-7 Zoning Ordinance Update – to study Inclusionary Housing Requirements – and to go further and adopt an Inclusionary Housing Policy. We recommend a policy that requires: 7.5% for very-low-income ($71,350 for family of 4) and 7.5% for low-income ($114,800 for family of 4). We support Extremely-LowIncome ($43,500 for family of 4) being a substitute for either of these categories.
We also wish to remind you of the concerns we shared with you earlier – particularly the recommendation to include more sites on the housing inventory in other parts of town.
Please see the attached letter.
Thank you for your service.
Sincerely,
Rona Henry, Chair Denise Legters, Laguna Hills Resident Welcoming Neighbors Home Welcoming Neighbors Home Volunteer Ann Owens, Volunteer Kate Van Camp
Welcoming Neighbors Home Volunteer Welcoming Neighbors Home Volunteer Rev Kent Doss, Minister
Tapestry Unitarian Universalist Congregation
cc: Larry Longenecker, Community Development Director, Laguna Hills Jarad Hildenbrand, City Manager, Laguna Hills
Jose Ayala, California Office of Housing and Community Development Cesar Covarrubias, Kenney Commission
Julian Gutierrez, Kennedy Commission
March 22, 2023
Jose Ayala
California Office of Housing and Community Development
2020 West El Camino Avenue
Sacramento, CA 95833
Dear Jose,
We understand that the City of Laguna Hills has submitted their March 2023 Housing Element Draft to HCD (posted on their website) – which we have now reviewed. We were advised that because it did not have substantive changes, it did not need to go back to City Council.
We are appreciative of the response letter from Larry Longnecker regarding our earlier public comments. We recognize the thoroughness of the letter and the time it took to write.
Below are our observations about the latest Housing Element draft. • We were glad to see that the Housing Inventory now excludes the Alicia Village and Alicia Plaza apartment sites that seemed to us unrealistic in terms of redevelopment. • We see letters from some of the property owners are attached in the housing element.
The re-zoning to 50 units/acre will give property owners more values to their land – and we can understand why the property owner who submitted letter were supportive. But none of the writers are committing to building affordable housing. We would like to better understand the City’s basis for optimism that lower income units will be built on these sites.
• The Program section does not include any incentive programs or requirements for lower income affordable housing. The language on Page A-3 (PDF Page 261) is vague:
“studying opportunities related to inclusionary housing requirements, adaptive reuse, and a congregational housing overlay”. Studying something is not the same as saying that you will be implementing such policies by a date certain. • We question the inclusion and assumptions listed on the Site Inventory for Site #115 - 23802 Avenida de la Carlota.
o This is the site of St. George’s Episcopal Church – located right next to the I-5 freeway.
o At one point there were discussions with CalTrans about possible traffic relief measures that might impact their property. That possibility no longer appears to apply. Rev. Pat McCaughan and Joyce Swaving, Bridge Builder and Bishop’s Warden at St. George’s indicated to us that they do NOT intend to move.
o We learned that St. George’s had actually considered building affordable housing on their parking lot several years ago and had gotten an assessment from an affordable housing developer. At that time, given the odd shape of the parking lot (see photo below) – which is about 6,000 square feet, and because the St. George’s would still need parking for its current use (services and school), at most the developer thought they could build only 25 units on this site. (It would need to be a podium structure with 2 floors of parking – which makes it more expensive to build.)
Site # 115 - 23802 Avenida de la Carlota - St. George’s Episcopal Church Parking lot:
o Apparently, there is property owned by the City of Laguna Hills next to the parking lot – and if this was added to the building site, perhaps the plot could expand to close to an acre and thus be financially feasible. But the City would need to donate the land, as well as adopt a Congregational Overlay. But it would have to be something less than 117 units because the Church does not plan to vacate any existing structures. That said, financing would be very difficult because the Orange County Housing Finance Trust is requiring City matches. To our knowledge, Laguna Hills has not been collecting in lieu fees or other fees that that could be used as a match.
o The bottom line: The 117 lower income units projected by the City at Site #115 does not seem feasible given that the Church does not plan to vacate the rest of the property.
• We wonder why the sites for lower income housing are segregated in one area of town, in the North by the I-5 freeway. We wonder if Fair Housing Law would require that lower income housing be dispersed throughout town, including census tracts with the higher scores for education, environment and income. Especially since at least 1 site is available in those areas (see next bullet).
• We were puzzled on why the City did not include on the newest Housing Inventory, or in its General Plan Annual Progress Report 2022 (shown in the March 14, 2023 City Council Agenda Packet on PDF Page 33), a Builders Remedy site at 25250-25254 La Paz Road, Laguna Hills, CA 92563. This site is listed on their website here:
https://www.ci.laguna-hills.ca.us/537/Builders-Remedy. The plans call for a total of 190, with 152 being market rate and 38 being low income units. Our preference would be for this project to include very-low-income and extremely-low-income units. Unfortunately, the City has not yet instituted an inclusionary housing ordinance that would have ensured this. That said, this site is in an area of town with the highest educational and environmental scores, and higher income, so it would be good to see some lower income housing going there.
From PDF Page 174 of March 2023 Housing Element Draft:
From PDF Page 175 of March 2023 Housing Element Draft:
From PDF Page 181 of March 2023 Housing Element Draft
In summary, we hope that before the City gives property owners an increase in land value by zoning for higher density, and developers the opportunity to earn higher profits, they adopt Housing Element programs that will ensure that lower income affordable housing (especially for very-low-income and extremely-low-income households) is included in any new housing development. The needs of residents such as teachers, retail workers, and health care aids will go unmet without having such programs in place.
Sincerely,
Rona Henry, Chair Denise Legters, Laguna Hills Resident Welcoming Neighbors Home Welcoming Neighbors Home Volunteer Ann Owens, Volunteer Kate Van Camp
Welcoming Neighbors Home Volunteer Welcoming Neighbors Home Volunteer Rev Kent Doss, Minister
Tapestry Unitarian Universalist Congregation
Cc: Larry Longnecker, Community Development Department, Laguna Hills Mayor Heft
Mayor Pro Tem Wheeler
Council Members Caskey, Pezold and Sweeny
Cesar Covarrubias, Kennedy Commission
Paul McDougall, CA State Office of Housing & Community Development Rev Pat McCaughan, St. George’s Episcopal Church
Joyce Swaving, St. George’s Episcopal Church
March 26, 2024
Mayor Dave Wheeler
City Council Members
City of Laguna Hills
24035 El Toro Rd
Laguna Hills, CA 92653
RE: Agenda Item #6: General Plan Amendment No. RZNE-0010-2024 To the Honorable Members of the City Council:
The Kennedy Commission (the Commission) is a broad-based coalition of residents and community organizations that advocates for the production of homes affordable for families earning less than $30,000 annually in Orange County. Formed in 2001, the Commission has been successful in partnering and working with Orange County jurisdictions to create effective housing and land-use policies that have led to the new construction of homes affordable to lower-income working families.
As the City of Laguna Hills works towards obtaining its 2021-29 Housing Element compliance, we urge the city to implement a strong inclusionary housing program along with the rezoning of sites to meet its affordable housing goals. Rezoning sites at higher density alone will not facilitate the development of lower income affordable housing.
The City needs sites at appropriate densities and an affordable housing policy that will intentionally facilitate affordable housing at lower incomes. Without an affordable housing policy the City will simply incentivize higher density market rate housing with these rezonings. As an example, these new higher-density market rate multi-family rentals average rent range from $3,100 - $3,400 a month for a 2 bedroom apartment at REATA Apartments in Laguna Hills. These units are unaffordable to most of the Laguna Hills residents and low income families.
Under the Regional Housing Needs Allocation (RHNA), the City must plan for the development of 1,985 new homes, 284 units are to be affordable to extremely low-income households, 284 units are for very low-income households, and 353 units are for low-income households. Affordable housing opportunities in Laguna Hills are greatly needed, especially for working-class families. It is imperative that the City Council finds every opportunity to ease the burden of its residents and creates housing opportunities for all in the City of Laguna Hills.
As the City moves forward with the general plan amendments and official zoning map in order to accommodate the development of new housing sites, we request that the city specifically focus on facilitating affordable housing for families who fall into the extremely low, very low, and low-income categories. To facilitate this process, the Kennedy Commission urges the City of Laguna Hills to adopt an Inclusionary Housing Policy, where developers will be required to build a percentage of units in a market-rate housing project as affordable to lower income households. Adopting an Inclusionary Housing Policy will greatly assist the City in meeting its allocated RHNA numbers, according to its 6th Cycle Housing Element.
In order to ensure that affordable housing is developed in the planning period, the Commission urges the City to:
1. Develop and implement policies and programs that facilitate affordable housing in the City. Examples of effective policies are mixed-income ordinances and inclusionary housing policies which guarantee that any development in the City will provide affordable housing.
2. Incentivize the development of affordable housing on the sites proposed to be rezoned or increased in densities to facilitate residential development. Rezoning increases land use opportunities for developers Public Comments
March 26, 2024
Item No. 6.1
and raises the value of the property. These incentives to owners and developers should be balanced with affordable housing needs in the City for lower income. The City should request that a minimum of 15% of the units on these sites be affordable to Low, Very Low and Extremely Low residents.
3. Prioritize the development of affordable housing on City-owned and land and surplus land. The city should incentivize the development of affordable housing on city-owned land.
4. Implementation of SB 4 the Affordable Housing on Faith Lands Act Additionally, the Commission recommends moving forward with implementing a congregational overlay, as stated in the City’s Housing Element. This congregational overlay will study the impacts of establishing a zoning overlay to allow affordable housing developments on properties occupied by a religious institution, at a maximum density of 50 units per acre. As you may know, Senate Bill 4: Affordable Housing on Faith Lands Act was adopted in 2023. This new state law provides for a streamline process for religious organizations and nonprofit colleges to develop affordable housing on their property.
5. Design Review - It is imperative for design standards to be non discretionary and should be examined to avoid impeding affordable housing construction, development and design costs.
Implementing these tools and priorities can help ease the affordable housing crisis by promoting sustainable development, increasing housing supply, and creating fair access to housing opportunities for all working-class residents.
We look forward to working with the City of Laguna Hills to encourage effective housing policies that will help create balanced housing development and create much-needed affordable housing in our local communities. If you have any questions, please feel free to contact me at (949) 250-0909 or [email protected].
Sincerely,
Cesar Covarrubias
Executive Director