Agenda packet — Lake Forest City Council, August 16, 2022 (part 2 of 4)

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9 ORDINANCE NO. _______

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF LAKE
FOREST, CALIFORNIA AMENDING SECTION 9.146.050 OF THE LAKE

FOREST MUNICIPAL CODE GOVERNING ACCESSORY DWELLING

UNITS AND JUNIOR ACCESSORY DWELLING UNITS AND FINDING

THE ACTION TO BE EXEMPT FROM CEQA
WHEREAS, the City of Lake Forest, California (“City”) is a municipal corporation, duly organized under the California Constitution and laws of the State of California; and WHEREAS, the Planning and Zoning Law authorizes local agencies to act by ordinance to provide for the creation and regulation of accessory dwelling units (“ADUs”) and junior accessory dwelling units (“JADUs”); and
WHEREAS, in 2019, the California Legislature approved, and the Governor signed into law a number of bills (“2019 ADU Laws”) that, among other things, amended Government Code sections 65852.2 and 65852.22 to impose new limits on local authority to regulate ADUs and JADUs; and
WHEREAS, on July 21, 2020, the City Council adopted Ordinance No. 336, which updated the City’s ADU and JADU regulations (contained in Lake Forest Municipal Code section 9.146.050) to comply with the 2019 ADU Laws; and WHEREAS, in September 2020, the California Legislature approved, and the Governor signed into law, Assembly Bill 3182 (“AB 3182”); and WHEREAS, AB 3182, among other things, amended Government Code section 65852.2 to expand the scenarios under which the City must allow certain ADUs and JADUs with only a building permit; and
WHEREAS, on January 19, 2021, the City Council adopted Ordinance No. 343, which updated the City’s ADU and JADU regulations to comply with AB 3182; and WHEREAS, in September 2021, the California Legislature approved, and the Governor signed into law, Assembly Bill 345 (“AB 345”); and WHEREAS, AB 345 requires cities to allow the separate sale or conveyance of certain ADUs that satisfy the conditions set forth in Government Code section 65852.26.

Such conditions include, among other things, that the ADU or the primary dwelling was constructed by a qualified nonprofit and the ADU is sold to a qualified low-income buyer; and
WHEREAS, the California Department of Housing and Community Development (“HCD”) recently issued guidance with respect to local implementation of the 2019 ADU Laws, AB 3182, and AB 345; and
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9 WHEREAS, this Ordinance updates the City’s ADU and JADU regulations to comply AB 345, align with HCD’s guidance, and further increase clarity for the benefit of staff and the general public; and
WHEREAS, on May 26, 2022, the City gave public notice of a Planning Commission public hearing to be held to consider this Ordinance by advertisement in a newspaper of general circulation; and
WHEREAS, on June 9, 2022, the Planning Commission held a duly-noticed public hearing to consider the staff report, recommendations by staff, and public testimony concerning this Ordinance. Following the public hearing, the Planning Commission voted to forward the Ordinance to the City Council with a recommendation in favor of its adoption; and
WHEREAS, on August 4, 2022 the City gave public notice of a City Council public hearing to be held to consider this Ordinance by advertisement in a newspaper of general circulation; and
WHEREAS, on August 16, 2022, the City Council held a duly-noticed public hearing to consider the Ordinance, including: (1) the public testimony and agenda reports prepared in connection with the Ordinance, (2) the policy considerations discussed therein, and (3) the consideration and recommendation by the City’s Planning Commission; and
WHEREAS, all legal prerequisites to the adoption of the Ordinance have occurred.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF LAKE FOREST DOES HEREBY ORDAIN AS FOLLOWS:

The foregoing Recitals are true and correct and are incorporated herein by this reference.

CEQA. Under California Public Resources Code section 21080.17, the California Environmental Quality Act (“CEQA”) does not apply to the adoption of an ordinance by a city or county implementing the provisions of section 65852.2 of the Government Code, which is California’s ADU law and which also regulates JADUs, as defined by section 65852.22. Therefore, the proposed ordinance is statutorily exempt from CEQA in that the proposed ordinance implements the State’s ADU law.

General Plan. This Ordinance is, as a matter of law, consistent with the City’s General Plan pursuant to Government Code Section 65852.2(a)(1)(C).

Code Amendments. Section 9.146.050 of the Lake Forest Municipal Code is hereby amended to read as set forth in Exhibit “A,” attached hereto and incorporated herein.

Effective Date. This Ordinance takes effect 30 days following its adoption.

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9 Submittal to HCD. The City Clerk shall submit a copy of this Ordinance to the Department of Housing and Community Development within 60 days after adoption.

Custodian of Records. The documents and materials that constitute the record of proceedings on which this Ordinance is based are located at the City Clerk’s office located at 100 Civic Center Drive, Lake Forest, CA 92630. The custodian of these records is the City Clerk.

Severability. If any section, sentence, clause or phrase of this Ordinance or the application thereof to any entity, person or circumstance is held for any reason to be invalid or unconstitutional, such invalidity or unconstitutionality shall not affect other provisions or applications of this Ordinance which can be given effect without the invalid provision or application, and to this end the provisions of this Ordinance are severable. The City Council hereby declares that they would have adopted this Ordinance and each section, sentence, clause or phrase thereof, irrespective of the fact that any one or more section, subsections, sentences, clauses or phrases be declared invalid or unconstitutional.

Certification. The City Clerk shall certify to the adoption of this Ordinance and cause it, or a summary of it, to be published once within 15 days of adoption in a newspaper of general circulation printed and published within the City of Lake Forest, and shall post a certified copy of this Ordinance, including the vote for and against the same, in the Office of the City Clerk in accordance with California Government Code section 36933.

PASSED, APPROVED, AND ADOPTED by the City Council of Lake Forest, California, on the _____ day of ___________ 2022.

ROBERT PEQUEÑO, MAYOR
ATTEST:

LISA BERGLUND, MPA

CITY CLERK
APPROVED AS TO FORM:

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9 MATTHEW E. RICHARDSON

CITY ATTORNEY

STATE OF CALIFORNIA )

COUNTY OF ORANGE ) SS

CITY OF LAKE FOREST )
I, Lisa Berglund, City Clerk of the City of Lake Forest, do hereby certify that the foregoing Ordinance No. _______ was duly introduced and placed upon its first reading at a regular meeting of the City Council on the ___ day of ________, 2022, and thereafter, said Ordinance was duly adopted and passed at a regular meeting of the City Council on the ___ day of _____ 2022, by the following vote, to wit:

AYES: COUNCIL MEMBERS
NOES: COUNCIL MEMBERS
ABSENT: COUNCIL MEMBERS
ABSTAIN: COUNCIL MEMBERS

LISA BERGLUND, MPA

CITY CLERK
EXHIBIT “A” TO ORDINANCE NO. ____
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9 Amended Lake Forest Municipal Code Section 9.146.050
A. Purpose. The purpose of this section is to allow and regulate accessory dwelling units (ADUs) and junior accessory dwelling units (JADUs) in compliance with California Government Code Sections 65852.2 and 65852.22.

B. Effect of Conforming. An ADU or JADU that conforms to the standards in this section will not be:

1. Deemed to be inconsistent with the City’s general plan and zoning designation for the lot on which the ADU or JADU is located.

2. Deemed to exceed the allowable density for the lot on which the ADU or JADU is located.

3. Considered in the application of any local ordinance, policy, or program to limit residential growth.

4. Required to correct a nonconforming zoning condition, as defined in subsection (C)(9) below. This does not prevent the City from enforcing compliance with applicable building standards in accordance with Health and Safety Code Section 17980.12.

C. Definitions. As used in this section, terms are defined as follows:

1. “Accessory dwelling unit” or “ADU” means an attached or a detached residential dwelling unit that provides complete independent living facilities for one or more persons and is located on a lot with a proposed or existing primary residence. An accessory dwelling unit also includes the following:
a. An efficiency unit, as defined by Section 17958.1 of the California Health and Safety Code; and
b. A manufactured home, as defined by Section 18007 of the California Health and Safety Code.

2. “Accessory structure” means a structure that is accessory and incidental to a dwelling located on the same lot.

3. “Complete independent living facilities” means permanent provisions for living, sleeping, eating, cooking, and sanitation on the same parcel as the single-family or multifamily dwelling is or will be situated.

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9 4. “Director” means the Director of Community Development.

5. “Efficiency kitchen” means a kitchen that includes all of the following:
a. A cooking facility with appliances.
b. A food preparation counter and storage cabinets that are of reasonable size in relation to the size of the JADU.

6. “Junior accessory dwelling unit” or “JADU” means a residential unit that:
a. Is no more than 500 square feet in size,
b. Is contained entirely within an existing or proposed single-family structure,
c. Includes its own separate sanitation facilities or shares sanitation facilities with the existing or proposed single-family structure, and
d. Includes an efficiency kitchen, as defined in subsection ( C.5) of this section.

7. “Living area” means the interior habitable area of a dwelling unit, including basements and attics, but does not include a garage or any accessory structure.

8. “Multifamily dwelling” means any structure with two or more attached dwellings on a single lot (e.g., apartments, attached townhomes, row houses).

9. “Nonconforming zoning condition” means a physical improvement on a property that does not conform with current zoning standards.

10. “Passageway” means a pathway that is unobstructed clear to the sky and extends from a street to one entrance of the ADU or JADU.

11. “Proposed dwelling” means a dwelling that is the subject of a permit application and that meets the requirements for permitting.

12. “Public transit” means a location, including, but not limited to, a bus stop or train station, where the public may access buses, trains, subways, and other forms of transportation that charge set fares, run on fixed routes, and are available to the public.

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9 13. “Tandem parking” means that two or more automobiles are parked on a driveway or in any other location on a lot, lined up behind one another.

D. Approvals. The following approvals apply to ADUs and JADUs under this section:

1. Building-Permit Only. If an ADU or JADU complies with each of the general requirements in subsection (E) below (“General ADU and JADU Requirements”), it is allowed with only a building permit in the following scenarios:
a. Converted on Single-Family Lot. One ADU (as described in this subsection (D)(1)(a)) and one JADU on a lot with a proposed or existing single-family dwelling on it, where the ADU or JADU:
i. Is either: within the space of a proposed single-family dwelling; or within the existing space of an existing
single-family dwelling; or within the existing space of an accessory structure, plus up to 150 additional square feet if the expansion is limited to accommodating ingress and egress.
ii. Has exterior access that is independent of that for the single-family dwelling.
iii. Has side- and rear-yard setbacks sufficient for safety, as dictated by applicable building and fire codes.
iv. The JADU complies with all the requirements of
Government Code Section 65852.22.
b. Limited Detached on Single-Family Lot: One detached, new- construction ADU on a lot with a proposed or existing single- family dwelling (in addition to any JADU that might otherwise be established on the lot under subsection (D)(1)(a) of this section), if the detached ADU complies with the following limitations:
i. The side- and rear-yard setbacks are at least four 4 feet. ii. The total floor area is 800 square feet or smaller. iii. The overall height above grade is 16 feet or less.

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9 c. Converted on Multifamily Lot: One or more ADUs within portions of existing multifamily dwelling structures that are not used as livable space, including, but not limited to, storage rooms, boiler rooms, passageways, attics, basements, or garages, if each converted ADU complies with state building standards for dwellings. Under this subsection (D)(1)(c), at least one converted ADU is allowed within an existing multifamily dwelling, up to a quantity equal to 25 percent of the existing multifamily dwelling units.
d. Limited Detached on Multifamily Lot: No more than two detached ADUs on a lot that has an existing multifamily dwelling, if each detached ADU satisfies the following
limitations:
i. The side- and rear-yard setbacks are at least four feet. ii. The peak height above grade is 16 feet or less.

2. ADU Permit—Required and Fee.
a. Except as allowed under subsection (D)(1) of this section (“Building-Permit Only”), no ADU may be created without a building permit and an ADU permit in compliance with the standards set forth in subsections (E) (“General ADU and JADU Requirements”) and (F) (“Specific ADU Requirements”) below. b. The City may charge a fee to reimburse it for costs incurred in processing ADU permits, including the costs of adopting or amending the City’s ADU ordinance. The ADU-permit
processing fee is determined by the Director and approved by the City Council by resolution.

3. Process and Timing.
a. An ADU permit is considered and approved ministerially, without discretionary review or a hearing.
b. The City must act on an application to create an ADU or JADU within 60 days from the date that the City receives a completed application. If the City does not act upon the completed application within 60 days, the application is deemed approved unless either:

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9 i. The applicant requests a delay in writing, in which case the 60 day time period is tolled for the period of the
requested delay; or
ii. When an application to create an ADU or JADU is
submitted with a permit application to create a new
single-family dwelling on the lot, the City may delay
acting on the permit application for the ADU or JADU until the City acts on the permit application to create the new single-family dwelling, but the application to create the ADU or JADU will still be considered ministerially without discretionary review or a hearing.

E. General ADU and JADU Requirements. The following requirements apply to all ADUs and JADUs that are approved under subsections (D)(1) (“Building- Permit Only”) or (D)(2) of this section:

1. Zoning.
a. An ADU or JADU subject only to a building permit under subsection (D)(1) above may be created on a lot in a residential or mixed-use zone.
b. An ADU or JADU subject to an ADU permit under subsection (D)(2) above may be created on a lot that is zoned to allow single-family dwelling residential use or multifamily dwelling residential use.

2. Fire Sprinklers. Fire sprinklers are required in an ADU if sprinklers are required in the primary residence.

3. Rental Term. No ADU or JADU may be rented for a term that is shorter than 30 days.

4. No Separate Conveyance. An ADU or JADU may be rented, but, except as otherwise provided in Government Code Section 65852.26, no ADU or JADU may be sold or otherwise conveyed separately from the lot and the primary dwelling (in the case of a single-family lot) or from the lot and all of the dwellings (in the case of a multifamily lot).

5. Septic System. If the ADU or JADU will connect to an onsite waste- water treatment system, the owner must include with the application (as required by subsections (D)(1)(“Building-Permit Only”) or (D)(2) above) a percolation test completed within the previous five years or, if the percolation test has been recertified, within the last 10 years.

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9 6. Owner Occupancy.
a. All ADUs permitted before January 1, 2020 are subject to the owner-occupancy requirement that was in place when the ADU was created.
b. An ADU that is permitted after January 1, 2020 but before January 1, 2025, is not subject to any owner-occupancy
requirement.
c. All ADUs that are permitted on or after January 1, 2025 are subject to an owner-occupancy requirement. A natural person with legal or equitable title to the property must reside on the property as the person’s legal domicile and permanent
residence.
d. All JADUs are subject to an owner-occupancy requirement. A natural person with legal or equitable title to the property must reside on the property, in either the primary dwelling or JADU, as the person’s legal domicile and permanent residence.

However, the owner-occupancy requirement of this paragraph does not apply if the property is entirely owned by another governmental agency, land trust, or housing organization.

7. Deed Restriction. Prior to issuance of a building permit for an ADU or JADU, a deed restriction must be recorded against the title of the property in the County Recorder’s office and a copy filed with the Director. The deed restriction must run with the land and bind all current and future owners. The form of the deed restriction will be provided by the City and must provide that:
a. Except as otherwise provided in Government Code Section 65852.26, the ADU or JADU may not be sold separately from the primary dwelling.
b. The ADU or JADU is restricted to the approved size and to other attributes allowed by this section.
c. The deed restriction runs with the land and may be enforced against all current and future property owners.
d. The deed restriction may be removed if the owner eliminates the ADU or JADU, as evidenced by, for example, removal of the kitchen facilities with a demolition permit. To remove the deed restriction, an owner may make a written request of the Item: 10
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9 Director, providing evidence that the ADU or JADU has in fact been eliminated. The Director may then determine whether the evidence supports the claim that the ADU or JADU has been eliminated. Appeal may be taken from the Director’s
determination consistent with other provisions of this Code. If the ADU or JADU is not entirely physically removed, but is only eliminated by virtue of having a necessary component of an ADU or JADU removed, the remaining structure and
improvements must otherwise comply with applicable
provisions of this Code.
e. The deed restriction is enforceable by the Director or his or her designee for the benefit of the City. Failure of the property owner to comply with the deed restriction may result in legal action against the property owner, and the City is authorized to obtain any remedy available to it at law or equity, including, but not limited to, obtaining an injunction enjoining the use of the ADU or JADU in violation of the recorded restrictions or abatement of the illegal unit.

8. Building & Safety. All ADUs and JADUs must comply with all local building code requirements.

F. Specific ADU Requirements. The following requirements apply only to ADUs that require an ADU permit under subsection (D)(2) of this section.

1. Maximum Size.
a. The maximum size of a detached or attached ADU subject to this subsection (F) is 850 square feet for a studio or one bedroom unit and 1,000 square feet for a unit with two or more bedrooms.
b. An attached ADU that is created on a lot with an existing primary dwelling is further limited to 50 percent of the floor area of the existing primary dwelling. Notwithstanding the foregoing, no application of the percent-based size limitation may require the ADU to be less than 800 square feet.

2. Setbacks.
a. An ADU subject to this subsection (F) must conform to a 25 foot front-yard setback.

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9 b. An ADU that is subject to this subsection (F) must conform to four foot side and rear-yard setbacks.
c. No setback is required for an ADU that is subject to this subsection (F) if the ADU is constructed in the same location and to the same dimensions as an existing structure.

3. Height.
a. A single-story attached or detached ADU may not exceed 16 feet in height above grade, measured to the peak of the structure.
b. A second story or two-story attached ADU may not exceed 35 feet in height.
c. A detached ADU may not exceed one story.

4. Passageway. No passageway, as defined by subsection (C)(10) (“Passageway”) of this section, is required for an ADU.

5. Parking.
a. Generally. One off-street parking space is required for each ADU. The parking space may be provided in setback areas or as tandem parking, as defined by subsection (C)(13) of this section.
b. Exceptions. No parking under subsection (F)(5)(a) (“Parking”) is required in the following situations:
i. The ADU is located within one-half mile walking distance of public transit, as defined in subsection (C)(12) of this section.
ii. The ADU is located within an architecturally and
historically significant historic district.
iii. The ADU is part of the proposed or existing primary residence or an accessory structure (under subsection
(D)(1)(a)(“Converted on a Single-Family Lot”)).
iv. When on-street parking permits are required but not offered to the occupant of the ADU.

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9 v. When there is an established car share vehicle stop located within one block of the ADU.
c. No Replacement. When a garage, carport, or covered parking structure is demolished in conjunction with the construction of an ADU or converted to an ADU, those off-street parking spaces are not required to be replaced.
d. The ADU and primary dwelling must use the same driveway to access the street.
e. Each unclosed parking space shall be at least nine feet wide and 18 feet long.
f. Each parking space that is provided in an enclosed garage shall be at least 10 feet wide and 20 feet long and have at least 7 ½ feet vertical clearance.

6. Architectural Requirements.
a. The ADU must have an independent exterior entrance, apart from that of the primary dwelling.
b. The interior horizontal dimensions of an ADU must be at least 10 feet wide in every direction.

7. Notice of Construction.
a. At least 10 business days before starting any construction of a second unit, the property owner shall give written notice to all the owners of record of each of the adjacent residential parcels, which notice shall include the following information:
i. Notice that construction has been authorized;
ii. The anticipated start and end dates for construction; iii. The hours of construction;
iv. Contact information for the project manager (for
construction-related complaints); and
v. Contact information for the City Building Division.
b. This notice requirement does not confer a right on the noticed persons or on anyone else to comment on the project before Item: 10
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9 permits are issued. Approval is ministerial. Under State law, the City has no discretion in approving or denying a particular ADU project under this section. This notice requirement is purely to promote neighborhood awareness and expectation.

G. Fees. The following requirements apply to all ADUs that are approved under subsections (D)(1) or (D)(2) above.

1. Impact Fees.
a. No impact fee shall be required for an ADU that is less than 750 square feet in size. For purposes of this subsection (G)(1), “impact fee” means a “fee” under the Mitigation Fee Act (Gov.

Code, § 66000(b)) and a fee under the Quimby Act (Gov. Code, § 66477). “Impact fee” does not include any connection fee or capacity charge for water or sewer service.
b. Any impact fee that is required for an ADU that is 750 square feet or larger in size must be charged proportionately in relation to the square footage of the primary dwelling unit. (E.g., the floor area of the ADU, divided by the floor area of the primary dwelling, times the typical fee amount charged for a new dwelling.)

2. Utility Connection and Fees.
a. If an ADU is constructed with a new single-family home, a separate utility connection directly between the ADU and the utility and payment of the normal connection fee and capacity charge for a new dwelling are required.
b. Except as described in subsection (G)(2)(a), converted ADUs on a single-family lot that are created under subsection (D)(1)(a) above are not required to have a new or separate utility connection directly between the ADU and the utility. Nor is a connection fee or capacity charge required.
c. Except as described in subsection (G)(2)(a), all ADUs not covered by subsection (G)(2)(b) require a new, separate utility connection directly between the ADU and the utility.
i. The connection is subject to a connection fee or capacity charge that is proportionate to the burden created by the ADU, based on either the floor area or the number of
drainage-fixture units (DFU) values, as defined by the
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9 California Plumbing Code, upon the water or sewer
system.
ii. The portion of the fee or charge that is charged by the City may not exceed the reasonable cost of providing this service.

H. Nonconforming ADUs and Discretionary Approval. Any proposed ADU or JADU that does not conform to the objective standards set forth in subsections (A) through (G)(2) of this section may be allowed by the City with a use permit, in accordance with Chapter 9.184 of this Code.

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ATTACHMENT 2
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Amended Lake Forest Municipal Code Section 9.146.050
A. Purpos
e. The purpose of this section is to allow and regulate accessory dwelling units (ADUs) and junior accessory dwelling units (JADUs) in compliance with California Government Code Sections 65852.2 and 65852.22.

B. Effect of Conforming. An ADU or JADU that conforms to the standards in this section will not be:

1. Deemed to be inconsistent with the City’s general plan and zoning designation for the lot on which the ADU or JADU is located.

2. Deemed to exceed the allowable density for the lot on which the ADU or JADU is located.

3. Considered in the application of any local ordinance, policy, or program to limit residential growth.

C. Definitions. As used in this section, terms are defined as follows:

1. “Accessory dwelling unit” or “ADU” means an attached or a detached residential d
welling unit that provides complete independent living
facilities for one (1) or more persons and is located on a lot with a proposed or existing primary residence. An accessory dwelling unit also includes the following:
a. An efficiency unit, as defined by Section 17958.1 of the Cal
ifornia Health and Safety Code; and
b. A manufactured home, as defined by Section 18007 of the California Health and Safety Code.

2. “Accessory structure” means a structure that is accessory and incidental to a dwelling located on the same lot.

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4. “Director” means the Director of Community Development.

5. “Efficiency kitch en” means a kitchen that includes eachall of the following:
a. A cooking facility with appliances.
b. A food preparation counter or counters that total at least fifteen (15) square feet in area and storage cabinets that are of reasonable size in relation to the size of the JADU.
c. Food storage cabinets that total at least thirty (30) cubic feet.

6. “Junior accessory dwelling unit” or “JADU” means a residential unit that:
a. Is no more than five hundred (50 0) square feet in size, b. Is contained entirely within an existing or proposed single-family structure,
c. Includes its own separate sanitation facilities or share s sanitation facilities with the existing or proposed single-family structure, and
d. Includes an efficiency kitchen, as defined in subsection (C)(5C)(5) of this section.

7. “Living area” means the interior habitable area of a dwelling unit, including basements and attics, but does not include a garage or any accessory structure.

8. “Multifamily dwelling” means any structure that contains more than one (1) residential dwelling.with two or more attached dwellings on a single lot (e.g., apartments, attached townhomes, row houses).

9. “Nonconforming zoning condition” means a physical improvement on a property that does not conform with current zoning standards.

10. “Passageway” me an
s a pathway that is unobstructed clear to the sky
and extends from a street to one (1) entrance of the ADU or JADU.

11. “Proposed dwelling” means a dwelling that is the subject of a permit application and that meets the requirements for permitting.

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13. “Tandem par
king” means that two (2) or more automobiles are parked on a driveway or in any other location on a lot, lined up behind one (1) another.

D. Approvals. The following approvals apply to ADUs and JADUs under this sectio
n:

1. Building-Permit Only. If an ADU or JADU complies with each of the general requirements in subsection (E) below (“General ADU and JADU Requirements”), it is allowed with only a building permit in the following scenarios:
a. Converted on Single-Family Lot. On
e (1) ADU (as described in
this su bsection (D)(1)(a)) and one (1) JADU on a lot with a proposed or existing single-family dwelling on it, where the ADU or JADU:
i. Is either: within the space of a proposed orsingle -family dwelling; or within the existing space of an existing
single-family dwelling; or within the existing space of an existing accessory structure, plus up to one hundred fifty (150) additional square feet if the expansion is limited to accommodating ingress and egress.
ii. Has exterior access that is independent of that for the single-f
amily dwelling.
iii. Has side- and rear -yard setbacks sufficient for safety, as dictated by applicable building and fire codes.
iv. The JADU complies with all the requirements of
Government Code Section 65852.22.
b. Limited Detached on Single-Family Lot: One (1) de
tached, new-
construction ADU on a lot with a proposed or existing single- family dwelling (in addition to any JADU that might otherwise be established on the lot under subsection (D)(1)(a) of this section), if the detached ADU complies with the following limitations:

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i. The side- and rear-yard setbacks are at least four (4)- feet.
ii. The total floor area is eight hundred (800 ) square feet or smaller.
iii. The overall height above grade is sixteen (16 ) feet or less.
c. Converted on Multifamily Lot: MultipleOne or more ADUs within portions of existing multifamily dwelling structures that are not used as livable space, including, but not limited to, storage rooms, boiler rooms, passageways, attics, basements, or garages, if each converted ADU complies with state building standards for dwellings. At least one Under this subsection (D)(1)(c), at least one converted ADU is allowed on a lot within an existing multifamily dwelling structure , up to a
numberquantity equal to twenty-five (25) percent of the existing multifamily dwelling units.
d. Limited Detached on Multifamily Lot: No more than two (2) detached ADUs on a lot that has an existing multifamily dwelling, if each detached ADU satisfies the following
limitations:
i. The side- and
rear-yard setbacks are at least four (4)-
feet.
ii. The total floor area is eight hundred (800) square pea k height above grade is 16 feet or smallerless.

2. ADU Permit—Required and Fee.
a. Except as allowed under subsection (D)(1) of this section (“Building-Permit Only”), no ADU may be created without a building permit and an ADU permit in compliance with the standards set forth in subsections (E) (“General ADU and JADU Requirements”) and (F) (“Specific ADU Requirements”) below. b. The City may charge a fee to reimburse it for costs incurred in processing an ADU permits, including the costs of adopting or amending the City’s ADU ordinance. The ADU-permit
processing fee is determined by the Director and approved by the City Council by resolution.

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3. Process and Timing.
a. An ADU permit shall be is c onsidered and approved
ministerially, without discretionary review or a hearing. b. The City must act on building permit applications (submitted under subsection (D)(1) above (“Building -Permit Only”)) and applications for an ADU permitan application to create an ADU or JADU within sixty (60) days from the date that the City receives a completed application. If the City does not act upon the completed application within sixty (60) days, the application is deemed approved unless either:
i. The applicant requests a delay in writing, in which case the sixty (
60) day time period is tolled for the period of
the requested delay; or
ii. When an application to create an ADU or JADU is
submitte
d with a permit application to create a new
single-family dwelling on the lot, the City may delay
acting on the permit application for the ADU or JADU until the City acts on the permit application to create the new single-family dwelling, but the application to create the ADU or JADU will still be considered ministerially without discretionary review or a hearing.

E. General ADU and JADU Requirements. The following requirements apply to all ADUs and JADUs that are approved under subsections (D)(1) (“Building- Permit Only”) or (D)(2) of this section:

1. Zoning.
a. An ADU or JADU subject only to a building permit under su
bsection (D)(1) above may be created on a lot in anya
residential or mixed-use zone.
b. An ADU or JADU subject to an ADU permit under subsection (D)(2) a bo
ve may be created on a lot that is zoned to allow
single-family dwelling residential use or multifamily dwelling residential use.

2. Fire Sprinklers. Fire sprinklers are required in an ADU if sprinklers are required in the primary residence.

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3. Rental Term. An ADU or JADU may be rented, but no No ADU or JADU may be rented for a term that is shorter than thirty (30) days.

4. No Separate Conveyance. No An ADU or JADU may be rented, but, except as otherwise provided in Government Code Section 65852.26, no ADU or JADU may be sold or otherwise conveyed separately from the lot and the primary dwelling (in the case of a single -family lot) or from the lot and all of the dwellings on that lot (in the case of a multifamily lot).

5. Septic System. If the ADU or JADU will connect to an onsite wat er- treatmentwaste-water treatment system, the owner must include with the application (as required by subsections (D)(1)(“Building -Permit Only”) or (D)(2) above) a percolation test completed within the previous five years or, if the percolation test ha s been recertified, within the previous ten (last 10) years.

6. Owner Occupancy.
a. All ADUs permitted before January 1, 2020 are subject to the ow
ner-occupancy requirement that was in place when the ADU was permittedcreated.
b. An ADU that is permitted after January 1, 2020 but before January 1, 2025, shallis not be subject to any owner-occupancy requirement.
c. All ADUs t ha t are permitted on or after January 1, 2025 shall beare subject to an owner -occupancy requirement. A natural person with legal or equitable title to the property must reside on the property as the person’s legal domicile and permanent residence.
d. All JADUs s h
all beare subject to an owner -occupancy
requirement. A natural person with legal or equitable title to the property must reside on the property, in either the primary dwelling or JADU, as the person’s legal domicile and
permanent residence. However, the owner -occupancy
requirement of this paragraph does not apply if the property is entirely owned by anyanother governmental agency, land trust, or housing organization.

7. Deed Restriction. Prior to issuance of a building permit for an ADU or JADU, a de
ed restriction must be recorded against the title of the DRAFT
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property in the County Recorder’s office and a copy filed with the Director. The deed restriction must run with the land and bind all current and future owners. The form of the deed restriction shallwill be provided by the City and shallmust provide that:
a. TheExcept as otherwise provided in Government Code Section 65852.26, the ADU or JADU may not be sold separately from the primary dwelling.
b. The ADU or JADU is restricted to the appr oved size authorized by the corresponding building permit and to other attributes allowed by this section.
c. The deed restriction runs with the land and may be enforced against all current and future property owners.
d. The deed restriction may be removed if the owner eliminates the ADU or JADU, as evidenced by, for example, removal of the kitchen facilities with a demolition permit. To remove t he deed restriction, an owner may make a written request of the Director, providing evidence that the ADU or JADU has in fact been eliminated. The Director may then determine whether the evidence supports the claim that the ADU or JADU has been eliminated. Appeal may be taken from the Director’s
determination consistent with other provisions of this Code. If the ADU or JADU is not entirely physically removed, but is only eliminated by virtue of having a necessary component of an ADU or JADU removed, the remaining structure and
improvements must otherwise comply with applicable
provisions of this Code.
e. The deed restriction is enforceable by the Director or his or her designee for the benefit of the City. Failure of the property owner to comply with the deed r estriction may result in legal action against the property owner, and the City is authorized to obtain any remedy available to it at law or equity, including, but not limited to, obtaining an injunction enjoining the use of the ADU or JADU in violation of the recorded restrictions or abatement of the illegal unit.

8. Building & Safety. All ADUs and JADUs must comply with all local building code requirements.

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F. Specific ADU Requirements. The following requirements apply only to ADUs that require an ADU permit under subsection (D)(2) of this section.

1. Maximum Size.
a. The maximum size of a detached or attached ADU subject to this
subsection (F) is eight hundred fifty (850) square feet for a studio or one (1)-bedroom unit and one thousand ( 1,000) square feet for a unit with two (2)or more bedrooms. No more than two (2) bedrooms are allowed.
b. An attached ADU that is created on a lot with an existing primary dwelling is further limited to fifty (50) percent of the floor area of the existing primary dwelling. Notwithstanding the foregoing, no application of the percent -based size limitation may require the ADU to be less than 800 square feet.

2. Setbacks.
a. No part of any An ADU su bject to this subsection (F) may be located within twenty-five (25) feet of the front property linemust conform to a 25 foot front-yard setback.
b. No part of anyAn ADU that is subject to this subsection (F) may be located within must conform to four (4) feet of afoot side or rear property lineand rear-yard setbacks.
c. No setback is required for an ADU that is subject to this subsection (F) if the ADU is constructed in the same location and to the same dimensions as an existing structure.

3. Height.
a.

A single-story attached or detached ADU may not exceed
sixteen
(16) feet in height above grade, measured to the peak
of the structure.
b. A second story or two-story attached ADU may not exceed thirty-five (
35) feet in height.
c. A detached ADU may not exceed one (1) story.

4. Passageway. No passageway, as defined by subsection (C)(10) (“Passageway”) of this section, is required for an ADU.

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5. Parking.
a. Generally. One (1 ) off-street parking space is required for each ADU. The parking space may be provided in setback areas or as tandem parking, as defined by subsection (C)(13) of this section.
b. Exceptions. No parking under subsection (F)(5)(a) (“Parking”) is
required in the following situations:
i. The ADU is located within one -ha lf (½) mile walking distance of public transit, as defined in subsection
(C)(12) of this section.
ii. The ADU is located within an architecturally and
historica
lly significant historic district.
iii. The ADU is part of the proposed or existing primary residence or an accessory structure (under subsection
(D)(1)(a)(“Converted on a Single-Family Lot”)).
iv. When on -street parking permits are required but not offered to the occupant of the ADU.
v. When there is an established car share vehicle stop
lo
cated within one (1) block of the ADU.
c. No Replacement. When a garage, carport, or covered parking structure is demolished in conjunction with the construction of an ADU or converted to an ADU, those off -street parking spaces are not required to be replaced.
d. The ADU and primary dwelling must use the same driveway to access the street.
e. Each unclosed parking space shall be at least nine (9) fee t wide
and eighteen (18) feet long.
f. Each parking space that is provided in an enclosed garage shall be at least ten ( 10) feet wide and twenty (20) feet long and have at least seven and one half (7 ½) feet vertical clearance.

6. Architectural Requirements.

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a. The ADU must have an independent exterior entrance, apart from that of the primary dwelling. The ADU entrance must be located on the side or rear building façade, not facing the same public-right-of-way as the primary dwelling.
b. The interior horizontal dimensions of an ADU must be at least ten (10) feet wide in every direction.

7. Notice of Construction.
a. At least ten (10) business days before starting any construction of a second unit, the property owner shall give written notice to all the owners of record of each of the adjacent residential parcels, which notice shall include the following information:
i. Notice that construction has been authorized;
ii. Th
e anticipated start and end dates for construction;
iii. The hours of construction;
iv. Contact information for the project ma nager (for
construction-related complaints); and
v. Contact information for the City Building Division.
b. This notice requirement does not confer a right on the noticed persons or on anyone else to comment on the project before permits are issued. Approval is ministerial. Under State law, the City has no discretion in approving or denying a particular ADU project under this section. This notice requirement is purely to promote neighborhood awareness and expectation.

G. Fees. Th
e following requirements apply to all ADUs that are approved under subsections (D)(1) or (D)(2) above.

1. Impact Fees.
a. No impact fe e sha ll be required for an ADU that is less than seven hundred fifty (750) square feet in size. For purposes of this subsection (G)(1), “impact fee” means a “fee” under the Mitigation Fee Act (Gov. Code, § 66000(b)) and a fee under the Quimby Act (Gov. Code, § 66477). “Impact fee” does not
include any connection fee or capacity charge for water or sewer service.

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b. Any impact fee that is required for an ADU that is seven hundred fifty (750) square feet or larger in size must be charged proportionately in relation to the square footage of the primary dwelling unit. (E.g., the floor area of the primary dwellingADU, divided by the floor area of the ADUprimary dwelling, times the typical fee amount cha rged for a new dwelling.) “Impact fee” here does not include any connection fee or capacity charge for water or sewer service.

2. Utility Connection and Fees.
a. If an ADU is cons tr ucted with a new single-family home, a separate utility connection directly betwe en the ADU and the utility and payment of the normal connection fee and capacity charge for a new dwelling are required.
b. a. ConvertedExcept as described in subsection (G)(2)(a), converted ADUs and JADUs on a single-family lot, that are created under subsection (D)(1)(a) of this section,above are not required to have a new or separate utility connection directly between the ADU or JADU and the utility. Nor is a connection fee or capacity charge required unless the ADU or JADU is constructed with a new single-family home.
b. All Except as described in subsection (G)(2)(a), all ADUs and JADUs not covered by subsection (G)(2)( ab) of this section require a new, separate utility connection directly between the ADU or JADU and the utility.
i. The connection is subject to a connection fee or capacity charge that is proportionate to the burden created by the ADU or JADU, based on either the floor area or the
number of drainage -fixture units (DFU) values, as
defined by the California Plumbing Code, upon the water or sewer system.
ii. The portion of the fee or charge that is charged by the City may not exceed the reasonable cost of providing this service.

H. Nonconforming ADUs and Discretionary Approval. Any proposed ADU or JADU th at doe
s not conform to the objective standards set forth in
subsections (A) through (G)(2) of this section may be allowed by the City with a use permit, in accordance with Chapter 9.184 of this Code.

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ATTACHMENT 3
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ATTACHMENT 4
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STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
A
pril 13, 2022
G
ayle Ackerman, AICP
Director of Community Development
City of Lake Forest
25550 Commerce Centre Drive
Lake Forest, CA 92630
D
ear Gayle Ackerman:

R
E: Review of Lake Forest’s Accessory Dwelling Unit (ADU) Ordinance under ADU Law (Gov. Code, § 65852.2)
T
hank you for submitting the City of Lake Forest (City) accessory dwelling unit (ADU) Ordinance No. 336 (Ordinance), adopted July 21, 2020, to the California Department of Housing and Community Development (HCD). The Ordinance was received on August 13, 2020. HCD has reviewed the Ordinance and is submitting these written findings pursuant to Government Code section 65852.2, subdivision (h). HCD has determined that the Ordinance does not comply with section 65852.2 in the manner noted below. Under the statute, the City has up to 30 days to respond to these findings. Accordingly, the City must provide a written response to these findings no later than May 13, 2022.

Th
e adopted ADU Ordinance addresses many statutory requirements; however, HCD finds that the Ordinance does not comply with ADU law in the following respects:
• 9.
146.050 (C)(5)(b) and (c) – Efficiency Kitchen Constraints – The Ordinance defines an efficiency kitchen as including a food preparation area “with counters that total 15 square feet in area” and “food storage cabinets that total at least 30 cubic feet.” However, the definition of an efficiency kitchen in Government Code section 65852.22, subdivisions (a)(6)(A) and (B), describe the food preparation counter and storage cabinets “of reasonable size” in relation to the size of the JADU. As written, the size requirements in the Ordinance are more stringent than required by statute. Therefore, the City must remove the size references. • 9.
146.050 (E)(7)(a) – Prohibiting subdivision – The Ordinance prohibits separate sale of an ADU from its respective primary dwelling. However, Government Code 65852.26, subdivision (a)(1), which went into effect January 1, 2022, creates a narrow exception to allow separate conveyance of ADUs with the involvement of Item: 10
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Gayle Ackerman, AICP
Director of Community Development

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qualified nonprofit housing organizations. The City should revise the Ordinance to allow for such an exception.

• 9.146.050 (F)(1)(a) – Bedroom restriction – The Ordinance states that for ADUs, “no more than two bedrooms are allowed….” Limiting the number of bedrooms within an ADU may constrain housing choice and result in discriminatory effects on families with children, people with disabilities, and other protected groups in violation of state and federal fair housing laws, including but not limited to Government Code section 65008, subdivisions (a)(1)(A) and (b)(1)(B)(i).

Therefore, the City must revise this section to avoid limiting the occupancy of housing units based on familial status or other protected characteristics.

• 9.146.050 (F)(6)(a) – Screened Entry – The Ordinance states that “the ADU entrance must be located on the side or rear building facade, not facing the same public-right-of way as the primary dwelling.” Since state law requires that ADUs and JADUs have an independent entry into the unit (Gov. Code § 65852.2, subd. (e)(1)(a)(ii) and Gov. Code § 65852.22, subd. (a)(5)), a constraint on the location of an entry door may make the creation of an additional housing unit infeasible.

Furthermore, local development standards provided by the Ordinance pursuant to Government Code section 65852.2, subdivisions (a) through (d), do not apply to ADUs created under Government Code section 65852.2, subdivision (e), and the restrictions as implied would not be permissible. Therefore, the City should revise or remove the section.

• 9.146.050 (G)(2)(b) – Utilities – The Ordinance requires that some ADUs and junior ADUs (JADUs) require a new, separate utility connection. However, Government Code section 65852.22, subdivision (e), states, “For purposes of providing service for water, sewer, or power, including a connection fee, a junior accessory dwelling unit shall not be considered a separate or new dwelling unit.” Therefore, the City must remove references to JADUs in this section.

In these respects, revisions are necessary to comply with statute.

HCD will consider any written response to these findings, such as a revised ordinance or a detailed plan to bring the ordinance into compliance with law by a date certain, before taking further action authorized pursuant to Government Code section 65852.2.

Please note that HCD may notify the California Office of the Attorney General in the event that the City fails to take appropriate and timely action under section 65852.2, subdivision (h).

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Gayle Ackerman, AICP
Director of Community Development

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HCD appreciates the City’s efforts in the preparation and adoption of the Ordinance and welcomes the opportunity to assist the City in fully complying with State ADU Law.

Please contact Mike Van Gorder, of our staff, at (916) 776–7541 or at [email protected] if you have any questions or would like HCD’s technical assistance in these matters.

Sincerely,

David Zisser
Assistant Deputy Director
Local Government Relations and Accountability
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CITY COUNCIL AGENDA REPORT
MEETING DATE: 8/16/2022
DEPARTMENT: Community Development
SUBJECT:

REVISED "2021-2029 HOUSING ELEMENT" OF THE GENERAL PLAN RECOMMENDED ACTION(S):

Adopt a Resolution entitled: A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LAKE FOREST, CALIFORNIA, ADOPTING THE REVISED “2021-2029 HOUSING ELEMENT” OF THE GENERAL PLAN.

EXECUTIVE SUMMARY:

State law requires all cities in California to adopt a comprehensive General Plan to guide land use planning decisions. The Housing Element is a State-mandated element of the City’s General Plan which is required to identify and analyze existing and projected housing needs. The Housing Element is the only element that must be updated at regular intervals or cycles (every 8 years) and is reviewed for conformance by the State Department of Housing and Community Development (“HCD”).

On November 4, 2021, the Planning Commission considered and made a recommendation to the City Council on the Draft Sixth Cycle 2021-2029 Housing Element (“Housing Element”). The Housing Element was adopted by City Council on January 4, 2022, and subsequently submitted to HCD. However, HCD staff required revisions to the adopted Housing Element. This necessitated modification to the document prior to resubmittal for certification.

Staff and the City’s consultant have closely coordinated with HCD and have incorporated the necessary modifications to the Housing Element to ensure it meets State law and can be certified by HCD. On July 7, 2022, the Planning Commission considered and adopted a resolution recommending the City Council adopt the revised 2021-2029 Housing Element of the General Plan (Attachment 2). Following City Council’s adoption, the revised Housing Element would be submitted to HCD for review and certification (Attachment 1). In accordance with the draft resolution, should there be additional minor modifications, changes may be made administratively by the Director of Community Development.

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BACKGROUND:

On November 4, 2021, the Planning Commission considered and made a recommendation to the City Council on the Housing Element. The Housing Element was adopted by City Council on January 4, 2022, and subsequently submitted to HCD by staff on January 6, 2022. A detailed background and prior agenda report is provided as Attachment 3 and the Draft Housing Element previously submitted to HCD can be found in the link of Attachment 4.

On March 7, 2022, HCD review staff sent a letter listing revisions that were necessary to comply with State Housing Element Law (Article 10.6 of the Gov.

Code) (“State law”) (Attachment 5). Staff and the City’s consultant, Amanda Tropiano of DeNovo Planning, worked extensively with HCD staff to clarify the comments and update the Housing Element to comply with State law. An excerpt list of the revisions made in response to HCD can be referenced in Attachment 6.

DISCUSSION:

In accordance with direction from HCD, changes to the adopted Housing Element were necessary to bring it into compliance with State law. The changes requested by HCD generally included additional supporting analysis, the establishment of quantifiable goals and a commitment to amend existing City regulations for compliance with State law. An excerpt of the revised changes is provided in Attachment 6. Specific changes include:
Additional analysis of trends regarding disproportionate housing needs and an assessment of how the sites inventory will improve fair housing conditions.
The inclusion of quantifiable goals to measure progress for Affirmatively Furthering Fair Housing (“AFFH”) programs.
Additional justification regarding local development trends impacting the viability of commercial and office uses.
Commitment to adopt future municipal code amendments to clarify regulations for residential care facilities and reasonable accommodation. Commitment to meet all requirements of Government Code Section 65583.2 when completing the rezoning of sites identified to accommodate the RHNA (Regional Housing Needs Assessment).
Additional commitment to monitor accessory dwelling unit (ADU) production and affordability.

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Additional information on the Neighborhood Improvement Task Force and programs completed to date.

As indicated above, once revisions are adopted by the City Council, the revisions to the Housing Element will be sent to HCD for final review and certification.

Based on feedback from HCD staff, it is not anticipated that there would be additional major changes to the Housing Element. Should HCD have minor revisions, modifications may be made administratively by the Director of Community Development.

Environmental Review:

This project is categorically exempt from the California Environmental Quality Act (CEQA) under CEQA Guidelines Section 15183, which allows a streamlined environmental review process for projects that are consistent with the densities established by existing zoning, community plan, or general plan policies for which an Environmental Impact Report (EIR) was certified, such as the City's recent General Plan EIR. An Environmental Analysis has been prepared to demonstrate this finding (Attachment 1, Exhibit B).

Public Noticing:

In accordance with the requirements of Section 9.184.040(C)(2) of the Municipal Code of the City of Lake Forest, this project has been noticed in a newspaper of general circulation on August 5, 2022. In addition, on August 5, 2022, public notices were posted at City Hall.

FISCAL IMPACT:

There is no fiscal impact associated with the adoption of the 2021-2029 Housing Element.

ATTACHMENTS:

1. Resolution to adopt the revised ”2021-2029 Housing Element” a. Revised Housing Element
b. Environmental Analysis

2. PC Resolution recommending City Council adopt the Revised “2021-2029 Housing Element”

3. City Council Agenda Report of January 4, 2022 (Link for Attachments)

4. Draft Housing Element dated March 7, 2022 (Link)

5. HCD Letter of Revisions
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6. Excerpt of Housing Element Revisions to HCD
Initiated By: Amy Stonich, AICP, Assistant Director of Community Development
Submitted By: Gayle Ackerman, AICP, Director of Community Development Approved By: Debra Rose, City Manager
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ATTACHMENT 1
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2021-2029 Housing Element (Revised) Agenda of August 16, 2022 - 1 -
RESOLUTION NO. CC 2022-__

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

LAKE FOREST, CALIFORNIA, ADOPTING THE REVISED
“2021-2029 HOUSING ELEMENT” OF THE GENERAL PLAN
WHEREAS, the California Government Code requires that cities review and update their Housing Elements every eight (8) years, according to a schedule set forth by the State Department of Housing and Community Development (“HCD”);
WHEREAS, the Housing Element sets forth the housing policies for the City, facilitates the preservation and development of housing, and establishes programs to accommodate the City's share of the regional housing needs in Southern California;
WHEREAS, the City of Lake Forest has been assigned an allocation of 3,236 new housing units as its share of the regional housing needs assessment (“RHNA”) in Southern California;
WHEREAS, in accordance with State Law, the City of Lake Forest has prepared a Draft Housing Element for the 6 th Cycle covering 2021-2029 period in accordance with California Government Code Sections 65580-65589.8 attached hereto as Exhibit A;
WHEREAS, in accordance with Government Code Section 65583, the City finds that the Housing Element (2021-2029) complies with the duty to Affirmatively Further Fair Housing;
WHEREAS, the Housing Element (2021-2029) complies with the requirements of State law and conforms to the purposes, intent and provisions of all the Elements of the City's General Plan;
WHEREAS, the Director of Community Development has reviewed the project’s potential effects on the environment, and has recommended that the project is categorically exempt from the California Environmental Quality Act (CEQA) under CEQA Guidelines Section 15183 which allows a streamlined environmental review process for projects that are consistent with the densities established by existing zoning, community plan or general plan policies for which an Environmental Impact Report (EIR) was certified, such as the City's recent General Plan EIR; and
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2021-2029 Housing Element (Revised) Agenda of August 16, 2022 - 2 -
WHEREAS, in preparation of the Housing Element (2021-2029), the City developed a robust Community Engagement Plan with a dedicated website which received over 1,200 views; conducted two online surveys between November 23, 2020, through December 22, 2020, as well as stakeholder interviews with the Kennedy Commission, Welcoming Neighbors Home, and the Fair Housing Council of Orange County; and held a virtual workshop conducted throughout the month of December 2020 to educate the community about housing issues and opportunities and gather input on housing-related topics; and WHEREAS, on September 23, 2021, pursuant to Government Code section 65585(b)(1), the City submitted the draft 2021-2029 Housing Element to the State of California Department of Housing and Community Development (“HCD”);
WHEREAS, the California Department of Housing and Community Development must review and provide comments on the Public Draft Housing Element and the City must update the Public Draft Housing Element in response to those comments in order to comply with State Housing Law; WHEREAS, on October 7, 2021, the City hosted a public open house event at which the draft Housing Element was shared and feedback was solicited;
WHEREAS, on November 4, 2021, the Planning Commission of the City of Lake Forest conducted a duly noticed public hearing for the purpose of considering the Housing Element update and made a recommendation to the City Council regarding its adoption;
WHEREAS, on January 4, 2022, the City Council conducted a public hearing for the purpose of considering the Housing Element update and adopted the draft Housing Element;
WHEREAS, based on requested revisions from HCD dated March 7, 2022, staff made minor revisions to the Draft Housing Element for consideration by the Planning Commission for recommendation to the City Council; WHEREAS, the City Manager or her designee is authorized to make minor modifications to the Housing Element to address comments provided by the Department of Housing and Community Development on this Housing Element, provided that the modifications would not exceed the total amount of development accommodated by the Housing Element prior to revisions and would not result in new actions by the City that would require a commitment of $20,000 or greater;
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2021-2029 Housing Element (Revised) Agenda of August 16, 2022 - 3 -
WHEREAS, the City gave notice of the public hearing at which the project would be considered by the Planning Commission by publishing a notice in a newspaper of general circulation on June 24, 2022, and by posting a notice at City Hall;
WHEREAS, on July 7, 2022, the Planning Commission of the City of Lake Forest conducted a duly noticed public hearing for the purpose of considering the revised Housing Element update and made a recommendation to the City Council regarding its adoption; and
WHEREAS, the City Council has duly considered all evidence, including the testimony of the City’s Consultant, interested parties, and the evaluation and recommendations by staff, presented at said hearing.

NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF LAKE FOREST DOES RESOLVE, DETERMINE, FIND AND ORDER AS FOLLOWS:

SECTION 1. CEQA. This project is categorically exempt from the California Environmental Quality Act (CEQA) under CEQA Guidelines Section 15183, which allows a streamlined environmental review process for projects that are consistent with the densities established by existing zoning, community plan or general plan policies for which an Environmental Impact Report (EIR) was certified, such as the City's recent General Plan EIR. An Environmental Analysis has been prepared to demonstrate this finding attached hereto as Exhibit B.

SECTION 2. The City Council further finds as follows:
a. Finding: The Draft Housing Element is consistent with the goals and policies of the General Plan.

Fact: The Draft Housing Element is a State-mandated Element of the City of Lake Forest’s General Plan. California State Legislation requires that the Housing Element be updated every eight years to adequately plan for the City’s housing needs. The Housing Element identifies sites that may accommodate the City's Regional Housing Needs Assessment (RHNA) obligation. As such, the Draft Housing Element is consistent with the goals and policies of the General Plan.
b. Finding: State law requires the adoption of a Housing Element as part of the General Plan of each municipality and said element shall be updated every eight years.

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2021-2029 Housing Element (Revised) Agenda of August 16, 2022 - 4 -
Fact: The current Housing Element for Lake Forest was adopted by the City Council in January 2014 for the 2014-2021 (5 th Cycle) planning period and was certified by the State. Lake Forest has complied with the State mandate to update its Housing Element for the 2021-2029 planning period. c. Finding: As required by State law during the preparation of an amendment to the General Plan, the planning agency has provided opportunities for the involvement of citizens, public agencies, civic, educational, and other community groups, though public hearing and other means the city deems appropriate.

Fact: Public involvement has been completed which included the involvement of residents, local housing community, several non-profit housing advocates, and key City staff. The City worked diligently to engage the community in safe and appropriate ways throughout 2020, during the COVID19 pandemic, when traditional in-person activities were not possible to conduct. This outreach also extended to the General Plan Update which was conducted during pre-COVID-19 protocols and included dozens of community meetings, an open house, and public hearings, where the community had the opportunity to weigh-in on key areas for future residential and non-residential growth. Further, the Planning Commission conducted a public hearing on November 4, 2021.

d. Finding: The City Council finds that the update to the Housing Element was prepared in accordance with State law and reviewed by the State Department of Housing and Community Development (HCD) as required by the California Government Code.

Fact: The City submitted a copy of the Housing Element on September 23, 2021, to HCD. HCD submitted a review letter to the City on November 22, 2021. Comments received from HCD were addressed and incorporated into the final document for City Council adoption of the Housing Element. e. Finding: In accordance with State law, the City Council finds that the existing uses on the nonvacant sites included in the inventory are likely to be discontinued during the planning period.

Fact: City of Lake Forest is essentially entirely built out. There is no vacant unentitled land remaining to accommodate new multifamily residential development. In order to accommodate its fair share of regional housing growth, the City must identify nonvacant sites to accommodate its remaining RHNA for all income levels (not only its lower income requirements). The City has specifically analyzed whether existing uses Item: 11
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constitute an impediment for residential uses on the site. Additional information provided in Appendix A Sites Analysis of the Housing Element (Exhibit A attached hereto) demonstrates that existing uses on the sites identified to accommodate a portion of the City’s RHNA do not constitute an impediment for residential uses on the site. Additional information regarding current operations and tenants, vacancies, properties listed for rent or sale, the demand for the current use, and contact with property/business owners are included. The City has considered each site individually and has concluded that, based on the substantial evidence provided, current uses are not an impediment to the sites’ redevelopment for residential uses (refer to the Suitability of Nonvacant Sites analysis on page BR-100 of Exhibit A).

SECTION 3. CITY COUNCIL ACTIONS. The City Council does hereby adopt the Housing Element (2021-2029) inclusive of revisions necessary in order to comply with State Housing Law.

PASSED, APPROVED AND ADOPTED this 16th day of August 2022, by the following vote, to wit:

ROBERT PEQUEÑO
MAYOR
ATTEST:

LISA BERGLUND

CITY CLERK
APPROVED AS TO FORM:

MATTHEW RICHARDSON

CITY ATTORNEY

STATE OF CALIFORNIA )

COUNTY OF ORANGE ) SS

CITY OF LAKE FOREST )
I, Lisa Berglund, City Clerk of the City of Lake Forest, California, do hereby certify that the foregoing Resolution No. <2022-___> was duly passed and Item: 11
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adopted at a regular meeting of the Lake Forest City Council on the 16 th day of August 2022 by the following vote, to wit:

AYES: COUNCIL MEMBERS:

NOES: COUNCIL MEMBERS:

ABSENT: COUNCIL MEMBERS:

ABSTAIN: COUNCIL MEMBERS:

LISA BERGLUND

CITY CLERK
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ATTACHMENT 1

EXHIBIT A
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2021-2029

HOUSING

ELEMENT
Adopted January 2, 2022
Minor Technical
Revisions June 2022
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Prepared For:

City of Lake Forest
Contact: Gayle Ackerman, AICP
Director of Community Development
City of Lake Forest
100 Civic Center Drive
Lake Forest, CA 92630
(949) 461-3460
https://lakeforestca.gov/

Prepared By:

De Novo Planning Group
Contact: Amanda Tropiano, Principal
180 E Main Street Suite 108
Tustin, CA 92780
[email protected]
https://denovoplanning.com/

2021-2029

HOUSING

ELEMENT
Adopted January 2, 2022
Minor Technical
Revisions June 2022
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2021-2029 Housing Element Organization

Part 1: Housing Plan
Part 1 of the 2021-2029 Housing Element is the City’s “Housing Plan”, which includes the goals, policies, and programs the City will implement to address constraints and needs. The City’s overarching objective is to ensure that decent, safe housing is available to all current and future residents at a cost that is within the reach of the diverse economic segments which comprise Lake Forest.

Part 2: Background Report
Part 2 of the 2021-2029 Housing Element is the “Background Report” which identifies the nature and extent of Lake Forest’s housing needs, including those of special populations, potential housing resources (land and funds), potential constraints to housing production, and energy conservation opportunities. By examining the City’s housings, resources, and constraints, the City can then determine a plan of action for providing adequate housing, as presented in Part 1: Housing Plan. In addition to identifying housing needs, the Background Report also presents information rega rding the setting in which these needs occur. This information is instrumental in providing a better understanding of the community, which in turn is essential for the planning of future housing needs.

Appendix A: Housing Sites Inventory
The Housing Element must include an inventory of land suitable and available for residential development to meet the City’s regional housing need by income level. Appendix A also includes a detailed analysis of nonvacant sites identified to meet a portion of the Ci ty’s lower income RHNA, including a description of existing uses, analysis of development trends applicable to each site, and a photo catalogue.

Appendix B: Public Engagement Summary
As part of the Housing Element Update process, the City hosted numerous opportunities for the community and key stakeholders to provide feedback on existing housing conditions, housing priorities, priority areas for new residential growth, and topics related to fair housing. Public participation played an important role in the refinement of the City’s housing goals and policies and in the development of new housing programs, as included in Part 1: Housing Plan. The public’s input also helped to validate and expand upon the contextual information included in Part 2: Background Report. The City’s efforts to engage the community in a meaningful and comprehensive way are summarized in Appendix B.

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PART 1:

HOUSING PLAN
Adopted January 2, 2022
Minor Technical
Revisions June 2022

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Housing Plan │ Page 1

HOUSING PLAN TABLE OF CONTENTS
1 2021-2029 HOUSING PLAN INTRODUCTION ................................................ 3 2 GOALS AND POLICIES ............................................................................... 3 3 CYCLE 6 HOUSING ELEMENT PROGRAMS ................................................. 76 Provision of Adequate Housing Sites to Achieve a Variety of Housing Types and Densities ............... 76 Removal of Constraints ...................................................................................................................... 1512 Housing and Supportive Services for Special Needs Populations (Goal 1) ...................................... 2115 Conserve the Existing Supply of Affordable Housing (Goal 2) .......................................................... 2620 Rehabilitate the City’s Existing Single-Family and Multi-Family Housing Stock (Goal 2) .................. 2822 Provide Housing Opportunities for First-Time Homebuyers (Goal 3) ................................................ 3225 Equal Housing Opportunity (Goal 4) .................................................................................................. 3326 4 QUANTIFIED OBJECTIVES .................................................................... 4834

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1 2021-2029 Housing Plan Introduction
This section presents the City’s Housing Plan, including goals, policies, and programs the City will implement to address constraints and needs. The City’s overarching objective is to ensure that decent, safe housing is available to all current and future residents at a cost that is within the reach of the diverse economic segments which comprise Lake Forest. To this end, the Housing Plan focuses on:
1) Encouraging housing diversity and opportunities;
2) Maintaining, preserving, and conser ving existing residential neighborhoods; 3) Increasing opportunities for home ownership;
4) Promoting equal opportunity for all residents to reside in the housing of their choice.

2 Goals and Policies
The Housing Element Background Report evaluates the City’s housing needs, opportunities and constraints, and presents a review of the previous element. This Ho using Plan reflects the City’s experience during the 2013-2021 planning period and sets forth the City’s goals, policies, and programs to address the identified housing needs and issues for the 2021-2029 planning period. Quantified objectives for new construction, rehabilitation and conservation are also identified. The goals and policies that guide the City’s housing programs and activities are as follows:

ISSUE: HOUSING DIVERSITY AND OPPORTUNITIES
Goal 1: Adequate housing to meet the existing and future needs of Lake Forest residents.

Policy 1.1: Allow for the development of a variety of housing opportuniti es (ownership and rental) in Lake Forest including low-density single-family homes, moderate-density townhomes, higher-density apartments and multi-family projects, mixed-use development, accessory dwelling units, and mobile homes to fulfill regional housing needs.

Policy 1.2: Support the development of affordable housing by offering development incentives on a case- by-case basis.

Policy 1.3: Support the provision of housing and suppor tive services for extremely low-income households and special groups, such as the elderly, persons with disabilities (including developmental disabilities), large families, single-parent households, and those in need of temporary shelter.

Policy 1.4: Promote the development of new housing units in the City’s mixed-use focus areas which are located along the City’s major transportation corridors and near community activity centers.

Policy 1.5: Remove or reduce constraints on affordable housing development to the extent feasible.

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Policy 1.6: Encourage residential developments to incorporate a minimum of 15% affordable units, including units affordable to extremely low-income households.

Policy 1.7: Maintain adequate capacity to acco mmodate the City’s unmet Regional Housing Needs Assessment (RHNA) allocation for all income categories throughout the planning period.

Policy 1.8: Allow by-right approval of housing devel opments proposed on non-vacant sites included in the previous housing element inventory and on vacant sites included in the two previous housing element inventories, provided that the propos ed housing development includes at least 20 percent lower-income affordable housing units.

ISSUE: MAINTENANCE, PRESERVATION, AND CONSERVATION OF HOUSING Goal 2: Maintenance and enhancement of the quality of existing residential neighborhoods.

Policy 2.1: Promote programs that improve the overall quality and conditions of existing housing in Lake Forest with an emphasis on housing that is affordable to lower-income households.

Policy 2.2: Promote and facilitate the conservation and rehabilitation of the City’s older residential properties.

Policy 2.3: Subject to the availability of funds, continue to offer rehabilitation and home improvement loans to qualified households.

Policy 2.4: Evaluate opportunities for comprehensi ve neighborhood improvements, including focused code enforcement and neighborhood clean-up days, and implement such activities as warranted.

Policy 2.5: Endeavor to preserve income-restricted affordable housing in the City that is at-risk of converting to market-rate.

Policy 2.6: Promote a balance of r ental and affordable ownership housing.

Policy 2.7: Continue to support County efforts to preserve and expand rental assistance programs for extremely low-income households, including the Housing Choice Voucher Program.

ISSUE: HOME OWNERSHIP
Goal 3: Increased opportunities for home ownership.

Policy 3.1: Encourage the development of affor dable ownership housing for first-time homebuyers.

Policy 3.2: Pursue state and federal funding sources to provide fair home purchase options to lower- and moderate-income households.

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Policy 3.3: Collaborate in regional efforts to pursue funding, such as mortgage revenue bonds and Mortgage Credit Certificates, for homeownership assistance programs.

ISSUE: EQUAL OPPORTUNITY
Goal 4: Promote equal opportunity for all residents to reside in housing of their choice by affirmatively furthering fair housing.

Policy 4.1: Encourage and support the enforcement of laws and regulations prohibiting discrimination in the sale, rental, or financing of housing based on race, color, ancestry, religion, national origin, sex, sexual orientation, gender ident ity, age, disability/medical conditions, familial status, marital status, source of income, or any other arbitrary factor.

Policy 4.2: Accommodate persons with disabilities w ho seek reasonable waiver or modification of land use controls and/or development standards pursuant to procedures and criteria set forth in the Zoning Code.

Policy 4.3: Assist in the enforcement of fair housing laws by prov iding support to organizations that can receive and investigate fair housing allegations, provide outreach and education regarding fair housing rights, monitor compliance with fair housing laws, and refer possible violations to enforcing agencies.

Policy 4.4: Encourage design which supports aging in place (such as universal design) in new development.

Policy 4.5: Encourage the development of housing a ffordable to lower-income households and housing for special needs groups throughout the community.

Policy 4.6: Provide information to the public on available housing, housing affordable to lower-income households, and special needs housing through the City’s public information channels.

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3 Cycle 6 Housing Element Programs
Lake Forest offers a variety of housing opportunities to meet the needs of the community and comply with state Housing Law. This section of the Housing Plan addresses the issues identified in the previous sections of the Element and provides a strategy to achieve the City’s housing goals. The housing programs designed to implement the City’s strategy are discussed in detail below.

The City has considered each program as it relates to affirmatively furthering fair housing. In addition to identifying the responsible agencies, funding sources, objectives, and timeframes for each program, the City has also identified the fair housing issue(s) and contributing factor(s) addressed by each program. For further information regarding fair housing issues and contributing factors in Lake Forest, see Section 6 of the Background Report.

PROVISION OF ADEQUATE HOUSING SITES TO ACHIEVE A VARIETY OF HOUSING TYPES AND

DENSITIES
A key element in satisfying the housing needs of all segments of the community is the provision of adequate sites for housing. This is an important function of both the General Plan and zoning.

Program 1: Land Use Policy, Entitlements, and Development Capacity (Shortfall Program) Planning and regulatory actions to achieve adequate housing sites are implemented through the Land Use Element, Zoning Code, and, in some instances, development agreements. These regulatory documents provide for a variety of residential development, rangi ng from lower-density single-family homes to higher- density apartments, condominiums, and mixed-use projects.

The City of Lake Forest received a RHNA allocati on of 3,236 units for the 2021-2029 RHNA period. After credits for constructed units (755461) and approved/entitled units (753976) are taken into consideration, the City of Lake Forest has a remaining 2021-2029 RHNA of 1,84 76 units, including 848 extremely/very low- income, 445 447 low-income, and 553 552 moderate-income units.

While the City adopted its new General Plan in 20202040 which establishes new mixed-use focus areas which designate sufficient sites to accommodate the City’s remaining RHNA, the City has not yet adopted new zoning standards to implement the land use designations. Without the zoning in place, the City finds that it currently has a shortfall of sites to accommodate it s remaining RHNA and must commit to a program to rezone sufficient sites to accommodate its RHNA for all income levels. The City is committed to rezoning all necessary parcels to create consistency with the General Plan Land Use Map, and is specifically committed, through this program, to complete the rezoning for all sites identified in Appendix A (Site Inventory) in accordance with the acreages, densities, and unit capacities identified therein. The new Zoning Map will be made available online and in person in accordance with transparency requirements. Sites will be rezoned consistent with Government Code Section 65583, s ubdivision (c)(1) and 65583.2 subdivisions (h) and (i).

The rezone will accommodate 100 percent of the shortfall during the planning period and will include the Item: 11
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following components.
 Permit owner-occupied and rental multifamily us es by right and do not require a conditional use permit or other discretionary review or approval for developments in which 20 percent or more of the units are affordable to lower income households.
 Permit the development of at l east 16 units per site and a minimum of 20 dwelling units per acre for suburban and metropolitan jurisdictions;
 For sites designated for mixed-use, allow 100 percent residential use and require that residential use occupy 50 percent of the total floor area of a mixed-use project;  Ensure sites will be available for development during the planning period where water and sewer can be provided.

The residential sites inventory consists of approxim ately 159 acres of land designated in mixed-use areas which allow for residential development at densities beyond greater than 30 du/ac, with the potential to yield at least 2,965 new units. These sites are located in areas adjacent to major transporta tion facilities and activity centers; the co-location of attainable/affordab le housing choices near transportation facilities and goods and services will improve access to opportunity for all persons, especially lower income households and persons with special needs, including persons with disabilities.

The City has also identified 34.55 acres of underdeveloped residential uses (two sites) that could yield an additional 382 units affordable to moderate and above moderate income households. Also construction of new accessory dwelling units (ADUs) will also add to the City’s housing stock. Together, these resources have the capacity to accommodate at least 3,378 new units affordable to all income levels. These sites can accommodate the City’s remaining RHNA allocation for all income levels through year 2029. The City will maintain an inventory of sites with residential development potential and provide it to prospective residential developers upon request.

Responsible Agencies: Community Development Department
Funding Sources: General Fund
2021-2029 Objectives: Maintain and monitor the residential sites inventory to ensure sufficient sites remain to accommodate the RHNA allocation throughout the RHNA period. Receive and process develop ment applications for residential projects. Rezone all sites identified in Appendix A consistent with the densities, acreages, and capacity levels identified in Appendix A.

Complete all rezoning pursuant to Government Code section 65583.2, subdivisions (h) and (i).

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Timeframe: Complete all necessary rezoning by October 15, 2022; Annual monitoring and reporting throughout the planning period.

Fair Housing Issues
Addressed:

Segregation and Integration; Disparities in Access to Opportunity; Racially and Ethnically Concentrated Areas of Poverty/Affluence; Disparities in Access to Opportunity for Persons with Disabilities; Disproportionate Housing Needs, including Displacement Risks; Site Inventory Contributing Factors
Addressed:

Community Opposition; Lack of Community Revitalization Strategies; Lack of Private Investment in Specific Neighborhoods; Land Use and Zoning Laws; Location and Type of Affordable Housing; Impediments to Mobility; Lack of Opportunity Due to High Housing Costs; Access to Transportation for Persons with Disabilities; Availability of Affordable Units in a Range of Sizes; Location of Employers

Program 2: Monitor Residential Capacity (No Net Loss)
The City will monitor the depletion of residential acreage, and review proposed General Plan amendments, Zone Changes, and development projects, to ensure an adeq uate inventory is available to meet the City’s 2021-2029 RHNA obligations. To ensure sufficient residential development capacity is maintained to accommodate the City’s RHNA allocation, the City will develop and implement a formal ongoing (project-by- project) evaluation procedure pursuant to Government Code Section 65863 and will make the findings required by that code section if a site is proposed for development with fewer units or at a different income level(s) than shown in the Housing Element Site Inv entory. Should an approval of development result in a reduction of residential development capacity below the capacity needed to accommodate the remaining need for lower-income, moderate-income, or above-moderate-income households, the City, and potentially the applicant (in accordance with State law), will identify and, if necessary, rezone sufficient sites within 180 days to accommodate the shortfall and ensure “no net loss” in capacity to accommodate the RHNA allocation, consistent with State law. Any rezoned site(s) will sa tisfy the adequate site requirements of Government Code Section 65583.2 and will be consistent with the City’s obligation to affirmatively further fair housing.

Responsible Agencies: Community Development Department
Funding Sources: General Fund
2021-2029 Objectives: Maintain adequate capacity to accommodate the City’s RHNA obligations at all income levels throughout the planning period. Report as required through the HCD annual report process.

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Timeframe: Ongoing implementation, at time of approval of a project on a site listed in the Housing Element, and annual reporting throughout the planning period.

Fair Housing Issues
Addressed:

Racially and Ethnically Concentrated Areas of Poverty/Affluence; Disparities in Access to Opportunity; Disproportionate Housing Needs, including Displacement Risks
Contributing Factors
Addressed:

Community Opposition; Displacement of Residents Due to Economic Pressures; Location and Type of Affo rdable Housing; Lack of Access to Opportunity due to High Housing Costs

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Program 3: Public Property Conversion to Housing Program The City will maintain a list of surplus City-owned la nds, including identification of address, APN, General Plan land use designation, zoning, current use, parcel size, and status (surplus land or exempt surplus land).

The City will work with non-profits and public agencies to evaluate the feasibility of transferring surplus City- owned lands not committed to other City purposes fo r development of affordable housing by the private sector. The inventory will be updated annually in conjunction with the Annua l Progress Report (“APR”) (Program 1). Any disposition of surplus lands shal l be conducted consistent with the requirements of Government Code Section 54220 et. seq.

Responsible Agencies: City Manager’s Office
Funding Sources: General Fund and federal and State technical assistance grants 2021-2029 Objectives: Collaborate with the development community on an annual basis , including affordable housing developers, to evaluate the viability of developing City-owned land as affordable housing.

Timeframe: Annually
Fair Housing Issues
Addressed:

Disparities in Access to Opportunity; Disproportionate Housing Needs, Including Displacement Risks
Contributing Factors
Addressed:

Lack of Public Investment in Specific Neighborhoods, including Services or Amenities; Lack of Local or R egional Cooperation; Land Use and Zoning Laws

Program 4: Replacement of Affordable Units
Consistent with the requirements of Government Code Section 65583.2(g), development projects on sites in the housing inventory (Appendix A) that have, or have had within the five years preceding the application, residential uses restricted wi th rents affordable to low- or very low-income households or residential uses occupied by low- or very low-income households, shall be conditioned to replace all such units at the same or lower income level as a condition of any development on the site, and such replacement requirements shall be consistent with Section 65915(c)(3).

Responsible Agencies: Community Development Department
Funding Sources: General Fund; replacement costs to be borne by developer of any such site
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2021-2029 Objectives: For all project applications , identify need for replacement of affordable housing units and ensure replacement, if required, occurs.

Timeframe: Ongoing
Fair Housing Issues
Addressed:

Fair Housing Enforcement and Outreach Capacity; Segregation and Integration; Disparities in Access to Opportunity; Disproportionate Housing Needs, Including Displacement Risks
Contributing Factors
Addressed:

Displacement of Residents Due to Economic Pressures; Location and TypeTyle of Affordable Housing; Lack of Opportunity Due to High Housing Costs; Quality of Affordable Housing Information Programs; Community Opposition; Loss of Affordable Housing

Program 5: Facilitate Affordable and Special Needs Housing Construction The City can encourage and facilitate affordable housing construction through financial assistance, removal of regulatory constraints, and administrative support. With limited funding, the City will rely on the following actions to encourage affordable housing production during the planning period:
• Affordable Housing Implementation Plans (AHIPs): During the two previous Housing Element cycles, the City entered into Development Agreements (DA) with the property owners/developers of land that was newly entitled for residential use. The DAs include an Affordable Housing Implementation Plan (AHIP) that required the production of affordable units in conjunction with the development. The City continues to monitor and enforce approved AHIPs and affordable housing covenants. • Collaborate with Affordable Housing Developers: Affordable housing developers work to develop, conserve and promote rental and ownership affordable housing. Particularly in relation to senior housing, the affordable housing developer is often, but not always, a local organization interested in developing affordable housing. The affordable housing developer is often involved with what is called "assisted housing", where some type of government assistance (such as Housing Choice Voucher program or Tax Credits) is provided to the individual household to keep rents affordable. An affordable housing developer may help meet the City’s goal of incorporating a minimum of 15% affordable units within new residential developments by implementing or assisting with the implementation of programs described in this Element. The City will continue to proactively collaborate with affordable housing developers to identify potential sites, write letters of support to help secure governmental and private-sector funding, and offer technical assistance related to the application of State density bonus provisions. The City will proactively provide affordable housing developer s with maps illustrating high resource areas and areas with high levels of people-based and place-based opportunities in the City in order to highlight Item: 11
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opportunities for new development to affirmatively further fair housing. In addition, the City will proactively provide developers the list of housing sites identified in Appendix A, which identifies those sites which are located in a 2021 TCAC/HCD moderate or high resource zone. • Regulatory Concessions and Incentives: The City will continue to work with developers on a case-by- case basis to provide State-mandated regulatory concessions and incentives to assist with the development of affordable and senior housing. In a relatively small city like Lake Forest, this is the most effective method of assisting developers, as each individual project can be analyzed to determine which concessions and incentives would be the most beneficial to the project’s feasibility. State-mandated regulatory concessions and incentives could include, but are not limited to, density bonuses, parking reductions, fee reductions or deferral, expedited permit processing, and modified or waived development standards.
• Collaborate with Housing Developers to Accommodate Large Families: Developers of affordable and market rate housing can help address the special needs of the community’s large families by providing a mix of unit types and sizes, including units with more than three bedrooms. The City will advise developers regarding the presence of larger families in Lake Forest and encourage them to include units with more than three bedrooms, if feasible. • Low-Income Housing Tax Credits (LIHTC): The City will assist developers in gaining funding for the development of affordable housing through the LIHTC program. Investors receive a credit against federal tax owed in return for providing funds to developers to build or renovate housing for low-income households. In turn, the capital subsidy allows rents to be set at below market rates.

Responsible Agencies: Community Development Department; Funding Sources: General Fund
2021-2029 Objectives: Monitor the City’s existing affordable housing stock and support affordable housing developers in their efforts to develop new affordable units in Lake Forest.

Timeframe: Annual outreach to the development community; Pp rovide ongoing assistance to interested affordable housing developers.

Fair Housing Issues
Addressed:

Outreach; Fair Housing Enforcement and Outreach Capacity; Segregation and Integration; Disparities in Access to Opportunity; Disproportionate Housing Needs, Including Displacement Risks
Contributing Factors
Addressed:

Lack of Private Fair Housing Outreach and Enforcement; Lack of Local or Regional Cooperation; Lack of Priv ate Investment in Specific Neighborhoods; Location of Accessible Housing; Availability of Affordable Item: 11
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Units in a Range of Sizes; Quality of Affordable Housing Information Programs

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REMOVAL OF CONSTRAINTS
State law requires the Housing Element to address, and where appropriate and legally possible, remove constraints affecting the maintenance, improvemen t, and development of housing. The following programs are designed to lessen governmental and nongovernmental constraints on housing development during the planning period.

Program 6: Monitor and Implement Changes in Federal and State Housing, Planning, and Zoning Laws
Although the 2021-2029 Housing Element update did not identify any significant governmental constraints to the development or maintenance of housing in Lake Forest, the City will continue to monitor its development process and zoning regulations to identify and remo ve constraints to the development of housing and affirmatively further fair housing goals. The City will also continue to monitor federal and State legislation that could impact housing and comment on, support, or oppose proposed changes or additions to existing legislation, as well as support new legislation when appropriate. The City will also endeavor to minimize governmental constraints to the development, improvement, and maintenance of housing.

As part of this program, the City commits to implementing current f ederal and State housing, planning and zoning laws. This includes complying with new tr ansparency requirements for posting all zoning, development standards and fees on the City’s website. While the City currently posts all zoning, development standards, and fees in various locations on the City’s website, the City will consolidate this information into the City’s Planning Division webpage to further sup port transparency and public access to information in compliance with new transparency laws.

Responsible Agencies: Community Development Department; City Manager’s Department Funding Sources: General Fund
2021-2029 Objectives: Comply with new transparency requirements for posting zoning, development standards, and fees on the City’s website. Stay updated on changes in federal and state housin g, planning, and zoning laws and participate in providing review and comments as appropriate.

Timeframe: Update the City’s website with consolidated zoning, development standards, and fee information by October 15, 2022. Annual monitoring and reporting throughout the planning period through the Housing Element Annual Progress Report (APR).

Fair Housing Issues
Addressed:

Fair Housing Enforcement and Outreach Capacity; Site Inventory Contributing Factors Land Use and Zoning Laws; Lack of State or Local Fair Housing Laws; Item: 11
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Addressed: Regulatory Barriers to Providing Housing and Supportive Services for Persons with Disabilities

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Program 7: Zoning Code Amendments – Housing Constraints The City shall update the Zoning Code to remove constraints to housing development and ensure the City’s standards and permitting requirements are consistent with State law. The update shall address the following:

A. Mixed-Use Standards. The Zoning Code shall be updated to address standards related to mixed- use development at densities and intensities consis tent with the Mixed-Use land use designations adopted as part of the City’s comprehensive General Plan Update approved in 2020. This process is anticipated to be completed by the end of 2022. See Program 1 (Shortfall Program) for more information.

B. Low Barrier Navigation Centers: The Zoning Code shall be updated to define and permit low- barrier navigation centers consistent with the requirements of Government Code Sections 65660 through 65668, including treating low-barrier navigation centers as a by-right use in areas zoned for mixed use and in nonresidential zones permitting multi-family uses (if applicable).

C. Transitional and Supportive Housing: The Zoning Code shall be revised as necessary to ensure that transitional and supportive housing is are allowed in residential and mixed-use zones subject to the same standards as a residence of the same type in the same zone consistentin accordance with Government Code Section 65583(c)(c)(3), and to allow eligible supportive housing as a by-right use in zones where multi-family and mixed uses are permitted pursuant toin accordance with Government Code Sections 65650 through 65656.

D. Employee Housing and Agricultural Worker Housing: The Zoning Code will be updated to define comply with Health and Safety Code Sections 1702 1.5, .6, .8“employee housing” distinctly from “agricultural worker housing” and to clarify that employee housing serving six or fewer employees shall be deemed a single-family structure and sha ll be subject to the same standards for a single- family residence in the same zone. Specifically, the City will only refer to it as employee housing and not make a distinction between agricultural versus employee housing types.

E. Agricultural Worker Housing : The Zoning Code will be updated to define “agricultural worker housing” and to identify that any agricultural worker housing providing no more than 36 beds in a group quarters, or consisting of 12 or fewer units or spaces, shall be deemed an agricultural land use and permitted in the same manner as agricultural uses consistent with Health and Safety Code Section 17021.6. The Zoning Code will also be up dated to provide for streamlined, ministerial approval of agricultural worker housing that meets the requirements of Health and Safety Code Section 17021.8.

F.E. Streamlined and Ministerial Review for Eligible Affordable Housing Projects: The Zoning Code will be updated to ensure that eligible multi-family projects with an affordable housing component are provided streamlined review and are subject only to objective design standards consistent with relevant provisions of SB 35 and SB 330, as provided for by applicable sections of the Government Item: 11
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Code, including but not limited to Sections 65905.5, 65913.4, 65940, 65941.1, 65950, and 66300.

State law defines objective design standards as those that “involve no personal or subjective judgement by a public official and are uniformly verifiable by reference to an external and uniform benchmark or criterion available and knowable by both the development applicant and public official prior to submittal.”
F. Emergency Shelter Parking: The Zoning Code will be updated to require sufficient parking to accommodate all staff working in an emergency shelter, provided that the standards will not require more parking for emergency shelters than other residential or commercial uses within the same zone, in compliance with AB 139.

G. Residential Care Facilities. The Zoning Code will be updated to re move references to residential care facilities in order to promote a barrier-free definition of family.

G.H. Reasonable Accommodation. The mMunicipal cCode will be amended to ensure that the cCity’s reasonable-accommodation procedures and findings comply with sState and federal fair-housing and disability laws and do not pose an illegal constraint on housing for persons with disabilities. The amendments will change the cCity’s “grounds for accommodation” findings to focus on the statutory criteria. Additionally, the cCity will make express the cCity’s existing practice of allowing persons to make a request for accommodations orally (not only in writing) and of making staff is available to assist in preparin g necessary written documentation to facilitate a re quest. Finally, the cCity will relocate the reasonable-accommodat ion section of the mMunicipal Cc ode out of Title 9, Planning and Zoning, to a more generally applicable location in the cCode to make clear that the process applies to governmental programs besides just planning and zoning requirements.

Responsible Agencies: Community Development Department
Funding Sources: General Fund
2021-2029 Objectives: Ensure that the City’s Zoning Code is consistent with State law and update the Zoning Code as needed to comply with future changes.

Timeframe: Zoning Code Amendments adopted by December 2022June 2023.

Fair Housing Issues
Addressed:

Segregation and Integration; Disparities in Access to Opportunity Contributing Factors
Addressed:

Lack of Affordable In-Home or Co mmunity-Based Supportive Services; Lack of Assistance for Transitioning from Institutional Settings to Integrated Housing; Land Use and Z oning Laws; Occupancy Codes and Restrictions

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Program 8: Accessory Dwelling Units
Accessory dwelling units (ADUs) and junior accessory dwelling units (JADUs) help meet the City’s housing needs for all income levels and also provide a housing resource for seniors, students, and low- and moderate-income households throughout the entire Lake Forest community, not just in any single geographic area. The City will continue to apply Zoning Code regulations that allow ADUs and JADUs (also known as second units or granny flats) by right in all residential zones, in accordance wi th State law. The City of Lake Forest will amend the ordinance as necessary to comply with current State Law. bBased on future changes to State law, the City will continue to amend the ordinance as necessary and work with HCD to ensure continued compliance with State Law. The City will also continue to monitor trends regarding the extent of ADU production to ensure that the Housing Element goals can be met.

While the City will continue to promote the opportunity for residents to develop ADUs throughout Lake Forest consistent with Section 9.146.050 of the Lake Forest Municipal Code, t he City is focused on promoting the development of ADUs that are affordable to lowe r income and moderate income households, and the development of ADUs in areas of opportunity as described in the Affirmatively Furthering Fair Housing section of the Housing Element Background Report. To the extent feasible, the City will survey ADU owners/builders to determine if they will be affordable to lower- or moderate-income households. The City will ask ADU permit applicants to voluntarily share the unit’s intended rental rate (if applicable) to track the supply of affordable ADUs in the City. As part of the City’s Housing Element Annual Progress Report preparation, the City will monitor ADU production and affordability against those projections identified in the Housing Element; if production is not keeping pace with projections so mu ch that a shortfall of sites to accommodate the City’s RHNA will occur, the City will, within 6 months, identi fy alternatives sites to maintain adequate capacity to accommodate the City’s remaining RHNA at all income levels.

Additionally, by the end of 2023, the City will identify and evaluate potential incentives (if any) to encourage production of affordable ADUs, particularly in high resource areas (as descri bed in the Affirmatively Furthering Fair Housing section of the Housing Element Background Report), and present potential strategies to implement those incentives to the Planning Comm ission and/or City Council during the planning period.

The City is considering the following incentives to facilitate production of ADUs:
 streamline the ADU permitting process
 provide clear step-by-step guide(s) to build an ADU (we have already created/provide a guide to the regulations; also make HCD’s guide available)
 provide staff support in the form of no cost consultation meetings (e.g., free one-hour meeting with Planning staff to review Code, guides; Q&A).
 make available ADU cost estimate calculator (in partnership with OCCOG’s grant-funded effort)  make available ADU standard plans (in partnership with OCCOG’s grant-funded effort) Item: 11
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 make available a list of contractors specializing in ADU construction (OCCOG may be working on such a list)
 promote any incentive programs offered by federal, state, county agencies The City will prepare new provide hard copies of ADU factsheets (in English and Spanish) and provide hard copies at City Hall and community facilities and share el ectronic versions on City social media accounts by June of 2022 . Upon request, the City will provide homeown er associations (HOAs) and other civic organizations with guidance to assist with the development of ADUs and work proactively to educate the community regarding the role ADUs play in providing affordable housing options and affirmatively furthering fair housing. The City has set a target of briefing at least one HOA or civic organization on the City’s ADU ordinance per year.

Responsible Agencies: Community Development Department
Funding Sources: General Fund
2021-2029 Objectives: Maintain an ADU Ordinance consistent with State Law. Support the development of accessory dwelling units in neighborhoods throughout the City.

Timeframe: Update the City’s current ADU ordinance by October 15, 2022 to comply with current State Law. Survey ADU owners/builders to determine affordability and update ADU application to inquire about affordability level:
2021-2022; identify and evaluate pot ential incentives to encourage production of affordable ADUs: 2022-2023; and present findings to the City’s Planning Commission and/or City Council: 2023; implementation and annual reporting throughout the RHNA period through the Housing Element Annual Progress Report: continuous. Prepare and distribute bilingual ADU factsheet by June of 2022. Invite all HOAs and relevant civic organization to meet annually to discuss the City’s ADU ordinance.

Fair Housing Issues
Addressed:

Segregation and Integration; Racially and Ethnically Concentrated Areas of Poverty/Affluence; Disparities in Access to Opportunity Contributing Factors
Addressed:

Availability of Affordable Units in a Range of Sizes; Displacement of Residents Due to Economic Pressures; Lack of Access to Opportunity Due to High Housing Costs; Location and Type of Affordable Housing

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HOUSING AND SUPPORTIVE SERVICES FOR SPECIAL NEEDS POPULATIONS (GOAL 1) Where there is a need for affordable housing, often there is also a need for supportive services for lower income households, including the homeless, extremely low-income households, and persons with disabilities (including developmental disabilities). The City assists service providers, with the allocation of CDBG funds, in meeting the immediate needs of persons with special needs, including the homeless, near-homeless, and extremely low-income households. Immediate need includes the provision of food, temporary shelter, health care, and other social services. The following programs are intend to address the overall need for housing and supportive services for special needs populations in Lake Forest.

Program 9: Sites for Homeless Shelters/ Homeless Prevention and Assistance Services Homelessness is a chronic problem throughout Souther n California. While the majority of the County’s homeless are in the older, more urbanized jurisdictions and in the beach communities, the 2019 Orange County Point-In-Time Report data indicates approximately 112 homeless persons within the City on any given night (for more information, see the Housing Element Background Report). In addition, the City has numerous households that may be considered at-ri sk of becoming homeless by virtue of their limited incomes. It is important for the City to provide and maintain the appropriate zoning to accommodate the provision of facilities that serve the homeless popul ation, most of whom are extremely-low-income, in accordance with State law.

The City allocates CDBG fundn ing to assist with homeless prevention and assistance services to organizations such as Families Forward, South Count y Outreach, and Family Assistance Ministries. The City contracts with Mercy House to provide an outreach worker in Like Forest. The outreach worker helps the homeless get into shelters, secure transitional or permanent housing, obtain medical assistance, or be admitted into a recovery program. The City also has a full time Homeless Liaison Officer (”HLO”) who works with the City’s homeless outreach provider to establish trust and communication with the homeless in an effort to offer supportive services.

Responsible Agencies: Community Development Department, City Manager Funding Sources: CDB G, State HEAP funds
2021-2029 Objectives: Support non-profit organiza tions that shelter the homeless (subject to available funding and on a case-by-case basis).

Timeframe: Annual monitoring and reporti ng throughout the planning period through the Housing Element Annual Progress Report (APR)
Fair Housing Issues
Addressed:

Fair Housing Enforcement and Outreach Capacity; Disparities in Access to Opportunity; Disproportionate Housing Needs, Including Displacement Risk
Contributing Factors Lack of AffordabilityAffordance, Integrated Housing for Individuals who need Supportive Services; Lack of A ssistance for Transition from Item: 11
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Addressed: Institutional Settings to Integrat ed Housing; Lack of Effective Accommodations for Unhoused Persons with Disabilities
Program 10: Transitional/Supportive and Affordable Housing The City provided financial assistance to non-profit service agencies (Families Forward, South County Outreach) to purchase existing housing in the community for use as transitional/supportive and affordable housing. In addition, the City owns two condominium units which are leased to a non-profit agency (Families Forward) for transitional/supportive affordable hous ing (Madrid Condominiums). These facilities help to address the needs of very low- and extremely low-inco me persons. Specifically, the City provided CDBG funding to a non-profit organization (South County Outrea ch) to assist with the purchase and operation of eight condominium units for transitional/supportive and affordable housing. In addition, the Lake Forest Redevelopment Agency acquired a four-unit apartment, wh ich was transferred to the Lake Forest Housing Authority, and subsequently sold to Families Forward (Saguaro Apartments). These units will continue to offer transitional/supportive and affordable housing to low-income residents through 2027–2031 (South County Outreach units), 2071 (Saguaro Apartments), and 2031 (expiration of Madrid Condominiums lease agreement with Families Forward). The City-owned units would likely continue to serve as affordable housing indefinitely, after the expiration of the current lease agreement.

Through the City’s partnership with Families Forward and South County Outreach, supportive services are provided to residents that include weekly case management counseling, weekly budget and financial counseling, child care assistance to attend counseling, education supplies assistance, employment supplies and tools assistance, health care payment assistan ce, permanent housing placement assistance, legal assistance (as available), life-skills training, weekly children’s program that addresses se lf-esteem, social skills, coping skills, values and beliefs, peer pres sure, anger management, self-care, and identifying social networks.

Responsible Agencies: City of Lake Forest, City of Lake Forest Housing Authority Funding Sources: CDBG
2021-2029 Objectives: Support non-profit organizations that provide affordable and transitional/supportive housing to individuals at risk for homelessness (subject to available funding and on a case-by-case basis) Timeframe: Annual monitoring and reporting throughout the planning period through the Housing Element Annual Progress Report (APR)
Fair Housing Issues
Addressed:

Fair Housing Enforcement and Outreach Capacity; Disparities in Access to Opportunity; Disproportionate Housing Needs, Including Displacement Risk
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Contributing Factors
Addressed:

Lack of Affordance, Integrated Housing for Individuals who need Supportive Services; Lack of Assistance for Transition from Institutional Settings to Integrated Housing; Lack of Effective Accommodations for Unhoused Persons with Disabilities

Program 11: Coordination with Social Service Agencies
A variety of social services agencies provide housing and supportive services to special needs groups in Lake Forest. Several of these social service agencies receive CDBG funds from the City to help administer these programs. The City determines its CDBG allocations to social service agencies annually based upon funding availability, applications rece ived, whether the agency provides a priority need in the City’s 5-year Consolidated Plan, past performance, if the agency meets Federal HUD regulations, and other criteria. In a typical program year, funding is allocated to nonprofits that serve the following needs of lower income individuals and households (i.e., those earning up to 80% AMI): food distribut ion, housing assistance, services and programs for the elderly and youth, serv ices for the disabled (including developmentally disabled), primary health care services, and fair housing advocacy and counseling.

Responsible Agencies: City of Lake Forest
Funding Sources: CDBG
2021-2029 Objectives: Continue to evaluate requests on an annual basis for allocation of CDBG Funds to social service agencies to benefit Lake Forest residents Timeframe: Annual monitoring and reporti ng throughout the planning period through the Housing Element Annual Progress Report (APR)
Fair Housing Issues
Addressed:

Outreach; Fair Housing Enforcement and Outreach Capacity; Disparities in Access to Opportunity for Persons with Disabilities
Contributing Factors
Addressed:

Lack of a Variety of Media; Lack of Resources for Fair Housing Agencies and Organizations
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Program 12: California Accessibility Standards Compliance Program The City will continue to ensure that all construction projects requiring build ing permits comply with the applicable State of California accessibility standards. The City will provide technical assistance as part of the building permit review process to assist property owners and contractors in understanding this law and related requirements applied to new development and/or retrofit or rehabilitation projects for public, residential, and commercial structures. The City will also provide a link on the City website to the Division of the State Architect’s web page that provides various access compliance reference materials, including an advisory manual and answers to frequently asked questions.

Responsible Agencies: Community Development Department
Funding Sources: General Fund
2021-2029 Objectives: Assure housing units accommodate residents with disabilities.

Timeframe: Ongoing implementation, updates to the City’s website by February 15, 2022
Fair Housing Issues
Addressed:

Disparities in Access to Opportunity for Persons with Disabilities Contributing Factors
Addressed:

Inaccessible Government Facilities or Services; Lack of Assistance for Housing Accessibility Modifications

Program 13: Density Bonus Implementation Program
The City will provide for density bonuses consistent with State law, including density bonuses and incentives for projects that contain 100% very low- and low-income units. The City will annually monitor State law updates which impact density bonuses and will update local plans and programs as necessary. As part of the City’s regular outreach to developers, the City wi ll advertise the City’s density bonus provisions and answer any questions on the program and its implementation.

Responsible Agencies: Community Development Department
Funding Sources: General Fund and planning grants
2021-2029 Objectives: Continue to implement density bonuses consistent with State law.

Timeframe: Annual monitoring of relevant legislation; annual outreach to the Item: 11
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development community; Oongoing implementation
Fair Housing Issues
Addressed:

Segregation and Integration; Racially and Ethnically Concentrated Areas of Poverty/Affluence; Disparities in Access to Opportunity Disproportionate Housing Needs, Including Displacement Risks; Site Inventory Contributing Factors
Addressed:

Lack of Community Revitalization Strategies; Lack of Private Investments in Specific Neighborhoods; Locati on and Type of Affordable Housing; Availability of Units in a Range of Sizes

CONSERVE THE EXISTING SUPPLY OF AFFORDABLE HOUSING (GOAL 2) Market rents in Lake Forest are at a level which signif icantly limits the supply of housing affordable to very low-income households. Rental subsidies are necessary to prevent many of the City's very low-income residents from spending upwards of 30% of their incomes on housing costs, and over-extending themselves financially. In addition to rent subsidies, actions to preserve the low-income housing projects in Lake Forest at-risk of converting to market rate will be necessary to maintain their affordability and not reduce affordable housing units available in the community.

Program 14: Rental Assistance
The Federal Housing Choice Voucher rental assistance program offers rental subsidies to extremely low- and very low-income families (i.e., those earning up to 50% AMI) and elderly who spend more than 30% of their income on rent. The subsidy represents the diff erence between the excess of 30% of their monthly income and the actual rent. Rent subsidies can be used to pay for mobile home park space rents.

The City will work with the Orange County Housing Authority to promote the program in a bilingual way to all residents while placing an emphasis on the City’s special needs populations, including persons with disabilities, female-headed households, seniors, and la rge families with the goal of assisting an average of approximately 190 extremely low- and very low-income households annually during the planning period.

Through other programs included in the Housing Plan, the City will educate the community on the importance of integrating affordable housing throughout all geogr aphic areas of the City to help create balanced and integrated neighborhoods.

Responsible Agencies: Orange County Housing Authority
Funding Sources: U.S. Department of Housing and Urban Development (HUD) Housing Choice Vouchers
2021-2029 Objectives: Promote the Housing Choice Vouchers program.

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Timeframe: Ongoing implementation and annual monitoring throughout the planning period.

Fair Housing Issues
Addressed:

Outreach; Disproportionate Housing Needs, Including Displacement Risks Contributing Factors
Addressed:

Lack of Variety of Media; Lack of Language Access; Lack of Accessible Forums; Displacement of Residents due to Economic Pressures; Private Discrimination

Program 15: Conservation of Existing Affordable Units
In order to meet the housing needs of all economic group s in Lake Forest, the City must develop programs to minimize the loss of housing units available to lower-income households. As of June 2021, the City’s affordable housing inventory consisted of 202 units, of which 811 were at risk of converting to market rate rents during the next 10 years.

The City will work with property owners, interest groups and the State and federal governments to conserve the City’s affordable housing stock through implementation of the following programs:
• Monitor Units at Risk: Maintain contact with prov iders and owners to monitor the status of existing and future affordable units.
• Work with Owners: Provide technical assistance to owners of properties with at -risk units by identifying funding sources and supporting grant or tax credit applications for the extension of affordability covenants.
• Work with Potential Purchasers: Where feasible, pr ovide technical assistance to public and non-profit agencies interested in purchasing and/or managing properties that include units at risk. • Tenant Education: The California Legislature extended the noticing requirement of at-risk units opting out of low-income use restrictions to one year. Should a property owner pursue conversion of the units to market rate, the City will strive to ensure that tenants are properly noticed and informed of their rights and that they are eligible to receive Housing Choice vouchers that would enable them to stay in their units, should they receive one.
• Preservation: Coordinate with qualified entities to preserve and maintain affordability of units at-risk of converting to market rate uses.
• Noticing Requirements: Comply with noticing requirements within three years, twelve months, and six months of the affordability expiration date.

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Responsible Agencies: City of Lake Forest Hous ing Authority; Orange County Housing Authority Funding Sources: U.S. Department of Housing and Urban Development Section 8 Allocation; Other funding sources as available
2021-2029 Objectives: Work with property owners, interest groups and the State and federal governments to conserve the City’s affordable housing stock.

Timeframe: Ongoing implementation and annual monitoring and reporting throughout the planning period through the Housing Element Annual Progress Report (APR). Within 60 days of notice of intent to convert at-risk units to market rate rents, the City will work with potential purchasers using HCD’s current list of Qualified Entities ( http://www.hcd.ca.gov/hpd/hrc/tech/presrv/), and educate tenants of their rights, in collaboration with property owners.

Fair Housing Issues
Addressed:

Outreach; Disproportionate Housing Needs, Including Displacement Risks; Site Inventory
Contributing Factors
Addressed:

Lack of Local Public Fair Housing Enforcement; Lack of Tenant Protections; Location and Type of Affordable Housing; Displacement of Residents Due to Economic Pressures

REHABILITATE THE CITY’S EXISTING SINGLE -FAMILY AND MULTI-FAMILY HOUSING STOCK (GOAL 2)
The majority of the City's housing stock is in good condit ion; however, it is important for the City to provide programs that ensure the continued maintenance of its housing stock. The City utilizes CDBG funds to operate a single-family housing (attached and detached and mobile homes) rehabilitation loan program for low- to moderate income households, and promotes improvements through its code enforcement and targeted Neighborhood Preservation programs Citywide.

Program 16: Housing Rehabilitation Loan Program
Subject to the availability of funding and annual City Council approval, the City provides housing rehabilitation assistance to low- to moderate-income homeowners through a loan program for owner-occupied single- family detached and attached homes and mobile home units, which is funded through the City’s CDBG program. A zero-interest deferred payment loan of up to $30,000 is available to conventional single-family residence households earning up to 80% AMI. A 3% interest loan amortized for a 15-year period is available to those who wish to pay off their loan sooner. Loan s of up to $15,000 are available to owners of mobile homes. Eligible repairs include roofing, windows, exte rior and interior painting, plumbing, electrical, energy/weatherization, garage doors, and other common home repairs, as well as accessibility Item: 11
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improvements.

The City promotes its owner-occupied Housing Rehab ilitation Loan Program on a year-round basis on its website and in the City’s quarterly newsletter. The loan program is only available for owner-occupied single- family homes, both attached and detached, and mobile homes.

Responsible Agencies: Community Development Department
Funding Sources: CDBG
2021-2029 Objectives: Assist 10 lower-income homeowners annually through the Housing Rehabilitation Loan Program.

Timeframe: Annual allocation of CDBG funds through the CDBG Action Plan process, and annual monitoring and reporting through the City’s (HUD required) Consolidated Annual Performance Evaluation Report (CAPER) process throughout the planning period.

Fair Housing Issues
Addressed:

Segregation and Integration; Racially and Ethnically Concentrated Areas of Poverty; Disparities and Access to Opportunity; Disproportionate Housing Needs, Including Displacement Risks
Contributing Factors
Addressed:

Lack of Public Investment in Specific Neighborhoods; Lack of Community Revitalization Strategies; Deteriorated and Abandoned Properties Program 17: Code Enforcement and Neighborhood Preservation The Code Enforcement and Neighborhood Preservation program implements a comprehensive approach to neighborhood improvement. Community Development Department inspectors respond to complaints related to substandard housing, property maintenance, overgrown vegetation, trash and debris, illegal conversions, improper occupancy and other nuisance and zoning complaints. For over two decades, the City has allocated CDBG funds annually to the Neighborhood Pride Paint Program. As funding permits, the City will continue sponsoring similar neighborhood preservation and revi talization events during the planning period. Code enforcement staff will also continue to inform eligible owners about the City’s housing rehabilitation loan and paint programs.

Responsible Agencies: Community Development Department
Funding Sources: CDBG and General Fund
2021-2029 Objectives: Continue to enforce applicable sectio ns of the Lake Forest Municipal Code, including the California Building Code
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Timeframe: Ongoing implementation and reporting throughout the planning period through the Housing Element Annual Progress Report (APR).

Fair Housing Issues
Addressed:

Lack of Public Investment in Specific Neighborhoods; Lack of Community Revitalization Strategies; Deteriorated and Abandoned Properties

Program 18: Energy Conservation and Energy Efficiency Opportunities The City will continue to implement energy-efficient standards for new construction and rehabilitation projects, including the California Green Buildin g Standards Code. Information regardi ng the City’s energy-efficiency standards and available programs to assist homeowner s and property owners, including those identified in the Housing Element Background Report, will be made av ailable on the City’s website and at the permit counter in English and Spanish . In addition to promoting the programs Citywide, the City will target special advertisements and education to the City’s lower-income census tracts to explain available programs and potential long-term utility cost saving s. The City will review the Gener al Plan to determine if updates are needed to support and encourage energy efficiency in existing and new housing, especially in areas of the City with lower CalEnviroScreen scores which may su ffer from elevated levels of environmental burdens. If updates are necessary, amend the General Plan to support this program.

Responsible Agencies: Community Development Department
Funding Sources: General Fund
2021-2029 Objectives: Improve energy-efficiency in new and existing development and promote available programs and benefits to all City residents, especially lower-income residents.

Timeframe: Ongoing implementation; review the General Plan to determine if updates are appropriate no later than December 1, 2022 and complete updates, if needed, no later than December 1, 2023.

Fair Housing Issues
Addressed:

Outreach
Contributing Factors Lack of Variety of Media; Lack of Language Access Item: 11
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Addressed:

Program 19: Lead Based Paint Education and Reduction Program Lead based paint was used commonly in the United Stat es in homes built prior to 1978. When properly maintained and managed, this paint poses little risk. However, due to exposure to lead-based paint hazards, people of all ages (and especially children), can have bl ood-lead levels above safe limits. Lead poisoning can cause permanent damage to the brain and many other organs and causes reduced intelligence and behavioral problems. To protect families from exposure to lead from paint, dust, and soil, Congress passed the Residential Lead Based Paint Hazard Reduction Act of 1992, also known as Title X. Section 1018 of this law directed HUD and EPA to require the disclosure of known information on lead-based paint and lead- based paint hazards before the sale or lease of most housing built before 1978.

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While the majority of Lake Forest’s housing stock was built after 1978, exposure to lead-based paint hazards continues to impact the community. Occupants of the City’s older homes tend to be some of the City’s more vulnerable special needs populations, including seniors and lower-income households.

The City is committed to helping minimize the risk of lead poisoning and will educate the community on issues regarding lead-based paint hazards and resources available to remove this hazard from their home. The City will identify neighborhoods with homes that were built before 1978 and target education directly to these homeowners via programs such as direct mailers or geographic-based social media posts. Issues related to lead based paint are most likely to be concentrated in the City’s older neighborhoods, specifically Southwest Lake Forest. Efforts to improve the quality of life and living conditions for Southwest Lake Forest residents are described in detail as part of Program 24, Neighborhood Improvement Task Force. Information will be provided in English and Spanish.

Responsible Agencies: Community Development Department
Funding Sources: Grant Funding
2021-2029 Objectives: Educate the community on issues regarding lead-based paint hazards.

Timeframe: Annual monitoring and reporting throughout the planning period through the Housing Element Annual Progress Report (APR).

Fair Housing Issues
Addressed:

Outreach
Contributing Factors
Addressed:

Lack of Variety of Media; Lack of Language Access

PROVIDE HOUSING OPPORTUNITIES FOR FIRST-TIME HOMEBUYERS (GOAL 3) Home ownership in Orange County is increasingly unaffordable to lower- and moderate-income residents.

Due to the high cost of housing in Lake Forest, first-ti me home buyer programs are cost-prohibitive for the City without a County or other complementary program.

Program 20: Homebuyer Assistance Programs
The City has identified a goal of assisting five households to achieve home ownership annually during the planning period. The Mortgage Credit Certificate (MCC) Program, administered by the County of Orange, enables lower- and moderate-income first-time homebuyers to receive a federal income tax credit of up to 15% of the annual mortgage interest paid. The MCC reduces federal income tax, increases take-home pay, and increases the qualifying loan amount for homebuyers. Program assistance is available only to income- Item: 11
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eligible persons and families who have not owned a home in the last three years. The property must be a single-family detached home, condominium, or townhou se. Although the program currently applies only to census tracts outside of Lake Forest, the City will continue to monitor the program for any future applicability to Lake Forest households and notify eligible applicants, as feasible.

The Southern California Housing Finance Agency (SCHFA) raises funds for mortgage financing through the sale of tax-exempt revenue bonds. The City cooperat es with lenders and the County in advertising the availability of the SCHFA program, including advertisements on the City’s website.

Responsible Agencies: County of Orange
Funding Sources: Federal tax credits; mortgage revenue bonds 2021-2029 Objectives: Continue to promote the homeb uyer assistance programs ; assist five households annually (as funding is available).

Timeframe: Ongoing implementation and reporting throughout the planning period through the Housing Element Annual Progress Report (APR).

Fair Housing Issues
Addressed:

Disparities in Access to Opportunity; Disproportionate Housing Needs, Including Displacement Risks
Contributing Factors
Addressed:

Access to Financial Services; Displacement of Residents Due to Economic Pressures; Lending Discrimination

EQUAL HOUSING OPPORTUNITY (GOAL 4)
Program 21: Fair Housing Services
Lake Forest currently contracts with the Fair Housi ng Council of Orange County (FHCOC) for the provision of fair housing services, and the City will continue to contract with a fair housing service provider to provide fair housing services for the duration of the planning period. Services offered include bilingual fair housing enforcement and education, landlor d/tenant counseling, mediation and homebuyer HUD counseling which includes first-time homebuyer education and mortgage default counseling.

The City monitors and attempts to minimize discri minatory housing practices with the assistance of the FHCOC. Funding to FHCOC is provided annually from the City’s CDBG funding allocation. Fair Housing actively counsels residents on landlord/tenant issues to help minimize discriminatory housing acquisition policies and practices. In addition to providing educational workshops to our residents, the organization advocates fair housing rights on behalf of residents. The City will continue to maintain the link on the City’s website providing information about fair housing services. The City will also work with its fair housing service Item: 11
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provider to identify any specific geographic areas in the City which have higher levels of discrimination claims and will target outreach and education to these areas.

To help address fair housing issues at local and regional levels, the City will continue efforts to mitigate impediments identified in the Regional Analysis of Impediments to Fair Housing Choice.

Responsible Agencies: City of Lake Forest; fair housing service provider Funding Sources: CDBG
2021-2029 Objectives: Support fair housing service providers and efforts to minimize discriminatory housing practices.

Timeframe: Annual allocation of funds to fair housing service provider. Annual monitoring and reporting throughout the planning period through the Housing Element Annual Progress Report (APR) and CDBG CAPER.

Fair Housing Issues
Addressed:

Outreach; Fair Housing Enforcement and Outreach Capacity Contributing Factors
Addressed:

Lack of Language Access; Lack of Accessible Forums; Lack of Resources for Fair Housing Agencies and Organizations

Program 22: Affirmatively Furthering Fair Housing Outreach and Coordination Program Facilitate equal and fair housing opportunities by implem enting actions to affirmatively further fair housing and opportunities for all persons regardless of race, re ligion, sex, age, marital or familial status, ancestry, national origin, color, disability, or other protecte d characteristics through provision of information, coordination, and education on fair housing law and practices to residents, landlords, and housing developers. This program addresses the fa ir housing issues of education and outreach, integration/segregation, and access to opportunity. Efforts will begin immediately and may include, but not be limited to:

The biggest fair housing issues facing Lake Forest are: displacement of residents due to economic pressures; lack of opportunity due to high housing costs; land use and zoning laws; of public investment in specific neighborhoods, including services or amenities; and location and type of affordable housing; private discrimination. The new Affirmatively Furthering Fair Housing (AFFH) component of the Housing Element connects these fair housing issues with programs in the Housing Element, as well as additional meaningful actions that the City will undertake to help address them. Table HP-2 on the following pages presents a summary of the issues, contributing factors, and the City’s planned actions to address these issues.

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Table 1: Fair Housing Issues, Factors, Actions, and Outcomes Fair Housing Issue Contributing Factor Priority
Level
Actions and Outcomes
Disparities in
Access to
Opportunity

(New Opportunities)
 Lack of opportunity due to high
housing costs
 Land use and zoning laws
 Displacement of residents due to
economic pressures
 Lack of public investment in specific
neighborhoods, including services or
amenities
 Community opposition
 Impediments to mobility
 Lack of local or regional cooperation
 Quality of affordable housing
information programs
High
City Actions
 Implement Program 1: Land Use Policy, Entitlements, and Development Capacity (Shortfall Program), to rezone sites to accommodate new residential and mixed-use development at densities consistent with the City’s General Plan (adopted in 2020) to meet the City’s RHNA at all income levels and ensure that the distribution of sites throughout the community is consistent with the City’s duty to affirmatively further fair housing  Implement Program 2: Monitor Residential Capacity (No Net Loss), to ensure that replacement sites identified to continue to accommodate the City’s rema ining RHNA throughout the
planning period are consistent with the City’s duty to affirmatively further fair housing
 On an ongoing basis, actively recruit residents from
neighborhoods of concentrated poverty to serve or participate on boards, committees, and other local government bodies as positions are made available due to the regular appointment process or vacancies
Action Outcomes:
 Through the above steps, the City’s goal will be to promote the development of 1,648 new units (including 303 lower income Item: 11
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units and 167 moderate income units, consistent with the City’s Quantified Objectives for 2021-2029, as shown in Table 2 of the Housing Plan) with 75% of the new units located in areas of moderate or high opportunity; rezone 158 acres to allow for the development of up to 2,965 multifamily units (as described in Appendix A, Table B), with 75% of the units located in areas of moderate or high opportunity as shown on Figure 21: TCAC/HCD Opportunity Area Map; and increase the number of applications from residents living in low or moderate resource areas for open Board and Commission positions by 20%
Disproportionate
Housing Needs,
including
Displacement Risks

(New Opportunities)
 Availability of affordable units in a
range of sizes
 Displacement of residents due to
economic pressures
 Lack of access to opportunity due to
high housing costs
 Land use and zoning laws
 Lack of public investment in specific
neighborhoods, including services or
amenities
High
 Implement Program 4: Replacement of Affordable Units, to ensure that affordable units that are removed from the City’s housing stock are replaced in accordance with State law  Implement Program 5: Facilitat e Affordable and Special Needs Housing Construction, to encourage the development of housing units to serve the needs of larger households, including large extremely low income households
 Implement Program 23: Economic Displacement Risk Analysis, to proactively identify potential issues related to economic displacement as a result of new development

Action Outcomes:
 Through the above steps, the City’s goal will be to maintain at least 202 affordable housing units in the City; increase the proportion of new multifamily units that are 3 or more bedrooms Item: 11
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by 10%; promote the develop of 70 new extremely low income housing units (consistent with the City’s Quantified Objectives for 2021-2029, as shown in Table 2 of the Housing Plan); and committed $70,500 to implement programs and improvements serving the Southwest Lake Forest neighborhood with a focus on programs and improvements that protect existing residents from displacement
Segregation and
Integration

(Place-based
Strategies,
Displacement)
 Community opposition
 Displacement of residents due to
economic pressures
 Lack of local or regional cooperation
 Land use and zoning laws
 Location and type of affordable
housing
 Private discrimination
 Lack of public investment in specific
neighborhoods, including services or
amenities
Medium City Actions:
 Coordinate with local organizations, through Community Action Agency, Continuum of Care, and Ho using Authority efforts, to encourage, expand, and publicize fa ir housing requirements as part of programs that provide rental assistance to lower income households.
 On an ongoing basis, and at least annually, review land use and planning proposals, including dev elopment proposals, general plan amendments, master planning efforts for parks, recreation, infrastructure, and other facilities and amenities, to ensure that the City is replacing segregated living patterns with integrated and balanced living patterns, where applicable and feasible, and work to transform racially and ethnically concentrated areas of poverty into areas of opportunity without displacement.  Implement Program 1: Land Use Policy, Entitlements, and Development Capacity (Shortfall Program), to allow for new development and investment in areas of lower household
incomes (Southwest Lake Forest) and Affluence (Foothill Ranch) Item: 11
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 Implement Program 8: Accessory Dwelling Units, to actively educate homeowners associations in areas of affluence about the potential for development of ADU to meet the needs of lower income households
 Implement Program 16: Housing Rehabilitation Loan Program, to support households in need of rehabilitation assistance, which are most likely to be located in areas of lower household income  Implement Program 24: Neighborhood Improvement Task Force, to study the needs of the City’s lower-income and racially- segregated neighborhoods and identify, fund, and implement improvements to address the needs identified
Action Outcomes:
 Through the above steps, the City’s goal will be to Increase the distribution of fair housing material by 15%; rezone 158 acres to accommodate the development of up to 2,965 new units (as described in Appendix A, Table B) with a focus to promote the development of units affordable to lower income households in areas of moderate or high opportunity; and encourage the development of 4 ADUs per year (with a goal of at least 3 being affordable to lower income households)
Disparities in
Access to
Opportunity for
Persons with
Disabilities
 Access to transportation for persons
with disabilities
 Lack of affordable in-home or
community-based supportive services
Medium
City Actions:
 Implement Program 1: Land Use Policy, Entitlements, and Development Capacity (Shortfall Program), to rezone sites adjacent to transit corridors and activity centers to allow for Item: 11
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(New Opportunities)
higher density residential development, suitable for affordable and special needs housing, including new opportunities for persons with disabilities
 Implement Program 5: Facilitat e Affordable and Special Needs Housing Construction, whereby the City will proactively reach out to developers of housing for special needs populations to share details about special needs groups in Lake Forest and promote the development of housing for special needs groups in areas of moderate and high levels of opportunity
 Implement Program 6: Monitor and Implement Changes in Federal and State Housing, Planning, and Zoning Laws to proactively identify changes in Federal and/or State regulations required to be implemented at the local level in order to improve access to opportunity for persons with disabilities
Action Outcomes:

Through the above steps, the City’s goal will be to rezone 158 acres to accommodate the development of up to 2,965 new units (as described in Appendix A, Table B) with a focus to promote the development of units affordable to lower income households in areas of moderate or high opportunity; Increase the number of local persons with disabilities taking transit by 10% by encouraging the development of new housing for persons with di sabilities to be located close to transit routes; increase the proportion of new multifamily units that are 3 or more bedrooms by 10%; and resolve 100% of reasonable accommodation requests consistent with the requirements of State Item: 11
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law
Fair Housing
Enforcement and
Outreach

(Housing Mobility,
Displacement)
 Lack of resources for fair housing
agencies and organizations
 Lack of local private fair housing
outreach and enforcement
Medium
City Actions:
 City staff will serve as liaison between the public and appropriate agencies in matters concerning housing discrimination within the City. The City will refer discrimination complaints to the City’s fair housing services provider.

Provide a bi-biennial fair housing update to the City Council.  Provide annual public service announcements, through
coordination with HCD, via various media (e.g., newspaper ads, public service announcements at local radio and television channels, the City’s website, or the City’s social media accounts).  Provide fair housing literature to schools, libraries, and post offices. This information is available via the City’s fair housing service provider and will be reviewed annually to ensure that the posters and literature being provided are up-to-date.
 Provide public information and brochures regarding fair housing/equal housing opportunity requirements including how to file a complaint and access the investigation and enforcement activities of the State Fair Employment and Housing
Commission. This information will be made available on the City’s website and at City Hall. This information will be reviewed annually to ensure that any materials, links, and information provided are current.
 Provide annual trai ning of City staff, including through Item: 11
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coordination with local advocacy groups or fair housing services provider, on how to receive, log, refer, and follow-up on fair housing complaints. If resolution was not obtained for any complaints, refer complaint to HCD to ensure that affordable housing laws are actively enforced.
 Provide a bi-biennial fair housing update to the City Council.  On an annual basis, provide education to the community on the importance of participating in the planning and decision-making process and completing Census questionnaires.

Action Outcomes:
 Through the above steps, the City’s goal will be to refer three discrimination complaints to the City’s fair housing services provider annually; increase the number of places with fair housing service provider information by 20% by 2024; and educate three landlords annually
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Education and Outreach
• Provide public information and brochures regarding fair housing/equal housing opportunity requirements including how to file a complain t and access the investigation and enforcement activities of the State Fair Employment and Ho using Commission. This information will be made available on the City’s website and at City Hall. This information will be reviewed annually to ensure that any materials, links, and information provided are current. • City staff will serve as liaison between the public and appropriate agencies in matters concerning housing discrimination within the City . The City will refer discrimination complaints to the City’s fair housing services provider.
• Provide annual training of City staff, including through coordination with local ad vocacy groups or fair housing services provider, on how to receive, log, refer, and follow-up on fair housing complaints. If resolution was not obtained for any complaints, refer complaint to HCD to ensure that affordable housing laws are actively enforced.
• Provide a bi-biennial fair housing update to the City Council. • Provide annual public service announcements, thro ugh coordination with HCD, via various media (e.g., newspaper ads, public service announcements at local radio and television channels, the City’s website, or the City’s social media accounts).
• Provide fair housing literature to schools, libraries, and post offices. This information is available via the City’s fair housing service provider and will be reviewed annually to ensure that the posters and literature being provided are up-to-date.

Provide public information and brochures regarding fair housing/equal housing opportunity requirements including how to file a complain t and access the investigation and enforcement activities of the State Fair Employment and Housing Commission. This information will be made available on the City’s website and at City Hall. This information will be reviewed annually to ensure that any materials, links, and information provided are current.

Provide annual training of City staff, including through coordination with local advocacy groups or fair housing services provider, on how to receive, log, refer, and follow-up on fair housing complaints. If resolution was not obtained for any complaints, refer complaint to HCD to ensure that affordable housing laws are actively enforced.

Integration/Segregation
• Coordinate with local organizations, through Community Action Agency, Continuum of Care, and Housing Authority efforts, to encourage, expand, and publicize fair housing requirements as part of Item: 11
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programs that provide rental assistance to lower income households. • On an ongoing basis, and at least annually, review land use and planning proposals, including development proposals, general plan amendments, master planning efforts for parks, recreation, infrastructure, and other facilities and amenities, to ensure that the City is replacing segregated living patterns with integrated and balanced living patterns, where applicable and feasible, and work to transform racially and ethnically concentrated area s of poverty into areas of opportunity without displacement.

Access to Opportunity
• Provide assistance to aid alleged victims of violence or discrimination in obtaining access to appropriate State or federal agency programs.
• On an ongoing basis, actively recruit residents fr om neighborhoods of concentrated poverty to serve or participate on boards, committees, and other lo cal government bodies as positions are made available due to the regular appointment process or vacancies. • On an annual basis, provide education to the community on the importance of participating in the planning and decision-making process and completing Census questionnaires.

Responsible Agencies: Community Development Department
Funding Sources: General Fund
2021-2029 Objectives: Facilitate equal and fair housing opportunities by implementing actions to affirmatively further fair housing and opportunities for all persons regardless of race, religion, sex, age, marital or familial status, ancestry, national origin, color, disability, or other protected characteristics through provision of information, coordination, and education on fair housing law and practices to residents, landlords, and housing developers.

Timeframe: Ongoing outreach and coordination, beginning immediately; annual review of fair housing educational informati on to ensure that the most recent information provided by the City’s fair housing service provider is being disseminated; annual presentations and media outreach.

Fair Housing Issues
Addressed:

Outreach; Fair Housing Enforcement and Outreach Capacity; Segregation and Integration; Racially and Ethnically Concentrated Areas of Poverty/Affluence; Disparities in Ac cess to Opportunity; Disparities in Access to Opportunity for Persons with Disabilities; Disproportionate Housing Needs, Including Displacement Risks; Site Inventory Item: 11
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Contributing Factors
Addressed:

All
Program 23: Economic Displacement Risk Analysis
Economic displacement can occur when new developm ent, particularly residential development, changes the market conditions in an existing area so much that current residents can no longer afford to live there.

The City of Lake Forest can reduce the impact of ec onomic displacement when it occurs by preventing practices that increase or enable displacement. To determine if market-force economic displacement is occurring due to development of new housing, increased housing costs, or other factors, the City will conduct an analysis to determine if individuals and families may be displaced as a result of new residential development in the City’s mixed-use areas. The analysis will consider gentrification locally and will assess how new development and community investments may pot entially influence displacement. If this study shows that displacement is expected as a result of new development in the City’s mixed-use areas, the City will develop an action program based on the identified causes of displacement, including specific actions to monitor and mitigate displacement. Annual review of the action program may result in modifications to further reduce displacement risk. This program addresses the fair housing issue of disproportionate housing needs, including displacement risk.

Responsible Agencies: Community Development Department
Funding Sources: Grant Funding; General Fund
2021-2029 Objectives: Understand the potential for market-force economic displacement and consider programs to address the issue, if necessary.

Timeframe: Conduct analysis by December 31, 2022 and establish resulting programs (if any) by December 31, 2023. Ongoing implementation and reporting throughout the planning period thro ugh the Housing Element Annual Progress Report (APR).

Fair Housing Issues
Addressed:

Disproportionate Housing Needs, Including Displacement Risks Contributing Factors
Addressed:

Displacement of residents due to economic pressures
Program 24: Neighborhood Improvement Task Force
The City of Lake Forest has created a new Neigh borhood Improvement Task Force (NITF) to address neighborhood-specific issues in the community’s older residential neighborhoods. The NITF is an interdepartmental partnership composed of City representatives from the City Manager’s Office, Community Item: 11
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Development Department, Economic Development Division, Public Works Department, Police Services Department, and Management Services Department led out of the City Manager’s Office. Programs recommended by the NITF will be a key tool the City will use to address fair housing issues and affirmatively further fair housing. For example, the City expects to host a workshop to attract developers and work with the Fair Housing representatives and residents of study areas to inform them of their rights under State law.

As analyzed in the Affirmatively Furthering Fair Housing section of the Housing Element Background Report, the City has identified the area of Southwest Lake Fo rest as an area in need of focused attention and investment. These findings are consistent with the City’s ongoing work to improve existing neighborhoods in Lake Forest, to maintain the quality of the City’s existing housing stock, suppor t current residents, and address several fair housing issues and contributing factors, including access to opportunity, displacement of residents due to economic pressures, and community opposition (see the discussion on Fair Housing Issues and Contributing Factors in Se ction 6 of the Background Report). Additionally,. the City conducts a satisfaction survey every two years. In 2021, the residents in the southw est area (Area 2) of Lake Forest were less likely than their counterparts to rank their quality of life as excellent, citing problems related to parking, traffic and noise, among other concerns such as property maintenance. The subject area is generally bounded by includes the boundaries of Muirlands Boulevard, El Toro Road, Cavanaugh Road, and Rockfield Boulevard and encompasses 169 single-family homes, 101 multi-family units and 175 businesses. A future affordable housing project, located at the corner of Raymond Way and Packer Place, will have 71 affordable housing units, including eight units that will be reserved for individuals and families who are experiencing or at-risk of homelessness. This project is currently under construction and is anticipated to be complete early 2024.

To assist the task force with the analysis of t he subject neighborhood, Communications LAB was engaged in September 2021 to conduct community outreach with stakeholders, to all residents and businesses, and perform a focused assessment of the project area, and provide a final Southwest Lake Forest Neighborhood Improvement Needs Assessment (“Needs Assessment”). The outreach included English and Spanish online survey, door-to-door canvassing, and a community pop-event event located centrally in the project area. The Needs Assessment is the resulting study document ing quality of life issues impacting the subject neighborhood and providing key recommendations for NITF review and action.

The Needs Assessment for Southwest Lake Forest included conducting an initial communications assessment and audit of the City’s existing communi cations, community ascertainment studies, and translating the collected data into actionable public policy recommendations. The Needs Assessment documents quality of life issues impacting the neigh borhood and provides key recommendations for the NITF’s review and action. At the conclusion of the evaluation team’s assessments, they identified specific issues and areas in need of improvement. These impr ovements included traffic, lighting, parking, noise, crime, issues related to homelessness, infrastructure repairs, property maintenance, disposal of bulky items, street sweeping, trash, beautification, and a need for parks within walking distance.

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In late 2021, the City’s consultant for the Neighborhood Improvement Needs Assessment prepared a draft of recommended improvements and programs based on the list of concerns identified for the project area. In January of 2022, staff will provideprov ided a presentation to the City Council as part of the City’s Strategic Plan update. This list will include the consultants recommendations and may identify specific programs from the recommended list to implement. While the exact recommendations are still under consideration, the City has committed $70,500 as part of the City’s two-year 2021-2023 Operating Budget to implement programs and improvements serving the Southwest Lake Forest neighborhood.

The City intends to continue the program by working with the community and the NITF to identify other target neighborhoods which could benefit from a Neighborhoo d Improvement Needs Assessment. The City will identify a list of recommended improvements for each target neighborhood for inclusion in the capital improvement plan (CIP) budget to address the unique needs of each of Lake Forest’s target neighborhoods.

As part of this process, the NITF will consider the cont ributing factors to fair housing issues identified in the Housing Element, the Orange County Analysis of Impediments to Fair Housing, and information from the City’s fair housing service providers. This information will be cons idered as part of the Council’s evaluation of recommended actions to ensure that those actions selected address the contributing factors identified for Lake Forest and work to affirmatively further fair housing practices in the City.

Additionally, as part of the City’s Strategic Business Plan covering Fiscal Years 2021-22 through 2027-28 (“Strategic Plan”), Strategic Plan goal #15 was set to initiate an Iinterdepartmental task force to address neighborhood concerns identified in the 2021 Community Satisfaction Survey. The City allocated $70,000 to evaluate the issues as noted in the Needs Assessme nt Study and implement improvements to the project area. The Quarterly Strategic Plan Updates are prepared by City staff and reported to the City Council. As of the January 18, 2022, the goals were incorporated and were noted to be substantially underway in that (in part):
 Lighting has been budgeted in the FY 23-25 CIP for the project area parks.  Work orders have been initiated for red curb markings to deter vehicle par king at the end of the street.
 Staff will provide community education on the per mit parking process to interested communities – scheduled summer 2022.
 Code enforcement officers have assessed the noise generated at nearby shopping centers and issued notice of violations to address early morning noise issues.  Police services have increased patrol at specific locations.  Police services staff continue to provide informat ion on etching services for catalytic converters.  Code enforcement has updated informational handouts on common property maintenance issues Item: 11
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and resources for distribution and posted on the City’s website.  Staff is workinghas worked with the Fair Hous ing Council of Orange County to update the City’s existing FAQ handout on housing rights, discrimination, and protection and to provide resources for residents and property owners.
 Implemented a bulky item pickup event in January 2022 and scheduled a second event in April 2022.

Another assessment will be performed in April.
 Regular quarterly meetings of the NITF will be hel d to coordinate, combine resources, and alleviate ongoing issues.

In conclusion, the Needs Assessment was created in response to local residents concerns and sets forth an action plan which has been funded with general fund monies. Action and implementation measures have been initiated and/or completed to date. The NITF will continue to meet quarterly and to take additional action and initiate future projects as needed. This plan has been solidified in the City’s Strategic Plan which incorporates the Needs Assessment recommendations and will further ensure achievement of the Strategic Plan goal.

Responsible Agencies: City Manager’s Office
Funding Sources: Grant Funding; General Fund
2021-2029 Objectives: Improve the Southwest Lake Forest neighborhood through implementation of the recommendations of the Neighborhood Improvement Plan.

Timeframe: Identification of improvements to implement in 2022; implementation of improvements from 2022-2023; assessment of need for future neighborhood project by January 2023.

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4 Quantified Objectives
State law requires the Housing Element to include quantified objectives for the maximum number of units that can be constructed, rehabilitated or conserved. Policies and programs in the Housing Element establish the strategies to achieve these objectives. The Ci ty’s quantified objectives are described under each program, and represent the City’s best effort in implementing each of the programs. Assumptions are based on past program performance and funding availability, construction trends, land availability, and future programs that will enhance program effectiveness and achieve full implementation of the City’s housing goals.

The new construction objectives shown in the table are based on the City’s RHNA for the 2021-2029 planning period for very low-, low- and moderate-income housi ng, historic trends, and expectations for new ADUs.

Rehabilitation and conservation objectives are based on specific program targets, including such programs as use of the City’s Housing Rehab Loan Program and Housing Choice Voucher program rental housing vouchers.

The table below summarizes the City’s quantified objectives for housing during the 2021-2029 planning period.

Table 221: Quantified Objectives 2021-2029
Income Category New Construction Rehabilitation Conservation/Preservation Extremely Low 70 324 202
(811 at-risk for conversion
during the next 10 years
and 191 not at-risk during
the next 10 years)
Very Low 70 324
Low
163 216
Moderate 167 216 29,800*--
-- Above Moderate 1,178 --
Totals 1,648 1080 811
* It is the City’s objective to promote the conservation/preservation of the City’s entire existing housing stock.

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PART 2:

BACKGROUND
REPORT
Adopted January 2, 2022
Minor Technical
Revisions June 2022
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Table of Contents

1. INTRODUCTION ........................................................................................................... 5

2. ACCOMPLISHMENTS UNDER 5TH CYCLE HOUSING ELEMENT .......................................... 7 2A. Review of 2013 Housing Element ................................................................................................... 7 2B. Housing Production During 5th Cycle RHNA Period ....................................................................... 7 2C. Appropriateness and Effectiveness of 2013 Housing Element ........................................................ 8

3. HOUSING NEEDS ASSESSMENT .................................................................................. 25 3A. Introduction and Background ......................................................................................................... 25 3B. Population Trends and Characteristics .......................................................................................... 25 3C. Household Characteristics ............................................................................................................. 29 3D. Income ............................................................................................................................................ 30 3E. Housing Characteristics ................................................................................................................. 33 3F. Housing Costs ................................................................................................................................ 37 3G. Future Housing Needs ................................................................................................................... 44 3H. Special Needs Groups ................................................................................................................... 44 3I. Units at Risk of Conversion ............................................................................................................ 56

4. CONSTRAINTS .......................................................................................................... 61 4A. Governmental Constraints ............................................................................................................. 61 4B. Non-Governmental Constraints ...................................................................................................... 98 4C. Environmental Constraints ........................................................................................................... 101 4D. Infrastructure Constraints ............................................................................................................. 102

5. HOUSING RESOURCES ............................................................................................ 105 5A. Regional Housing Needs Allocation (RHNA) ............................................................................... 105 5B. Progress Towards the RHNA ....................................................................................................... 105 5C. Residential Sites Inventory ........................................................................................................... 109 5D. Housing, Financial, and Administrative Resources...................................................................... 126 5E. Energy Conservation Opportunities ............................................................................................. 130

6. AFFIRMATIVELY FURTHERING FAIR HOUSING ............................................................ 133 6A. Outreach ....................................................................................................................................... 133 6B. Fair Housing Needs Assessment ................................................................................................. 135 6C. Sites Inventory .............................................................................................................................. 203 6D. Analysis of Contributing Factors and Fair Housing Priorities and Goals ..................................... 229

List of Tables
Table 1: Regional Housing Needs Allocation – 5th Cycle Progress ................................................................ 8 Table 2: Evaluation of the 2013 Housing Programs ........................................................................................ 9 Table 3: Population Trends – lake Forest and Neighboring Jurisdictions ..................................................... 26 Table 4: Population by Age (2018) ................................................................................................................ 26 Table 5: Race and Ethnicity (2018) ................................................................................................................ 27 Table 6: Job Growth and Employment Status ............................................................................................... 27 Table 7: Jobs by Industry (2018) ................................................................................................................... 28 Table 8: Jobs by Occupation (2018) .............................................................................................................. 28 Table 9: Travel Time to Work (2018) ............................................................................................................. 28 Table 10: Commute Method (2018) ............................................................................................................... 28 Table 11: Households by Tenure and Age (2018) ......................................................................................... 29 Table 12: Household Size by Tenure (2018) ................................................................................................. 30 Table 13: Median Household and Per Capita Income ................................................................................... 30 Item: 11
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Table 14: Household Income for All Households and by Tenure (2018) ....................................................... 31 Table 15: Households by Income Group (2017) ............................................................................................ 31 Table 16: Occupations with Wages for Extremely Low-Income Households (2020) ..................................... 32 Table 17: Housing Stock by Type and Vacancy (2020) ................................................................................. 33 Table 18: Vacancy by Type (2018) ................................................................................................................ 33 Table 19: Housing Stock Conditions (2018) .................................................................................................. 35 Table 20: Overcrowding by Tenure (2018) .................................................................................................... 36 Table 21: Household Size by Tenure (2018) ................................................................................................. 37 Table 22: Number of Bedrooms by Tenure (2018) ........................................................................................ 37 Table 23: Homes for Sale (January 2021) ..................................................................................................... 37 Table 24: Rental Costs (2018) ....................................................................................................................... 38 Table 25: Rental Rates by Number of Bedrooms .......................................................................................... 39 Table 26: State Income Limits – Orange County (2021) ............................................................................... 39 Table 27: Housing Affordability by Income Group ......................................................................................... 40 Table 28: Households by Income Level and Overpayment (2017)................................................................ 41 Table 29: Deed Restricted Affordable Housing Units .................................................................................... 43 Table 30: Regional Housing Needs Allocation – 6th Cycle ........................................................................... 44 Table 31: Senior Population and Households (2010 & 2018) ........................................................................ 46 Table 32: Householder Age by Tenure (2018) ............................................................................................... 46 Table 33: Disabilities by Disability Type (2018) ............................................................................................. 48 Table 34: Disabled Persons by Employment Status (2018) .......................................................................... 48 Table 35: Developmentally Disabled Persons by Residence Type (2018) .................................................... 49 Table 36: Median Income by Household Size (2018) .................................................................................... 50 Table 37: Household Size Versus Bedroom Size by Tenure (2018) ............................................................. 51 Table 38: Families and Female Householder with Children Under 18 (2018) ............................................... 51 Table 39: Homeless Facilities (2019)* ........................................................................................................... 55 Table 40: Summary of At-Risk Subsidized Housing Units ............................................................................. 57 Table 41: Summary of Needs ........................................................................................................................ 60 Table 42: General Plan Residential Land Use Designations ......................................................................... 63 Table 43: Residential Zoning Districts from Zoning Code ............................................................................. 65 Table 44: Baker Ranch Planned Community ................................................................................................. 66 Table 45: El Toro Planned Community .......................................................................................................... 67 Table 46: Foothill Ranch Planned Community............................................................................................... 68 Table 47: Lake Forest Planned Community ................................................................................................... 69 Table 48: Nakase Planned Community ......................................................................................................... 70 Table 49: Portola Hills Planned Community .................................................................................................. 71 Table 50: Rancho De Los Alisos Planned Community .................................................................................. 72 Table 51: Rancho Serrano Planned Community ........................................................................................... 73 Table 52: Serrano Highlands Planned Community ........................................................................................ 74 Table 53: Permitted Residential Uses by Zone.............................................................................................. 77 Table 54: ADU and JADU Development Standards ...................................................................................... 80 Table 55: Residential Parking Requirements ................................................................................................. 85 Table 56: Typical Permit Processing Times and Reviewing Body................................................................. 90 Table 57: Planning and Development Fees (Effective 08/16/2021) .............................................................. 95 Table 58: Proportion of Fee in Overall Development Cost for a Typical Residential Development (2021) ... 97 Table 59: Road Improvement Standards ....................................................................................................... 97 Table 60: Comparison of Zoned and Built Densities ................................................................................... 100 Table 61: RHNA 2021-2029 ......................................................................................................................... 105 Table 62: Credits Towards the RHNA .......................................................................................................... 106 Table 63: Remaining 6th Cycle RHNA ......................................................................................................... 109 Table 64: Capacity Adjustment Factors – Mixed-Use Zones ....................................................................... 119 Item: 11
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Table 65: Summary of Residential development POTENITAL on General Vacant Sites ............................ 123 Table 66: Summary of Residential DEVELOPMENT POTENTIAL on Underutilized Mixed-Use Sites ....... 124 Table 67: Comparison of RHNA Candidate Sites Realistic Capacity and RHNA ........................................ 126 Table 68: Compliance with Fair Housing Laws ............................................................................................ 139 Table 69: Regional Opportunity Index (ROI) Data Points ............................................................................ 177 Table 70: Opportunity Indicators by Race.Ethnicity - Lake Forest............................................................... 178 Table 71: Regional Opportunity Index (ROI) Data Points ............................................................................ 179 Table 72: Place-Based Regional Opportunity Index (ROI) Low Opportunity Census Tracts ...................... 180 Table 73: Lake Forest Opportunity Resource Levels by Census Tracts ..................................................... 191 Table 74: Low Resource Census Tract Analysis ......................................................................................... 192 Table 75: Citywide Opportunity Index Values .............................................................................................. 192 Table 76: Demographics of Households with Disproportionate Housing Needs ......................................... 193 Table 77: Fair Housing Issues and Contributing Factors ............................................................................. 229

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List of Figures
Figure 1: Median Home Sales Price .............................................................................................................. 38 Figure 2: 2021-2029 Housing Element Site Inventory ................................................................................. 121 Figure 3: Census Track Boundaries, Lake Forest ....................................................................................... 145 Figure 4: Dissimilarity Index ......................................................................................................................... 149 Figure 5: Diversity Index by Census Block Group, City of Lake Forest ....................................................... 153 Figure 6: Diversity Index by Census Block Group, Countywide .................................................................. 155 Figure 7: Proportion of Population with Disability by Census Tract, City of Lake Forest............................. 157 Figure 8: Proportion of Population with Disabilities by Census Tract, Countywide ..................................... 159 Figure 9: Female-Headed Households by Proportion of Children Present, City of Lake Forest ................. 161 Figure 10: Female-Headed Households by Proportion of Children Present, Countywide .......................... 163 Figure 11: Proportion of Senior Residens by Census tract, City of Lake Forest ......................................... 165 Figure 12: Proportion of Senior Residents by Census Tract, Countywide .................................................. 167 Figure 13: Median Household Income by Block Group, City of Lake Forest ............................................... 169 Figure 14: Median Household Income by Block Group, Countywide .......................................................... 171 Figure 15: Ethnicity Analysis – Racial Concentrations, City of Lake Forest ................................................ 173 Figure 16: Ethnicity Analysis – Racial Concentrations, Countywide............................................................ 175 Figure 17: People-Based Opportunity by Census Tract, City of Lake Forest .............................................. 183 Figure 18: People-Based Opportunities by Census Tract, Countywide ...................................................... 185 Figure 19: Place-Based Opportunities by Census Tract, City of Lake Forest ............................................. 187 Figure 20: Place-Based Opportunities by Census Tract, Countywide ......................................................... 189 Figure 21: TCAC/HCD Opportunity Area Map, City of Lake Forest ............................................................. 199 Figure 22: TCAC/HCD Opportunity Area Map, Countywide ........................................................................ 201 Figure 23: Cost-Burdened Renter Households by Census Tract, City of Lake Forest ................................ 203 Figure 24: Cost-Burdened Renter Households by Census Tract, Countywide ........................................... 205 Figure 25: Cost-Burdened Owner Households by Census Tract, City of Lake Forest ................................ 207 Figure 26: Cost-Burdened Owner Households by Census Tract, Countywide ............................................ 209 Figure 27: Overcrowded Households by Census Tract ............................................................................... 211 Figure 28: Overcrowded Households by Census Tract, Countywide .......................................................... 213 Figure 29: Sensitive Communities ............................................................................................................... 215

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1. Introduction

The City of Lake Forest is located in southern Orange County, nestled within Saddleback Valley, southwest of the Santa Ana Mountains. Lake Forest is bordered by the cities of Irvine and Mission Viejo, and is within 7 miles (northeast) of the Pacific Ocean. Interstate 5, 405 Freeway, and California State Route 241 provide regional access. Lake Forest has a population of 84,711 (Department of Finance, 2020) and is approximately

16.6 square miles in size. The City incorporated in 1991 and expanded its city limits in 2000 to include the master planned developments of Foothill Ranch and Portola Hills. Although Lake Forest is a relatively new city, the community has a rich history dating back to the mid-1800s.

Lake Forest has the feel of a small community, but with the amenities of a large city. The City provides a diverse range of employment, lifestyle, and housing opportunities, all complemented by the surrounding natural environment. As such, the community has become a desirable place to live, offering lake-front homes, condominiums, town homes, mobile home parks, retirement communities, and affordable housing. Lake Forest’s family-oriented atmosphere is especially appealing to those with younger children. The City is served by quality public schools for grades K-12, several preschools, and private elementary schools.

State Housing Law (Government Code Section 65583) stat es that a “housing element shall consist of an identification and analysis of existing and projected hou sing needs and a statement of goals, policies, quantified objectives, financial resources, and scheduled programs for t he preservation, improvement, and development of housing. The housing element shall ident ify adequate sites for housing, including rental housing, factory-built housing, and mobile homes, and shall make adequate provision for the existing and projected needs of all economic segments of the co mmunity.” This Background Report is an update of the City’s 2013 Housing Element (5
th Cycle), adopted in January 2014.

The assessment and inventory must include all of the following:
 Analysis of population and employ ment trends, documentation of projections, and a quantification of the locality’s existing and projected housing needs for all income levels. Such existing and projected needs shall include the locality’s share of the r egional housing need in accordance with Section 65584 of the Government Code.
 Analysis and documentation of household characteri stics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition.  An inventory of land suitable for residential development, including vacant sites and sites having potential for redevelopment, and an analysis of the relationship between zoning, public facilities, and city services to these sites.
 Analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels and fo r persons with disabilities, including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, local processing and permit proc edures, and any locally adopted ordinances that directly impact the cost and supply of residential development.  Analysis of potential and actual non-governmental constraints upon the maintenance, improvement, or development of housing for all income levels, in cluding the availability of financing, the price of land, the cost of construction, requests to develop housing at densities below the minimum densities in the inventory of sites, and the length of time between receiving approval for a housing development and submittal of an application for building permits t hat hinder the construction of a locality’s share of the regional housing need.

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 Analysis of any special housing needs, such as those of the elderl y, disabled (including developmentally disabled), large families, farmwork ers, families with female heads of households, and families and persons in need of emergency shelter.
 Analysis of opportunities for energy conserva tion with respect to residential development.  Analysis of existing assisted multifamily rental housing developments t hat are eligible to change from low-income housing to market-rate during the next 10 years.

The Background Report of this Housing Element identifies the nature and extent of Lake Forest’s housing needs, including those of special populations, pot ential housing resources (land and funds), potential constraints to housing production, and energy conservati on opportunities. By examining the City’s housing needs, resources, and constraints, the City can deter mine a plan of action for providing adequate housing.

This plan is presented in the Housing Plan, which is the policy component of the Housing Element. In addition to identifying housing needs, this Background Report also presents information regarding the setting in which these needs occur. This informati on is instrumental in providing a better understanding of the community, which in turn is essential for the planning of future housing needs.

Since the update of the City’s prior Housing Element in 2014, statutory changes have occurred that must be included in the 2021-2029 Lake Forest Housing Element. These laws have been incorporated in the appropriate sections throughout this Background Report as well as in its accompanying Policy Document.

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2. Accomplishments Under 5th Cycle Housing Element

The following section reviews and evaluates the City’s progress in implementing the 2013 Housing Element.

It reviews the results and effectiveness of programs, policies, and objectives from the previous Housing Element planning period, which covered 2013 through 2021. This section also analyzes the difference between projected housing need and actual housing production. 2A. Review of 2013 Housing Element
The 2013 Housing Element program strategy focused on the implementation of policies and programs to ensure adequate housing sites, encourage the production of new housing, including affordable and special needs housing, encourage the maintenance and preservation of existing housing, remove various constraints to housing, including housing for special needs populations, and encourage fair housing and non- discrimination. The 2013 Housing Element identified the following goals:

ISSUE 1 – HOUSING DIVERSITY AND OPPORTUNITIES
GOAL 1.0: Adequate housing to meet the existing and future needs of Lake Forest residents.

ISSUE 2 – MAINTENANCE, PRESERVATION, AND CONSERVATION OF HOUSING GOAL 2.0: Maintenance and enhancement of the quality of existing residential neighborhoods.

ISSUE 3 – HOME OWNERSHIP
GOAL 3.0: Increased opportunities for home ownership.

ISSUE 4 – EQUAL OPPORTUNITY
GOAL 4.0: Promote equal opportunity for all residents to reside in housing of their choice. 2B. Housing Production During 5th Cycle RHNA Period
The City’s 5
th Cycle Housing Element specifically address ed housing needs for Lake Forest from October 15, 2013 through October 15, 2021, in line with the Regional Housing Needs Assessment (RHNA) planning period adopted by the Southern California Associati on of Governments (SCAG). It should be noted that although the planning period was from October 15, 2013 through October 15, 2021, the RHNA period (identified by HCD for purposes of projecting housing needs and establishing the City’s RHNA allocation), actually began on January 1, 2014.

Table 1 shows the total number of building permits issued by the City during the 5 th RHNA Cycle based on the City’s 2020 Housing Element Annual Progress Report and compares this number with the units required to be accommodated pursuant to the City’s RHNA alloca tion. Housing development in the City increased significantly since the 4 th Cycle, with the City exceeding its over all RHNA allocation by almost 1,000 units (Note: Although the total number of units permitted exceeded the total RHNA allocation, the new units were largely in the above-moderate income category, as shown in Table 1).

During the 2013-2021 RHNA period, the City issued 3,650 building permits; this included 32 deed-restricted very low-income units, 25 deed-restricted low-income units, 205 market-rate units affordable to moderate- income households, and 3,388 units affordable to above moderate-income households.

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TABLE 1: REGIONAL HOUSING NEEDS ALLOCATION – 5TH CYCLE PROGRESS Status Very Low Low Moderate Above
Moderate TOTAL
RHNA Allocation 647 450 497 1,133 2,727
Permits Issued 32 25 205 3,388 3,650
Remaining Allocation 615 425 292 0 1,332
Sources: City of Lake Forest 2013 Housing Element; 2020 General Plan Annual Progress Report 2C. Appropriateness and Effectiveness of 2013 Housing Element While the majority of goals, policies, and programs included in the 2013 Housing Element continue to be appropriate to address the City’s housing needs, the Housing Plan has been updated to provide clearer guidance to encourage affordable and special needs housing production. The Housing Plan was also updated to streamline programs and facilitate implementation, and to include a matrix that makes it easier to identify the applicability and timing of programs. In order to facilitate implementation of the Housing Plan and tracking of programs, the housing programs are presented in a user-friendly table.

As part of its Housing Element update effort, the City carefully evaluated the effectiveness of its existing housing programs, as discussed in Table 2. Based on this evaluation and community input, the City has found that most of the housing programs in the 2013 Housing Element have been effective and will be included in the 2040 Housing Plan, with revisions to addr ess specific housing needs, constraints, or other concerns identified as part of this update, and to affi rmatively further fair housing. The City implemented many of the housing programs in prior years and anti cipates that the revisions included in the Housing Program will further encourage affordable and special needs housing production.

Since adoption of the prior Housing Element in 2014, the City has used CDBG funds for housing rehabilitation programs, and to provide fair housing services and services to special needs and at-risk populations (homeless, persons at risk of homelessness).

Due to the limited amount of funds available on an annual basis to substantially subsidize a rental or ownership housing development, it can require several years of accrued funds to assist a single project.

Nonetheless, the City partnered with an affordable housing developer during the planning period (2020) to develop an affordable housing project (scheduled to break ground in 2021).

The Housing Plan included in this 2021-2029 Housing Element includes modifications to make programs more effective, clarify objectives, and ensure that the programs are implementable. See the Housing Plan for the goals, policies, and programs of this Housing Element.

While the City took several significant steps to promote housing during the prior planning period, the experience of Lake Forest and other communities throughout the state demonstrates th at it is very difficult for local governments to meet their fair share housing goals for lower and moderate-income housing (i.e., the RHNA allocation). All cities, including Lake Forest, have limited financial and staffing resources and require substantial state and/or federal assistance, which has not been available at the levels necessary to support the City’s housing needs, or for-profit and non-profit housing developers and agencies. As discussed below, the City has evaluated the success of existing progra ms to support the development of affordable housing, and has added new programs to the Housing Plan to address this objective. .

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TABLE 2: EVALUATION OF THE 2013 HOUSING PROGRAMS
Program Accomplishments

PROVISION OF ADEQUATE HOUSING SITES TO ACHIEVE A VARIETY OF HOUSING TYPES AND

DENSITIES
Program 1: Land Use Policy, Entitlements, and
Development Capacity: Planning and regulatory
actions to achieve adequate housing sites are
implemented through the Land Use Element,
Zoning Code, and implementation of existing
development agreements. These regulatory
documents provide for a variety of residential
types, ranging from lower-density single-family
homes to higher-density apartments,
condominiums, and mixed-use development.

Lake Forest’s residential sites inventory consists
of over 600 acres of developable land with the
capacity to yield nearly 3,900 new units during the
planning period. As noted in Section III, these
sites are adequate to meet the City's share of
regional housing needs for the 2013-2021 RHNA
period.

Program Objectives:
 Maintain and monitor the residential sites
inventory to ensure adequate sites remain
to accommodate the RHNA throughout
the RHNA period. Receive and process
development applications for projects
within the New Neighborhoods.

Result/Evaluation: Program considered successful. The
City has maintained an inventory of residential sites and has adequate capacity to accommodate its RHNA.

However, changing circumstances will necessitate program modifications.

The City prepares a General Plan Annual Progress Report (“APR”) annually, to monitor progress towards its RHNA
allocation. The 2020 APR reported that 3,650 dwelling units were permitted during the 2013-2021 planning period.

Continue/Modify/Delete: Modify. This program provides
relevant information to ensure the City is able to
accommodate its RHNA allocation. However, given the
increase in the City’s RHNA allocation from 2,727 units (5 th
Cycle) to 3,228 units (6th Cycle), a more robust program will be implemented that includes the following:
 Monitor and report housing production annually
and revise development standards as necessary.
 Promote the constructi on of accessory dwelling
units (“ADUs”) by ensuring that ADUs are
permitted by-right if they comply with Section

9.146.050 of the LFMC and State law, and
continuing to streamline ADU approvals.
 Inform developers of sites appropriate for multi-
family and special-needs housing.

Program 2: Monitor Residential Capacity (No
Net Loss): Monitor the consumption of residential
acreage to ensure an adequate inventory is
available to meet the City’s RHNA obligations. To
ensure sufficient residential capacity is maintained
to accommodate the RHNA, the City will develop
and implement a formal ongoing (project-by-
project) evaluation procedure pursuant to
Government Code Section 65863. Should an
approval of development result in a reduction of
capacity below the residential capacity needed to
accommodate the remaining need for lower
income households, the City will identify and, if
necessary, rezone sufficient sites to accommodate
the shortfall and ensure “no net loss” in capacity to
accommodate the RHNA.

Program Objectives:
 Develop and implement a formal
evaluation procedure pursuant to
Government Code Section 65863 by
Result/Evaluation: The City has developed a project-
based annual monitoring and tracking tool to ensure that adequate inventory is available to meet the City’s RHNA obligations.

Continue/Modify/Delete: Continue. This program
continues to be appropriate and is included in the 2021- 2029 Housing Element.

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Program Accomplishments
January 1, 2014.

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Program 3: Facilitate Affordable Housing
Production: Affordable housing developments
face a number of hurdles, including financing,
development codes and standards, and in some
cases, public opposition. Dissolution of the City’s
Redevelopment Agency by the State in 2012
eliminated the Low and Moderate Income Housing
Fund (LMIHF), formerly the City’s primary
mechanism for providing direct funding support of
affordable housing development. Continuing
reductions in federal funding of HUD programs
(e.g., CDBG) will constrain the City’s ability to offer committed funding assistance to future affordable
housing even further. The City can encourage and
facilitate affordable housing through financial
assistance, removal of regulatory constraints, and
administrative support. With limited funding, the
City will rely on the following actions to encourage
affordable housing production during the planning
period:
 Affordable Housing Implementation Plans
(AHIPs):
 Collaborate with Affordable Housing
Developers
 Regulatory Concessions and Incentive:

Program Objectives:
 Maintain contact information for affordable
housing developers for the purposes of
soliciting their involvement in development
projects in Lake Forest. Participate with
affordable housing developers to review
available federal and State financing
subsidies and apply as feasible on an
annual basis. Assist and support
developers of housing for lower-income
households, especially housing for
extremely low-income households, with
site identification, supporting applications,
conducting pre-application meetings,
assisting with design and site
requirements, and providing State-
mandated regulatory incentives and
concessions. Monitor and enforce AHIP
provisions and collaborate with developers
of affordable housing over the planning
period to facilitate the construction of 250
affordable units over the planning period
(10 extremely low-income, 40 very low-
income, and 200 low-income units).

Result/Evaluation: Program considered successful. The
City entered into an Exclusive Negotiation Agreement with National Community Renaissance (“National CORE”) in
2017 for an affordable housing development. Project
financing combines the City’s $3.7 million in affordable housing developer in-lieu fees with tax credits, debt
financing, loans, and other available financial sources.

National CORE submitted an application for a 71-unit
project on 3.97 acres in December 2019. The project
includes 70 units affordable to households earning less than 60% of the Area Median Income, with 12 units set
aside for Permanent Supportive Housing, and 1 caretaker’s unit. The project was approved on August 18, 2020 and
construction is expected to begin in 2021.

The City continues to monitor and enforce approved AHIPs and affordable housing covenants, and maintains a
qualified staff ready and willing to assist affordable housing developers with site identification, regulatory compliance and fast-track application processing.

Continue/Modify/Delete: Continue. This program
continues to be appropriate and is included in the 2021- 2029 Housing Element.

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REMOVAL OF GOVERNMENTAL CONSTRAINTS
Program 4: Farm Employee Housing: The City’s
Zoning Code includes two districts that allow
agricultural uses (A-1 and OS). Commercial
agriculture is permitted by right in the A1 zone and
with approval of a Site Development Permit in the
OS zone. Pursuant to the California Employee
Housing Act, facilities with up to 36 beds or 12
units to board farm workers must be treated as
accessory or incidental to agriculture operations.

State law also provides that employee housing
occupied by six (6) or fewer employees in a single
family structure, shall be treated the same as a
family dwelling of the same type in the same zone.

The City will evaluate provisions for commercial
agriculture operations in the A-1 and OS zones
(and the related farm worker housing issues) and
revise the Zoning Code to address compliance
with Sections 17021.5 and 17021.6 of the Health
and Safety Code.

Program Objectives:
 Review and revise the Zoning Code to
address compliance with Health and
Safety Code Sections 17021.5 and
17021.6.

Result/Evaluation: Program considered successful. Zone
Change 12-14-4673 was approved on June 16, 2015,
which added a definition for “agricultural employee
quarters” as well as allowing such housing by right within the City’s Agricultural and Open Space zones.

Continue/Modify/Delete: Delete. Program no longer
necessary and is not included in the 2021-2029 Housing
Element.

Program 5: Monitor Changes in Federal and
State Housing, Planning, and Zoning Laws:

Although the 2013 Housing Element update did
not identify any significant governmental
constraints to the development or maintenance of
housing in Lake Forest, the City will continue to
monitor its development process and zoning
regulations to identify and remove constraints to
the development of housing. The City will also
continue to monitor federal and State legislation
that could impact housing and comment on,
support, or oppose proposed changes or additions
to existing legislation, as well as support new
legislation when appropriate. Special attention will
be given by the City in the minimizing of
governmental constraints to the development,
improvement, and maintenance of housing.

Program Objectives:
 Monitor State and federal legislation as
well as City development process and
zoning regulations to identify and remove
housing constraints.

Result/Evaluation: Program considered successful. City
staff and the City Attorney’s office regularly monitor
legislation changes and update zoning regulations
accordingly.

Continue/Modify/Delete: Continue. This program
continues to be appropriate and is included in the 2021- 2029 Housing Element.

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HOUSING AND SUPPORTIVE SERVICES FOR SPECIAL NEEDS POPULATIONS Program 6: Sites for Homeless Shelters:

Homelessness is a chronic problem throughout
Southern California. While the majority of the
County’s homeless are in the older, more
urbanized jurisdictions and in the beach
communities, current data indicates approximately
25 homeless persons within the City on any given
night. In addition, the City has numerous
households who may be considered at-risk of
becoming homeless by virtue of their limited
incomes. It is important for the City to provide and
maintain the appropriate zoning mechanisms to
accommodate the provision of facilities that serve
the homeless population, most of whom are
extremely-low-incomes.

Program Objectives:
 Provide financial support to non-profit
organizations that shelter the homeless
(subject to available funding and on a
case-by-case basis). Assist non-profit
organizations identify potential sites for
homeless shelters. Continue staff
participation in the Commission to End
Homelessness and support of a Homeless
Liaison within the Police Services
Department.

Result/Evaluation: Program considered successful.

Although no opportunities to assist non-profits to locate a homeless shelter were identified during the planning period, the City continued its contract with Mercy House, a non- profit service provider specializing in assisting the
homeless. Mercy House conducts field outreach and case
management work five days per week. The services include mental and physical health assessments and connection of homeless individuals to various services. As part of the contract, Mercy House works with shelter and housing
partners to find suitable temporary or long-term housing for the homeless. In addition, the City provided funding for a Homeless Liaison Officer position through its law
enforcement services contract with the Orange County
Sheriff’s Department. The City also provided pass-through CDBG funding annually to local non-profits, including
Families Forward, Family Assistance Ministries and South County outreach, that provide food banks, rental
assistance, counseling and other forms of assistance to individuals and families at risk of becoming homeless.

Continue/Modify/Delete: Continue. This program
continues to be appropriate and is included in the 2021- 2029 Housing Element.

Program 7: Transitional and Supportive
Housing: The City provided financial assistance
to non-profit service agencies to purchase existing
housing in the community for use as transitional
and supportive housing. These facilities help to
address the needs of very low and extremely low
income persons. Specifically, the City has
provided CDBG funding to non-profit organizations
for the purchase and operation of condominium
units for transitional/supportive and affordable
housing. These condominiums will continue to
offer transitional/supportive and affordable
housing to extremely low income residents
through 2022–2030.

Through the City’s partnership with Families
Forward, supportive services are provided to
residents that include weekly case management
counseling, weekly budget and financial
counseling, child care assistance to attend
counseling, education supplies assistance,
employment supplies and tools assistance, health
care payment assistance, permanent housing
Result/Evaluation: Program considered successful. During the 2019-20 fiscal year, for example, the City assisted 4,314 individuals through CDBG sub-recipient funding of nine non-profit organizations that provide services to
homeless, low and moderate-income persons, including:
case management and in-home support services for home-
bound seniors; adult daycare and ancillary services for seniors and adults with Alzheimer’s, other forms of
dementia, and disabilities; reduced cost medical and
pediatric dental services for low- and moderate-income
persons; fair housing counseling/advocacy and referral
services; transitional housing, support services, and case management for homeless families; rental assistance to
help prevent eviction/homelessness; food bank and case
management services for lower-income individuals,
individuals at risk of homelessness, and homeless
individuals (funds also used to prevent evictions and utility shut-off); job training and job development services for adults with developmental disabilities; and motel and
transportation vouchers for homeless individuals. The total expenditure for this activity was $73,245. Comparable
assistance was provided in each preceding year of the
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placement assistance, legal assistance (as
available), life-skills training, weekly children’s
program that addresses self-esteem, social skills,
coping skills, values and beliefs, peer pressure,
anger management, self-care, and identifying
social networks.

Program Objectives:
 Provide financial support to non-profit
organizations that provide
transitional/supportive housing for
homeless (subject to available funding
and on a case-by-case basis).
provided $40,000-$50,000 annually in homeless services
contracts.

Continue/Modify/Delete: Continue. This program
continues to be appropriate and is included in the 2021- 2029 Housing Element.

Program 8: Coordination with Social Service
Agencies: A variety of social services agencies
provide housing and supportive services to special
needs groups in Lake Forest. Several of these
social service agencies receive CDBG funds from
the City to help administer these programs. The
City determines its CDBG allocations to social
service agencies annually based upon
applications received, whether the agency
provides a priority need in the City’s 5-year
Consolidated Plan, and if the agency meets
Federal HUD regulations. In a typical program
year, funding is allocated to nonprofits that serve
the following needs of lower income individuals
and households (i.e., those earning up to 80%
AMI): food distribution, housing assistance,
services and programs for the elderly and youth,
before and after school care programs, services
for the disabled (including developmentally
disabled), primary health care services, and fair
housing advocacy and counseling.

Similar to the Housing Element update, the
Consolidated Plan involves comprehensive
outreach, citizen participation workshops, and
assessment of community needs to develop a
road map for programs and activities to be
pursued in the ensuing five years. The variety of
social service agencies that may be awarded
CDBG are guided by priority needs articulated in
the Consolidated Plan. All CDBG-contracted and
funded programs (emergency housing/shelter,
food distribution, primary health care services to
the indigent or non-insured, senior case-
management services and home-delivered meals,
and before-and-after school youth programs for
lower income families) address and assist the
needs of lower income persons and households of
Result/Evaluation: Program considered successful. In
Fiscal Year 2019-2020, for example, nine non-profit social services agencies received pass-through CDBG funding
from the City to provide support and assistance to
residents. In addition, two non-profit social services
agencies received direct funding from the City to support homeless outreach services. Comparable assistance was
provided in each preceding year of the program.

Continue/Modify/Delete: Continue. This program
continues to be appropriate and is included in the 2021- 2029 Housing Element.

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our community.

Program Objectives:
 Continue to evaluate on an annual basis
allocation of CDBG Funds to social
service agencies to benefit Lake Forest
residents.

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CONSERVE THE EXISTING SUPPLY OF AFFORDABLE HOUSING
Program 9: Rental Assistance: The Housing
Choice Voucher rental assistance program
extends rental subsidies to extremely low and very
low income families and elderly (i.e., those earning
up to 50% AMI) who spend more than 30% of their
income on rent. The subsidy represents the
difference between the excess of 30% of their
monthly income and the actual rent. Rent
subsidies can be used to pay for mobile home
park space rents. Lake Forest contracts with the
Orange County Housing Authority (OCHA) to
administer the Federal Housing Choice Voucher
Program. According to OCHA, approximately 194
Lake Forest resident households received voucher
assistance as of March 2013, with another 809
applicants on the waiting list.

Program Objectives:
 Continue to contract with the OCHA to
administer the Housing Choice Vouchers
Program with the goal of assisting an
average of approximately 190 extremely
low and very low income households
annually during the planning period.

Promote the Housing Choice Vouchers
program on City website. Support the
OCHA’s applications for additional
voucher allocations and efforts to maintain
and expand voucher use in the City.

Result/Evaluation: Program considered successful.

Residents continue to be assist ed by the Housing Choice Voucher program, which is a HUD Section 8 program that is administered by the Orange County Housing Authority. On average, 190 very low-income households received voucher assistance annually during the planning period.

Continue/Modify/Delete: Continue. This program
continues to be appropriate and is included in the 2021- 2029 Housing Element.

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Program 10: Conservation of Existing and
Future Affordable Units: In order to meet the
housing needs of all economic groups in Lake
Forest, the City must develop programs to
minimize the loss of housing units available to
lower income households. As of April 2013, the
City’s affordable housing inventory consisted of
264 units with at least another 250 affordable units
anticipated during the planning period. Of the
existing 264 affordable units, 255 were at risk of
converting to market rate rents. Of the at-risk
units, 209 are only considered “at risk” because
owners that have the option to could pre-pay bond
funding before 2023. Affordability covenants for 38
units in the Crestwood Apartments expire in 2017,
6 units at Bellecour Way could convert to market
rate in 2018, and 2 transitional housing units
become “at risk” in 2022 and 2023.

Program Objectives: The City will work with
property owners, interest groups and the State
and federal governments to implement the
following programs on an ongoing basis to
conserve its affordable housing stock:
 Monitor Units at Risk: Maintain contact
with providers and owners to monitor the
status of existing and future affordable
units, including the 255 at-risk units.
 Work with Owners: Provide technical
assistance to owners of properties with at-
risk units by identifying funding sources
and supporting grant or tax credit
applications for the extension of
affordability covenants.
 Work with Potential Purchasers: Where
feasible, provide technical assistance to
public and non-profit agencies interested
in purchasing and/or managing properties
that include units at risk.
 Tenant Education: The California
Legislature extended the noticing
requirement of at-risk units opting out of
low income use restrictions to one year.

Should a property owner pursue
conversion of the units to market rate, the
City will ensure that tenants were properly
noticed and informed of their rights and
that they are eligible to receive Section 8
vouchers that would enable them to stay
in their units.

Result/Evaluation: Program considered partially
successful. As of 2020, a total of 202 affordable units were available in the City. Of these, 11 were designated “at risk”.

The City actively monitors these units. Should a notice of intent to convert to market rate units be filed, the City will work with potential purchasers to preserve the units and ensure that tenants are properly notified of their rights under California law.

During the prior planning period, five apartment complexes that received bond funding from the County that included affordability covenants for 30 years, with an option to pre- pay bond funding beginning in 2013, converted to fully
market-rate complexes. Additionally, six affordable units developed under an agreement with the City’s former
Redevelopment Agency also converted to market rate units at the end of their affordability term. New affordable units were added to the City’s housing stock, including Arroyo at Baker Ranch (187 affordable units) and Saguaro
Apartments (4 affordable units).

Continue/Modify/Delete: Continue. This program
continues to be appropriate and is included in the 2021- 2029 Housing Element with modifications.

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REHABILITATE THE CITY'S EXISTING SINGLE-FAMILY AND MULTI-FAMILY HOUSING STOCK Program 11: Housing Rehabilitation Loan
Program: The City provides housing rehabilitation
assistance to lower income homeowners through
a loan program for owner-occupied single-family
detached and attached homes and mobile home
units, which is funded through the City’s CDBG
program. A zero-interest deferred payment loan of
up to $30,000 is available to households earning
up to 80% AMI. A 3% interest loan amortized for a
15 year period is available to those who wish to
pay off their loan sooner. Loans of up to $15,000
are also available to owners of mobile homes.

Eligible repairs include roofing, windows, exterior
and interior painting, plumbing, electrical,
energy/weatherization, garage doors, and other
common home repairs, as well as accessibility
improvements. Since the City has its own
rehabilitation program, City residents are no
longer eligible to participate in County-sponsored
rehabilitation programs.

The City promotes its owner-occupied Housing
Rehabilitation Loan Program on a year-round
basis on its website and in the City’s quarterly
newsletter. The loan program is only available for
owner-occupied homes, townhomes and mobile
homes.

Program Objectives:
 Assist 10 lower income homeowners
annually.

Result/Evaluation: Program considered successful. The
City's Housing Rehabilitation Program offers a zero percent deferred interest loan and a three percent amortized
interest loan for homes, condominiums, and mobile homes.

As an example, during the 2019-2020 fiscal year, 11
income-qualified homeowners participated in and
completed needed repairs and improvements to their
homes (e.g., roofing, plumbing, electrical, and flooring) through the City’s Housing Rehabilitation Loan Program.

Total allocation for this program during FY 2019-20 was $273,690.

Continue/Modify/Delete: Continue. This program
continues to be appropriate and is included in the 2021- 2029 Housing Element.

Program 12: Code Enforcement and
Neighborhood Preservation: The Code
Enforcement and Neighborhood Preservation
program implements a comprehensive approach
to neighborhood improvement in ten targeted
Neighborhood Preservation Areas. Code
enforcement officers respond to complaints
related to substandard housing, property
maintenance, overgrown vegetation, trash and
debris, illegal conversions, improper occupancy
and other nuisance and zoning complaints. In the
past, the City has allocated CDBG funds to
sponsor periodic neighborhood clean-up and paint
days. As funding permits, the City will consider
sponsoring similar neighborhood preservation and
revitalization events during the planning period.

Code enforcement staff will also continue to inform
eligible owners about the City’s rehabilitation
program (see Program 11).

Result/Evaluation: Program considered successful. The
City continues to provide code enforcement activities with the goal of the Code Enforcement and Neighborhood
Preservation Program being to address housing and
property concerns before they become serious problems. In addition to inspections in target areas, code enforcement officers continue to inform property owners of rehabilitation opportunities. The Neighborhood Pride Paint Program
provides grant funding assistance to qualified low- and moderate-income homeowners for the purpose of painting
the exterior of their homes. The program is part of broader effort to maintain and improve the character, aesthetic quality and property values within the community. This
program is funded on an annual basis, subject to the
availability of Federal Community Development Block Grant (CDBG) funds and City Council authorization.

The City allocated $25,370 of CDBG grant funding for the Neighborhood Pride Paint Program in FY 2019-20. In FY
2019-20, five homes were professionally prepped and
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Program Objectives:
 Continue to implement the applicable
sections of the Lake Forest Municipal
Code, including the California Building
Code.
painted with program assistance. The program contributes to the City’s efforts to enhance the appearance of homes in the community and preserve property values. For Fiscal
Year 2020-2021, a significant portion of the City's
Community Development Block Grant (CDBG) funding was
allocated to assist Lake Forest's residents and small-
businesses with preparing, preventing and responding to the COVID-19 pandemic.

Continue/Modify/Delete: Continue. This program
continues to be appropriate and is included in the 2021- 2029 Housing Element.

PROVIDE HOUSING OPPORTUNITIES FOR FIRST-TIME HOMEBUYERS Program 13: Homebuyer Assistance
Programs: A few resources are available to Lake
Forest residents. The Mortgage Credit Certificate
(MCC) Program, administered by the County of
Orange, enables lower and moderate income first-
time homebuyers to receive a federal income tax
credit of up to 15% of the annual mortgage
interest paid. The MCC reduces federal income
tax, increases takehome pay, and increases the
qualifying loan amount for homebuyers. Program
assistance is available only to income-eligible
persons and families who have not owned a home
in the last three years. The property must be a
single-family detached home, condominium, or
townhouse.

The Southern California Housing Finance Agency
(SCHFA) raises funds for mortgage financing
through the sale of tax-exempt revenue bonds.

The City cooperates with lenders and the County
in advertising the availability of the SCHFA
program.

Program Objectives:
 Continue to promote the MCC and
SCHFA programs by notifying eligible
applicants to County programs and
providing information on the City’s website
with the goal of assisting five households
to achieve home ownership annually
during the planning period.

Result/Evaluation: Program considered successful. The
City continues to promote and refer individuals to the MCC and SCHFA programs, although the number of
homeownership opportunities through these programs may
have been limited due to the high cost of homes in Orange County. Nonetheless, the City is optimistic that the
increased attention to affordable housing needs at the state level will result in an increase in state-funded programs to assist jurisdictions in providing homebuyer assistance for low- and moderate-income households.

Although the MCC program currently applies only to census tracts outside of Lake Forest, the City will continue to monitor the program for any future applicability to Lake Forest households. Pursuant to a cooperation agreement
with the Lake Forest Housing Authority, persons interested in the Housing Choice Voucher Program (formerly Section 8) are referred to the Orange County Housing Authority.

The County of Orange offers a homeownership program
whereby participants may be able to use housing
assistance subsidies for mortgage payments. The County
also maintains an affordable housing rental list, which contains contact information for affordable rentals
throughout the County. Information is provided on the City’s website.

Continue/Modify/Delete: Continue. This program
continues to be appropriate and is included in the 2021- 2029 Housing Element.

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EQUAL HOUSING OPPORTUNITY
Program 14: Fair Housing Services: Lake
Forest currently contracts with the Fair Housing
Council of Orange County (FHCOC) for the
provision of fair housing services. Services offered
include counseling and information on potential
discrimination and landlord/tenant problems,
special assistance for ethnic minority and single-
headed households (which includes escort
services to locate adequate housing), bilingual
housing literature and video-tape presentations,
day-care services, and housing assistance
counseling.

The City monitors and attempts to minimize
discriminatory housing practices with the
assistance of the FHCOC that is annually funded
by the City’s CDBG. Fair Housing actively
counsels residents on landlord/tenant issues to
help minimize landlord and housing acquisition
policies that utilize discriminatory practices. In
addition to providing educational workshops to
City residents, the organization advocates fair
housing rights on behalf of residents.

Program Objectives:
 Continue to contract with a fair housing
service provider to provide fair housing
services. Maintain the link on the City
website providing information about fair
housing services. Participate in the
Regional Analysis of Impediments to Fair
Housing Choice and work to mitigate
impediments identified in the study.

Result/Evaluation: Program considered successful. The
City is committed to furthering fair housing practices in the community and cooperates with the Fair Housing Council of Orange County to eliminate discriminatory practices
countywide. The City continues to contract with the Fair Housing Council of Orange County. The Fair Housing
Council provides services that include fair housing
enforcement and education, landlord/tenant counseling,
mediation, and homebuyer HUD counseling which includes
first-time homebuyer education and mortgage default
counseling. Services are available to low-to-moderate
income clients free of charge and to others for a moderate donation. Services are available in English, Spanish, and Vietnamese.

In 2016, Lake Forest participated with 15 other Orange
County entitlement cities to prepare a regional Analysis of Impediments to Fair Housing Choice (AI) to fulfill their HUD requirement and remove barriers to fair housing choice for all their residents. The AI examined policies, procedures, and practices within the region that may limit a person’s ability to choose their residence free from discrimination.

The AI provided an overview of laws, regulations,
conditions, or other possible obstacles that may affect an individual or a household’s access to housing in the region.

It also presented local and regional demographic profiles, assessed the extent of housing needs among specific
groups, identified existing barriers or impediments that may limit housing choice, and proposed actions to overcome
those barriers.

More recently, in FY 2021-22, the City awarded FHCOC a
$$7,500 grant to fund counseling services for tenants and landlords, enforcement, and community education in
furtherance of fair housing. FHCOC assisted 70 Lake
Forest households in FY 2019-20.

Continue/Modify/Delete: Continue. This program
continues to be appropriate and is included in the 2021- 2029 Housing Element.

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Cumulative Evaluation of the Effectiveness in Meeting the Housing Needs of Special Needs Populations While goals, policies, and programs that increase the number and variety of different types of units and maintain the high-quality of existing housing stock benefits all residents in Lake Forest, the 2013 Housing Element included a number of policies and programs to specifically address the needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers, and persons experiencing homelessness). To meet the housing needs of special needs populations, the City accomplished the following during the last planning period:
 Elderly
o Program 8: The City allocates CDBG funds to social services agencies that administer housing and supportive services, including services for the elderly. In FY 2019-2020, nine non-profit social services agencies received pass-through CDBG funding from the City to provide support and assistance, including to elderly residents, and comparable assistance was provided in each preceding year of the program.
o Program 9: The City contracts with OCHA to administer the Housing Choice Voucher rental assistance program. During the planning period, 190 very low-income households received assistance annually.
 Persons with Disabilities
o Program 8: As described abov e, the City allocates CDBG funds to social services agencies that administer housing and supportive services, including services for persons with disabilities (including developmentally disabled). In Fiscal Year 2019-2020, nine non-profit social services agencies received pass-thr ough CDBG funding from the City to provide support and assistance, includi ng to persons with disabilities, and comparable assistance was provided in each preceding year of the program.
o Program 14: The City is committed to furthering fair housing practices and cooperates with the Fair Housing Council of Orange County to eliminate discriminatory practices countywide.

The City continues to contract with the Fair Housing Council of Orange County, which provides services that include fair housin g enforcement and education, landlord/tenant counseling and mediation. In 2016, Lake Fore st participated with 15 other Orange County entitlement cities to prepare a regional Analysis of Impediments to Fair Housing Choice (AI) to remove barriers to fair housing choice for all their residents. The AI examined policies, procedures, and practices within the region that may limit a person’s ability to choose their residence free from discrimination. Additionally, the City awarded FHCOC a $7,500 grant to fund counseling services for tenants and landlords, enforcement, and community education in furtherance of fair housing. FHCOC assisted 70 Lake Forest households in FY 2019-20. o In addition, the City’s Reasonable Accommodation Ordinance is codified in Chapter 9.224 of the Zoning Code, and allows for reasonable accommodation (i.e., modifications or exceptions) in the City’s zoning laws and other land use regulations to allow disabled persons an equal opportunity to use and enjoy a dwelling.
 Large Family Households
o Program 14: As described above, the City is committed to furthering fair housing practices and cooperates with the Fair Housing Council of Orange County to eliminate discriminatory practices countywide. The City continues to contract with the Fair Housing Council of Orange County, which provides services that include fair housing enforcement and education, landlord/tenant counseling and mediation. In 2016, Lake Forest participated with 15 other Item: 11
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Orange County entitlement cities to prepare a regional Analysis of Impediments to Fair Housing Choice (AI) to remove barriers to fair housing choice for all their residents. The AI examined policies, procedures, and practices within the region that may limit a person’s ability to choose their residence free from di scrimination. Additionally, the City awarded FHCOC a $7,500 grant to fund counseling services for tenants and landlords, enforcement, and community education in furtherance of fa ir housing. FHCOC assisted 70 Lake Forest households in FY 2019-20.
o In addition, as shown in Table 37, there are sufficient units in Lake Forest to accommodate both large owner and renter households. The City is further addressing the needs of large family households in the 6 th Cycle Housing Element: refer to Program 5, which directs the City to proactively collaborate with housing developers to address the needs of large families.
 Female-Headed Households
o Program 14: As described above, the City cont racts with the Fair Housing Council of Orange County, which provides fair housing services, including for single-headed households (which includes escort services to locate adequate housing). In 2016, Lake Forest participated with 15 other Orange County entitlement cities to prepare a regional Analysis of Impediments to Fair Housing Choice (AI) to remove barriers to fair housing choice for all their residents. The AI examined policies, procedures, and practices within the region that may limit a person’s ability to choose their residence free from di scrimination. Additionally, the City awarded FHCOC a $7,500 grant to fund counseling services for tenants and landlords, enforcement, and community education in furtherance of fa ir housing. FHCOC assisted 70 Lake Forest households in FY 2019-20.
 Farmworkers
o Program 4: Zone Change 12-14-4673 was approved on June 16, 2015, which added a definition for “agricultural employee quarters” as well as allowing such housing by right within the City’s Agricultural and Open Space zones.
 Persons Experiencing Homelessness
o Program 6: The City contract s with Mercy House, a non-profit service provider specializing in assisting the homeless. In addition, the City provided funding for a Homeless Liaison Officer position through its law enforcement services contract with the Orange County Sheriff’s Department. The City also provided pass-through CDBG funding annually to local non-profits, including Families Forward, Family Assistance Ministries and South County outreach, that provide food banks, rental assistance, counseling and other forms of assistance to individuals and families at risk of becoming homeless. Further, in 2013, the City amended the Zoning Code to allow emergency shelters by right in the City’s industrial zoning districts, subject to compliance with objective standards consistent with the requirements identified in Government Code Section 65583(a)(4), and transitional and supportive housing by right in all residentia l zoning districts and subject only to the same requirements for residential uses of the same type (e.g., single-family or multi-family) in the same zone.
o Program 7: The City provides financial assist ance to non-profit service agencies that serve persons experiencing homelessness. During the 2019-20 fiscal year, for example, the City assisted 4,314 individuals through CDBG su b-recipient funding of nine non-profit organizations that provide services to homeless and low and moderate-income persons. The Item: 11
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total expenditure for this activity was $73,245. Comparable assistance was provided in each preceding year of the program. In addition, for the past three years, the City has provided $40,000-$50,000 annually in homeless services contracts. o In addition, Lake Forest supports a regional effort among the various local agencies making up the South Service Planning Area of Orange County.

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3. Housing Needs Assessment

3A. Introduction and Background
The purpose of the Housing Needs Assessment is to describe housing, economic, and demographic conditions in Lake Forest, assess the demand for housing for households at all income levels, and document the demand for housing to serve various special needs populations. The Housing Needs Assessment also addresses whether assisted housing projects are at risk of converting to market rate projects. The Housing Needs Assessment is intended to assist Lake Forest in developing housing goals and formulating policies and programs that address local housing needs.

Several sources of data were used to describe ex isting demographic and housing conditions, including the following:
 Local Housing Data package for the City of Lake Forest developed by the Southern California Association of Governments (S CAG) and pre-certified by the California Department of Housing and Community Development (HCD) for use in 6th cycle housing elements.
 Data from the 2010 U.S. Census, 2014-2018 U.S. Census American Community Survey (ACS), California Department of Finance (DOF), California Employee Development Department (EDD), and U.S. Department of Housing and Urban Development (HUD) is included to provide information on population, household, housing, income, employment, and other demographic characteristics.
 Regional information from the Fair Housing Council of Orange County.  Other sources of economic data such as inform ation from website rental listings, multiple listing service, and other published data are used where current Census, ACS, DOF, HUD, and other standard data sources do not provide relevant data.  Interviews with key agencies and organizations were conducted to obtain information on housing needs and, in particular, needs of populations with special housing needs.  Research and data related to fair housing, including Census Scope, Social Science Data Analysis Network, the UC Davis Center for Regional Change and Rabobank, N.A., and the California Fair Housing Task Force.

Due to the use of multiple data sources (with varying dates), there are slight va riations in some of the information, such as total population and total household numbers, presented in this document. However, these variations do not significantly affect the discussion of overall housing trends and changes. 3B. Population Trends and Characteristics

POPULATION GROWTH
Table 3 shows population growth for Lake Forest and other jurisdictions in the region from 2000 through 2020. According to data prepared by the California DOF, the population of Lake Forest in 2020 was 84,711 persons, an increase of approximat ely 9.5% since 2010. During the previous decade (2000 to 2010), the City’s population increased 31.8% to total 77,395 in 2010, due in large part to the annexation of Foothill Ranch and Portola Hills. Lake Forest’s growth during this time was higher than countywide growth. Orange County population growth rates between 2000 to 2010 and 2010 to 2020 are shown in Table 3. Of neighboring jurisdictions, Irvine had both the greatest numeric ch ange in population (136,079 persons) and the largest percentage change in population (93.4%) between 2000 and 2020.

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TABLE 3: POPULATION TRENDS – LAKE FOREST AND NEIGHBORING JURISDICTIONS Jurisdiction 2000 2010 2020
Change
2000-20
% Change
2000-20
Lake Forest 58,707 77,395 84,711 26,004 44.3%
Irvine 145,628 212,375 281,707 136,079 93.4%
Laguna Hills 31,178 30,270 31,508 330 1.1%
Mission Viejo 93,102 93,174 94,267 1,165 1.3%
Rancho Santa Margarita 47,214 47,853 48,793 1,579 3.3%
San Juan Capistrano 33,826 34,593 36,318 2,492 7.4%
Orange County 2,846,289 3,010,232 3,194,332 348,043 12.2% Sources: US Census, 2000; DOF, 2020
AGE
Changes in age groups can indicate future housing needs. Table 4 compares Lake Forest’s age cohort sizes in 2018 with Orange County’s. In Lake Forest, children under 15 years of age comprise 17.8% of the City’s population, teens and young adults (age 15 – 24) represent 11.8%, and adults in family-forming age groups (age 25 – 44) comprise 28.3%. Adults between the ages of 45 and 64 represent 29% of the population and seniors (age 65 and over) comprise 13.1%. In 2018, the median age in Lake Forest (39.0) was higher than that of Orange County (37.8) and 2.7 years higher than the statewide median age (36.3). The median age of City residents increased from the 2010 median age of 34.1.

TABLE 4: POPULATION BY AGE (2018)
Age
Lake Forest Orange County
Number Percent Number Percent
Under 5 Years 5,232 6.3% 188,956 6.0%
5 to 9 4,366 5.3% 189,548 6.0%
10 to 14 5,160 6.2% 206,380 6.5%
15 to 19 4,849 5.8% 208,793 6.6%
20 to 24 4,972 6.0% 218,993 6.9%
25 to 34 12,528 15.1% 453,121 14.3%
35 to 44 10,905 13.2% 415,919 13.1%
45 to 54 13,794 16.6% 453,608 14.3%
55 to 64 10,304 12.4% 388,376 12.3%
65 to 74 6,768 8.2% 249,211 7.9%
75 to 84 2,888 3.5% 131,180 4.1%
85 and Over 1,145 1.4% 60,097 1.9%
TOTAL 82,911 100% 3,164,182 100%
Source: US Census, 2014-2018 ACS

RACE/ETHNICITY
Table 5 shows the ethnic composition of Lake Forest’s population. Similar to Orange County as a whole, the majority of the City’s population are White (67.3%). The next largest racial group is Asian (17.1%), followed by “other race” (7.1%), “two or more races” (4.9%), Black or African American (2.2%), and American Indian or Alaska Native (1.2%), and Native Hawaiian and Pacific Islander (0.1%). More than one-fifth of the population (22.7%) is of Hispanic or Latino origin.

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TABLE 5: RACE AND ETHNICITY (2018)
Race/Ethnicity
Lake Forest Orange County
Number Percent Number Percent
White 55,805 67.3% 1,950,902 61.7%
Black or African American 1,845 2.2% 54,732 1.7%
American Indian or Alaska Native 977 1.2% 14,466 0.5%
Asian 14,216 17.1% 635,672 20.1%
Native Hawaiian and Pacific Islander 94 0.1% 9,442 0.3% Some Other Race 5,897 7.1% 370,679 11.7%
Two or More Races 4,077 4.9% 128,289 4.1%
TOTAL 82,911 100% 3,164,182 100%
Hispanic or Latino (of any race) 18,808 22.7% 1,080,195 34.1% Source: US Census, 2014-2018 ACS

EMPLOYMENT
One of the factors that can contribute to an increase in demand for housing is expansion of the employment base. Table 6 shows the employment and unemployment rates for persons 16 years and older that were in the labor force in 2010 and 2018. In 2018, ACS data indicated that there were 45,788 employed persons in the Lake Forest labor force and that the unemployment rate in Lake Forest was approximately 4.8%, a minor increase from 5.6% in 2010. According to the labor report data compiled by the California EDD, the Anaheim- Santa Ana-Irvine Metropolitan Area’s average annual unemployment rate in 2018 was estimated at 3.0%.

Orange County’s rate was also 3.0%, while California’s was 4.1%.

TABLE 6: JOB GROWTH AND EMPLOYMENT STATUS
2010 2018
Number Percent Number Percent
Total Persons in Labor Force 43,789 100% 48,110 100%
Employed 41,346 94.5% 45,788 95.1%
Unemployed 2,443 5.6% 2,322 4.8%
Sources: US Census, 2010-2014 ACS and 2014-2018 ACS

INDUSTRY AND OCCUPATION
Of Lake Forest’s employed residents, the “Educational services, health care and social assistance” industry employed the most people at 20.0%. The second largest employment sector was the “Professional, scientific, management, administrative, waste management” industry, which had 14.4% of the total employed persons in Lake Forest. The top two employment sectors in Orange County were also the “Educational services, health care and social assistance” industry at 19. 3% and the “Professional, scientific, management, administrative, waste management” industry at 14.4%.

The City’s workforce holds a variety of jobs types as shown in Table 7, with the largest sector (49.5%) working in “Management, business, science, and arts occupations”, followed by 23.4% in “Sales and office” occupations. Employment and occupation trends play an important role in defining housing needs. This relationship extends beyond the impact of employment growth on housing demand in the City and includes how wage levels and median earnings affect the type of housing affordable to workers and households in Lake Forest. For example, there is a significant gap between the median earnings of a resident employed in management and a resident employed in a service occupation. This informs the types of housing needed in the City.

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TABLE 7: JOBS BY INDUSTRY (2018)
Industry Number Percent
Agriculture, forestry, fishing and hunting, mining 140 0.3% Construction 2,081 4.5%
Manufacturing 6,148 13.4%
Wholesale trade 1,498 3.3%
Retail trade 4,862 10.6%
Transportation, warehousing, utilities 1,497 3.3%
Information 1,306 2.9%
Finance and insurance, real estate and rental and leasing 3,847 8.4% Professional, scientific, management, administrative, waste mgmt. 6,608 14.4%
Educational services, health care and social assistance 9,131 20.0% Arts, entertainment, recreation, accommodation, food services 4,450 9.7% Other services 2,909 6.4%
Public administration 1,285 2.8%
TOTAL (Civilian Labor Force) 45,762 100%
Armed Forces 26 100%
Source: US Census, 2014-2018 ACS
TABLE 8: JOBS BY OCCUPATION (2018)
Occupation Number Percent Median
Earnings*
Management, business, science, and arts 22,652 49.5% $81,087 Sales and office 10,707 23.4% $41,417
Service 7,223 15.8% $19,792
Production, transportation, and material moving 3,203 7.0% $34,804 Natural resources, construction, and maintenance 1,977 4.3% $40,088 *Median earnings in 12 months prior to survey
Sources: SCAG 6th Cycle Data Package; US Census, 2014-2018 ACS

TRAVEL TO WORK
Approximately 61% of Lake Forest workers aged 16 and over travelled less than 30 minutes to work.

Comparatively, only 6.6% of workers drive more than 60 minutes to work. Most Lake Forest workers, 82.5%, drive alone to work and 7.5% carpool. Table 9 identifies travel time to work, and Table 10 identifies commute methods for Lake Forest workers, in 2018.

TABLE 9: TRAVEL TIME TO WORK (2018)
Number Percent
Less than 10 minutes 3,698 8.8%
10-19 minutes 11,787 28.0%
20-29 minutes 10,216 24.2%
30-44 minutes 11,011 26.1%
45-59 minutes 2,658 6.3%
60 + minutes 2,785 6.6%
Source: US Census, 2014-2018 ACS

TABLE 10: COMMUTE METHOD (2018)
Number Percent
Drive Alone 37,118 82.5%
Carpooled 3,363 7.5%
Public Transportation 437 1.0%
Walk 289 0.6%
Other 948 2.1%
Work at Home 2,810 6.2%
Source: US Census, 2014-2018 ACS

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3C. Household Characteristics
According to the Census, a household is defined as all persons living in a housing unit. This definition includes families (related individuals living together), unrelated individuals living together, and individuals living alone. Householder refers to the person (or one of the people) in whose name the housing unit is owned or rented (maintained) or, if there is no such person, any adult member, excluding roomers, boarders, or paid employees. The number of householders is equal to the number of households; the number of family householders is equal to the number of families.

A housing unit is defined by the Census as a house, an apartment, a mobile home, a group of rooms, or a single room that is occupied (or if vacant, is intende d for occupancy) as separate living quarters. Separate living quarters are those in which the occupants live and eat separately from any other persons in the building and which have direct access from the outside of the building or through a common hall. The occupants may be a single family, one person living alone, two or more families living together, or any other group of related or unrelated persons who share living arrangements.

People living in retirement homes or other group livin g situations are not considered “households” for the purpose of the U.S. Census count. The household characteristics in a community, including household size, income, and the presence of special needs households, are important factors in determining the size and type of housing needed in the City. Table 11 below identifies the ages of householders in Lake Forest and Orange County in 2018 based on ACS data from 2014-2018. Homeowner households are generally headed by residents early middle-aged to middle-aged, with 54.8% of homeowner households headed by a resident 35-59 years of age. Renter households are generally younger; about 25.2% of renter households are headed by a person aged 25-34.

TABLE 11: HOUSEHOLDS BY TENURE AND AGE (2018)

Lake Forest Orange County
Number % Number %
Total: 28,713 - 1,032,373 -
Owner Occupied: 19,955 69.5% 592,269 57.4%
Householder 15 to 24 years 58 0.2% 2,053 0.2%
Householder 25 to 34 years 1,764 6.1% 36,065 3.5%
Householder 35 to 44 years 3,070 10.7% 86,899 8.4%
Householder 45 to 54 years 5,410 18.8% 137,678 13.3%
Householder 55 to 59 years 2,451 8.5% 75,371 7.3%
Householder 60 to 64 years 1,878 6.5% 67,259 6.5%
Householder 65 to 74 years 3,429 11.9% 104,985 10.2%
Householder 75 to 84 years 1,494 5.2% 58,068 5.6%
Householder 85 years and older 401 1.4% 23,891 2.3%
Renter Occupied: 8,758 30.5% 440,104 42.6%
Householder 15 to 24 years 237 0.8% 23,193 2.3%
Householder 25 to 34 years 2,211 7.7% 105,489 10.2%
Householder 35 to 44 years 2,144 7.5% 101,763 10%
Householder 45 to 54 years 2,037 7.1% 91,096 8.8%
Householder 55 to 59 years 865 3.0% 33,973 3.3%
Householder 60 to 64 years 496 1.7% 24,592 2.4%
Householder 65 to 74 years 473 1.6% 33,099 3.2%
Householder 75 to 84 years 105 0.4% 16,518 1.6%
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Householder 85 years and older 190 0.7% 10,381 1%
Source: US Census, 2014-2018 ACS 5-Year Data Profile (Table B25007) Table 12 identifies the household sizes by housing tenure. In 2018, the majority of households consisted of 2 to 4 persons. Large households of 5 or more persons made up 9.9% of the total households in Lake Forest, which represents a smaller percentage than the percent of large households residing in Orange County. The average household size was 2.87 persons in Lake Forest, compared to 3.02 persons in the County.

Additionally, the average household size in 2018 for owner-occupied units was 2.89 persons per household, compared to 2.82 persons per household for renter-occupied units.

The City has included Program 5: Facilitate Affo rdable and Special Needs Housing Construction to encourage the production of housing units to accommodate larger households for all income levels, including for extremely very low income households.

TABLE 12: HOUSEHOLD SIZE BY TENURE (2018)

Lake Forest Orange County
Number % Number %
Owner Households 19,955 100% 592,269 100%
Householder living alone 3,713 18.6% 110,780 18.7%
Households 2–4 persons 14,331 71.8% 404,680 68.3%
Large households 5+ persons 1,911 9.6% 76,809 13%
Average Household Size 2.89 persons 2.99 persons
Renter Households 8,758 100% 440,104 100%
Householder living alone 2,343 26.8% 106,627 24.2%
Households 2–4 persons 5,474 62.5% 263,316 59.8%
Large households 5+ persons 941 10.7% 70,161 15.9%
Average Household Size 2.82 persons 3.06 persons
Total Households 28,713 100% 1,032,373 100%
Householder living alone 6,056 21.1% 217,407 21.1%
Households 2–4 persons 19,805 69.0% 667,996 64.7%
Large households 5+ persons 2,852 9.9% 146,970 14.2%
Average Household Size 2.87 persons 3.02 persons
Sources: SCAG 6th Cycle Data Package; U.S. Census Bureau, 2014-2018 ACS; 2014-2018 ACS 5-Year Data Profile (Table B25009) 3D. Income

HOUSEHOLD INCOME
From 2000 to 2018, the median household income incr eased by 53.7% to $104,449 and the per capita income increased by 57.4% to $44,999. An increase in both per capita and median household incomes also occurred from 2010 to 2018. Table 13 shows per capita and median household incomes in 2000, 2010 and 2018.

TABLE 13: MEDIAN HOUSEHOLD AND PER CAPITA INCOME
2000 2010 2018
Median Household Income $67,967 $91,040 $104,449
Per Capita Income $28,583 $38,844 $44,999
Sources: US Census, 2000; US Census, 2014-2018 ACS
In 2018, the majority (51.6%) of Lake Forest’s households earned more than $100,000 per year. The incidence of households earning less than $35,000 per year was higher among renter households (18.8%) Item: 11
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than owner households (10.8%). Table 14 identifies household income by tenure. As shown in Table 14, the average income of owner households is approximately $50,000 more than renter households.

TABLE 14: HOUSEHOLD INCOME FOR ALL HOUSEHOLDS AND BY TENURE (2018) All Households Owner Households Renter Households
Income Number Percent Number Percent Number Percent
Less than $5,000 664 2.3% 336 1.7% 328 3.7%
$5,000 to $9,999 326 1.1% 150 0.8% 176 2.0%
$10,000 to $14,999 609 2.1% 316 1.6% 293 3.3%
$15,000 to $19,999 448 1.6% 301 1.5% 147 1.7%
$20,000 to $24,999 558 1.9% 336 1.7% 222 2.5%
$25,000 to $34,999 1,194 4.2% 700 3.5% 494 5.6%
$35,000 to $49,999 2,564 8.9% 1,293 6.5% 1,271 14.5%
$50,000 to $74,999 4,063 14.2% 2,199 11.0% 1,864 21.3%
$75,000 to $99,999 3,465 12.1% 2,325 11.7% 1,140 13.0%
$100,000 to $149,999 5,878 20.5% 4,151 20.8% 1,727 19.7% $150,000 or more 8,944 31.1% 7,848 39.3% 1,096 12.5%
Median Household
Income $104,449 $123,913 $70,654
Source: US Census, 2014-2018 ACS

HOUSEHOLDS BY INCOME GROUP
A special aggregation of 2013-2017 ACS data perfor med by HUD – titled the Comprehensive Housing Affordability Strategy (CHAS) data – provides a breakdown of households by income group by tenure. The number of households in Extremely Low, Very Low, Low, and Moderate/Above Moderate income groups is shown in Table 15. The majority of households (64.6%) are above moderate income. The HUD CHAS data indicates the extremely low-income group represents 9.9% of households, and a higher proportion are renters (1,470) than owners (1,305). The very low-income group represents 9.6% of households and the low-income group represents 15.9% of households. The smaller amount of extremely low and very low-income households in the City is likely due to the limited housing opportunities for the lower income groups in Lake Forest, including a deficiency of housing with affordable rent. The City’s RHNA (see Table 30) identifies the City’s share of regional housing needs for extremely low, very low, and low-income households, as well as for moderate and above moderate-income households. As shown in Table 15, there is a larger proportion of renters in the extremely low, very low, and low-income groups, while there is a larger proportion of moderate and above moderate-income groups in owner households.

TABLE 15: HOUSEHOLDS BY INCOME GROUP (2017)
Income Group Total Owner Renter
Households Percent Households Percent Households Percent Extremely Low (<30% AMI) 2,775 9.9% 1,305 6.7% 1,470 17.1% Very Low (31–50% AMI) 2,670 9.6% 1,345 6.9% 1,325 15.4% Low (51–80% AMI) 4,460 15.9% 2,555 13.2% 1,905 22.2%
Moderate and Above Moderate
(>80% AMI) 18,060 64.6% 14,180 73.2% 3,880 45.2%
TOTAL 27,965 100% 19,385 100% 8,580 100%
Source: HUD Comprehensive Housing Affordability Strategy (CHAS), 2013-2017 Available: https://www.huduser.gov/portal/datasets/cp.html Item: 11
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POVERTY LEVELS
The 2014-2018 ACS data indicates that 909 (4.3%) of all Lake Forest families and 5,839 individuals (7.1%), had incomes at or below the poverty level. According to the ACS data, poverty rates are disparate between races and economic indicators are particularly severe for Hispanic and Latino populations. In 2018, Hispanics/Latinos had a poverty rate of 11.8% compar ed to 6.5% for African Americans/Blacks, 5.9% for Whites, 5.8% for Asians, and 5.3% for American Indian and Alaska Natives.

The level of poverty in a jurisdiction often infl uences the need for housing to accommodate those persons and families in the very low and low-income categories. The U.S. Census Bureau measures poverty by using a set of money income thresholds that vary by family size and composition of who is in poverty. If a family’s total income is less than the family’s threshold, then t hat family and every individual in it is considered in poverty. For example, the poverty threshold for a family of two with no children would be $17,120, a household of two with a householder aged 65 or older and no children has a poverty threshold of $15,453, and the poverty threshold of a family of four with two children under the age of 18 would be $25,926. ( U.S.

Census Bureau, 2019).

Extremely Low-Income Households
Extremely low-income (ELI) households are defined as those earning up to 30% of the area median household income. For Orange County, the median household income in 2020 was $103,000. For ELI households in Lake Forest (and the rest of Orange County) , this results in an income of $38,450 or less for a four-person household or $26,950 for a one-person household. ELI households have a variety of housing situations and needs. For example, most families and individuals receiving only public assistance, such as social security insurance or disability insurance are considered ELI households. Table 16 provides representative occupations with hourly wages that are within or close to the ELI income range. As shown in Table 15, ELI households make up 9.9% of all households in Lake Forest. Based on Table 28, 80.5% of ELI households in Lake Forest pay more than 30% of their incomes for housing.

TABLE 16: OCCUPATIONS WITH WAGES FOR EXTREMELY LOW-INCOME HOUSEHOLDS (2020) Occupation Title Median Hourly Wage
Laborers and Freight, Stock, and Material Movers $12.70 Telemarketers $12.43
Waiters and Waitresses $12.07
Retail Salespersons $12.03
Ambulance Drivers and Attendants, Ex cept Emergency Medical Technicians $11.94 Cooks, Fast Food $11.63
Couriers and Messengers $11.61
Personal Care Aides $11.59
Hosts and Hostesses, Restaurant, Lounge, and Coffee Shop $11.52 Amusement and Recreation Attendants $11.42
Cashiers $11.42
Parking Lot Attendants $11.41
Source: Employment Development Department, Long-Term Occupational Projections 2016-2026 (accessed January 2021) Pursuant to Government Code Section 65583(a)(1), 50% of Lake Forest’s very low-income regional housing needs assigned by HCD are projected to be extremely lo w-income households. As a result, from the very low-income need of 954 units (see Table 29), the City has a projected need of 477 units for extremely low- income households (i.e., households earning 30% or less of the average median income). Based on current figures, extremely low-income hou seholds will most likely be facing an overpayment, overcrowding, or substandard housing conditions. Some extremely low-income households could include individuals with Item: 11
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mental or other disabilities and special needs. To address the range of needs of ELI households, the City will implement several programs including the following programs (refer to the Housing Plan for more detailed descriptions of these programs):
 Program 5: Facilitate Affordable and Special Needs Housing Construction  Program 9: Sites for Homeless Shelters/Homeless Prevention and Assistance Services  Program 10: Transitional/Supportive and Affordable Housing  Program 11: Coordination with Social Service Agencies 3E. Housing Characteristics

HOUSING TYPE
Table 17 identifies the types of housing units in Lak e Forest in 2020. The table summarizes total housing stock according to the type of structure. As shown in the table, the majority of housing in Lake Forest is single-family detached housing, which accounted for 58. 8% of units in 2020. Mobile/manufactured homes represent 4.2% of the housing stock. Multi-family uni ts represent 26.1% of the housing stock, with duplex through fourplex units accounting for 5.0% and multi-family developments with five or more units accounting for 21.1%. Single-family attached homes represent 14.9% of housing units.

TABLE 17: HOUSING STOCK BY TYPE AND VACANCY (2020)

Total
Single Family Multi-family Mobile
Homes
Occupied Vacant
Detached Attached 2 – 4 5 + Units
Units 30,244 16,567 4,508 1,525 6,369 1,275 28,831 1,413 Percent 100% 58.8% 14.9% 5.0% 21.1% 4.2% 95.3% 4.7%
Sources: SCAG 6th Cycle Data Package; DOF E-5 Report 2020

VACANCY RATE
Table 17 also shows the number and percentage of occupied units and the percentage of vacant units. It is important to note that these counts include all vacant units, including those units that are newly constructed but not yet occupied. In order for the housing market to function properly in a city, there should always be some level of housing vacancy, otherwise rents or housing prices could skyrocket. The 4.7% vacancy rate in Lake Forest is considered low (the historical equilibrium in California is 5.5% for rental vacancy and 1.2% for homeownership vacancy).1
The 2014-2018 ACS data indicates that there were 1,282 vacant units in 2018. As shown in Table 18, of the total vacant units in 2018, 284 were for rent, 170 were for sale, 394 were rented or sold but not yet occupied, and 313 were for seasonal, recreational, or occasional use. The overall vacancy rate in Lake Forest in 2018 was 4.3%, a rate which has fluctuated slightly since 2010.

TABLE 18: VACANCY BY TYPE (2018)
Vacancy Type Number Percent
For rent 284 22.2%
Rented, not occupied 112 8.7%
For sale only 170 13.3%
Sold, not occupied 282 22.0%
For seasonal, recreational, or occasional use 313 24.4% For migrant workers 0 0.0%
Other vacant 121 9.4%

1 “California’s low residential vacancy rates signal more construction,” First Tuesday Journal (February 15, 2021).

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TOTAL 1,282 100%
Source: US Census, 2014-2018 ACS
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HOUSING CONDITIONS
The U.S. Census provides only limited data that can be used to infer the condition of Lake Forest’s housing stock. In most cases, the age of a community’s housing stock is a good indicator of the condition of the housing stock. Moreover, many federal and state progr ams also use the age of housing as one factor in determining housing rehabilitation needs. Typically, housing over 30 years of age is more likely to have rehabilitation needs that may include pl umbing, roof repairs, electrical repairs, foundation rehabilitation, or other significant improvements.

The 2014-2018 ACS data indicates that just over half of the housing in the City is less than 40 years old (in 2018); 57.6% of units were built in 1980 or later. Another 32.9% of units were built between 1970 and 1979.

Due to the relatively young age of the City’s housing stock, overall housing conditions are good. While units built after 1970 may require new roofs and windows, it is anticipated that most units built after 1970 would not need significant rehabilitation to the structure, foundation, electric al, and plumbing systems. Units built prior to 1970 may require aesthetic and maintenance repairs including roof, window, and paint improvements and some units in this age range may also require si gnificant upgrades to structural, roof, plumbing, and other systems.

When examining a housing stock to determine what condition it is in, there are certain factors that the Census considers. For example, older units may not have plumbing that is fully functional, or the plumbing might be substandard. Table 19 indicates that a small percentage of dwelling units (0.5%), which were either owner- occupied or vacant, lacked complete plumbing facilities in 2018.

TABLE 19: HOUSING STOCK CONDITIONS (2018)
Year Structure Built
Owner-Occupied Renter-Occupied Total
Number Percent Number Percent Number Percent
2014 or later 792 4.0% 528 6.0% 1,659 5.5%
2010 to 2013 166 0.8% 94 1.1% 300 1.0%
2000 to 2009 349 1.7% 233 2.7% 627 2.1%
1990 to 1999 3,815 19.1% 1,646 18.8% 5,533 18.4%
1980 to 1989 5,994 30.0% 2,788 31.8% 9,170 30.6%
1970 to 1979 6,937 34.8% 2,604 29.7% 9,879 32.9%
1960 to 1969 1,571 7.9% 642 7.3% 2,273 7.6%
1950 to 1959 214 1.1% 177 2.0% 391 1.3%
1940 to 1949 52 0.3% 9 0.1% 61 0.2%
1939 or earlier 65 0.3% 37 0.4% 102 0.3%
TOTAL 19,955 100% 8,758 100% 29,995 100%
Plumbing Facilities
Units with Complete Plumbing
Facilities
19,926 99.9% 8,758 100% 29,844 99.5%
Units Lacking Complete Plumbing
Facilities
29 0.1% 0 0.0% 151 0.5%
Source: US Census, 2014-2018 ACS (Table B25036)
The City’s housing stock remains relatively new with only 9.5% of dwelling units in Lake Forest having been constructed prior to 1970, and as such, structural deterioration and maintenance problems are rare. Code enforcement officers conducted a window survey of 600 homes in southwest Lake Forest (the oldest neighborhood most in need of attention) to assess the condition of housing stock in Lake Forest. Of the 600 homes, no homes were identified to need major rehabilitation or replacement. Most, most issues noted included minor exterior issues such as deteriorated paint, dead or dying landscaping, broken windows, etc.

One was considered to need major rehabilitation or replacement. This equates to 0.1%. Based on a total Item: 11
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housing stock of 30,244 (per Table 3-15), this equates to an estimate of up to 30 units which may be in need of rehabilitation or replacement citywide. The City’s Code Enforcement staff have estimated that a very low percentage of housing units are in need of substantial rehabilitation or replacement. Nonetheless, the goal of the City’s Code Enforcement program is to address housing concerns before they become serious problems. The City has introduced Program 24, Neighborhood Improvement Task Force, to address the need of the City’s older neighborhoods. The City’s first Neighborhood Improvement Plan is being prepared for Southwest Lake Forest, and as described in the Program, the City has committed $70,500 to implementing improvements in the Southwest Lake Forest neighborhood from 2021-2023.

To supplement the Census information regarding housing conditions, the City of Lake Forest included specific questions pertaining to the quality of the City’s hou sing stock in its Housing Element Update community survey, which was posted for over one month (this is further detailed in Appendix B). When asked to rate the physical condition of the residence they lived in, 39.4% responded that their home shows signs of minor deferred maintenance such as peeling paint or chipped stucco while 54.5% indicated that their home was in excellent condition. Another 9.1% of respondents indicated that their home was in need of a modest repair (like a new roof or new siding) and no one reported that their home needed a major repair (such as new foundation, complete new plumbing, or complete new electrical). Although the sample size was small, renters (57.1%) were just as likely as homeowners (53.8%) to respond that their residence was in excellent condition.

Community members were also asked to report the type of home improvements they have considered making to their homes. The most popular answer s that applied were painting, new heating and air conditioning, and roofing.

Additionally, the City’s Planning Division’s assessment is that, while there are a limited number of homes in need of significant repair scattered throughout various nei ghborhoods in the City, there are no areas of the City in which it appears that a preponderance of the ho mes need major repair. In general, areas of the City with older homes have a greater number in need of major repair. The City will continue to implement its residential Rehabilitation Loan Program (RLP) using CD BG funds (when available) to help qualified homeowners to rehabilitate substandard housing.

OVERCROWDING
Typically, a housing unit is considered overcrowded if there is more than one person per room and severely overcrowded if there are more than 1.5 persons per room. Table 20 summarizes overcrowding data for Lake Forest. It should be noted that kitchenettes, strip or Pullman kitchens, bathrooms, porches, balconies, foyers, halls, half-rooms, utility rooms, unfin ished attics, basements, or other sp ace for storage are not defined as rooms for Census purposes.

Overcrowded households are usually a reflection of the lack of affordable housing available. Households that cannot afford housing units suitably sized for their families are often forced to live in housing that is too small for their needs, which may result in poor physical condition of the dwelling unit. In 2018, 1,364 housing units (4.8% of the total occupied units) were overcrowded, which represented 2.1% of owner-occupied units and

10.7% of renter-occupied units.

TABLE 20: OVERCROWDING BY TENURE (2018)
Persons per Room
Owner Renter Total
Number Percent Number Percent Number Percent

1.00 or less 19,528 97.9% 7,821 89.3% 27,349 95.2%

1.01 to 1.50 382 1.9% 517 5.9% 899 3.2%

1.51 or more 45 0.2% 420 4.8% 465 1.6%
TOTAL 19,955 100% 8,758 100% 28,713 100%
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Overcrowded 427 2.1% 937 10.7% 1,364 4.8%
Source: US Census, 2014-2018 ACS
As shown in Table 21, the average household size in Lake Forest was 2.87 persons in 2018, which was an increase from the average household size of 2.84 persons in 2010. Table 21 shows Lake Forest’s household sizes for owner-occupied, renter-occupied, and all households. The average household size was slightly higher for owner-occupied units (2.89 persons). Renter-occupied households had an average size of 2.82 persons. The large majority (71.8%) of owner-occupied households had two to four persons, whereas 72.0% of renter-occupied households were one to three persons in size. Table 22 identifies bedrooms by tenure.

Although larger renter households and larger owne r households are proportionally comparable, the proportion of larger (4 or more bedroom) homes is significantly higher for owner households.

TABLE 21: HOUSEHOLD SIZE BY TENURE (2018)
Household Size
Owner Renter Total
Number Percent Number Percent Number Percent
1-person 3,713 18.6% 2,343 26.8% 6,056 21.1%
2-person 6,381 32.0% 2,454 28.0% 8,835 30.8%
3-person 3,969 19.9% 1,502 17.2% 5,471 19.1%
4-person 3,981 19.9% 1,518 17.3% 5,499 19.2%
5-person 1,274 6.4% 570 6.5% 1,844 6.4%
6-person 346 1.7% 180 2.1% 526 1.8%
7-or-more-person 291 1.5% 191 2.2% 482 1.7%
TOTAL 19,955 100% (69.5% of total) 8,758 100% (30.5% of total) 28,713 100%
Average Household
Size

2.89 2.82 2.87
Source: SCAG 6th Cycle Data Package
TABLE 22: NUMBER OF BEDROOMS BY TENURE (2018)
Bedroom Type
Owner Renter Total
Number Percent Number Percent Number Percent
No bedroom 41 0.2% 273 3.1% 314 1.1%
1-bedroom 514 2.6% 2,624 30.0% 3,138 10.9%
2-bedroom 3,718 18.6% 3,328 38.0% 7,046 24.5%
3-bedroom 7,171 35.9% 1,707 19.5% 8,878 30.9%
4-bedroom 6,916 34.7% 652 7.4% 7,568 26.4%
5 or more bedroom 1,595 8.0% 174 2.0% 1,769 6.2%
TOTAL 19,955 100% 8,758 100% 28,713 100%
Source: US Census, 2014-2018 ACS
3F. Housing Costs

FOR SALE HOUSING
TABLE 23: HOMES FOR SALE (JANUARY 2021)
Price Homes Percent
$700,000 and more 113 64.6%
$600,000 - $699,999 13 7.4%
$500,000 - $599,999 9 5.1%
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As shown in Figure 1, between 2000 and 2018,
median home sales prices in Lake Forest increased
207% while prices in the SCAG region increased
151%. The 2018 median home sales price in Lake
Forest was $731,000 – the highest median sales price
experienced since 2000. Prices in the City have
ranged from a low of 92.7% of the SCAG region
median in 2007 to a high of 132.7% in 2017.

In January 2021, there were 175 homes listed for sale in Lake Forest on Zillow.com with prices ranging from $65,000 to $2,599,000. Of these homes, there were 135 detached single-family homes with sales prices beginning at $65,000 (manufactured home). As shown in Table 23, the vast majority of homes for sale were in the $700,000+ price range (64.6%), with 18.8% of homes in the $400,000 to $699,999 range, and 29 priced under $400,000. Zillow identified the January 2021 median sales price as $774,000. While the median sales price is not affordable to lower and moderate-income households (see Table 27), the City’s median home sales price was lower than the Orange County median sales pr ice (Zillow reported a median home sales price of $872,000 for the County in January 2021) , which may result in higher demand for housing in Lake Forest.

FIGURE 1: MEDIAN HOME SALES PRICE

Source: SCAG 6th Cycle Data Package

RENTAL HOUSING
Table 24 summarizes rents paid in Lake Forest in 2018 by rent-cost range. The majority (84.9%) of units rented for $1,500 or more. Only 3.4% of rentals were under $1,000 per month. More than one-third of rentals were in the $1,500 to $1,999 range. Based on a review of rental listings on Zillow.com and Craiglist.com, the average rent in Lake Forest (J anuary 2021) is $2,802 per month. There were 49 rentals available in January 2021. Rents ranged from $1,900 to $2,549 for 2 bed/2 bath homes to $3,600 to $7,500 for four or more-bedroom homes, as shown in Table 25.

TABLE 24: RENTAL COSTS (2018)
Rent Range Number Percent
Less than $500 125 1.5%
$500 to $999 166 1.9%
$1,000 to $1,499 994 11.6%
$400,000 - $499,999 11 6.3%
$300,000 - $399,999 7 4.0%
$200,000 - $299,999 6 3.4%
$100,000 - $199,999 12 6.9%
$0 - $99,999 4 2.3%
Source: Zillow.com, 2021
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$1,500 to $1,999 3,347 39.0%
$2,000 to $2,499 2,345 27.3%
$2,500 to $2,999 903 10.5%
$3,000 or more 695 8.1%
Median (dollars) $1,949
Source: US Census, 2014-2018 ACS
TABLE 25: RENTAL RATES BY NUMBER OF BEDROOMS
Bedroom Type
Rental Survey
Units
Available Range Average Rent
Studio 2 $1,600 - $2,031 $1,816
1 bed 12 $1,650 - $2,098 $1,841
2 bed 22 $1,900 - $2,549 $2,225
3 bed 10 $2,600 - $3,900 $3,193
4 bed or more 3 $3,600 - $7,500 $4,933
Sources: Zillow.com and Craigslist.com, Jan. 2021

INCOME GROUPS
The California Department of Housing and Community Development (HCD) publishes household income data annually for areas in California. Table 26 shows the maximum annual income level for each income group adjusted for house hold size for Orange County. The maxi mum annual income data is utilized to calculate the maximum affordable housing payments for different households (by income level and number of persons in household) and their eligibility for housing assistance programs.  Extremely Low-Income Households have a combined income at or lower than 30% of area median income (AMI), as established by the Department of Housing and Community Development (HCD).  Very Low-Income Households have a combined income between 30 and 50% of AMI, as established by HCD.
 Low-Income Households have a combined income between 50 and 80% of AMI, as established by HCD.
 Moderate-Income Households have a combined income between 80 and 120% of AMI, as established by HCD.
 Above Moderate-Income Households have a combined income greater than 120% of AMI, as established by HCD.

TABLE 26: STATE INCOME LIMITS – ORANGE COUNTY (2021)
Income Group 1 Person 2 Person 3 Person 4 Person 5 Person 6 Person 7 Person 8 Person Extremely Low $28,250 $32,300 $36,350 $40,350 $43,600 $46,850 $50,050 $53,300 Very Low $47,100 $53,800 $60,550 $67,250 $72,650 $78,050 $83,400 $88,800 Low $75,300 $86,050 $96,800 $107,550 $116,200 $124,800 $133,400 $142,000 Moderate $89,650 $102,450 $115,250 $128,050 $138,300 $148,550 $148,550 $169,050 Above Moderate $89,650+ $102,450
+
$115,250
+
$128,050
+
$138,300
+
$148,550
+
$148,550
+
$169,050
+
Source: HCD 2020 Orange County Income Limits
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HOUSING AFFORDABILITY
Table 27 shows the estimated maximum rents and sales prices that are affordable to very low, low, moderate, and above moderate-income households. Affordability is based on a household spending 30% or less of their total household income for shelter. Affordability is based on the maximum household income levels established by HCD (Table 26). The annual income limi ts established by HCD are similar to those used by the U.S. Department of Housing and Urban Development (HUD) for administering various affordable housing programs. Maximum affordable sales price is based generally on the following assumptions: 4% interest rate, 30-year fixed loan, and down payments that vary with income level, as described in Table 27.

Comparing the maximum affordable housing costs in Table 27 to the rental rates, rental rates in Lake Forest are generally affordable to moderate-income househol ds of two or more persons and to above moderate- income households of all household sizes. While there are some units affordable to low-income households, they tend to be smaller units ranging in size from 1- to 2-bedrooms. Moderate and above moderate-income households can afford a broad range of available housing options.

Although there are homes for sale in Lake Forest available to all income, the overwhelming majority of homes (i.e., in the $700,000+ range) are affordable to only above moderate-income households.

TABLE 27: HOUSING AFFORDABILITY BY INCOME GROUP
Income
Group
One Person Two Person Four Person Six Person
Home
Sale
Price*
Monthly
Rent or
Housing
Cost
Home
Sale
Price*
Monthly
Rent or
Housing
Cost
Home
Sale
Price*
Monthly
Rent or
Housing
Cost
Home
Sale
Price*
Monthly
Rent or
Housing
Cost
Extremely Low $100,663 $706 $116,026 $808 $146,561 $1,009 $171,216 $1,171 Very Low $180,231 $1,178 $201,200 $1,345 $252,218 $1,681 $293,184 $1,951 Low $286,375 $1,883 $327,151 $2,151 $408,704 $2,689 $474,136 $3,120 Moderate $358,009 $2,241 $407,950 $2,561 $493,708 $3,201 $571,467 $3,714 Above Moderate $358,009+ $2,241+ $407,950+ $2,561+ $493,708+ $3,201+ $571,467+ $3,714+ *Maximum affordable sales price is based on the following assumptions: 4.0% interest rate, 30-year fixed loan; down payment: $5,000 – extremely low, $10,000 – very low; $15,000 – low, $25,000 – moderate; property tax, utilities, and homeowners insurance as 30% of monthly housing cost (extremely low/very low), 28% of monthly housing cost (low), and 25% of monthly housing cost (moderate/above moderate). Homes sales prices are rounded to nearest $100.

Source: De Novo Planning Group, 2021
Extremely Low-income Households
As previously described, extremely low-income households earn less than 30% of the County Area Median Income (AMI). Depending on the household size, t hese households can affo rd rents between $706 and $1,171 per month and could purchase homes priced at $100,663 to $171,216. As of January 2021, there were no rental homes listed on Zillo w or Craigslist that would be affo rdable to extremely low-income households. However, based on US Census data, approximately 3.4% of renters pay monthly rents affordable to extremely low-income households. Extremely low-income households may be able afford to purchase a manufactured home in Lake Forest; however, r eal estate listings for these homes indicate that homes affordable at this price point may need significant maintenance and repair and there is an extremely limited supply.

Very Low-income Households
Very low-income households earn between 31% and 50% of the County Area Median Income (AMI).

Depending on the household size, these households can afford rents between $1,178 to $1,951 per month and could purchase homes priced at $180,231 to $293,18 4. As of January 2021, there were some studio and one-bedroom rental units listed on Zillow or Craigslist that could be affordable to very low-income Item: 11
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households. However, based on US Census data, approximately 15.0% of r enters pay monthly rents affordable to very low-income households (inclusive of units also affordable to extremely low-income). Very low-income households may be able afford to purchase a manufactured home or multi-family home in Lake Forest; however, even those units affordable to very low-income households need maintenance and repair and there continues to be a very limited supply.

Low-income Households
Low-income households earn between 51% and 80% of the County Area Median Income (AMI). Depending on the household size, these households can afford rents between $1,883 to $3,120 per month and could purchase homes priced at $286,375 to $474,136. As of January 2021, all studio, one-, and two-bedroom options listed on Zillow or Craigslist would be afford able to rent for low-income households. Based on US Census data, 81.3% of renters in Lake Forest pay monthly rents affordable to low-income households.

However, most renters are not larger six-person households, so the actual a ffordability by household size may be significantly more limited. Low-income househol ds can afford to rent a variety of home types, including better-maintained manufactured homes, multi-family homes, and some single-family detached homes.

Moderate-income Households
Moderate-income households earn between 80% and 120% of the County Area Median Income (AMI).

Depending on the household size, these households can afford rents between $2,241 and $3,714 per month and could purchase homes priced at $358,009 to $571,467. As of January 2021, nearly all studio, one-, two- , and three-bedroom rental units available were affordable to moderate-income households; these units included multi-family homes as well as single-family homes listed for rent by the homeowner. Moderate- income households can also afford a broader array of homes listed for sale as of January 2021. These unit types include manufactured homes, single-family homes, and multi-family homes. This is further confirmed by US Census data.

OVERPAYMENT
As in most communities, the location of the home is one of the biggest factors with regard to price. Housing in Lake Forest is more affordable than the County ($774,000 versus $872,000 according to Zillow median sales prices in January 2021). However, housing is not affordable for all income levels, particularly the extremely low, very low, and low-income households.

As shown in Table 28, 50.6% of renters in Lake Forest and 28.1% of homeowners overpay for housing. The majority of renters that overpay ar e in the lower income groups, with 76.2% in the extremely low-income group and 64.1% in the very low-income group severely overpaying for housing (over 50% of their monthly income). Comparatively, 71.6% of extremely low-income owners and 42.0% of very low-income owners are severely overpaying. Therefore, while overpaymen t is more predominate among lower income renter households, overpayment is an issue for both renter and owner households. Slightly more than one-third (35.0%) of all households in Lake Forest overpay for housing.

TABLE 28: HOUSEHOLDS BY INCOME LEVEL AND OVERPAYMENT (2017) Household Overpayment Renters Owners Total % of
Income Category
Extremely Low-Income Households 1,470 1,305 2,775 100%
With Cost Burden >30% 1,215 / 82.7% 1,020 / 78.2% 2,235 80.5% With Cost Burden >50% 1,120 / 76.2% 935 / 71.6% 2,055 74.1% Very Low-Income Households 1,325 1,345 2,670 100%
With Cost Burden >30% 1,185 / 89.4% 860 / 63.9% 2,045 76.6% Item: 11
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Household Overpayment Renters Owners Total % of
Income Category
With Cost Burden >50% 850 / 64.1% 565 / 42.0% 1,415 53.0% Low-Income Households 1,905 2,555 4,460 100%
With Cost Burden >30% 1,255 / 65.9% 1,585 / 62.0% 2,840 63.7% With Cost Burden >50% 165 / 8.7% 515 / 20.2% 680 15.2% Total Extremely Low, Very Low, and
Low-Income Households Paying >30 % 3,655 / 78% 3,465 / 67% 7,120 72% of lower income household s
Moderate and Above Moderate-Incom e
Households 3,880 14,180 18,060 100%
With Cost Burden >30% 690 /17.8% 1,990 / 14.0% 2,680 14.8% With Cost Burden >50% 55 / 1.4% 180 / 1.3% 235 1.3%
Total Households 8,580 19,385 27,965 100%
With Cost Burden >30% 4,345 / 50.6% 5,455 / 28.1% 9,800 35.0% With Cost Burden >50% 2,190 / 25.5% 2,195 / 11.3% 4,385 15.7% Note: Data is rounded to the nearest 5.

Source: HUD Comprehensive Housing Affordability Strategy (CHAS), 2013-2017 Item: 11
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AFFORDABLE HOUSING INVENTORY
Affordability covenants in Lake Forest include deve lopments that received federal pass-through funding (CDBG), received tax credits or mortgage revenue bond s, were financed with redevelopment funds or by non-profit developers, and/or were created to meet the City’s inclusionary housing policy.

Table 29 shows assisted units with covenants that requi re rents to be maintained at affordable levels for various agreed upon periods of time. In 2021, Lake Fo rest has 202 total deed-restricted affordable units. A recorded deed restriction serves as an affordability covenant that restricts the income level of a person who occupies the property, andproperty and ensures the property will remain available for low to moderate-income persons for a defined period.

The City has included Program 15: Conservation of Exis ting Affordable Units, to outline steps the City can take to help preserve all 11 units that are at-risk of converting to market rate units in the next 10 years.

TABLE 29: DEED RESTRICTED AFFORDABLE HOUSING UNITS
Project Name/Location No. & Type of
Affordable Units
Duration of
Affordability
Shelter for the Homeless (forme rly American Family Housing) 1 20927 Serrano Creek Road
1 affordable 2029
South County Outreach Condo Units 1

1 Transitional 2022
2 Transitional 2023
2 Transitional 2024
3 Transitional 2025
Madrid Transitional Housing Condo Units 2
22702, 22706 Madrid Drive
2 Transitional 2030
The Arroyo at Baker Ranch, 100 Indigo Place 3 187 affordable 2045 Saguaro Apartments, 23201 Saguaro Street 4 4 affordable 2071 202
Notes:
1 There are 8 transitional housing units and 1 affordable unit that received CDBG funding from the City, and are required to be affordable to very low or low-income households for 25 years from the da te the covenants were first agreed upon. Under the covenant for th e affordable unit, the occupant(s) in that unit may remain in the unit as long as he or she continues to qualify as an affordable household.

The affordable unit may continue to be rented by the same tenant (s) as long as the tenant(s) continue to qualify as a very low or low- income household.
2 The Madrid condos are owned by the Lake Forest Housing Authority and were purchased with Redevelopment Agency Housing Set-Aside Funds

3. Per Shea/Baker Ranch Development Agreement/Affordable Housing Implementation Plan 4 The Saguaro Apartments were purchased from the Lake Forest Housing Authority by Families Forward.

MOBILE HOMES
Mobile homes offer a more affordable option for those interested in homeownership. The median value of a mobile home in Orange County in 2018 was $59,000 (2 018 ACS 5-Year Estimates Data Profile). Overall, 1,275 mobile homes are located in Lake Forest (DOF, Table 2: E-5, 1/1/2020). According to HCD, there are four mobile home parks in the City with a total of 1,238 permitted spaces. They are:
 El Toro Mobile Estates (30-0282-MP), 24921 Muirlands Blvd. – 328 MH spaces  Forest Gardens Mobile Home Community (30-0268-MP), 24001 Muirlands Blvd. – 494 MH spaces  Kimberly Gardens Mobile Home Park (30-0266-MP), 24922 Muirlands Blvd. – 159 MH spaces  Prothero Mobile Estates (30-0299-MP), 24701 Raymond Way – 257 MH spaces In addition to the cost of a mobile home, owners must either purchase a residential site or rent a mobile home space. And although they present a more affordable alternative, mobile home rents have risen steadily in Item: 11
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Orange County and throughout southern California since 2009.2 3G. Future Housing Needs
A Regional Housing Needs Plan (RHNP) is mandated by the State of California (Government Code [GC], Section 65584) for regions to address housing issues and needs based on future growth projections for the area. The RHNP for Lake Forest is developed by the Southern California Association of Governments (SCAG), and allocates a “fair share” of regional housing needs to individual cities and counties (for unincorporated portions of the region). The intent of the RHNP is to ens ure that local jurisdictions address not only the needs of their immediate areas but also that needs of the entire region are fairly distributed to all communities. A major goal of the RHNP is to assure that every community provides an opportunity for a mix of housing affordable to all economic segments of its population.

This Housing Element addresses SCAG’s Regional Housing Needs Assessment (RHNA) schedule for the 6 th Cycle, from 2021 through 2029. The City will n eed to plan to accommodate 3,236 new units, which includes 956 extremely low/very low, 543 low, 559 moderate, and 1,178 above moderate-income units.

Pursuant to Government Code Section 65583(a)(1), 50% of Lake Forest’s very low-income regional housing need assigned by HCD are extremely low-income units, effectively resulting in 478 extremely low-income units and 478 very low-income units. Table 30 summarizes Lake Forest’s fair share, progress to date, and remaining units.

TABLE 30: REGIONAL HOUSING NEEDS ALLOCATION – 6TH CYCLE Status
Extremely
Low/Very
Low
Low Moderate Above Moderate TOTAL
RHNA Allocation 956 543 559 1,178 3,236
Completed, Under
Construction/Permits
Issued (Since 6/30/2021 ,
accurate as of August 31,
20221)
13 13 14 752451 755461
Units Approved/Entitled 107105 9793 53 544775 753976
Remaining Allocation 848 445447 553552 0 (with a surplus of 118 48 units) 1,8467*
Source: City of Lake Forest, August 31, 2021, SCAG, 2021 * The total remaining allocation is the remaining allocation of extremely low/very low, low, and moderate income units (848, 445447, and 553552, respectively). This results in a remaining allocation of 1,8476 units. The surplus of above moderate-income units (11848) cannot be deducted from the remaining allocation, which is based on the remaining allocation by income level. 3H. Special Needs Groups
Government Code Section 65583(a)(7) requires housing elements to address special housing needs, such as those of the elderly; persons with disabilities, including a development al disability, as defined in Section 4512 of the Welfare and Institutions Code; large families; farmworkers; families with female heads of households; and families and persons in need of emergenc y shelter. The needs of these groups often call for targeted program responses, such as temporary housing, preservation of residential hotels, housing with features to make it more accessible, and the development of four-bedroom apartments. Special needs groups have been identified and, to the degree possible, responsive programs are provided in the Housing Plan. A principal effort in addressing the needs of these groups is to continue to seek state technical assistance grants to identify the extent and location of those wi th special needs and identify ways and means to assist

2 Jeff Collins, “Soaring rents jolt senior tenants at mobile home park,” OC Registrar (July 20, 2018).

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them. Local government budget limitations may act to limit effectiveness in implementing programs for these groups. Please refer to Section 5E of this Element for a discussion of agencies and programs that serve special needs populations in Lake Forest.

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SENIORS
Seniors are considered persons age 65 or older in
this Housing Element. However, some funding
programs have lower age limits for persons to be
eligible for their senior housing. Seniors have special housing needs primarily resulting from physical
disabilities and limitations, fixed or limited income,
and health care costs. Additionally, senior
households also have other needs to preserve their
independence including supportive services to
maintain their health and safety, in-home support
services to perform activities of daily living,
conservators to assist with personal care and
financial affairs, public administration assistance to
manage and resolve estate issues, and networks of
care to provide a wide variety of services and daily
assistance.

Various portions of the Housing Element describe characteristics of the senior population, the extent of their needs for affordable housing, housing designated for seniors, and City provisions to accommodate their need. Senior household growth in Lake Forest from 2010 to 2018 is shown in Table 31. The large increase in elderly persons is likely due to the residential growth experienced in Lake Forest as well as aging in place of Lake Forest’s residents. Senior households increased by approximately 56.2% from 2010 to 2018. While seniors represent approximately 13.1% of the City’s population, senior households represent approximately

21.2% of total households, which is primarily due to the smaller senior household size.

Table 32 summarizes senior households by age and tenure. The majority of senior households are owners (5,324 or 87.4%). Approximately 12.6% of senior households (768), are renters. Lake Forest has a slightly higher percentage of owner-occupied elderly households than Orange County (18.5% vs. 18.1%), but a lower percentage of renter-occupied elderly households (2.7% vs. 5.8%). Elderly renters tend to prefer affordable units in smaller single-story structures or multi-story structur es with an elevator, clos e to health facilities, services, transportation, and entertainment.

During the planning period, senior households are anticipated to increase at a rate commensurate with overall population and household growth. It is anticipated that approximately 21% of the City’s RHNA allocation will be needed or used by senior households. Senior housing types can include market rate homes, senior single- family housing communities, senior apartments, and mobile/manufactured homes.

TABLE 32: HOUSEHOLDER AGE BY TENURE (2018)
Age Group
Owners Renters
Number Percent Number Percent
65-74 years 3,429 64.4% 473 61.6%
75-84 years 1,494 28.1% 105 13.7%
85 plus years 401 7.5% 190 24.7%
TOTAL
5,324

18.5%
(of total
pop.)
768

2.7%
(of total
pop.)
Source: US Census, 2014-2018 ACS

TABLE 31: SENIOR POPULATION AND HOUSEHOLDS
(2010 & 2018)
Population 2010 2018
Number 7,011 10,801
Percent Change - 54.1%
Annual Percent
Change - 6.8%
Households 2010 2018
Number 3,899 6,092
Percent Change - 56.2%
Annual Percent
Change - 7.0%
Source: US Census, 2010; US Census, 2014-2018 ACS
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The 2014-2018 ACS survey indicates that 9.9% of senior households in Lake Forest are below the poverty level. It is likely that a portion of these senior house holds overpay for housing due to their limited income.

The median income of households with a head of household that is 65 years and over is $64,289; significantly less (38.4%) than the all-ages median household income of $104,449.

Senior Housing
A variety of housing types are available to the senior population. This section focuses on three basic types.

Independent Living – Housing for healthy seniors who are self-sufficient and want the freedom and privacy of their own apartment or house. Many seniors age in place, and others move to residential communities which provide enhanced security, amenities and social activities geared towards a senior community.

Group Living – Shared living arrangements in which seniors live in proximity to their peers and have access to activities and special services.

Assisted Living – Provides the greatest level of support, including meal preparation and assistance with other activities of daily living.

There are a number of licensed community care facilities in Lake Forest operating out of homes that serve elderly persons. Furthermore, there is one commercially operating assisted living residential care facilities for the elderly in the City:
 Freedom Village, 23442 El Toro Road – senior living community offering independent and assisted living, and Alzheimer’s care
Several programs address the non-housing needs of seni ors in Lake Forest. Additional support for senior residents is provided by the City-operated Clubhouse S enior Center, which serves as the primary site for senior programs offered by the City. Some of the programs and services provided at the Clubhouse include health screening and health care counseling, legal assi stance, and driver safety courses. The City also partners with and funds the non-profit Age Well Senior Services organization to provide senior transportation services.

DISABLED PERSONS
A “disability” includes, but is not limited to, any physical or mental di sability as defined in California Government Code Section 12926. A “mental disability” involves having any mental or psychological disorder or condition that limits a major life activity. A “physical disability” involves having any physiological disease, disorder, condition, cosmetic disfigurement, or anatom ical loss that affects body systems. In addition, a mental or physical disability limits a major life activity by making the achievement of major life activities difficult including physical, mental, and social activities and working.

Physical, mental, and/or developmental disabilities could prevent a person from working, restrict a person’s mobility, or make caring for oneself difficult. Therefore, disabled persons often require special housing needs related to potential limited earning capacity, the lack of accessible and affordable housing, and higher health costs associated with disab ilities. Additionally, people with disabilit ies require a wide range of different housing, depending on the type and severity of their dis ability. Housing needs can range from institutional care facilities to facilities that support partial or full independence (i.e., group care homes). Supportive services such as daily living skills and employment assistance may ne ed to be integrated in the housing situation.
 Individuals with a mobility, visual, or hearing limitation may require housing that is physically accessible. Examples of accessibility in housin g include widened doorways and hallways, ramps, kitchen and bathroom modifications (e.g., lowered countertops, grab bars, adjustable shower heads, etc.) and special sensory devices including smoke alarms and flashing lights.

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 Individuals with self-care limitations (which can in clude persons with mobility difficulties) may require residential environments that include in-home or on-site support services ranging from congregate to convalescent care. Support services may include medical therapy, daily living assistance, congregate dining, and related services.
 Individuals with developmental disabilities and ot her physical and mental conditions that prevent them from functioning independently may require assisted care or group home environments.  Individuals with disabilities may require financial assistance to meet their housing needs because a higher percentage than the population at large are low-income and their special housing needs are often more costly than conventional housing.

According to the 2014-2018 ACS, there were 5,920 persons with one or more disabilities in Lake Forest. Of the disabled population, 55.0% were aged 5 to 64 and 44.6% were aged 65 and over. No disabilities were reported in the population aged 5 and under (except for hearing difficulty – 21 persons under 5 years of age).

Table 33 shows the number of persons with one or more disability by type of disability.

TABLE 33: DISABILITIES BY DISABILITY TYPE (2018)
Type of Disability
Persons Ages 5-64 Persons Ages 65+ Total
Number Percent Number Percent Number Percent
Hearing Difficulty 812 24.9% 1,308 49.5% 2,141 36.2%
Vision Difficulty 456 14.0% 399 15.1% 855 14.4%
Cognitive Difficulty 1,480 45.4% 638 24.2% 2,118 35.8%
Ambulatory Difficulty 1,066 32.7% 1,568 59.4% 2,634 44.5% Self-Care Difficulty 567 17.4% 663 25.1% 1,230 20.8%
Independent Living
Difficulty 1,160 35.6% 1,282 48.5% 2,442 41.3%
Total Persons with One
or More Disabilities
1 3,258
100% /

55.0% of
disabled
2,641
100% /

44.6% of
disabled
5,920 100%
1A person may have more than one disability, so the total disabilities may exceed the total persons with a disability Source: US Census, 2014-2018 ACS
As shown in Table 34, the 2014-2018 ACS indicates that for individuals between the ages of 16 and 64, approximately 1,286 persons had some form or type of disability and were not in the labor force. This indicates that their disability may impede their ability to earn an adequate income, which in turn could affect their ability to afford suitable housing accommodations to meet their special needs. Therefore, many in this group may need housing assistance.

TABLE 34: DISABLED PERSONS BY EMPLOYMENT STATUS (2018)
Ages 16 to 64 Percent
Employed with Disability 1,261 44.9%
Unemployed with Disability 260 9.3%
Not in Labor Force 1,286 45.8%
Total 2,807 100%
Source: US Census, 2014-2018 ACS
While recent Census data does not provide income levels or overpayment data for persons with a disability, the 2014-2018 ACS survey does report on indicators that relate to a disabled person’s or household’s income.

The 2014-2018 ACS data indicates that 583 Lake Forest residents with a disability are below the poverty Item: 11
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level. It is likely that a portion of these disabled perso ns are in households that overpay for housing due to their limited income. The 2014-2018 ACS data indicates that 15.7% of households receiving food stamps or similar assistance have a disabled member. Of the 4,521 households with a disabled member, 284 households receive food stamps or similar assistance. The 2014-2018 ACS data indicates that the median earnings for males 16 years of age and older with a disability was $24,453 compared with $60,898 for males with no disability. Median earnings for females 16 y ears of age and older with a disability was $29,500, compared to $41,142 for females with no disability.

The persons in the “with a disability” category in Tables 3-31 and 3-32 include persons with developmental disabilities. “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.” This term includes intellectual disability, cerebral palsy, epilepsy, autism, and disabling conditions found to be closely related to intellectual disability or to require treatment similar to that required for individuals with intellectual disabilities, but does not include othe r handicapping conditions that are solely physical in nature.

While the U.S. Census reports on a broad range of disabilities, the Census does not identify the subpopulation that has a developmental disability. The California Department of Developmental Services (DDS) maintains data regarding people with developmental disabilities, defined as those with severe, life-long disabilities attributable to mental and/or physical impairments. The DDS data is reported by zip code, so the data reflects a larger area than the City of Lake Forest; however, the data was joined at the jurisdiction level by SCAG to approximate the counts for Lake Forest. The DDS/SCAG data indicates that 452 developmentally disabled persons reside in zip codes 92610, 92630, and 92679. Table 35 breaks down the developmentally disabled population by residence type. Of t hese persons, the majority (366) live at home with a parent or guardian and only 29 live independently.

TABLE 35: DEVELOPMENTALLY DISABLED PERSONS BY RESIDENCE TYPE (2018)

Home of
Parent/
Guardian
Independe
nt/
Supported
Living
Communit
y Care
Facility
Intermedi
ate Care
Facility
Foster/
Family
Home
Other TOTAL
Lake Forest* 366 29 36 11 5 5 452
*Data is for the Lake Forest portion of zip codes 92610, 92630, and 92679 Sources: CA DDS, 2020; SCAG 6th Cycle Data Package
Housing for Disabled Persons
Households with a disabled member will require a mixture of housing units with accessibility features, in- home care, or group care housing facilities. Some of these households will have a member with a developmental disability and are expected to have special housing needs. Developmentally disabled persons may live with a family in a typical single-family or multi-family home, but some developmentally disabled persons with more severe disabilities may have special housing needs that may include extended family homes, group homes, small and large residential care facilities, intermediate care, and skilled nursing facilities, and affordable housing such as extremely low/very low/lo w-income housing (both rental and ownership), Section 8/housing choice vouchers, and single room occupancy-type units.

Although there are no Adult Residential Facilities for Persons with Special Health Care Needs, including physical, mental, and developmental disabilities in Lake Forest, there are ten licensed adult residential facilities operating in the City as of August 2021. Furthermore, there are service providers operating in the City such as BrightStar Care that provide in-home ca re to support people with disabilities like spina bifida and cerebral palsy. The Regional Center of Orange County offers services and support for persons with developmental disabilities by referrin g consumers to specific programs that meet t heir respective housing, Item: 11
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work, educational, and leisure needs. In addition, in an effort to assist persons with developmental disabilities, the City previously and for many years allocated part of its CDBG funding to the non-profit Vocational Visions organization, which offers vocational training and support services for consumers through community supported employment. 3 Residents with dis abilities can also benefit from services offered by the Dayle McIntosh Center for the Disabled – South County Br anch in neighboring Laguna Hills. The center offers disabled persons a variety of services including peer support and advocacy, along with housing referral, and rental and hotel/motel assistance if needed.

The 2014-2018 ACS data indicates that for individuals between the ages of 5 and 64, approximately 1.3% of the total population of Lake Forest have an ambulatory difficulty, 0.5% have a vision difficulty, 1.0% have a hearing difficulty, and 1.4% have an independent living difficulty. These types of disabilities may impede their ability to find suitable housing accommodations to meet their special needs. Therefore, many in these groups may need housing assistance. Households containi ng disabled persons may also need housing with universal design measures or special features to allow better physical mobility for occupants.

The 2014-18 ACS data also indicates that 4,521 households (15.7%) in Lake Forest had one or more disabled persons, including developmentally dis abled persons. It is ant icipated that this rate will remain the same during the planning period. Housing needed for persons with a disability during the planning period is anticipated to include community care facilities or at-home supportive services for persons with an independent living difficulty or self-care difficulty (approximately 4.4% of the population), as well as housing that is equipped to serve persons with ambulatory and sensory disabilities. Approximately 15% of the City’s RHNA allocation, 484 units, may need to have universal des ign measures or be accessible to persons with a disability.

LARGE FAMILY HOUSEHOLDS
Large-family households are defined by the US Census Bureau as households of five or more persons.

Large-family households are considered a special need s group because there is often a limited supply of adequately sized housing to accommodate their needs. Generally, the more persons in a household, the more rooms are needed to accommodate that household. Specifically, to avoid being considered living in overcrowded conditions, a five-person household would require three or four bedrooms, a six-person household would require four bedrooms, and a seven-person household would require four to six bedrooms.

In Lake Forest, 2,852 households (9.9% of all households) have five or more persons as described in Table

21. Of the large households, 67.0% own their home and 33.0% rent. Typically, there are more owner- occupied large households that are cost burdened when compared to renter households and the population as a whole. However, the 2014-2018 ACS survey does not provide data regarding overpayment for large households. Table 36 compares the median income for households with five or more persons to the Citywide median income for 2018. For each large-family categor y, the median household income was higher versus the Citywide median of $104,449.

TABLE 36: MEDIAN INCOME BY HOUSEHOLD SIZE (2018)
Size Median Income
5-Person Households $152,095
6-Person Households $145,714
7 or More Person Households $124,087
Median Household Income (All Households) $104,449
Source: US Census, 2014-2018 ACS
Large families can have a difficult time finding housing units large enough to meet their needs. In Lake Forest,

3 Vocational Visions did not apply for Fiscal Year 2021-2022 funding.

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there appears to be a significant amount of both ownership housing and rental housing available to provide units with enough bedrooms for larger households. T able 37 identifies the number of large households by household size versus the number of large owner and rental units. While there are sufficient units in Lake Forest to accommodate large owner and renter households, it does not mean there is a match between housing units that exist and large families. As desc ribed in Table 20, 2.1% of owner-occupied homes and

10.7% of renter-occupied homes are overcrowded.

TABLE 37: HOUSEHOLD SIZE VERSUS BEDROOM SIZE BY TENURE (2018) Tenure 3 BR
Units
5 Person Households
4+ BR
Units
6 Person and Larger
Households
House-
holds
Shortfall/
Excess
House-
holds
Shortfall/
Excess
Owner 7,171 1,274 5,897 8,511 637 7,874
Renter 1,707 570 1,137 826 371 455
Source: US Census, 2014-2018 ACS
Large households typically require housing units with more bedrooms than needed by smaller households.

In general, housing for these households should provide safe outdoor play areas for children and should be located to provide convenient access to schools and childcare facilities. These types of needs can pose problems particularly for large families that cannot afford to buy or rent single-family houses. It is anticipated that approximately 10% of the RHNA units will be needed to accommodate large households and an emphasis should be placed on ensuring rental units are available to large households.

SINGLE PARENT AND FEMALE-HEADED HOUSEHOLDS
Single parent households are households with children under the age of 18 at home and include both male- and female-headed households. These households generally have a higher ratio between their income and their living expenses (that is, living expenses take up a larger share of income than is generally the case in two-parent households). Ther efore, finding affordable, decent, and safe housing is often more difficult for single parent and female-headed households. Additional ly, single parent and female-headed households have special needs involving access to daycare or childcare, health care, and other supportive services.

While the majority of households in Lake Forest are ei ther couples or single person households, 21.8% of family households are headed by a single male or single female. There are 1,226 male heads of household with no spouse present and 413 of these households ha ve children under 18. There is a larger number of female householders with no spouse present – 3,378 households or 11.8% of family households – and 1,702 of these female-headed households have children under 18. Table 38 identifies single parent households by gender of the householder and presence of children.

The median income of female-headed households ( no spouse present) is $6 8,933, 17.4% less than the median income of a male-headed, no spouse pres ent family ($83,458) and 34.0% less than the median income of all households in the City ($104,449). Approximately 3.2% of households are under the poverty level while 18.9% of female-headed households with related children under 18 years of age are under the poverty level.

TABLE 38: FAMILIES AND FEMALE HOUSEHOLDER WITH CHILDREN UNDER 18 (2018) Category Number Percent
Total Families 21,128 100%
Male householder, no wife present 1,226 4.3%
With children under 18 413 1.4%
Female householder, no husband present 3,378 11.8%
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With children under 18 1,702 5.9%
Source: US Census, 2014-2018 ACS
As Lake Forest’s population and households grow, there will be a continued need for supportive services for single parent households with children present.

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In addition, the creation of innovat ive housing for female-headed households could include co-housing developments where childcare and meal preparation responsibilities can be shared. The economies of scale available in this type of housing would be advantageous to this special-needs group as well as all other low- income household groups. Limited equity cooperatives sponsored by non-profit housing developers are another financing structure that could be considered for the benefit of all special-needs groups.

FARMWORKERS
Farmworkers are traditionally defined as persons whose primary incomes are earned through permanent or seasonal agricultural labor. Following changes in the area’s economy, Orange County today is a mostly developed urban/suburban region with a strong local economy that is not tied to an agricultural base. While there are still active farming areas on the Irvine Ranch and in other cities, shifts in the County’s economy to manufacturing, technology, and service-oriented sectors have significantly curtailed agricultural production.

Furthermore, the only agricultural operation existing in Lake Forest in recent years – the 126-acre Nakase Brothers Wholesale Nursery, closed in 2020. The site was approved for redevelopment in January 2020. A master-planned community designed to include more than 540 housing units will be developed on the Nakase site.

The 2014-2018 ACS data estimates that only 140 (less than 1% of the working population) of Lake Forest’s residents were employed in agriculture (or related industries – forestry, fishing and hunting, mining) in 2018.

Given the limited active agriculture operations in and around the City, the number of residents employed in agriculture as opposed to those employed in forestry, fishing and hunting, or mining is likely to be smaller than 140. In addition, it is possible (although statistics are not available) that a number of active farmworkers are not full-time residents of Lake Forest and migrate into the area depending on seasonal crop harvest. The United States Department of Agriculture (USDA) estimates that there were just 340 migrant farmworkers in Orange County in 2017. USDA estimates that 666 farmworkers worked seasonally (hired for a period of less than 150 days) in Orange County in 2017, while 1,106 farmworkers in Orange County were permanent (hired for a period of greater than or equal to 150 days). Such farmworkers may find temporary housing by living with relatives, or short-term rental of a single unit for several families, resulting in overcrowded conditions.

Although there is not a significant nee d for farmworker housing in Lake Forest, the City allows agricultural uses within the A-1 and OS zones, and therefore farmworker housing must be allowed as an accessory use pursuant the California Employee Housing Act. The City revised the Zoning Code in June 2015 to comply with the California Employee Housing Act.

HOMELESS PERSONS
Government Code Section 65583(a)(7) requires that the Housing Element include an analysis of the needs of homeless persons and families. Homeless persons are defined as those who lack a fixed and adequate residence. People who are homeless may be chronica lly homeless (perhaps due to substance abuse or mental health issues) or situationally homeless (perhaps resulting from job loss or family strife). Homeless people face critical housing challenges due to their very low incomes and lack of appropriate housing. Thus, State law requires jurisdictions to plan to help meet the needs of their homeless populations.

The law also requires that each jurisdiction address community needs and available resources for special housing opportunities known as transitional and suppo rtive housing. These housing types provide the opportunity for families and individuals to “transition” from a homeless condition to permanent housing, often with the assistance of suppor tive services to assist in dividuals in gaining necessary life skills in support of independent living.

Homeless Estimates
Counting the homeless population is problematic due to their transient nature; however, through the efforts of the Orange County Continuum of Care (CoC) estimates have been developed. The Orange County CoC is a consortium of individuals and organizations wi th the common purpose of developing and implementing a strategy to address homelessness in Orange County. The Orange County CoC is responsible for managing U.S. Department of Housing and Urban Development (HUD) funds for homelessness and is uniquely Item: 11
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positioned to identify system needs and take steps to address them with the collaboration and partnership of community stakeholders.

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As the primary coordinating body for homeless issues and assistance for the entire county, the Orange County CoC accomplishes a host of activities and programs vital to the County, including a biennial point-in- time “snapshot” survey to identify and assess the needs of both the shelter ed and unsheltered homeless.

Orange County’s 2019 Point-In-Time sheltered count t ook place the night of T uesday, January 22, 2019.

Emergency shelters and transitional housing programs co llected client-level demographic information from individuals and families staying the night in each program. The 2019 Point-In-Time unsheltered count process took place over two days, Wednesday, January 23 and Thursday, January 24, to ensure the 800 square mile County jurisdiction was canvassed effectively.

The 2019 Point-In-Time Report identified 112 people in the City of Lake Forest experiencing homelessness, representing 1.6% of Orange County’s total homeless count (6,860 individuals). An estimated 76 (67.9%) of the 112 homeless individuals in Lake Forest were unsheltered and an estimated 36 (32.1%) were sheltered.

From the 2017 to the 2019 Homeless Count, there wa s an increase of homeless individuals counted in Orange County from 4,792 to 6,860, which is a 43% increase. This has been a greater increase in the County of homeless counts compared to previous years. In comparison, from 2015 to 2017, there was a 14% increase in the homeless count in Orange County. Prim arily, the increase from 2017 to 2019 in the County was unsheltered individuals, which increased from 2,584 individuals in 2017 to 3,961 individuals in 2019.

Housing Accommodations
In 2013, the City amended the Zoning Code to allow 1) em ergency shelters by right in the City’s industrial zoning districts, subject to compliance with objective standards consistent with the requirements identified in Government Code Section 65583(a)(4), and 2) transitional and supportive housing by right in all residential zoning districts and subject only to the same requirements for residential uses of the same type (e.g., single- family or multi-family) in the same zone. The Housing Plan includes policies and programs directed to encourage the provision of housing and services for the homeless population as well as persons and households at-risk of homelessness.

Currently (2021), there are several transitional housing units operating in the City. Lake Forest also supports a regional effort among the various local agencies ma king up the South Service Planning Area of Orange County, which includes 12 cities (Lake Forest, Aliso Viejo, Dana Point, Irvine, Laguna Beach, Laguna Hills, Laguna Niguel, Laguna Woods, Mission Viejo, Rancho Santa Margarita, San Clemente, and San Juan Capistrano).

The most recent inventory of resources available within Orange County for emergency shelters, transitional housing, and permanent supportive housing units comes from the 2019 Housing Inventory reported to HUD by the Orange County CoC. Table 39 shows the total num ber of beds offered by homeless facilities in the Orange County CoC area.

TABLE 39: HOMELESS FACILITIES (2019)*
Facility Type
Orange County CoC Region
Family Units Family Beds Adult-Only
Beds
Total Year-
Round Beds
Emergency Shelter 170 574 1,401 1,989
Transitional Housing 272 816 289 1,105
Permanent Supportive Housing 213 518 1,725 2,243
Rapid Re-Housing 149 615 159 774
Other Permanent Housing 8 16 92 108
TOTAL UNITS/BEDS 812 2,539 3,666 6,219
*Numbers are for the total Orange County Continuum of Care region for which Lake Forest is a participating member Source: HUD 2019 Continuum of Care Homeless Assistance Programs, Housing Inventory Count Report Item: 11
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 Emergency Shelters – Six emergency shelters are availabl e to provide services in the South Service Planning Area of the CoC jurisdiction – CSP Youth Shelter (Laguna Beach), Cold Weather Shelter (Laguna Beach), Friendship Shelter (Laguna Beach), Gilchrist House (San Clemente), Human Options (Irvine), and Laura’s House (San Clemente). According to the HUD 2019 Continuum of Care Housing Inventory Count Report for t he Orange County CoC, a total of 1,989 year-round emergency shelter beds and 400 seasonal beds are available in the Orange County CoC region.

During the 2019 point-in-time survey, the CoC f ound that the average occupancy for emergency shelter beds was 79.2%.
 Transitional Housing – Sometimes referred to as “bridge” housing, provides housing accommodations and support services for persons and families, but restricts occupancy to no more than 24 months. In the Orange County CoC region, a total of 1,105 transitional housing beds are provided. Transitional housing providers nearest to Lake Forest include Families Forward, Friendship Shelter, Henderson House, Hope’s House, Gilchrist House, Kathy’s House, Laura’s House, South County Outreach, and Toby’s House. The 2019 point-in-time survey found that the average occupancy for transitional housing beds was 78.2% at the time of the survey.  Permanent Supportive Housing – Supportive housing has no limit on length of stay and is linked to onsite or offsite services that assist residents in retaining the housing, improving their health status, and maximizing their ability to live and, when poss ible, work in the community. A total of 2,243 permanent housing beds are provided in the Orange County CoC region.  Rapid Re-Housing – Rapid re-housing provides short-term rental assistance and services. The goals are to help people obtain housing quickly, increase self-sufficiency, and stay housed.  Other Permanent Housing – Consists of permanent housing with services (no disability required for entry) and permanent housing with housing only.

Assessment of Need
Based on the available information, there is a countywide homeless population of 6,860 persons but only 6,219 beds, indicating an unmet demand for 641 homeless persons. It is noted that the 2019 Point-in-Time survey identified 2,899 sheltered homeless persons and 3,961 unsheltered homeless persons (36 sheltered and 76 unsheltered for Lake Forest). The discrepancy between sheltered homeless persons and the County’s total capacity to house homeless persons indicates a need for additional community services resources to assist and match the homeless population with the Countywide shelter and housing resources. Overall, the average bed-utilization rate for emergency shelters is 79.2% and is 78.2% for transitional housing, according to the Point-in-Time survey information. Although there are seasonal fluctuations in bed counts, these figures demonstrate a demand for supportive housing.
3I. Units at Risk of Conversion

ASSISTED HOUSING AT RISK OF CONVERSION
California housing element law requires jurisdictions to provide an analysis of low-income, assisted multi- family housing units that are eligible to change from low-income housing uses during the next 10 years (2021- 2031) due to termination of subsidy contracts, mort gage prepayment, or expiration of restrictions on use (Government Code 65583). These units risk the terminat ion of various subsidy groups which could convert certain multifamily housing from affordable to market rate. State law requires housing elements to assess at- risk housing in order to project any potential loss of affordable housing.

The California Housing Partnership (CHP) provides data on assisted housing units, including those in Lake Forest.

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Table 40 indicates the extent of subsidized multifamily rental housing in the City, the subsidy programs that are in place for each project, and the likelihood of current housing assisted projects to convert to market rate projects that would not provide assistance to lower income residents. The City has identified 11 units at-risk of conversion during the next 10 years (2 at moderate risk, 8 at high risk, and 1 at very high risk).

TABLE 40: SUMMARY OF AT-RISK SUBSIDIZED HOUSING UNITS
Project/Address
No. & Type
of Units
Type of
Subsidy Current Owner
Earliest
Date of
Conversion Risk
Shelter for The Homeless
(formerly American Family
Housing)
20927 Serrano Creek Road
1 / affordable CDBG Shelter for The
Homeless 2024 High
Saguaro Apartments
23201 Saguaro Street 4 / affordable
Purchased
from Lake
Forest
Housing
Authority
Families Forward 2071 Low
SCO Transitional Housing
Condo Units
1 /
transitional CDBG
South County Outreach
2022 Very
High
1 /
transitional CDBG 2023 High
2 /
transitional CDBG 2024 High
2 /
transitional CDBG 2025 High
2 /
transitional CDBG 2026 High
Madrid Transitional Housing
Condo Units
22702, 22706 Madrid Drive
2 Family
Redevelop
ment
Agency
Housing
Set-Aside
Unreserved
Funds
2030 Moderate
The Arroyo at Baker Ranch
100 Indigo Place 187 Family LIHTC Meta Housing
Corporation 2069 Low
Sources: California Housing Partnership, January 2021; SCAG 6th Cycle Data Package

PRESERVATION OPTIONS
Depending on the circumstances of the at-risk projects, different options may be used to preserve or replace the units. The following discussion high lights ways that the City’s eight ve ry high- or high-risk units (SCO Transitional Housing Condo Units) could be preserved as affordable housing. All of the presented alternatives are costly and beyond the ability of the City of Lake Forest to manage without large amounts of subsidy from federal and/or state resources.

Option 1: Replacement Through New Construction of Replacement Units The construction of of new lower income housing units is a means of replacing the at-risk units should they be converted to market-rate. The cost of developing new housing depends on a variety of factors such as density, size of units, location and related land cost s, and type of construction. Assuming an average Item: 11
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development cost of $ 200350,000 per unit for condominium housing, replacement of the 8 11 at-risk units would require approximately $ 1,600,0003,850,000, excluding land costs, which vary depending upon location.

Purchase of Replacement Units
One preservation option is for a non-profit organization to purchase similar units. By purchasing similar units, a non-profit organization can secure lower-income restrictions and potentially enable the project to become eligible for a greater range of governmental assistan ce. The cost of purchasing similar units depends on a number of factors, including the market conditions at the time, occupancy rate, and the physical condition of the units to be acquired.

Current market value for the at-risk units is estimated on the basis of the units’ potential annual income, and operating and maintenance expenses. The estimated mark et value of Lake Forest’s current stock of at-risk affordable housing is $2,500,000. This estimate is provided for the purpose of comparison and understanding the magnitude of costs involved and does not represent the precise market value of the at-risk units or units that could be purchased to offset converted units. The actual market value at time of sale would depend on market and property conditions, lease-out/turnover rates, among other factors.

Option 2: Purchase of Affordability Covenants
Another option to preserve the affordability of at-risk projects is to provide an incentive package to the owners to maintain the projects as affordable housing. Incentives could include writing down the interest rate on the remaining loan balance, and/or supplementing the subsidy amount received to market levels.

To purchase the affordability covenant on these proj ects, an incentive package should include interest subsidies at or below what the property owners can obtain in the open market. To enhance the attractiveness of the incentive package, the interest subsidies may need to be combined with rent subsidies that supplement the HUD fair market rent levels.

Option 3: Rental Assistance
Tenant-based rent subsidies could be used to preserve the affordability of housing. Rent subsidies using alternative State or local funding sources could be used to maintain affordability. Subsidies could be structured similar to the Section 8 program, where HUD pays the owners the difference between what tenants can afford to pay (30% income) and what HUD establishes as the Fair Market Rent. The level of the subsidy required to preserve the at-risk units is estimated to equal the Fair Market Rent (FMR) for a unit minus the housing cost affordable by a very low-income household. Approximately $5,2566,105 in rent subsidies would be required monthly (or $36,07273,260 annually). Assuming a 20-year affordability period, the total subsidy is about $ 1,261,4401,465,000, and assuming a 55-year affo rdability period, the total subsidy is about $4,029,300. .

Cost Comparisons
In terms of cost effectiveness for pr eservation of the 11 at-risk units, 55 years’ worth of rent subsidies ($4 million) is fairly comparable to the cost of construction of replacement units ($3.85 million); however the cost identified to construct replacement units excludes the price of land, which can add a significant expense to the overall project. While the cost of purchasing the affo rdability covenants is unknown, it is possible that it would provide a cost-effective strategy for preserving the at-risk units and should be explored further to support the City’s preservation objectives. The following are strategies the City will undertake to work towards preservation of the 11 at-risk units in these projects:
• Monitor At-Risk Units: Contact property owners with in at least one year of the affordability expiration date to discuss City’s desire to preserve as affordable housing. • Explore Funding Sources/Program Options: As ne cessary, contract with the California Housing Partnership Corporation to explore outside funding sources and program options for preservation.

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• Purchase of Affordabilit y Covenants: Proactively identify potential partners interested in purchasing and extending expiring affordability covenants.
• Tenant Education: Property owners are required to give a twelve-month notice of their intent to opt out of low-income use re strictions. The City will work with tenants, and as necessary contact specialists like the California Housing Partnership to provide education regarding tenant rights and conversion procedures.

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ESTIMATES OF HOUSING NEED
Several factors influence the degree of demand, or "need," for housing in Lake Forest. The major needs categories considered in this element include:
• Housing needs resulting from the overcrowding of units • Housing needs that result when households pay more than they can afford for housing • Housing needs of "special needs groups" such as elderly, large families, female-headed households, households with a disabled person, farm workers, students, and the homeless State law requires that cities quantify existing housing need in their Housing Element.

Table 41 summarizes those findings.

TABLE 41: SUMMARY OF NEEDS
Summary of Households/Persons with Identified Housing Need Percent of Total City Population/Households
Households Overpaying for Housing:
% of Renter Households Overpaying 50.6%
% of Owner Households Overpaying 28.1%
% of Extremely Low income Households (0-30% AMI) Overpaying 80.5% % of very low income Households (0-30% AMI) Overpaying 76.6% % of Low income Households (0-30% AMI) Overpaying 63.7% Overcrowded Households
% of Overcrowded Renter Households 10.7%
% of Overcrowded Owner Households 2.1%
% of All Overcrowded Households 4.8%
Special Needs Groups:

Elderly Households

13.1% of pop.

21.2% of households
Disabled Persons 7.1% of pop.

Developmentally Disabled Persons 0.5% of pop
Large Households 9.9% of households
Female Headed Households 11.8% of households
Female Headed Households with Children 5.9% of households Farmworkers 0.2% of labor force
Homeless 112 persons (2019)
Affordable Housing Units At-Risk of Conversion to Market Rate Costs 811 Source: US Census, 2014-2018 ACS; Orange County Regional Analysis of Impediments to Fair Housing Choice Item: 11
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4. Constraints

Constraints to housing development are defined as government measures or non-governmental conditions that limit the amount or timing of residential development.

Government regulations can constrain the supply of housing available in a community if the regulations limit the opportunities to develop housing, impose requirements that unnecessarily increase the cost to develop housing, or make the development process so arduous as to discourage housing developers. State law requires housing elements to contain an analysis of the governmental constraints on housing maintenance, improvement, and development (Government Code Section 65583(a)(4)).

Non-governmental constraints (required to be analyzed under Government Code Section 65583(a)(5)) may include land prices, construction costs, and financing. While local governments cannot control prices or costs, identification of these constraints can be helpful to Lake Forest in formulating housing programs. 4A. Governmental Constraints
Housing affordability is affected by factors in both the private and public sectors. Actions by the City can have an impact on the price and availability of housing in Lake Forest. Land use controls, site improvement requirements, building codes, fees, and other local programs intended to improve the overall quality of housing may also serve as a constraint to housing de velopment. These governmental constraints can limit the operations of the public, private, and non-profit sectors, making it difficult to meet the demand for affordable housing and limiting supply in a region. All City zoning regulations, development standards, specific plans, and fees are posted online and available to the public, consistent with the transparency requirements of AB 1483. Upon adoption of new mixed-use zoning, updated information and maps will continue to be made available online in accordance with transparency requirements.

LAND USE CONTROLS
Local land use policies and regulations impact the price and availability of housing, including affordable housing. This section discusses the General Plan land use designations and provisions in the Zoning Code that specify the types of housing allowed within Lake Forest as a potential governmental constraint.

General Plan
The General Plan Land Use Element establishes land use designations that specify the allowed types, locations, and intensities or densities of land uses in the City. The Zoning Code (Title 9 of the Municipal Code) implements the General Plan by providing land use regulations and development standards for each zoning district.

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Table 42 shows General Plan residential land uses de signations, the most common corresponding zoning designation(s), and permitted densities allowed for housing as specified in the General Plan.

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TABLE 42: GENERAL PLAN RESIDENTIAL LAND USE DESIGNATIONS General Plan
Designation 1 Description Zoning District
Very Low Density
Residential (VLDR)
Provide for development of single-family dwellings and
accessory buildings. Allows a density of 0-2 du/ac.

R1 – Single-Family
Residential District
RS – Residential
Single-Family
District
Low Density
Residential (LDR)
Provide for development of single-family dwellings and
accessory buildings. Allows a density of 2-7 du/ac.

R1 – Single-Family
Residential District
RS – Residential
Single-Family
District
Low-Medium
Density Residential
Provides for development of a wide range of living
accommodations, including single-family detached and
attached dwelling units, mobile homes, duplexes, and
multiple-family dwellings, such as townhomes,
condominiums, apartments, and cooperatives. Allows a
density of 7-15 du/ac
R4 – Suburban
Multi-Family
Residential District
RP – Residential
Professional District
Medium Density
(MDR) Residential
For the development of a wide range of living
accommodations, including single-family dwellings, and
multiple-family dwellings, such as townhomes,
condominiums, apartments, and cooperatives. This
designation allows for a density of 15-25 du/ac.

R2 – Multi-family
Dwelling District
High-Density
Residential (HDR)
For the development of a wide range of living
accommodations, including single-family dwelling units
and multiple-family dwellings, such as townhomes,
condominiums, apartments, and cooperatives. This
designation allows a density of 25 – 43 du/ac.

R2 – Multi-family
Dwelling District
Mixed-Use 32
(MU-32)
For mixtures of commercial, office, and residential uses in the same building, on the same parcel of land, or within the same area. This designation allows a maximum
density of 32 du/ac.

R2 – Multi-family
Dwelling District1
Mixed-Use 43
(MU-43)
For mixtures of commercial, office, and residential uses in the same building, on the same parcel of land, or within the same area. This designation allows a maximum
density of 43 du/ac.

R2 – Multi-family
Dwelling District1
Urban Industrial 25
(UI-25)
For a mix of traditional light industrial and commercial uses, as well as live-work units and home-based
businesses. This designation allows a maximum density
of 25 du/ac.

R2 – Multi-family
Dwelling District1
Urban Industrial 43
(UI-43)
For a mix of traditional light industrial and commercial uses, as well as live-work units and home-based
businesses. This designation allows a maximum density
of 43 du/ac.

R2 – Multi-family
Dwelling District1

1. The City is preparing new mixed-use zoning standards to implement the mixed-use land use designations identified in the General Plan. New mixed-use zoning for these areas will be adopted by early 2022 and will be consistent with the densities set forth by land use designations in the General Plan. Until the adoption of new mixed-use development standards, the current zoning standards apply.

2. The City has numerous zones associated with its Planned Communities, as described below. Zones contained within a Planned Community must be consistent with the General Plan Land Use Designation and provide standards specific to the Planned Community.

Sources: City of Lake Forest General Plan, 2020; City of Lake Forest Zoning Code, 2021 Item: 11
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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-64
Planned Communities
Much of the land use in Lake Forest is based on pr e-incorporation planning for ten largescale Planned Communities (PCs). The existing PCs include Baker Ranch, El Toro, Foothill Ranch, Lake Forest, Nakase, Pacific Commercentre, Portola Hills, Rancho de Los Alisos, Rancho Serrano, and Serrano Highlands.

Several of these PCs are the subject of development agreements that specify the density of development allowed. Future development in these areas must comply with the PC District regulations and any applicable development agreement.

Many of the development standards found in the PCs are similar to the R1 and RS zoning found in the City’s Zoning Code. Two of the largest PCs, Lake Forest PC and Rancho De Los Alisos PC, allow for smaller and more flexible side yard setbacks and allow for cluster development. Several PCs include a “High Density Residential” or “Heavy Density Residential” zone, which allow a variety of multi-family residential uses. The Baker Ranch, Foothill Ranch, and Portola Hills Planned Communities have mixed-use zones.

Zoning Code
Land use policies in the General Plan are implemented primarily through the Zoning Code. The Zoning Code provides for a range of densities and residential uses and is designed to protect and promote the health, safety, and general welfare of residents, which includes preserving the character and integrity of established residential neighborhoods. To that end, the City has est ablished specific development standards that apply to residential construction in various districts. These may include, but are not limited to, density, lot coverage, building height, parking standards, and other requirement s. The City initiated an update to its Zoning Code in early 2021 to develop new mixed-use zoning standards to implement the City’s 2040 General Plan. These standards will be adopted by early 2022.

Table 43 through Table 53 show development standards in the Zoning Code.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-65
TABLE 43: RESIDENTIAL ZONING DISTRICTS FROM ZONING CODE Zoning
District
Setbacks (ft) From
Ultimate Street
R.O.W.

B – Five (5) feet: and one (1) foot for each additional story over two (2).

C – Ten (10) feet one (1) side only or ten (10) feet total of two (2) sides combined.

D – In computing the depth or a rear setback from any building where such setback opens on an alley, private street, public park or public beach, one-half of the width of such alley, street park or beach may be deemed to be a portion of the rear setback, except that under this provision, no rear setback shall be less than fifteen (15) feet.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-66
TABLE 44: BAKER RANCH PLANNED COMMUNITY
Zoning
District
Setbacks (ft) From
Ultimate Street
R.O.W.

N/A N/A
Source: City of Lake Forest
Notes:

M - A minimum 8 foot setback is required from building elevations with a front entry.

N - Planning Area 5B has a 35 foot maximum height.

P - A single family dwelling unit has maximum height of 35 feet.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-67
TABLE 45: EL TORO PLANNED COMMUNITY
Zoning
District
Setbacks (ft)
From Ultimate
Street R.O.W.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-68
TABLE 46: FOOTHILL RANCH PLANNED COMMUNITY Zoning
District
Setbacks (ft)
From Ultimate
Street R.O.W.

Setbacks (ft) from
property line not
abutting a street
Setbacks Panhandle
building site from any
property line
Minimum Lot Size (sq ft)
Minimum distance (ft)
between Principal
Structures
Maximum Building
Height (ft)
Maximum Lot Coverage
Area (sq ft) per Unit
Front
Side
Rear
Side
Rear
Detached
(conventional) 5* 10 10 C 10 N/A 3,000 N/A 35 N/A N/A
Attached
Single-Family
Dwelling
5* 10 5 0 0 N/A 2,000 N/A 35 N/A N/A
Cluster
Subdivision E N/A N/A 35 70% N/A
Multiple-Family
Dwellings
(Apartments &
Condominiums)
E 5,000 N/A N/A 60% 1,000
Source: City of Lake Forest
Notes:
* Garage and carport placement – The point of vehicular entry to a garage or carport shall be a distance of five (5) feet or less, or eighteen (18) feet or more from the back of sidewalk, or if there is no sidewalk, from the back of curb. Automatic garage door openers are required for garages set back less than eighteen (18) feet to the point of vehicular entry.

C - Ten (10) feet one (1) side only or ten (10) feet total of two (2) sides combined.

E - 10’ from any exterior boundary line of the project. No setback from any individual building site’s property line development unit or lot except as required to comply with the UBC; Multiple-Family Dwellings require 25’ minimum from property lines abutting single family residential areas.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-69
TABLE 47: LAKE FOREST PLANNED COMMUNITY
Zoning
District
Setbacks (ft)
From Ultimate
Street R.O.W.

10* 10 10 G G N/A 5,000 N/A 35 60% 5,000
HIDR –
Multiple-Family
Residential
F, G, J N/A N/A N/A 60 60% 2,400
Heavy Density
Residential
(HEDR) –
Multiple Family
Residential
F, G, J N/A N/A N/A 35 60% 2,400
HEDR – SFR 10* 10 10 C 0 N/A
Source: City of Lake Forest
Notes:
* Garages must be a minimum of 20’ from R.O.W. or back of sidewalk, whichever is closer.

C - Ten (10) feet one (1) side only or ten (10) feet total of two (2) sides combined F - The minimum setback distance between any building or structure and street right-of-way or back of sidewalk shall be 10’.

G - The minimum side and rear setback is 0 ’, except 5’ setback from property line between detached adjacent structures or single- dwelling units.

H - 10’ from any exterior boundary line of the project. No setback from any individual building site’s property line development unit or lot; except as required to comply with the UBC.

J - When there is a difference in elevation of 3’or more between adjacent building pads on lots having a common side property line, “R1” side yard regulations shall apply to that common side yard only.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-70
TABLE 48: NAKASE PLANNED COMMUNITY
Zoning
District
Setbacks (ft) From
Ultimate Street
R.O.W.

Q - The minimum front setback from a private court or motor court is 3 feet.

R - 5 feet/15 feet , with a minimum 35% of the rear elevation at 15 foot setback S - 5 feet/15 feet , with a minimum 35% of the rear elevation at 15 foot setback.

T - 5 feet/15 feet , with a minimum 45% of the rear elevation at 15 foot setback.

U - 5 feet/10 feet , with a minimum 45% of the rear elevation at 10 foot setback.

V - Entry door to front door requires a 20 foot minimum separation.

W - If attached garages are included in the project then 70% lot coverage allowed.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-71
TABLE 49: PORTOLA HILLS PLANNED COMMUNITY
Zoning
District
Setbacks (ft)
From Ultimate
Street R.O.W.

Setbacks (ft) from
property line not
abutting a street
Setbacks Panhandle
building site from any
property line
Minimum Lot Size (sq ft)
Minimum distance (ft)
between Principal
Structures
Maximum Building
Height (ft)
Maximum Lot Coverage
Area (sq ft) per Unit
Front
Side
Rear
Side
Rear
Detached SFD
(rural estate) 20 8 25 8 25 N/A 1 acre N/A 35 N/A N/A
Detached SFD
(conventional) 10* 10 10 C 10 N/A 3,000 N/A 35 N/A N/A
Attached SFD
(conventional) 10* 10 10 0 0 N/A 2,000 N/A 35 N/A N/A
Cluster
Subdivision E N/A N/A 35 70% N/A
Multiple-Family
Dwellings
(Apartments &
Condominiums)
E 5,000 N/A 35 or K 60% 1,000
Source: City of Lake Forest
Notes:
* Garage and carport placement – The point of vehicular entry to a garage or carport shall be a distance of five (5) feet or less, or eighteen (18) feet or more from the back of sidewalk, or if there is no sidewalk, from the back of curb. Automatic garage door openers are required for garages set back less than eighteen (18) feet to the point of vehicular entry.

C – Ten (10) feet one (1) side only or ten (10) feet total of two (2) sides combined.

E – 10’ from any exterior boundary line of the project. No setback from any individual building site’s property line development unit or lot except as required to comply with the UBC; Multiple-Family Dwellings require 20’ minimum setback from any exterior property lines.

K – Sub-Planning Areas F1 an F2 of the Portola Hills Area Plan have a maximum height of 45 feet.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-72
TABLE 50: RANCHO DE LOS ALISOS PLANNED COMMUNITY
Zoning
District
Setbacks (ft) From
Ultimate Street
R.O.W.

Setbacks (ft) from
property line not
abutting a street
Setbacks Panhandle
building site from any
property line
Minimum Lot Size (sq ft)
Minimum distance (ft)
between Principal
Structures
Maximum Building
Height (ft)
Maximum Lot Coverage
Units/ Acre
Front
Side
Rear
Side
Rear
Low Density
Residential
(LDR)
10* 10 10 C 0 N/A 7,000 N/A 35 50% 2
Medium
Density
Residential
(MDR) –
Single Family
Residential
(SFR)
10* 10 10 C 0 N/A 3,000 N/A 35 60% 9
MDR – other
than SFR 20 5 25 5 25
or D N/A 3,000 N/A 35 60% 9
High Density
Residential
(HIDR)
10* 10 10 0 0 N/A 3,000 N/A 35 60% 18
Heavy Density
Residential
(HEDR)
10* 10 10 0 0 N/A 3,000 N/A 60 60% 30
Source: City of Lake Forest
Notes: Additional building setbacks: a) The minimum setback from arterial highways for all buildings shall be 25’ plus 5’ for each story above 2 stories. b) The minimum setback between single family and multiple family main buildings or mobile homes shall be 25’ plus 5’ for each story above 2 stories of the multiple family building. * Garages must be a minimum of 20’ from R.O.W. or back of sidewalk, whichever is closer (Section 7-9-137.1) C – Ten (10) feet one (1) side only or ten (10) feet total of two (2) sides combined.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-73
TABLE 51: RANCHO SERRANO PLANNED COMMUNITY Zoning
District
Setbacks (ft) From
Ultimate Street R.O.W.

C – Ten (10) feet one (1) side only or ten (10) feet total of two (2) sides combined.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-74
TABLE 52: SERRANO HIGHLANDS PLANNED COMMUNITY
Zoning
District
Setbacks (ft) From
Ultimate Street
R.O.W.

Setbacks (ft) from
property line not
abutting a street
Setbacks Panhandle
building site from any
property line
Minimum Lot Size (sq ft)
Minimum distance (ft)
between Principal
Structures
Maximum Building Height
(ft)
Maximum Lot Coverage
Units/ Acre
Front
Side
Rear
Side
Rear
Medium
Density
Residential
(MDR) –
Conventional
Subdivision
10* 10 10 0 0 N/A 5,000 N/A 35 50% 5
Medium
Density
Residential
(MDR) –
Planned
Concept
Subdivision
10* 10 10 0 0 N/A N/A N/A 35 N/A 5
High Density
I Residential
(HIDR1)
10* 0 0 0 0 N/A N/A N/A 35 or L 60% 13
High Density
II Residential
(HIDR2)
10* 0 0 0 0 N/A N/A N/A 35 or L 60% 18
Source: City of Lake Forest
Notes:
* Garage and carport placement – The point of vehicular entry to a garage or carport shall be a distance of five (5) feet or less, or twenty (20) feet or more from the back of sidewalk, or if there is no sidewalk, from the back of curb. Automatic garage door openers are required for garages set back less than five (5) feet to the point of vehicular entry.

L- Unless a greater height is specifically approved on the site plan by the Planning Commission.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-75
Flexibility in Development Standards
The City’s Municipal Code includes different proces ses that would allow for housing developers to either create new development standards or to deviate from existing development standards, as follows: .  The City has a Planned Development overlay zoning di strict that allows de viation from specific development standards for planned development proj ects. (Lake Forest Municipal Code Section

9.124)
 Many of the City’s Planned Communities include a process for an alternative development standards. (Baker Ranch Planned Community, Foothill Ranch Planned Community, Nakase Planned Community, and Portola Hills Planned Community)
 An Area Plan is required for larger residential developments. The Area Plan process allows for the creation of development standards for the specific housing development (Lake Forest Municipal Code Section 9.184.020).
 For affordable housing projects, the City allows incentives, which usually include deviations from development standards, and density bonuses (Lake Forest Municipal Code Chapter 9.152).

Analysis of Land Use Controls
The City has considered and analyzed all relevant land use controls as potential constraints on a variety of housing types, both independently and cumulatively with other land use controls. This analysis, as outlined above, includes reviewing current General Plan guidance (updated in 2020), and existing zoning standards including standards identified for the City’s Planned Communities.

As previously mentioned, the City adopted new mixed-us e land use districts as part of its comprehensive General Plan Update in 2020 and is currently prep aring mixed-use zoning standards to implement the densities identified for these land use categories. The City has included Program 1 as part of the Housing Plan to commit the City to prepare, adopt, and implement new zoning standards consistent with the densities and intensities identified in the General Plan. At this time, if an application was to be submitted for a site designated for mixed-use with no applicable zoning standards, the City would work with the applicant to prepare specific Planned Community standards for t he site and/or a Specific Plan which would set customized zoning consistent with the land use parameters identified in the General Plan. The City is committed to allowing the densities and intensities id entified for mixed-use development even as the final zoning standards are being prepared. Given this commitment and the City’s inclusion of specific programs in the Housing Plan which commit the City to complete the rezoning process, the City finds that its current land use controls no not impact the ability to achieve the densities identified in the sites inventory.

PROVISIONS FOR A VARIETY OF HOUSING TYPES
State housing element law requires that jurisdictions facilitate and encourage a range of housing types for all economic segments of the community. This includes housing to meet the needs of a variety of households with incomes ranging from low to above-moderate. The Housing Element is the City’s plan for achieving this objective.

As shown in
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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-76
Table 53, the City’s Zoning Code accommodates a wide variety of conventional and special needs housing, including single-family dwellings, duplexes, multifamily , ADUs, manufactured housing, mobile home parks, community care facilities (small and large), and tran sitional and supportive hous ing. Please note that the information contained in this Table represents accurate information only at the time of the Housing Element’s preparation; future amendments and modifications to the Zoning Code may change the information in this Table. All interested parties should refer directly to the Zoning Code to ensure that the most accurate information is considered.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-77
TABLE 53: PERMITTED RESIDENTIAL USES BY ZONE
Housing Type
Residential District Commercial
District
Urban
Activity
District
Light
Industrial
District
Agricultural
District
R1 RS R2/R4 RP C2/CC UA M1 A1
Conventional Housing
Single-Family
--Detached
--Attached
P
--
P
--
P
P
P
--
--
--
--
--
--
--
P
--
Two-Family Dwelling (Duplex)1 -- -- P -- -- -- -- --
Multifamily1
--Four or fewer units
--Five or more units
--
--
--
--
P
SD
U
--
--
--
--
--
--
--
--
--
Manufactured Housing P P P P -- -- -- P
Mobile Home Park - - U U -- -- -- --
Accessory Dwelling Unit
(Second Unit) P P P P -- -- -- P
Special Needs Housing
Community Care Facility
--6 or fewer clients
--7-12 clients
P
-
P
-
P
-
P
-
--
--
--
--
--
--
P
U
Congregate Care Facility (12 or
more persons) -- -- U -- U U -- --
Emergency Shelter -- -- -- -- -- -- P --
Transitional Housing P/
U
P/U/
SD
P/U/S
D
P/

U -- -- -- --
Supportive Housing P/
U
P/U/
SD
P/U/S
D
P/

U U U -- P/U
Single Room Occupancy -- -- -- -- SD SD -- --
Source: City of Lake Forest Zoning Code, 2021
Notes: “P” = Permitted; “U” = Use Permit; “SD” = Site Development Permit; and “--” = Not Permitted

1. Condominium projects require a use permit
Single-Family: Detached single-family dwellings are permitted by right within the R1, RS R2, R4, RP, and A1 zones. Attached single-family dwellings, which are units that are attached side by side and separated by a property line aligned with the shared wall, are allowed within the R2/R4 zones. Single-family projects are subject to a ministerial review.

Multifamily: Multifamily developments with four or fewer units are permitted in the R2/R4 zones by right, and permitted in the RP district subject to a Use Permit. Mu ltifamily developments with five or more units are permitted in the R2/R4 zones subject to Site Development Permit. Multifamily projects with four or fewer units are subject to administrative plan review. For projects wi th five or more units, a Site Development Permit is required.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-78
Accessory Dwelling Unit (ADU): Government Code Section 65852.2(a)(1) allows local agencies to designate areas within a city where accessory dwelling units (ADU) may be permitted and to impose development standards addressing issues such as unit size, height, setbacks, lot coverage, parking, landscaping, and architectural review. The City updated (2021) Section 9.146.050 of its Municipal Code to be consistent with California Government Code Sections 65852.150 and 65852.2, which establish regulations for accessory dwelling units. The information contained in this section is valid at the time of the Housing Element’s preparation (2021). Please refer directly to the Lake Forest Municipal Code for all current applicable regulations pertaining to ADUs.

Lake Forest Municipal Code (LFMC) Section 9.146.050 was amended to define an accessory dwelling unit as “an attached or a detached residential dwelling unit that provides complete independent living facilities for one (1) or more persons and is located on a lot with a proposed or existing primary residence.” An ADU includes permanent provisions for living, sleeping, eating, cooking, and sanitation.

Construction of an ADU or JADU (junior accessory dwelling unit) is permitted in zones that allow residential uses and include a proposed or existing dwelling. AD Us and JADUs are subject to compliance with the requirements described in
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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-79
Table 54 below and in LFMC Section 9.146.050. ADUs s hall be permitted on any residential or mixed-use zone that allows residential units, subject to the following criteria, which include (but are not limited to):
 Sites developed or proposed to be developed with a single-family residence shall be permitted one ADU.
 Sites developed with a multifamily building may convert existing non-habitable square footage within the building to a minimum one ADU and a maximum that shall not exceed twenty-five percent of the number of units on the site. Sites developed with a multifamily building are also permitted to construct two ADUs or to convert detached accessory buildings, garages, carports, or covered parking structures to a maximum of two ADUs.
 A maximum of one JADU is allowed on sites developed or proposed to be developed with a single- family residence. A JADU must be contained entirely within an existing or proposed single-family structure.

The City’s approval process for ADUs is consistent wi th State law. The ordinance sets forth the following development standards for ADUs, which are applicable as of September 2021:

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-80
TABLE 54: ADU AND JADU DEVELOPMENT STANDARDS
Specific Regulations
ADU
JADU Additional
Provisions Attached Detached
Maximum Size
Building permit only: 800
sq. ft.

Building permit and ADU
Permit: 850 sf (0-1
bedroom)
1,000 sf (2 bedroom)
Building permit only:
800 sq. ft.

Building permit and
ADU Permit:
850 sf (0-1 bedroom)
1,000 sf (2 bedroom)
500 sf (1)
Maximum Height 16 ft (1 story)
35 ft (2 story) 16 ft (1 story)
Same as
primary
residence

Minimum Front Yard Setback
Building permit only:
none
Building permit and ADU
Permit: 25 ft
Building permit only:
none
Building permit and
ADU Permit:25 ft
-- (2)
Minimum Side/Rear Yard
Setback 4 ft 4 ft -- (2)
Minimum parking 1 space 1 space -- (3)(4)(5)(6)
Tandem Parking Permitted Permitted --
Source: City of Lake Forest Zoning Code, 2021

1. An attached ADU that is created on a lot with an existing primary dwelling is further limited to fifty (50) percent of the floor area of the existing primary dwelling.

2. No setback is required for an ADU subject to this subsection (F) if the ADU is constructed in the same location and to the same dimensions as an existing structure.

3. No parking is required under the following situations: the ADU is located within one-half (½) mile walking distance of public transit; the ADU is located within an architecturally and historically significant historic district; the ADU is part of the proposed or existing primary residence or an accessory structure; when on-street parking permits are required but not offered to the occupant of the ADU; and/or, when there is an established car share vehicle stop located within one (1) block of the ADU.

4. When a garage, carport, or covered parking structure is demolished in conjunction with the construction of an ADU or converted to an ADU, those off-street parking spaces are not required to be replaced.

5. Each unclosed parking space shall be at least nine (9) feet wide and eighteen (18) feet long.

6. Each parking space that is provided in an enclosed garage shall be at least ten (10) feet wide and twenty (20) feet long and have at least seven and one half (7 ½) feet vertical clearance.

Manufactured Housing: State law requires that manufactured housing, when constructed as a single-family dwelling on a permanent foundation, be treated as a conventional single-family home subject to the same development standards applicable to a single-family residential dwelling on the same lot, except for architectural requirements limited to its roof overhang , roofing material, and siding material. In accordance with State law, manufactured housing in the City ma y be placed on lots that allo w single-family residential uses provided that the homes are attached to a foundation system in compliance with all applicable building regulations and Section 18551 of the Health and Safety Code and occupied only as a residential use.

Mobile Home Park: Mobile home parks, including manufactured home parks, that conform to the State Mobile Home Parks Act (Division 13, Part 2.1 of t he California Health and Safety Code, commencing with Section 18200) or the implementing State guidelines (Title 25, Division I, Chapter 2 of the California Code of Regulations) and Section 18300 of the Health and Safety Code, are allowed in the R2, R4, and RP residential zones but require a use permit. The City of Lake Forest currently has four mobile home parks.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-81
Residential Care Facility: Residential care facilities refer to any family home, group home, or rehabilitation facility that provides 24-hour non-medical care to persons in need of personal services, protection, supervision, assistance, guidance, or training essential for daily living. The City of Lake Forest Zoning Code refers to residential care facilities as “community care facilities.” “Small” community care facilities (those serving six or fewer clients) are permitted by right in all residential zones and in the A1 zone subject to the same development standards and permit processing requirements as other residential uses in those zones, pursuant to the California Lanterman Developmental Di sabilities Services Act. “Large” community care facilities (those serving se ven or more clients) are permitted with a use permit in the Commercial, Urban Activity, and Agriculture (A1) zones. In order to implement a barrier-free definition of family, Program 7 states that the Zoning Code shall be revised to remove all references to residential care facilities.

In 2017, residential care facilities were separated out of residential zones and transitory-lodging uses in residential districts were included in conformance with State law. Program 7 states that the Zoning Code shall be revised as necessary to ensure that transitional and supportive housing are allowed in residential and mixed-use zones subject to the same standards as a residence of the same type in the same zone consistent with Government Code Section 65583(c)(c)(3).

Farm Worker Housing: Although the City of Lake Forest is not located within a major agricultural area, the City’s Zoning Code includes two districts that allow agricultural uses (A1 and OS). Pursuant to the California Employee Housing Act and consistent with Health and Safety Code Section 17021.6, facilities with up to 36 beds in a group-quarters or 12 units or spaces to board farm workers are treated as accessory or incidental to agriculture operation and permitted in the same manner as agricultural uses. The City permits Agriculture Employee Quarters in the A-1 and OS zones by right.

As included in Program 7 of the Housing Plan, the Zoning Code will be updated to define “agricultural worker housing” and to stipulate that any agricultural worker housing providing no more than 36 beds in a group- quarters, or consisting of 12 or fewer units or spaces, shall be deemed an agricultural land use and permitted in the same manner as agricultural uses consistent with Health and Safety Code Section 17021.6. The Zoning Code will also be updated to provide for streamli ned, ministerial approval of agricultural worker housing that meets the requirements of Health and Safety Code Section 17021.8.

As included in Program 7 of the Housing Plan, the Zoning Code will be updated to define “employee housing” distinctly from “agricultural work er housing” and to clarify that employee housing serving six or fewer employees shall be deemed a single-family structure and shall be subject to the same standards for a single- family residence in the same zone.

Emergency Shelter: Emergency shelters are allowed by-right (i.e., ministerial approval) in the Industrial (I) zone, subject to compliance with objective standards consistent with the requirements identified in Government Code Section 65583(a)(4).

No emergency shelters are currently located within Lake Forest. While all of the City’s Industrial parcels are developed (consistent with all other areas of the City), there are vacancies within existing buildings, allowing for potential adaptive reuse of existi ng space. These parcels are infill sites in developed areas and are suitable for emergency shelters. Water, sewer, and utilities are available in the road ways adjacent to these parcels.

The I zone is suitable for emergency shelters because:
 Shelters are compatible with a range of uses t hat are common in suburban communities and allowed in the I zone (e.g., office buildings, religious institutions, child or day care, commercial or vocational schools, warehousing, libraries, civic or government uses, etc.);  I zoned parcels are served by public bus routes th at connect to regional transit with an average Item: 11
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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-82
distance of 0.29 miles from each parcel to a bus stop;
 Existing uses in the I zone are primarily light industrial, warehousing, and office uses – no heavy industrial uses are present; and
 The parcels are not known to be constrained by the presence of hazardous materials either on or adjacent to the properties.

As included in Program 7 of the Housing Plan, the Zoning Code will be updated to require sufficient parking to accommodate all staff working in an emergency shelter, provided that the standards will not require more parking for emergency shelters than other residential or commercial uses within the same zone, in compliance with Government Code Section 65583(a).

Low Barrier Navigation Center: A low barrier navigation center is 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 experienci ng homelessness to income, public benefits, health services, shelter, and housing. AB 2162 amended Government Code Section 65583 to require jurisdictions to streamline approval of eligible low barrier navigation center applications in areas zoned for mixed-use and residential zones permitting multifamily uses, subject to specific criteria. As in cluded in Program 7 of the Housing Plan, the Zoning Code will be updated to define and permit low-barrier navigation centers consistent with the requirements of Government Code Sectio ns 65660 through 65668, including treating low-barrier navigation centers as a by-right use in areas where multifamily or mixed uses are permitted Transitional and Supportive Housing: Transitional housing is a type of housing used to facilitate the movement of homeless individuals and families to permanent housing. Transitional housing can take several forms, including group quarters with beds, single-fa mily homes, and multifamily apartments and typically offers case management and support services to return people to independent living (usually between 6-24 months). The Zoning Code defines tr ansitional housing as “buildings configured as rental housing developments but operated under [multifamily housing] program requirements that call for the termination of assistance and recirculation of the assisted unit to another eligible program recipient at some predetermined future point in time, which shall be no less than six (6) months” This definition is consistent with Government Code Section 65582(j).

According to the National Housing Institute, suppo rtive housing is permanent housing with a service component, which can be provided either on-site or off-site. The Zoning Code defines supportive housing as “housing with no limit on length of stay, that is occupied by the target [homeless] population, and that is linked to on-site or off-site services that assist the supportive housing resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community.” The target population may include persons with disabilit ies, elderly, youth aging out of the foster system, veterans, and homeless. The City’s definition is consistent with Government Code Section 65582(g).

Senate Bill 2 amended Government Code Sections 65582, 65583, and 65589.5 and provides that transitional housing and supportive housing that is a rental housing development constitutes a residential use. It requires zoning to treat such uses as a residential use and s ubject only to those restrictions that apply to other residential uses of the same type in the same zone. Included as Program 7 of the Housing Plan, the Zoning Code shall be revised to ensure that transitional and supportive housing is allowed in residential and mixed- use zones subject to the same standards as a residence of the same type in the same zone consistent with Government Code Section 65583(c)(3), and to allow eligib le supportive housing as a by-right use in zones where multi-family and mixed uses are permitted pursuant to Government Code Sections 65650 through 65656.

Single-Room Occupancy (SRO): Single-room occupancy (SRO) fac ilities are a housing type that is considered suitable to meet the needs of extremely low, very low, and low-income households. With high Item: 11
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housing costs, many communities in California are exploring the use of single-room occupancy housing to fulfill the affordable housing needs of certain segments of the community, such as seniors, students, and single workers. The Lake Forest Zoning Code defines an SRO unit as follows:

A building with a common entrance containing a cluster of at least five (5) rental units which provide sleeping and living facilities for one (1) or two (2) persons where kitchen and/or bathroom facilities may be shared.

The units shall have a minimum of one hundred (100) net square feet of space for single occupancy and one hundred twenty (120) square feet for two-person occupancy. The calculation for floor space in the sleeping area includes built-in cabinets, sinks, and closets but excludes toilet compartments. A unit larger than two hundred twenty-five (225) square feet shall be deem ed an efficiency dwelling unit and not a Single-Room Occupancy (SRO).

SROs are permitted in the Commercial (C) and Urban Activity (UA) zones subject to a Site Development Permit, and in the Industrial (I) zones subject to a Use Permit. Standards for SROs are addressed in Zoning Code section 9.146.150. Requirements relate to the performance of the facility, such as parking, security, and management.

Housing for Disabled Persons: On January 1, 2002, SB 520, which amended Government Code Section 65589.5 and added sections 65913.5 and 65913.6 and C hapter 4.35 became effective and required local jurisdictions to analyze local government constraints on developing, maintaining, and improving housing for persons with disabilities. In accordance with SB 520 and Government Code 65583(a)(7), the City recognizes the importance of providing housing for persons with disabilities. Persons with disabilities have a number of specific housing needs, including those related to des ign and location. Design needs generally include the removal of architectural barriers that limit the accessibility of dwelling uni ts, and construction of wheelchair ramps, railings, etc. Location needs include accessibility to public transportation, commercial services, health care, and supportive services. Some persons with disabilities need group housing opportunities, especially those who are lower-income or homeless. The following discussion addresses these issues and determines that no specific City policy or regulation serves to impede the access that persons with disabilities have to housing that suits their specific needs.

Zoning and Land Use: The General Plan and Zoning Code provide for the development of multifamily housing with four or fewer units in the R2/R4 zones by right, as well as in the RP zone by Use Permit. Multifamily housing with five or more units are permitted in the R2/R4 zones subject a Site Development Permit.

Traditional multifamily housing for persons with spec ial needs, such as apartments for the disabled, are considered regular residential uses permitted in th ese zones. The City’s land use policies and zoning provisions do not constrain the development of such housing.

Under the Lanterman Developmental Disabilities Se rvices Act (Lanterman Act), small State-licensed residential care facilities for six or fewer persons must be permitted in all zones that allow single or multifamily uses, subject to the same permit processing require ments and development standards. The City of Lake Forest Zoning Code treats small residential care homes as a single-family residential use permitted by right in residential zones, in compliance with the Lanterman Act. Large residential care facilities serving seven or more clients are allowed in the A1 zone. Occupancy standards for residential care facilities are the same as occupancy standards for all other residential uses. The Zoning Code also accommodates transitional and supportive housing in all residential districts subject only to the same requirements for residential uses of the same type (e.g., single-family or mu ltifamily) in the same zone. These facilities may serve persons with disabilities.

Building Code: Building construction and procedures within Lake Forest are required to conform to the current California Building Code, as adopted in Title 8 of th e City’s Municipal Code. Standards within the Building Code include provisions to ensure accessibility for persons with disabilities. These standards are consistent with the Americans with Disabilities Act (ADA). No local amendments that would constrain accessibility or Item: 11
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increase the cost of housing for persons with disabilities have been adopted and City officials are not aware of any instances in which an applicant experienced delays or rejection of a retrofitting proposal for accessibility to persons with disabilities.

Reasonable Accommodation: Both the federal Fair Housing Act and the California Fair Employment and Housing Act direct local governments to make reasonable accomm odation (i.e., modifications or exceptions) in their zoning laws and other land use regulations to allow disabled persons an equal opportunity to use and enjoy a dwelling. For example, it may be a reasonable accommodation to waive a setback requirement so that elevated ramping can be constructed to provide access to a dwelling unit for a resident who has mobility impairments.

Whether a particular modification is reasonable depends on the circumstances and must be decided on a case- by-case basis.

Reasonable accommodation refers to flexibility in standards and policies to accommodate the needs of persons with disabilities. The City’s zoning and buildi ng codes, as well as approach to code enforcement, allow for special provisions that meet the needs of per sons with disabilities without the need for variances.

The City’s Reasonable Accommodation Ordinance is codified in Chapter 9.224 of the Zoning Code.

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The City’s Director of Community Development has administrative/ministerial authority to hear and decide applications for reasonable accommodation to allow reasonable remedy from zoning and other land use regulations, policies, and procedures for individuals with physical or mental impairment. 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.

Lake Forest Municipal Code Section 9.224 outlines the process for reasonable accommodation applications.

Conclusion: Current planning policies and zoning regul ations have mitigated potential constraints to the availability of housing for persons with disabilities. The City has analyzed its Zoning Code and procedures to ensure that it is flexible, and not constraining the development of, housing for persons with disabilities.

Development Standards
Development standards directly shape the form and intensity of residential development by providing controls over land use, heights and volumes of buildings, open space on a site, etc. Site development standards also ensure a quality living environment for all household groups in the City, including special groups such as lower and moderate-income households and senior citizens.

Residential Parking Requirements
Parking standards are an important development regulation in communities. The City’s parking requirements are intended to ensure that adequate off-street parking and loading facilities are provided in proportion to the need created by the type of use. Adequate parking for residential projects contributes to the value of a project, the safety of residents, and the quality of a project’s appearance. However, excessive parking standards can pose a significant constraint to the development of housing because they can reduce the buildable area on a site and impact the funding available for project amenities or additional units. The parking requirements for residential and mixed-use developments, as applicable in September 2021, are shown in Table 55.

TABLE 55: RESIDENTIAL PARKING REQUIREMENTS
Use Requirement Additional Regulations
Single-Family Dwelling  2 covered spaces
Those dwellings having less than
an eighteen (18) foot setback from
the back of curb or sidewalk,
whichever is closest to the garage
or carport, shall provide one (1)
additional parking space within
two hundred (200) feet of the
dwelling. On-street parking, where
permitted, may be used for the
additional space.

Multifamily (2+ units)*
 0 – 1 bdrm: 1.5 spaces per du
 2 bdrm: 2 spaces per du
 3+ bdrm: 2.5 spaces per du + 0.5 per
bedroom in excess of 3
 In addition to above, add 0.2 guest parking
spaces per dwelling unit (rounded to the
nearest whole number)
 For multifamily projects of 5+
units, requirement that off-
street parking spaces be
covered is not applicable
Multifamily (5+ units)*
Unit Size (square
feet)
700 or less:

Assigned

1.0 1.0
Unassigned

+0.17
 For Multifamily projects with
5+ units, off-street parking
requirements may be used in
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701-800
801-900
901-1,000
1,001-1,100
1,101-1,200
1,201-1,300
1,301-1,400
1,401-1,500
Over 1,500

1.0 1.0

1.0 1.0
+0.34
+0.50
+0.67
+0.84
+1.00
+1.18
+1.34
+1.5
lieu of Multifamily (2+ units)
above
 For multifamily projects of 5+
units, requirement that off-
street parking spaces be
covered is not applicable
 In addition to above, add 0.2
guest parking spaces per
dwelling unit (rounded to the
nearest whole number)
Accessory Dwelling Unit  1 space per ADU
 No spaces required for JADU
No parking is required if ADU is:
 Located within 0.5-mile
walking distance of public
transit
 Located within an
architecturally and historically
significant historic district
 Part of the proposed or
existing primary residence or
an accessory structure
 When on-street parking
permits are required but not
offered to the occupant of the
ADU
 When there is a car share
vehicle located within one
block of the ADU
Congregate care facility
serving more than 12
persons
1 space per unit --
Affordable Housing
Projects Using Density
Bonus
 0 - 1 bdrm: 1 on-site parking space
 2 - 3 bdrm: 2 on-site parking spaces
 4+ bdrm: 2.5 on-site parking spaces
--
Sources: City of Lake Forest Zoning Code, 2021.

Pursuant to State law, the City provides development incentives for projects that include affordable housing units and may waive or reduce the parking requirements for such projects. The Director of Community Development may approve a parking reduction of up to five (5) percent of the total parking requirement for the sole purpose of accommodating modifications to an existing development to meet current legal requirements or regulations for purposes of accessibility and safety. The Planning Commission may approve parking reductions of up to ten (10) percent, subjec t to certain provisions. Moreover, affordable housing developments that are eligible for a density bonus pursuant to Government Code Section 65915-65918 are eligible to use parking standards established by State Density Bonus law.

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DEVELOPMENT PROCESSING PROCEDURES
The time and cost of permit processing and project re view can be a constraint to housing development if significant development review is required. Project review and permit processing are necessary steps to ensure that residential construction complies with applicable codes, standards. The time required for project approval is often not so much a factor of the approval body (e.g., Director versus Planning Commission), but the complexity of the project and associated environmental review. However, small infill projects that can be approved administratively are generally less complex and take a shorter time to obtain appropriate approvals.

Larger and more complex projects like mixed-use development or residential subdivision maps subject to the California Environmental Quality Act (CEQA), require a public hearing before the Planning Commission.

Projects reviewed by the Planning Commission, including Site Development Permits, Tentative Parcel Maps, and Tentative Tract Maps, typically require between 3 to 12 months to process. Projects reviewed by the City Council, such as General Plan and Zoning Code amendments, typically require between 6 to 12 months to process.

The City has and continues to take proactive steps to facilitate efficient development process. As part of the General Plan Update, the City prepared a program environmental impact report (EIR) that future applicants may rely upon, resulting in significant time and finan cial savings. The City reviews all applications for development prior to issuance of building permits to ensure projects contribute in a positive manner to the community and improve quality of life. Residentia l development projects may be subject to approvals – ministerial or discretionary (either with or without a public hearing). For most property in Lake Forest, new residential development with fewer than five units is permitted by right, provided the project adheres to the development standards of the zone. Projects with five or more units require approval of a Site Development Permit by the Planning Commission. The discretionary process allows the project to be reviewed for appropriateness, scale, architecture, site design, and compatib ility with the surrounding area. The City is currently (2021) preparing objective design standards consistent with the requirements of SB 35 Streamlined Permitting (Government Code Sections 65400 and 65582.1) requirements. This section outlines the timeline for typical residential development review and describes the permitting requirements and procedures for Site Development Permits, Use Permits, Subdivision Maps, etc. Based on the development activity during the 5 th
Cycle RHNA period, the City’s processing and permitting procedures do not appear to unduly constrain the development of housing.

DISCRETIONARY PERMITS
A discretionary permit is a permit issued or approved by the City of Lake Forest as the result of an application the City retains the right to approve or disapprove. Se ction 9.184 of the Municipal Code specifies the City’s Discretionary Permit process, including the pr ocedures and requirements for discretionary permit applications and the basis or “findings” for decisions regarding such applications.

FEATURE PLANS
A feature plan is a plan which conceptually describes, graphically and/or in writing, a proposed development for an identified and relatively large area of real proper ty. The purpose of a feature plan is to describe how significant natural and man-made features will be preserved or developed and how large-scale planning issues of special concern (e.g., traffic) will be add ressed. All subsequently ad opted discretionary permits (e.g., area plans) and subdivision maps shall be consistent with the feature plan.

Feature plans shall be processed initially to the City Council. The Planning Commission shall be the approving authority for feature plan amendments, ex cept when the commission finds that an amendment application proposes a change in policy from the or iginally approved feature plan, such amendment application shall be acted upon by the City Council.

After the date of final determination and after compliance with the Municipal Code, the policies and concepts of an approved feature plan shall be applicable to the property included within the boundaries of the feature Item: 11
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plan until such time as the feature plan is amended or the applicable zoning regulations are revised so that the feature plan is no longer valid. All grading, deve lopment and improvements shall be in substantial conformance with the currently approved feature plan.

AREA PLANS
An area plan is similar to a feature plan except that an area plan contains relatively more detailed information and addresses a relatively smaller area of real proper ty. A feature plan may or may not be required prior to the approval of an area plan. An area plan for a planned community or specific plan may have less restrictive site development standards if allowed by the enabling ordinance. The Planning Commission is the approving authority for all area plan applications and amendments.

After the date of final determination and after complia nce with the Municipal Code, an approved area plan shall be applicable to the development of all real proper ty included within the boundaries of such area plan until such time as it is amended or rendered invalid by amendment of the zoning regulations or feature plan applicable to the property. All grading, development and improvements shall be in substantial conformance with the provisions of the currently approved area plan.

USE PERMITS
The purpose of a use permit is to provide for the public review of detailed final plans for a proposed use.

Uses which require a use permit are regarded as having a relatively moderate to high potential for adverse impacts on the subject site or surrounding community due to the nature of magnitude of the use vis-à-vis the sensitivity of the subject site or surrounding community. Use permits shall require a public hearing. If the land use regulations of a planned community or a specific plan allow a use permit to modify the site development standards to be less restrictive than otherwise stated in the enabling ordinance, such a use permit shall always require a public hearing before the Planning Commission.

SITE DEVELOPMENT PERMIT
The purpose of a site development permit is to prov ide for the administrative (or discretionary review, if applicable) of detailed development plans for a proposed use. Uses which require a site development permit are regarded as having a relatively low potential for adverse impacts on the subject site or surrounding community due to the nature or magnitude of the use vis-à-vis the sensitivity of the subject site or surrounding community.

A site development permit shall be processed as an administrative action, unless the Director of Community Development determines on a case-by-case basis that the public interest would be better served by a public hearing before the Planning Commission. If the land use regulations of a planned community or a specific plan allow a site development permit or site plan to modify the site development standards to be less restrictive than otherwise stated in the enabling ordinance, such a site development permit shall always require a public hearing before the Planning Commission.

Establishment, maintenance, and operation of the use or uses proposed by the application shall be in compliance with the information and specifications shown on the approved site development permit.

FINDINGS
The following findings shall be made by the approving authority prior to the approval of any discretionary permit:
 General Plan. The use or project proposed is consistent with the General Plan.  Zoning Code. The use, activity or improvement(s) proposed by the application is consistent with the provisions of the Zoning Code.
 CEQA. The approval of the permit application is in compliance with the requirements of the California Item: 11
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Environmental Quality Act.
 Compatibility. The location, size, design and operat ing characteristics of the proposed use will not create significant noise, traffic or other conditions or situations that may be objectionable, detrimental or incompatible with other permitted uses in the vicinity.

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 General Welfare. The application will not result in conditions or circumstances contrary to the public health and safety and the general welfare.
 Development Fees for Provision of Public Facilitie s. One (1) of the following findings shall be made:
o The property to which the permit applies is not located in a fee area. o The permit would not allow development of a project which would contribute to the need for the facility for which a fee is required.
 The project has been reviewed in accordance with Citywide Design Guidelines and is consistent with the purpose and intent of the guidelines.

As previously stated, the City is currently (2021) preparing objective design standards for by-right residential development, which will change the project review process. Please refer to the City for more information regarding the most current requirements.

TYPICAL TIMEFRAMES
Table 56 outlines the typical processing times for singl e-family and multifamily projects with and without preparation of a robust environmental document.

TABLE 56: TYPICAL PERMIT PROCESSING TIMES AND REVIEWING BODY Project Type
Processing Time without
Negative Declaration/EIR Processing Time with Negative
Declaration/EIR
Single-Family Dwelling 3-6 weeks N/A
Multifamily (Four or Fewer Units) 1-3 months 9-18 months Multifamily (Five or More Units) 3-6 months 9-18 months Source: City of Lake Forest, 2021
The length of time between the project approval and request for a building permit is minimal. Specifically, there is a 15 day appeal period following approval of a discretionary permit. In certain circumstances, a “hold harmless” letter may be filed and an applicant may submit their building plans with the understanding that fees may be lost if an appeal results in denial of the projectis filed.

Discretionary permits subject tothat require approv al by the Director of Community Development is approximatelytypically require 4-6 weeks for processing. Discretion ary permits subject to Planning Commission approval are processed in approximately 4-6 months.

Subdivisions
This review process applies to all residential land divisions within the City. Title 7 of the Lake Forest Municipal Code includes the standards and processes for subdivis ions. It is based primarily on the State Subdivision Map Act. As it relates to residential development, the regulations apply to all land divisions that create lots for single-family homes and lots, or condominiums, for multifamily development. As part of the review process for subdivisions, the City reviews applications for compliance with lot size and shape standards, the general layout of the subdivision, and infrastructure requirements. If the project complies with the subdivision standards and General Plan density, the project can proceed through the approval process.

Reasonable Accommodation
The City’s process for providing reasonable accommodation allows individuals, or their representatives, to make requests for reasonable accommodations for per sons with disabilities. Requests for reasonable accommodation are approved administratively unless the r equest also requires a permit or entitlement requiring Planning Commission or City Council approval. City staff is available to provide assistance regarding the processing of requests for the construction of a ccessory structures intended to accommodate persons with disabilities.

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The City amended its Zoning Ordinance in 2007 to establish the process for requesting and granting reasonable accommodations for persons with disa bilities. Requests for reasonable accommodation are subject to review and approval by the Director of Community Development. The Community Development Department provides assistance with applying for a reasonable accommodation to those who need it. The request must state the basis of the request, including t he modification(s) or exception(s) to the regulations, standards or practices for the siting, development or use of housing or housing related facilities that would eliminate regulatory barriers and provide an individual with a disability equal opportunity to housing of his or her choice.

Lake Forest’s reasonable accommodation procedure does not require a public hearing when the reasonable request is made on its own (if it was to be combin ed with entitlement, then a hearing would be required related to the entitlement request) and preserves privacy laws and fair housing laws. Only owners of abutting properties are notified of reasonable accommodation requests and approvals not subject to a public hearing.

Lake Forest’s reasonable accommodation procedure complies with Housing Element law and provides for disabled residents to make necessary changes to their properties.

The City’s reasonable accommodation process requires the requester to provide a letter specifying the request and an explanation of how the request will provide reasonable accommodation in the application of the City’s zoning laws to afford a disabled person(s) an equal opportunity to use and enjoy a dwelling within the City. If the requester is unable to prepare a written request, the requester can make an oral request to Staff and Staff will work with the requester to prepare the necessary written material. The City has and will continue to give appropriate consideration to re asonable accommodation request s even if the requester makes the request orally or does not use the City’s preferred forms or procedures. Depending on the nature of the request, plans may be required to clearly illustra te the request. The City does not charge a fee for a request for reasonable accommodation. Within 5 days of receipt of the letter and plans (if applicable) the City will notify the applicant if any additional information is necessary to complete the application.

A decision for a request for a reasonable accommodati on will be determined by the Director of Community Development within 30 days of receipt of the application that was deemed complete. With the exception, that when the request is part of an entitlement requiring Planning Commission or City Council review, the request will be processed with the entitlement. A decision for a request for a reasonable accommodation must be approved if the request meets the following criteria:

1. The accommodation is reasonable, consideri ng the nature of the applic ant’s disability, the surrounding land uses, and the rule, standard, policy or practice from which relief is sought;

2. The accommodation is necessary to afford the applicant equal opportunity to enjoy and use a dwelling;

3. The accommodation will have only incidental econ omic or monetary benefits to the applicant, and the primary purpose of the accommodation is not to assist with real estate speculation or excess profit-taking;

4. The accommodation does not create a substantial adverse impact on surrounding land uses, or a public nuisance, that cannot be reasonably mitigated;

5. The accommodation is reasonably feasible, consid ering the physical attributes of the property and structures;

6. There are no alternative accommodations which may provide an equivalent level of benefit to the applicant, while minimizing adverse impacts on surrounding land uses and lessening the financial and/or administrative burden on the City;

7. In the case of a determination involving a one (1 ) family dwelling, whether the household would be considered a single housekeeping unit if it were not using special services that are required because of the disabilities of the residents;
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8. The requested accommodation does not impose an undue financial or administrative burden on the City; and

9. The requested accommodation does not require a fu ndamental alteration in the nature of a program. (Ord. 176 § 1, 2007)
The City has evaluated its reasonable accommodate procedure for compliance with fair housing laws and has included Program 7 to update its procedures to co mply with fair housing laws and ensure that the procedure does not pose a constraint to the housing for persons with disabilities.

ENVIRONMENTAL REVIEW
The City has adopted procedures for complying with the requirements of the California Environmental Quality Act (CEQA), including assessing the potential env ironmental impacts of development applications determined to be a “project” as defined by Public Re sources Code 21000-21177. Environmental review is required for most discretionary actions including Us e Permits, Subdivision Maps, and legislative actions including General Plan amendments, zone changes, and code amendments. Environmental review occurs while the application is being processed. An environmental determination by City staff for a project is made to prepare the appropriate environmental document for consideration by the decision-making authority.

Certain classes of residential projects may be categorically exempt from the provisions of CEQA or require only an Initial Study and Negative Declaration. The envir onmental review of categorically exempt projects requires a minimal amount of time and does not pose a significant constraint to housing development.

In 2020, the City adopted a comprehensive update to its General Plan and certified a Program Environmental Impact Report (EIR) which analyzed the potential impacts associated with implementation of the General Plan Land Use Map. Environmental documents for projects which are consistent with the densities and intensities analyzed under the General Plan Program EI R may tier off the analysis included in the General Plan EIR, which could significantly reduce the time and costs associated with preparation of required environmental documents. By proactively planning to accommodate new residential development throughout the City and analyzing the potential impact s of such development as part of the Program EIR, the City has helped to streamline the environmental review and approval process.

STREAMLINING APPROVALS
Lower Income Sites Included in Previous Elements
While the Development Review process is not cons idered a constraint to housing, Policy 1.8 has been included to comply with Government Code 65583.2. This program will allow by-right approval of housing developments proposed on non-vacant sites included in the previous housing element inventory and on vacant sites included in the two previous housing el ement inventories, provided that the proposed housing development includes at least 20 percent lower-income affordable housing units. This will increase certainty for affordable and multifamily developers related to residential sites throughout the community, as identified in Appendix A.

Senate Bill (SB) 35
SB 35 (Government Code Sections 65400 and 65582.1 provides provisions for streamlining projects based on a jurisdiction’s progress towards its RHNA allocation and timely submittal of the Housing Element Annual Progress Report. Jurisdictions that have made insuffic ient progress toward their above moderate-income RHNA allocation and/or have not submitted the latest Housing Element Annual Progress Report are subject to the streamlined ministerial approval process for proposed developments with at least 10% affordability.

HCD reviews the annual progress report deadlines and R HNA progress on an annual basis. Lake Forest is currently subject to SB 35 streamlining provisions when proposed developments include at least 50% affordability. Program 7 in the Ho using Plan has been provid ed to incorporate the mandatory streamlining provisions into the City’s Zoning Code. These streamlining provisions will reduce approval requirements for Item: 11
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projects that include a minimum of 50% of units affo rdable to lower income households and that meet the criteria specified by State law.

FLEXIBILITY IN DEVELOPMENT STANDARDS
Development standards affect the financials of a re sidential project, both from the revenue side (through achievable density) and through the costs of complying with specific development standards. However, there is no specific threshold that determines whether a par ticular standard or set of standards constrains the affordability or supply of housing. Many factors determi ne project feasibility. While prior sections discussed how to reduce development costs, the following describes ways that the Zoning Code offers flexibility in development standards.

Residential Density Bonus
The City Zoning Code allows density bonuses and other incentives for affordable and senior residential projects in accordance with State Density Bonus law. Section 9.152.010 of the Zoning Code incorporates by reference the procedures for providing density bonus or other incentives in compliance with state law (Government Code §65915 et seq.).

Condominium Conversions
In order to ensure a variety of housing opportunities (ownership and rental) including low-density single- family homes, moderate-density townhomes, higher-den sity condominiums and mobile homes, Chapter

9.172 of the City’s Zoning Code provides the following requirements for proposed condominium conversions:
 A requirement for a condominium use permit approved by the City Council (if five or more units);  Compliance with the applicable standards and requirements of the zoning district is which the project is located;
 The provision of a tenant purchase option;
 The payment of relocation expenses of $1,500 in 2006 dollars adjusted annually in accordance with the Consumer Price Index;
 A requirement to submit an affordable housing implementation plan which incorporates a minimum of 15% affordable units (either rental or ownership); and  A general prohibition on conversions (with specif ied overriding considerations) that becomes effective when the average rental vacancy rate within the City during the 12 preceding months is 4% or greater.

When a condominium conversion is permitted, the increase in the supply of less expensive for sale-units helps to compensate for the loss of rental units. One condominium conversion has been approved since adoption of amended condominium conversion standards in 2006. This demonstrates that the ordinance regulating condominium conversions is reasonable to preserve rental housing opportunities, and does not present an unreasonable constraint on the production of ownership housing.

Short-Term Rentals
Short-term rentals are defined in the Lake Forest Municipal Code under “Transitory-Lodging Use.” Transitory- Lodging is prohibited in the City of Lake Forest. Nonetheless, there were 21 short-term rentals in Lake Forest listed on Airbnb.com in July 2021; however, only six of t he rentals were for an entire apartment or condominium. The other 15 rentals were limited to a room or suite within a home and do not decrease the amount of housing stock available for permanent occupancy. A significant number of short-term rentals has the potential to affect the availability of housing stock. Therefore, this will be an issue that the City continues to monitor to ensure it does not negatively impact permanent housing options in the City.

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BUILDING CODES AND ENFORCEMENT
New construction in Lake Forest, including additions and remodels, must comply with the current edition of the California Building Code (CBC). The City continue s to adopt the most recent CBC with all required updates. The CBC establishes construction standards necessary to protect public health, safety, and welfare, and the local enforcement of this code does not unduly constrain development of housing. The 2019 California Building Code, Title 24, Part 2, Volumes 1 and 2, published by the International Code Council, was adopted by the City by reference as Title 8 of the City’s Municipal Code and subject to the amendments contained in that title.

No local amendment to the CBC has been initiated or approved that directly impacts housing standards or processes. Code enforcement is conducted by City staff which is responsive to complaints from community members. The City maintains records of code comp laints and works proactively in neighborhoods where violations are most prevalent to address potential iss ues before they become significant. The City enforces its code equitably and as necessary throughout the community. Program 16 in the Housing Plan helps support homeowners with rehabilitating substandard housing. The Code Enforcement and Building Divisions assist property owners with meeting State health and safety codes.

DEVELOPMENT FEES AND IMPROVEMENT REQUIREMENTS
State law limits fees charged for deve lopment permit processing to the reasonable cost of providing the service for which the fee is charged. Various fees and assessments are charged by the City and other public agencies to cover the costs of processing permit applications and providing services and facilities such as schools, parks, and infrastructure. Almost all these fees are assessed through a pro rata share system, based on the magnitude of the project's impact or the extent of the benefit that will be derived.

For new residential projects, developers in Lake Forest may be required to pay one or more of the following fees depending on the location, type, and size of the project:

Planning, Building, and Environmental Fees: In accordan ce with the adopted fee schedule, developers are charged standard fees for plan check, entitlement application processing, building permits, environmental impact studies, and other applications commensurate with the cost of processing such applications, conducting inspections, and performing other associated tasks.

Regional Agency Fees: Regional agency fees include water and sewer fees collected by the water district and sanitation district, and school impact fees collected by the school districts as allowed by State law to finance the construction and expansion of schools to accommodat e student enrollment. The water, sanitation, and school districts have the authority to set their respective fees. The City does not have any ability to adjust these fees. Regional agency fees also include transportation agency fees, including the Foothill Circulation Phasing Plan, Foothill Eastern Transporta tion Corridor, Santiago Canyon Road, and El Toro Road program fees.

Regional agency fees corresponding to a multifamily affordable housing project approved in 2021 (“Mountain View”, 71 units) totaled approximately $19,000 per unit. Some regional agency fees vary based on the product type (single-family or multifamily), but differences are relatively minor and the regional agency fee corresponding to the Mountain View project is representative of fees for both residential types. Table 57 lists fees the City charges for new, standard residential development.

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TABLE 57: PLANNING AND DEVELOPMENT FEES (EFFECTIVE 08/16/2021)

Source: City of Lake Forest, 2021
Note: This is only a partial list of typical Planning fees. *Time and Materials
Table 58 identifies typical fees that would be co llected per unit for hypothetical new single-family and Entitlements
Planning and Application Fees
Accessory Dwelling Unit (ADU) Permit $500 fee
Pre-Application Review $2,500 deposit
Tentative Parcel Map $7,500 deposit
Tentative Tract Map $10,000 deposit
Site Development Permit (administrative) $2,500 deposit Site Development Permit (discretionary) $5,000 deposit
Site Development Permit (not except from CEQA) $10,000 deposit Use Permit (minor) $2,5001 deposit
Use Permit (major) $5,0001 deposit
Use Permit (not except from CEQA) $10,000 deposit
Specific Plan $10,000 deposit
General Plan Amendment $10,000 deposit
Development Agreement $10,000 deposit
Zone Change $10,000 deposit
Area Plan $10,000 deposit
Feature Plan $10,000 deposit
Variance $5,000 deposit
Public Works
Lot Line Adjustments $2,000 deposit
Grading Plan Check and Inspection $2,500 deposit
Water Quality Management Plan $1,000 deposit
Map Checking $3,500 deposit
Environmental
Environmental Review (Initial Study, Neg. Dec., EIR, etc.) Deposit TBD T&M* plus 15% admin fee
Peer-Reviewed Technical Studies Deposit TBD
T&M* plus 15% admin fee
Hourly Rate for Deposit Based Services
Planning (In-House and Contract Service Planning) $143/hr Public Works In-House Land Development Review $158/hr
Building and Safety $140/hr
City Clerk Dept. Billing Rate for Development Review $78/hr City Manager Dept. Billing Rate for Development Review $101/hr Community Services Development Review Services $176/hr
Finance Development Review Support $83/hr
IT / GIS Development Review Support $105/hr
Code Enforcement Divisional Billing Rate for Development Review Direct Services $78/hr
Police Dept. Billing Rate for Development Review $90/hr Contract Service Support (e.g. Attorney, Contract
Engineering, etc.) T&M* plus 15% administrative
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multifamily development projects, based on the fees in effect in 2021 (see Item: 11
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Table 57). Development fees in this example ma ke up approximately less than 3% percent of a home purchase price. Because the City does not have development impact fees, Lake Forest fees are typically less than most surrounding communities.

TABLE 58: PROPORTION OF FEE IN OVERALL DEVELOPMENT COST FOR A TYPICAL RESIDENTIAL DEVELOPMENT (2021)
Development Cost for a Typical Unit Single -Family (50 units) Multifamily (140 units) Typical City of Lake Forest estimated
fees per unit
$535 $188
Typical regional agency fees estimated
per unit
$19,000 $19,000
Total typical fees per unit $19,535 $19,188
Source: City of Lake Forest, 2021
The City periodically evaluates the actual cost of pr ocessing development permits when revising its fee schedule. The last review and update occurred in 2021.

After the passage of Proposition 13 and its limitation on local governments’ property tax revenues, cities and counties have faced increasing difficulty in providing public services and facilities to serve their residents.

One of the main consequences of Proposition 13 has be en the shift in funding of new infrastructure from general tax revenues to development impact fees a nd improvement requirements on land developers. The City requires developers to provide on-site and off-site improvements necessary to serve their projects. Such improvements may include water, sewer and other utility extensions, street construction and traffic control device installation that are reasonably related to the project. Dedication of land or in-lieu fees may also be required of a project for rights-of-way, transit facilities, recreational facilities, and school sites, consistent with the Subdivision Map Act.

A typical local street requires a 60-foot right-of-way, with two 18-foot travel lanes. The City’s road standards are typical for cities in Orange County and do not act as a constraint to housing development. Table 59 illustrates the City’s road improvement standards.

TABLE 59: ROAD IMPROVEMENT STANDARDS
Roadway Designation Number of Lanes Ri ght-of-Way Width Curb-to-Curb Width Principal Arterial 8 140’ 120’
Major Arterial 6 120’ 102’
Primary Arterial 4 100’ 84’
Secondary Arterial 4 80’ 64’
Local Street 2 60’ 36’
Source: City of Lake Forest, 2021
The City’s Capital Improvement Program (CIP) contains a schedule of public improvements including streets and other public works projects to facilitate the continued buildout of the City’s General Plan. The CIP helps to ensure that construction of public improvements is coordinated with private development.

Although development fees and improvement requirements increase the cost of housing, cities have little choice in establishing such requirements due to the limitations on property taxes and other revenue sources needed to fund public improvements.

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4B. Non-Governmental Constraints
Non-governmental constraints refer to market factor s such as the demand for housing, the price of land, construction costs, availability of financing, and other factors that increase the cost of housing development.

DEVELOPMENT COSTS
Land Prices
The cost to develop housing is influenced by the cost of the raw land, the cost of holding the land during the development process, and the cost of providing services to meet City standards for development. The cost of raw land is influenced by variables such as scarcity , location, availability of public utilities, zoning, and unique features like trees and adjoining uses. In Orange County, undeveloped land is limited, and combined with a rapidly growing population, land prices have generally increased. A review of lots for sale and recently sold, using Zillow and LoopNet listings, found one vacant quarter-acre lot zoned for residential use in Lake Forest, zoned MDR and sold for $530,000 or approxima tely $53 per square foot (approximately $2 million per acre).

A small number of underdeveloped parcels with a single-fa mily unit that could be redeveloped with larger, single-family homes (with ADUs) or duplexes ha ve been sold for $735,000 to $1,200,000 or approximately $86 to $267 per square foot, largely depending on the location within the community.

It is difficult to ascertain the cost of raw land fo r multifamily development since there has been a limited number of recent multifamily property sales in Lake Forest. A 4-unit property (fourplex) at 23061 Village Drive sold in August 2019 for $1,425,000 or $121 per square foot ($356,250 per unit); a 2-unit property (duplex) at 23192 Saguaro Street sold in September 2019 for $1, 575,000 or $193 per square foot ($787,500 per unit); and a 5-unit property at 24512 Bendricon Lane sold in February 2020 for $1,931,500 or $200 per square foot ($386,300 per unit)
Cost of Construction
Construction cost is determined primarily by the cost of labor and materials. The relative importance of each is a function of the complexity of the construction jo b and the desired quality of the finished product. As a result, builders are under constant pressure to complete a project for as low a price as possible while still providing a quality product. This pressure has led (and is still leading) to an emphasis on labor-saving materials and construction techniques.

The International Code Council (ICC) provides estima tes for the average cost of labor and materials for typical Type VA protected, wood-frame housing. Es timates are based on “good-quality” construction, providing for materials and fixtures well above the minimum required by state and local building codes. In the 2018 edition of the Building Safety Journal, the ICC estimated that the average per square foot cost for good- quality housing was $129-167 per square foot for Type I or II multifamily construction, $113-147 per square foot for Type V (Wood Frame) multifamily construc tion, and $122-141 per square foot for Type V (Wood Frame) one-and two-family dwelling construction. Although construction costs are a substantial portion of the overall development cost, they are consistent throughout the region and therefore are not considered a major constraint to housing production. The 2020 COVID-19 pandemic social distancing guidelines may increase constructions costs for an unknown period.

Construction cost increases, like land cost increases, affect the ab ility of consumers to pay for housing.

Construction cost increases occur due to the cost of materials, labor, and higher government-imposed standards (e.g., energy conservation requirements). The development community is currently producing market rate for-sale housing that is affordable to moderate and above moderate-income households.

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Cost and Availability of Financing
Financing is critical to the housing market. Develope rs require construction financing and buyers require permanent financing. The two principal ways in which financing can serve as a constraint to new residential development are the availability and cost of construction financing and the availability and cost of permanent financing.
 If financing is not easily available, more equi ty may be required for developing new projects. This results in fewer homebuyers who can purchase homes, since higher down payments are required.  Higher construction period interest rates for developers result in higher development costs. For homebuyers, higher interest rates translate into higher mortgage payments (for the same loan amount). This in turn reduces the purchasing power of homebuyers.

On May 6, 2021, the reported average rate for a 30-year mortgage was 2.96% with 0.6 fees/points (Freddie Mac, 2021). From 2005 through 2021, average monthly mortgage rates have ranged from a high of 6.76% in July 2006 to today’s record lows. For homebuyers, it is necessary to pay a higher down payment than in the recent past, and demonstrate credit worthiness and adequate incomes, so that loan applications meet standard underwriting criteria. While adherence to strict underwriting criteria was not required during the early and mid-2000s, the return to stricter standards is consistent with loan standards prior to 2001.

Approved and Built Densities
While the City’s General Plan identifies minimum and maximum densities that can be developed in Lake Forest, individual developers may opt to build at the lower, mid-range, or higher end of allowed densities.

Additionally, the City’s Zoning Code does not prescribe minimum or maximum densities, but rather relies on other development standards (minimum lot size, maximum height, and setbacks) to shape the scale of development. Recent projects in Lake Forest that are built or are under construction are consistent with the densities anticipated by the City’s General Plan, PC Development Plans, and Zoning Code and typically built within the maximum allowable density. The City ha s received feedback from the development community that the maximum density levels are realistic and achievable, and the City requires projects be built within the allowable density.

AFFORDABLE HOUSING DEVELOPMENT CONSTRAINTS
In addition to the constraints to market rate housing development discussed above, affordable housing projects face other constraints. While there is a r ange of sites available for potential affordable housing projects, as well as projects that focus on special needs populations, financial assistance for the development of affordable housing is limited and highly competitive.

Multiple funding sources are typically needed to construct an affordable housing project since substantial subsidies are required to make the units affordable to extremely low, very low, and low-income households.

It is not unusual to see five or more funding sources assembled to make a project financially feasible. Each of these sources may have different requirements and application deadlines and some sources may require that the project has already successfully secured fi nancing commitments. Since financing is critical and generally competitive, organizations and agencies that provide funding can often effectively dictate the type and size of projects. Thus, in some years senior housing may be favored by financing programs, while in other years family housing may be preferred. Target income levels can also vary from year to year.

This situation has worsened in recent years. Federal and state funding has decreased and limited amounts of housing funds are available. Tax credits, often a fundamental source of financing for affordable housing, are no longer selling on a one for one basis. In other words, once a project has received authorization to sell a specified amount of tax credits to equity investors, the investors are no longer purchasing the credits at face value but are purchasing them at a discount.

Nonetheless, the City has been successful in collabor ating with other stakeholders for the development of Item: 11
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affordable housing in Lake Forest. For example, t he City recently entered into an affordable housing agreement with National Community Renaissance for a loan to assist with the development of the 71-unit Mountain View Affordable Housing Community. The City approved entitlements for the community with four incentives, that included reductions in the City’s development standards.

The City has collaborated through Development Agreements with several developers on affordable housing in new neighborhoods. The City has included Program 5: Facilitate Affordable and Special Needs Housing Construction, to continue this tradition and further enhance the development of affordable and special needs housing in the City. The following represent affordable housing in conjunction with the new housing developments in Lake Forest:
 Baker Ranch has an affordable housing apartment complex (The Arroyo at Baker Ranch).  The Portola Center development (under cons truction in 2021), which will be located at the intersection of Glenn Ranch Road and Saddleback Ranch Road, will feature an affordable housing complex age-restricted for senior citizens.
 “The Meadows Senior Affordable Apartments” were approved by Planning Commission on August 19, 2021. The project includes two- story 65-unit apartment complex, including 64 senior affordable units (of which 7 will be permanent supportive hous ing) and one market-rate manager’s unit and associated site improvements. The project site is located on an approximately 2.6-acre lot in the Nakase Planned Community located on the southeast corner of the intersection of Rancho Parkway and Bake Parkway.

REQUESTS TO DEVELOP AT LOWER DENSITIES
New State Housing Element law now requires the non- governmental constraints analysis to evaluate developer requests to build at densities below the density identified in the Housing Element sites inventory.

The following table presents the developed densities in recent multi-family and mixed-use projects in the Lake Forest, compared to the maximum permitted densities under zoning:

TABLE 60: COMPARISON OF ZONED AND BUILT DENSITIES
Project Zoning General
Plan
Permitted
Density
Built
Density
Percent
of Max
Sr. Housing – Meadows
(Approved but not
constructed as of 12/21)
Senior Affordable
Housing (SAH) in the
Nakase Planned
Community
High
Density
Residential
25-43 du/ac 25 du/ac 58%
Mountain View Affordable
Housing Community
(Approved but not
constructed as of 12/21)
Multifamily Dwellings
(R2)
High
Density
Residential
25-43 du/ac 36 du/ac 84%
Portola Center Senior
Housing Mixed Use
(Approved but not
constructed as of 12/21)
Mixed Use (MU) in the
Portola Hills Planned
Community
Mixed Use
43 Maximum
43 du/ac
29 du/ac 67%
Copper Leaf and Silver Oak
at Iron Ridge
Multi-Family Dwellings
(MF) in the Portola
Hills Planned
Community
Medium
Density
Residential
15-25 du/ac 18 du/ac 72%
Covera at Serrano Summit Multifamily Dwellings
(R2) with Planned
Development overlay
Medium
Density
Residential
15-25 du/ac 19 du/ac 76%
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Arieta at Serrano Summit Multifamily Dwellings
(R2) with Planned
Development overlay
Medium
Density
Residential
15-25 du/ac 21 du/ac 84%
Brookland at Baker Ranch Residential (R) in the
Baker Ranch Planned
Community
Medium
Density
Residential
15-25 du/ac 13 du/ac 52%
The Rowe and The Courts
at Baker Ranch (mix of
multi-family and single-
family)
Mixed Use (MU) in the
Baker Ranch Planned
Community
Mixed Use
43 Maximum
43 du/ac
17 du/ac 40%
The Rowe II and The
Courts II at Baker Ranch
(mix of multi-family and
single-family)
Residential (R) in the
Baker Ranch Planned
Community
Medium
Density
Residential
15-25 du/ac 16 du/ac 64%
Arroyo Apartmen ts at Baker
Ranch
Mixed Use (MU) in the
Baker Ranch Planned
Community
Mixed Use
43 Maximum
43 du/ac
30 du/ac 70%
Avalon Apartments at Baker
Ranch
Mixed Use (MU) in the
Baker Ranch Planned
Community
Mixed Use
43 Maximum
43 du/ac
30 du/ac 70%
El Paseo Condominiums Residential (R) in the
Foothill Ranch
Planned Community
Medium
Density
Residential
15-25 du/ac 20 du/ac 80%
Source: City of Lake Forest, 2021
As illustrated by this table, the City has approved and the market supports projects at the middle to upper end of the density range. However, in order to ensure future development implements densities planned for in the Housing Element sites inventory, the City has relied on a capacity adjustment of 75% based on typical densities, consistent with default densities for lower income affordability. Combined with other adjustments, the City assumes a 50% capacity at mixed-use sites based on the maximum density allowed. 4C. Environmental Constraints
According to the City’s 2040 General Plan Existing Conditions Report and General Plan Environmental Impact Report, there are multiple environmental hazards affecting residential development in the City. These hazards include geologic and seismic conditions, wildfire (which provide the greatest threat to the built environment), and human-induced hazards (including hazardous materials). The following hazards may impact development of residential units in Lake Fores t. None of the sites identified in the land inventory (Appendix A) have environmental constraints that would preclude the assumed level of development.

GEOLOGIC AND SEISMIC HAZARDS
Similar to other southern California cities, the City of Lake Forest is located in an area of high seismic activity.

Although no active or potentially active faults traverse the City, Lake Forest is loca ted in close proximity of multiple faults: the Newport-Inglewood-Rose Canyon Fault; the Palos Verdes Fault; the Whittier-Elsinore Fault; the Chino Fault; the San Andreas Fault; and the San Jacinto Fault. Surface rupture in Lake Forest is unlikely since no faults have been identified within the City boundaries. However, the City is likely to experience ground shaking, the degree to which wo uld be based on the fault from which the earthquake occurs, its distance from the City, and the magnitude. Impacts of an earthquake include potential liquefaction, which occurs when the str ength and stiffness of a soil is reduced by intense ground shaking. Structures particularly susceptible to earthquake damage include tilt-up structures, unreinforced masonry buildings, older buildings, and mobile homes.

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The City is located along the southwestern flank of the Santa Ana Mountains and contains areas with steep slopes, particularly in the Foothill Ranch and Portola Hills area. Portions of Lake Forest are located within state-designated liquefaction and landslide zones. After the 1971 San Fernando earthquake, building codes and design criteria were updated to address seismic oc currences. The Lake Forest General Plan Public Safety Element contains Goals, Policies, and Actions that address geologic and seismic hazards within the City. Policies include requiring special site-specific studies in areas potentially subject to liquefaction and incorporating site specific seismic structural design as required by applicable building codes.

WILDFIRE
Parts of Lake Forest are located within areas identif ied by CAL FIRE as Very High Fire Hazard Severity Zones, including the Whiting Ranch Wilderness Ar ea, the open space north of Portola Parkway between Portola Hills and Foothill Ranch, and a small portion extending south to Portola Parkway northwest of the Foothill Ranch community.4 These areas are within local responsibility areas and under the service area of Orange County Fire Authority (OCFA). The Lake Forest General Plan Public Safety Element contains Goals, Policies, and Actions that address wildfires and emergency preparedness in the city. These include regulatory standards such as ensuring residential building codes comply with California Building and Fire Codes, mutual aid agreements and coordination with OCFA and CAL FIRE, and emergency operations and preparedness plans. Although these standards may constrain development to an extent, they are necessary to ensure public safety.

HAZARDOUS MATERIALS RELEASE
The City of Lake Forest is susceptible to the danger of hazardous materials spills from highways, railways and industrial facilities that store, use, or dispose of hazardous materials. This danger is somewhat mitigated, however, by various State and Federal legislation regulating the use, stor age, and transportation of hazardous materials and the strict enf orcement of these regulations. A dditionally, the San Onofre Nuclear Generating Station is approximately 25 miles south of Lake Forest. It was shut down in 2012 and permanently retired in 2013 after attempts to restart it failed. Although it is no longer operational, a large volume of nuclear waste is stored on site. Lake Forest is in the station’s “ingestion pathway zone,” that is, the area where radioactive material released from the plant could contaminate food or water and potentially be ingested. 4D. Infrastructure Constraints
Another factor adding to the cost of new construction is the provision of adequate infrastructure: major and local streets; curbs, gutters, and sidewalks; water and sewer lines; storm drains; and street lighting. All these improvements may be required to be built or installed in conjunction with new development. In most cases, these improvements are dedicated to the City, which is then responsible for their maintenance. The initial construction cost of these facilities is borne by de velopers, added to the cost of new housing units, and eventually passed on to the homebuyer or property owner. As noted in the Resources chapter of this Housing Element, public infrastructure and services are available for all the sites included in the sites inventory, including the capacity to accommodate Lake Forest’s total share of the regional housing need (RHNA).

Senate Bill 1087 (enacted 2006) requires that water provid ers develop written policies that grant priority to proposed development that includes housing affordable to lower income households. The legislation also prohibits water providers from denying or conditioning the approval of development that includes housing affordable to lower income households unless specif ic written findings are made. Senate Bill 1087 also mandates priority sewage collection and treatment service to housing developments providing units affordable to lower income households. The City will provide a copy of the Housing Element to its water and sewer providers in compliance with Government Code Section 65589.7 and SB 1087. As well, the Community Development Department will continue to coordinate with the water and sewer providers to ensure priority

4 “Very High Fire Hazard Severity Zones in LRA,” CAL FIRE (October 2011).

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service provision to affordable housing developments.

WATER CAPACITY
Water service in Lake Forest is provided by three separate, independent utility districts: Irvine Ranch Water District (IRWD), El Toro Water Di strict (ETWD), and Trabuco Canyon Water District (TCWD). Most of the City (approximately 83%) receives its water from IRWD, one of the largest water districts in Orange County and a member agency of the Municipal Water District of Orange County (MWDOC), which is a wholesale importer and member agency of the Metropolitan Water District (MWD). A small portion of the City, the Portola Hills community, is located within TCWD service area boundary, yet is provided water by IRWD. IRWD receives its water supplies through a combination of groundwater from the Orange County Groundwater Basin, recycled water, and imported water supplies through MWDOC. The ETWD provides service to residents in the southeast corner of the City and re lies completely on imported treated water from MWDOC to meet potable water demands.

Both the IRWD 2020 Urban Water Management Plan and ETWD 2020 Draft Urban Water Management Plan state they will be able to serve 100 percent of projected demands for the City of Lake Forest in normal, single- dry and multiple-dry years. Because of this, the projected purchases from IRWD and ETWD are assumed to make up differences between demand and other projec ted (groundwater and recycled water) supplies.

Collectively, water supplies are projected to be suffi cient to meet demands in all year types through the planning horizon (20 years).
5,3
The City of Lake Forest General Plan Environmental Impact Report (EIR) analyzed potential impacts to water capacity as a result of implementation of the G eneral Plan Land Use Plan. When the net impact to potable water demand generated as a result of implementation of the Land Use Plan is compared to the supply available to the two Districts, it can be seen that both Districts have ample water supply to account for buildout of the General Plan. The General Plan includes a range of policies designed to ensure an adequate water supply for development and to minimize the potential adverse effects of increased water use.

SEWER CAPACITY
As with the water system, the City’s sewer services are divided up by three utility districts, IRWD, ETWD, and TCWD. Among the three agencies, there are approximately 215 miles of sewer main within the borders of Lake Forest. As of 2008, the IRWD MWRP had a plant capacity of 18 million gallons per day (mgd) but it was recently expanded to a capacity of 28 mgd. As of 2014, the ETWD LAWRP had a plant capacity of 7.5 mgd but only approximately 3.43 mgd was being conveyed to the LAWRP for treatment. As discussed above, the only section of Lake Forest which TCWD provides wastewater services for is a portion of the Portola Hills community. The amount of flow capaci ty available to the Portola Hills Community is limited by the total capacity that TCWD owns in SMWD’s wastewater collection system and the Chiquita Water Reclamation Plant. The District owns 0.558 mgd of capacity in SMWD’s wastewater collection system and Chiquita Water Reclamation Plant. 0.428 mgd is reserved specifically for TCWD’s El Toro Road Zone. Of the 0.428 mgd reserved for the El Toro Road Zone, 0.158 mgd is reserved for its Portola Hills customers.

As Lake Forest continues to develop in the future, there will be an increased need for water and wastewater services, including a reliable source of recycled water. These needs have been addressed in the three utility districts’ master plans in coordination with the City. It will require that the Districts continue to implement phased improvements to some pump stations, sewer mains, and the various wastewater treatment plants when triggered by growth.

Based on implementation of the General Plan Land Use Plan with which this sites inventory is consistent, the projected flows for each District are not expect ed to exceed the treatment capacity available for the Districts. This assumes that the majority of the flow generated in the IRWD service area is conveyed to the

5 “2020 Urban Water Management Plan: Irvine Ranch Water District,” Irvine Ranch Water District (June 2021).

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LAWRP for treatment. There may be local infrastructure impacts for each of the focu s areas as identified in the General Plan. Sub-Area master plans or devel opment impact studies may be required by IRWD and ETWD for each of the focus areas to determine infrastructure impacts.

While full buildout of the development in the General Plan would slightly increase the existing treatment demand at the Districts’ treatment plants, the General Plan includes a range of policies designed to ensure an adequate wastewater treatment capacity for development. The Districts must also periodically review and update their Master Plans. As growth continues to occur within the Planning Area and prior to the approval of new development, the Districts will identify necessary system upgrades and capacity enhancements to meet growth in coordination with the City.

STORM WATER DRAINAGE
The City of Lake Forest spans three watershed areas wi th five natural creeks. A flood control system has been constructed to direct runoff away from develop ed areas and prevent flooding from rain. The Orange County Flood Control District (OCFCD) is responsible for regional flood control and maintains several facilities within the City. The City works closel y with OCFCD to determine needs for flood control improvements and to identify improvements needed to accommodate proposed development projects. With these existing facilities and review procedures in place, the City’s flood control system is not expected to limit development during the planning period.

ELECTRIC, GAS, AND TELECOMMUNICATIONS
Southern California Edison (SCE) provides electr ical service and Southern California Gas Company (SoCalGas) provides natural gas services to residences and businesses throughout the City of Lake Forest.

SCE provides electricity service to 15 million peo ple over an approximately 50,000 square mile area throughout southern California. 6 SoCalGas provides natural gas service to approximately 21.6 million customers, spanning roughly 20,000 miles. 7 Infrastructure to deliver electricity and natural gas throughout Lake Forest is currently in place. SCE and SoCalGas can generally can provide these services to newer development on request.

Telecommunications services in Lake Forest are provided by a variety of service providers including AT&T and Spectrum. Infrastructure to deliver telecommunications throughout Lake Forest is currently in place and can generally be provided to newer development upon request.

6 “About Us,” Southern California Edison, https://www.sce.com/about-us (November 2021). 7 “Company Profile,” Southern California Gas Company, https://www.socalgas.com/about-us/company-profile (November 2021).

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5. Housing Resources
This section of the Housing Element describes resources available for housing development. Resources include land designated for housing development and financ ial resources to assist with the development of housing.
5A. Regional Housing Needs Allocation (RHNA)
The City of Lake Forest falls under the jurisdiction of the Southern California A ssociation of Governments (SCAG). SCAG is responsible for developing a Regional Housing Needs Plan (RHNP) allocating the region’s share of the statewide housing needs to lower-level councils of governments, which then allocate the needs to cities and counties in the region. The Regional Housing Need Assessment (RHNA) is a minimum projection of additional housing units needed to accommodate projected household growth of all income levels by the end of the Housing Element’s statutory planning period.

This RHNA covers an 8-year planning period (2021 through 2029) and is divided into four income categories:
very low, low, moderate, and above moderate. Pursuant to AB 2634, local jurisdictions are also required to project the housing needs of extremely low-income households (0-30% Area Median Income (AMI)). In estimating the number of extremely low-income households, a jurisdiction can use 50% of the very low- income allocation; therefore, the City’s very low income RHNA of 956 units can be split into 478 extremely low income and 478 very low-income units.

The largest component of Lake Forest’s RHNA (36%) is for above-moderate income households, which is primarily addressed through the development of single -family homes (attached and detached). Multifamily projects like apartments and condominiums, especially smaller unit sizes, are affordable to lower income households. Housing for lower income households is not typically provided in the Orange County market without some level of subsidy or regulatory requirement, and thus the Housing Element will need to provide sites at sufficient densities, combined with programs to support affordability, to address the housing needs of lower income households.

TABLE 61: RHNA 2021-2029
Income Group Total Housing
Units Allocated
Percentage of
Units
Extremely/Very Low 956 30%
Low 543 17%
Moderate 559 17%
Above Moderate 1,178 36%
Total 3,236 100%
Source: Southern California Association of Governments, 2021 5B. Progress Towards the RHNA
Since the RHNA uses June 30, 2021 as the baseline for growth projections for the 2021-2029 planning period, jurisdictions may count housing units that have been developed, are under construction, and/or have received their building permits after June 30, 20210 toward their RHNA obligation. Since this date, 755 461 housing units have been developed, are under construction, or have received building permits in Lake Forest (Table 62). These figures are accurate as of August 31, 2021.

Jurisdictions may also count projects that are appr oved/entitled but not yet built or under construction;. 753 976 units in multiple income categories have been approved/entitled and are expected to be developed within the planning period. These credits towards meeting the City’s RHNA obligation are specified in Table 62, and the affordability of each unit type/project is described in the following sections. These figures are accurate as Item: 11
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of August 31, 2021.

TABLE 62: CREDITS TOWARDS THE RHNA
Project
Extremely
and Very
Low income
(0-50% AMI)
Low
income (51-
80% AMI)
Moderate
income (81-
120% AMI)
Above
Moderate
income
(121%+ AMI)
Total
Units Constructed/Under Construction/Building Permits Issued since June 30, 2021 Teresina 0 0 0 5731 5731
Serrano Summit 0 0 0 308200 308200
Portola Center 0 0 0 386217 386217
Portola Center Second Units 1 1 1 0 3
Accessory Dwelling Units 12 12 13 13 410
Subtotal 13 13 14 752451 755461
Approved/Entitled Units Not Yet Under Construction
Teresina 0 0 0 26 26
Serrano Summit 0 0 0 65 65
Portola Center 0 0 0 140 140
Portola Center Second Units 53 84 53 00 1810
Portola Senior Housing
Project
25 32 0 1 58
The Meadows (Nakase) 7 57 0 542 606
Mountain View 70 0 0 1 71
Portola Senior Housing
Project
25 32 0 1 58
Portola Center Second Units 5 8 5 0 18
Subtotal 107105 9793 53 544775 753976
Total 108 9896 67 1,2961,226 1,5081,437
Source: City of Lake Forest, August 31,2021.

Note: Units identified as affordable to extremely and very low- and low-income households will be deed restricted.

AFFORDABILITY OF UNITS CREDITED TOWARDS THE RHNA
Units credited towards the RHNA are distributed among the four affordability categories (extremely/very low, low, moderate, and above moderate) based on affordability restrictions (as is the case with affordable housing projects including the Meadows, Mountain View, and Portola Senior Housing Project ) or housing cost for those specific types of units (the case for all other units, excl uding accessory dwelling units and second units), based on real home rental/sale rates and established affordability levels. For example, tT he market rate rents and sales prices for both single-family attached and single-family detached homes in Lake Forest are typically affordable to households earning above moderate incomes (120%+ AMI), and are allocated as such, as discussed in the Housing Affordability by Income Level discussion above (this applies to Teresina, Serrano Summit, Portola Center, and the Meadows). The City has approved several (410) ADUs since July 1, 2021 and has an additional three inunits in the pipeline (discussed separately) ; based on information collected as part of the ADU application process and industry standards including SCAG’s ADU affordability methodology (discussed later), the City has assumed one two of the permitted constructed/under construction ADUs is are affordable to extremely low/very low income, one two is are affordable to low income, one three is are affordable to moderate income, and one isthree are affordable to above moderate income.

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According to data collected from Zillow.com and Craigslist.com in January 2021, the average rents reported for Lake Forest were $1,816 for studio units, $1,841 for 1-bedroom units, $2,225 for 2-bedroom units, $3,193 for three-bedroom units, and $4,933 for four or more bedroom units. Based on this data and the housing affordability thresholds shown in the Needs Assessment, low income (51-80% AMI) households (affordable monthly rent is at least $1,883) can afford a studio or 1-bedroom unit, while 2-bedroom units are generally affordable to moderate income (81-120%) households (affordable monthly rent is at least $2,241). Larger (3+ bedrooms) units are sometimes affordable to larger (4+ person) households but are generally affordable to above moderate income (120%+ AMI) households.

Actual unit affordability will vary greatly based on un it size, household size and other factors. Given the distribution of affordability by income level based on unit and family size as described above, the City has assumed that new multifamily housing generally develops at densities of at least 30 du/ac and will result in the availability of units at very low, low, and moderate incomes; and new single-family attached or detached units will be suitable for moderate and above moderate income households.

Condominium units are considered entry-level homes and based on pricing are designated as affordable to moderate-income households. According to Zillow.com, in January 2021, the median price for condominiums sold in the City was $485,000, which is affordable to a four-person moderate-income household (for which the maximum affordable purchase price is $493,708).

UNITS CONSTRUCTED OR UNDER CONSTRUCTION
According to City building permit records, as of June 30, 2021, 755 461 new units have been constructed, are under construction, or have building permits pulled in Lake Forest, of which 1 3 (an two ADUs and one second unit in Portola Center) has have been determined to be affordable to extremely low/very low income households, 13 (an two ADU s and one second units in Portola Center ) has have been determined to be affordable to low income households, 14 (an three ADUs and one second unit in Portola Center ) has have been determined to be affordable to moderate income households, and the remaining 760 451 units are affordable to above-moderate income households. Comp leted/under construction/building permits issued units include the following projects:

Teresina (formerly “Pinnacle at Serrano Highlands”)
Teresina is a single-family detached residential subdivision of approximately 24.6 acres with residences ranging from 3,238-4,329 square feet, including 4-5 bedrooms , and priced from $1,305,000. Teresina includes 85 detached single-family residential units. As of June 30August 31, 2021, 57 31 of the units have have been constructed or are under not completed construction since the planning baseline date of June 30, 2021; units constructed prior to this date are not counted as a credit towards the City’s 6th Cycle RHNA.. These homes are affordable to above moderate-income households.

Serrano Summit
Serrano Summit is a residential community composed of detached single-family residential and attached condominiums located adjacent to the City’s Civic Center. Serrano Summit includes 537 residential units, a portion of which have already been developed. As of June 30August 31 , 2021, 308 200 of the units have been constructed or are under construction since the planning baseline date of June 30, 2021; units constructed prior to this date are not counted as a credit towards the City’s 6th Cycle RHNAhave not b een completed construction. These units range in price from $700,000 to $1,200,000 and are affordable to above moderate- income households.

Portola Center (including Second Units)
Portola Center totals nearly 196 acres and includes single-family and multi-family residential units and commercial retail space, as well as other public and private recreational amenities. At completion, the 195- acre Portola Center site will include:

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 860 residences, including, single-family residences, multi-family residential units and affordable senior housing above commercial space.
 10,000 square feet of commercial space.
 A 5-acre public park with playgrounds, picnic areas, and sports fields.  New trails with exercise stations.
 Three private neighborhood parks totaling more than ten acres, including one with a rec center and pool.
 44-plus acres of open space, including a 1.5-mile Perimeter Trail available to the public and adjacent private perimeter park with trail connections to Whiting Ranch Regional Park.

A portion of Portola Center has been developed. As of June 30August 31 , 2021, 386 217 of the units have been constructed or are under construction since the planning baseline date of June 30, 2021; units constructed prior to this date are not counted as a credit towards the City’s 6th Cycle RHNAhave not completed construction.

These are all assumed to be affordable to above moderate-income households. An additional 58 units (the affordable senior housing project) are approved/entitled but not yet (2021) under construction and are addressed in the following section. It should be noted that the Portola Center project also requires the development of 18 second units , three of which have been constructed or are under construction, as of August 31, 2021 (but after the baseline date of June 30, 2021) . The affordability level of these ADUs is assumed to be consistent with the findings of SCAG ’s ADU affordability study and the findings for Orange County.

UNITS APPROVED/ENTITLED
Based on City records, 753 976 units have been approved in Lake Forest that are not currently (2021) under construction but are expected to be completed during the planning period. Of these 753 976 units, 102 will be deed-restricted affordable to extremely low/ very low-income households, 89 will be deed-restricted to low- income households, and 544 774 are affordable to above-moderate income households. An additional 18 10 second units will be provided in Portola Center, and the expected affordability of these second units is based on SCAG’s ADU affordability methodology for Orange County. Projects that are approved but not yet constructed include the following:

Teresina (formerly “Pinnacle at Serrano Highlands”)
As discussed in the prior section, Teresina will include 85 homes; as of August 31, 2021, 26 of these units are approved/entitled, but not yet under construction. All of these units are expected to be affordable to above moderate income households.

Serrano Summit
As discussed in the prior section, Serrano Summit will include 537 homes; as of August 31, 2021, 65 of these units are approved/entitled, but not yet under construction. All of these units are expected to be affordable to above moderate income households.

Portola Center (including Second Units)
As discussed in the prior section, Portola Center will include 860 homes; as of August 31, 2021, 140 of these primary units (excluding the Senior Housing Project, which is discussed separately) are approved/entitled, but not yet under construction. An additional 10 second units are also approved/entitled, but not yet under construction. All of the 140 primary units are expected to be affordable to above moderate income households; three of the second units are expected to be affordable to extremely very low/low income households, four are expected to be affordable to low income households, and three are expected to be affordable to moderate income households.

Portola Senior Housing Project
As previously described, the 195-acre Portola Center site will include a 58-unit affordable senior housing project. This project will accommodate extremely low/ very low and low-income households and, based on discussions with the developer, the City has assumed that 25 of the units will be affordable to extremely Item: 11
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low/very low-income households, 32 will be affordable to low-income households, and 1 (the manager’s unit) will be affordable to above moderate-income households.

The Meadows (formerly “Nakase”)
The Meadows is a 126-acre subdivision located s outheast of the Bake Parkway/Rancho Parkway intersection. The property was previously a plant nursery. The project includes 541 single-family residential units in five neighborhoods, a 65-unit senior affordable housing, and a potential elementary school site. The project includes over 20 acres of parks, open space, and habitat restoration area.

The City is currently finalizing an Affordable Housin g Implementation Plan (AHIP) for the Meadows project.

The project will include at least 64 deed-restricted affordable units, including 7 permanent supportive housing units (assumed to be affordable to extremely low/ve ry low-income households) and 57 units affordable to low-income households. The remaining units (542) are expected to be affordable to above moderate-income households.

Mountain View
The Mountain View affordable housing project is an approved 71-unit apartment complex to be built at 24551 Raymond Way, near the northeast corner of El Toro Road and Raymond Way. The project will be developed by National Core Renaissance, an affordable housing developer. The project will provide housing for very-low income and extremely low-income households. The project includes the demolition of an existing office building located at the site. Funding for the project requires that all units (except the manger’s unit) be affordable to extremely very low/very low-income households. Of the 71 units, 70 will be deed-restricted affordable units for extremely very low/very low-income households and 1 unit (the manager’s unit) will be affordable to above moderate- income households.

REMAINING RHNA
As of September 2021, the City has already achieved approximately half of its overall RHNA obligation with housing units constructed, under construction, or approved/entitled (1,5081,437 units). With these units taken into account, the City has met its allocation of above moderate-income units and has a remaining RHNA of 1,8467 units ( 853 848 extremely low/ very low-income units, 453 447 low-income units, and 558 552 moderate income units).

TABLE 63: REMAINING 6TH CYCLE RHNA
Status
Extremely
Low/Very
Low
Low Moderate Above Moderate TOTAL
RHNA Allocation 956 543 559 1,178 3,236
Completed, Under
Construction/Permits
Issued (Since 6/30/2021 ,
accurate as of 8/31/2021 )
31 13 14 752451 755461
Units Approved/Entitled 105107 9793 53 544775 753976
Remaining Allocation 848 445447 553552 0 (with a surplus of 118 48 units) 1,8467*
Source: City of Lake Forest, August 31, 2021, SCAG, 2021 * The total remaining allocation is the remaining allocation of extremely low/very low, low, and moderate income units (848, 445447, and 552553, respectively). This results in a remaining allocation of 1,8467 units. The surplus of above moderate-income units (11848) cannot be deducted from the remaining allocation, which is based on the remaining allocation by income level. 5C. Residential Sites Inventory
Housing element law requires an inventory of land suitable for residential development (Government Code Item: 11
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Section 65583(a)(3)). An important purpose of this in ventory is to determine whether a jurisdiction has sufficient land allocated for the development of housing to meet the jurisdiction’s share of the regional housing need, including housing to accommodate households of all income levels.This section provides an analysis of the land available within the City for residential development. In addition to assessing the quantity of land available to accommodate the City’s total housing needs, this section also considers the availability of sites to accommodate a variety of housing types suitable for households with a range of income levels and housing needs.

This Housing Element identifies underutilized sites that can accommodate residential uses (including 100% residential projects) within Lake Forest. It is noted that Lake Forest is essentially built-out with no remaining vacant land designed for residential development. As part of the City’s recent comprehensive General Plan update (adopted in 2020), the City proactively planned for growth and identified key areas of the community (referred to as “focus areas”) wh ere mixed-use development is des irable. Moreover, the land use designations created and applied to these mixed-use areas allow for development of at least 30 du/ac, further supporting the City’s goal of increasing its housin g stock affordable to all income categories. This development density is uncommon in Lake Forest. It is t he City’s intent to promote the production of new housing units for all income levels, including for moderate-income households which have traditionally found it difficult to afford homeownership in Lake Forest.

A Citywide parcel database, aerial photos, and General Plan Geographic Information System (GIS) data were used to identify parcels for this update. In addition, numerous field visits were conducted and outreach with property owners was completed as part of the General Plan Update. Parcel acreages by land use designation referenced herein are based on Orange County Tax Assessor and GIS data.

MIXED-USE SITES
The City adopted a comprehensive update to its General Plan in June 2020. As part of this effort, the City engaged the community in a robust discussion regarding the potential for mixed-use development of key opportunities sites throughout the City. The intent of th is process was to strategically identify areas of the City most likely to redevelop over time and to provide appropriate intensity and density standards to facilitate successful redevelopment. As a result, the City ’s land use plan includes new mixed-use land use designations applied to property along the City’s major transportation corridors and around its activity centers.

The mixed-use designations accommodate dynamic, vibrant, mixed-use and residential development close to jobs, goods and services. These new mixed-use designated sites are fundamental to the City’s commitment to accommodate new residential development for all income levels. Through the General Plan update process, over 380 acres of land was designated for mixed use development at densities up to 32 du/ac or up to 43 du/ac (depending on the location) and an additional 95 acres was designated for mixed- use development at a density of up to 25 du/ac. In summ ary, the General Plan identified a capacity for at least 10,500 housing units in areas allowing for at least 30 du/ac (in areas designated for MU-32, MU-43, or UI-43), and another 792 units in mixed-use areas allowing for up to 25 du/ac (in areas designated for UI-25).

To harness the energy of the General Plan update and implement the new land use plan, the City immediately initiated an update to its Zoning Code to create new mixed-use zoning districts. The City conducted community surveys and other outreach and engaged a cons ultant team to create new zoning districts, regulations and development standards for City Council review and adoption by early 2022.

Goal LU-5 (in the City’s Land Use Element) addresses focus areas for economic stability and growth, and envisions Lake Forest as “a community featuring mix ed-use activity centers located along the City’s major roadways and trans portation facilities which a llow for the co-locat ion and harmonious development of housing, shopping, jobs, and public uses.” The Land Use Element includes policies that promote the revitalization of these key focus areas. Additiona lly, the Land Use Element includes policies promoting densities and intensities sufficiently high to encourage redevelopment of underutilized sites, and an expanded Item: 11
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range of housing types and densities to meet the di verse demographic, economic, and social needs of the community. In this context, all sites identified for mixed-use development in the City’s General Plan are suitable for redevelopment, but only those sites best suited for redevelopment during the planning period have been identified and included in the City’s sites inv entory. In identifying those sites most suitable for redevelopment, the City considered the following factors:
• Site size and ownership patterns
• Developer interest in the property
• Redevelopment plans shared by the property owner
• Existing/past uses on the site
• Improvement to land value ratio
• Impacts of the COVID-19 pandemic on commercial real estate • Site utilization/lot coverage/FAR
• Access to infrastructure, goods, se rvices, and transportation facilities • Site access and configuration
• Whether the site has similar characteristics to recent redevelopment projects in the region

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Based on the factors listed, the Ci ty identified 78 parcels totaling approximately 162 acres as the most suitable and likely for redevelopment during the planni ng period, 60 of which (totaling 127 acres) are designated for development allowing at least 30 du/ac and identified to meet a portion of the City’s lower- income RHNA allocation. Although each of these sites are developed with office, industrial, and/or retail uses, the sites typically are underutilized and are suitable for infill development or redevelopment (potentially without needing to demolish existing improvements), have st ructures at or near the end of their useful life, and/or existing intensity of developm ent substantially lower than allowed by the City’s 2040 General Plan.

Furthermore, the current COVID-19 pandemic has seriousl y impacted the viability of many retail, service, and restaurant businesses. In recent years, many non-residential sites in the region have been redeveloped with mixed-use or residential-only projects. Appendix A identifies the sites included in the City’s inventory along with existing land use information.

To date (September 2021), no projects have been deve loped on sites designated (2020) for mixed-use in the 2040 General Plan. In order to determine a cons ervative development estimate for the mixed-use designated areas, the City assumed that these sites will only develop at 50% of their development potential.

This conservative estimate considers the following capa city factors, as identified in housing element statue (Gov. Code section 65583.2(c)(2)): land use controls, site improvements, realistic capacity of the site, and typical densities. Of the five factors only land use cont rols and site improvements, realistic capacity of the site, and typical densities are relevant when considering the capacity of sites in Lake Forest, Infrastructure constraints and environmental constraints are not applicable. Despite the fact that the City has the General Plan land use designations in place to accommodate it s RHNA and is nearly complete with the associated update to its Zoning Code, the City does not yet have the zoning in place to accommodate its RHNA and therefore has been found to have a shortfall of sites. The City must complete its rezoning effort to accommodate its RHNA, including its lower income RH NA requirements. The City has included Program 1 to specifically commit to acreage, allowable densities, and anticipated units to accommodate its RHNA for all income levels. In addition, to accommodate the ho using needs of lower-income households, the program specifically commits to rezoning pursuant to Government Code section 65583.2, subdivisions (h) and (i).

HOUSING AFFORDABLE TO LOWER-INCOME HOUSEHOLDS
The California Government Code states that if a local government has adopted density standards consistent with the population-based criteria set by State law (a t least 30 units per acre for Lake Forest), HCD is obligated to accept sites with those density standa rds (30 units per acre or higher) as appropriate for accommodating the jurisdictions share of regional housing need for lower-income households. Per Government Code Section 65583.2(c)(3 )(B), the City’s Mixed Use 32, Mixed Use 43, and Urban Industrial 43 designations are consistent with the default dens ity standard (30 units per acre) for metropolitan jurisdictions such as Lake Forest and therefore considered appropriate to accommodate housing for lower- income households. Therefore, based on State law, sites that allow development densities of at least 30 units per acre are credited toward fulfilling a portion of the City’s lower-income RHNA allocation. It should be noted that, the City has also assumed that a percentage of the units at these sites will be affordable to moderate income households.

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SUITABILITY OF NONVACANT SITES
Because nonvacant sites comprise more than half of Lake Forest’s sites invent ory, Government Code Section 65583.2(g)(2) requires that the City analyze t he extent to which existing uses may constitute an impediment to additional residential development, past ex perience in converting existing uses to higher density residential development, market trends and conditions, and regulatory or other incentives to encourage redevelopment. Furthermore, the City will make findings based on substantial evidence that the existing use is not an impediment and will likely discontinue during the planning period.

City of Lake Forest is e ssentially entirely built out. There is no vacant unentitled land remaining to accommodate new multifamily residential development. In order to accommodate its fair share of regional housing growth, the City must identify nonvacant sites to accommodate its remaining RHNA for all income levels (not only its lower income requirements).

Increase in Development Potential in Mixed-Use Focus Areas In 2018, Lake Forest began a 2-year process to comprehensively update the City’s General Plan. As part of the Update, the City evaluated the General Plan Land Use Map to determine if the land uses and development patterns reflected the community’s vision for the future of Lake Forest. An extensive outreach effort was initiated that included three community wo rkshops, pop-up events and an on-line survey, which allowed the City to collect input from businesses a nd residents in the community to identify the locations within the City where land use changes could be supported by the city, local market conditions and economic factors.

The General Plan Update process included the development of an Existing Conditions Report, published in October of 2018. The report identified developm ent patterns, socioeconomic conditions, and natural resources. It included important information of city demographics, housing supply, the size and composition of the local economy, commercial real estate market tr ends, as well as office, hospitality, and retail trends.

Key socio-economic, market and fiscal trends for the City of Lake Forest were analyzed and compared to its regional neighbors-or trade area- in order to bette r understand the key issues and challenges facing Lake Forest in the future and to ensure that future land use changes would be feasible and implementable.

A General Plan Advisory Committee (GPAC) was formed that included members representing the real estate sector, commercial center owners, business owner s, industrial uses, educational community, law enforcement, homeowners, tenants. The potential land use changes were discussed by the GPAC over the course of one year and their recommendations were presented to the City Council for consideration.

Five Focus Areas were identified, including the El Toro Road Corridor, Lake Forest Corridor, the Light Industrial Area, the Civic Center Area and the Foothill Towne Center. Ultimately, new mixed use land designations, allowing development at densities up to 43 du/ac, were adopted as part of the General Plan Update. In building the sites inventory for the 6th Cy cle Housing Element, the most viable sites within the Focus Areas were selected for inclusion in the inventory. The RHNA for the lower income households was included in 4 of the Focus Areas. (The Civic Center area does not allow for sufficient density to support lower income households).

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Property Owner Outreach
Staff met with property owners and property managers in the El Toro and Lake Forest Corridors, the Light Industrial Area and the Foothill Towne Center during the preparation of the General Plan Update. The landowners were supportive of the inclusion of high-density residential land uses in the areas. Since adoption of the General Plan in June of 2020, staff has met with 2 property owners who own sites included in the 6th Cycle inventory. Both landowners have prepared prel iminary plans for the development of residential and mixed use on their sites. In one case, the owner would demolish all structures of the site and in another, the owner would modernize an existing office building, demolish several older non-competitive retail properties, and add residential land use at a density of 43 du/acre. In addition, a third property owner in the El Toro Focus Area has approved plans for the demolition of an existing office building and the construction of an affordable housing project. Lastly, during the 5th Cycle of the Housing Element, 2 existing auto dealerships in the Foothill Towne Center were demolished and replaced with medium density residential uses. Therefore, it has been demonstrated that existing uses on properties do not impede the development of new residential projects and that existing uses are likely to be discontinued during the planning period.

Assessment of Sites (Appendix A)
The City has completed a detailed assessment of t he suitability of all nonvac ant sites identified to accommodate its RHNA. Included in Appendix A, the City has described the existing uses located at each site, any known constraints to development, any cont act with property owners and tenants, and any other relevant information which supports the City’s finding that all sites identified in its inventory are suitable for redevelopment during the planning period at densities and in tensities consistent with the realistic capacity assumptions identified for the site, by income level. In particular, the City has identified six key trends prevalent in the redevelopment of occupied sites in Lake Forest and south Orange County, more generally.

As described in Appendix A, all sites identified in the City’s inventory exhibit at least two of these trends. The list of sites identified in the inventory has been revi ewed by an economic consultant experienced working with the City and there are no known constraints that would preclude development of residential uses during the planning period. Moreover, given the significant increase in commercial real estate development potential created through the redesignation of these sites to mixed-use (through the General Plan and ongoing Zoning Code Update), commercial real estate professionals wo rking in and around Lake Forest fully expect to see properties turn-over for redevelopment at levels not previously seen, given the newness of these opportunities. While the City of Lake Forest has only recently adopted a new Land Use Map with new land use designations to allow for the redevelopment of underutilized sites, many of its neighbors (Laguna Hills, Mission Viejo, Irvine) initiated similar efforts in t he preceding years and have seen success in redeveloping sites such as Laguna Hills Mall.

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Development Trends
In addition to the site characteristics described above for mixed-use sites, the City has specifically considered six trends present in the region that have been identified as factors contributing to the likelihood of a site’s redevelopment. These factors, which are described belo w, are identified by their applicationapplicability to each site anticipated to accommodate a portion of the City’s lower-income RHNA in Appendix A. The factors include:

1. Oversupply of Retail

2. Discontinuation of Office Uses

3. Known Vacancies/Buildings for Rent or Sale

4. Opportunity for Infill Development

5. Expressed Interest from Property Owners/Developers

1.6. Unique Site Characteristics (Low Utilization/Blighted Conditions)

1. Oversupply of Retail
Local market trends were presented to the City coun cil by the Kosmont Companies in May of 2021, in a presentation entitled “Resetting the Economic Development Table: Public and Private Investment Beyond COVID”. The presentation noted that store closures and e-commerce is driving changes at malls and retail centers and that retail downsizing is being replaced by new blended use, including residential. Lake Forest is “over-retailed” and the quality of existing retail center s continues to diminish. There is no evidence that commercial development will expand in Lake Forest; in fact, pressure to redevelop commercial property into mixed-use or residential projects is extremely high . The City of Lake Forest has historically had two concentrations of commercial activity: the area adjacent to the Interstate 5 Free way at El Toro Road and Lake Forest Drive, and the Foothill To wn center north of the Foothill Co rridor State Highway 241. The El Toro Road corridor is flanked by large commercial centers that served as a hub of activity in the Saddleback Valley in the 1970’s and 80’s. In contrast, the Foothill Towne Center, north of the 241 includes a mix of big box retailers, in-line commercial tenants, movie theatre s and offices. The El Toro Road corridor must now compete with commercial centers on the south side of the I-5 Freeway, including a planned mixed-use site on a former regional mall in Laguna Hills and the Irvine Spectrum located 2 miles to the north along the I-5.

Irvine Spectrum includes 1.2 million square feet of retail, restaurant and entertainment uses. Faced with this strong retail competition to the north and aging and dat ed commercial centers adjacent to the I-5 corridor, property owners have expressed strong interest in transitioning to residential and mixed-use projects.

On January 25, 2022 the OC Register published an article titled “Malls adding apartments to offset dwindling numbers of shoppers”, cataloging a series of at least 10 southern California malls which have plans to add residential development to their footprint. As described in the article, malls in southern California planning to add residential uses are following national trends wh ereby at least 192 malls across the country have proposals to add housing. Consumer preferences hav e shifted away from traditional big-box retail environments to more experience-based shopping areas and online retail, a trend that has been exacerbated by the COVID-19 pandemic. Regional development trends include the addition of residential uses to MainPlace Mall in Santa Ana, the mixture of residential and nonresidential uses at Huntington Beach’s Bella Terra and Glendale’s The Americana on Brand, and plans to develop residential uses at malls in Woodland Hills, Laguna Hills, Redondo Beach, and Studio City (among others).

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The article lists the following apart ments at southern California malls, included here to demonstrate the development trend and potential for the redevelopment of retail uses in the City of Lake Forest:
• Bella Terra, Huntington Beach: The mall has 467 units, built in 2013, according to CoStar. • The Americana on Brand, Glendale: Has 242 luxury units on the mall’s west side. • Village at Laguna Hills Mall: Owner Merlone Geier Partners is seeking city approval to build 1,200 to 1,500 apartments, plus a boutique hotel and 390,000 to 520,000 square feet of office space. • Promenade mall, Woodland Hills: Won city approval in December for a $1 billion project to build 1,432 apartments, a 28-story office tower, two hotels with 572 rooms, and a 10,000-seat entertainment and sports center.
• Baldwin Hills Crenshaw Plaza in South L.A.: New owner Harridge Development Group, which acquired the mall in August, is ev aluating a new redevelopment plan that will include “some sort of residential,” a company official said.
• South Bay Galleria, Redondo Beach: The first phas e of a redevelopment plan includes a 300-unit apartment building, plus a 150-room boutique hotel, 75,000 square feet of office space, a new plaza and a new open-air retail and dining area. Timing for construction of the apartments has yet to be determined, a spokesman said.
• Buena Park Mall: Merlone Geier Partners acquired t he Sears building at the mall and is working with the city to develop a plan that will have a re sidential component, said Managing Partner Scott McPherson. The initial plan included 1,300 apartments and townhomes, “but that’s subject to change,” he said.
• The Shops at Sportsman’s Lodge, Studio City: Deve lopers transforming the iconic 1960s hotel into a retail center announced in August they plan to raze the last remnants of the hotel and build a mixed- use housing development with 520 apartments units.
• NoHo West, North Hollywood: Apartment developer Trammell Crow plans to build 642 apartments on a part of the parking lot in the mall’s northeast corner it acquired from mall owner Merlone Geier Partners.
• Santa Monica’s Third Street Promenade: A plan developed last year encourages the city to consider rezoning parts of the retail district for housing and hotels among other strategies to revitalize an area that’s seeing rising vacancies in the face of online shopping and the pandemic, according to online news reports.

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2. Discontinuation of Office Uses
The City finds that the COVID-19 pandemic will have a real impact on commercial real estate and that office usespace will decline in demand as businesses maintain a long-term work from home option. A Cushman & Wakefield Orange County market report prepared for the Orange County mark et indicates office vacancies have been on the rise over the past year and are presently at 15.9% (Cushman & Wakefield, Marketbeat OC Office, Q2 2021).

In Lake Forest, the redevelopment of an underutilized offi ce property into an affordable housing project (Mountain View) demonstrates that t he market is ready to take advantage of the opportunity to repurpose sites in Lake Forest for residential uses, including affordable housing. The Mountain View Affordable Housing Community is a 71-unit apartment complex located at 24551 Raymond Way, near the northeast corner of El Toro Road and Raymond Way. The project will provide housing for low-income households. It is being developed by National Core Renaissance, an affordable housing developer. Mountain View is within walking distance of schools, grocery stores, and retail. Re sidents of Mountain View will have access to onsite amenities such as laundry facilities, a beautiful cour tyard featuring outdoor fireplaces, leisure areas, and a playground. A community center will serve as the hub for activities and services for residents and the neighborhood at large. Onsite programming will be offered by the Hope through Housing Foundation, providing services that give residents the resources and support they need to thrive. High-quality wraparound supportive services will be offered onsite to residents who have previously experienced homelessness and will be overseen by Hope through Housing’s services coordinator.

There are other regional trends of the demolition of office uses for residential development. For example, the City of Newport Beach recently approved a new apartment project in t he Airport Area which will include the demolition of an existing 33,000 square foot office building to allow for the development of nearly 200 new rental housing units, including affordable units.

3. Known Vacancies/Buildings for Rent or Sale
The City has conducted an inquiry to identify vacancies and buildings for rent or sale in Lake Forest that are included in Appendix A. Many of the sites identified in the inventory have vacancies, and in some cases, the entire site is unoccupied (as of December 2021). Thes e sites are particularly well-suited for redevelopment because property owners are incentivized to think about the highest and best use of their property to maximize profit in the face of vacancies.

4. Opportunity for Infill Development
The retail areas in Foothill Towne Center, which are dominated by big-box retailers and abundant surface parking, have been impacted by changing consumer preferences in shopping with the explosionrapid growth of e-commerce facilities. According to a report from CBRE Group, e-commerce will account for 26% of all retail sales in the US by 2025. The Towne Center area also includes an auto mall, with only one dealer left in operation. Two dealerships closed in the 2000’s and were replaced with 219 units of medium density residential uses. At this location, the City anticipates that existing retail uses can and will stay, and new residential development can be accommodated at the location without demolishing existing uses. This pattern is seen at Laguna Hills Mall where new residential development will be introduced at an aging mall, revitalizing the project area for residential and nonresidential tenants.

This trend reinforcessupports the oversupply of retail trend describesd earlier, including the range of residential development projects at sSouthern California malls. These projects represent the development of infill residential uses at underutilized/underperforming retail centers. As described previously, this trend can be seen in nearly a dozen sSouthern California communities, including in Orange County, as well as nearly 200 mall sites throughout the country.

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5. Expressed Interest from Property Owners/Developers
The City regularly receives inquiries from the development community regarding opportunities in the El Toro and Lake Forest Focus Areas. Of note, the new owner of a 9-story office building and surroundingadjacent fast food uses has met with the City and informed staff that that the lease of the tenant lease of the office building will expire in 2024. The owner has engaged a design team and prepared preliminary concepts for the development of office and residential uses on the entire property holding. Sites where developers and/or property owners have expressed interest in developing residential uses in the site are identified in Appendix A.

6. Unique Site Characteristics (Low Utilization/Blighted Conditions) Lastly, tThe City has visually inspected each site to determine if the existing uses represent a reasonable utilization of the site based on similar financially successful projects/centers in the region or if there are unique visual characteristicsclues that would indicate the site is not well-maintained and property owners may be interested in selling the property for a higher return. In particular, the City considered the site’s existing parking configuration (including whether the parking lots appear regularly occupied), ingress/egress issues, the visualvisible condition of the building and landscaping (whether or not it’s in need of repair), and other factors present through a visual inspection. Given the oversupply of retail and availability of retail options in the City and region, marginal uses and buildings are not expected to continue remaining competitive and their corresponding property value is likely higher with the option to develop residential uses on the site.

In 2021, the City of Lake Forest approved the redeve lopment of the Nakase property, a 125-acre former nursery site, to allow for the development of up to 60 5 homes and associated public facilities and services.

This development opportunity representedThe project site was a significantly underutilized site in the City of Lake Forest and is an example of how an underutilized site can be redeveloped for residential uses.

In Lake Forest, sites developed for industrial uses al so represent some of the City’s most underutilized property. The Opportunities Study is a comprehensiv e planning process that the City of Lake Forest undertook to rezone nearly 838 acres of land zoned for busi ness and industrial use on 5 properties in Lake Forest. The zoning changes allowed for a new plan with residential uses and facilities such as a sports park and community / civic center. As part of the Opportuniti es Study process, the City allowed for residential development at areas that were developed with industrial uses; market demand resulted in the redevelopment of these areas into the communities of Baker Ranch, Portola Center, Serrano Summit, the Pinnacle, and Whisler Ranch residential neighborhoods. Through the General Plan Update process, the City identified additional areas (namely in the Civic Center Focus Area) where industrial uses currently exist but where residential uses are now allowed, similar to th e process of redesignating sites via the Opportunities Study.

Suitability of Nonvacant Sites Findings
The City has specifically analyzed whether existing uses constitute an impediment for residential uses on the site. Additional information provided in Appendix A demonstrates that existing uses on the sites identified to accommodate a portion of the City’s RHNA do not constitute an impediment for residential uses on the site.

Additional information regarding current operations and tenants, vacancies, properties listed for rent or sale, the demand for the current use, and contact with pr operty/business owners are included. The City has considered each site individually and has concluded that based on the substantial evidence provided, current uses are not an impediment to the sites redevelopment for residential uses.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-119

REALISTIC CAPACITY
To date (September 2021), no projects have been deve loped on sites designated (2020) for mixed-use in the 2040 General Plan. In order to determine a realisti c development capacity estimate for the mixed-use designated areas, the City assumed that these sites will only develop at 50% of their development potential.

This conservative estimate considers the following capa city factors, as identified in housing element statue (Gov. Code section 65583.2(c)(2)): land use controls and site improvements, realistic capacity of the site, and typical densities. Of the five factors only land use c ontrols and site improvements, realistic capacity of the site, and typical densities are relevant when considering the capacity of sites in Lake Forest; infrastructure constraints and environmental constraints are not ap plicable. While the underlying zoning currently allows for 100 percent nonresidential uses, the City has not seen any applications or had preapplication discussions for mixed-use projects where residential uses repres ent anything less than 80% of the site’s development potential. The City finds that it is not financially feasible or desirable for developers to redevelop any of the sites listed in the Housing Element inventory for 100% nonresidential uses. In an abundance of caution, the City has applied a 50% reduction to the maximum site capacity, but all evidence (including the Kosmont study) suggests that residential uses will comprise the vast majority of new development in the City, even if the underlying zone allows for 100% nonresidential uses.

Table 64 summarizes how the various factors identified in housing element statute (Gov. Code section 65583.2(c)(2)) result in an adjusted site capacity of 50 percent the maximum densities in the mixed-use districts.

TABLE 64: CAPACITY ADJUSTMENT FACTORS – MIXED-USE ZONES Capacity Factor Adjustment Reasoning
Land use controls and site
improvements 90% For net acreage due to on-site
improvements (sidewalks, easements)
Realistic capacity of the site 85%
Adjustment based on past
redevelopment trends in mixed-use
zones in Orange County and programs
to incentivize development in mixed-use
areas
Typical densities 75%
Based on Table 60, market rate
projects develop between 70-80% of
maximum capacity but affordable
housing projects are more likely to be
built out to maximum or above-
maximum (through density bonus
provisions) density
Infrastructure availability No adjustment Not applicable, no constraint Environmental constraints No adjustment Not applicable, no constraint Source: City of Lake Forest, 2021

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CAPACITY TO ACCOMMODATE UNMET RHNA ALLOCATION
The City of Lake Forest’s 6th Cycle residential capacity falls into three categories:
1) Accessory dwelling units
2) Underutilized residential sites, and
3) Underutilized sites in mixed-use areas.

As described throughout this section, the City has sufficient land appropriately designated in the General Plan for residential uses throughout the community to accommodate its RHNA allocation for the 2021-2029 planning period and the City is currently undertaking a Zoning Code Update to implement the land use designations included in the General Plan (see Housing Plan Program 1) . Moreover, Lake Forest has a proven track record of supporting development of a ffordable housing, working with affordable housing developers, promoting home types that are affordable to lower-income households, including multifamily projects and mixed-use developments, and addressing needs of the community’s vulnerable populations, including seniors. Sites designated to accommodate the City’s RHNA allocation for the 2021-2029 planning period are illustrated on Figure 2, Housing Sites Inventory, and detailed in Appendix A.

Accessory Dwelling Units
In January 2020, new State legislati on pertaining to Accessory Dwelling Units (ADUs) went into effect. The legislation amended Government Code Sections 65852.2 and 65852.22. The City subsequently updated its zoning ordinance for consistency with State law.

The City approved two ADUs in 2018, three ADUs in 2019, and seven ADUs in 2020. The City has taken significant proactive steps to advertise the opportunity for residents to construct ADUs, including information on the City’s website, hosting presentations to the Planning Commission and City Council, and answering questions from the public in-person at City Hall and over the telephone.

Lake Forest made a conservative estimate of the number of ADUs that will meet a portion of the City’s RHNA obligation. The City used the average annual number of ADUs constructed over the past three years multiplied by 8 (the number of years in the planning period), to estimate the number ADUs (at a minimum) to be constructed during the planning period.

The average annual number of ADUs developed from 2018-2020 was 4, multiplied by 8, yields the estimate of 32 ADUs to be constructed between 2021 and 2029. This is a conservative assumption and production will likely outpace this target during the planning period. Additionally, the affordability level of these ADUs is assumed to be consistent with the findings of SCAG ’s ADU affordability study and the findings for Orange County.

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Baker Ranch
58-75
8-13
38-44
45-57
Foothill Ranch
Port ola H ills
§¨¦
5 ALISO CREEK

BORREGOCANYON

SAN DIEGO CREEK

BORREGOCANYON WA SH

SERRANO CREEK
4 5
6 7
14 15
16 22
24 27
28 33
34 35
36 37
1 32
31 30
29 26 25
23 21
20 19
18 17
3 2
Figure 2: 2021-2029 Housing Element Site Inventory
Legend
City of Lake Forest
Assessor Parcel Boundary
Low Density Residential
Low-Medium Density Residential
Medium Density Residential
High Density Residential
Commercial
Mixed-Use 32
Mixed-Use 43
Business Park
Mixed Use Office
Professional Office
Light Industrial
Urban Industrial 25
Urban Industrial 43
Public Facility
Community Park/Open Space
Regional Park/Open Space
Open Space
Lake
T ransportation Corridor
Underutilized Residential Site (Density <30 du/ac)
Low-Medium Density Residential
Medium Density Residential
Underutilized Mixed-Use Site (Density > 30 du/ac)
Mixed-Use 32
Mixed-Use 43
Urban Industrial 43
Underutilized Mixed-Use Site (Density < 30 du/ac)
Urban Industrial 25
Lake Forest Dr
8 9 10
1112
13 42 43
41 44
40 39
38 Inset A
Jeronimo Rd
El Toro Rd
52 45
53 49 54 5546
51 56
50 57
47 48
64 65 6766
6863
58 5960
61 62
74 7572
73 6970
71 Inset A
Inset B
Inset B
Inset C
Inset C
DimensionDr
CanadaRd
Commercentre Dr
CentreDr
OrangeAve
AspanSt
RockfieldBlvd
Sources: City of Lake
Forest; SWA Group.

Date: September 13,
2021.
(Inset map scales vary)
Í
0 ½¼
Miles
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Underutilized Residential Sites
The City has identified two properties currently de signated for residential development as suitable for accommodating a portion of the City’s moderate and above moderate-income RHNA allocation.

The first site is an 0.63 acre site designated for low-medium density residential. This site is the last remaining vacant residentially-designated site in the City and can accommodate up to 8 units for above moderate income households.

The City has identified Saddleback Ranch Apartments as an opportunity site for redevelopment. Saddleback Ranch Apartments is currently developed with 304 mult ifamily units (approximately 9 du/ac), which is significantly less than the maximum allowable densit y of 25 du/ac. To determine the development potential of this site, the City assumed that redevelopment wo uld occur at 80% of the maximum density (678 units) and subtracted the number of existing units (304) to arrive at a potential additional yield of 374 units. Half of the potential additional units (187) are assumed to be affordable to moderate-income households and half to above moderate-income households.

The owners of the Saddleback Ranch Apartments have met with the City on 3 separate occasions in the last 10 years to discuss their plans to demolish the existing buildings and construct a new 3-4 story apartment project. The property owner continues to indicate that there is an interest in redeveloping the site at a higher density consistent with the current land use designation and zoning standards. The property was constructed over 30 years ago, and is now reaching the end of its useful life. Significant remains and improvements (e.g., plumbing, electrical, and roof repairs) will need to be made to the property to keep it functioning in the coming years and it is likely that the site is now poised to redevelop given t he immediate investments that will be required. Additionally, the City of Mission Viejo, loca ted immediately to the property’s east, has identified sites to accommodate its RHNA in proximity to Saddleback Apartments. There is an energy and interest for redevelopment of these sites which spans jurisdictio nal boundaries. Given the age of the building, repairs required to maintain the existing use, the site of the site and development potential (in an area with very few sizable sites designated for multifamily development), the City finds that this is a suitable site to accommodate a portion of the City’s moderate and above-moderate income RHNA.

These vacant properties, identified in Table 65, have the potential to yield 382 units. None of these units are assumed to be affordable to lower income households.

TABLE 65: SUMMARY OF RESIDENTIAL DEVELOPMENT POTENITAL ON GENERAL VACANT SITES General Plan Zoning Max
Density
Acres Realistic
Capacity
(units)*
Affordability
Low-Medium Density
Residential
(APN 617-064-18)
R2
Multifamily
Dwellings
15 du/ac 0.63 8 Above Mod
Medium Density
Residential
(APN 613-351-05)
R2
Multifamily
Dwellings
25 du/ac 33.92 374** Moderate/
Above Mod
Total 448.8 382
Notes:
* Unit count is based on 80 percent of the maximum site density. This estimate is based on existing patterns of development in residential areas.
** The City has identified Saddleback Apartments as an opportunity site for redevelopment. Saddleback Apartments is currently developed with 304 multifamily units (approximately 9 du/ac), which is significantly less than the maximum allowable density of 25 du/ac. To determine the development potential of this site, the City assumed that redevelopment would occur at 80% of the maximum density (678 units) and subtracted the number of existing units (304) to arrive at a potential additional yield of 374 units. Half of the Item: 11
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potential additional units (187) are assumed to be affordable to moderate-income households and half to above moderate-income households.

Underutilized Sites in Mixed-Use Areas
As described in the City’s Land Use Element, new residential growth is anticipated to occur in mixed-use focus areas located throughout the City. Although the General Plan identifies opportunities for development of up to 11,500 units in all of its mixed-use areas, for the purpose of this Housing Element and identifying the remaining units needed to meet the City’s assigned housing need, only highly desirable and suitable mixed- use parcels larger than 0.50 acres are included in this portion of the sites inventory. Of the 56 underutilized parcels identified in mixed-use areas which are planned to accommodate a portion of the City’s lower income RHNA, only one site (in the Foothill Ranch Towne Center) is larger than 10 acres. However, the City chose to include this site in its inventory due to the changing nature of the movie business and the potential for this large parcel to develop residential units on a portion of its existing surface parking area. The development potential at this site is 342 units. If the site were excluded from the inventory, the City would still have sufficient capacity to accommodate its RHNA allocation at all income levels.

Only 50% of the development potentia l at mixed-use sites has been allocated to accommodate the City’s RHNA allocation, to account for potential mixed-use and non-residential development on portions of the sites.

For example, a vacant two-acre parcel designated as Mixed-Use 32, which allows a density of 30 or more du/ac, is assumed a yield of 32 units for purposes of meeting the RHNA allocation. By building in this generous buffer, the City may accommodate development at levels higher than those identified in the sites inventory while ensuring sufficient site availability fo r units affordable to lower-income households for the duration of the planning period.

Table 66 summarizes the City’s inventory of underutilized sites in mixed-use areas. Available sites are shown in Figure 19 and are described in detail in Appendix A.

TABLE 66: SUMMARY OF RESIDENTIAL DEVELOPMENT POTENTIAL ON UNDERUTILIZED MIXED-USE SITES General Plan Zoning* Max
Density
Acres Realistic
Capacity
(units)**
Affordability
Level
Mixed-Use 32 MU-32 32 du/ac 10 161
Ex Low/Very
Low, Low,
Mod
Mixed-Use 43 MU-43 43 du/ac 97 2,039
Ex Low/Very
Low, Low,
Mod
Urban Industrial 25 UI-25 25 du/ac 35 426 Mod, Above
Mod
Urban Industrial 43 UI-43 43 du/ac 16 339
Ex Low/Very
Low, Low,
Mod
Total 159 2,965
Notes:
* The City adopted its comprehensive General Plan Update in June 2020 and immediately began work on an update to its Zoning Code to create new zoning districts to implement the City’s new mixed-use land use designations. The new zoning districts are expected to be adopted by early 2022.
** Only 50% of the total potential yield at mixed-use sites has been identified to accommodate the City’s RHNA to account for the potential for mixed-use and non-residential development on a portion of the sites. Projects can be 100% residential.

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for densities of at least 30 du/ac. This Housing Element only relies on 123 acres of the 383 acres designated for such development, or just over 32%. In addition, given that the City has assumed only a 50% yield at mixed-use sites (regardless of density), the City has developed ex tremely conservative estimates regarding future development potential. It is entirely possible that new development will exceed capacities identified in the Housing Element and more closely reflect the development potential identified and analyzed as part of the City’s comprehensive General Plan update.

The City has a successful history of redevelopment of underut ilized/developed sites. Successful projects include:
 Foothill Ranch Auto Center: The Foothill Ranch Auto Center, which was previously designated for commercial development, was rezoned and redeveloped as a mixture of single-family and multifamily residential uses.
 Mountain View: The Mountain View affordable projec t includes demolition of an underutilized office building to allow for development of 71 units (70 affordable units).  The Meadows (formerly “Nakase”): The Meadows pr operty (approximately 122 acres) was previously a wholesale plant nursery. It is cu rrently (2021) entitled for development of up to 606 units and will include deed-restricted affordable units.
 Parkside: Toll Brothers redevelop ed an underutilized 30-acre industrial site, (located northwest of the Rancho Parkway/Portola Parkway intersection) previously used as a sand and gravel mine, with 195 single-family dwellings.
 Encanto: The Encanto project consists of 52 singl e-family residential units on 5.75 acres that was formerly designated Light Industrial by the General Plan and changed to Low-Medium Density Residential. The site was previously undeveloped but was home to temporary uses.  Opportunity Study Area (OSA): The vast majority of residential development experienced by the City over the last 15 years is a direct result of redevelopment of underutilized sites included in the City’s Opportunities Study Area (OSA). Following City Council approval of a General Plan Amendment, Zone Change, and Development Agreements, which paved the way for redevelopment of 838 acres of land previously zoned for business and industria l uses (on 5 large properties), the development community moved forward with preparing and submitting project applications within 3 months.

Regionally, Lake Forest’s neighbors (including Laguna Woods, Mission Viejo, Irvine, and others) are experiencing similar patterns of redevelopment of underutilized sites at densities and intensities not previously seen in the South Count y area. Development in these citi es demonstrates the viability of redevelopment of underutilized sites in the region cons istent with the City’s assumptions regarding development interest and viability. Recently, in the City of Mission Viejo, a Home Depot center was redeveloped into housing, new residential development was added next to Trader Joe’s in Laguna Hills, and the Laguna Hills Mall is adding significant new hous ing as part of a redevel opment of the underutilized commercial property.

In April of 2021, the City entered into a contract with SWA, an urban planning and design consultant, to prepare the Development Standards for the new Mixed-Use land uses categories included in the General Plan. SWA has teamed up with Economic & Planning Systems (EPS) and economic consultant. While SWA will draft development standards, including density, height, massing, form and setbacks, and prepare Development Standard Feasibility Test for one large site in each of the 5 Focus Areas to ensure that the allowable density for residential us es can be achieved. EPS will prepar e a corresponding proforma cash flow model for each of the tests to simulate the project economics of the concepts from the perspective of a private developer to evaluate the economic feasibility.

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ENVIRONMENTAL CONSTRAINTS
The sites inventory analysis reflects land use designati ons and densities established in the recently (2020) adopted Land Use Element. Thus, any environmental constr aints that would lower the potential yield (e.g., fire hazards) have already been accounted for. Any additional constraints that would occur on a more detailed site review basis would be addressed as part of the individual project review process.

The City’s capacity to meet its RHNA allocation is not constrained by environmental conditions.

ADEQUACY OF SITES FOR RHNA
As described in the previous section, the City wa s allocated 3,236 housing units by the SCAG Regional Housing Needs Assessment (RHNA) for 2021 through 2029. The City’s progress to date includes 755 461 units that have been constructed, are under constructi on, or have received building permits since June 30, 2021. The City also has an additional 753 976 units that have been approved/entitled. The City has 1,84 76 units remaining to be accommodated.

As shown in Table 67, the City has adequate sites to accommodate the RHNA for all income levels.

For lower income units (extremely low income, very low income, and low income), the City has a remaining allocation of 1,3061,295 units and can accommodate 1,779 units on sites that allow densities of at least 30 units per acre, consistent with the assumptions for lower income sites established by Government Code Section 65583.2(c)(3)(B)(iii). This is further supported by the City’s history of successful redevelopment of underutilized sites, including the development of affordable projects. The City also has a surplus of sites for moderate and above moderate-income units.

TABLE 67: COMPARISON OF RHNA CANDIDATE SITES REALISTIC CAPACITY AND RHNA Candidate Sites Extremely
and Very
Low income
(0-50% AMI)
Low income
(51-80%
AMI)
Moderate
income (81-
120% AMI)
Above
Moderate
income (121%+
AMI)
Total
Remaining 6th Cycle
RHNA 848 445447 553552 0 (with a surplus
of 118 48 units) 1,8476
ADUs 8 14 9 1 32
Underutilized
Residential Sites* 0 0 187 195 382
Underutilized Sites in
Mixed-Use Areas* 1,167 608 979 218 2,965
Total + 327 329
(surplus)
+ 177
(surplus)
+ 622 618
(surplus)
+ 532 456
(surplus)
+
1,6581,579
(surplus)
Notes:
*The realistic capacity analysis of underutilized residential land assumes that only 80% of the potential capacity would be realized.

The realistic capacity analysis of underutilized sites in mixed-use areas assumes that only 50% of the potential capacity of development at 30 du/ac would be realized. If the sites develop closer to their maximum capacity, which has been realized as part of past projects, the City’s surplus of units affordable to lower-income households would be significantly higher. 5D. Housing, Financial, and Administrative Resources

STATE AND FEDERAL RESOURCES
Community Development Block Grant Program (CDBG)
Federal funding for housing programs is available through the Department of Housing and Urban Development (HUD). The City’s use of federal funds is described in the 2020-2024 Consolidated Plan. As an Item: 11
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Entitlement City, Lake Forest participates in the Co mmunity Development Block Grant (CDBG) program.

CDBG funds are used by the City to fund its Hous ing Rehabilitation Loan Program (see Program 11). The City does not currently participate in other HUD programs such as HOME, Emergency Shelter Grant (ESG) or Housing Opportunities for Persons with AIDS (HOPWA).

HOME Investment Partnership
Funds are granted by a formula basis from HUD to increase the supply of decent, safe, sanitary, and affordable housing to lower income households. Eligible activities include new construction, acquisition, rental assistance and rehabilitation. The City participates in the Orange County-administered HOME Program, which administers HOME funds to projects in participating jurisdictions. County-administered HOME funds for first time homebuyer assistance are m ade available to residents or employees of the local jurisdictions participating in the HOME program. Ne w development projects are typically allocated funding on a competitive basis.

Housing Choice Voucher Program Rental Assistance (Formerly “Section 8”) The City of Lake Forest works cooperatively with t he Orange County Housing Authority, which administers the Housing Choice Voucher Program. The program assists very-low-income, elderly and disabled households by paying the difference between 30% of an eligible household's income and the actual cost of renting a unit. The City facilitates use of the voucher program within its jurisdiction by encouraging apartment owners to list available rental units with the Count y Housing Authority for potential occupancy by tenants receiving vouchers.

Project Based Housing Voucher program is a component of the form er Section 8 Housing Choice Voucher program funded through HUD. The program's objective is to induce property owners to make standard housing available to low-income families at rents within the program limits. In re turn, the Housing Authority or HUD enters into a contract with the owner that guarantees a certain level of rents.

Section 811/202 Program (Supportive Housing for Persons with Disabilities/Elderly) – Non- profit and consumer cooperatives can receive no interest capital advances from HUD under the Section 202 program for the construction of very-low income rental housing for seniors and persons with disabilities. These funds can be used in conjunction with Section 811, which can be used to develop group homes, independent living facilities and immediate care facilities. Eligible activities include acquisition, rehabilitation, new construction and rental assistance.

California Housing Finance Agency (CalHFA) Multifamily Programs Provides permanent financing for the acquisition, rehabilitation, and preservation or new construction of rental housing that includes affordable rents for Low and M oderate income families and individuals. One of the programs is the Preservation Acquisition Finance Program that is designed to facilitate the acquisition of at- risk affordable housing developments and provide lowcost funding to preserve affordability.

CalHOME Program
Provides grants to local public agencies and non- profit developers to assist households in becoming homeowners. CalHome funds may be used for predevelopment, development, acquisition, and rehabilitation costs as well as downpayment assistance. While CalHOME funding has been limited to disaster assistance in recent years, this would be an appropriate program for the City to pursue to begin to develop a local portfolio of housing assistance programs and funds.

California Housing Finance Agency (CHFA)
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Offers permanent financing for acquisition and rehabilit ation to for-profit, non-profit, and public agency developers seeking to preserve "at-risk" housing units. In addition, CHFA offers low interest predevelopment loans to nonprofit sponsors through its acquisition/rehabilitation program.

Emergency Housing and Assistance Program (EHAP)
Provides funds to local government agencies and non-prof it corporations for capital development activities and facility operation for emergency shelters, transitional housing and safe havens that provide shelter and supportive services for homeless individuals and families. No current funding is offered for this program.

Federal Home Loan Bank System
Facilitates Affordable Housing Progr ams (AHP), which subsidize the inte rest rates for affordable housing.

The San Francisco Federal Home Loan Bank District provides local service within California. Interest rate subsidies under the AHP can be used to finance the purchas e, construction, and/or rehabilitation of rental housing. very low-income households must occupy at least 20% of the units for the useful life of the housing or the mortgage term.

Housing for a Healthy California (HHC)
Provides funding on a competitive basis to deliver supportive housing opportunities to developers using the federal National Housing Trust Funds (NHTF) allocations for operating reserve grants and capital loans. The Department will also utilize from a portion of moneys collected in calendar year 2018 and deposited into the Building Homes and Jobs Trust Fund to provide funding through grants to counties for capital and operating assistance. Funds will be announced through a Notice of Funding Availability.

Infill Infrastructure Grant Program (IIG)
Funds infrastructure improvements to facilitate new housing development with an affordable component in residential or mixed-use infill projects and infill areas.

Low-Income Housing Tax Credit Program
The Low-Income Housing Tax Credit Program was created by the Tax Reform Act of 1986 to provide an alternate method of funding low-and moderate-income housing. Each state receives a tax credit, based upon population, toward funding housing that meets program guidelines. The tax credits are then used to leverage private capital into new construction or acquisition and rehabilitation of affordable housing. Limitations on projects funded under the Tax Credit programs include minimum requirements that a certain percentage of units remain rent-restricted, based upon median income, for a term of 15 years. The City has included Program 5: Facilitate Affordable and Special Needs Housing Construction to continue assisting developers in gaining funding for the development of affordable housing through the LIHTC program.

Low-income Housing Preservation and Residential Home Ownership Act (LIHPRHA) Requires that all eligible HUD Section 236 and Section 221(d) projects “at-risk” of conversion to market-rate rental housing through the mortgage prepayment option be subject to LIHPRHA Incentives. The incentives to owners include HUD subsidies which guarantee owners an 8% annual return on equity. Owners must file a Plan of Action to obtain incentives or offer the project for sale to a) non-profit organizations, b) tenants, or c) public bodies for a 12 month period followed by an additional three-month sale to other purchasers. Only then are owners eligible to prepay the subsidized mortgages.

National Housing Trust Fund
A permanent federal program with dedicated sources of funding not subject to the annual appropriations.

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The funds can be used to increase and preserve the supply of affordable housing, with an emphasis on rental housing for extremely low income households. Californi a is receiving approximately $10.1 Million for the program in 2019. Funds will be made available through a competitive process and will be announced through a Notice of Funding Availability.

SB 2 Planning Grants Program
Provides one-time funding and technical assistance to all eligible local governments in California to adopt and implement plans and process improvements that streamline housing approvals and accelerate housing production. Eligible activities include updating a variety of planning documents and processes such as general plans and zoning ordinances, conducting environm ental analyses, and process improvements that expedite local planning and permitting. The planning grants program is funded through the Building Homes and Jobs Act Trust Fund (SB 2, Chapter 364, Statutes of 2017). The City applied for funds through this program and was approved for funding of various programs.

California Community Reinvestment Corporation (CCRC)
A multifamily affordable housing lender whose mission is to increase the availability of affordable housing for Low-income families, seniors and residents with special needs by facilitating private capital flow from its investors for debt and equity to developers of affordable housing. Eligible activities include new construction, rehabilitation and acquisition of properties.

Southern California Housing Finance Agency (SCHFA) Mortgage Financing for First-Time Homebuyers The SCHFA raises funds for mortgage financing through the sale of tax-exempt revenue bonds. The City cooperates with lenders and the County in advertising the availability of the SCHFA program.

Supplement Security Income (SSI)
A federal welfare program for persons 65 and over and for blind or disabled persons of any age. "Disabled" means that you have a physical or mental disability that is expected to keep you from working for 12 months or longer, or will result in death. Medicare is a federal health insurance program for people who are 65 and over, for some younger people with permanent disab ilities, and for people with end-stage kidney disease.

SSI may provide total monthly income or it may supplement a low income. In addition to cash payments, SSI recipients are automatically covered by Medi-Cal, the state health insurance plan.

ADMINISTRATIVE RESOURCES
Agencies with administrative capacity to implement programs contained in the Housing Element include the City of Lake Forest and local and regional nonprofit private developers. The City of Lake Forest Community Development Department takes the lead in implementing Housing Element programs and policies. The City also works closely with non-profit developers to expand affordable housing opportunities in Lake Forest.

COMMUNITY DEVELOPMENT DEPARTMENT
The Community Development Department consists of four divisions: Planning, Housing, Building and Safety, and Code Enforcement. The Department coordinates development activity within the City to ensure planned orderly growth. The Planning Division administers the General Plan and Zoning Code, the California Environmental Quality Act (CEQA) and other enviro nmental regulations, and provides primary staff assistance to the Planning Commission. The Housing Division manages the City’s Community Development Block Grant.

NON-PROFIT DEVELOPERS
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active in the region; several are included in the State’s list of entities with the legal and managerial capacity to acquire and manage at-risk projects.
• C&C Development
• The Waterford Group
• Community Housing Works
• National Community Renaissance (National CORE)
• The City has included Program 5: Facilitate Affordable and Special Needs Housing Construction to work closely with developers to expand the range of affordable housing options in Lake Forest. 5E. Energy Conservation Opportunities
State of California Energy Efficiency Standards for Residential and Nonresidential Buildings were established in 1978 in response to a legislative mandate to r educe California's energy consumption. The standards are codified in Title 24 of the California Code of Regulations and are updated periodically to allow consideration and possible incorporation of new energy efficiency technologies and methods. California's building efficiency standards (along with those for energy efficient appl iances) have saved nearly $80 billion in electricity and natural gas costs since 1978.5F
Title 24 sets forth mandatory energy standards and requires the adoption of an “energy budget” for all new residential buildings and additions to residential buildings. Separate requirements are adopted for “low-rise” residential construction (i.e., no more than 3 stories) and non-residential buildings, which includes hotels, motels, and multi-family residential buildings with four or more habitable stories. The standards specify energy saving design for lighting, walls, ceilings a nd floor installations, as well as heating and cooling equipment and systems, gas cooling devices, conservation standards a nd the use of non-depleting energy sources, such as solar energy or wind power. The home building industry must comply with these standards while localities are responsible for enforcing the energy conservation regulations through the plan check and building inspection processes.

Examples of techniques for reducing residential energy use include the following:
• Glazing – Glazing on south facing exterior walls a llows for winter sunrays to warm the structure.

Reducing glazing and regulating sunlight penetration on the west side of the unit prevents afternoon sunrays from overheating the unit.
• Landscaping – Strategically placed vegetation reduces the amount of direct sunlight on the windows.

The incorporation of deciduous trees in the landscaping plans along the southern exposure of units reduces summer sunrays, while allowing penetration of winter sunrays to warm the units. • Building Design – The implementation of roof over hangs above southerly facing windows shield the structure from solar rays during the summer months.
• Cooling/Heating Systems – The use of attic ventila tion systems reduces attic temperatures during the summer months. Solar heating systems for sw imming pool facilities saves on energy costs.

Natural gas is conserved with the use of flow restrictors on all hot water faucets and showerheads. • Weatherizing Techniques – Weatherization techni ques such as insulation, caulking, and weather stripping can reduce energy use for air-conditioning up to 55% and for heating as much as 40%.

Weatherization measures seal a dwelling unit to guard against heat gain in the summer and prevent heat loss in the winter.
• Efficient Use of Appliances – Appliances can be us ed in ways that increase their energy efficiency.

Unnecessary appliances can be eliminated. Proper maintenance and use of stove, oven, clothes dryer, washer, dishwasher, and refrigerator can also reduce energy consumption. New appliance Item: 11
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purchases can be made on the basis of efficiency ratings. • In addition to the requirements of Title 24, the City encourages energy conservation through its land use planning policies. Lake Forest contains a mix of housing, employment, commercial, recreation, educational and other community facilities. Lake Forest is located within a jobs-rich portion of south Orange County giving the residents of the City acce ss to a variety of jobs within a short driving distance. Other opportunities for energy efficiency include the following:
• Voluntary Green Building program for residential remodels • Implementation of Citywide design guidelines
• Energy efficient improvements, including window replacement, are eligible for rehabilitation loan program
• The City’s existing network of on- and off-road bi cycle trails link residential areas to employment centers within Lake Forest and surrounding cities.

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6. Affirmatively Furthering Fair Housing
All Housing Elements due on or after January 1, 2021 must contain an Assessment of Fair Housing (AFH) consistent with the core elements of the analysis requir ed by the federal Affirmatively Further Fair Housing Final Rule of July 16, 2015. Under State law, affirm atively further fair housing means “taking meaningful actions, in addition to combatting discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics”. These characteristics can include, but are not limited to, race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability.

The AFFH analysis must contain the following:
 A: Outreach
 B: Assessment of Fair Housing
• Key Data and Background Information
• Fair Housing Enforcement and Outreach Capacity
• Integration and Segregation Patterns and Trends
• Racially or Ethnically Concentrated Areas of Poverty
• Disparities in Access to Opportunity
• Disproportionate Housing Needs in the Jurisdiction
• Displacement Risk
 C: Sites Inventory
 D: Identification of Contributing Factors
 E. Goals and Actions
While this section provides a focused analysis of fair housing issues in Lake Forest, several other sections of the Housing Element address the issue and are included in this section by reference. 6A. Outreach
Appendix B of the Housing Element details the public participation that was undertaken as part of the Housing Element preparation process. The City of Lake Forest has made an effort to involve the public in the update of its Housing Element and has solicited input from the public throughout the year-long Housing Element process. The City provided ongoing notification to local housing service providers that represent lower income and special needs populations, such as The Kennedy Commission, Welcoming Neighbors Home, and the Fair Housing Council of Orange County and conducted interviews with each. Appendix B to the Housing Element provides a summary of t he key comments received during the Housing Element update process, and how they have been considered and addressed in the Element. The City implemented the following public outreach program.

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PROJECT WEBSITE
A dedicated project website (https://lakeforest.generalplan.org/) serves as the main conduit of information for individuals who can access material online. The proj ect website launched in January 2018 (first associated with the City’s comprehensive General Plan Update) and is regularly updated to reflect ongoing community input opportunities, advertise draft work products, and answer commonly asked questions.

Since the launch of the Housing Element Update in September 2020, the project website received over 1,200 views from 950 unique visitors resulting in a total of 2,700 pageviews. The peak of activity happened coincident with the online surveys in December 2020.

VIRTUAL WORKSHOP
As part of the community outreach, a virtual community workshop was conducted to educate the community about housing issues and opportunities facing Lake Fore st, and to gather input on housing-related topics.

The virtual workshop was hosted on the project webs ite throughout the month of December 2020. The extended timeframe was intended to allow community members and stakeholders to participate at their leisure and in accordance with their schedule and av ailability. The Virtual Community Workshop consisted of three parts:
• Part A: Overview video describing Housing Elements and why they are important • Part B: PowerPoint presentation describing existing conditions in Lake Forest and the City’s Housing Element Update process
• Part C: Housing Element Survey (described below)

HOUSING ELEMENT SURVEY
The City hosted two online Housing Element surveys which were available from November 23, 2020 through December 22, 2020. The surveys asked for input on the community’s housing priorities and strategies to address Lake Forest’s future housing growth needs. A total of 62 individuals responded to the first survey, which focused on issues of home maintenance, affordability, home type, and living conditions. A total of 49 individuals responded to the second survey, which focused on community priorities related to housing. A summary of the key survey results is provided in the Housing Element Introduction section, with the complete results included in Appendix B.

STAKEHOLDER INTERVIEWS
The City invited key community stakeholders to meet with Staff to discuss housing issues in Lake Forest.

The City met with the Kennedy Commission, Welcoming Neighbors Home, and the Fair Housing Council of Orange County. The Fair Housing Council of Orange County provided specific input regarding fair housing issues facing Lake Forest residents, such as access to information and the process for training/educating landlords and tenants, and well as issues facing the region.

COMMUNITY OPEN HOUSE
The City is scheduled to host a community open house on the Public Draft Housing Element in early October 2021. At this open house, the City will present the Public Draft Housing Element and solicit feedback on the Element that will be considered and reflected in the final document. The City will specifically present information related to fair housing and describe the goals, policies, and programs that the City has added to the Housing Element to address this topic.

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ADVERTISEMENTS
The City of Lake Forest maintains various social media accounts including Facebook, Nextdoor, and Instagram. Starting in September 2020, and continuing throughout the project, the City posted updates to its social media platforms advertising opportunities to provide input and alerting the public to upcoming meetings and workshops.

EMAILS
The project team complied a database of community members and stakeholders who registered to be notified via email of future public engagement opportunities and key deliverables. Direct emails were sent to these individuals to publicize the Housing Element Community Meeting, the Online Workshop, the Fair Housing Survey, and the Public Review Draft 2021-2029 Housing Element. 6B. Fair Housing Needs Assessment
This section presents an overview of available federal, state, and local data to analyze fair housing issues in Lake Forest. This data is supplemented with local knowledge of existing conditions in the community to present a more accurate depiction of fair housing issues in Lake Forest, and a more informed perspective from which to base goals, policies and programs to affirmatively further fair housing.

KEY DATA AND BACKGROUND INFORMATION
In 2016, Lake Forest participated with 15 other Orange County Community Development Block Grant (CDBG) entitlement cities to prepare a regional Analysis of Impediments to Fair Housing Choice (AI) to fulfill their HUD requirement and remove barriers to fair hous ing choice for all their residents. The AI examined policies, procedures, and practices within the region that may limit a person’s ability to choose their residence free from discrimination. The AI provided an overview of laws, regulations, conditions, or other possible obstacles that may affect an individual or a household’s access to housing in the region. It also presented local and regional demographic profiles, assessed the extent of housing needs among specific groups, identified existing barriers or impediments that may limit housing choice, and proposed actions to overcome those barriers.

The City's demographic and income profile, househol d and housing characteristics, housing cost and availability, and special needs populations are discussed in previous sections of this Background Report.

Barriers to fair housing choice specific to the City of Lake Forest that were identified in the County AI and the commitments of the City to address identified barriers were incorporated into this AFH. Supplemental data analysis was conducted to further understand potential fair housing issues, within the context of AFH topics, at the city-level. Lake Forest is comprised of 16 Census Tracts, although several are only partially located in Lake Forest. Figure 3 shows the Tract boundaries.

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FAIR HOUSING ENFORCEMENT AND OUTREACH CAPACITY
The Orange County Analysis of Impediments to Fair Housing Choice (County AI) was adopted by the Lake Forest City Council in June 2020 and “is a thorough examination of structural barriers to fair housing choice and access to opportunity for members of historically marginalized groups protected from discrimination by the federal Fair Housing Act (FHA).”8
For the County AI, a variety of tools were used for the community participation process, including community meetings, focus groups and public hearings. The AI preparers also reached out to tenants, landlords, homeowners, fair housing organizations, civil rights a nd advocacy organizations, l egal services providers, social services providers, housing developers, and industry groups to hear directly about fair housing issues affecting residents of Orange County. Evening comm unity meetings were held in Mission Viejo, Westminster/Garden Grove, Santa Ana, and Fullerton. Additional outreach was conducted for members of protected classes, including the Latino and Vietnamese communities. All community meetings had translation services available if requested in Spanish and Vietname se. In addition, all meetings were held in locations accessible to people with mobility issue. 9
The County AI describes the departments and organizations that handle fair housing enforcement and outreach in Lake Forest. The California Department of Fair Employment and Housing (DFEH) investigates complaints of employment and housing discrimination. The Fair Housing Council of Orange County (FHCOC) provides services throughout the County, including Lake Forest, to ensure equal access to housing. The Council’s services include outreach and education, homebuyer education, mo rtgage default counseling, landlord-tenant mediation, and limited low-cost advocacy. The Fair Housi ng Council investigates claims of housing discrimination and assists with referrals to DFEH. Community Legal Aid SoCal is a legal service provider serving low-income people in Orange County and Southeast Los Angeles County.

During the 2019-2020 report period the City of Lake Forest took the following actions (on its own or in cooperation with regional partners and the Fair Housing Council of Orange County (FHCOC)) to overcome impediments to fair housing choice identified in the regional AI and demonstrate and implement its outreach capacity to provide outreach and education to assure community members are well aware of fair housing laws and rights:
• Fair Housing Community Education – During 2019-20, the FHCOC regionally conducted or participated in 115 education and/or outreach activities, reaching a culturally and ethnically diverse audience, in which they made participants aware of fair housing laws and counseling services (including services to help households improve their readiness for a home purchase). Three of these activities took place in the city of Lake Forest. Regionally, over 1,900 people were served by these activities.

Through its various regional outreach efforts FHCOC distributed over 36,150 pieces of literature on fair housing, FHCOC’s services and other housing-related topics, in either English, Spanish or Vietnamese.

Additionally, throughout Orange County FHCOC held 21 training sessions for rental property owners/managers. FHCOC presented 2 fair housing seminars for housing providers in cooperation with the Apartment Association of Orange County (AAOC), at AAOC’s Santa Ana office. Nineteen general fair housing workshops intended for attendance by either housing consumers and/or providers were held throughout Orange County. One landlord workshop and two tenant workshops occurred in Lake Forest.
• Fair Housing Enforcement – On a regional basis, FHCOC staff received 96 allegations of housing discrimination and opened 40 cases where the allegations seemed sufficiently meritorious to warrant further investigation and/or action. Four allegations arose from Lake Forest, however none resulted in the opening of a case file involving housing in Lake Forest. On a regional basis, FHCOC also conducted 114 paired on-site, systemic tests for discriminatory rental housing practices, including 4 for

8 Orange County Analysis of Impediments to Fair Housing Choice , Prepared by the Orange County Jurisdictions and the Lawyers’ Committee for Civil Rights Under Law, August 6, 2020.
9 Orange County Analysis of Impediments to Fair Housing Choice , Prepared by the Orange County Jurisdictions and the Lawyers’ Committee for Civil Rights Under Law, August 6, 2020.

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real estate brokerage transactions and 4 for pre-application lending transactions, with 3 of these systemic tests occurring in Lake Forest.
• Housing Dispute Evaluation & Resolution – On a regional basis, activities provided by FHCOC included assisting 1,984 unduplicated households addressing 7,215 issues, disputes and/or inquires.

Of these, 78 unduplicated households, involving 273 issues, disputes and/or inquires, were from Lake Forest.
• Reasonable Accommodations – On a regional basis, 14 inquiries regarding reasonable accommodations and modifications were received by FHCOC that resulted in casework beyond basic counseling. None of the inquiries arose from Lake Forest. Overall, 13 of the 14 clients requested and received a reasonable accommodation, while another request was denied. It is under consideration as to whether an administrative complaint should be filed with the Fair Housing and Equal Opportunity (FHEO) Office of the U.S. Department of Housing and Urban Development (HUD). • Web-based Outreach – FHCOC’s website currently has an on-line housing discrimination complaint- reporting tool that generates an email to FHCOC. The tool is also used for other, non-discrimination, housing-related issues, which sometimes indirectly reveal discriminatory practices. The City of Lake Forest has a link to the FHCOC website where residents can access this information. • Monitoring On-line Advertising – Orange County rentals listed on Craigslist were monitored by FHCOC for discriminatory content (as permitted by staffing limitations). Any discriminatory advertisements were flagged as prohibited and FHCOC responded to these ads through Craigslist’s reply mechanism in order to inform the poster of possible discriminatory content. In many instances it was not possible to identify the property address and the identity of the individual making the posting.

When investigation was found to be feasible, the ad was referred to FHCOC’s investigators for possible additional investigation and enforcement action. Other on-line rental advertising sites (e.g., OC Register, LA Times, Westside Rentals, etc.) were sporadically monitored; however, the lack of an efficient text search function on these sites made monitoring them less practical. Regarding federally protected bases, without exception, among the ‘apt / housing’ Craigslist rental listings, the identified problematic postings indicated restrictions with regard to children under the age of 18 or improper preference for seniors or ‘older adults’ for housing opportunities that did not appear to qualify as housing for older persons (age 55 and over). Overt racial or national origin discrimination was not observed. Advertising that continued to limit access to housing for persons utilizing a federally-funded Housing Choice Voucher (often called ‘Section 8’) or other types of rental assistance was observed despite it having become illegal in California as of January 1, 2020. Advertising in the ‘rooms / shared’ area of Craigslist were observed to have a higher incidence of stated preferences that violated fair housing law. However due to the practical aspects of resource limitations and case law considerations of shared housing situations, almost none were not acted upon.

The monitoring of regional Craigslist and other advertising resulted in the filing of four complaints with HUD for violations involving familial status, all of which involved Orange County properties, none of which were in Lake Forest. One of these four violations was found on a non-Craigslist platform. The Craigslist monitoring also resulted in the filing of three complaints with the California Department of Fair Employment and Housing (DFEH) for violations of California’s source of income protection. These all related to new law, effective January 1, 2020, which made it illegal to discriminate on the basis of a person utilizing a federally-funded Housing Choice Voucher (often called ‘Section 8’) or other types of rental assistance. One of those complaints involved a property in Orange County. • Monitor Home Mortgage Disclosure Act Data - Ongoing monitoring of Home Mortgage Disclosure Act (HMDA) data continues to be infeasible due to limited resources at FHCOC. FHCOC last was able to conduct such analysis using 2008 data (then the latest available) in conjunction with the preparation of the 2010-2015 Regional AI. Analysis of updated HMDA data from 2013, as well as other mortgage lending practices, was included as part of the City of Lake Forest’s FY 2015-2020 Regional Analysis of Impediments to Fair Housing Choice (AI), which was submitted as part of its Five-Year Consolidated Item: 11
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Plan FY 2015 - 2019. Some analysis of more recent HMDA data is included in the Orange County 2020- 2024 Regional Analysis of Impediments, which is submitted as part of Lake Forest’s Five-Year Consolidated Plan FY 2020 – 2024.

The following general progress was also made:
• During 2019-20, FHCOC continued efforts to promot e housing affordability within Orange County. It provided services and outreach to organizations involved in the creation and preservation of affordable housing. These groups included the Kennedy Commission, Mental Health Association of Orange County, Radiant Health Centers (formerly Aids Services Foundation), Affordable Housing Clearinghouse, Mary Erickson Community Housing, Jamboree Housing Corporation, Orange County Congregations Community Organizations (OCCC), and Orange County Community Housing Corporation.
• During the 2019-20 report period, FHCOC continued to offer fair housing training sessions that were open to all local government staff. Any staff attending training could receive certification of their attendance.
• The FHCOC produced and provided written fair housing related materials in English, Spanish and Vietnamese to residents of Lake Forest, as well as for distribution at public locations operated by the City of Lake Forest. FHCOC also undertook specific outreach efforts to immigrant populations in low- income neighborhoods. On a regional basis, an estimated 1,150 limited English proficiency households were served during the 12-month program period, through a combination of telephonic contact and in- person education and outreach activities. FHCOC also continued to implement activities under HUD Fair Housing Initiatives Program grants, for both education and outreach and fair housing enforcement.

These program efforts specifically targeted fair housing services to persons with disabilities, minority groups and immigrant communities, especially immigrants with limited English proficiency. Program efforts included a fair housing testing program that sought to involve members of immigrant populations with limited English proficiency, both for purposes of enforcing fair housing laws as testers and as a vehicle to increase outreach to these populations.
• Through its status as a HUD-approved Housing Counseling agency, FHCOC assisted individuals, including those with limited English proficiency (LEP), with various housing related problems. This included being available to counsel and assist those who had received loans with documents, all prepared in English, which had terms that were different from what they believed or were informed they were obtaining, or of which they had less than a full understanding. Many of the other counseling activities under its HUD-approved Housing Counseling also assisted individuals with LEP.

The City of Lake Forest complies with fair housing laws and regulations as described in Table 68.

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TABLE 68: COMPLIANCE WITH FAIR HOUSING LAWS
Law Description Compliance
California Fair
Employment and
Housing Act (FEHA)

The Fair Employment and Housing Act
(FEHA) applies to public and private
employers, labor organizations and
employment agencies.

It is illegal for employers of 5 or more
employees to discriminate against job
applicants and employees because of a
protected category or retaliate against them
because they have asserted their rights
under the law.

The FEHA prohibits harassment based on a
protected category against an employee, an
applicant, an unpaid intern or volunteer, or a
contractor. Harassment is prohibited in all
workplaces, even those with fewer than five
employees.

Compliance is achieved through
strict enforcement in hiring
practices and regular training of
and by Human Resources staff.

Government Code
Section 65008

Covers actions of a city, county, city and
county, or other local government agency,
and makes those actions null and void if the
action denies an individual or group of
individuals the enjoyment of residence,
landownership, tenancy, or other land use in
the state because of membership in a
protected class, the method of financing,
and/or the intended occupancy.

For example, a violation under Government
Code section 65008 may occur if a
jurisdiction applied more scrutiny to
reviewing and approving an affordable
development as compared to market-rate
developments, or multifamily housing as
compared to single family homes.

Compliance is achieved by uniform
application of the City’s codes,
regulations, policies and practices,
including development standards,
design guidelines, application
submittal requirements, fees and
approval findings.

Government Code
Section 8899.50

Requires all public agencies to administer
programs and activities relating to housing
and community development in a manner to
affirmatively further fair housing and avoid
any action that is materially inconsistent with
its obligation to affirmatively further fair
housing.

Compliance is achieved through
consultations with community
stakeholders and support agencies
as part of program evaluating and
funding decisions. The 6 th Cycle
Housing Element Housing Plan
describes how each Program
addresses fair housing issues and
contributing factors.

Government Code
Section 11135 et seq.

Requires full and equal access to all
programs and activities operated,
administered, or funded with financial
Compliance is achieved through
promotion/availability of activities
and programs to all persons of all
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Law Description Compliance
assistance from the state, regardless of
one’s membership or perceived
membership in a protected class.
backgrounds to participate equally
in community programs and
activities.

Density Bonus Law (Gov.

Code, § 65915.)

Density bonus law is intended to
support the construction of affordable
housing by offering developers the
ability to construct additional housing
units above an agency’s otherwise
applicable density range, in exchange
for offering to build or donate land for
affordable or senior units. Density
Bonus Law also provides for incentives
intended to help make the development
of affordable and senior housing
economically feasible.

Compliance is achieved by
administration of Lake Forest
Municipal Code Chapter 9.152 –
Affordable Housing Incentives and
Density Bonus Provisions, which
provides for compliance with
Government Code Section 65915
et seq.

Housing Accountability
Act (Gov. Code, §
65589.5.)

Provides that a local agency shall not
disapprove a housing development
project, for very low, low-, or moderate-
income households, or an emergency
shelter, or condition approval in a
manner that renders the housing
development project infeasible for
development for the use of very low,
low-, or moderate-income households,
or an emergency shelter, including
through the use of design review
standards, unless it makes certain
written findings, based upon a
preponderance of the evidence in the
record.

Compliance is achieved through
the development review process
with is completed consistent with
the Housing Accountability Act.

Additionally, the City is in the
process of preparing objective
design standards to facilitate an
objective and equitable review of
applicable projects.

No-Net-Loss Law (Gov.

Code, § 65863)

Ensures development opportunities
remain available throughout the
planning period to accommodate a
jurisdiction’s regional housing need
assessment (RHNA) allocation,
especially for lower- and moderate-
income households.

The City’s draft Housing Element
identifies a surplus of sites with a
capacity to accommodate the
City’s RHNA allocation. The City
has also identified additional sites
for accommodating any shortfall
that may occur with respect to
anticipated development density
capacity, that may be added to the
site list if necessary.

Least Cost Zoning Law
(Gov. Code, § 65913.1)

Provides that, in exercising its authority
to zone for land uses and in revising its
housing element, a city, county, or city
and county shall designate and zone
Compliance is achieved through
adoption of the City’s
comprehensive General Plan
Update (2020) and the
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Law Description Compliance
sufficient vacant land for residential use
with appropriate standards, in relation
to zoning for nonresidential use, and in
relation to growth projections of the
general plan to meet housing needs for
all income categories as identified in the
housing element of the general plan.
implementation of Housing
Element Housing Plan Program 1
which commits the City to
completing the rezoning of sites
identified to accommodate the
City’s RHNA at densities and
intensities consistent with those
specified by site in Appendix A.

Excessive Subdivision
Standards (Gov. Code, §
65913.2.)

Provides that, in exercising its authority
to regulate subdivisions a city, county,
or city and county shall:
(a) Refrain from imposing criteria for
design, as defined in Section 66418, or
improvements, as defined in Section
66419, for the purpose of rendering
infeasible the development of housing
for any and all economic segments of
the community. However, nothing in
this section shall be construed to
enlarge or diminish the authority of a
city, county, or city and county under
other provisions of law to permit a
developer to construct such housing.
(b) Consider the effect of ordinances
adopted and actions taken by it with
respect to the housing needs of the
region in which the local jurisdiction is
situated.
(c) Refrain from imposing standards
and criteria for public improvements
including, but not limited to, streets,
sewers, fire stations, schools, or parks,
which exceed the standards and criteria
being applied by the city, county, or city
and county at that time to its publicly
financed improvements located in
similarly zoned districts within that city,
county, or city and county.

Compliance is achieved through
the implementation of a fair and
equitable development review
process which is administrated
consistent with the Excessive
Subdivision Standards Act.

Limits on Growth
Controls (Gov. Code, §
65302.8.)

Provides that, if a county or city, including a
charter city, adopts or amends a mandatory
general plan element which operates to limit
the number of housing units which may be
constructed on an annual basis, such adoption
or amendment shall contain findings which
The City’s draft Housing
Element and the elements in
the City’s recently adopted
General Plan do not include
any provisions which further
limits (relative to the current
Item: 11
469

City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-142
Law Description Compliance
justify reducing the housing opportunities of the
region. The findings shall include all of the
following:
(a) A description of the city’s or county’s
appropriate share of the regional need for
housing.
(b) A description of the specific housing
programs and activities being undertaken by
the local jurisdiction to fulfill the requirements
of subdivision (c) of Section 65302.
(c) A description of how the public health,
safety, and welfare would be promoted by such
adoption or amendment.
(d) The fiscal and environmental resources
available to the local jurisdiction
Housing Element and prior
General Plan) the
development of housing,
except such provisions as may
be required by state or federal
laws.

Lake Forest City CouncilAugust 16, 2022

Lake Forest City Council
August 16, 2022