Agenda packet — Lake Forest City Council, August 16, 2022 (part 3 of 4)

Housing Element Law
(Gov. Code, § 65583,
esp. subds. (c)(5),
(c)(10).)

Section 65583 stipulates that the housing
element shall consist of an identification and
analysis of existing and projected housing
needs and a statement of goals, policies,
quantified objectives, finan cial resources, and
scheduled programs for the preservation,
improvement, and development of housing.

The housing element shall identify adequate
sites for housing, including rental housing,
factory-built housing, mobilehomes, and
emergency shelters, and shall make adequate
provision for the existing and projected needs
of all economic segments of the community.

Subdivision (c)(5) provides that, in order to
make adequate provision for the housing
needs of all economic segments of the
community, the program shall promote and
affirmatively further fair housing opportunities
and promote housing throughout the
community or communities for all persons
regardless of race, religion, sex, marital status,
ancestry, national origin, color, familial status,
or disability, and other characteristics
protected by the California Fair Employment
and Housing Act (Part 2.8 (commencing with
Section 12900) of Division 3 of Title 2), Section
65008, and any other state and federal fair
housing and planning law.

Compliance is achieved
through preparation and
adoption of a Housing Element
found to be in substantial
compliance with State Housing
Element Law by the California
Department of Housing and
Community Development.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-143
Locally, the City of Lake Forest provides outreach and education to assure community members are well aware of fair housing laws and rights by providing in formation from the Fair Housing Council of Orange County at City Hall, online, and on request. The City has included Program 22 in its Housing Plan to further strengthen its fair housing outreach capacity in a num ber of ways, including biennial updates to the City Council, additional advertisements and education on the City’s social media platforms, and providing information to schools, libraries and other community facilities for distribution.

Other relevant factors include the City’s contract with Families Forward, an affordable housing nonprofit to operate the property as affordable housing, rent the units to income-qualified families as part of its transitional housing services, and to operate the units in full compliance with the lease and successfully provide housing to families threatened with homelessness. Together with its partners, the City of Lake Forest is committed to enforcing fair housing laws and conducting meaningful outreach to provide education and support to community members.

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M I S S I O N V I E J OM I S S I O N V I E J O

R A N C H OR A N C H O

S A N T AS A N T A

M A R G A R I T AM A R G A R I T A

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W O O D SW O O D S

L A G U N A H I L L SL A G U N A H I L L S

I R V I N EI R V I N E
City of Lake Forest
Census Tract Partially or Completely
within Lake Forest*
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
Figure 3: Census Tracts within Lake Forest
Sources: City of Lake Forest; AFFH. Map Date: September 14, 2021.

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* Census tract labels followed by an asterisk (*) denote tracts that include area outside of the Lake Forest city boundary.

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ANALYSIS OF AVAILABLE FEDERAL, STATE, AND LOCAL DATA AND LOCAL KNOWLEDGE Other Relevant Factors
Lake Forest was incorporated in 1991 and is a relati vely new city in South Orange County. Prior to incorporation, residential development took place under the County of Orange. Less than 1,000 units were constructed prior to 1970. Since 1970, development has taken place primarily in Planned Communities, which served as the zoning standards. The Planned Community documents do not include any restrictive covenants or constitute a redlining practice. Since incorporation in 1991, the City approved several zone changes that allowed residential uses to be constructed on land that had formerly been restricted to non- residential development due to the impacts of the former Marine Corps Air Station at El Toro. These rezonings did not create any barriers, redlining practices or restrictive covenants.

Integration and Segregation
To inform priorities, policies, and actions, Lake forest Forest has included an analysis of integration and segregation, including patterns and trends, related to people with protected characteristics. Segregation generally means a condition in which there is a high co ncentration of persons of a particular race, color, religion, sex, familial status, national origin, or ha ving a disability or a particular type of disability when compared to a broader geographic area. Conversely, integration refers to a condition in which there is a not a high concentration of person s of a particular race, colo r, religion, sex, familial status, national origin, or having a disability or a particular type of disability when compared to a broader geographic area. The following analysis will analyze levels of segregation and integration for race and ethnicity, persons with disabilities, familial status, age, and income to identify the groups in Lake Forest that experienc e the highest levels of segregation.

Dissimilarity Index
The dissimilarity index is the most commonly used m easure of segregation between two groups, reflecting their relative distributions across neighborhoods (as defined by census tracts). The index represents the percentage of the minority group t hat would have to move to new neighborhoods to achieve perfect integration of that group. An index score can range in value from 0 percent, indicating complete integration, to 100 percent, indicating complete segregation. An index number between 30 and 60 indicates moderate similarity and community segregation while an index number above 60 is considered to show high similarity and a segregated community.

There are a number of reasons why patterns of racial segregation exist (or don’t exist) within a community.

Some of these reasons may be institutional (discriminatory lending practices) while others can be cultural (persons of similar backgrounds or lifestyles choosing to live near one another to provide support and familiarity). As such, discussions regarding segregation are complicated and there is not a “one size fits all” approach to addressing patterns of racial segregation.

Figure 4 shows the dissimilarity between each of the identified race and ethnic groups and white population for the City of Lake Forest and the Orange County metr opolitan region. The White (not Hispanic or Latino) population within Lake Forest makes up approximately 68% of the City’s population. The higher scores indicate higher levels of segregation among those race and ethnic groups. The City does not have any racial or ethnic groups with scores higher than 60 (indicating high similarity and segregation). Several race and ethnic groups (Other Races, American Indian, Native Hawaiian, and Hispanic) exhibit moderate levels of dissimilarity and segregation in Lake Forest (scores between 30 and 60), wi th most scores indicating moderate levels of segregation on the lower end of the moderate range.

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The highest levels of segregation within Lake Forest are Other Races (41.5%) and Native Hawaiian (40.2%), both of which fall within the moderate similarity and segregation range. However, it should be noted that only 102 individuals identified as “Other Race” and only 113 individuals identified as “Native Hawaiian”, and such small populations can indicate a pattern of segregati on that is not of signific ant concern. These scores correlate directly with the percentage of people within that racial or ethnic group that would need to move into a predominately white census tract in order to achieve a more integrated community. For instance, 40.2% of the Native Hawaiian population would need to move into predominately white census tract areas to achieve “perfect” integration.

When compared to the Orange County metropolitan region, Lake Forest exhibits lower levels of dissimilarity and segregation than the region as a whole for all race and ethnic groups, except for Hispanic, where the City’s index is slightly higher (32.4 in the City and 28.9 in the County). For the categories previously identified as showing moderate levels of segregation in Lake Forest, the Native Hawaiian dissimilarity index is 15 points lower in the City than in the region, while the “Other” category is 3 points lower in the City than the region.

These patterns indicate that in general, Lake Forest is less dissimilar and more integrated for most of the identified racial and ethnic groups, and the community’s most dissimilar community (its Native Hawaiian and “Other Race” populations) reflect trends seen throughout the region. This analysis suggested that patterns of segregation at the local level reflect those at the regional level as well, and that partnerships with regional agencies and advocates may be an effective way to address local issues of moderate segregation.

While not evident based on the Dissimilarity Inde x discussed above, the County AI does identify some patterns of White isolation throughout the County, including in the City of Lake Forest. The County AI points out that white residents have especially high Isolation values in eight Orange County cities (Aliso Viejo, Costa Mesa, Huntington Beach, Laguna Niguel, Lake Forest, Mission Viejo, Rancho Santa Margarita, and San Clemente) and that while some of these cities have lower non-White populations, Lake Forest’s Hispanic population suggests that White residents are disproportionately isolated.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-149
A potentially relevant contributing fa ctor to the County AI’s identifica tion of potential isolation of White residents in Lake Forest include land use and zoning laws (historic), which may have led to higher concentrations of White residents in areas throughout Lake Forest when compared to the region.

Source: Census Scope, Social Science Data Analysis Network * Not Hispanic or Latino
Diversity Index
Tracking the diversity of cities and counties through out California is crucial to understanding the shifting demographics of race and ethnicity in California and the United States. Esri’s Diversity Index captures the racial and ethnic diversity of a geographic area in a single number, from 0 to 100. Scores less than 40 represent lower diversity in the jurisdiction while sc ores of greater than 85 represent higher diversity.

Additionally, scores between 40-55 represent low divers ity, 55-70 represent moderate diversity, and 70-85 represent high diversity. As shown in Figure 4, thereThere generally appears to be higher diversity index scores throughout the City of Lake Forest (compared to its neighbors), with the highest diversity index scores (>85) located along El Toro Road. The lowest diversity index scores include census block groups that boarder the City of Irvine, which are not very populat ed and comprised mostly of nonresidential uses. The Citywide average diversity index score is 67.1, which is slightly higher than the County’s average diversity index score of 66.7. The City’s diversity index is illustrated in Figure 5. As shown in Figure 6, communities in Orange County with higher diversity index scores are somewhat more likely to be located in the more racially and ethnically diverse northern and central portion of the County than they are in the southern and coastal portion of the County.

Mapped Patterns of Integration and Segregation
FIGURE 4: DISSIMILARITY INDEX
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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-150
Patterns of integration and segregation are also consider ed for people with disabilities, familial status, and income groups. Relying primarily on data available from the US Census, it is possible to map and consider existing patterns which may indicate historical influences and future trends by census tract and census block groups.

As shown in Figure 7, persons with disabilities are present throughout the Lake Forest community, with higher concentrations in areas near transit and major activity centers, with a similar distribution to the adjacent cities of Mission Viejo and Laguna Hills . In Lake Forest, tT he highest concentration of persons with disabilities exists along both sides of El Toro Road, just east of I-5. This area is composed primarily of single-family detached homes and commercial development with a small population size. Persons with disabilities make up approximately 6.6% of the City’s population. The small population may be a contributing factor in the higher percentage of persons reporting disabilities. Housing that accommodates persons with disabilities is more likely to be located near transit and activity centers, as reflected Figure 7,. More geographically isolated areas or areas with steep topography, like the City’s northern neighborhoods are less suitable for persons with disabilities who may have impaired mobility and difficulty accessing goods and services. The County AI found that across Orange County, concentrations of persons with particular types of disabilities vary widely.

In Aliso Viejo, Irvine, Laguna Niguel, Rancho Santa Margarita, San Clemente, Santa Ana, Tustin, and Lake Forest, concentrations of persons with various types of disabilities are generally lower than they are countywide. As shown in Figure 8, communities with higher concentrations of persons with disabilities are somewhat more likely to be located in the more racially and ethnically diverse northern portion of the County than they are in the southern portion of the County. Persons with dis abilities account for 8.5% of the Countywide population, which is sli ghtly higher percentage than the City. Based on this analysis, the City finds that there are not significant patterns of segregation im pacting persons with dis abilities living in Lake Forest.

Lake Forest is also home to a number of female-headed households located throughout the community with limited discernible patterns of segregat ion, as illustrated on Figure 9. Two census tracts located within the Rancho de los Alisos Planned Community have the highest concentrations of female-headed households in the City, but the ratio is still low. There are no know n historic patterns of segr egation by familial status, including by household gender, which the City finds as contributing factors to continued segregation in Lake Fforest. Figure 9 indicates that female-headed households are located in a variety of census tracts with different incomes, access to opportunities, and resource levels. Female-headed households make up approximately 13.3% of households in the City of Lake Forest, as compared to 13.9% of the total households for the County. As shown in Figure 10, communities in Orange County with higher concentrations of female- headed households are somewhat more likely to be loca ted in the more racially and ethnically diverse northern portion of the County than they are in the southern portion of the County.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-151
The community’s older residents, persons 65 years of age or older, tend to be concentrated in a few census tracts in the City’s older neighborhoods, specifically along El Toro and Muirlands Boulevard, as shown in Figure 11. These areas generally correspond with the City’s older homes, which are some of the more affordable homes in the community and attractive to seni or residents. The City c ontinues to find that these options are an important part of the City’s housing stock and expects that senior residents will continue to choose to live in these areas as a result of the affo rdable home options available to them. The City’s newer neighborhoods tend to have lower concentrations of senior s; this is due in part to the product type offered (generally larger single-family detached homes) wh ich may not be the preferred housing type of older residents. In Lake Forest, persons 65 years or older comp rise of 13.1% of the City’s population. In comparison, persons 65 years or older comprise of 13.9% of Orange County’s population. As shown in Figure 12, communities in Orange County with higher concentrations of persons 65 years of age or older tend to be concentrated in coastal areas with higher median ho me prices, as well as the northeastern portion of the County. Central Orange County communities, such as Santa Ana and Tustin have relatively youthful populations, where there are lower median home prices, as well as a larger stock of single-family homes.

Patterns of segregated economic wealth, as indicated by median household income, are not present in Lake Forest, as illustrated on Figure 13. Low and high median household incomes are dispersed throughout the community, with lower and higher levels coexisting in no distinguishable pattern. The two block groups with lower median household incomes are found in two different parts of the City; one of the lower household median income block groups is located near the intersection of Muirlands Boulevard and El Toro Road, where there are several mobile home/manufactured home communi ties, and the other is located just south of the Civic Center, in a block group with a relatively low population. As shown in Figure 14, communities in Orange County with lower median incomes are somewhat more likely to be located in the more racially and ethnically diverse northern and central portion of the County than they are in the southern and coastal portion of the County. In the southern portion of the County, areas of lower median income are located along the I-5 freeway, where there is a greater concentration of multi-family and more affordable housing. In comparison, the median income in Lake Forest ($121,747) is higher than the Countywide average of $98,007.

Findings
The City has considered trends and patterns related to integration and segregation based on racial and ethnic factors, disability, female-headed households, seniors, and median household income. In all cases, there are no distinguishable patterns of segregation, and the community appears to be well-integrated. Moreover, when considering patterns of integration and segregation compared to its neighbors (including the cities of Irvine, Mission Viejo, Laguna Woods, Rancho Santa Margarita, Laguna Hills, and Aliso Viejo – all of which are shown on the above figures), Lake Forest’s patterns appear to be consistent with the region. As part of the City’s regular participation in the County AI, the City will continue to consider these patterns to determine any changes from current conditions.

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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-152
Racially or Ethnically Concentrated Areas of Poverty (R/ECAP) To assist communities in identifying racially/ethnically concentrated areas of poverty (R/ECAPs), HUD has developed a census tract-based definition of R/ECAPs. The definition involves a racial/ethnic concentration threshold and a poverty test. The racial/ethnic concent ration threshold is straightforward: R/ECAPs must have a non-white population of 50 percent or more. Regarding the poverty threshold, Wilson (1980) defines neighborhoods of extreme poverty as census tracts with 40 percent or more of individuals living at or below the poverty line. Because overall poverty levels are substantially lower in many parts of the country, HUD supplements this with an alternate criterion. Thus, a neighborhood can be a R/ECAPs if it has a poverty rate that exceeds 40% or is three or more times the aver age tract poverty rate for the metropolitan/micropolitan area, whichever threshold is lower.

The 2020 AI performed an analysis of R/ECAPs within Orange County. There are four R/ECAPs in Orange County, two of which are found in Santa Ana, two of which are found in Irvine. The two R/ECAPs found in Santa Ana are predominantly Hispanic and found clos e to the Santa Ana Freeway. The northernmost R/ECAP is located along North Spurgeon Street, while the more southern R/ECAP is found along South Standard Avenue. The R/ECAPs found in Irvine are adjac ent to each other and located on the campus of University of California, Irvine, ma king it likely that they qualify as R/ ECAPs due to the high proportions of students. These R/ECAPs have a much more diverse group of residents, with some White, Asian or Pacific Islander, Hispanic and Black residents. However, no R/ECAPs were identified in the City of Lake Forest.

Further analysis using the U.S. Department of Housing and Urban Developments RECAP GIS mapping tool confirms that all census tracts within Lake Forest have a RECAP value of 0, indicating that the census tracts within Lake Forest do not meet the defined parameters for a racially or ethnically concentrated area of poverty as defined by HUD.

Comparing Figure 5 to Figure 13, it appears that, generally, areas ranking in the high (70-85) and highest diversity index categories appear to have the lowest median household incomes in the City. Conversely, areas ranking in the low (40-55) and moderate (55-70) diversity index categories appear to have the highest median household incomes in the City. It appears that moderately segregated economic wealth exists within the City based on diversity, as one of the areas of the City with the lowest median household incomes (less than $30,000 annually) contains a white majority racial concentration while the other contains a Hispanic majority. Figure 15 provides an ethnicity analysis identifying the majority racial concentrations in the City. As shown, the majority of the City contains a white majority racial concentration, with a slim (<10%) to sizeable (10 – 50%) Hispanic majority racial concentration gene rally located along El Toro Road adjacent to I-5.

Overall, it appears that the City does not exhibit si gnificant patterns or trends of greater racial/ethnic concentrations correlating to increased poverty. Figure 16 provides an ethnicity analysis identifying racial concentrations in the County. Countywide, the northern portion of the County generally has areas with high diversity index scores and lower median incomes, wh ile the southern and coastal portions of the County of lower diversity index scores and higher median incomes.

As discussed in the Findings section, the Housing Plan includes programs to encourage increased diversity and housing opportunities in the City and to provide education related to fair housing rights.

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Map date: September 13, 2021.

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Figure 6: Diversity Index by Census Block Group - Countywide Legend
City of Lake Forest
County Boundary
Diversity Index (2018)
Higher Diversity
70-85
55-70
40-55
Lower Diversity
No Data
Data sources: AFFH Data and Mapping Resources, California Department of Housing and Community Development,
"RaceDemographics_BlockGrp_2018."
Map date: December 13, 2021.

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Sources: AFFH Data and Mapping Resources,
California Department of Housing and Community
Development, "DisabilityPopulation_Tract_2015_19."
Map date: September 13, 2021.

Figure 7: Proportion of Population with Disabilities by Census Tract City of Lake Forest
Incorporated Area
Unincorporated Area
Potential Housing Sites
Underutilized Residential Site
(Density <30 du/ac)
Underutilized Mixed-Use Site
(Density > 30 du/ac)
Underutilized Mixed-Use Site
(Density < 30 du/ac)
Percent of Population with a Disability
< 10%
10 - 20%
20 - 30%
30 - 40%
> 40%
LEGEND

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Figure 8: Proportion of Population with Disabilities by Census Tract - Countywide Legend
City of Lake Forest
County Boundary
Percent of Population with a Disability
< 10%
10 - 20%
20 - 30%
30 - 40%
> 40%
Data sources: AFFH Data and Mapping Resources, California Department of Housing and Community Development,
"DisabilityPopulation_Tract_2015_19."
Map date: December 13, 2021.

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Legend
City of Lake Forest
Incorporated
Unincorporated
Potential Housing Sites
Underutilized Residential Site
(Density <30 du/ac)
Underutilized Mixed-Use Site
(Density > 30 du/ac)
Underutilized Mixed-Use Site
(Density < 30 du/ac)
Percent of Children in
Female-Headed Household in
which No Spouse or Partner
Present is Present
< 20%
20 - 40%
40 - 60%
60 - 80%
> 80%
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Sources: AFFH Data and Mapping Resources, California
Department of Housing and Community Development,
"FamilyStatus_Tract_2015_19."
Map date: September 13, 2021.

Figure 9: Female-Headed Households by Proportion of Children Present by Census Tract

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Figure 10: Female-Headed Households by Proportion of Children Present - Countywide Legend
City of Lake Forest
County Boundary
Percent of Children in Female-Headed
Household in which No Spouse or Partner
Present is Present
< 20%
20 - 40%
40 - 60%
60 - 80%
> 80%
No Data
Data sources: AFFH Data and Mapping Resources, California Department of Housing and Community Development,
"FamilyStatus_Tract_2015_19."
Map date: December 13, 2021.

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Map date: September 13, 2021.

Figure 11: Proportion of Senior Residents by Census Tract

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Figure 12: Proportion of Senior Residents by Census Tract - Countywide Legend
City of Lake Forest
County Boundary
Percent of Population At or Over Age 65
< 10%
10 - 15%
15 - 20%
20 - 25%
25 - 30%
>30%
No Data
Data sources: U.S. Census Bureau's American
Community Survey (ACS) 2015-2019 5-year estimates,
Table(s) B01001.

Map date: December 7, 2021.

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City of Lake Forest
Incorporated Area
Unincorporated Area
Potential Housing Sites
Underutilized Residential Site
(Density <30 du/ac)
Underutilized Mixed-Use Site
(Density > 30 du/ac)
Underutilized Mixed-Use Site
(Density < 30 du/ac)
Median Income by Block Group
< $30,000
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$55,000 - $87,100*
$87,100 - $125,000
> $125,000
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Sources: AFFH Data and Mapping Resources, California
Department of Housing and Community Development,
"MedianIncome_BlockGrp_2015_19."
Map date: September 13, 2021.

Figure 13: Median Household Income by Block Group
* 87,100 is the HCD State Median Income

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Figure 14: Median Household Income by Block Group - Countywide Legend
City of Lake Forest
County Boundary
Median Income by Block Group
< $30,000
$30,000 - $55,000
$55,000 - $87,100*
$87,100 - $125,000
> $125,000
No Data
Data sources: AFFH Data and Mapping Resources, California Department of Housing and Community Development,
"MedianIncome_BlockGrp_2015_19."
Map date: December 13, 2021.

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City of Lake Forest
Incorporated Area
Unincorporated Area
Potential Housing Sites
Underutilized Residential Site
(Density <30 du/ac)
Underutilized Mixed-Use Site
(Density > 30 du/ac)
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Asian Majority by Dominance
Slim (gap < 10%)
Sizeable (gap 10 - 50%)
Predominant (gap > 50%)
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Dominance
Slim (gap < 10%)
Sizeable (gap 10 - 50%)
Predominant (gap > 50%)
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"PredominantPop_AsianMajority,"
"PredominantPop_HispanicMajority,"
"PredominantPop_WhiteMajority."
Map date: September 13, 2021.

Figure 15: Ethnicity Analysis - Racial Concentrations

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Figure 16: Ethnicity Analysis - Racial Concentrations - Countywide Legend
City of Lake Forest
County Boundary
African American Majority by Dominance
Slim (gap < 10%)
Sizeable (gap 10 - 50%)
Predominant (gap > 50%)
Asian Majority by Dominance
Slim (gap < 10%)
Sizeable (gap 10 - 50%)
Predominant (gap > 50%)
Hispanic Majority by Dominance
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Sizeable (gap 10 - 50%)
Predominant (gap > 50%)
White Majority by Dominance
Slim (gap < 10%)
Sizeable (gap 10 - 50%)
Predominant (gap > 50%)
Data sources: AFFH Data and Mapping Resources, California Department of Housing and Community Development,
"MedianIncome_BlockGrp_2015_19."
Map date: December 13, 2021.

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Racially/Concentrated Areas of Affluence
According to the Housing and Community Development AFFH Guidance Memo, “segregation is a continuum, with polarity between race, poverty, and affluence, which can be a direct product of the same policies and practices”. Therefore, both sides of the continuum must be examined. While HCD does not have a standard definition for RCAAs, looking at the percentage of the White population and median household income can provide a good indicator for areas of affluence.

In addition to RECAPs utilized by HUD, scholars at the University of Minnesota Humphrey School of Public Affairs created the Racially Concentrated Areas of Affl uence (RCAAs) metric to more fully tell the story of segregation in the United States10. RCAAs are defined as census tracts where 1) 80 percent or more of the population is white, and 2) the median household income is $125,000 or greater (slightly more than double the national the median household income in 2016). Table 69 looks at the median household incomes of white residents in Lake Forest as well as the County as a whole. While the majority of the City contains a white majority racial concentration, there are no census tracts with a median household income of $125,000 or more. As such, there are no RCAAs located in Lake Forest.

TABLE 69: REGIONAL OPPORTUNITY INDEX (ROI) DATA POINTS
Median Household
Income
Lake Forest Orange County
White households $105,661 $89,504
All households $104,449 $85,398
% of white population 71.8% 65.2%
Source: American Communities Survey 2014-2018
Disparities in Access to Opportunity
HUD developed the opportunity indicators to help in form communities about disparities in access to opportunity, the scores are based on nationally available data sources and assess resident’s access to key opportunity assets in the City. Table 70 provides the index scores (ranging from zero to 100) for the following opportunity indicator indices:
• Low Poverty Index: The low poverty index captur es poverty in a given neighborhood. The poverty rate is determined at the census tract level. The higher the score, the less exposure to poverty in a neighborhood.
• School Proficiency Index: The school proficienc y index uses school-level data on the performance of 4th grade students on state exams to describe which neighborhoods have high-performing elementary schools nearby and which are near lower performing elementary schools. The higher the score, the higher the school system quality is in a neighborhood. • Labor Market Engagement Index: The labor ma rket engagement index provides a summary description of the relative intensity of labor market engagement and human capital in a neighborhood.

This is based on the level of employment, labor force participation, and educational attainment in a census tract. The higher the score, the higher the labor force participation and human capital in a neighborhood.
• Transit Trips Index: This index is based on estimates of transit trips taken by a family that meets the following description: a three-person single-parent family with income at 50% of the median income for renters for the region (i.e. the Co re-Based Statistical Area (CBSA)). The higher the transit trips index, the more likely residents in that neighborhood utilize public transit.

10 Goetz, E. G., Damiano, A., & Williams, R. A. 2019. Racially Concentrated Areas of Affluence: A Preliminary Investigation. Cityscape: A Journal of Policy Development and Research, Volume 21(1) [pages 99–124]. Available at: https://www.huduser.gov/portal/periodicals/cityscpe/vol21num1/ch4.pdf Item: 11
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• Low Transportation Cost Index: This index is based on estimates of transportation costs for a family that meets the following description: a three-person single-parent family with income at 50% of the median income for renter s for the region/CBSA. The higher the index, the lower the cost of transportation in that neighborhood.
• Jobs Proximity Index: The jobs proximity index quantif ies the accessibility of a given residential neighborhood as a function of its distance to all job locations within a region/CBSA, with larger employment centers weighted more heavily. The higher the index value, the better the access to employment opportunities for residents in a neighborhood. • Environmental Health Index: The environmental health index summarizes potential exposure to harmful toxins at a neighborhood level. The higher the index value, the less exposure to toxins harmful to human health. Therefore, the higher the value, the better the environmental quality of a neighborhood, where a neighborhood is a census block group.

Opportunity indicators were obtained for Lake Forest from the HUD Affirmatively Furthering Fair Housing GIS tool. Table 70 identifies the opportunity indicators by race and ethnicity for the total population of Lake Forest.

TABLE 70: OPPORTUNITY INDICATORS BY RACE.ETHNICITY - LAKE FOREST Race/ Ethnicity
Low Poverty
Index
School
Proficiency
Index
Labor Market
Index
Transit Index
Low
Transportation
Cost Index
Jobs Proximity
Index
Environmental
Health Index
White 76.36 72.36 81.64 32.24 69.42 71.33 42.33
Black 73.27 69.65 81.67 32.34 70.96 72.67 42.25
Hispanic 67.04 66.07 76.36 31.35 73.18 70.57 39.94
Asian or
Pacific
Islander

73.63 72.58 82.39 32.16 69.56 73.34 42.56
Native
American

75.43 68.97 79.14 32.03 71.55 69.17 41.59
Total
Average

76.36 72.36 81.64 32.24 69.42 71.33 42.33

Source: HUD Affirmatively Furthering Fair Housing GIS Explorer, https://egis.hud.gov/affht/ As shown in Table 70, all residents of Lake Forest appear to have relatively high access to opportunity (values over 60), except for transit access and environmental health. Additionally, all residents appear to have fairly similar values. Specifically, all residents had values below 33 in the transit index, which could indicate residents, regardless of race/ethnicity, are not likely to take public transit. Additionally, all residents had values near 40 in the environmental health index, indicating that this area should receive special attention to ensure that the opportunity levels do not dip lower into the lowest quadrant (25 or lower). As such, access to opportunity does not appear to be significantly influenced by race or ethnicity.

The County AI found generally, access to opportunity is highest for non-Hispanic White and Asian/Pacific Islander residents in Orange County. By contrast, access to opportunity is generally lower for Black residents than for non-Hispanic White and Asian residents and access is lowest for Hispanic residents.

Regional Opportunity Index
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The UC Davis Center for Regional Change and Rabobank, N.A. partnered to develop the Regional Opportunity Index (ROI) intended to help understand social and eco nomic opportunity in California’s communities. The goal of the ROI is to help target resources and policies toward people and places with the greatest need to foster thriving communities. The ROI integrates a variety of data topics, including education, economic development, housing, mobility, health/environ ment, and civic life, and “maps” areas of potential investment by identifying specific areas of urgent need and opportunity. The ROI relies on many of the same data sources analyzed in the Housing Element, including the American Community Survey (ACS), the Longitudinal Employer-Household Dynamics (LEHD) Or igin-Destination Employment Statistics (LODES) data, the California Department of Education, the California Department of Public Health, among others (data points are from 2014).

There are two ROI “maps”; the “people” RO I illustrates the relative measure of the people’s assets in education, the economy, housing, mobility/transportation, health/environment, and civic life) while the “place” ROI illustrates the relative measure of a place’s assets in those same categories. The tool analyzes different specific indicators for each of the 6 data topics, as summarized in Table 71 below.

TABLE 71: REGIONAL OPPORTUNITY INDEX (ROI) DATA POINTS
People-Based Data Points Place-Based Data Points
Education • Elementary School
Truancy
• English Proficiency
• Math Proficiency
• College Educated Adults
• High School Discipline rate
• Teacher Experience
• UC/CSU Eligible
• High School Graduation Rate
Economic Development • Minimum Basic Income
• Employment Rate
• Bank Accessibility
• Job Quality
• Job Growth
• Job Availability
Housing • Housing Cost Burden
• Homeownership
• Housing Affordability
• Housing Adequacy
Mobility • Internet Access
• Commute Time
• Vehicle Availability
• N/A
Health/Environment • Years of Life Lost
• Births to Teens
• Infant Health
• Air Quality
• Health Care Availability
• Access to Supermarket
• Prenatal Care
Civic Life • English Speakers
• Voting Rates
• Neighborhood Stability
• US Citizenship

As shown in Figure 17 and Figure 19, Lake Forest has a range of opportunity levels throughout the community with slight differences between the relative measure of people-based assets versus placed-based assets, with people-based opportunities scoring slightly better than place-based opportunities. All census tracts are shown to have average (yellow) to high (green) levels of people-based opportunity, which indicates positive access to opportunities across the six data topics. However, in terms of place-based assets, there are two census tracts which indicates a lower level of opportunity (shown in red). The higher and lower levels of opportunity for these two census tracts, by indicator, are summarized in Table 72.

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TABLE 72: PLACE-BASED REGIONAL OPPORTUNITY INDEX (ROI) LOW OPPORTUNITY CENSUS TRACTS Census Tract (Place) Opportunity
Level
Average or Higher
Opportunities
Lower Opportunities
06059052423 Lowest
Opportunity
• Economy
• Education
• Health/Environment
• Civic Life
• Housing
06059052428 Lowest
Opportunity
• Education
• Civic Life
• Housing
• Health/Environment
• Economy
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For census tract 06059052423, which is south of SR-241 and along El Toro Road, there appears to be limited opportunities related to civic life, health/environment, and housing. Upon a deeper dive into the data, the most pressing health/environment issue is limited access to a supermarket, which can help inform the City’s land use planning decisions. In regards to civic life, the concerns relate to neighborhood stability. This census tract also has low levels of housing affordability. For census tract 06059052428, located along SR-241 and El Toro Road, there appears to be limited opportunities related to health/environment and the economy. The most pressing health/environment issue is limited access to a supermarket and health care. In regard to the economy, the concerns are bank accessibility and job availability. This census tract is predominately residential and surrounded by residential uses, which explains the indicators regarding access to goods and services.

In Orange County, areas with lower people-based and place-based opportunities are concentrated in the central and northern portion of the County, including the cities of Santa Ana and Garden Grove, as illustrated in Figure 18 and Figure 20. For the lowest people-based opportunity census tracts in the County, there appears to be limited opportunities related to housing. For the lowest place-based opportunity census tracts in the County, there are a variety of limited opportunities depending on the location related to civic life, health/environment, housing, economy, and education.

In order to better understand access to opportunities for protected classes (persons with disabilities, race, familial status), this section compares potential patterns of isolation and segregation presented in the prior section with the Regional Opportunity Index (people and place) discussed here.

As shown in Figure 7 and previous ly discussed, persons with disab ilities are located throughout the community. The census tracts with the most significant percentage of its population reporting a disability are located in an area of moderate to high levels of people-based opportunities and high levels of place-based opportunities. There does not seem to be a correlation between where persons with disabilities are located and lower levels of opportunity.

As shown in Figure 9 and previously discussed, female-headed households are prevalent throughout the community and generally represent 20% of households in all census tracts. The census tract with the highest number of female-headed households is located in an area where access to people-based opportunities is moderate and access to place-based opportunities is hi gh. Given that there is no discernable pattern of segregation associated with female-headed households, there does not seem to be a relationship between where female-headed households are more likely to be located and specific resource levels.

As shown in Figure 11 and previously discussed, there are no discernible patterns of isolation or segregation based on age. The census tracts with the highest leve ls of senior residents are located along the City’s southern boundary, which includes the oldest areas of the City. These census tracts are identified as having moderate to high people-based opportunity levels and the highest place-based opportunity levels. In general, the other census tracts showing higher-than-average levels of senior residents also have moderate or better people- and place-based opportunities.

Concentrations of the City’s Asian, Hispanic and nonwhite populations are shown in Figure 15. In addition to showing patterns of racial concentration, this Figure, like the others presented here, also identifies candidate housing sites in relation to patterns of racial concentration and illustrate that access to people- and place- based opportunities is most likely to be correlated with patterns of racial concentration versus the other classes discussed earlier in this section. The lowest levels of access to people-based opportunity are consistent with those census tracts with the highest concentration of Hispanic residents. However, while the vast majority of Lake Forest exhibits moderate or better levels of access to place-based opportunity, the two census tracts with lower-levels of opportunity (located in the City’s northern area) are predominantly White.

So, while this pattern warrants further study and coul d necessitate focused investment, the pattern is not consistent and areas with high concentrations of Hi spanic and nonwhite residents still have access to a variety of resources, consistent with the patterns seen citywide.

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Figure 17: People-Based Opportunities by Census Tract

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Regional Opportunity
Highest Opportunity
Lowest Opportunity
No Data
Sources: Sources: UC Davis Center for Regional Change/
Placeworks 2021 (Original data sourced from:
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Figure 19: Place-Based Opportunities by Census Tract

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Regional Opportunity
Highest Opportunity
Lowest Opportunity
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Sources: Sources: UC Davis Center for Regional Change/
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2021 TCAC/HCD Opportunity Area Map
Additionally, the Department of Housing and Community Development together with the California Tax Credit Allocation Committee established the California Fair Ho using Task Force to provide research, evidence- based policy recommendations, and other strategic re commendations to HCD and other related state agencies/departments to further the fair housing goal s (as defined by HCD). The Task force developed the 2021 TCAC/HCD Opportunity Area Maps to understand how public and private resources are spatially distributed. The Task force defines opportunities as pathways to better lives, including health, education, and employment. Overall, opportunity maps are intended to display which areas, according to research, offer low- income children and adults the best chance at economic advancement, high educational attainment, and good physical and mental health.

According to the Task Force’s methodology, the tool allocates the 20 percent of the tracts in each region with the highest relative index scores to the “Highest Resource” designation and the next 20 percent to the “High Resource” designation. Each region then ends up with 40 percent of its total tracts as “Highest” or “High” resource. These two categories are intended to help State decision-makers identify tracts within each region that the research suggests low-income families are most likely to thrive, and where they typically do not have the option to live—but might, if given the choice. The remaining tracts are then evenly divided into “Low Resources” and “Moderate Resource”. Table 70 identifies the resource levels by census tract and the corresponding scores for economic, education, and environmental indicator scores. As shown in Table 73 and Figure 21, approximately half of Lake Forest is classified as “High” or “Highest” resource, a quarter is classified as “Moderate” resource, and the remaining quarter (four census tracts) is classified as “ModerateLow” resource.

TABLE 73: LAKE FOREST OPPORTUNITY RESOURCE LEVELS BY CENSUS TRACTS Census Tract
(Place)
Resource Level Economic Score Education Score Environmental Score
052410* Low 18 36 1
052411 Low 12 34 9
032014 Low 9 34 14
052408* Low 68 53 1
052415 Moderate 68 53 58
052416 Moderate 56 49 51
032027* Moderate 36 42 65
052422* High 80 63 51
052425 High 51 59 70
052424 Moderate 35 59 59
032029 Moderate 49 44 65
052423 Moderate 55 54 61
032047* High 49 68 80
052426* High 67 87 21
052428* Highest 82 74 64
Source: 2021 TCAC/HCD Opportunity Map, https://belonging.berkeley.edu/2021-tcac-opportunity-map. * Census tracts labels followed by an asterisk (*) denote tracts that include area outside the Lake Forest city boundary.

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The four “low” resource level census tracts are all located adjacent to, or near the I-5 freeway. Table 74 shows a more detailed look of the four low resource census tracts TABLE 74: LOW RESOURCE CENSUS TRACT ANALYSIS
Census Tract (Place) Census Tract
052410
Census Tract
052411
Census Tract
032014
Census Tract
052408
Race/Ethnicity
White
Black
Asian
Hispanic

50%
2%
22%
22%

37%
2%
17%
39%

35%
2%
11%
46%

67%
0%
17%
14%
% of Population in Poverty 11.4% 14.9% 18.9% 1.8%
% of Population that is Disabled 8.3% 10.6% 15.7% 5.4%
% of Households in Renter-
Occupied Housing Units

32.9% 20.3% 31.6% 13.5%
Overcrowding 3.66% 9.53% 17.15% 2.11%
Overpayment
Renters
Owners

54.2%

42.7%

56.0%

31.4%

73.4%

18.0%

35.6%

11.6%
Source: California Department of Housing and Community Development, AFFH Data and Mapping Resources.

The County AI found that Countywide, there are disparities across racial/ethnic groups in access to educational opportunities as measured by the in dex. Across all tracts in Orange County, non-Hispanic White residents exhibit the highest exposure to educational opportunities (index score of 59) and non-Hispanic Asian residents second highest (index score of 53). Hispanic residents have the lowest access to these opportunities (31), with non-Hispanic Black residents in between (46). Countywide, there are disparities across racial/ethnic groups in access to environmental opportunities, measured as lower exposure to and effects from pollution. Jurisdictions with the highest environmental opportunity appear to have primarily large concentrations of non-Hispanic White and Asian/Pacific Islander residents. In Orange County there are significant disparities in access to economic opportunity, with Hispanic residents having the lowest access to economic opportunity of all racial and ethnic groups in Orange County. Economic Opportunity Index scores are generally lower in North Orange County than in South Orange County. Countywide TCAC/HCD Opportunity levels are shown in Figure 22.

THE COUNTY AI FOUND THAT LAKE FOREST, LIKE OTHER JURISDICTIONS IN THE COUNTY, HAVE RELATIVELY

LARGE DISPARITIES BY PROJECTED CLASS GROUPS AND HISPANIC RESIDENTS HAVE SIGNIFICANTLY LOWER ACCESS TO ECONOMIC OPPORTUNITY THAT OTHER RACIAL/ETHNIC GROUPS. TABLE 75 SHOWS THE OPPORTUNITY INDEX VALUES FOR THE CITY OF LAKE FOREST.

TABLE 75: CITYWIDE OPPORTUNITY INDEX VALUES
Population Economic
Score
Environmental
Score
Educational
Score
Low
Transportation
Cost Score
Transit
Score
Total Population
White, Non-Hispanic 52 55 61 32 3
Black, Non-Hispanic 49 55 61 34 3
Hispanic 40 44 53 36 3
Asian or Pacific Islander,
Non-Hispanic
52 54 60 32 3
Native American, Non-
Hispanic
46 54 59 34 3
Population below federal poverty line
White, Non-Hispanic 43 48 65 35 3
Black, Non-Hispanic 59 62 49 29 3
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Hispanic 24 18 43 33 3
Asian or Pacific Islander,
Non-Hispanic
35 37 52 39 4
Native American, Non-
Hispanic
6 10 40 50 3
Source: Orange County Analysis of Impediments to Fair Housing Choice, May 2020.

Findings
Overall, it appears that residents in Lake Forest have varying levels of access to opportunities, and access to opportunity is not correlated to the location of special groups, like female-headed households, seniors, or persons with disabilities. While there is some minor correlation between access to opportunities and racial/ethnic composition in the southern areas of the City near El Toro/I-5, there are other areas of the City with lower levels of access to opportunity where the residents are predominately white. Access to opportunity appears to be consistent and equitable across the communitytotal population, however inequities exist in populations below the federal poverty line, with Hispanic residents below the federal poverty line have less access to opportunities than other groups. Program 24, Neighborhood Improvement Task Force, has been added to address this Finding.

Discussion of Disproportionate Housing Needs
Across Orange County, many residents face high rates of housing problems, severe housing problems, and severe housing cost burden. The County AI found that 27.1% of households have a severe housing problem, which are lack of kitchen or plumbing, more than on e person per room, or cost burden greater than 50%.

Hispanic households are most likel y to have a severe housing problem (44.5% of households). In comparison, the County AI found that 19.9% of households in Lake Forest have a severe housing problem, with 42.4% of Hispanic households having a severe housing problem. Hispanic residents face severe housing problems at a higher than average in Lake Forest compared to the County. Overall, across the County, Black and Hispanic residents are more likely to face all of these housing problems, with varying rates across different jurisdictions. Housing problems occur more frequently in more populated areas of the County. The County AI found that while housing problems are generally evenly dispersed throughout the County, however, Lake Forest has higher percentages of households with housing problems in areas with higher numbers of Hispanic residents.

The analysis of disproportionate housing needs within Lake Forest evaluated existing housing need, needs of the future housing population, and units within the community at-risk of converting to market-rate (of which there are 8 11 units).

The four HUD-designated housing problems include when a 1) housing unit lacks complete kitchen facilities; 2) housing unit lacks complete plumbing facilities; 3) household is overcrowded; and 4) household is cost burdened. Households are considered to have a housing problem if they experience at least one of the above.

Table 76 summarizes the demographics of households with disproportionate housing needs in the City and region. As shown in Table 76, Lake Forest has a lower perc entage of residents experiencing housing problems compared to the region. For both the City and the region as a whole, non-White households are more likely to experience at least one of the housing problems than White households.

TABLE 76: DEMOGRAPHICS OF HOUSEHOLDS WITH DISPROPORTIONATE HOUSING NEEDS Housing Needs Lake Forest Los Angeles-Long Beach-Anaheim, CA Region
Households
experiencing any of 4
housing problems
# with
problems
#
households
% with
problems
# with
problems
# of
households
% with
problems
Race/Ethnicity
White 6,225 18,234 34.14% 710,485 1,741,265 40.80%
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Housing Needs Lake Forest Los Angeles-Long Beach-Anaheim, CA Region
Black 240 540 44.44% 186,785 332,330 56.20%
Hispanic 2,705 4,370 61.90% 924,105 1,458,220 63.37%
Asian or Pacific
Islander
1,305 3,865 33.76% 312,775 666,628 46.92%
Native American 15 19 78.95% 4,655 9,535 48.82%
Other 299 528 56.63% 44,255 90,895 48.69%
Total 10,780 27,555 39.12% 2,183,075 4,298,855 50.78%
Household Type and Size
Family households, <5
people
5,795 17,550 33.02% 1,029,920 2,301,365 44.75%
Family households, 5+
people
1,640 3,165 51.82% 434,995 628,630 69.20%
Non-family households 3,340 6,824 48.94% 718,155 1,368,880 52.46% Households
experiencing any of 4
severe housing
problems
# with
severe
problems
#
households
% with
severe
problems
# with
severe
problems
# of
households
% with
severe
problems
Race/Ethnicity
White 2,735 18,234 15.00% 387,770 1,741,265 22.27%
Black 140 540 25.93% 115,450 332,330 34.74%
Hispanic 1,855 4 370 42.45% 1,458,220 44.53%
Asian or Pacific
Islander
660 3,865 17.08% 189,350 666,628 28.40%
Native American 15 19 78.95% 2,645 9,535 27.74%
Other 174 528 32.95% 26,215 90,895 28.84%
Total 5,590 27,555 20.29% 1,370,770 4,298,855 31.89%
Source: HUD Affirmatively Furthering Fair Housing (AFFH) Database, 2020.

Future Growth Need
The City’s future growth need is based on the RHNA, which allocates production of 956 very-low and 543 low-income units to the City for the 2021-2029 pl anning period. Figure 2 shows that both existing and proposed affordable units are well dispersed thro ughout the community and do not present a geographic barrier to obtaining affordable housing. Appendix A of this Housing Element shows the City’s ability to meet its 2021-2029 RHNA need at all income levels. This demonstrates the City’s ability to accommodate the anticipated future affordable housing needs of the community.

Existing Need
As described earlier in this Background Report, the City has a history of working with affordable housing developers to help facilitate the development of housing for lower-income households. Lake Forest has 202 rent-restricted units, representing approximately 1% of the City’s housing stock. The City actively works with affordable housing developers to identify and evaluate potential sites and to expand opportunities for lower- income households throughout the City. Lake Forest continues to encourage development of 15% affordable housing in conjunction with development of market rate housing.

Cost Burden
A household is considered cost burdened if the household pays more than 30% of its total gross income for housing costs. For renters, housing co sts include rent paid by the tenant plus utilities. For home owners, housing costs include mortgage payment, taxes, insurance, and utilities. As discussed in the Background Report, as with most communities, the location of the home is one of the biggest factors with regard to price. shows the sites designated to meet the RHNA alloca tion in relation to percent of renter households overburdened by housing costs, by census tract. Some sites (located within the El Toro Road and Light Item: 11
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City of Lake Forest GENERAL PLAN │ Revised Adopted Housing Element Background Report │ Page BR-195
Industrial focus areas) are located in the census tr acts with the highest levels of renter households overburdened by housing costs and some sites (located within the El Toro Road and Lake Forest Drive focus areas) are located in the census tracts with the highest levels of homeowner households overburdened by housing costs. These patterns appear to be generally co nsistent with the prior analysis regarding median household incomes and access to opportunity as they relate to region al patterns, as illustrated in . shows the sites proposed to meet Lake Forest’s RHNA in relation to percent of homeowner households overburdened by housing costs, by census tract. The intent of introducing new residential development in these areas (at locations currently developed with commercial uses) is to add new housing to desirable areas and provide a range of housing choices at different prices to current and future residents. The sites designated to accommodate the City’s RHNA are not currently developed with residential uses and are not expected to displace current residents. A regional comparison is provided in .

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. As described in Table 20 in the Background Report, 2.1% of owner-occupied homes and 10.7% of renter-occupied homes are overcrowded, and a total of 4.8% of all households in Lake Forest are overcrowded. Figure 27 shows the concentration of overcrowded households in Lake Forest. One census tract, 032014 has 15.01-20% of households which are overcrowded.

As shown in Figure 33, the more racially/ethnically diverse northern Orange County has a significantly higher concentration of overcrowded households than the southern and coastal areas of the County.

Substandard Housing
Typically, housing over 30 years of age is more likely to have rehabilitation needs that may include plumbing, roof repairs, electrical repairs, foundation rehabilitation, or other significant improv ements. As discussed in Section 3 of the Background Report, the 2014-2018 ACS dat a indicates that 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 housing units were between 1970 and 1979. Die to the relatively young age of the City’s housing stock, the overall housing conditions are good. 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, 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%. The City has introduced Prog ram 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.

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.

Findings
“Disproportionate housing needs” generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area. Based on input from the community and the County AI, the Item: 11
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most disproportionate housing needs in Lake Forest includes rehabilitation of the existing housing stock and increased variety of housing types at affordable prices, including housing for lower income households and larger households. Additionally, as demonstrated in Table 74, Census Tract 032014 located in the southern portion of the City and adjacent to the I-5 Freeway has a comparatively high percentage of disproportionate housing needs, with 73.4% of renters overpaying and 17.15% of households which are overcrowded.

According the HCD’s AFFH Data Viewer, this Census Tract’s population is predominately Hispanic (46.4%), and has a slightly higher percentage of population with a disability (15.7%) compared to the City as a whole.

Program 24 of the Housing Plan, Neighborhood Improvem ent Task Force (NITF), targets this area of the City. Programs recommended by the NITF will be a key tool the City will use to address fair housing issues and affirmatively further fair housing.

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Displacement Risk
As previously discussed, there are 8 deed-restricted affordable units currently at-risk of converting to market-rate within the next 30 years. The vast majority of the City’s affordable housing stock was constructed in conjunction with the development of the City’s Opportunities Study areas, and these units have an expiration date well beyond the planning period. The City also has a number of units which are affordable to lower-income families but are not deed-restricted. As described earlier in this Background Report, the City plans to accommodate the vast majority of its 2021-2029 RHNA allocation on parcels designat ed for mixed-use development, with a focus on new development along the City’s major transportation corridors and near activity centers, which have good access to transportation facilities, amenities, and infrastructure. Moreover, given that the majority of new residential development will happen in areas envisioned to support mixed-use development, it is expected that residential uses will be developed alongside complementary commercial and civic uses, which will help facilitate bringing jobs and housing closer together. There are two underdeveloped residential sites identified as meeting a portion of the City’s moderate- and above-moderate income units; based on the net addition of units at these locations (which currently provide units affordable to moderate-income households), there is no a significant displacement risk associated with the City’s current affordable housing stock as a result of new development.

The Urban Displacement Project
11 identifies displacement risk throughout Orange County. The eastern, southern and coastal portions of the County are primarily exclusive or at risk of becoming exclusive. Approximately half of the census tracts in the City are considered “Stable/Advanced Exclusive,” a little less than half of the census tracts are considered “At Risk for Becoming Exclusive,” and one census tract is considered “Stable Moderate/Mixed Income.” Additionally, there are three census tracts in the City that according to the AFFH Data and Mapping Resources Map, are considered “Sensitive Communities” where residents may be particularly vulnerable to displacement in the event of increased redevelopment and shifts in housing costs, as illustrated in Figure 29. This includes census tracts 06059052411 and 06059032014 located adjacent to the I-5 freeway and census tract 06059052425, located in central Lake Forest between Lake Forest Drive and Trabuco Road. Census tract 06059032014 includes a large mobile home park that would be at risk for redevelopment. There are affordable housing opportunity sites located in all three census tracts, that would potentially displace existing residents due to redevelopment.

The City recognizes that even though it has identified sufficient land to accommodate its RHNA allocation at all income levels, there is still the potential for economic displacement because of new development and investment.

This “knock-on” effect can occur at any time, and it can be challenging for the City to predict market changes and development patterns which have the potential to impact rental rates and sales prices for housing available in the marketplace. To date, the City has no evidence that new development (affordable or market-rate) has resulted in economic displacement. However, the City recognizes that economic displacement might occur in the future and has developed Program 23 to study and address potential issues related to displacement.

The City has also considered the risk of displacement specifically for protected classes, including persons with disabilities, female-headed households, seniors, and nonwhite residents (as discussed previously throughout this Background Report). The highest levels of persons with disabilities, female-headed, and lower income households are not located in areas where residential development is planned, and the risk of displacement to these groups (like to the City’s lower-income residents) is low. However, some future housing sites are located in areas with high levels of senior residents, and these groups appear to be more vulnerable to potential future displacement. As discussed above, Program 23 has been included in the City’s Housing Plan to study and address issues related to future displacement, and the City remains committed to maintaining its existing affordable housing stock, which includes affordable units throughout the City, including in census tracts with high levels of senior residents.

To the extent that future development occurs in areas where there is existing housing, all housing must be replaced according to SB 330's replacement housing provisions (Government Code Section 66300). SB 330 also provides relocation payments to existing low-income tenants. The State has also adopted “just cause” eviction provisions and statewide rent control to protect tenants from displacement.

Findings

11 Urban Displacement Project, www.urbandisplacement.org/los-angeles/los-angeles-gentrifiction-and-displacement, December 2021.

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The City is committed to making diligent efforts to engage underrepresented and disadvantaged communities in studying displacement. Program 22 detail efforts the City will take to engage these communities during the planning period.

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MARGARITA

ALISO VIEJO
LAGUNA
WOODS

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IRVINE
Legend
City of Lake Forest
Incorporated Area
Unincorporated Area
Potential Housing Sites
Underutilized Residential Site
(Density <30 du/ac)
Underutilized Mixed-Use Site
(Density > 30 du/ac)
Underutilized Mixed-Use Site
(Density < 30 du/ac)
Opportunity Areas
Highest Resource
High Resource
Moderate Resource (Rapidly
Changing)
Moderate Resource
Low Resource
High Segregation and Poverty
Missing or Insufficient Data
Í
0 1½
Miles
Sources: AFFH Data and Mapping Resources, California
Department of Housing and Community Development,
"TCAC_OpportunityAreas_Tract_2021."
Map date: September 13, 2021.

Figure 21: TCAC/HCD Opportunity Area Map

REVISED FIGURE
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O R A N G E C O U N T Y

RI V E R S I D E C O U NT Y
S A N

B E R N A R DI N O

CO U NT Y

S A N D I E G O

CO U NT Y
P
A
C
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O
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Figure 22: TCAC/HCD Opportunity Area Map - Countywide
Legend
City of Lake Forest
County Boundary
Opportunity Areas
Highest Resource
High Resource
Moderate Resource (Rapidly Changing)
Moderate Resource
Low Resource
High Segregation and Poverty
Missing or Insufficient Data
Data sources: AFFH Data and Mapping Resources, California Department of Housing and Community Development,
"TCAC_OpportunityAreas_Tract_2021."
Map date: December 13, 2021.

Í
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Miles

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TUSTIN

MISSION VIEJO

LAKE FOREST

LAGUNA BEACH

RANCHO SANTA

MARGARITA

ALISO VIEJO
LAGUNA
WOODS

LAGUNA HILLS
IRVINE
Legend
City of Lake Forest
Incorporated Area
Unincorporated Area
Potential Housing Sites
Underutilized Residential Site
(Density <30 du/ac)
Underutilized Mixed-Use Site
(Density > 30 du/ac)
Underutilized Mixed-Use Site
(Density < 30 du/ac)
Percent of Renter Households
for whom Gross Rent (Contract
Rent Plus Tenant-Paid Utilities)
is 30% or More of Household
Income
< 20%
20 - 40%
40 - 60%
60 - 80%
> 80%Í
0 1½
Miles
Sources: AFFH Data and Mapping Resources, California
Department of Housing and Community Development,
"Overpayment_Tract_2015_19:" Map date: September 13, 2021.

Figure 23: Cost-Burdened Renter Households by Census Tract

REVISED FIGURE
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P
A
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Figure 24: Cost-Burdened Renter Households by Census Tract - Countywide Legend
City of Lake Forest
County Boundary
Percent of Renter Households for whom
Gross Rent (Contract Rent Plus Tenant-Paid
Utilities) is 30% or More of Household
Income
< 20%
20 - 40%
40 - 60%
60 - 80%
> 80%
No Data
Data sources: AFFH Data and Mapping Resources, California Department of Housing and Community Development,
"Overpayment_Tract_2015-19."
Map date: December 13, 2021.

Í
0 52½
Miles

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TUSTIN

MISSION VIEJO

LAKE FOREST

LAGUNA BEACH

RANCHO SANTA

MARGARITA

ALISO VIEJO
LAGUNA
WOODS

LAGUNA HILLS
IRVINE
Legend
City of Lake Forest
Incorporated Area
Unincorporated Area
Potential Housing Sites
Underutilized Residential Site
(Density <30 du/ac)
Underutilized Mixed-Use Site
(Density > 30 du/ac)
Underutilized Mixed-Use Site
(Density < 30 du/ac)
Percent of Owner Households
with Mortgages whose Monthly
Owner Costs are 30% or More
of Household Income
< 20%
20 - 40%
40 - 60%
60 - 80%
> 80%
No Value
Í
0 1½
Miles
Sources: AFFH Data and Mapping Resources, California
Department of Housing and Community Development,
"Overpayment_Tract_2015_19."
Map date: September 13, 2021.

Figure 25: Cost-Burdened Owner Households by Census Tract

REVISED FIGURE
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CO U NT Y
P
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Figure 26: Cost-Burdened Owner Households by Census Tract - Countywide Legend
City of Lake Forest
County Boundary
Percent of Owner Households with
Mortgages whose Monthly Owner Costs are
30% or More of Household Income
< 20%
20 - 40%
40 - 60%
60 - 80%
> 80%
No Data
Data sources: AFFH Data and Mapping Resources, California Department of Housing and Community Development,
"Overpayment_Tract_2015-19."
Map date: December 13, 2021.

Í
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Miles

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TUSTIN

MISSION VIEJO

LAKE FOREST

LAGUNA BEACH

RANCHO SANTA

MARGARITA

ALISO VIEJO
LAGUNA
WOODS

LAGUNA HILLS
IRVINE
Legend
City of Lake Forest
Incorporated
Unincorporated
Affordable Housing Sites
Underutilized Residential Site
(Density <30 du/ac)
Underutilized Mixed-Use Site
(Density > 30 du/ac)
Underutilized Mixed-Use Site
(Density < 30 du/ac)
Percentage of Households that
are Overcrowded
< 8.2% (Statewide Average)

8.2 - 12%
12 - 15%
15 - 20%
> 20%Í
0 1½
Miles
Sources: AFFH Data and Mapping Resources, California
Department of Housing and Community Development,
"OvercrowdedHouseholds_Tract." Map date: April 14, 2022.

Figure V-27: Overcrowded Households by Census Tract

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Figure 28: Overcrowded Households by Census Tract - Countywide Legend
City of Lake Forest
County Boundary
Percentage of Households Severely
Overcrowded (none within Orange County)
0>- 5%
5% - 20%
20% - 35%
35% - 65%
65% -100%
Percentage of Households that are
Overcrowded
< 8.2% (Statewide Average)

8.2 - 12%
12 - 15%
15 - 20%
> 20%
Data sources: AFFH Data and Mapping Resources, California Department of Housing and Community Development,
"OvercrowdedHouseholds_Tract" and
"OvercrowdedHouseholds_Severe_Tract."
Map date: April 15, 2022.

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TUSTIN

MISSION VIEJO

LAKE FOREST

LAGUNA BEACH

RANCHO SANTA

MARGARITA

ALISO VIEJO
LAGUNA
WOODS

LAGUNA HILLS
IRVINE
Legend
City of Lake Forest
Incorporated Area
Unincorporated Area
Affordable Housing Sites
Underutilized Residential Site
(Density <30 du/ac)
Underutilized Mixed-Use Site
(Density > 30 du/ac)
Underutilized Mixed-Use Site
(Density < 30 du/ac)
Sensitive Community
Vulnerable to Displacement
Í
0 1½
Miles
Sources: AFFH Data and Mapping Resources, California
Department of Housing and Community Development,
"SensitiveCommunities_UrbanDisplacementProject_Tract."
Map date: April 14, 2022.

Figure 29: Sensitive Communities

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6C. Sites Inventory
AB 686 requires that jurisdictions identify sites throughout the community in a manner that is consistent with its duty to affirmatively further fair housing. The site identification includes not only an analysis of site capacity to accommodate the RHNA (provided in this section), but also considers whet her the identified sites serve the purpose of replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity. This section analyzes the role of all sites, regardless of income le vel, in assisting to affirmatively further fair housing.

However, special attention is paid to those sites identified to accommodate a portion of the City’s lower- income RHNA to ensure that the City is thinking care fully about how the development of new affordable housing options can promote patterns of equality and inclusiveness.

SEGREGATION/INTEGRATION
As previously stated, the City find s that there are no known historic patterns of segregation by race and ethnicity, persons with disabilities, familial status, age or income. Nonetheless, as described throughout this Housing Element, the City is committed to supporting the development of housing to promote a balanced and integrated community. This is highlighted in Table 67 in the Housing Resources chapter, as the City has identified a surplus of sites and excess development capacity for housing for all income levels.

Figure 5 shows the sites identified to meet Lake Forest’s RHNA allocation in relation to racial/ethnic diversity.

As shown, proposed very-low and low-income RHNA sites underutilized mixed-use sites, including those very-low and low-income RHNA sites underutilized mixed-use allowing for densities of at least 30 du/ac), are located throughout the community and are not concentrated in areas of low diversity. The vast majority of sites are located in areas of moderate to high diversity, and some sites (located along Lake Forest Drive) are in areas of low diversity.

Figure 7 shows the sites designated to meet Lake Forest’s RHNA allocation in relation to the concentration of persons with disabilities. As shown, proposed sites, including those very-low and low-income sites (underutilized mixed-use sites allowing for densities of at least 30 du/ac) , are located throughout the community and are not concentrated in areas with high proportions of per sons with disab ilities. The vast majority of sites are located in census tracts with 10% or less of the population indicating a disability, including some sites in areas with 10%-20% of residents indicating a disability. Additionally, the City’s mixed-use areas are located near transit corridors and activity centers, which also benefits persons with disabilities. However, these sites are not concentrated in ar eas with already high levels of disability. The locations of sites designated to meet the City’s very-low and low-income RHNA allocation are not expected to contribute to patterns of isolation or segregation for persons with disabilities.

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Figure 9 shows the sites designated to meet Lake Fore st’s RHNA allocation in relation to female-headed households. As shown, proposed sites, including very-low and low-income sites (und erutilized mixed-use sites allowing for densities of at least 30 du/ac) , are located throughout the community and are not concentrated in areas with high levels of female-headed households. No sites are located in the census tract with the highest proportion of female-headed households . The locations of sites designated to meet the City’s very-low and low income RHNA allocation are not expected to co ntribute to patterns of isolation or segregation for female-headed households.

Figure 11 shows the sites designated to meet Lake Forest ’s RHNA allocation in relation to concentration of senior residents. As shown, proposed sites, including very-low and low-income sites (underutilized mixed- use sites allowing for densities of at least 30 du/ac) , are located throughout the community and are not concentrated in areas with high proportions of senior residents. The vast majority of sites are located in areas with low levels of senior residents (less than 20%) and some sites are located in areas where seniors make up 20-25% of the population. However, these areas (located generally along El Toro Road and Lake Forest Drive near I-5) are also good locations for seniors because they provide easy access to goods and services and are located near transportation facilities and activity centers. The locations of sites designated to meet the City’s very-low and low income RHNA allocation are not expected to contribute to patterns of isolation or segregation for senior households.

Figure 13 shows the sites designated to meet Lake Forest’s RHNA allocation in relation to median household income. As shown, proposed sites, including very-low and low-income RHNA sites (underutilized mixed-use sites allowing for densities of at least 30 du/ac) , are located throughout the community and are not concentrated in areas with low median household income. Some candidate sites are located in one of the City’s two lowest median household income census tracts, but as previously described, this census tract is home to many mobile/manufactured homes, which are not proposed for redevelopment. Development is expected to occur at other sites where nonresidential uses are currently (2021) located. The location of new development to meet the City’s very-low and low income RHNA are not expected to contribute to patterns of isolation or segregation for lower-income households.

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R/ECAPS
The City does not have any racially or ethnically concentrated areas of poverty and the identification of sites to accommodate the City’s RHNA is not expected to alter this finding. Additionally, while the majority of the City contains a white majority racial concentration, there are no census tracts with a median household income of $125,000 or more. As such, there are no RCAAs located in Lake Forest.

ACCESS TO OPPORTUNITY
Approximately 5% of the City’s underutilized mixed-use sites are located within census tract 06059052423, which is considered an area with low place-based opportunities. The concerns in this area include neighborhood stability, access to supermarkets, and housing affordability. The introduction of new mixed- use development in this area will help to create more housing affordable to households at lower-income levels, introduce new residents to an area which can contribute to higher neighborhood stability, and expand opportunities for people to live and work in the same area. Taken together, new mixed-use development in this area, which is focused on underutilized commercial sites, will help to diversify the land use pattern without displacing existing residents.

One of the high opportunity areas identified in the analysis is the Foothill Ranch Towne Center, which originally represented a concentration of commercial land uses on 216 acres of land within the Foothill Ranch Planned Community. In the 1980’s, 30 acres of land was developed as an Auto Center and medical office uses. Several rezonings have been approved by the City that allowed for 219 multi-family residential to be constructed on land that had formerly been used for auto dealerships. In addition, 3,710 single family and multi-family units are included within the Planned Community, which offer opportunities for the development of ADU’s and increasing housing choices in the area.

DISPLACEMENT RISK
shows the sites designated to meet the very-low and low-income RHNA allocation for Lake Forest sites (underutilized mixed-use si tes allowing for densities of at least 30 du/ac) in relation to percent of renter households overburdened by housing costs, by census tract. Some sites (located within the El Toro Road and Light Industrial focus areas) are located in the census tracts with the highest levels of renter households overburdened by housing costs and some sites (located within the El Toro Road and Lake Forest Drive focus areas) are located in the census tracts with the highest levels of homeowner households overburdened by housing costs. These patterns appear to be generally consistent with the prior analysis regarding median household incomes and access to opp ortunity as they relate to regional patterns, as illustrated in . shows the sites proposed to meet Lake Forest’s very-low and low-income RHNA allocation (underutilized mixed- use sites allowing for densities of at least 30 du/ac) in relation to percent of homeowner households overburdened by housing costs, by census tract. The intent of introducing new residential development in these areas (at locations currently developed with commercial uses) is to add new housing to desirable areas and provide a range of housing choices at different prices to current and future residents. The sites designated to accommodate the City’s lower-income RHNA are not currently developed with residential uses and are not expected to displace current residents. A regional comparison is provided in .

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SITE ANALYSIS FINDINGS
To accommodate the City’s RHNA allocation, five key focus areas of economic investment/opportunity have been identified consistent with the City’s comprehensive General Plan Update (adopted in 2020). These focus areas include: El Toro Road, Lake Forest Driv e, Light Industrial/Railroad, Civic Center, and Foothill Ranch Towne Center, all of which allow and incentiv ize mixed-use development at the densities needed to stimulate affordable housing development. These area s, located along transportation corridors and near activity centers, are designated for mixed-use development in the City’s General Plan. The City’s very-low and low RHNA needs are largelyThe sites identified to ac commodate the City’s RHNA at all income levels are largely accommodated in these locations . By locatingdesignating sites throughout the City, and at permitted densities which promote a variety of housing types to meet all income needs, the sites affirmatively further fair housing and provides for housing for all income types in moderate and high resource areas.

Specifically, housing sites designated Urban Industrial 25 are located in a high resource area and have the capacity for approximately 426 units at moderate and above moderate income levels., which do not represent extremely concentrated racial or ethnic populations, per sons with disabilities, female household, senior households, or low-income households.

As shown in Table 66, most of the site capacity for extremely low, very low, and moderate units isare located within sites designated as Mixed-Use 43 (approximately 69 percent of the total site inventory). Approximately 731 of those proposed units, including an anticipated 336 very low-income units are locateddesignated in the Foothill Ranch Towne Center, which is a high opportunity area. The Urban Industrial 43 land use designation is located in a Moderate Resource area and will acco mmodate approximately 339 extremely low, very low, and moderate units (sites 58-75).

Because sites are located throughout the City, some site s are located in areas of greater racial diversity and/or low-income household concentration, particularly in the southern portion of the City, in the areas around the I-5 Freeway (approximately 44 percent of t he total sites). These include sites 1-15, 34, 35, and 38-44, all of which are underutilized mixed-use sites that are permitted at densities that are suitable for all income levels. However, the City has included pr ograms in the Housing Plan to address neighborhood- specific issues in this areathese areas of the City, including Program 22: Affirmatively Furthering Fair Housing Program, Program 23: Economic Displacement Risk Analysis, and Program 24: Neighborhood Improvement Task Force, which will encourage lower-income sites to be located in areas with more resources and will help to revitalize areas in which lower-income sites are located.

THowever, the City has included a program to encourage additional development of lower-income units throughout the community through its accessory dwelling unit program (Program 8). For these reasons, the City finds that the sites proposed to accommodate its RHNA allocation do not unduly burden existing areas of concentrated racial or ethnic homogeneity, poverty, or other characteristics. Moreover, the sites affirmatively further fair housing by helping to stimulate investment in areas where additional people- and place-based opportunity is desired, and where new residential and/or mixed-use development can help to improve some of the opportunity level characteristics discussed earlier in this section.

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FIGURE 29: COST-BURDENED RENTER HOUSEHOLDS BY CENSUS TRACT,

CITY OF LAKE FOREST
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FIGURE 30: COST-BURDENED RENTER HOUSEHOLDS BY CENSUS TRACT,

COUNTYWIDE
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FIGURE 31: COST-BURDENED OWNER HOUSEHOLDS BY CENSUS

TRACT, CITY OF LAKE FOREST
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FIGURE 32: COST-BURDENED OWNER HOUSEHOLDS BY CENSUS

TRACT, COUNTYWIDE
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6D. Analysis of Contributing Factors a nd Fair Housing Priorities and Goals The December 2015 Affirmatively Furthering Fair Ho using Rule Guidebook identifies examples of contributing factors by each fair housing issue ar ea: outreach, fair housing enforcement and outreach capacity, segregation and integration, racially and ethni cally concentrated areas of poverty, disparities in access to opportunity, disparities in access to o pportunities for pers ons with disabilities, disproportionate housing needs, including displacem ent risks, and sites inventory. Based on the analysis included in this Background Report, the City has identified the following potential contributing factors to fair housing issues in Lake Forest and, as described later in this section, has developed a series of specific programs to address these contributing factors.

The following are contributing factors that have been identified based on the fair housing issues presented in the County AI and the analysis in this document that affect fair housing choice in Lake Forest, specifically.

Table 77 lists the fair housing issues and contributing factors that exist in the City of Lake Forest and outlines the meaningful actions to be taken. The meaningful actions listed in the table relate to the actions identified in the Housing Plan.

TABLE 77: FAIR HOUSING ISSUES AND CONTRIBUTING FACTORS
Fair Housing Issue Contributing Factors Priority Meaningful Action Disparities in Access
to Opportunity

(New Opportunities)
• Lack of opportunity due to high housing
costs
• Land use and zoning laws
• Lack of public investment in specific
neighborhoods, including services or
amenities
• Community opposition
• Lack of local or regional cooperation

High • Program 1
• Program 2
• Program 3
• Program 4
• Program 5
• Program 13
• Program 14
• Program 15
• Program 20
• Program 21
• Program 22
• Program 23
Outreach • Lack of resources for fair housing
agencies and organizations
Medium • Program 11
• Program 16
• Program 21
• Program 22
Fair Housing
Enforcement and
Outreach Capacity
• Lack of local private fair housing outreach
and enforcement
• Lack of resources for fair housing
agencies and organizations
High • Program 11
• Program 16
• Program 21
• Program 22
Segregation and
Integration
• 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 • Program 1
• Program 2
• Program 3
• Program 4
• Program 5
• Program 11
• Program 13
• Program 15
• Program 21
• Program 22
• Program 23
•
Lack of public • Access to transportation for persons with Medium • Program 1 Item: 11
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investment in
specific
neighborhoods,
including services
or
amenitiesDisparities
in Access to
Opportunity for
Persons with
Disabilities
disabilities
• Lack of affordable in-home or community-
based supportive services
• Program 2
• Program 3
• Program 4
• Program 5
• Program 10
• Program 11
• Program 12
Disproportionate
Housing Needs,
Including
Displacement Risks
• 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 • Program 1
• Program 2
• Program 3
• Program 4
• Program 5
• Program 13
• Program 14
• Program 15
• Program 20
• Program 21
• Program 22
• Program 23
The City has identified the following primary contributing factors and prioritized their importance:

1. Land use and zoning laws. The City of Lake Forest comprehensively updated its General Plan in 2020 to allow for new mixed-use development at densities not previously allowed in Lake Forest. Before this update, the City’s land use direction did not allow for development at densities sufficiently high to promote the development of affordable housing. In the past, the City has relied on Development Agreements to procure the development of affording units as part of new residential developers. However, the new General Plan identifies areas for mixed-use develo pment at densities of up to 32 du/ac or 43 du/ac, depending on the location. By allowing for resident ial development where residential development was not previously allowed, the City formalized a plan to accommodate new growth at key locations near a transportation corridor and activity centers where jobs and housing can be located close together. The City is currently updating its Zoning Code to incl ude new standards for the City’s mixed-use areas and to provide clear direction to the development community . As part of this effort, the City continues to encourage the provision of 15% affordable units in conjunction with new market rate housing. Programs 1, 2, and 7 have been included to address this contributing factor.

2. Lack of public investment in specific nei ghborhoods, including services or amenities . The Fair Housing Analysis included in this section illustrates the need for focused attention in the southwest Lake Forest neighborhood, which is one of the City’s lower-income neighborhoods, most racially segregated, with the most limited access to opportunity. The southwest Lake Forest neighborhood is one of the oldest residential communities not just in Lake Forest, but in south Orange County. The homes in this area are more likely to be in need of repair and language barriers may make it more challenging for the City to educate residents on housing programs and their right to fair and safe housing opportunities. To address this contributing factor, the City has created a Neighborhood Improvement Task Force ( Program 24), with the intent to identify concerns facing specific neighborhoods (beginning with southwest Lake Forest) and fund improvements to address concerns. The City has identified southwest Lake Forest as the first neighborhood to receive this special attention and has committed $70,500 in the 2021-2023 budget to implement the recommendations of the Neighborhood Improvement Study.

3. Community opposition. The County AI identified community opposition as a potential significant contributing factor to fair housing issues in Orange County and Lake Forest. In Lake Forest, and many Item: 11
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other communities, there is a lack of comm unity understanding around affordable housing and the important role it plays in helping meet the needs of a variety of community members, including young people, working professionals, seniors, persons with disabilities, single-parent households, low-income households, and other at-risk populations. Program 22, Affirmatively Furthering Fair Housing Outreach and Coordination Program, has been included in the City’s Housing Plan to address this contributing factor.

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Moving forward, the City remains committed to prov iding a diversity of housing options for all income levels, encouraging development throughout the comm unity to help overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. The vast majority of the City’s Housing Programs designed to address fair housing are required to be implemented on an ongoing basis, with annual progress reports and programs evaluations to ensure they are achieving the City’s objectives. The following list summarizes those programs identified in this Housing Element which affirmatively further fair housing and implement the County AI’s recommendations:
 Program 4, to replace affordable units
 Program 5, to facilitate affordable and special needs housing construction  Program 7, to accommodate specialized housing types and update the City's policies and procedures regarding mixed-use development, low barrier navigation centers, supportive housing, employee housing, and farmworker housing
 Program 8, to encourage the production of accessory dwelling units  Program 9, to allow for homeless shelters
 Program 10, to allow for transitional and supportive housing  Program 13, to ensure that the City’s density bonus ordinance continues to be in compliance with state law
 Program 22, to continue utilizing a fair housing servic e provider to assist with addressing fair housing issues in Lake Forest and to educate the commu nity, especially Lake Forest’s underserved and underrepresented residents, and affirmatively further fair housing  Program 23, to study and address economic displacement risks

3. To the extent that these programs represent ongoi ng work efforts, these programs are evaluated for effectiveness in Section 2 of this Background Report. The City has undertaken a series of proactive amendments to its Zoning Ordinance to address new requirements related to density bonus law and accessory dwelling units, and the City will continue to partner with local and regional stakeholders to affirmatively further fair housing.

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Appendix A: Site
Inventory
Adopted January 2, 2022
Minor Technical
Revisions June 2022
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Please Start Here, Instructions in Cell A2,
Table in A3:B15 Form Fields
Site Inventory Forms must be submitted to
HCD for a housing element or amendment
adopted on or after January 1, 2021. The
following form is to be used for satisfying
this requirement. To submit the form,
complete the Excel spreadsheet and submit
to HCD at [email protected].

Please send the Excel workbook, not a
scanned or PDF copy of the tables.

General Information
Jurisidiction Name LAKE FOREST
Housing Element Cycle 6th
Contact Information
First Name Gayle
Last Name Ackerman
Title of Community Deve
Email [email protected]
Phone (949) 461-3463
Mailing Address
Street Address
100 Civic Center
Drive
City Lake Forest
Zip Code 92630
City of Lake Forest 2021‐2029 Public Draft Housing Element Appendix A ‐ Site Inventory Item: 11
562

Table A: Housing Element Sites Inventory, Table Starts in Cell A2 Jurisdiction Name Site
Address/Intersection
5 Digit ZIP
Code
Assessor Parcel
Number
Consolidated
Sites
General Plan
Designation (Current)
Zoning
Designation
(Current)
Minimum Density
Allowed (units/acre)
Max Density
Allowed (units/acre) Parcel Size (Acres) Existing
Use/Vacancy Infrastructure Publicly-Owned Site Status Identified in Last/Last Two Planning Cycle(s) Lower Income Capacity
Moderate
Income Capacity
Above Moderate
Income Capacity Total Capacity Optional
Information1
Optional
Information2
Optional
Information3
LAKE FOREST 23572 PROTHERO 92630 617 ‐064‐18 LOW‐MEDIUM DENSITY RER2 ‐ Multifamily Dwelli 7 15 0.630937691 Vacant YES ‐ Current NO ‐ Privately‐Owned Available 8 8 36 Low Resource LAKE FOREST 23139 LOS ALISOS BLVD 92630 613‐351 ‐05 MEDIUM DENSITY RESIDENR2 ‐ Multifamily Dwelli 15 25 33.9193663 4 Residential, 304 YES ‐ Current NO ‐ Privately‐Owned Available 187 187 374 37 Moderate Resource City of Lake Forest 2021‐2029 Public Draft Housing Element Appendix A ‐ Site Inventory Item: 11
563

Table B: Candidate Sites Identified to be Rezoned to Accommodate Shortfall Housing Need, Table Starts in Cell A2 Jurisdiction
Name Site Address/Intersection 5 Digit ZIP Code Assessor Parcel Number
Very Low-
Income Low-Income Moderate-
Income
Above
Moderate-
Income
Type of Shortfall Parcel Size
(Acres)
Current General Plan
Designation Current Zoning
Proposed
General Plan
(GP)
Designation
Proposed
Zoning
Minimum
Density
Allowed
Maximum
Density Allowed Total Capacity Vacant/
Nonvacant
Description
of Existing
Uses
Optional
Information1
Optional
Information2
Optional
Information3
LAKE FOREST23861 EL TORO RD 92630 617-053-09 12 6 8 0 Shortfall of Sites 1.263383665 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 27 Non-Vacant Underutilized c 1 Low Resource El Toro LAKE FOREST23862 BRIDGER RD 92630 617-053-10 12 6 8 0 Shortfall of Sites 1.300886792 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 27 Non-Vacant Underutilized c 2 Low Resource El Toro LAKE FOREST23861 EL TORO RD 92630 617-053-02 8450 Shortfall of Sites 0.852017981 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 18 Non-Vacant Underutilized c 3 Low Resource El Toro LAKE FOREST23782 BRIDGER RD 92630 617-053-03 31 16 20 0 Shortfall of Sites 3.258929751 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 68 Non-Vacant Underutilized c 4 Low Resource El Toro LAKE FOREST23831 EL TORO RD 92630 617-053-11 81 42 53 0 Shortfall of Sites 8.389165381 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 176 Non-Vacant Underutilized c 5 Low Resource El Toro LAKE FORESTMERCURY RD & ROCKFIELD BLVD 92630 617-474-16 20 11 13 0 Shortfall of Sites 2.10018798 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 44 Non-Vacant Underutilized c 6 Low Resource Lake Forest Dr LAKE FOREST23764 MERCURY RD 92630 617-474-10 40 21 26 0 Shortfall of Sites 4.160877054 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 87 Non-Vacant Underutilized c 7 Low Resource Lake Forest Dr LAKE FOREST23591 ROCKFIELD BLVD 92630 617-431-06 8450 Shortfall of Sites 0.786263309 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 17 Non-Vacant Underutilized c 8 Low Resource Lake Forest Dr LAKE FOREST23581 ROCKFIELD BLVD 92630 617-431-07 9560 Shortfall of Sites 0.963305525 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 20 Non-Vacant Underutilized c 9 Low Resource Lake Forest Dr LAKE FOREST22821 ASPAN ST 92630 617-433-03 14 7 9 0 Shortfall of Sites 1.452132908 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 30 Non-Vacant Underutilized c 10 Low Resource Lake Forest Dr LAKE FOREST22762 ASPAN ST 92630 617-433-04 12 6 8 0 Shortfall of Sites 1.181806178 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 25 Non-Vacant Underutilized c 11 Low Resource Lake Forest Dr LAKE FOREST22771 CENTRE DR 92630 617-431-02 34 18 22 0 Shortfall of Sites 3.465348263 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 73 Non-Vacant Underutilized c 12 Low Resource Lake Forest Dr LAKE FORESTASPAN ST & CENTRE DR 92630 617-433-08 22 12 14 0 Shortfall of Sites 2.283045845 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 48 Non-Vacant Underutilized c 13 Low Resource Lake Forest Dr LAKE FOREST22681 LAKE FOREST DR 92630 617-493-01 77 40 50 0 Shortfall of Sites 7.995414481 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 168 Non-Vacant Underutilized c 14 Low Resource Lake Forest Dr LAKE FOREST22471 ASPAN ST 92630 617-491-04 13 7 8 0 Shortfall of Sites 1.319692179 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 28 Non-Vacant Underutilized c 15 Low Resource Lake Forest Dr LAKE FOREST20780 LAKE FOREST DR C 92630 613-621-16 6340 Shortfall of Sites 0.8517301 MIXED-USE 32 Community CommercMIXED-USE 32MU-32 0 32 14 Non-Vacant Underutilized c 16 Moderate ResouCivic Center LAKE FOREST20768 LAKE FOREST DR 92630 613-621-17 9560 Shortfall of Sites 1.275748018 MIXED-USE 32 Community CommercMIXED-USE 32MU-32 0 32 20 Non-Vacant Underutilized c 17 Moderate ResouCivic Center LAKE FOREST20761 LAKE FOREST DR 92630 613-622-09 12 6 8 0 Shortfall of Sites 1.603887531 MIXED-USE 32 Community CommercMIXED-USE 32MU-32 0 32 26 Non-Vacant Underutilized c 18 High Resource Civic Center LAKE FOREST20722 LAKE FOREST DR 92630 613-621-12 6340 Shortfall of Sites 0.742644428 MIXED-USE 32 Community CommercMIXED-USE 32MU-32 0 32 12 Non-Vacant Underutilized c 19 Moderate ResouCivic Center LAKE FOREST20702 LAKE FOREST DR 92630 613-621-10 16 8 10 0 Shortfall of Sites 2.153975934 MIXED-USE 32 Community CommercMIXED-USE 32MU-32 0 32 34 Non-Vacant Underutilized c 20 Moderate ResouCivic Center LAKE FOREST20652 LAKE FOREST DR 92630 613-621-11 8450 Shortfall of Sites 1.116763 MIXED-USE 32 Community CommercMIXED-USE 32MU-32 0 32 18 Non-Vacant Underutilized c 21 Moderate ResouCivic Center LAKE FOREST20651 LAKE FOREST DR 92630 613-623-02 5230 Shortfall of Sites 0.640688958 MIXED-USE 32 Community CommercMIXED-USE 32MU-32 0 32 10 Non-Vacant Underutilized c 22 High Resource Civic Center LAKE FOREST20671 LAKE FOREST DR 92630 613-623-01 12 6 8 0 Shortfall of Sites 1.656835568 MIXED-USE 32 Community CommercMIXED-USE 32MU-32 0 32 27 Non-Vacant Underutilized c 23 High Resource Civic Center LAKE FOREST26672 TOWNE CENTRE DR 92610 612-093-34 37 19 24 0 Shortfall of Sites 3.860087605 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 81 Non-Vacant Underutilized c 24 High Resource Foothill Ranch LAKE FOREST26642 TOWNE CENTRE DR 92610 612-093-33 36 19 24 0 Shortfall of Sites 3.77419289 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 79 Non-Vacant Underutilized c 25 High Resource Foothill Ranch LAKE FOREST26632 TOWNE CENTRE DR 92610 612-093-32 34 18 22 0 Shortfall of Sites 3.503322929 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 74 Non-Vacant Underutilized c 26 High Resource Foothill Ranch LAKE FOREST26622 TOWNE CENTRE DR 92610 612-093-26 11 6 7 0 Shortfall of Sites 1.135987335 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 24 Non-Vacant Underutilized c 27 High Resource Foothill Ranch LAKE FOREST26612 TOWNE CENTRE DR 92610 612-093-27 21 11 14 0 Shortfall of Sites 2.189852497 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 46 Non-Vacant Underutilized c 28 High Resource Foothill Ranch LAKE FOREST26592 TOWNE CENTRE DR 92610 612-093-25 12 6 8 0 Shortfall of Sites 1.254145848 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 26 Non-Vacant Underutilized c 29 High Resource Foothill Ranch LAKE FOREST26582 TOWNE CENTRE DR 92610 612-093-16 12 6 8 0 Shortfall of Sites 1.196160598 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 25 Non-Vacant Underutilized c 30 High Resource Foothill Ranch LAKE FOREST26572 TOWNE CENTRE DR 92610 612-093-30 6340 Shortfall of Sites 0.57254868 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 12 Non-Vacant Underutilized c 31 High Resource Foothill Ranch LAKE FOREST26602 TOWNE CENTRE DR 92610 612-093-13 157 82 103 0 Shortfall of Sites 16.26471722 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 342 Non-Vacant Underutilized c 32 High Resource Foothill Ranch LAKE FOREST26526 TOWNE CENTRE DR 92610 612-093-31 10 5 6 0 Shortfall of Sites 1.019581701 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 21 Non-Vacant Underutilized c 33 High Resource Foothill Ranch LAKE FOREST24288 SWARTZ DR 1 92630 617-501-01 59 31 39 0 Shortfall of Sites 6.153220763 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 129 Non-Vacant Underutilized c 34 Low Resource El Toro LAKE FOREST24392 ROCKFIELD BLVD 92630 617-501-04 88 46 58 0 Shortfall of Sites 9.161718949 MIXED-USE 43 Community CommercMIXED-USE 43MU-43 0 43 192 Non-Vacant Underutilized c 35 Low Resource El Toro LAKE FOREST22722 CENTRE DR 92630 617-432-03 13 7 8 0 Shortfall of Sites 1.326328663 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 28 Non-Vacant Underutilized c 38 Low Resource Lake Forest Dr LAKE FOREST22765 ASPAN ST 92630 617-432-18 7450 Shortfall of Sites 0.738090139 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 15 Non-Vacant Underutilized c 39 Low Resource Lake Forest Dr LAKE FOREST22741 ASPAN ST 92630 617-432-19 6340 Shortfall of Sites 0.589382745 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 12 Non-Vacant Underutilized c 40 Low Resource Lake Forest Dr LAKE FOREST22859 LAKE FOREST DR 92630 617-432-14 7450 Shortfall of Sites 0.742447552 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 16 Non-Vacant Underutilized c 41 Low Resource Lake Forest Dr LAKE FOREST22865 LAKE FOREST DR 92630 617-432-25 5330 Shortfall of Sites 0.510942448 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 11 Non-Vacant Underutilized c 42 Low Resource Lake Forest Dr LAKE FOREST22855 LAKE FOREST DR 92630 617-432-13 11 6 7 0 Shortfall of Sites 1.07768409 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 23 Non-Vacant Underutilized c 43 Low Resource Lake Forest Dr LAKE FOREST22831 LAKE FOREST DR 92630 617-432-09 12 6 8 0 Shortfall of Sites 1.304262211 MIXED-USE 43 Industrial Park MIXED-USE 4 3MU-43 0 43 27 Non-Vacant Underutilized c 44 Low Resource Lake Forest Dr LAKE FORESTORANGE AVE & WHISLER DR 92630 617-241-57 6340 Shortfall of Sites 0.591088064 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 12 Non-Vacant Underutilized c 45 Low Resource Industrial/Rail LAKE FOREST25142 FRONT ST 92630 613-374-08 19 10 12 0 Shortfall of Sites 1.960023625 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 41 Non-Vacant Underutilized c 46 Moderate ResouIndustrial/Rail LAKE FOREST23131 ORANGE AVE 92630 613-371-01 23 12 15 0 Shortfall of Sites 2.43740836 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 51 Non-Vacant Underutilized c 47 Moderate ResouIndustrial/Rail LAKE FOREST23081 ORANGE AVE A 92630 613-361-03 9560 Shortfall of Sites 0.917284252 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 19 Non-Vacant Underutilized c 48 Moderate ResouIndustrial/Rail LAKE FOREST25101 FRONT ST 92630 613-372-05 5330 Shortfall of Sites 0.506062432 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 11 Non-Vacant Underutilized c 49 Moderate ResouIndustrial/Rail LAKE FOREST23132 ORANGE AVE 92630 613-372-02 19 10 13 0 Shortfall of Sites 1.981549095 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 42 Non-Vacant Underutilized c 50 Moderate ResouIndustrial/Rail LAKE FOREST23132 ORANGE AVE 92630 613-372-01 8450 Shortfall of Sites 0.844433033 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 18 Non-Vacant Underutilized c 51 Moderate ResouIndustrial/Rail LAKE FOREST23222 OLIVE AVE 92630 613-373-06 11 6 7 0 Shortfall of Sites 1.166339659 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 24 Non-Vacant Underutilized c 52 Moderate ResouIndustrial/Rail LAKE FORESTCHERRY AVE & FRONT ST 92630 613-373-03 6340 Shortfall of Sites 0.651443735 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 14 Non-Vacant Underutilized c 53 Moderate ResouIndustrial/Rail LAKE FORESTOLIVE AVE & FRONT ST 92630 613-373-02 8450 Shortfall of Sites 0.82959032 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 17 Non-Vacant Underutilized c 54 Moderate ResouIndustrial/Rail LAKE FOREST23271 CHERRY AVE 92630 613-373-01 12 6 8 0 Shortfall of Sites 1.218513428 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 26 Non-Vacant Underutilized c 55 Moderate ResouIndustrial/Rail LAKE FOREST23211 CHERRY AVE 92630 613-362-04 16 8 10 0 Shortfall of Sites 1.641492507 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 34 Non-Vacant Underutilized c 56 Moderate ResouIndustrial/Rail LAKE FOREST25312 JERONIMO RD 92630 613-362-02 14 7 9 0 Shortfall of Sites 1.437847034 URBAN INDUSTRIAL 43 Industrial Park URBAN INDU SUI-43 0 43 30 Non-Vacant Underutilized c 57 Moderate ResouIndustrial/Rail LAKE FOREST20772 CIVIC CENTER DR 92630 104-132-78 0077 Shortfall of Sites 1.192169857 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 14 Non-Vacant Underutilized c 58 High Resource Civic Center LAKE FOREST20712 CIVIC CENTER DR 92630 610-332-07 0 0 21 21 Shortfall of Sites 3.464594704 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 42 Non-Vacant Underutilized c 59 High Resource Civic Center LAKE FORESTINDIAN OCEAN DR & COMMERCENTRE DR 92630 610-332-04 0 0 14 14 Shortfall of Sites 2.329840458 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 28 Non-Vacant Underutilized c 60 High Resource Civic Center LAKE FOREST20602 CIVIC CENTER DR 92630 610-332-09 0 0 30 30 Shortfall of Sites 4.964294627 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 60 Non-Vacant Underutilized c 61 High Resource Civic Center LAKE FOREST26000 COMMERCENTRE DR 92630 610-332-08 0 0 19 19 Shortfall of Sites 3.088663236 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 37 Non-Vacant Underutilized c 62 High Resource Civic Center LAKE FORESTINDIAN OCEAN DR & COMMERCENTRE DR 92630 104-132-79 0 0 15 15 Shortfall of Sites 2.383955339 URBAN INDUSTRIAL 25 Open Space URBAN INDU SUI-25 0 25 29 Non-Vacant Underutilized c 63 High Resource Civic Center LAKE FOREST20941 CANADA RD 92630 610-151-29 0 0 17 17 Shortfall of Sites 2.872984571 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 34 Non-Vacant Underutilized c 64 High Resource Civic Center LAKE FOREST20845 CANADA RD 92630 610-301-24 0066 Shortfall of Sites 0.900152383 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 11 Non-Vacant Underutilized c 65 High Resource Civic Center LAKE FOREST20762 LINEAR LN 92630 610-301-29 0088 Shortfall of Sites 1.218441897 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 15 Non-Vacant Underutilized c 66 High Resource Civic Center LAKE FOREST20792 CANADA RD 92630 610-301-31 0088 Shortfall of Sites 1.298525214 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 16 Non-Vacant Underutilized c 67 High Resource Civic Center LAKE FOREST20742 LINEAR LN 92630 610-301-13 0055 Shortfall of Sites 0.71561155 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 9 Non-Vacant Underutilized c 68 High Resource Civic Center LAKE FOREST20722 LINEAR LN 92630 610-301-22 0044 Shortfall of Sites 0.697844104 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 8 Non-Vacant Underutilized c 69 High Resource Civic Center LAKE FOREST20702 LINEAR LN 92630 610-301-23 0055 Shortfall of Sites 0.749709659 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 9 Non-Vacant Underutilized c 70 High Resource Civic Center LAKE FOREST26212 DIMENSION DR 92630 610-301-11 0088 Shortfall of Sites 1.259701242 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 15 Non-Vacant Underutilized c 71 High Resource Civic Center LAKE FOREST20781 CANADA RD 92630 610-301-16 0055 Shortfall of Sites 0.711370225 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 9 Non-Vacant Underutilized c 72 High Resource Civic Center LAKE FOREST20761 CANADA RD 92630 610-301-17 0 0 10 10 Shortfall of Sites 1.544583418 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 19 Non-Vacant Underutilized c 73 High Resource Civic Center LAKE FOREST26242 DIMENSION DR 92630 610-301-18 0099 Shortfall of Sites 1.400052107 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 17 Non-Vacant Underutilized c 74 High Resource Civic Center LAKE FOREST20700 CANADA RD 92630 613-821-04 0 0 27 27 Shortfall of Sites 4.493663549 URBAN INDUSTRIAL 25 Light Industrial URBAN INDU SUI-25 0 25 54 Non-Vacant Underutilized c 75 High Resource Civic Center City of Lake Forest 2021‐2029 Public Draft Housing Element Appendix A ‐ Site Inventory Item: 11
564

Table C: Land Use, Table Starts in A2
Zoning Designation
(From Table A, Column G) General Land Uses Allowed
R2 Multifamily
Multifamily dwellings; single‐family
dwellings; modiblehome developments;
residential condominiums; residential
planned (unit) developments.

City of Lake Forest 2021‐2029 Public Draft Housing Element Appendix A ‐ Site Inventory Item: 11
565

Suitability of Nonvacant Sites | City of Lake Forest 6th Cycle RHNA Oversupply
of Retail
Discontinuation
of Office (Work
from Home)
Vacancies/For
Rent/For Sale
Opportunity for
Infill (Keep Existing
Uses)
Expressed Property
Owner Interest
Site Characteristics
(Low Utilization/
Blighted)
23861 EL TORO RD 1 617‐ 053‐09
Commercial use, 7‐story multi‐tenant office building. Saddleback Executive Suites. Fo rmer Chase Bank on bottom floor (listed as "permanently closed" on Google) with suites above. Street access from El Toro Road and driveway to back entrance and large parking lot. Not currently listed for lease or sale on Loopnet. https://www.loopnet.com/Listing/23861‐El‐Toro‐Rd‐Lake‐Forest‐CA/11282809/. Large angled parking lot. Likely, but unconf irmed Moderate XXX X
23862 BRIDGER RD 2 617‐ 053‐10
Commercial use, 1 story restaurant/bar (occupied by The Pub) and parking lot. Connected to fast‐food (Arby's) with a drive‐thru. Small enclosed outside patio. Small/Medium parking lot as part of a larger parking lot (connects to 23861 El Toro Rd) Low
X X
23861 EL TO RO RD 3 617‐ 053‐02 Parking lot and drive‐thru ATM (Chase). Angled parking used for 23861 El Toro Rd Moderate XXX 23782 BRIDGER RD 4 617‐ 053‐03
Commercial/light industrial use, 1 story nursery (Green Thumb Nursery). Small building footprint, larger storage and dirt/gravel plant area with plants for sale, pallets/soil/groundcover and loading/unloading area. 2 in/out dr iveways along Bridger Rd and 1 loading/unloading driveway. No sidewalk along Bridger Rd (paved sidewalk north and south of site terminates Low
X X
23831 EL TORO RD 5 617‐ 053‐11
Multi‐tenant commercial use shopping mall and parking lot. Lake Forest Marketplace shopping center. Big box retailers (99 Cent Store, Guitar Center, Harbor Fr eight), Bank of America, smaller restaurants & retail (T‐ shirts Plus, Cigar Bar, etc.). Large parking lot with multiple access driveways, parking aisles, a Del Taco drive‐ thru. Three (3) units for lease (16,838 SF of retail at 23783‐23811 El Toro Rd) ‐ https://www.loopnet.com/Listing/23783‐23811‐El‐Toro‐Rd‐Lake‐Forest‐CA/18001783/ Three units for lease Low XX X
MERCURY RD & ROCKFIELD BLVD 6 617‐ 474‐16
Commercial use and medium/large parking lot. 1 story retail chains (Turner's Outdoorsman and Boot Barn).

Part of Rockfield Pla ce shopping mall (along with Map Reference 7). Borders I‐5 freeway on western side.

Medium/large 90‐degree parking lot looks underutilized Low XX X
23764 MERCURY RD 7 617‐ 474‐10
Commercial use and parking lot (Rockfield Showplace). 1 story retail (Salvation Army, restaurant, Leslie's Pool Supplies, massage, dentist) in a strip‐mall setting wi th medium/large 90‐degree parking lot, lot looks underutilized. Part of Rockfield Place shopping Mall (along with Map Reference 6). One (1) unit for lease (1,792 SF of retail at 23804) https://www.loopnet.com/Listing/23762‐23822‐Mercury‐Rd‐Lake‐Forest‐ CA/12314921/ One unit for lease (23804) Low
XX
23591 ROCKFIELD BLVD 8 617‐ 431‐06
1‐story commercial use in str ip ‐mall setting. Rockfield Center. Enterprise Rent‐A‐Car and 5 other small retail/restaurants with a small 90‐degree parking lot with one aisle, two driveways (Rockefeller Blvd and Centre Dr). Slightly unkempt. Low
X X
23581 ROCKFIELD BLVD 9 617‐ 431‐07
Commercial/light industrial use car wash (Checkered Flag). Lots of pavement (loading/driveway/parking), encl
osed automatic car wash and vacuums at parking stalls. Driveway shares entrance with Map Reference 8 (on Rockefeller Blvd) Low
X
22821 ASPAN ST 10 617‐ 433‐03
1‐story commercial with small office/retail uses (fitness studio, trophy engravers, physical therapy, salon).

Part of Aspan Plaza neighborhood shopping center, medium size parking lot with m ultiple aisles, 90‐degree parking. Driveway access from Aspan St. two (2) units for lease (5,000 sf of retail) https://www.loopnet.com/Listing/22821‐Lake‐Forest‐Dr‐Lake‐Forest‐CA/11747867/. Shares parking lot with Map Reference 11
Two units for lease (ste 109
and 206) Low
XX X
22762 ASPAN ST 11 617‐ 433‐04
1‐story commercial with small office/retail uses ( acupuncture, pawn shop). Part of Aspan Plaza neighborhood shopping center, medium size parking lot with multiple aisles, 90‐degree parking. Driveway access from Aspan St. Shares parking lot with Map Reference 10 See Map Reference 10 Low XX X
22771 CENTRE DR 12 617 ‐431‐02
1‐story commercial with one tenant, bowling alley (Forest Lanes) wi th large parking lot that appears to be severely underutilized Low XX
ASPAN ST & CENTRE DR 13 617 ‐433‐08
1‐story commercial with small office/retail uses (medical, real estate office, copy store, etc.). Part of Aspan Plaza neighborhood shopping center, medium size parking lot with multiple aisles, 90‐degree parking. one (1) uni t for lease (500 sf of office/retail). https://www.loopnet.com/Listing/22706‐22762‐Aspan‐St‐Lake‐ Forest‐CA/12854621/ One unit for lease (ste 703b) Low
XX X X
22681 LAKE FOREST DR 14 617 ‐493‐01
1‐story, multi‐tenant commercial use shopping mall and large parking lot. Lake Forest Town Center. Retail big box (99 cent store) and chains (Pepboys, Wingstop, Jack in th e Box with drive‐thru), with several smaller restaurant and retail uses. Six (6) units for lease (one large 6,225 sf that was former Mimi's Restaurant and five 1,000‐1,500 SF units) https://www.loopnet.com/Listing/22651‐22671‐Lake‐Forest‐Dr‐ Lake‐Forest‐CA/12017031/ 6 units for lease Low
XX X
22471 ASPAN ST 15 617‐ 491‐04 2 St ory office building and parking lot. Aspan Office Center. Built in 1980s. Low X X 20780 LAKE FOREST DR C 16 613 ‐621‐16
1 story office/restaurant (Starbucks drive‐thru, veterinary, bakery, salon) and parking lot. One (1) unit for lease (1800 SF) https://www.loopnet.com/Listing/20770‐20780‐Lake‐Forest‐Dr‐Lake‐Forest‐CA/12171787/ 1 unit for lease Moderate/Mixed XX X X 20768 LAK E FOREST DR 17 613 ‐621‐17 3 ‐story hotel use (Holiday Inn Express) and parking lot.

Low (Newer hotels
available) X
20761 LAKE FOREST DR 18 613 ‐622‐09 1 story retail/restaurant in strip‐mall setting Low X X 20722 LAKE FOREST DR 19 613 ‐621‐12 1 story self‐service car wash. 4 long loading driveways going into car wash bay. Pa rking and vacuums. Low X X 20702 LAKE FOREST DR 20 613 ‐621‐10 Multi ‐tenant 1 story restaurant/auto repair uses in horseshoe‐shaped, strip‐mall setting. Low X X 20652 LAKE FOREST DR 21 613 ‐621‐11 1 story restaurant (Wienerschnitzel) with drive‐thru and parking lot. Low X X 20651 LAKE FOREST DR 22 613 ‐623‐02
1 story multi‐tenant mini‐mall (Foothill Retail Ce nter). Liquor store, deli, salon, preschool and parking lot.

Main suite appears vacant (dark windows, no signage).

Possibly, at least one unit
appears vacant Low XX X
20671 LAKE FOREST DR 23 613 ‐623‐01 1 story corner restaurant/medical uses. In same parking lot as Map reference Number 22. Low XX X 26672 TOWNE CENTRE DR 24 612 ‐093‐34 3 story o ffice uses and parking lot Low X X 26642 TOWNE CENTRE DR 25 612 ‐093‐33 3 story office uses and parking lot Low X X 26632 TOWNE CENTRE DR 26 612 ‐093‐32 3 story office uses and parking lot. 3 office units for lease 3 units for lease Low XX X 26622 TOWNE CENTRE DR 27 612 ‐093‐26 1 story bank (Wells Fargo) (part of F oothill Ranch Towne Center, a large outdoor mall). Moderate XX 26612 TOWNE CENTRE DR 28 612 ‐093‐27 1 story multiple restaurants and large parking lot (part of Foothill Ranch Towne Center, a large outdoor Moderate X 26592 TOWNE CENTRE DR 29 612 ‐093‐25 1 story freestanding restaurant (Miguel's) (part of Foothill Ranch Towne Center, a large out door mall). Moderate X 26582 TOWNE CENTRE DR 30 612 ‐093‐16 1 story freestanding restaurant (Islands) (part of Foothill Ranch Towne Center, a large outdoor mall). Moderate X 26572 TOWNE CENTRE DR 31 612 ‐093‐30
1 story freestanding restaurant (vacant, used to be Souplantation). Part of Foothill Ranch Towne Center.

For lease, 7,500 SF. https://www.loopnet.com/Listing/26572‐Towne‐Centre‐Dr‐F oothill ‐Ranch‐ Yes, vacant Moderate XX 26602 TOWNE CENTRE DR 32 612 ‐093‐13 Large 1 story cinema (Regal Cinemas) and parking lot (part of Foothill Ranch Towne Center) Moderate X 26526 TOWNE CENTRE DR 33 612 ‐093‐31 Large 1 story restaurant/entertainment (Chuck E Cheese) and parking lot. Moderate X 24288 SWARTZ DR 1 34 617 ‐501‐01
Large 1‐story, multi‐building, multi‐t enant retail/restaurant (Big 5 Sports, Tommy's, etc.) shopping mall and large parking lot. Built approx. 1980. Two (2) large (~6,000 SF) retail units for lease. https://www.loopnet.com/Listing/24280‐24400‐Swartz‐Dr‐Lake‐Forest‐CA/19523509/ 2 units for lease Low XX X
24392 ROCKFIELD BLVD 35 617‐ 501‐04
Large 1‐story, multi‐unit shopping mall (Sprouts, CVS, Ross) with sm aller retail units (massage, clothing store, etc and parking lot. Low X X
23572 PROTHERO 36 617 ‐064‐18 Abandoned house with overgrown landscaping Low X Redevelopment Trends Present
Address Demand for
Current Use
Map
Reference APN Specific Description of Uses Known Vacancies/For Rent Item: 11
566

Oversupply
of Retail
Discontinuation
of Office (Work
from Home)
Vacancies/For
Rent/For Sale
Opportunity for
Infill (Keep Existing
Uses)
Expressed Property
Owner Interest
Site Characteristics
(Low Utilization/
Blighted)
Redevelopment Trends Present
Address Demand for
Current Use
Map
Reference APN Specific Description of Uses Known Vacancies/For Rent 23139 LOS ALISOS BLVD 37 613‐ 351‐05 Saddleback Ranch Apartments developed with 304 units Moderate XX 22722 CENTRE DR 38 617 ‐432‐03
1‐story commercial use in a strip mall setting. One larger banquet hall and 4 smaller retail/office (Avis Rent‐ A‐Car, a pub, massage) with a small, one‐aisle parking lot and two driveway entr ances on Centre Dr. Low X X 22765 ASPAN ST 39 617‐ 432‐18
Commercial/light industrial (America's Tire). Alleyway on Aspan St borders northern section of site and leads to other auto‐related uses (Map Reference Number 40), cars being repaired parked along alley. Low X X 22741 ASPAN ST 40 617‐ 432‐19
Light industrial uses (auto repair shops). Accessed by a lleyway on Aspan St. Cars being repaired parked along alley. Low X X
22859 LAKE FOREST DR 41 617 ‐432‐14 This property is a vacant Del Taco restaurant building. Vacant Very low XX X 22865 LAKE FOREST DR 42 617 ‐432‐25 This property is a vacant office building. Vacant Very low XX X 22855 LAKE FOREST DR 43 617 ‐432‐13
1 story retail/office/restaurant use (m edical, cleaners, dentist, Subway). Sadleback Court shopping mall.

Small/Medium parking lot with multiple parking aisles. One (1) space for lease (1,189 sf retail) https://www.loopnet.com/Listing/22855‐Lake‐Forest‐Dr‐Lake‐Forest‐CA/22572454/ 1 unit for lease Low XX X
22831 LAKE FOREST DR 44 617 ‐432‐09
1 story retail with small wrap‐around parking lot. US Bank wi th drive‐thru and retail/office (chiropractic, window treatment, employment agency). Low X X
ORANGE AVE & WHISLER DR 45 617 ‐241‐57 2 story Towing and self‐storage Low X X 25142 FRONT ST 46 613‐ 374‐08 2 story self‐storage Low X 23131 ORANGE AVE 47 613‐ 371‐01 1 story multi‐tenant auto repair/light industrial mini‐mall. One (1) unit for lease 1 uni t for lease Low XX 23081 ORANGE AVE A 48 613 ‐361‐03 1 story multi‐tenant auto repair/light industrial Low X 25101 FRONT ST 49 613‐ 372‐05 Tow yard/auto storage, fenced‐in Low X 23132 ORANGE AVE 50 613‐ 372‐02 Industrial (Ganahl Lumber) parking and operations. Moderate X 23132 ORANGE AVE 51 613‐ 372‐01 Industrial (Ganahl Lumber) parking and operations. Moderate X 23222 OLIVE AVE 52 613‐ 373‐0 6 Industrial/storage (closed to public, storage containers visible) Low X CHERRY AVE & FRONT ST 53 613‐ 373‐03 Industrial/storage Low X OLIVE AVE & FRONT ST 54 613‐ 373‐02 Industrial/storage (Resource Building Materials) Moderate X 23271 CHERRY AVE 55 613‐ 373‐01 Industrial/storage (Resource Building Materials) Moderate X 23211 CHERRY AVE 56 613‐ 362‐04 1 story multi‐tenant auto repair and two aisle parking lot Low X 25312 JERONIMO R D 57 613 ‐362‐02
1 story multi‐tenant commercial/light industrial (gym, wood and laminate showroom) with parking lot. One (1) unit for lease (3,400 sf @ 25302 Jeronimo Rd) https://www.loopnet.com/Listing/25302‐25332‐Jeronimo‐ Rd‐Lake‐Forest‐CA/24105076/ 1 unit for lease Low
XX X
20772 CIVIC CENTER DR 58 104‐132‐78
Large paved lot with vehicles and construction equipment, small office/vehicle storage, fenced‐in, occupied by Sunstate Equipment (Construction Equipment Rentals & Tools) Moderate X 20712 CIVIC CENTER DR 59 610‐332‐07 1 story freestanding industrial building and parking lot, landscaping nea r road. Secured parking lot. Vacant For lease Moderate X INDIAN OCEAN DR & COMMERCENTRE
DR 60 610 ‐332‐04
Paved, fenced‐in industrial storage with hangers and equipment staging/storage, appears to be connected to APN 610‐332‐09 and owned/operated by ARB Industrial (subsidiary of Primoris Services Corporation) Moderate X 20602 CIVIC CENTER DR 61 610 ‐332‐09
2 story i ndustrial/warehousing building, narrow and long with bay doors on southern building face, paved with vehicle and semi‐truck parking, storage units/shipping containers, possibly some sort of fill up (gas) station. Connected to APN 610‐332‐04, appears to be owned by ARB Industrial (subsidiary of Primoris Services Corporation) Moderate
X
26000 COMMERCENTRE DR 62 610 ‐332‐08
1 story commercial/light industrial building, occupied by ARB Industrial (subsidiary of Primoris Services Corporation). Wraparound parking lot and landscaping occupy much of the site. Surrounded by business park type uses. Moderate
X
INDIAN OCEAN DR & COMMERCENTRE
DR 63 104 ‐132‐79 (No street‐level view available). Undeveloped, easement with gravel access ro ad underneath utility lines. Moderate X 20941 CANADA RD 64 610 ‐151‐29
(No street‐level view available). Self‐storage building occupied by American Mini Storage. Adjacent to residential uses on southern and western border, easement and industrial/warehousing uses on the northern border, light industrial uses on eastern border. Moderate X
20845 CANADA RD 65 610 ‐301‐24
(No str eet ‐level view available). 1 or 2 story office building in manufacturing/business park, occupied by Camali Corp (engineering and IT company specializing in data centers) Moderate X 20762 LINEAR LN 66 610 ‐301‐29
1 or two story office/warehousing building with bay door, loading/unloading, storage and parking lot.

Occupied by All Seals (distributer of rubber pa rts) Moderate X 20792 CANADA RD 67 610 ‐301‐31
2 story office/warehousing building and parking lot, solar panel covered parking. Occupied by Schmaze Custom Coatings (paint/coating) Moderate X
20742 LINEAR LN 68 610 ‐301‐13 1 story office/manufacturing building and parking lot, occupied by AFAB Precision Machining Moderate X 20722 LINEAR LN 69 610 ‐301‐22 1 story office building and parking lot, p ossibly occupied by Wieser Educational Inc. Moderate X 20702 LINEAR LN 70 610 ‐301‐23
1 story office/manufacturing building and parking lot, occupied by Lyall Turbosonics, Inc. (product design and injection molder of thermoplastics) Moderate X
26212 DIMENSION DR 71 610 ‐301‐11
2 story multi‐tenant office/light industrial building with alleyway and bay doors behind it. Tenants include au
to repair shop, other light industrial uses, marketing, accounting firm, etc. Possibly one‐two vacancies (cannot confirm) Possibly but unconfirmed Moderate
X
20781 CANADA RD 72 610 ‐301‐16
1‐2 story light industrial building occupied by Carstar (auto body) and parking lot. Landscaping in between building and street. Moderate X
20761 CANADA RD 73 610 ‐301‐17
2‐3 stor y office/light manufacturing/warehousing building with paved shipping/receiving area and bay doors in back Moderate X
26242 DIMENSION DR 74 610 ‐301‐18
2 story multi‐tenant office/light industrial building with alleyway and bay doors behind it. Tenants include a gym, insurance agent, PT/sports rehab, kid's bounce house, etc. Possibly one‐two vacancies (cannot Possibly but unconf irmed Moderate X 20700 CANADA RD 75 613 ‐821‐04 1 ‐2 story self‐storage with gate and fencing, landscaping alongside road. Moderate X Item: 11
567

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Item: 11
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Item: 11
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/26 /2 /27 /4 /i255 /12 /19 /10 /4 /28 /8 /29 /i255 /30 /2 /20 /23 /31 /19 /10 /32 /23 /2 /33 /34 /i255/36/37/38 /39 /40 /38 /41 /i255 /38 /42 /i255 /43 /i255 /38 /44 /39 /45 /46 /47 /37 /48 /42 /i255 /49 /48 /50 /42 Map Reference: 000006

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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /4 /13 /i255 /14 /15 /14/16/17 /i255/14 /15/14 /16 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/4 /13 /i255 /14 /15 /14 /16 /26 /2 /27 /4 /i255 /12 /19 /10 /4 /28 /8 /29 /i255 /30/2 /20 /23 /31 /19 /10 /32 /23 /2 /i255 /18 /19 /19 /3 /20 /4
/14 /33 /34 /16 /35 /i255/36/4/10 /6 /9 /10 /37 /i255 /38 /39 /40 /41 /i255 /43 /44 /40 /45 /46 /i255/47/48/49 /50 /51 /49 /52 /i255 /49 /53 Map Reference: 000007

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /4 /13 /i255 /14 /15 /14/16/17 /i255/14 /15/14 /16 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/4 /13 /i255 /14 /15 /14 /16 /26 /2 /27 /4 /i255 /12 /19 /10 /4 /28 /8 /29 /i255 /30/2 /20 /23 /31 /19 /10 /32 /23 /2 /i255 /18 /19 /19 /3 /20 /4
/14 /14 /33 /33 /33 /i255 /30 /4 /32 /8 /10 /4 /i255 /34 /10 /35 /36 /i255 /38 /39 /40 /41 /42 /i255 /43 /44 /45 /46 /47 /48 /49 /50 /51 /i255 /52 /50 /53 /51 Map Reference: 000008

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /2 /13 /i255 /14 /15 /14/16/17 /i255/14 /15/14 /16 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/2 /13 /i255 /14 /15 /14 /16 /i255/18 /19 /19 /3 /20 /4
/26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /13 /23 /2 /33 /34 /i255 /36 /37 /38 /39 /40 /i255 /41 /42 /43 /44 /45 /46 /47 /48 /49 /i255 /50 /48 /51 /49 Map Reference: 000009

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /4 /13 /i255 /14 /15 /14/16/17 /i255/14 /15/14 /16 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/4 /13 /i255 /14 /15 /14 /16 /26 /2 /27 /4 /i255 /12 /19 /10 /4 /28 /8 /29 /i255 /30/2 /20 /23 /31 /19 /10 /32 /23 /2 /i255 /18 /19 /19 /3 /20 /4
/14 /14 /33 /34 /35 /i255 /36 /28 /7 /2 /32 /i255 /21 /8 /37 /38 /39 /i255 /41 /41 /42 /41 /37 /i255 /43 /44 /45 /43 /46 /i255 /44 /47 Map Reference: 000010

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /4 /13 /i255 /14 /15 /14/16/17 /i255/14 /15/14 /16 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/4 /13 /i255 /14 /15 /14 /16 /26 /2 /27 /4 /i255 /12 /19 /10 /4 /28 /8 /29 /i255 /30/2 /20 /23 /31 /19 /10 /32 /23 /2 /i255 /18 /19 /19 /3 /20 /4
/14 /14 /33 /34 /35 /i255 /36 /28 /7 /2 /32 /i255 /21 /8 /37 /37 /38 /i255 /40 /40 /41 /42 /40 /i255 /43 /44 /45 /43 /46 /i255 /44 /47 Map Reference: 000011

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Item: 11
578

/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /2 /13 /i255 /14 /15 /14/16/17 /i255/14 /15/14 /16 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/2 /13 /i255 /14 /15 /14 /16 /i255/18 /19 /19 /3 /20 /4
/26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /13 /23 /2 /33 /34 /35 /i255 /34 /34 /37 /37 /33 /i255 /38 /39 /40 /41 /42 /39 /i255 /43 /42 Map Reference: 000012

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /2 /13 /i255 /14 /15 /14/16/17 /i255/14 /15/14 /16 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/2 /13 /i255 /14 /15 /14 /16 /i255/18 /19 /19 /3 /20 /4
/26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /13 /23 /2 /33 /34 /35 /i255 /37 /38 /39 /37 /40 /i255 /38 /41 /i255 /42 /i255 /43 /44 /40 /41 /45 /44 /i255 /46 /45 Map Reference: 000013

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255/12/2/10 /i255 /13 /14 /13/14/15 /i255/13 /14/13 /16 /i255 /17 /18 /18 /3 /19 /4 /20 /8 /10 /4 /4 /8 /i255 /21 /22 /4/23/i255/24 /i255 /12/2 /10 /i255 /13 /14 /13 /14 /i255/17 /18 /18 /3 /19 /4
/25 /2 /26 /4 /i255 /27 /18 /10 /4 /28 /8 /29 /i255 /30 /2 /19 /22 /31 /18 /10 /32 /22 /2 /33 /34 /35 /i255 /37 /37 /38 /39 /33 /i255 /40 /41 /42 /43 /i255 /44 /45 /46 /43 /47 /48 /i255 /49 /46 Map Reference: 000014

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /4 /13 /i255 /14 /15 /14/16/17 /i255/14 /15/14 /16 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/4 /13 /i255 /14 /15 /14 /16 /26 /2 /27 /4 /i255 /12 /19 /10 /4 /28 /8 /29 /i255 /30/2 /20 /23 /31 /19 /10 /32 /23 /2 /i255 /18 /19 /19 /3 /20 /4
/14 /14 /33 /34 /16 /i255 /35 /28 /7 /2 /32 /i255 /21 /8 /36 /37 /38 /i255 /40 /40 /41 /42 /36 /i255 /43 /44 /45 /43 /46 /i255 /44 /47 Map Reference: 000015

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255/12/2/10 /i255 /13 /14 /13/14/15 /i255/13 /14/13 /16 /i255 /17 /18 /18 /3 /19 /4 /20 /8 /10 /4 /4 /8 /i255 /21 /22 /4/23/i255/24 /i255 /12/2 /10 /i255 /13 /14 /13 /14 /i255/17 /18 /18 /3 /19 /4
/25 /2 /26 /4 /i255 /27 /18 /10 /4 /28 /8 /29 /i255 /30 /2 /19 /22 /31 /18 /10 /32 /22 /2 /33 /34 /35 /i255 /37 /38 /39 /40 /38 /i255 /41 /42 /43 /44 /i255 /45 /46 /47 /44 /48 /49 /i255 /50 /47 Map Reference: 000016

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /4 /13 /i255 /14 /15 /14/16/17 /i255/14 /15/14 /16 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/4 /13 /i255 /14 /15 /14 /16 /26 /2 /27 /4 /i255 /12 /19 /10 /4 /28 /8 /29 /i255 /30/2 /20 /23 /31 /19 /10 /32 /23 /2 /i255 /18 /19 /19 /3 /20 /4
/14 /15 /33 /34 /35 /i255 /26 /2 /27 /4 /i255 /12 /19 /10 /4 /28 /8 /i255 /36 /10 /37 /38 /39 /i255 /41 /42 /38 /43 /44 /i255 /45 /46 /47 /48 /i255 /49 /50 /51 /48 /52 /53 /i255 /54 /51 Map Reference: 000017

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /7 /10 /i255 /13 /14 /15/16/17 /i255/13 /14/13 /15 /i255 /18 /19 /19 /3 /20 /4 /i255/18 /19 /19 /3 /20 /4
/21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12 /7 /10 /i255 /13 /14 /15 /16 /26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /33 /23 /2 /34 /35 /36 /i255 /38 /39 /40 /41 /34 /i255 /42 /43 /44 /45 /i255 /46 /47 /48 /45 /49 /50 /i255 /51 /48 Map Reference: 000018

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255/12/2/10 /i255 /13 /14 /13/14/15 /i255/13 /14/13 /16 /i255 /17 /18 /18 /3 /19 /4 /20 /8 /10 /4 /4 /8 /i255 /21 /22 /4/23/i255/24 /i255 /12/2 /10 /i255 /13 /14 /13 /14 /i255/17 /18 /18 /3 /19 /4
/25 /2 /26 /4 /i255 /27 /18 /10 /4 /28 /8 /29 /i255 /30 /2 /19 /22 /31 /18 /10 /32 /22 /2 /33 /34 /35 /i255 /37 /38 /39 /37 /37 /i255 /40 /41 /42 /43 /i255 /44 /45 /46 /43 /47 /48 /i255 /49 /46 Map Reference: 000019

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255/12/2/10 /i255 /13 /14 /13/14/15 /i255/13 /14/13 /16 /i255 /17 /18 /18 /3 /19 /4 /20 /8 /10 /4 /4 /8 /i255 /21 /22 /4/23/i255/24 /i255 /12/2 /10 /i255 /13 /14 /13 /14 /i255/17 /18 /18 /3 /19 /4
/25 /2 /26 /4 /i255 /27 /18 /10 /4 /28 /8 /29 /i255 /30 /2 /19 /22 /31 /18 /10 /32 /22 /2 /33 /34 /35 /i255 /33 /34 /37 /34 /33 /i255 /38 /39 /40 /41 /i255 /42 /43 /44 /41 /45 /46 /i255 /47 /44 Map Reference: 000020

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /4 /13 /i255 /14 /15 /14/16/17 /i255/14 /15/14 /16 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/4 /13 /i255 /14 /15 /14 /16 /26 /2 /27 /4 /i255 /12 /19 /10 /4 /28 /8 /29 /i255 /30/2 /20 /23 /31 /19 /10 /32 /23 /2 /i255 /18 /19 /19 /3 /20 /4
/14 /15 /33 /34 /14 /i255 /26 /2 /27 /4 /i255 /12 /19 /10 /4 /28 /8 /i255 /35 /10 /36 /37 /38 /i255 /36 /40 /41 /42 /36 /i255 /43 /44 /45 /46 /i255 /47 /48 /49 /46 /50 /51 /i255 /52 /49 Map Reference: 000021

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /7 /10 /i255 /13 /14 /15/16/17 /i255/13 /14/13 /15 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/7 /10 /i255 /13 /14 /15 /16 /i255/18 /19 /19 /3 /20 /4
/26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /33 /23 /2 /34 /34 /35 /i255 /34 /37 /38 /39 /40 /i255 /41 /42 /43 /44 /i255 /45 /46 /47 /44 /48 /49 /i255 /50 /47 Map Reference: 000022

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /4 /13 /i255 /14 /15 /14/16/17 /i255/14 /15/14 /16 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/4 /13 /i255 /14 /15 /14 /16 /26 /2 /27 /4 /i255 /12 /19 /10 /4 /28 /8 /29 /i255 /30/2 /20 /23 /31 /19 /10 /32 /23 /2 /i255 /18 /19 /19 /3 /20 /4
/14 /15 /33 /34 /16 /i255 /26 /2 /27 /4 /i255 /12 /19 /10 /4 /28 /8 /i255 /35 /10 /36 /37 /38 /i255 /36 /40 /41 /42 /43 /i255 /44 /45 /46 /47 /i255 /48 /49 /50 /47 /51 /52 /i255 /53 /50 Map Reference: 000023

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /7 /10 /i255 /13 /14 /15/16/17 /i255/13 /14/13 /15 /i255 /18 /19 /19 /3 /20 /4 /i255/18 /19 /19 /3 /20 /4
/21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/7 /10 /i255 /13 /14 /15 /16 /26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /33 /23 /2 /34 /35 /36 /i255 /34 /38 /38 /39 /34 /i255 /40 /41/42/43/44 /i255 /45 /44 /43 /40 /46 /44 /i255 /47 /46 Map Reference: 000024

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /7 /10 /i255 /13 /14 /15/16/17 /i255/13 /14/13 /15 /i255 /18 /19 /19 /3 /20 /4 /i255/18 /19 /19 /3 /20 /4
/21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/7 /10 /i255 /13 /14 /15 /16 /26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /33 /23 /2 /34 /35 /36 /i255 /34 /38 /38 /39 /34 /i255 /40 /41/42/43/44 /i255 /45 /44 /43 /40 /46 /44 /i255 /47 /46 Map Reference: 000025

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /7 /10 /i255 /13 /14 /15/16/17 /i255/13 /14/13 /15 /i255 /18 /19 /19 /3 /20 /4 /i255/18 /19 /19 /3 /20 /4
/21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/7 /10 /i255 /13 /14 /15 /16 /26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /33 /23 /2 /34 /35 /36 /i255 /34 /35 /35 /38 /34 /i255 /39 /40/41/42/43 /i255 /44 /43 /42 /39 /45 /43 /i255 /46 /45 Map Reference: 000026

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /7 /10 /i255 /13 /14 /15/16/17 /i255/13 /14/13 /15 /i255 /18 /19 /19 /3 /20 /4 /i255/18 /19 /19 /3 /20 /4
/21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/7 /10 /i255 /13 /14 /15 /16 /26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /33 /23 /2 /34 /35 /36 /i255 /34 /38 /38 /34 /34 /i255 /39 /40/41/42/43 /i255 /44 /43 /42 /39 /45 /43 /i255 /46 /45 Map Reference: 000027

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /7 /10 /i255 /13 /14 /15/16/17 /i255/13 /14/13 /15 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/7 /10 /i255 /13 /14 /15 /16 /i255/18 /19 /19 /3 /20 /4
/26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /33 /23 /2 /34 /35 /36 /i255 /34 /38 /38 /39 /34 /i255 /40 /41/42/43/44 /i255 /45 /44 /43 /40 /46 /44 /i255 /47 /46 Map Reference: 000028

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /7 /10 /i255 /13 /14 /15/16/17 /i255/13 /14/13 /15 /i255 /18 /19 /19 /3 /20 /4 /i255/18 /19 /19 /3 /20 /4
/21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/7 /10 /i255 /13 /14 /15 /16 /26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /33 /23 /2 /34 /35 /36 /i255 /34 /38 /39 /35 /34 /i255 /40 /41/42/43/44 /i255 /45 /44 /43 /40 /46 /44 /i255 /47 /46 Map Reference: 000029

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /7 /10 /i255 /13 /14 /15/16/17 /i255/13 /14/13 /15 /i255 /18 /19 /19 /3 /20 /4 /i255/18 /19 /19 /3 /20 /4
/21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/7 /10 /i255 /13 /14 /15 /16 /26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /33 /23 /2 /34 /35 /36 /i255 /38 /39 /40 /41 /38 /i255 /42 /43/44/45/46 /i255 /47 /46 /45 /42 /48 /46 /i255 /49 /48 Map Reference: 000030

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /7 /10 /i255 /13 /14 /15/16/17 /i255/13 /14/13 /15 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12 /7 /10 /i255 /13 /14 /15 /16 /i255/18 /19 /19 /3 /20 /4
/26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /33 /23 /2 /34 /35 /36 /i255 /38 /39 /40 /41 /38 /i255 /42 /43/44/45/46 /i255 /47 /46 /45 /42 /48 /46 /i255 /49 /48 Map Reference: 000031

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Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /7 /10 /i255 /13 /14 /15/16/17 /i255/13 /14/13 /15 /i255 /18 /19 /19 /3 /20 /4 /21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/7 /10 /i255 /13 /14 /15 /16 /i255/18 /19 /19 /3 /20 /4
/26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /33 /23 /2 /34 /35 /36 /i255 /35 /38 /38 /39 /35 /i255 /40 /41/42/43/44 /i255 /45 /44 /43 /40 /46 /44 /i255 /47 /46 Map Reference: 000032

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Item: 11
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/21 /8 /10 /4 /4 /8 /i255 /22 /23 /4/24/i255/25 /i255 /12/7 /10 /i255 /13 /14 /15 /16 /26 /2 /27 /4 /i255 /28 /19 /10 /4 /29 /8 /30 /i255 /31 /2 /20 /23 /32 /19 /10 /33 /23 /2 /34 /34 /35 /i255 /37 /38 /39 /37 /38 /i255 /40 /41/42/43/44 /i255 /45 /44 /43 /40 /46 /44 /i255 /47 /46 Map Reference: 000033

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Item: 11
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Item: 11
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Item: 11
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Item: 11
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Item: 11
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Item: 11
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Item: 11
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Item: 11
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Item: 11
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Item: 11
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Item: 11
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Item: 11
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Item: 11
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Map Reference000049

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Item: 11
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Map Reference000050

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Map Reference000051

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Item: 11
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Item: 11
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Map Reference000053

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Item: 11
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Map Reference000054

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Map Reference000055

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/13 /33 /34 /15 /13 /i255 /35 /4 /10 /18 /32 /22/1/18/i255 /36 /37 /38 /39 /40 /i255 /42 /38 /43 /44 /42 /i255 /45 /46 /47 /48 /49 /50/51/48/i255 /47 /52 Map Reference000057

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Item: 11
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/13 /14 /32 /33 /32 /i255 /29 /21 /34 /21 /6 /i255 /29 /4 /31 /8 /4 /10 /i255 /35 /10 /36 /37 /38 /i255 /40 /41 /42 /40 /43 /41 /i255 /44 /45 /46 /43 /41 /i255 /42 /47 /i255 /48 /i255 /45 /44/49/49/46/47 /45 /46 /41 /50 /47 /46 /i255 /42 /47 /i255 /51 /36 /52 /37 /53 /54 /54 /55 /53 /37 /56 /57 60 NEW CONTENT JUNE 2022
Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /6 /8 /i255 /13 /14 /13/14/15 /i255/13 /14 /13 /13/i255 /16 /17 /17 /3 /18 /4 /19 /20 /20 /21 /22 /23 /24 /24 /22 /25 /26 /27 /24/28/25/29 /25 /30 /31 /32 /33 /34 /35 /36 /35 /34 /37 /38 /39 /40 /39 /41 /37 /38 /42 /43 /44 /42 /45 /37 /46 /45 /13 /14 /47 /13 /48 /i255 /49 /50 /51 /50 /6 /i255 /49 /4 /52 /8 /4 /10 /i255 /53 /10 /54 /55 /56 /i255 /58 /59 /54 /59 /58 /i255 /60 /61 /62 /61 /60 /i255 /60 /63 /64 /65 /63 /66 /i255 /67 /66 /i255 /68 /54 /55 /59 /69 /70 /70 /58 /69 /59 /71 /72 61 NEW CONTENT JUNE 2022
Item: 11
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/0/1/2/3 /4 /i255 /6 /2 /7 /8 /9 /10 /4 /11 /i255 /12 /6 /8 /i255 /13 /14 /13/14/15 /i255/13 /14 /13 /13/i255 /16 /17 /17 /3 /18 /4 /19 /8 /10 /4 /4 /8 /i255 /20 /21 /4/22/i255/23 /i255 /12 /6 /8 /i255 /13 /14 /13 /14 /24 /2 /25 /4 /i255 /26 /17 /10 /4 /27 /8/28 /i255 /29 /2 /18 /21 /30 /17 /10 /31 /21 /2 /i255 /16 /17 /17 /3/18 /4
/13 /14 /32 /33 /34 /i255 /29 /21 /35 /21 /6 /i255 /29 /4 /31 /8 /4 /10 /i255 /36 /10 /37 /38 /39 /i255 /38 /37 /41 /41 /41 /i255 /42 /43/44/44/45/46 /42 /45 /47 /48 /46 /45 /i255 /49 /46 /i255 /50 /37 /51 /41 /52 /53 /53 /38 /52 /41 /54 /55 62 NEW CONTENT JUNE 2022
Item: 11
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Item: 11
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/11 /12 /13 /i255 /15 /16 /17 /18 /12 /i255 /19 /20 /21 /20 /22 /20 /i255 /23 /22 /i255 /24 /11 /25 /16 /26 /27 /16 /25 /26 /15 /18 /28 65 NEW CONTENT JUNE 2022
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/11 /11 /12 /i255 /14 /15 /16 /11 /14 /i255 /17 /18 /19 /20 /21 /22 /i255 /17 /19 /i255 /11 /23 /15 /24 /25 /15 /23 /24 /14 /26 66 NEW CONTENT JUNE 2022
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/7 /8 /9 /i255 /11 /12 /8 /13 /11 /i255 /14 /15 /16 /15 /17 /15 /i255 /18 /17 /i255 /19 /7 /20 /12 /21 /22 /12 /20 /21 /22 /20 /23 67 NEW CONTENT JUNE 2022
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/11 /12 /13 /i255 /15 /16 /17 /18 /15 /i255 /19 /20 /21 /22 /23 /24 /i255 /19 /21 /i255 /25 /11 /26 /16 /27 /28 /16 /26 /27 /26 /28 /29 68 NEW CONTENT JUNE 2022
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/10 /11 /12 /i255 /14 /15 /16 /14 /14 /i255 /17 /18 /19 /20 /21 /22 /i255 /17 /19 /i255 /23 /10 /24 /15 /25 /26 /15 /24 /25 /14 /14 /27 69 NEW CONTENT JUNE 2022
Item: 11
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/10 /11 /12 /i255 /14 /11 /10 /11 /14 /i255 /15 /16 /17 /18 /19 /20 /i255 /15 /17 /i255 /21 /22 /23 /11 /24 /25 /11 /23 /24 /14 /25 /26 70 NEW CONTENT JUNE 2022
Item: 11
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Appendix B: Public
Engagement
Summary
Adopted January 2, 2022
Minor Technical
Revisions June 2022
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1 City of Lake Forest Housing
Element Update
September December 2021

In partnership with De Novo Planning Group

Public
Engagement
Summary
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2 Table of Contents
Introduction ...................................................................................................................................................................... 33 General Education and Advertisements .......................................................................................................................... 44 Project Website ................................................................................................................................................................ 55 Virtual Community Workshop ......................................................................................................................................... 66 Stakeholder Meetings/Consultation ........................................................................................................................... 2019 Public Review of Draft Housing Element ..................................................................................................................... 2120 Feedback Influence ....................................................................................................................................................... 2120 Public Comment: Tapestry ........................................................................................................................................... 2322

Figures
Figure 1: How long have you lived in the City? ................................................................................................... 109 Figure 2: What made you decide to live here? ................................................................................................. 1110 Figure 3: If you wish to own a home in Lake Forest but do not currently own one, what issues are preventing you from owning a home at this time? ............................................................................................................. 1211 Figure 4: How would you rate the physical condition of the residence you live in? ........................................ 1312 Figure 5: Which of the following housing upgrades or expansions have you considered making on your home? ........................................................................................................................................................................... 1413 Figure 6: What types of housing are most needed in the City of Lake Forest? (Residents) ............................. 1615 Figure 7: What types of housing are most needed in the City of Lake Forest? (Non-Residents) ..................... 1716 Figure 8: If you are currently employed, approximately how long is your one-way commute to work? ........ 1817 Figure 9: How important are the following housing priorities to you and your family? .................................. 2019

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3 Introduction
The City of Lake Forest is updating its Housing Element as part of the 2021-2029 Housing Element Cycle (Cycle 6). Lake Forest is dedicated to meeting the future housing needs of its residents. The Housing Element Update process is a unique opportunity to connect with residents of Lake Forest and learn more about residents’ values, priorities, concerns, and ideas.

While the City’s public engagement program connected directly to the Housing Element Update began in late 2020, the City conducted a robust outreach program as part of its comprehensive General Plan Update (which was adopted in mid-2020). As part of that work effort, which included dozens of community meetings, study sessions, and public hearings, the community had the opportunity to weigh-in on key areas for focused future residential and nonresidential growth.

Through this effort, the City identified five focus areas where new mixed-use development is desirable. These areas are designated as “Mixed-Use” in the General Plan and the City is currently preparing a focused update to its Zoning Ordinance to adopt new zoning standards for these mixed- use areas. A majority of the sites included in the City’s Housing Element Site Inventory (Appendix A) are located within these mixed-use areas. The Housing Element is a continuation of the City’s comprehensive General Plan Update and builds upon the legacy of public involvement included in that work, which included focused outreach to the City’s lower-income residents through participation of Council-appointed representatives to the General Plan Advisory Committee and pop- up community workshops and events in lower-income neighborhoods of the community. For more information related to the General Plan public engagement program, please see the City’s website at https://www.lakeforestca.gov/292/Planning-Documents.

Throughout the process, the City supported meaningful public engagement by sending direct advertisements, posting to social media, hosting surveys, facilitating workshops, and sharing summaries of feedback to validate what we heard. Looking forward to the public review period of the Draft Housing Element, the City will continue to engage the community to seek feedback on the goals, policies, and programs included in the Housing Plan as well as input regarding key issues and challenges identified in the Background Report, including the City’s plan to accommodate its fair share of future regional housing growth.

The following activities have been conducted in support of the Housing Element Update and are summarized in this document; copies of key advertisements and presentations are included at the end of this document and are also available on the project website at https://lakeforest.generalplan.org/. • General Education and Advertisements
• Project Website
• Virtual Workshop
• Stakeholder Meetings/Consultation
• Public Review of Draft 2021-2029 Housing Element
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4 General Education and Advertisements
The City engaged in a multifaceted campaign to advertise the focused update to the City’s Housing Element to all members of the community, including lower-income households. Using the City’s social media accounts, email listserv generated through the General Plan Update, the City’s dedicated General Plan Update website and the City’s own website, and direct mailers to interested stakeholders, project announcements as part of the City’s community services material (delivered to every resident in the City), the City worked hard to educate the community on this project and solicit meaningful feedback from all stakeholders.

Social Media
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 advertise the
Housing Element Community Meeting, the Online
Workshop, and the Public Review Draft 2021-2029
Housing Element.

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5 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 project website is a continuation of the General Plan Update website (launched in 2018) and is regularly updated to reflect ongoing community input opportunities, advertise draft work products, and answer commonly asked questions. The project website includes the following pages:
• Home Page: Introduction about the project
• FAQ: A presentation of common questions and answers including an overview of why public feedback is important and how it will be used to shape the work products • Survey: Dedicated page to host open surveys
• Get Involved: Information regarding upcoming and past meetings and events, including public workshops, open houses, and hearings
• Documents & Maps: Library of relevant documents and maps prepared for the project as well as links to the City’s Planning Division webpage which hosts additional City documents • Contact Us: Project team contact information and a fillable form to submit comments on an ongoing basis and register to receive future project updates Since September 2020, the project website received over 1,200 views from 959 unique visitors resulting in a total of 2,800 pageviews. The peak of activity happened around the housing survey, facilitated throughout the month of December 2021.

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6 Virtual Community Workshop
As part of the community outreach, a virtual community workshop was conducted to educate the community about housing issues and opportunities facing Lake Forest and gather input on housing- related topics. The virtual workshop was hosted on the project website from November 23, 2020 through December 22, 2020. The extended timeframe was intended to allow community members and stakeholders to participate at their leisure and in accordance with their schedule and availability.

The Virtual Community Workshop consistent of three parts:

Part A: Overview video (narrated in English and subtitled in Spanish) 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 (https://youtu.be/c-LAnI2MGWc)
Part C: Two surveys to gather information on housing-related issues. Survey #1 focused on issues of home maintenance, affordability, home types, and living conditions in Lake Forest as well as demographic questions. Survey #2 focused on community priorities related to housing. This section includes a summary of the responses received and the general themes that emerged. • Survey #1 was 14 questions long. It had a 94% completion rate and 124 total responses. • Survey #2 was 2 questions long. It had an 87% completion rate and 69 total responses.

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7 Community Survey
The City of Lake Forest is updating its Housing Element as part of the 2021-2029 Housing Element Cycle (Cycle 6). The City recently updated its General Plan (2020); updating the Housing Element builds upon that foundation of analysis and community engagement to address the future housing needs of its residents. The Housing Element Update process is a unique opportunity to connect with residents of Lake Forest and learn more about residents’ values, priorities, concerns, and ideas.

As part of the community outreach, a virtual community workshop was conducted and two surveys were presented. The two surveys work together to gather information on housing-related issues.

Survey #1 focused on issues of home maintenance, affordability, home types, and living conditions in Lake Forest as well as demographic questions. Survey #2 focused on community priorities related to housing. This report is a summary of the responses received and the general themes that emerged.

Both surveys were posted to the website on November 23, 2020 and were open for a month. The surveys were closed on December 22, 2020.

Survey #1 was 14 questions long. It had a 94% completion rate and 62 total responses.

Survey #2 was 2 questions long. It had an 69% completion rate and 49 total responses.

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8 Executive Summary

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9 Survey #1: Respondent Demographics
The survey contained 7 questions related to demographics. The first question of the survey was, “Do you live in Lake Forest?”1 Approximately 47% of respondents answered, “No.” Given the large number of responses that came from non-residents on a survey meant to ascertain information about residential conditions and attitudes towards housing within the City, the results from residents and non-residents are analyzed separately in this Community Survey Report. Non-residents also skipped large portions of the survey (which would be expected since the questions are largely non- applicable to non-residents). As such, unless otherwise noted, all survey results reported are from the sample of resident responses (33 in total for Survey #1 regarding housing conditions).

Of the other six demographic questions asked, one of those questions included an opportunity for users to sign-up for more information about the Housing Element update process. The other five questions highlighted the following about the respondents:
• Of those individuals who live in Lake Forest, approximately 64% have lived here for 10+ years.

The next highest response (27%) was 5-10 years, followed by 2-5 years (9%).2 • Most of the respondents own their own home (79%), with 21% of respondents renting.3 • Most of the respondents (79%) live in a single-family home, with the next highest category being multi-family homes (15%), followed by duplex/attached homes (5%) and mobile homes (5%).4
• Of the respondents surveyed, the most common types of households include couples (33%), couples with children younger than 18 (24%), and single-person households (21%). There was considerable range in household types including 9% who identified as an unlisted household type, such as couples with adult children living with them.5 • The respondents were primarily 56-74 years old (36%), followed by 40-55 years old (30%), and 24-39 years old (18%).6

1 Question 1: Do you live in Lake Forest?
2 Question 2: How long have you lived in the City?
3 Question 4: Do you currently own or rent your home?
4 Question 5: Select the type of housing that best describes your current home. 5 Question 9: Which of the following best describes your household type? 6 Question 14: What age range most accurately describes you? Item: 11
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10 Figure 1: How long have you lived in the City?

Survey #1 Responses
The survey responses reveal information about housing in Lake Forest. The results are grouped into four categories: values and priorities; housing affordability; housing maintenance; and housing fit.

VALUES AND PRIORITIES
When respondents were asked, “What made you decide to live here?”7 the most common answers were:
• Affordability (48%)
• Proximity to job/work (45%)
• Proximity to family and/or friends (45%)
• Safety of neighborhood (42%)
• Quality of housing stock (27%)
• Quality of local school system (24%)
• Other (27%)
• Proximity to shopping and services (18%)
• City services and programs (6%)

Some of the other responses included:
• Living with family
• Smaller town atmosphere with lower density and some breathing room • The view from our house
• Proximity to parks, trails, and other outdoor opportunities • Quiet neighborhood

7 Question 3: What made you decide to live here?
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11 Figure 2: What made you decide to live here?

HOUSING AFFORDABILITY
When respondents were asked, “If you wish to own a home in Lake Forest but do not currently own one, what issues are preventing you from owning a home at this time?”8 those who do not already own a home responded:
• I cannot find a home within my target price range in Lake Forest (18%) • I cannot find a home that suits my living needs in Lake Forest (housing size, disability accommodations) (12%)
• I do not currently have the financial resources for an appropriate down payment (9%) • I do not currently have the financial resources for an adequate monthly mortgage payment (6%)
• I cannot currently find a home that suits my quality standards in Lake Forest (3%)

8 Question 10: If you wish to own a home in Lake Forest but do not currently own one, what issues are preventing you from owning a home at this time? (Select all that apply) Item: 11
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12 Over 70% of Lake Forest residents who responded to this question already owned a home in Lake Forest. None of the residents expressed the opinion that they do not wish to own or rent in Lake Forest.

Figure 3: If you wish to own a home in Lake Forest but do not currently own one, what issues are preventing you from owning a home at this time?

When the responses of non-residents were compared, the following differences occur:

For those who do not currently live in Lake Forest, 67% responded that they do not currently wish to own or rent a home within the City. Additionally, 33% of non-residents responded that they cannot find a home within their target price range in Lake Forest, and 4% responded that they do not currently have the financial resources for an appropriate down payment.

HOUSING MAINTENANCE
When respondents were asked, “How would you rate the physical condition of the residence you live in?”9 more than half of all respondents answered positively, with the response “excellent condition” receiving 55%.

9 Question 7: How would you rate the physical condition of the residence you live in? Item: 11
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13 Figure 4: How would you rate the physical condition of the residence you live in?

Approximately 40% of respondents answered that their residence showed signs of minor deferred maintenance such as peeling paint or chipped stucco. No respondents indicated that their home needed one or more major repairs, which is generally consistent with the home maintenance issues related to the City’s relatively young housing stock.

When asked, “Which of the following housing upgrades or expansions have you considered making on your home?”10 the top responses included:
• Painting (55%)
• HVAC (36%)
• Roofing (33%)
• Other (33%)
• Solar (27%)

The other responses included: landscaping, kitchen or bathroom remodels, plumbing, and other maintenance related to the interior of the home.

10 Question 8: Which of the following housing upgrades or expansions have you considered making on your home? Item: 11
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14 Figure 5: Which of the following housing upgrades or expansions have you considered making on your home?

HOUSING FIT
When asked, “How satisfied are you with your current housing situation?”11, over 90% of respondents indicated that they were very satisfied or somewhat satisfied with their current housing. The top responses were:
• I am very satisfied (61%)
• I am somewhat satisfied (30%)
• I am somewhat dissatisfied (9%)
• I am dissatisfied (6%)
Some of the explanations as to why respondents were dissatisfied include:
• The city is growing too fast for the infrastructure (i.e. roadways, etc.) • Have outgrown current type of housing, but single-family homes in the area are too expensive • Want to buy a condo, but cannot find one
• Too much traffic-related noise
• On a fixed-income and worried about rising housing costs

11 Question 6: How satisfied are you with your current housing situation? Item: 11
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15 When asked, “Do you think that the range of housing options currently available in the City of Lake Forest meets your needs?”12 respondents answered:
• Yes (59%)
• No (41%)
While more than half (59%) of resident respondents answered that there were a sufficient range of housing options currently available in the City, non-residents answered this question nearly the exact opposite. Fifty-eight (58%) of non-residents stated, “No,” while only (42%) of non-residents stated, “Yes.” This shows a fairly even division of opinions on the matter.

When asked, “What types of housing are most needed in the City of Lake Forest?”13 respondents answered:
• Condominiums (multifamily ownership homes) (44%)
• Other (41%)
• Apartments (multi-family rental homes) (38%)
• Senior Housing (38%)
• Duplex/Attached Housing (25%)
• Housing for people with disabilities (25%)
• Single-family (detached) (25%)

12 Question 11: Do you think that the range of housing options currently available in the City of Lake Forest meets your needs?
13 Question 12: What types of housing are most needed in the City of Lake Forest? Item: 11
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16 Figure 6: What types of housing are most needed in the City of Lake Forest? (Residents)

Some of the other responses included:
• Affordable housing including in the low-income and very low-income price ranges • Handicap accessible housing
• Transition housing for individuals experiencing homelessness • Single-story single-family homes so individuals can age in place Non-residents felt differently about the matter. Of non-residents the top responses included:
• Housing for people with disabilities (57%)
• Other (43%)
• Senior Housing (43%)
• Condominiums (multifamily ownership homes) (43%)
• Apartments (multi-family rental homes) (43%)

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17 Figure 7: What types of housing are most needed in the City of Lake Forest? (Non-Residents)

Some of the other responses included:
• Affordable housing
• Homeless housing
• Permanent supportive housing

When asked, “If you are currently employed, approximately how long is your one-way commute to work?”14 respondents were most likely to reply:
• I am not currently employed (45%)
• 10-25 miles (18%)
• I am employed, but work from home (15%)
These responses, coupled with the age of survey respondents, indicate that a larger percentage of individuals completing the survey are retired. Given the on-going nature of the COVID-19 pandemic, it should be noted that some of those currently employed but working from home may be doing so on a temporary basis. This issue will be explored further as part of the City’s upcoming Community Satisfaction Survey.

Of non-residents who are employed, the most commonly reported commute distances were 5-10 miles (16%). There were no non-residents who reported commute distances of 25 miles or more

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18 which seems to indicate that individuals who work in Lake Forest but live elsewhere live in nearby jurisdictions.

Figure 8: If you are currently employed, approximately how long is your one-way commute to work?

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19 Survey Responses #2
The second survey focused on understanding the relative importance of various housing priorities to the respondent and their family. Of the 49 respondents, 34 responded that they were residents.

When asked, “Do you live and/or work in Lake Forest?”15 respondents stated:
• Yes (69%)
• No (31%)
Note that if the respondent answered “no,” to this question they were not invited to complete the remainder of the survey; this is because the question relates to prioritization of City resources, and City residents are more directly impacted by how the City elects to spend its resources versus non- residents. This preserves the integrity of the survey questions, but also lowered the completion rate (69%) of the survey. That does mean, however, that 100% of respondents who answered, “Yes” to Question 1, went on to complete the survey.

When asked, “How important are the following housing priorities to you and your family?”16 the top priorities listed as either “very important” or “somewhat important” were:
• Support fair/equitable housing opportunities (100%)
• Support programs to help maintain and secure neighborhoods that have suffered foreclosures (100%)
• Establish programs to help at-risk homeowners keep their homes, including mortgage loan programs (97%)
• Provide housing affordable to working families (94%)
• Rehabilitate existing housing (94%)

The issue that ranked as the lowest importance were:
• Build more single-family housing (34%)

15 Question 1: Do you live and/or work in Lake Forest?
16 Question 2: How important are the following housing priorities to you and your family? Item: 11
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20 Figure 9: How important are the following housing priorities to you and your family?

Stakeholder Meetings/Consultation
Throughout preparation of the Public Draft General Plan, the City has engaged directly with community stakeholders working in and around Lake Forest. The City sent a hard copy letter and email to over two dozen stakeholders, including affordable housing developers and advocates, faith- based organizations, and community groups to invite them to consult on the Housing Element Update process. The City met one-on-one with three groups:
• Tapestry, A Unitarian Universalist Congregation/Welcoming Neighbors Home (Tapestry’s Initiative to End Homelessness)
• The Kennedy Commission
• Province Group
• Orange County Fair Housing Council
The City was pleased to meet and hear from these organizations as part of the preparation process, and the input received through these meetings was invaluable in helping to plan for and address the City’s current and future housing needs.

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21 Public Review of Draft Housing Element
The Public Review Draft 2021-2029 Housing Element was made available to the public on September 22, 2021. The material was posted to the project website and a press release was posted to the City’s website and advertised at public hearings and to individuals registered for project notifications. The City is also advertising the Public Review Draft and providing direction on how individuals can provide public comment via its social media challenges and direct letters to stakeholder engaged in housing services in and around Lake Forest.

Interested parties are were invited to submit public comments using a fillable comment card available on the project website, provide written comments via mail to City Hall, or email comments to the City’s Housing Element Project Manager.

The City will hosted a Community Meeting on the Public Review Draft Housing Element on October 7, 2021. The intent of the Community Meeting will was be to provide another avenue/opportunity for the public to learn about the Housing Element, provide input, and ask questions. The Community Meeting will included a live presentation, and a copy of this presentation will was made be available on the project website.

Feedback Influence
The feedback received from the public during preparation of the Housing Element and on the Public Draft Housing Element directly influenced the goals, policies, and programs included in the Housing Plan. Table 1 below summarize how public input is reflected in the Housing Plan.

General Input Received Applicable Reference
Goal Policy Program Other
There should be more
affordable housing choices for
people who want to live in
Lake Forest, including kids
who grow up in Lake Forest
(Survey)
• Goal 1 • Policy 1.1
• Policy 1.2
• Policy 1.3
• Policy 1.4

• Program 1
• Program 4
• Program 5
• Program 8
•

The City should have a range
of housing options to meet
different personal preferences
(Survey)
• Goal 1 • Policy 1.1
• Policy 1.3
• Policy 1.4
• Program 1
• Program 5
• Program 7
• Program 8
• Program 15

The City should create
additional opportunities for
lower cost homeownership
(Survey)
• Goal 3 • Policy 3.1
• Policy 3.2
• Policy 3.3
• Program 20
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22 Revise policies to include a
requirement for affordable
housing (Tapestry)
• Goal 1 • Policy 1.6
• Policy 1.7
• Policy 1.8
• Program 1
• Program 5

Market available housing sites
to housing developers
(Tapestry)
• Program 5
• Program 22
•
Assess current fee structure
(Tapestry)
• Goal 1 • Policy 1.5 • Program 6
Work with County
representatives and
neighboring cities to address
affordable and permanent
supportive housing (Tapestry)
• Program 9
• Program 10
• Program 11
•
Implement best planning
practices (Tapestry)
• All • All • All
Engage the community from
the beginning of the Housing
Element Update process
(Kennedy Commission)
The City provided
early opportunities
for public input
through the
community survey
on online comment
card. The City
continues to make
opportunities
available through
the Community
Open House and
public review
process.

City can help advertise fair
housing resources in new
ways (OC Fair Housing Council)
• Goal 4 • Policy 4.6 • Program 22
Consider funding new fair
housing programs, as
requested by service
provider(s) (OC Fair Housing
Council)
• Goal 4 • Policy 4.3 • Program 21

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23 Public Comment: Tapestry

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24 Item: 11
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25 Item: 11
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26 Item: 11
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27 Item: 11
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28 Item: 11
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29 Item: 11
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30 Item: 11
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31 Item: 11
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ATTACHMENT 1

EXHIBIT B
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Environmental Analysis

2021-2029 Housing Element Update
October 2021

Prepared for:

City of Lake Forest
100 Civic Center Drive
Lake Forest, CA 92630

Prepared by:

De Novo Planning Group
180 E. Main Street, Suite 108
Tustin, CA 92780

De Novo Planning Group
A Land Use Planning, Design, and Environmental Firm
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ENVIRONMENTAL ANALYSIS – 2021-2029 HOUSING ELEMENT OCTOBER 2021

CITY OF LAKE FOREST PAGE 1

INTRODUCTION ............................................................................................................................................................... 2 DESCRIPTION OF THE PROPOSED PROJECT ....................................................................................................... 2 BACKGROUND ...................................................................................................................................................... 2 PROJECT LOCATION AND SETTING ............................................................................................................ 3 CHARACTERISTICS OF PROPOSED PROJECT REVISIONS/ADDITIONS ....................................... 5 PREVIOUS ENVIRONMENTAL ANALYSES APPLICABLE TO THE PROPOSED PROJECT .................. 11 CEQA GUIDELINES SECTION 15183 ........................................................................................................ 11 PROJECT ENVIRONMENTAL REVIEW CONCLUSION ....................................................................... 14 ENVIRONMENTAL ANALYSIS ................................................................................................................................... 15 I. AESTHETICS ................................................................................................................................................... 15 II. AGRICULTURE AND FORESTRY RESOURCES ................................................................................. 16 III. AIR QUALITY ............................................................................................................................................... 18 IV. BIOLOGICAL RESOURCES ...................................................................................................................... 20 V. CULTURAL RESOURCES ........................................................................................................................... 21 VI. ENERGY ......................................................................................................................................................... 22 VII. GEOLOGY AND SOILS ............................................................................................................................. 23 VIII. GREENHOUSE GAS EMISSIONS ........................................................................................................ 25 IX. HAZARDS AND HAZARDOUS MATERIALS ...................................................................................... 26 X. HYDROLOGY AND WATER QUALITY .................................................................................................. 30 XI. LAND USE AND PLANNING ................................................................................................................... 33 XII. MINERAL RESOURCES ........................................................................................................................... 34 XIII. NOISE........................................................................................................................................................... 34 XIV. POPULATION AND HOUSING ............................................................................................................ 36 XV. PUBLIC SERVICES .................................................................................................................................... 37 XVI. RECREATION ............................................................................................................................................ 39 XVII. TRANSPORTATION .............................................................................................................................. 39 XVIII. TRIBAL CULTURAL RESOURCES .................................................................................................. 41 XIX. UTILITIES AND SERVICE SYSTEMS ................................................................................................ 41 XX. WILDFIRE .................................................................................................................................................... 44

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INTRODUCTION
The following pages provide an ana lysis of the proposed 2021-2029 Housing Element (Project) with respect to the Project’s consistency with the 2040 Lake Forest General Plan ( 2040 General Plan) and the analysis contained in the 2040 Lake Forest General Plan Final Environmental Impact Report (2040 General Plan FEIR) State Clearinghouse No. 2019090102.

As explained in the following pages, the proposed P roject is consistent with the 2040 General Plan, for which an EIR was prepared and certified, and there are no impacts associated wit h the proposed Project that have not been fully addressed in a previous environmental document. The findings presented below demonstrate that no additional environmental analysis is required under the California Environmental Quality Act (CEQA) prior to approval of the proposed Project.

DESCRIPTION OF THE PROPOSED PROJECT

BACKGROUND
The Housing Element is a State -mandated element of the General Plan. The City of Lake Forest must update its Housing Element every eight years. Updates to the Housing Element must meet the requirements of California Government Code Sections 65580 -65589. The purposes of the Housing Element are to identify the community's housing needs; to state the community's goals and objectives with regard to housing production, rehabilitation, and conservation to meet those needs; and to define the policies and programs that the community will implement to achieve the stated goals and objectives.

State law requires that the City accommodate its “fair share” of regional housing needs, which are assigned by the Southern California Association of Governments (SCAG) for all jurisdictions in the SCAG region. SCAG established the 2021-2029 Regional Housing Needs Plan (RHNP) to assign each city and the unincorporated county in the region its fair share of the regional housing need based on a number of factors established by State law (Government Code Section 65584) and regional housing burdens and needs. The objectives of the Regional Housing Needs Allocation (RHNA) are:
• Increase housing supply and the mix of housing types; • Promote infill, equity, and environment;
• Ensure jobs housing balance and fit;
• Promote regional income equity; and
• Affirmatively further fair housing.

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CITY OF LAKE FOREST PAGE 3

Beyond the income -based housing needs established by the RHNA, the Housing Element must also address special needs groups; such as seniors, persons with disabilities including developmental disabilities, single female parents, large families, farm workers, and homeless persons.

PROJECT LOCATION AND SETTING
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 lim its 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 wit h 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.

The 2040 General Plan Land Use and Design Element designates the general distribution and intensity of residential, commercial, industrial, open space, public/semi -public, and other categories of pub lic and private land uses throughout the City. It also identifies high -level community design objectives for the City of Lake Forest, including the relationship between the public and private realm, streetscapes, best site planning practices, and placemaking strategies.

The Land Use and Design Element is primarily implemented by the City’s Zoning Ordinance, which specifies districts and performance standards for various types of land uses described in the 2040 General Plan. The zone districts specify the permitted uses for each category and applicable development standards. The City is currently preparing an update to its Zoning Ordinance to create new mixed -use zones to implement the mixed -use land use designations included in the 2040 General Plan; this update is expected to be completed in 2022.

The Land Use and Design Element includes the Land Use Map, which identifies land use designations for each parcel in the City Limits and Planning Area (Figure LU -1 of the Land Use and Design Element). Table 1 Land Use Development Potential Summary , summarizes the expected development capacity for residential uses within Lake Forest based on reasonable density assumptions for the City and SOI.

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TABLE 1: LAKE FOREST LAND USE DEVELOPMENT POTENTIAL SUMMARY Land Use Designation Acres
(1)
Allowed
Density
and/or
Intensity
Assumed
Density
and/or
Intensity (2)
Units Population
(3)
Non-
Residential
Square Feet
Jobs (4)

RESIDENTIAL LAND USES
Very Low Density - 0-2 du/ac 1 du/ac - - - -
Low Density 2,499 2-7 du/ac 6.8 du/ac 17,023 50,559 - - Low-Medium Density 880 7-15 du/ac 10.9 du/ac 9,589 28,481 - - Medium Density 361 15-25 du/ac 22 du/ac 7,931 23,555 - - High Density 16 25-43 du/ac 38 du/ac 620 1,840 - -
Residential Subtotal 3,756 35,163 104,435 - -

NON-RESIDENTIAL LAND USES
Commercial 341 1.0:1 FAR 0.25 FAR - - 3,718,616 8,263
Professional Office 12 1.2:1 FAR 0.30 FAR - - 156,816 522 Business Park 298 1.0:1 FAR 0.35 FAR - - 4,545,819 7,576 Light Industrial 627 0.60:1 FAR 0.35 FAR - - 9,565,602 15,943 Public Facility 373 1.2:1 FAR 0.05 FAR - - 811,508 812 Non-Residential Subtotal 1,651 - - 18,798,361 33,116

MIXED-USE LAND USES
Mixed-Use 32 49 32 du/ac

1.0:1 FAR
32 du/ac;

0.25 FAR 1,570 4,663 534,327 1,186
Mixed-Use 43 312 43 du/ac

1.2:1 FAR
36 du/ac (2);

0.40 FAR 8,179 24,290 5,429,287 12,067
Mixed-Use Office 24 1.5:1 FAR 0.50 FAR - - 513,715 1,284 Urban Industrial 25 95 25 du/ac

1.0:1 FAR
22 du/ac;

0.40 FAR 2,090 6,207 1,655,280 2,758
Urban Industrial 43 22 43 du/ac

1.2:1 FAR
36 du/ac;

0.40 FAR 792 2,352 323,328 539
Mixed-Use Subtotal 502 12,631 37,512 8,455,937 17,834

LIMITED DEVELOPMENT LAND USES
Community Park/Open Space 249 0.40:1 FAR 0.0025 FAR - - 27,148 27 Regional Park/Open Space 1,939 0.10:1 FAR 0.0001 FAR - - 8,448 8 Open Space 877 0.40:1 FAR - - - - -
Lake 58 - - - - - -
Transportation Corridor 30 0.20:1 FAR - - - - -
Right-of-Way 1,681 - - - -
Limited Development Subtotal 4,834 - - 35,596 36
Totals 10,742 47,794 141,947 27,289,894 50,986

1. Acres are given as adjusted gross acreages, which do not include the right -of-way for major roadways, flood control facilities, or railroads.

2. Density/intensity includes both residential density, expressed as dwelling units per acre, and nonresidential intensity, expressed as floor area ratio (FAR), which is the amount of building square feet in relation to the size of the lot. Historically, citywide buildout levels do not achieve the maximum allowable density/intensity on every parcel, and are, on average, lower than allowed by the General Plan. Accordingly, the projections in this General Plan do not assume buildout at the maximum density or intensity but are adjusted downward to account for variations in development.

3. Estimates of population are based on average household size of 2.97, as identified by the California Department of Finance, 2018.

4. Estimates of jobs by land use designation are based on employment generation rates derived from the Longitudinal Employer - Household Dynamics (2015) Report.

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CHARACTERISTICS OF PROPOSED PROJECT REVISIONS/ADDITIONS The project analyzed herein involves the 20 21-2029 Housing Element Update. The proposed update would not modify the 2040 Gener al Plan Land Use Map, land use designations, or intensities/densities identified within the 2040 General Plan Land Use and Design Element. No changes to the maximum development potential approved for the 2040 General Plan and analyzed in the 2040 General Plan FEIR would occur with the proposed Project.

In compliance with State Housing Element Law requirements, the City of Lake Forest has prepared the 2021-2029 Housing Element (Project) to:
• Provide goals, policies, quantified objectives and scheduled programs to preserve, improve and develop housing
• Identify and analyze existing and projected housing needs for all economic segments of the community
• Identify adequate sites that are zoned and available within the 8 -year housing cycle to meet the City’s fair share of regional housing needs at all income levels • Affirmatively further fair housing
• Be certified (approved) by the State Department of Housing and Community Development (HCD) as complying with State law
• Be internally consistent with other parts of the General Plan

HOUSING ELEMENT ORGANIZATION
The proposed Housing Element Update covers the October 15, 2021 through October 15, 2029 planning period and is comprised of the following components:

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. To this end, the Housing Plan focuses on:
1) Encouraging housing diversity and opportunities;
2) Maintaining, preserving, and conserving existing residential neighborhoods; 3) Increasing opportunities for home ownership;
4) Promoting equal opportunity for all residents to reside in the housing of their choice.

The Housing Plan includes only minor modifications to the City’s current Housing Element Goals and Policies. The Housing Plan includes a number of new programs to address State housing law including future required updates to the Lake Forest Zoning Ordinance, new programs to support affirmatively furthering fair housing, and tracking and reporting requirements for Housing Sites.

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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. In addition to identifying housing needs, the Background Report also presents information regarding the setting in which these needs occur. The Background Report comprehensively updates the background context and conditions identified in the City’s current Housing Element.

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. The California Department of Housing and Community Development (HCD) requires that the Housing Sites Inventory be prepared using a State -approved format, included as Appendix A. No land use changes are proposed to accommodate the City’s Regio nal Housing Needs Allocation (RHNA); future residential development is expected to occur in those areas already identified for residential uses including land within mixed-use areas identified in the 2040 General Plan. All sites identified in the City’s Housing Sites Inventory are currently identified for new development consistent with the potential development capacities identified in Appendix A.

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.

CAPACITY TO MEET REGIONAL HOUSING NEEDS
As determined by SCAG , the City of Lake Forest ’s fair share allocation (RHNA) is 3,236 new housing units during this planning cycle . This includes: 956 units affordable to extremely/very low income households; 543 units affordable to low income households; 559 units affordable to moderate income households; and 1,178 units affordable to above moderate income households.

State Income Limits which are used to determine affordability levels are set annually by the California Department of Housing and Community Development.

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Progress Towards the RHNA
RHNA uses June 30, 2021 as the baseline for growth projections for the 2021 -2029 planning period. Jurisdictions may count toward the RHNA housing units that have been developed, are under construction, and/or have received their building permits after June 30, 202 1. Since this time, 755 housing units have been developed, are under construction, or have received their building permits in Lake Forest. Jurisdictions may also count projects that are approved/entitled but not yet built or under construction ; 753 units in multiple income categories, have been approved/entitled and are expected to be developed within the planning period. With these units taken into account, Lake Forest has a remaining RHNA of 1,846 units (848 extremely low/very low income units, 445 low income units, 553 moderate income units); a surplus of 118 unit occurs within the above-moderate income units.

TABLE 2: REMAINING 6TH CYCLE RHNA
Status Extremely
Low/Very
Low
Low Moderate Above
Moderate
TOTAL
RHNA Allocation 956 543 559 1,178 3,236
Constructed, Under
Construction/Permits
Issued (Since 6/30/2021)
1 1 1 752 755
Units Approved/Entitled 107 97 5 544 753
Remaining Allocation 848 445 553 0 (with
surplus of
118 units)
1,846*
Source: City of Lake Forest, 2021, Southern C3alifornia Association of Governments, 2021 *The total remaining allocation is the remaining allocation of extremely low/very low, low, and moderate income units (848, 44 5, and 553, respectively). This results in a remaining allocation of 1,846 units. The surplus of above moderate -income units (118) cannot be deducted from the remaining allocation, which is based on the remaining allocation by income level.

Residential Sites Inventory to Accommodate Remaining RHNA The City has sufficient land appropriately zoned for residential uses throughout the community to accommodate its remaining RHNA (1,846 units) for the 2021-2029 planning period. The City of Lake Forest’s 6th Cycle residential sites fall into three categories:
1) Accessory dwelling units. ADUs are allowed on any lot that is zoned for single- family or multifamily dwelling residential use. In 2020 the City updated its ADU ordinance to encourage the production of ADUs throughout the community. The City approved two ADUs in 2018, three ADUs in 2019, and seven ADUs in 2020. The City continues to promote ADUs as a way to expand the City’s housing stock and anticipates production to continue at or above 2020 levels for the duration of the planning period. The City has assumed production of ADUs at a rate of 4 units per year for the 8 year planning period, resulting in an assumed production of 32 ADUs from 2021- 2029.

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2) Underutilized residential sites . As part of this Housing Element update, the City has identified two properties currently designated for residential development as suitable for accommodating a portion of the City’s moderate and above moderate - income RHNA allocation. These vacant propert ies have the potential to yield 382 units, assuming each parcel is developed at 80% of its maximum capacity.

3) 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. As part of the City’s General Plan Update, over 383 acres were designated for mixed-use development allowing for densities of at least 30 du/ac. The Housing Element only relies on 123 acres of the 383 acre s designated for such development, or just over 32%. Only 50% of the development potential 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. Based on this methodology, underutilized sites in mixed -use areas have the potential to yield 2,965 units.

TABLE 3: COMPARISON OF RHNA CANDIDATE SITES REALISTIC CAPACITY AND RHNA Status Extremely
Low/Very Low
Low Moderate Above
Moderate
TOTAL
Remaining 6th
Cycle RHNA
848 445 553 0 (with a surplus
of 118 units)
1,846
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 (surplus) +177 (surplus) +622 (surplus) +532 (surplus) +1,658 (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 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.

SUMMARY OF HOUSING ELEMENT MODIFICATIONS
As previously noted, State law requires that the Housing Element be reviewed and updated not less than every eight years, in order to remain relevan t and useful, and reflect a community’s changing housing needs. The proposed Housing Element Update involves minor changes/additions to the Housing Element and environmental conditions under which it would be implemented. The following summarizes the modif ications to the Housing Element, as compared to the 2013-2021 Housing Element:

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Goals, Policies, and Programs (Part 1: Housing Plan)
The City made minor modifications to the Policies included in the Housing Element to reflect the City’s current housing needs and State mandates.

The Housing Plan revises existing policies to better reflect state law regarding the provision of special needs housing, removing governmental and nongovernmental constraints, and affirmatively furthering fair housing. Revised goals and policies include:
• Policy 2.1: Quality and Conditions of Existing Housing Stock • Policy 2.3: Rehabilitation and Home Improvement Funding • Policy 2.6: Rental and Homeownership Opportunities
• Policy 3.2: State and Federal Funding Sources for Fair Home Purpose Options • Policy 4.3: Enforcement of Fair Housing Laws
The Housing Plan includes new policy direction, consistent with state law, related to maintaining adequate capacity to accommodate the City’s RHNA at all income levels for the duration of the planning period, the reuse of sites identified in prior Housing Elements, and reducing impacts associated with nongovernmental constraints. New policies include:
• Policy 1.7: Maintain Adequate Capacity
• Policy 1.8: By-Right Approval for Qualified Sites Identified in Past Inventories The Housing Plan includes numerous revisions to existing programs to better reflect the community’s housing needs. Revised programs include:
• Program 1: Land Use Policy, Entitlements and Development Capacity • Program 2: Monitor Residential Capacity (No Net Loss) • Program 5: Facilitate Affordable and Special Needs Housing Construction • Program 6: Monitor Changes in Federal and Sate Housing, Planning, and Zoning Laws • 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 • Program 14: Rental Assistance
• Program 15: Conservation of Existing Affordable Units • Program 16: Housing Rehabilitation Loan Program
• Program 17: Code Enforcement and Neighborhood Preservation • Program 20: Homebuyer Assistance Programs
• Program 21: Fair Housing Services
The Housing Plan includes new programs consistent with state law and the goals and policies included in the City’s Housing Element. New programs include:

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• Program 3: Public Property Conversation to Housing Program • Program 4: Replacement of Affordable Units
• Program 7: Zoning Code Amendments – Housing Constraints • Program 8: Accessory Dwelling Units
• Program 12: California Accessibility Standards Compliance Program • Program 13: Density Bonus Implementation Program
• Program 18: Energy Conservation and Energy Efficiency Opportunities • Program 19: Lead Based Paint Education and Reduction Program • Program 22: Affirmatively Furthering Fair Housing Outreach and Coordination Program • Program 23: Economic Displacement Risk Analysis
All other Goals, Policies and Programs are reflective of the City’s current Housing Element with limited or no modifications to reflect current conditions.

Background Information (Part 2: Background Report)
The Background Report of the Housing Element has been comprehensively updated to include current information. This section of the Housing Element includes: Introduction, Accomplishments Under 5 th Cycle Housing Element, Housing Needs Assessment, Constraint s, Housing Resources, and Affirmatively Furthering Fair Housing Analysis.

Appendix A: Housings Sites Inventory
The City has updated its Housing Sites Inventory to demonstrate capacity to accommodate its 2021-2029 RHNA. The Housing Sites Inventory includes a list of sites appropriate to accommodate the RHNA at the appropriate densities and income levels and includes sites identified in the Current Housing Element and other sites designated for residential development consistent with the City’s 2040 General Plan. No land use changes are proposed as part of the 2021-2029 Housing Element.

Appendix B: Public Engagement Summary
The public engagement program conducted as part of the Housing Element Update project is summarized in Appendix B.

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PREVIOUS ENVIRONMENTAL ANALYSES APPLICABLE TO THE

PROPOSED PROJECT
In June 2020 , the Lake Forest City Council considered and certified the Final EIR (State Clearinghouse No. 2019090102) for the 2040 Lake Forest General Plan. The 2040 General Plan FEIR evaluated the anti cipated development that could occur within the Planning Area based upon land use densities and intensities proposed as part of the 2040 General Plan.

The proposed Project would be consistent with the development densities established by the 2040 General Plan policies for which the 2040 General Plan FEIR was certified. Residential development consistent with the 2040 General Plan, including cumulative impacts, were fully addressed in the 2040 General Plan FEIR.

CEQA GUIDELINES SECTION 15183
The Housing Element Update is a Project under CEQA and was analyzed in the 2040 General Plan FEIR. California Environmental Quality Act (CEQA) Guidelines Section 15183 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 EIR was certified. As noted below, the proposed Project is consistent with the land use designations and densities established by the 2040 General Plan, for which an EIR was certified. The provisions contained in Section 15183 of the CEQA Guidelines are presented below. 15183. Projects Consistent with a Community Plan or Zoning (a) CEQA mandates that projects which are consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR was certified shall not require additional environmental review, except as might be necessary to examine whether there are project -specific signi ficant effects which are peculiar to the project or its site. This streamlines the review of such projects and reduces the need to prepare repetitive environmental studies.
(b) In approving a project meeting the requirements of this section, a public agency shall limit its examination of environmental effects to those which the agency determines, in an initial study or other analysis:
(1) Are peculiar to the project or the parcel on which the project would be located, (2) Were not analyzed as significant effects in a prior EIR on the zoning action, general plan, or community plan, with which the project is consistent, (3) Are potentially significant off- site impacts and cumulative impacts which were not discussed in the prior EIR prepared for the general plan, community plan or zoning action, or
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(4) Are previously identified significant effects which, as a result of substantial new information which was not known at the time the EIR was certified, are determined to have a more severe adverse impact than discussed in the prior EIR. (c) If an impact is not peculiar to the parcel or to the project, has been addressed as a significant effect in the prior EIR, or can be substantially mitigated by the imposition of uniformly applied development policies or standards, as contemplated by subdivision (e) below, then an additional EIR need not be prepared for the project solely on the basis of that impact.
(d) This section shall apply only to projects which meet the following conditions:
(1) The project is consistent with:
(A) A community plan adopted as part of a general plan, (B) A zoning action which zoned or designated the parcel on which the project would be located to accommodate a particular density of development, or (C) A general plan of a local agency, and
(2) An EIR was certified by the lead agency for the zoning action, the community plan, or the general plan.
(e) This section shall limit the analysis of only those significant environmental effects for which:
(1) Each public agency with authority to mitigate any of the significant effects on the environment identified in the planning or zoning action undertakes or requires others to undertake mitigation measures specified in the EIR which the lead agency found to be feasible, and
(2) The lead agenc y makes a finding at a public hearing as to whether the feasible mitigation measures will be undertaken.
(f) An effect of a project on the environment shall not be considered peculiar to the project or the parcel for the purposes of this section if uniformly applied development policies or standards have been previously adopted by the City or county with a finding that the development policies or standards will substantially mitigate that environmental effect when applied to future projects, unless substan tial new information shows that the policies or standards will not substantially mitigate the environmental effect. The finding shall be based on substantial evidence which need not include an EIR. Such development policies or standards need not apply throughout the entire City or county, but can apply only within the zoning district in which the project is located, or within the area subject to the community plan on which the lead agency is relying. Moreover, such policies or standards need not be part of the general plan or any community plan, but can be found Item: 11
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within another pertinent planning document such as a zoning ordinance. Where a City or county, in previously adopting uniformly applied development policies or standards for imposition on future proj ects, failed to make a finding as to whether such policies or standards would substantially mitigate the effects of future projects, the decision-making body of the City or county, prior to approving such a future project pursuant to this section, may hold a public hearing for the purpose of considering whether, as applied to the project, such standards or policies would substantially mitigate the effects of the project. Such a public hearing need only be held if the City or county decides to apply the standards or policies as permitted in this section.
(g) Examples of uniformly applied development policies or standards include, but are not limited to:
(1) Parking ordinances.
(2) Public access requirements.
(3) Grading ordinances.
(4) Hillside development ordinances.
(5) Flood plain ordinances.
(6) Habitat protection or conservation ordinances.
(7) View protection ordinances.
(8) Requirements for reducing greenhouse gas emissions, as set forth in adopted land use plans, policies, or regulations.
(h) An environmental effect shall not be considered peculiar to the project or parcel solely because no uniformly applied development policy or standard is applicable to it. (i) Where the prior EIR relied upon by the lead agency was prepared for a general plan or community plan that meets the requirements of this section, any rezoning action consistent with the general plan or community plan shall be treated as a project subject to this section.
(1) “Community plan” is defined as a part of the general plan of a City or county which applies to a defined geographic portion of the total area included in the general plan, includes or references each of the mandatory elements specified in Section 65302 of the Government Code, and contains specific development policies and implementation measures which will apply those policies to each involved parcel. (2) For purposes of this section, “consistent” means that the density of the proposed project is the same or less than the standard expressed for the involved parcel in the Item: 11
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general plan, community plan or zoning action for which an EIR has been certified, and that the project complies with the density -related standards contained in that plan or zoning. Where the zoning ordinance refers to the general plan or community plan for its density standard, the project shall be consistent with the applicable plan. (j) This section does not affect any requirement to analyze potentially significant offsite or cumulative impacts if those impacts were not adequately discussed in the prior EIR. If a significant offsite or cumulative impact was adequately discussed in the prior EIR, then this section may be used as a basis for excluding further analysis of that offsite or cumulative impact.

PROJECT ENVIRONMENTAL REVIEW CONCLUSION
A comprehensive environmental evaluation has been completed for the Project as documented in the attached Environmental Analysis. This evaluation concludes that the Project qualifies for an exemption from additional environmental review because it is consistent with the development density established by the 2040 General Plan, as analyzed by the 2040 General Plan FEIR, and all required findings can be made. The proposed Project would not result in: 1) a peculiar impact that was not identified as a significant impact under the 2040 General Plan FEIR; 2) a more severe impact due to new information; or 3) a potentially significant off-site impact or cumulative impact not discussed in the 2040 General Plan FEIR.

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ENVIRONMENTAL ANALYSIS
This section of the Environmental Analysis incorporates the most current Appendix "G" Environmental Checklist Form contained in the CEQA Guidelines. Impact questions and responses are included in narrative formats for each of the environmental topic areas.

I. AESTHETICS
The 2040 General Plan FEIR determined that impacts to aesthetic resources would be less than significant through the implementation of policies and actions in the 2040 General Plan.

While the Lake Forest Planning Area contains numerous areas and viewsheds with relatively high scenic value, there are no officially designated scenic vista points in the Planning Area.

Additionally, there are no officially designated scenic highways located in the vicinity of Lake Forest. Significant visual resources in the Planning Area include several prominent creeks, including Aliso Creek, Serrano Creek, San Diego Creek, and the Bor rego Canyon Wash, and the Eucalyptus groves that surround portions of the lakes. Other prominent visual features throughout the Planning Area include views of ridgelines, hillsides, and canyons.

Implementation of the 2040 General Plan could lead to new an d expanded urban and suburban development throughout the City. This new development may result in changes to the skyline throughout the Planning Area, which may obstruct or interfere with views of visual features surrounding the Planning Area. Furthermore, buildout under the 2040 General Plan and implementation of the 2040 General Plan Land Use Map has the potential to result in new and expanded development along highway corridors with high scenic values, even though these corridors are not officially desig nated as State Scenic Highways. Additionally, expanded development could occur alongside roadways within the City of Lake Forest considered landscape corridors by the Orange County General Plan, which include El Toro Road and a portion of Santa Margarita Parkway. This is considered a potentially significant impact, which would be mitigated to a less than significant level through the implementation of the policies and actions in the 2040 General Plan.

Zoning and other regulations governing scenic quality ap plicable to the City of Lake Forest include the Lake Forest Citywide Design Guidelines, the El Toro Redevelopment Project Area Design Guidelines, the Light Industrial Design Guidelines. Policies in the 2040 General Plan are intended to complement and further the intent of these provisions regulating scenic quality and resources, and any development occurring under the 2040 General Plan would be subject to compliance with these guidelines, as well as the applicable regulations set forth in the Lake Forest Municipal Code. The 2040 General Plan would therefore not substantially degrade the existing visual character or quality of public views of the Sphere of Influence and its surroundings. Scenic quality-related impacts associated with the 2040 General Plan implementation would thus be less than significant
The primary sources of daytime glare are generally sunlight reflecting from structures and other reflective surfaces and windows. Implementation of the 2040 General Plan would introduce new Item: 11
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sources of daytime glare into previously developed areas of the Planning Area and increase the amount of daytime glare in existing urbanized areas. The primary sources of nighttime lighting are generally from exterior building lights, street lights, and vehicle headlights. Nighttime lighting impacts would be most severe in areas that do not currently experience high levels of nighttime lighting. Increased nighttime lighting can reduce visibility of the night sky, resulting in fewer stars being visible and generally detracting from the quality of life in Lake Forest. This is considered a potentially significant impact, which would be mitigated to a less than significant level through the implementation of the policies and actions in the 2040 General Plan.

However, potential development of vacant and underutilized sites to accommodate the City’s RHNA would be consistent with the adopted land use policy and would not result in any changes to existing land uses or allow for greater development than what was analyzed in the 2040 General Plan FEIR. Future housing development, consistent with the 2040 General Plan, would be reviewed for consistency with policies and programs aimed to reduce potential impacts to aesthetic resources and implement mitigation measures, as appropriate. The Housing Element policies and programs would not have an impact on existing 2040 General Plan policies protecting aesthetic and visual resources. The 2040 General Plan includes policies and programs to reduce potential impacts to scenic vista resources and to reduce impacts associated with light and glare as a result of new development.

The revisions to the Housing Element would not result in new aesthetic impacts beyond those identified in the 2040 General Plan FEIR. Following complian ce with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts to aesthetics as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no aesthetic impacts peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

II. AGRICULTURE AND FORESTRY RESOURCES
The 2040 General Plan FEIR determined that impacts to agriculture and forestry resources would be less than significant through the implementation of policies and actions in the 2040 General Plan.

There are approximately 140.3 acres of Important Farmlands located within the City, including

0.2 acres of Prime Farmland and 140.1 acres of Unique Farmland. The Prime Farmland area is currently developed with residential uses (Shea/Baker Ranch Project). The Unique Farmland is located in two nearby areas in the center of the City: one area west of Alton Parkway and south of State Route 241 (adjacent to the 0.2 acres of Prime Farmland), and one area east of Bake Parkway and south of Rancho Parkway. The Unique Farmland area west of Alton Parkway and south of State Route 241 is currently developed with residential uses (Shea/Baker Ranch Item: 11
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Project). The Unique Farmland area east of Bake Parkway and south of Rancho Parkway is known as the Nakase site, which is currently being developed with residential and public uses.

There are no lands within the Lake Forest Planning Area that are currently under a Williamson Act contract. As such, 2040 General Plan implementation would result in no impact to Williamson Act contracts.

There are 521.45 acres of land throughout the Planning Area that are zoned for agricultural use.

The City has one zoning district for agricultural uses: A1, Agriculture District. The A1 District is established to provide for agriculture, outdoor recreational uses, and those low intensity uses which have a pr edominately open space character. It is also intended that this district may be used as an interim zone in those areas which the 2040 General Plan may designate for more intensive urban uses in the future. The majority of the land zoned A1 is currently developed with urban uses or is currently designated for urban uses by both the existing and proposed Land Use Maps. There are some areas in Lake Forest zoned A1 that are not urbanized, but rather, are designated for Regional Park/Open Space uses on the Land Use Map. As previously described, all of the land within the Planning Area is planned for urban development in one form or another, with the exception of areas designated for Open Space or Regional Park/Open Space uses. It is assumed that the land within t he City zoned A1 and not designated for Open Space or Regional Park/Open Space uses will eventually be developed with urban land uses, consistent with the proposed Land Use Map. Given the purpose, intent, and flexibility of the established A1 Zoning District, the 2040 General Plan FEIR determined the proposed Land Use Map would not conflict with existing agricultural zoning in the City of Lake Forest.

There are no forest lands or timber lands located within the Lake Forest Planning Area. There are also no parcels that are currently zoned as forest land, timber, or timber production.

Therefore, implementation of the 2040 General Plan would have no impact on forest land, timber, or timber production.

The Project does not propose site -specific development, bu t is rather an update to a policy document to comply with new laws and reinforce existing policy direction. Potential development of vacant and underutilized sites to accommodate the City’s RHNA would be consistent with the adopted land use policy and would not result in any changes to existing land uses or affect any parcels under a Williamson Act contract. Future housing development, consistent with the 2040 General Plan, would be reviewed for consistency with policies and programs aimed to reduce potential impacts to agricultural and forestry resources and implement mitigation measures, as appropriate. The Housing Element policies and programs would not have an impact on existing 2040 General Plan policies protecting agricultural and forestry resources.

The revisions to the Housing Element would not result in new agricultural or forestry resource impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts to agriculture and forestry Item: 11
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resources as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to agriculture and forestry resources peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

III. AIR QUALITY
The 2040 General Plan FEIR determined that impacts to air quality would b e significant and unavoidable.

Future development in the City of Lake Forest that is consistent with the 2040 General Plan would increase vehicle trips and vehicle miles traveled (VMT) that would result in emissions of ozone precursors and particulate matt er. Individual projects under the 2040 General Plan would be required to undergo subsequent environmental review pursuant to CEQA, and would be required to demonstrate compliance with the A ir Quality Management Plan (AQMP). Individual projects would also be required to demonstrate compliance with the South Coast Air Quality Management District (SCAQMD) rules and regulations governing air quality. The City of Lake Forest continues to coordinate with the SCAQMD and the Southern California Association of Governments (SCAG) to ensure citywide growth projections, land use planning efforts, and local development patterns are accounted for in the regional planning and air quality planning processes. Therefore, the operation of the 2040 General Plan would not conflict with or obstruct the implementation of the applicable air quality plan and impacts are less than significant.

Construction of the growth anticipated by the 2040 General Plan has the potential to temporarily emit criteria air pollutant emissions, and construction-related daily emissions would exceed the SCAQMD significance thresholds for VOCs. Future operations associated with growth anticipated by the 2040 General Plan would generate criteria air pollutant emissions from project-generated vehicle trips traveling within the City, energy sources such as natural gas combustion, and area sources such as landscaping equipment and consumer products usage. The exact level of construction emissions from the development anticipated by the 2040 General Plan cannot be quantified without full detail of the development projects to be implemented and the extent to which mitigation can be applied. Individual projects anticipated by the 2040 General Plan will be required to implement their own environmental review. The proposed policies and actions of the 2040 General Plan would potentially reduce emissions, which could potentially address impacts related to conflicts with an applicable air quality plan. With respect to operational emissions, future development under the 2040 General Plan would be required to comply with AQMP, SIP, CARB, SCAQMD regulations, Title 24 energy efficiency standards, and the proposed project policies and actions. However, as there is no way to determine the effectiveness of such regulations, policies, and actions for individual projects, it is impossible to determine if potential impacts would be reduced to below regulatory thresholds. While implementation of the 2040 General Plan policies and actions would reduce criteria pollutant emissions, the extent to which the impacts would have to be determined on a project-by-project basis, as necessary. Therefore, the 2040 General Plan FEIR determined this impact would be significant and unavoidable.

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Criteria air pollutant emissions have the potenti al to result in health impacts on sensitive receptors located near new development within the 2040 General Plan Planning Area. With respect to local air quality emissions, toxic air contaminant emissions, and health impacts, future development under the 2040 General Plan would be required to comply with AQMP, SIP, CARB, SCAQMD regulations, Title 24 energy efficiency standards, and the 2040 General Plan policies and actions. Implementation of the 2040 General Plan policies and actions would mitigate and reduce such emissions. However, the exact location, type, nature, and size of future projects that may expose sensitive receptors to pollutant concentrations cannot be calculated at this time, as the details of potential future projects are not currently known . As such, there is no way to determine the extent to which these regulations will be, or need to be, implemented, and it is impossible to determine if potential impacts would be reduced to below regulatory thresholds.

Additionally, there are no feasible m itigation measures beyond the policies and actions.

Therefore, the 2040 General Plan FEIR determined localized operational impacts, construction and operational health and toxic air impacts would remain significant and unavoidable.

With respect to other em issions, future development under the 2040 General Plan would be required to comply with AQMP, SIP, CARB, SCAQMD regulations, Title 24 energy efficiency standards, and the 2040 General Plan policies and actions. Implementation of the 2040 General Plan policies and actions would mitigate and reduce such emissions. However, the exact location, type, nature, and size of future projects that may expose sensitive receptors to pollutant concentrations cannot be calculated at this time, as the details of potential future projects are not currently known. As such, there is no way to determine the extent to which these regulations will be, or need to be, implemented, and it is impossible to determine if potential impacts would be reduced to below regulatory thresholds. Additionally, there are no feasible mitigation measures beyond the policies and actions listed below. Therefore, the 2040 General Plan FEIR determined localized operational impacts, construction and operational health and toxic air impacts would remain significant and unavoidable.

Future housing development, consis tent with the 2040 General Plan, would be reviewed for consistency with policies and programs aimed to reduce impacts to air quality and implement mitigation measures, as appropriate. The Housing Element policies and programs would not have an impact on existing 2040 General Plan policies related to air quality.

The revisions to the Housing Element would not result in new air quality impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts to air quality as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as Item: 11
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such, there are no impacts to air quality peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

IV. BIOLOGICAL RESOURCES
The 2040 General Plan FEIR determined that impacts to biological resources would be less than significant through the implementation of policies and actions in the 2040 General Plan.

Implementation of the 2040 General Plan and Land Use Map would allow and facilitate future development in Lake Forest, which could result in adverse impacts to special- status plant and wildlife species, as well as sensitive natural habitat or wildlife movement corridors. While future development has the potential to result in significant impacts to protected special status plants and animals, including habitat, riparian habitat, wetlands and waters of the U.S. and wildlife movement corridors, the 2040 General Plan FEIR determined implementation of the policies and actions in the 2040 General Plan, as well as Federal and State regulations, would reduce impacts to these resources to a less than significant level.

The City of Lake Forest is a participant in the Orange County Central-Coastal Natural Community Conservation Plan/Habitat Conservation Plan (NCCP/HCP). The 2040 General Plan Land Use Map does not re-designate any land currently designated for open space or habitat protection. As such, the 2040 General Plan and the Land Use Map are consistent with the adopted HCP/NCCP in terms of land uses and habitat protection. Implementation of the 2040 General Plan would not conflict with the provisions of an adopted HCP/NCCP, or other approved local, regional, or State habitat conservation plan. Future projects that do not comply with the Orange County Central -Coastal NCCP/HCP could result in potentially significant impacts, which would be mitigated to a less than significant level through the implementation of 2040 General Plan Action RR-5b.

The 2040 General Plan includes policies and programs to reduc e potential impacts to biological resources and implement mitigation measures, as appropriate. Future housing development, consistent with the 2040 General Plan, would be reviewed for consistency with policies and programs aimed to reduce impacts to biolog ical resources and implement mitigation measures, as appropriate. The Housing Element policies and programs would not have an impact on existing 2040 General Plan policies protecting biological resources.

The revisions to the Housing Element would not result in new biological resource impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or signifi cantly different impacts to biological resources as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 Item: 11
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General Plan, and as such, there are no impacts to biological resources peculiar to the Housin g Element that have not been fully addressed in the 2040 General Plan EIR.

V. CULTURAL RESOURCES
The 2040 General Plan FEIR determined that impacts to cultural and tribal cultural resources would be less than significant through the implementation of polic ies and actions in the 2040 General Plan.

While the 2040 General Plan does not directly propose any adverse changes to any historic or archaeological resources, future development allowed under the 2040 General Plan could affect known historical and archae ological resources or unknown historical and archaeological resources which have not yet been identified. As future development and infrastructure projects are considered by the City, each project will be evaluated for conformance with the City’s 2040 General Plan , Municipal Code, and other applicable State and local regulations. Subsequent development and infrastructure projects would also be analyzed for potential environmental impacts, consistent with the requirements of CEQA. The 2040 General Plan includes policies and actions that would reduce impacts to cultural, historic, and archaeological resources, as well as policies and actions for the conservation of cultural, historic, and archaeological resources, which would ensure that adverse effects on sig nificant historic and archaeological resources are reduced to a less than significant level.

Excavation and construction activities allowed under the 2040 General Plan may yield human remains that may not be marked in formal burials. Future projects may disturb or destroy buried Native American human remains, including those interred outside of formal cemeteries. As future development and infrastructure projects are considered by the City, each project will be evaluated for conformance with the City’s 2040 General Plan , Municipal Code, and other applicable State and local regulations. Subsequent development and infrastructure projects would also be analyzed for potential environmental impacts, consistent with the requirements of CEQA. Implementation of the policies and actions in the 2040 General Plan ensures that potential adverse impacts to human remains would be less than significant.

The Housing Element Update proposes housing policies that would encourage housing production within the Planning Area . However, potential development of vacant and underutilized sites to accommodate the City’s RHNA would be consistent with the adopted land use policy and would not result in any changes to existing land uses or allow for greater development than what was analyzed in the 2040 General Plan FEIR. The 2040 General Plan includes policies and programs to reduce potential impacts to historic and archeological resources and human remains, including Native American artifacts. Future housing development, consistent with the 2040 General Plan, would be reviewed for consistency with policies and programs aimed to reduce potential impacts to cultural resources and implement mitigation measures, as appropriate. The Housing Element policies and programs would not have an impact on existing 2040 General Plan policies protecting cultural resources.

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The revisions to the Housing Element would not result in new cultural resource impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recomme nded 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts to cultural resources as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to cultural resources peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

VI. ENERGY
The 2040 General Plan FEIR determined that impact s to energy would be less than significant through the implementation of policies and actions in the 2040 General Plan. This topical area is addressed in the 2040 General Plan FEIR’s Greenhouse Gas Emissions and Energy section.

Buildout of the 2040 General Plan would use energy resources for the operation of buildings (electricity and natural gas), for on-road vehicle trips (e.g. gasoline and diesel fuel), and from off- road construction activities (e.g. diesel fuel) associated wi th buildout of the 2040 General Plan.

Developers of individual projects within the Planning Area would be responsible for conserving energy, to the extent feasible, and would rely heavily on reducing per capita energy consumption to achieve this goal, incl uding through Statewide and local measures. Buildout of the 2040 General Plan would be in compliance with all applicable federal, state, and local regulations regulating energy usage. As a result, the 2040 General Plan would not result in any significant adverse impacts related to project energy requirements, energy use inefficiencies, and/or the energy intensiveness of materials by amount and fuel type for during 2040 General Plan buildout, including during construction, operations, maintenance, and/or removal. The City of Lake Forest would comply with all existing energy standards, and would not result in significant adverse impacts on energy resources. Buildout of the 2040 General Plan would not be expected cause an inefficient, wasteful, or unnecessary use of energy resources nor conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

The Housing Element Update proposes housing policies that would encourage housing production within the Planning Area . However, potential development of vacant and underutilized sites to accommodate the City’s RHNA would be consistent with the adopted land use policy and would not result in any changes to existing land uses or allow for greater development than what was analyzed in the 2040 General Plan FEIR. The 2040 General Plan includes policies and programs to reduce potential impacts to energy resources. Future housing development, consistent with the 2040 General Plan, would be reviewed for consistency with policies and programs aimed to reduce potential impacts to energy resources. The Housing Element policies and programs would not have an impact on existing 2040 General Plan policies addressing energy resources.

The revisions to the Housing Element would not result in new energy resource impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no Item: 11
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new significant or significantly different impacts to energy resources as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to energy resources peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

VII. GEOLOGY AND SOILS
The 2040 General Plan FEIR determined that impacts to geology and soils would be less than significant through the implementation of policies and actions in the 2040 General Plan.

There are no known active or potentially active faults, or Alquist-Priolo Earthquake Fault Zones, located within the Planning Area. However, there are numerous faults located in the region. As a result, future development in the City of Lake Forest may expose people or structures to potential adverse effects associated with a seismic event, including strong ground shaking and seismic- related ground failure. As future development and infrastructure projects are considered by the City, each project will be evaluated for conformance with the California Building Standards Commission (CBSC), 2040 General Plan , Zoning Ordinance, and other regulations. Subsequent development and infrastructure wou ld also be analyzed for potential environmental impacts, consistent with the requirements of CEQA. In addition to the requirements associated with the CBSC and the Municipal Code, the 2040 General Plan includes policies and actions to address potential impacts associated with seismic activity. With the implementation of the policies and actions in the 2040 General Plan , as well as applicable State and City codes, potential impacts associated with a seismic event, including rupture of an earthquake fault, seismic ground shaking, liquefaction, and landslides would be less than significant.

The 2040 General Plan would allow development and improvement projects that would involve some land clearing, mass grading, and other ground-disturbing activities that could temporarily increase soil erosion rates during and shortly after project construction. Construction -related erosion could result in the loss of a substantial amount of nonrenewable topsoil and could adversely affect water quality in nearby surface waters. As future development and infrastructure projects are considered by the City, each project will be evaluated for conformance with the CBSC, 2040 General Plan , Zoning Ordinance, and other regulations. In addition to compliance with City standards and polic ies, the Regional Water Quality Control Board will require a project specific Storm Water Pollution Prevention Plan (SWPPP) to be prepared for each project that disturbs an area of one acre or larger. The 2040 General Plan includes a range of policies and one action related to best management practices, National Pollutant Discharge Elimination System ( NPDES) requirements, and minimizing discharge of materials (including eroded soils) into the storm drain system. With the implementation of the policies and actions in the 2040 General Plan , as well as applicable State and City requirements, potential impacts associated with erosion and loss of topsoil would be less than significant Development allowed under the 2040 General Plan could result in the exposure of people and structures to conditions that have the potential for adverse effects associated with ground instability or failure. Soils and geologic conditions in the Lake Forest Planning Area have the Item: 11
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potential for landslides, lateral spreading, subsidence, liquefaction, or collapse. As future development and infrastructure projects are considered by the City of Lake Forest, each project will be evaluated for conformance with the CBSC, the 2040 General Plan, Zoning Ordinance, and other regulations. Subsequent development and infrastructure projects would also be analyzed for potential environmental impacts, consistent with the requirements of CEQA. Future development and improvement projects would be required to have a specific geotechnical study prepared and incorporated into the improvement design, consistent with the requirements of the State and City codes. In addition to the requirements associated with the CBSC and the Municipal Code, the 2040 General Plan includes policies and actions to ensure that dev elopment projects address potential geologic hazards, at-risk buildings and infrastructure is evaluated for potential risks, and site -specific studies are completed for area subject to liquefaction. With the implementation of the policies and actions in th e 2040 General Plan, as well as applicable State and City codes, potential impacts associated with ground instability or failure would be less than significant.

The majority of the City of Lake Forest has low potential for expansive soils, including most of the developed land. The areas with moderate to high expansive soils represent only a small portion of the City of Lake Forest, and would require special design considerations due to shrink -swell potentials. As future development and infrastructure projects are considered by the City, each project will be evaluated for conformance with the CBSC, 2040 General Plan , Zoning Ordinance, and other applicable regulations. Subsequent development and infrastructure pro jects would also be analyzed for potential environmental impacts, consistent with the requirements of CEQA.

Consistency with the 2040 General Plan policies will require identification of geologic hazards and risk inventory of existing at -risk buildings and infrastructure. Design criteria and specifications set forth in the design -level geotechnical investigation will ensure impacts from problematic soils are minimized. There are no additional significant adverse environmental impacts that are anticipated to occur associated with expansive soils. Therefore, this impact is considered less than significant.

There will be no septic tanks or alternative waste water disposal systems utilized for new development planned under the 2040 General Plan . Therefore, 2040 General Plan implementation does not have the potential to have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water; this impact is considered less than significant.

It is possible that undiscovered paleontological resources could be encountered during ground - disturbing activities. This is considered a potentially significant impact, which would be mitigated to a less than significant level through the implementation of the policies and actions in the 2040 General Plan.

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Area. However, potential development of vacant and underutilized sites to accommodate the City’s RHNA would be consistent with the adopted land use p olicy and would not result in any changes to existing land uses or allow for greater development than what was analyzed in the 2040 General Plan FEIR. The 2040 General Plan includes policies and programs to reduce potential impacts associated with geology and soils. Future housing development, consistent with the 2040 General Plan, would be reviewed for consistency with policies and programs aimed to reduce potential impacts associated with geology and soils, including preparation of site - specific geotechnical analysis and required compliance with the Lake Forest Municipal Code. The Housing Element policies and programs would not have an impact on existing 2040 General Plan policies regarding geology and soils.

The revisions to the Housing Element would not result in new impacts to geology and soils beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts to geology and soils as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to geology and soils peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

VIII. GREENHOUSE GAS EMISSIONS
The 2040 General Plan FEIR determined that impacts to greenhouse gas (GHG) emissions would be less than significant through the implementation of polici es and actions in the 2040 General Plan.

The City has developed the 2040 General Plan to achieve local per capita GHG emissions levels that would be consistent with the statewide reduction targets established by Assembly Bill (AB) 32, Senate Bill (SB) 32 and the CARB’s 2017 Scoping Plan. The 2040 General Plan’s approach to GHG reductions is consistent with the framework established by ICLEI – Local Governments for Sustainability, through the “Five Milestones Framework,” which offers a systematic approach for analyzing baseline GHG emissions, developing an emissions reduction target, developing and implementing a climate action plan, and monitoring emissions reduction progress. Upon adoption of the 2040 General Plan, and implem entation of the policies and actions, the City of Lake Forest would not exceed the per capita GHG emission targets established to ensure compliance with SB 32 and other California legislation for future year 2030 and 2040 General Plan buildout year 2040. T herefore, the 2040 General Plan would not generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment.

There is a less than significant impact following adoption and implementation of the policies and actions in the 2040 General Plan.

As future development projects are received and reviewed by the City in subsequent years, those projects will be reviewed for consistency with the 2040 General Plan and all relevant State-level programs and requirements. All future projects must implement the most current version of the Title 24 energy efficiency requirements, as required by State law. Consistency with the 2040 Item: 11
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General Plan and other mandatory State -level programs would ensure that future project -level contributions to global climate change would be less than significant.

The 2040 General Plan would be consistent with the CARB’s 2017 Scoping Plan, and thus all current statewide GHG reduction laws (i.e. AB 32 and SB 32) relevant to the 2040 General Plan that have been adopted to reduce GHG emissions. The 2040 General Plan would reduce emissions to below the per capita thresholds through buildout of the 2040 General Plan (i.e. for years 2030 and 2040), which ensures that the 2040 General Plan is consistent with all GHG reduction targets established for the state. Therefore, the 2040 General Plan would not conflict with the State of California’s GHG reduction goals and targets. The 2040 General Plan would not conflict with an applicable plan, policy, or regu lation adopted for the purpose of reducing the emissions of greenhouse gases and impacts would be less than significant.

The revisions to the Housing Element wo uld not result in new GHG emission impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or sign ificantly different impacts to GHG emissions as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to GHG emissions peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

IX. HAZARDS AND HAZARDOUS MATERIALS
The 2040 General Plan FEIR determined that impacts to hazards and hazardous materials would be significant and unavoidable through the implementation of policies and actions in the 2040 General Plan.

Future development, infrastructure, and other projects allowed under the 2040 General Plan may involve the transportation, use, and/or disposal of hazardous materials. Accidental release of hazardous materials that are used in the construction or operation of a project may occur. There is also the potential for accidental release of pre -existing hazardous materials, associated with previous activities on a site. All future projects allowed under the 2040 General Plan would be required to comply with the provisions of Federal, State, and local requirements related to hazardous materials. As future development and infrastructure projects are considered by the City, each project would be evaluated for potential impacts, specific to the project, associated with hazardous materials as required under CEQA. In addition, the 2040 General Plan includes policies and actions to address potential impacts associated with hazardous mate rials among other Item: 11
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issues. These policies and actions in the 2040 General Plan would ensure that potential hazards are identified on a project site, that development is located in areas where potential exposure to hazards and hazardous materials can be miti gated to an acceptable level, and that business operations comply with Federal and State regulations regarding the use, transport, storage, and disposal of hazardous materials. The 2040 General Plan also includes policies and actions to ensure that the Cit y has adequate emergency response plans and measures to respond in the event of an accidental release of a hazardous substance. Therefore, implementation of the 2040 General Plan policies and actions, as well as Federal and State regulations, would ensure that potential impacts associated with the routine use, transport, storage, or disposal or accidental release of hazardous materials would be reduced to a less than significant level.

The 2040 General Plan is not anticipated to directly lead to the establishment of new businesses that would emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste because the 2040 General Plan does not approve any specific development project. However, given the unknown nature of future business establishments within the commercial and industrial use areas, the potential for hazardous materials is present .

Nevertheless, all hazardous materials would be required to be handled in accordance with Federal, State, and County requirements, which would limit the potential for a project to expose nearby uses, including schools, to hazardous emissions or an accidental release. Hazardous emissions are monitored by the SCAQMD, R egional Water Quality Control Board (RWQCB) , Department Toxic Substances Control (DTSC) and the local Certified Unified Program Agenc y (CUPA). In the event of a hazardous materials spill or release, notification and cleanup operations would be performed in compliance with applicable Federal, State, and local regulations and policies, including hazard mitigation plans. As part of the development review process, the City’s 2040 General Plan also requires projects that may result in significant risks associated with hazardous materials to include measures to address and reduce the risks to an acceptable level such that surrounding uses are not exposed to hazardous materials in excess of adopted state and federal standards, and also requires the submittal of information regarding hazardous materials manufacturing, storage, use, transport, and/or disposal by existing and proposed businesses and developments to the Orange County Fire Authority. Compliance with all existing regulations as well as 2040 General Plan policies and actions related to land use compatibility and hazardous materials would ensure that the impact is less than significant.

There are no hazardous materials release sites compiled pursuant to Government Code Section 65962.5 located in the 2040 General Plan Planning Area. There are: three locations with a Lake Forest address that are listed in the Envirostor database; 52 locations within Lake Forest (i.e. with a Lake Forest address) that are listed in the GeoTracker database; and two solid waste facilities listed in the SWIS database. These sites are subject to various Federal and State laws and regulatory agencies, including the CERCLA, EPA, DTSC, and RWQCB. Development allowed by the 2040 General Plan could create a hazard to the public or the environment through a disturbance or release of contaminated materials if the development occurs on or adjacent to contaminated sites without app ropriate measures to contain or mitigate the existing contamination. Federal and State regulations ensure that existing hazards, including those associated with known Item: 11
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hazardous materials sites, are addressed prior to development. Additionally, before accepting as complete an application for any development project, the Local Guidelines for Implementing the California Environmental Quality Act Section states that the City shall consult lists compiled by the Secretary for Environmental Protection of the California EPA pursuant to Government Code Section 65962.5 listing hazardous waste sites and other specified sites located in the City’s boundaries. When acting as Lead Agency, the City shall notify an applicant for a development project if the project site is located on such a list and not already identified. The 2040 General Plan includes policies that are intended to ensure cleanup sites are identified, reviewed, and if needed, remediated, to prevent inappropriate release of hazardous materials. Additionally, compliance with Federal and State regulations and review requirements included in the City’s “Local Guidelines for Implementing the California Environmental Quality Act” would ensure that potential impacts associated with the hazardous conditions on sites listed pursuant to Government Code Section 65962.5 would be less than significant.

There are no airport facilities located within the 2040 General Plan Planning Area. The nearest airport facility within the vicinity of the Planning Area is the John Wayne Airport (SNA): SNA is located to the west of the City, in the City of Santa Ana, in the northern part of Orange County.

Lake Forest does not lie within the Runway Protection Zone, Inner/Outer Safety Zones, Inner Turning Zone, Sideline Safety Zone, or Traffic Pattern Zone for this airport. None of the Planning Area lies within the land use compatibility zones for nearby airports. In relation to airplane noise 2040 General Plan Policy PS-6.10 states that the City will maintain communication with John Wayne Airport and other relevant air transportation agencies to ensure that all future plans have limited impacts to the community of Lake Forest. However, the 2040 General Plan does not include any policies or actions that would impact air hazards or safety. Impl ementation of the 2040 General Plan would have a less than significant impact with regard to this issue.

The 2040 General Plan would allow a variety of new development, including residential, commercial, industrial, and public projects, which would result in increased jobs and population in Lake Forest. Future development and infrastructure projects are not anticipated to remove or impede any established evacuation routes within the City. Furthermore, the 2040 General Plan does not include land uses, polici es, or other components that conflict with adopted emergency response or evacuation plans. However, given that the type, location, and size of future development and infrastructure projects is not known at this time, there is the potential that the City could receive a development proposal that could potentially interfere with an established emergency evacuation route or plan. The 2040 General Plan ensures that the City’s emergency access routes, emergency contact lists, and public information regarding designated facilities and routes are regularly reviewed to ensure that up to date information is available to the City and the public in the event of an emergency. Important new critical facilities would be located to ensure resiliency in the event of a natur al disaster. Implementation of the 2040 General Plan policies and actions listed below would reduce this potential impact to a less than significant level.

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Wildfires are a potential hazard to development and land uses located in the foothill and forested areas of the city. Local Responsibility Areas (LRA) are concentrated in the incorporated areas of Lake Forest. The eastern portions of the city are categorized as a "Very High" Fire Hazard Severity Zone (FHSZ) by CalFire. State Responsibility Areas just out side the Planning Area are found to the east in the hilly terrain of the Foothills. Specifically, this includes the areas that are outside the city limits. The hilly terrain in this State Responsibility Area is categorized as a "High" FHSZ.

Development under the 2040 General Plan would allow development to place people and/or structures in currently developed areas that are identified as having a significant risk of wildland fires. All future projects allowed under the 2040 General Plan would be required to comply with the provisions of Federal, State, and local requirements related to wildland fire hazards, including State fire safety regulations associated with wildland -urban interfaces, fire -safe building standards, and defensible space requirements. As future development and infrastructure projects are considered by the City, each project would be evaluated for potential impacts, specific to the project, associated with wildland fire hazards as required under CEQA. However, even with the policies regulati ons and standards, given that existing and limited future development in Lake Forest would be allowed in areas identified as having a very high risk of wildfire, there will always be a risk of loss of life and property as a result of wildland fires within populated areas of the City. Therefore, impacts related to this topic would remain significant and unavoidable. Implementation of the 2040 General Plan policies and actions, combined with local and state requirements discussed previously, would ensure that potential wildland fire hazards to people and structures is mitigated to the greatest extent feasible. However, the City cannot state with certainty that this impact would be reduced to a less than significant level. There is no additional feasible mitiga tion available that would reduce this potential impact to a less than significant level.

The revisions to the Housing Element would not result in new hazards and hazardous materials impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts related to hazards and hazardous materials as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to hazards and hazardous materials peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

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X. HYDROLOGY AND WATER QUALITY
The 2040 General Plan FEIR determined that impacts to hydrology and water quality would be less than significant through the implementation of policies and actions in the 2040 General Plan.

Grading, excavation, removal of ve getation cover, and loading activities associated with future construction activities could temporarily increase runoff, erosion, and sedimentation.

Construction activities also could result in soil compaction and wind erosion impacts that could adversely affect soils and reduce the revegetation potential at construction sites and staging areas. The 2040 General Plan sets policies and actions for build -out of the City, but it does not envision or authorize any specific development project. Because of this, the site -specific details of potential future development projects are currently unknown and analysis of potential impacts of such projects is not feasible and would be speculative. However, each future project must include detailed project specific drainage plans that control storm water runoff and erosion, both during and after construction. The RWQCB will require a project specific SWPPP to be prepared for each future project that disturbs an area one acre or larger. The SWPPPs will include project specific best management measures that are designed to control drainage and erosion.

Due to future development and infrastructure projects, t he overall volume of runoff in Lake Forest could be increased compared to existing conditions. Future increases in impe rvious surfaces would result in increased urban runoff , pollutants, and first flush roadway contaminants, as well as an increase in nutrients and other chemicals from landscaped areas.

Additionally, if the City’s drainage system is not adequately designed, 2040 General Plan buildout could result in localized higher peak flow rates.

The City manages local storm drain facilities and the Orange County Flood Control District (OCFCD) is responsible for regional flood control planning within the County. Provisio n of stormwater detention facilities as needed would reduce runoff rates and peak flows. The implementation of the 2040 General Plan includes policies aimed to enhance stormwater quality and infiltration as well as actions to review development projects to identify potential stormwater and drainage impacts and require development to include measures to ensure off - site runoff is not increased beyond pre -development levels. Existing regulatory requirements that manage water quality include requirements to obtain approval from the RWQCB for NPDES permits, other discharge permits, WQMP s, SWPPPs, and to implement B est Management Practices. These regulatory requirements are intended to ensure that water quality does not degrade to levels that would violate water quality standards. Through implementation of the 2040 General Plan policies and actions, implementation of the Lake Forest Municipal Code requirements, compliance with mandatory Federal and State regulations, and compliance with the existing regulations for the San Diego Creek and Aliso Creek Watersheds would ensure that impacts to drainage patterns and water quality would be mitigated to a less than significant level.

The City of Lake Forest is underlain by the Orange County Groundwater Basin. The City of Lake Forest does not directly provide water service to its residents. Rather, three separate, independent utility districts provide this service to residents within the City. The majority of the Item: 11
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City of Lake Forest’s residents are provided water, wastewater collection, and wastewater treatment services by the Irvine Ranch Water District (IRWD). R esidents located along the southwest edge of the City are provided these utility services by El Toro Water District (ETWD).

Finally, a small portion of residents in the northeastern section of the City are serviced by Trabuco Canyon Water District (TCWD). IRWD is projected to have significantly more supply than demand in 2035 (the furthest projected year). ETWD’s projected 2035 supply is equal to the demand.

Subsequent development projects under the 2040 General Plan, such as residential, commercial, industrial, and roadway projects would result in new impervious surfaces and co uld reduce rainwater infiltration and groundwater recharge. However, the majority of the developable areas within the city are currently developed with urban uses. The majority of open undeveloped lands within the city are designated for parks and open space uses. The 2040 General Plan Land Use Map does not re -designate any areas currently designated for open spaces uses to urban uses.

Given that implementation and future buildout of the 2040 General Plan would not appreciably add to the volume of imperious surfaces in Lake Forest, when compared to the overall size of the regional groundwater basin recharge area, and that there are adequate water supplies (including groundwater) to serve the projected buildout demand of the 2040 General Plan , this potential impact would be less than significant. Additionally, the 2040 General Plan includes policies that support water conservation, the use of permeable surfaces and the use of recycled water for non- potable uses and coordination with local water districts when planning for adequate capacity to accommodate future growth. The 2040 General Plan and development codes are consistent with the Groundwater Management Plan. Implementation of the following 2040 General Plan policies, combined with allocation standard for water producers set by the OCWD Groundwater Management Plan Basin Production Percentage (BPP), would further ensure that the 2040 General Plan would have a less than significant impact. 2040 General Plan implementation has the potential to impact the Plan ning Area’s storm drainage system. The potential impacts would be primarily derived from development in what are now underdeveloped and/or underutilized areas. The 2040 General Plan sets policies and actions for build-out of the City, but it does not envision or authorize any specific development project. Because of this, the site -specific details of potential future development projects are currently unknown and analysis of potentia l impacts of such projects is not feasible and would be speculative. F uture project applicant s would be required to obtain permits from the Army Corps of Engineers and the Department of Fish and Wildlife if any work is performed within a waterway. Each future development project must also include detailed project specific floodplain and drainage studies that assess the drainage characteristics and flood risks so that an appropriate storm drainage plan can be prepared to control storm water runoff, both during and after construction. The drainage plan will ultimately include project specific best management measures that are designed to allow for natural recharge and infiltration of stormwater.

Construction of storm drainage improvements would occur as part of an overall development or infrastructure project, and is considered in the environmental impacts associated with project construction and implementation as addressed throughout this EIR. Through implementation of Item: 11
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the 2040 General Plan policies and actions, implementation of the Lake Forest Municipal Code requirements, compliance with mandatory Federal and State regulations, and compliance with the existing regulations for the San Diego Creek and Aliso Creek Watersheds would ensure that impacts related to increased flooding or water quality impacts associated with increased runoff would be mitigated to a less than significant level.

The Planning Area is subject to limited flooding problems along the natural creeks , drainages, and lakes in the Planning Area. Only a small area within Lake Forest is located within a mapped portion of either the 100-year or 500- year FEMA flood zones. The 2040 General Plan would allow development and improvement projects that would involve some land clearing, grading, and other ground-disturbing activities that could temporarily increase soil erosion rates during and shortly after project construction. As required by the Clean Water Act, each subsequent development project or improvement project will require an approved SWPPP that includes best management practices for grading and preservation of topsoil. In addition to complying with the NPDES programs and WQMP stormwater requirements, the 2040 General Plan contains policies to reduce impacts associated with stormwater and drai nage including policies to maintain sufficient levels of storm drainage service, improvements to flood control facilities and channel segments, and other best practices in order to protect the community from flood hazards and minimize the discharge of mate rials into the storm drain system that are toxic. The implementation of the 2040 General Plan would result in a less than significant impact There are no dam inundation areas in the City of Lake Forest. As such, the City is not at significant risk from a dam failure. In addition, limited isolated damage to adjacent and down -slope structures has been observed from seiches occurring in swimming po ols and in small shallow lakes and ponds. Man -made lakes within the Planning Area are shallow with limited surface areas, and would not generate devastating seiches. The City of Lake Forest is not within a tsunami hazard area and would not be subject to s ubstantial impacts from seiche events. This is a less than significant impact.

The Project does not propose site -specific development, but is rather an update to a policy document to comply with new laws and reinforce existing policy direction. The Housing Element Update proposes housing policies that would encourage housing production within the Planning Area. However, potential development of vacant and underutilized sites to accommodate the City’s RHNA would be consistent with the adopted land use policy and would not result in any changes to existing land uses or allow for greater development than what was analyzed in the 2040 General Plan FEIR. Future housing development, consistent with the 2040 General Plan, would be reviewed for consistency with policies and programs aimed to reduce potential impacts associated with hydrology and drainage. The 2040 General Plan includes policies and programs to reduce potential impacts to hydrology and water quality , increase water supply, decrease pollutants, and increase groundwater quality to reduce potential impacts.

The revisions to the Housing Element would not result in new hydrology and water quality impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the Item: 11
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recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts related to hydrology and water as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to hydrology and water quality peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

XI. LAND USE AND PLANNING
The 2040 General Plan FEIR determined that impacts to land use and planning would be less than significant through the implementation of policies and actions in the 2040 General Plan.

The 2040 General Plan establishes the City’s vision for future growth and development. New development and redevelopment projects would be designed to complement the character of the existing community and neighborhoods and provide connectivity between existing development and new development. The 2040 General Plan does not include any new areas designated for urbanization or new roadways, infrastructure, or other features that would divide existing communities. The refore, the 2040 General Plan would have a less than significant impact associated with the physical division of an established community.

The 2040 General Plan would not remove or conflict with City plans, policies, or regulations adopted for environmental protection. The 2040 General Plan would require modifications to the City’s Zoning Ordinance to provide consistency between th e 2040 General Plan and zoning; however, these modifications will not remove or adversely modify portions of the Lake Forest Municipal Code that were adopted to mitigate an environmental effect. Subsequent development and infrastructure projects would be r equired to be consistent with all applicable policies, standards, and regulations, including those land use plans, policies, and regulations adopted to mitigate environmental effects by the City as well as those adopted by agencies with jurisdiction over c omponents of future development projects. Any potential environmental impact associated with conflicts with land use requirements would be less than significant.

Future housing development, consistent with the 2040 General Plan, would be reviewed for consistency with land use policies and programs. The 2040 General Plan includes policies and programs to reduce potential impacts resulting from new development and intensification of land uses.

The revisions to the Housing Element would not result in new land use and planning impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts to land use and planning as a Item: 11
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result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to land use and planning peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

XII. MINERAL RESOURCES
The 2040 General Plan FEIR determined that impacts to mineral resources would be less than significant through the implementation of policies and actions in the 2040 General Plan.

Within the 2040 General Plan Planning Area, mineral resources include sand and gravel. The 62- acre area designated as MRZ-2 is currently developed with residential uses, a baseball field, and a storm drain basin. Given that the only known MRZ in Lake Forest has already been mined and then subsequently developed, there is no additional potential for resource extraction from this MRZ. There are no other known mineral deposits or resources within Lake Forest that are of significant value to the region or the state. As such, implementation of the 2040 General Plan would have a less than significant impact.

The Planning Area does not contain a locally-important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan. The proposed project would not result in loss of a mineral resource. Therefore, this impact is considered less than significant.

The revisions to the Housing Element would not result in new mineral resources impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts to mineral resources as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to mineral resources peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

XIII. NOISE
The 2040 General Plan FEIR determined that impacts to noise would be less than significant through the implementation of policies and actions in the 2040 General Plan.

Buildout of the 2040 General Plan would not result to an exceedance of the City’s transportation noise standards and/or result in significant incre ases in traffic noise levels at existing sensitive receptors; this is a less than significant impact.

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Future development located along railroad lines could be exposed to unacceptable exterior noise levels. However, implementation of the 2040 General Plan policies and actions would ensure that development allowed under the 2040 General Plan is not exposed to noise levels associated with railroad operations in excess of the City’s established standards. This is a less than significant impact.

Implementation of the 2040 General Plan could result in the future development of land uses that generate noise levels in excess of applicable City noise standards for non -transportation noise sources. While the 2040 General Plan does not specifically propose any new nois e generating uses, the Land Use Map includes industrial land use designations, which may result in new noise sources. Specific land uses that would be located in the City are not known at this time. The 2040 General Plan includes policies and actions that are intended to reduce noise associated with stationary sources. Implementation of the proposed policies and actions of the 2040 General Plan will reduce noise impacts from stationary noise sources to a less than significant level.

New development, maintenance of roadways, and installation of public utilities and infrastructure generally require construction activities. The 2040 General Plan includes policies and actions that are intended to reduce noise associated with construction noise. Implementation of the proposed policies and actions of the 2040 General Plan will reduce noise impacts from construction noise to a less than significant level.

Construction activities facilitated by the 2040 General Plan may include demolition of exist ing structures, site preparation work, excavation of below grade levels, foundation work, pile driving, and new building erection, and may potentially generate substantial vibration in the immediate vicinity. 2040 General Plan Action PS-6e would ensure administrative controls such as notifying neighbors of scheduled construction activities and scheduling construction activities with the highest potential to produce perceptible vibration to hours with the least potential to affect nearby businesses, in order to ensure that perceptible vibration can be kept to a minimum, and as such would not result in a significant impact with respect to perception.

Development facilitated by the 2040 General Plan could expose persons to excessive groundborne vibration levels attributable to trains. The 2040 General Plan includes Action PS - 6f requires that individual development projects undergo project-specific environmental review and address potential vibration impacts associated with railroad operations. If project -level significant vibration impacts are identified, specific mitigation measures will be required under CEQA. The implementation of this policy would limit potential groundborne vibrations associated with railroad operations to a less than significant level.

The City of Lake Forest is not located within any adopted airport land use plan, there are no private airstrips in the vicinity of the City, and there are no public airports located within two miles of the City. As such, there are no impacts related to pri vate airports, public airports, airstrips, or adopted airport land use plans.

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Cumulative conditions would not contribute to an exceedance of the City’s transportation noise standards and would not result in significant increases in traffic noise levels at existing sensitive receptors. Therefore, the 2040 General Plan would have a less than cumulatively considerable impact relative to traffic noise.

The Project does not propose site -specific development, but is rather an update to a policy document to comply with new laws and reinforce existing policy direction. The Housing Element Update proposes housing policies that would encourage housing production within the Planning Area. However, potential development of vacant and underutilized sites to accommodate the City’s RHNA would be consistent with the adopted land use policy and would not result in any changes to existing land uses or allow for greater development than what was analyzed in the 2040 General Plan FEIR. Future housing development, consistent with the 2040 General Plan, would be reviewed for consistency with policies and programs aimed to reduce potential impacts associated with noise. The 2040 General Plan includes policies and programs to reduce potential impacts to ambient noise levels as a result of groundborne vibration or exposure to excessive noise levels.

The revisions to the Housing Element would not result in noise impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts related to noise as a r esult of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to noise peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

XIV. POPULATION AND HOUSING
The 2040 General Plan FEIR determined that impacts to population and housing would be less than significant through the implementation of policies and actions in the 2040 General Plan. This topical area is addressed in the 2040 General Plan FEIR’s Land Use Planning and Population/Housing section.

The 2040 General Plan accommodates future growth in Lake Forest that may increase the city’s population by approximately 70,574 residents and 14,202 employees compared to the existing condition. With implementation of 2040 General Plan policies and actions intended to guide growth to appropriate areas and provide services necessary to accommodate growth, the land uses allowed under the 2040 General Plan, the infrast ructure anticipated to accommodate proposed land uses, and the goal and policy framework would not induce growth that would exceed adopted thresholds, beyond those disclosed and analyzed throughout the 2040 General Plan EIR. Therefore, population and housing growth associated with the 2040 General Plan would result a less than significant impact, as there are no additional potential environmental impacts that would result from growth accommodated by the 2040 General Plan.

The majority of developed land in the Planning Area is comprised of residential uses, which are not anticipated to undergo significant land use changes under the Proposed Project. The Item: 11
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Proposed Project focuses infill development opportunities in vacant and underutilized areas in Lake Forest, as well as areas currently developed with commercial uses which may transition to mixed uses in the future. The 2040 General Plan Land Use Map was developed to preserve existing neighborhoods throughout the City. Throughout the Planning Area, the Proposed Project is projected to increase the overall number of dwelling units and provide housing to serve the diverse needs of the community at various socioeconomic levels. Therefore, impacts of the 2040 General Plan on the displacement of people or housing are considered less than significant.

The revisions to the Housing Element would not result in housing and population impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts related to population and housing as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to population and housing peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

XV. PUBLIC SERVICES
The 2040 General Plan FEIR determined that impacts to public services would be less than significant through the implementation of policies and actions in the 2040 General Plan.

Development accommodated under the 2040 General Plan would result in additional residents and businesses in the City, including new residential, industrial, office, and commercial uses.

Development and growth facilitated by the 2040 General Plan would result in increased demand for public services, including fire protection, law enforcement, schools, parks, libraries, and other public and governmental services. The 2040 General Plan includes policies and actions to ensure that public services are provided a t acceptable levels and that the City will m aintain and implement public facility master plans, in collaboration with appropriate outside service providers and other agencies, to ensure compliance with appropriate regional, state, and federal laws and to provide efficient public facilities and services to Lake Forest.

The 2040 General Plan does not propose or approve actual development projects, or the physical expansion of public facilities. As future development and infrastructure projects (including new governmental facilities) are considered by the City, each project will be evaluated for conformance with the 2040 General Plan, Municipal Code, and other applicable regulations. Such development and infrastructure projects would also be analyzed for potent ial environmental Item: 11
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impacts, consistent with the requirements of CEQA. Any future expansion of public facilities required by growth in the City would be required to be reviewed for site -specific impacts. The 2040 General Plan includes a range of policies and actions to ensure that public services are provided in a timely fashion, are adequately funded, are coordinated between the City and appropriate service agency, and that new development funds its fair share of services. The specific impacts of providing n ew and expanded facilities cannot be determined at this time, as the 2040 General Plan does not propose or authorize development nor does it designate specific sites for new or expanded public facilities. However, the facilities would be primarily provided on sites with land use designations that allow such uses and the environmental impacts of constructing and operating the governmental facilities would likely be similar to those associated with new development, redevelopment, and infrastructure projects under the 2040 General Plan.

Therefore, impacts related to the provisions and need for public facilities are less than significant.

Growth accommodated under the 2040 General Plan would include a range of uses that c ould increase the population of the City and also attract additional workers and tourists to the City.

Such growth would result in increased demand for parks and recreation facilities. The 2040 General Plan does not propose or approve any development nor does it designate specific sites for new or expanded parks and recreational facilities. The 2040 General Plan includes a range of policies and actions to ensure that parks and recreational facilities are adequately funded, and that new development funds its fair share of services needed to meet 2040 General Plan objectives. New development is required to participate in the provision and expansion of public services, recreational amenities, and facilities, and is also required to demonstrate that the City’s public services and facilities can accommodate the increased demand for said services and facilities associated with future projects during the entitlement process . Any new parks or recreational facilities that may be constructed in the future would be primarily provided on sites with land use designations that allow such uses and the environmental impacts of constructing and operating the parks and recreational facilities would likely be similar to those associated with new development, redevelopment, and infrastructure projects under the 2040 General Plan.

Therefore, impacts related to the provisions and need for park and recreational facilities are less than significant.

The Housing Element Update proposes housing policies that would encourage housing production within the Planning Area. Potential development of vacant and underutilized sites to accommodate the City’s RHNA would be consistent with the adopted land use policy and would not result in any changes to existing land uses. The 2040 General Plan in cludes policies and programs to reduce potential impacts to public services as a result of new development and intensification of land uses.

The revisions to the Housing Element would not result in public services impacts beyond those identified in the 20 40 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts related to public services as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Item: 11
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Plan, and as such, there are no impacts to public services peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

XVI. RECREATION
The 2040 General Plan FEIR determined that impacts to recreation would be less than significant through the implementation of policies and actions in the 2040 General Plan. This topical area is addressed in the 2040 General Plan FEIR’s Public Services and Recreation section. As discussed above and in the 2040 General Plan FEIR, impacts related to the provisions and need for park and recreational facilities are less than significant.

The revisions to the Housing Element would not result in parks and recreation facilities impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts related to recreation as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to recreation peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

XVII. TRANSPORTATION
The 2040 General Plan FEIR determined that impacts to transportation would be less than significant through the implementation of policies and actions in the 2040 General Plan.

The 2040 General Plan is not expected to increase vehicle miles traveled (VMT) per person above No Project conditions. Therefore, the VMT-related impacts of the Plan would be considered less than significant.

The Orange County Transit Authority’s (OCTA’s) Congestion Management Program ( CMP) designates three CMP intersections; all three are expected to operate acceptably (Level of Service E or better) under Cumulative (2040) Plus Plan (2040 General Plan) conditions. Therefore, the impacts of the 2040 General Plan to CMP facilities would be considered less than significant.

As noted previously, there are no airport facilities located within the 2040 General Plan Planning Area. John Wayne Airport is located approximately 10 miles northwest of Lake Forest. The nature of the 2040 General Plan as a local plan for residential and commercial development (including mixed-used development) within the City of Lake Forest is such that it would not result in a change in air traffic patterns. Lake Forest itself has no existing or planned airport facilities, and Item: 11
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potential development within the Planning Area would have no effect on the John Wayne Airport approach or departure zones. Development attributable to the 2040 General Plan would be expected to have no impact to air traffic.

Lake Forest maintains improvement standards that guide the construction of new transportation facilities to minimize design hazards for all users of the system. Development and infrastructure projects in Lake Forest would be required to comply with the 2040 General Plan, Municipal Code, and applicable State and local regulations. Further, the 2040 General Plan does not contain any provisions that would increase hazards due to design features of incompatible uses. Therefore, this impact is less than significant.

Implementation of the 2040 General Plan would result in increased development which would result in new roadways and would increase the number of users on the city’s transportation system. The 2040 General Plan is a programmatic-level document, and emergency accessibility is typically assessed at the project -level. Adequacy of emergency access associated with future development projects would be analyzed and evaluated in detail through the environmental review process. Additionally, the Mobility Element d eveloped as part of the 2040 General Plan contains policies in support of emergency access along local roads. As a result, the 2040 General Plan’s impacts to emergency circulation and access are considered to be less than significant.

Implementation of the 2040 General Plan could lead to increases in the city’s population and employment that would increase the demand for transit services offered by OCTA, Metrolink, and Amtrak. The 2040 General Plan includes policies that support transit -oriented development patterns, strengthen ties between the pedestrian and bicycle networks to transit, promote enhancements to transit facilities, and support increased transit coverage and frequencies in Lake Forest. The Mobility Element developed as par t of the 2040 General Plan contains several policies that support access to and the performance of transit, bicycle, and pedestrian facilities.

Further, the Plan includes mixed-use development that is supportive of non-automotive modes.

Overall, the impact of the Plan with respect to access to and performance of transit, bicycle, and pedestrian impacts would be considered less than significant, The Housing Element Update proposes housing policies that would encourage housing production within the Planning A rea. However, potential development of vacant and underutilized sites to accommodate the City’s RHNA would be consistent with the adopted land use policy and would not result in any changes to existing land uses or allow for greater development than what w as analyzed in the 2040 General Plan FEIR. The 2040 General Plan includes policies and programs to reduce potential impacts to the circulation system as a result of new development and intensification of land uses.

The revisions to the Housing Element wou ld not result in transportation impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts related to transportation as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Item: 11
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Plan, and as such, there are no impacts to transportation peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

XVIII. TRIBAL CULTURAL RESOURCES
The 2040 General Plan FEIR determined that impacts to tribal cultural resources would be less than significant through the implementation of policies and actions in the 2040 General Plan. This topical area is addressed in the 2040 General Plan FEIR’s Cultural Resources section.

As discussed above, impacts from future development could impact unknown archaeological resources including Native American artifacts and human remains. Impacts would be reduced to a less-than-significant level with implementation of 2040 General Plan policies and actions and local review guidelines. Compliance with the 2040 General Plan policies and actions, as well as State and local guidelines would provide an opportunity to identify, disclose, and avoid or minimize the disturbance of and impacts to a tribal resource through tribal consultation and CEQA review procedures. Therefore, impacts related to tribal resources as a result of 2040 General Plan implementation would be considered less than significant.

The Housing Element policies and programs would not have an impact on existing 2040 General Plan policies protecting tribal cultural resources.

The revisions to the Housing Element would not result in new tribal cultural resource impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts to tribal cultural resources as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to tribal cultural resources peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

XIX. UTILITIES AND SERVICE SYSTEMS
The 2040 General Plan FEIR determined that impacts to utilities and service systems would be less than significant through the implementation of policies and actions in the 2040 General Plan.

Implementation of the 2040 General Plan would result in increased population and employment growth within the Planning Area, and a corresponding increase in the demand for additional water supplies. As described above, when the net impact to potable water demand is compared to the supply available to the two water Districts, it can be seen that both D istricts have ample water supply to account for buildout of the 2040 General Plan . Given that projected water Item: 11
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demands associated with 2040 General Plan buildout would not exceed the p rojected available water supplies, and that the 2040 General Plan includes a comprehensive set of goals and policies to ensure an adequate and reliable source of clean potable water, impacts associated with water supplies are less than significant.

Development and growth in the C ity under the 2040 General Plan would result in increased demand for water supplies, including water conveyance and treatment infrastructure. The 2040 General Plan includes policies and actions to ensure that water supplies are provided at acceptable levels and to ensure that development and growth does not outpace the provision of available water supplies. Future development in the Planning Area would be required to connect to existing water distribution infrastructure in the vicinity of each site, pay the applicable water system connection fees, and pay the applicable water usage rates. Future projects may be required to implement site specific and limited off -site improvements to the water distribution system in order to connect new project sites to the existing water infrastructure network. The specific impacts of providing new and expanded waster distribution infrastructure cannot be determined at t his time, as the 2040 General Plan does not propose or authorize any specific development projects or include details on any future development projects. However, any future improvements to the existing water distribution infrastructure would be primarily provided on sites with land use designations that allow for urbanized land uses, and the environmental impacts of constructing and operating the new water distribution infrastructure would likely be similar to those associated with new development, redevelopment, and infrastructure projects under the 2040 General Plan. Therefore, this impact is considered less than significant.

As with the water system, the City’s sewer services are divided up by three utility districts, IRWD, ETWD, and TCWD. 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 and will require that the districts, in coordination with the City, continue to implement phased improvements to some pump stations, sewer mains, and the various wastewater treatment plants when triggered by growth While full buildout of the development contemplated in the 2040 General Plan would slightly increase the existing treatment demand at the districts’ treatment plants, the 2040 General Plan includes a range of policies designed to ensure an adequate wastewater treatment capacity for development. Given that projected wastewater generation volumes associated with 2040 General Plan buildout would not exceed the projected wastewater generation volumes described in the IRWD Master Plan and ETWD Master Plan , this impact would be less than significant.

Development contemplated under the 2040 General Plan would result in increased wastewater flows, resulting in the need for additional or expanded wastewater treatment facilities and conveyance infrastructure, as described above. The infrastructure and facilities necessary to serve new growth would involve development of some facilities on new development sites, some facilities off-site, such as at existing wastewater treatment facilities, on appropriately designated land, and may also involve improvements to other existing facilities and disturbance of exist ing Item: 11
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rights-of-way. The specific impacts of providing new and expanded facilities cannot be determined at this time, as the 2040 General Plan does not propose or approve development nor does it designate specific sites for new or expanded public facilities. Wastewater treatment and conveyance facilities would be evaluated at the project -level in association with subsequent development projects. However, the facilities would be primarily provided on sites with land use designations that allow such uses and the environmental impacts of constructing and operating the facilities would likely be similar to those associated with new development, redevelopment, and infrastructure projects under the 2040 General Plan . As future development and infrastructure projects are considered by the City, each project will be evaluated for conformance with the 2040 General Plan , Municipal Code, and other applicable regulations. Subsequent development and infrastructure projects would also be analyzed for potential environmental impacts, consistent with the requirements of CEQA. As such, this impact would be less than significant.

Development under the 2040 General Plan would result in increased areas of impervious surfaces throughout the Planning Area, resulting in the need for additional or expanded stormwater drainage, conveyance, and retention infrastructure. Stormwater drainage and conveyance facilities would be evaluated at the project -level in association with subsequent development projects. However, the facilities would be primarily provided on sites with land use designations that allow such uses and the environmental impacts of constructing and operating the facilities would likely be similar to those associated with new development, redevelopment, and infrastructure pro jects under the 2040 General Plan . As future development and infrastructure projects are considered by the City, each project will be evaluated for conformance with the 2040 General Plan , Municipal Code, and other applicable regulations. Subsequent development and infrastructure projects would also be analyzed for potential environmental impacts, consistent with the requirements of CEQA. As such, this is a less than significant impact.

The City’s projected increase in solid waste generation associated with future buildout of the 2040 General Plan is well within the permitted capacity of the Frank R. Bowerman Sanitary Landfill, where the City disposes of the vast majority of its solid waste. Future projects within the Planning Area would be required to compl y with applicable state and local requirements including those pertaining to solid waste, construction waste diversion, and recycling. While there is adequate permitted landfill capacity to accommodate future growth, the 2040 General Plan includes actions to further reduce the project’s impact on solid waste services. The 2040 General Plan would not exceed the permitted capacity of the landfill serving the city, and the 2040 General Plan complies with regulations related to solid waste. This is a less than significant impact.

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includes policies and programs to reduce potential impact s to utilities and service systems as a result of new development and intensification of land uses. The Housing Element policies and programs would not have an impact on existing 2040 General Plan policies addressing utilities and service systems.

The revisions to the Housing Element would not result in new utilities and service systems impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts related to utilities and service systems as a result of the proposed Project. The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to utilities and service systems peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

XX. WILDFIRE
The 2040 General Plan FEIR determined that impacts to wildfire would be less than significant through the implementation of policies and actions in the 2040 General Plan.

The 2040 General Plan would allow a variety of new development, including residential, commercial, industrial, and public service projects, which would result in increased jobs and population in Lake Forest. Future projects are not anticipated to remove or impede evacuation routes, and the 2040 General Plan does not include land uses, policies, or other components that conflict with adopted emergency response or evacuation plans. The 2040 General Plan is a policy document that does not include any site specific designs or proposals and does not propose any entitlements for development that would have the potential to impair or conflict with an adopted emergency response or evacuation plan. Any future development projects that would implement the 2040 General Plan , including buildout of uses contemplated under the proposed Land Use Map, would be subject to all applicable City regulations, reviews, and requirements pertaining to emergency response, emergency access, and maintaining emergency evacuation routes, as well as further CE QA analysis of project -specific impacts. The 2040 General Plan ensures that the City’s emergency access routes, emergency contact lists, and public information regarding designated facilities and routes are regularly reviewed to ensure that up to date info rmation is available to the City and the public in the event of an emergency. Important new critical facilities would also be located to ensure resiliency and functionality in the event of a natural disaster.

Implementation of the 2040 General Plan would have a less than significant impact with regard to this issue.

Development under the 2040 General Plan would allow development to place people and/or structures in currently developed areas that are identified as having a significant risk of wildland fires. Any future development projects that would implement the 2040 General Plan including buildout of uses allowed under the proposed Land Use Map would be subject to all applicable City regulations, reviews, and requirement s pertaining to emergency response, emergency access, and maintaining emergency evacuation routes, as well as being subject to all applicable Item: 11
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building code and fire code requirements as well as further CEQA analysis of project -specific impacts for individual development projects. Nothing in the 2040 General Plan will substantially alter the slope, prevailing winds, or other factors that would increase exposure to Lake Forest residents, employees or visitors to increased pollutant concentrations from wildfir e or result in the uncontrollable spread of a wildfire. 2040 General Plan implementation would not exacerbate wildfire risks in Very High Fire Hazard Severity Zones (VHFHSZs); therefore, these impacts would be less than significant.

Development in or near fire hazard severity zones would require the construction and installation of infrastructure, including roads water and sewer and power lines. Development of such infrastructure may increase wildfire risks in the affecte d areas. Infrastructure required to serve development allowed under the 2040 General Plan would generally be located in and along established City roadways and would be located in areas that are already urbanized and are currently served by infrastructure. As such, implementation of the 2040 General Plan would not exacerbate wildfire risks.

The potential for future projects to impact environmental resources to meet compliance with fire development standards (such as fuel breaks and clearance requir ements) would require site - specific environmental review under CEQA to identify any site-specific impacts. As demonstrated throughout the EIR, implementation of th e various policies and actions contained in the 2040 General Plan would reduce potential impacts associated with the construction and expansion of infrastructure. Implementation of the 2040 General Plan policies and actions listed below, combined with local and state requirements, as discussed previously, would ensure that potential wildland fire hazards would not be exacerbated by local infrastructure, and this impact would be reduced to a less than significant level.

Expansion of man -made developments in to fire-prone wildlands has created situations where fast-moving, highly destructive debris flows triggered by intense rainfall are one of the most dangerous post-fire hazards. The 2040 General Plan would allow development and improvement projects that would involve some land clearing, grading, and other ground -disturbing activities that could temporarily increase soil erosion rates during and shortly after project construction.

As future development and infrastructure projects are considered by the City, each project will be evaluated for conformance with the California Building Code, Zoning Ordinance, and other regulations. In addition to compliance with City standards and policies, the Regional Wat er Quality Control Board will require a project specific Storm Water Pollution Prevention Plan (SWPPP) to be prepared for each project that disturbs an area of one acre or larger. Subsequent development and infrastructure projects would also be analyzed fo r potential environmental impacts, consistent with the requirements of CEQA. While the City cannot state with certainty that future risks associated with post -fire flooding and debris flow would not occur in Lake Forest, implementation of the 2040 General Plan would not exacerbate this risk. Implementation of Action PS-2a would reduce this risk to the greatest extent feasible, resulting in an impact that is less than significant.

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The Project does not propose site -specific development, but is rather an upd ate to a policy document to comply with new laws and reinforce existing policy direction. The Housing Element Update proposes housing policies that would encourage housing production within the Planning Area. However, potential development of vacant and un derutilized sites to accommodate the City’s RHNA would be consistent with the adopted land use policy and would not result in any changes to existing land uses or allow for greater development than what was analyzed in the 2040 General Plan FEIR. The 2040 General Plan includes policies and programs to reduce potential impacts due to wildfires. The Housing Element policies and programs would not have an impact on existing 2040 General Plan policies addressing wildfire.

The revisions to the Housing Element would not result in new wildfire impacts beyond those identified in the 2040 General Plan FEIR. Following compliance with the recommended 2040 General Plan FEIR mitigation measures and 2040 General Plan Policies, there would be no new significant or significantly different impacts related to wildfire as a result of the proposed Project.

The Housing Element Update has been prepared to be consistent with the 2040 General Plan, and as such, there are no impacts to wildfire peculiar to the Housing Element that have not been fully addressed in the 2040 General Plan EIR.

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ATTACHMENT 2

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ATTACHMENT 3

Link for Attachment
Draft Housing Element
Submitted January 6, 2022

https://www.lakeforestca.gov/1048/Housing-
Element
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ATTACHMENT 4
Link to Draft Housing
Element dated
March 7, 2022

https://www.lakeforestca.gov/1048/Housing-
Element

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ATTACHMENT 5

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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

March 7, 2022

Debra D. Rose, City Manager
City of Lake Forest
100 Civic Center Dr.

Lake Forest, CA 92630

Dear Debra Rose:

RE: City of Lake Forest’s 6th Cycle (2021-2029) Adopted Housing Element

Thank you for submitting the City of Lake Forest’s (City) adopted housing element received for review on January 06, 2022. Pursuant to Government Code section 65585, subdivision (h), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation on March 4,2022 with Gayle Ackerman, Director, and Amanda Tropiano, Consultant. In addition, HCD considered comments from Welcoming Neighbors Home pursuant to Government Code section 65585, subdivision (c).

The adopted element addresses many statutory requirements described in HCD’s November 22, 2021 review; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code). The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

As a reminder, the City’s 6th cycle housing element was due October 15, 2021. As of today, the City has not completed the housing element process for the 6th cycle. The City’s 5th cycle housing element no longer satisfies statutory requirements. HCD encourages the City to revise the element as described above, adopt, and submit to HCD to regain housing element compliance.

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the statutory deadline (October 15, 2021), then any rezoning to accommodate the regional housing needs allocation (RHNA), including for lower-income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i).

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Debra D. Rose, City Manager

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Lake Forest City CouncilAugust 16, 2022

Lake Forest City Council
August 16, 2022