Manhattan Beach City Council
September 23, 2022

Addendum
City of Manhattan Beach
General Plan Amendment:
6th Cycle Housing
Element Update
SEPTEMBER 2022
Prepared for:

CITY OF MANHATTAN BEACH
1400 Highland Avenue
Manhattan Beach, California 90266
Contact: Talyn Mirzakhanian, Planning Manager
Prepared by:

38 North Marengo Avenue
Pasadena, California 91101
Contact: Nicole Cobleigh

Printed on 30% post-consumer recycled material.

ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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Table of Contents

SECTION PAGE
Acronyms and Abbreviations ............................................................................................................................................ iii 1 Introduction .......................................................................................................................................................... 5

1.1 Purpose of Addendum ............................................................................................................................ 5

1.2 CEQA Compliance ................................................................................................................................... 5

1.3 Project Overview ..................................................................................................................................... 6

1.4 Previously Adopted Final IS/ND ............................................................................................................. 8 2 Project Description ............................................................................................................................................... 9

2.1 Project Location and Setting .................................................................................................................. 9

2.2 Originally Adopted HEU .......................................................................................................................... 9

2.3 Revised HEU ........................................................................................................................................ 11 3 Initial Study Checklist........................................................................................................................................ 15

3.1 Aesthetics ............................................................................................................................................ 21

3.2 Agriculture and Forestry Resources ................................................................................................... 22

3.3 Air Quality ............................................................................................................................................. 24

3.4 Biological Resources ........................................................................................................................... 25

3.5 Cultural Resources .............................................................................................................................. 27

3.6 Energy .................................................................................................................................................. 29

3.7 Geology and Soils ................................................................................................................................ 30

3.8 Greenhouse Gas Emissions ................................................................................................................ 32

3.9 Hazards and Hazardous Materials ..................................................................................................... 33

3.10 Hydrology and Water Quality ............................................................................................................... 35

3.11 Land Use and Planning ....................................................................................................................... 37

3.12 Mineral Resources .............................................................................................................................. 39

3.13 Noise .................................................................................................................................................... 40

3.14 Population and Housing ...................................................................................................................... 41

3.15 Public Services .................................................................................................................................... 43

3.16 Recreation ............................................................................................................................................ 44

3.17 Transportation ..................................................................................................................................... 46

3.18 Tribal Cultural Resources .................................................................................................................... 47

3.19 Utilities and Service Systems .............................................................................................................. 49

3.20 Wildfire ................................................................................................................................................. 51

3.21 Mandatory Findings of Significance ................................................................................................... 52 4 References and Preparers ................................................................................................................................ 55

4.1 References Cited ................................................................................................................................. 55 ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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4.2 List of Preparers .................................................................................................................................. 55

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Acronyms and Abbreviations
Acronym/Abbreviation Definition
AB Assembly Bill
ADU accessory dwelling unit
APN Assessor’s Parcel Number
CD Downtown Commercial District
CEQA California Environmental Quality Act
CG General Commercial
City City of Manhattan Beach
CL Local Commercial District
CNE North End Commercial District
County County of Los Angeles
EIR Environmental Impact Report
GHG greenhouse gas
HCD California Department of Housing and Community Development HEU City of Manhattan Beach 6th Cycle Housing Element Update HVAC heating, ventilation, and air conditioning
IS Initial Study
JADU junior accessory dwelling unit
LCP Local Coastal Plan
MBMC Manhattan Beach Municipal Code
MND Mitigated Negative Declaration
ND Negative Declaration
NOD Notice of Determination
NOI Notice of Intent
NPDES National Pollution Discharge Elimination System
OS Open Space
PD Planned Development
RH High-Density Residential District
RHNA Regional Housing Needs Allocation
RM Medium-Density Residential District
RS Single-Family Residential District
RTP Regional Transportation Plan
SCAG Southern California Association of Governments
SCS Sustainable Communities Strategy
TCR tribal cultural resource(s)
VHFHSZ Very High Fire Hazard Severity Zone

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1 Introduction

1.1 Purpose of Addendum
The City of Manhattan Beach (City) adopted an Initial Study (IS)/Negative Declaration (ND) for the 6th Cycle Housing Element Update (Originally Adopted HEU) in March 2022 (State Clearinghouse No. 2021110408). The Final IS/ND was prepared pursuant to the California Environmental Quality Act (CEQA) and contains a disclosure and analysis of potential environm ental effects associated with implementation of the Originally Adopted HEU . Based on the analysis contained in the Final IS/ND, the Manhattan Beach City Council adopted the 6th Cycle Housing Element Update (HEU) on March 22, 2022.

State law empowers the California Department of Housing and Community Development (HCD) to review and certify cities’ housing element s to ensure compliance with state housing element law (Government Code Article 10.6) .

Pursuant to Government Code Section 65585, subdivision (h), HCD reported the results of its review of the Originally Adopted HEU to the City in writing on June 3, 2022. According to HCD’s review letter, revisions to the Originally Adopted HEU were necessary to fully comply with state housing element law. In response to HCD’s June 3, 2022, review letter—provided as Appendix A, HCD Review Letter (June 3, 2022), of this Addendum—the City is proposing to revise the Originally Adopted HEU to fully comply with state housing element law . Proposed revisions include updates to Section 5, Goals and Policies, and Section 6, Implementation Programs, of the Originally Adopted HEU, as well as to the HEU’s Appendix C, Constraints and Zoning Analysis, Appendix D, Affirmatively Furthering Fair Housing and Appendix E, Sites Analysis and Inventory. The recent Housing Element Update (HEU) revisions made in response to HCD’s June 3, 2022, review letter will be referred to as the “Revised HEU” in this Addendum.

The previously adopted IS/ND (Final IS/ND) determined that the Originally Adopted HEU would not result in any significant environmental impacts and no mitigation measures were required. The purpose of this Addendum is to analyze the proposed revisions to the Originally Adopted HEU and to determine whether implementation of the Revised HEU would result in any new or different environmental impacts than those identified in the Final IS/ND for the Originally Adopted HEU. The Final IS/ND and Originally Adopted HEU are hereby incorporated by reference.

1.2 CEQA Compliance
Under CEQA, an addendum to an adopted negative declaration may be prepared if only minor technical changes or additions are necessary, or none of the conditions described in CEQA Guidelines Section 15162 calling for the preparation of a subsequent negative declaration have occurred (CEQA Guidelines Section 15164[b]). Pursuant to CEQA Guidelines Section 15162, when a negative declaration is adopted for a project, no subsequent EIR shall be prepared for a project unless the lead agency determines, on the basis of substantial evidence in the light of the whole record, one or more of the following (CEQA Guidelines Section 15162[a]):

1. Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;

2. Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or negative declaration due to the involvement of new ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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significant environmental effects or a substantial increase in the severity of previously identified significant effects; or

3. New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time of the previous EIR was certified as complete or the negative declaration was adopted, shows any of the following:

A. The project will have one or more significant effects not discussed in the previous EIR or negative declaration;
B. Significant effects previously examined will be substantially more severe than shown in the previous EIR;
C. Mitigation measures or alterna tive previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or D. Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

CEQA recommends that a brief explanation of the decision to prepare an Addendum rather than a subsequent negative declaration be included in the record for a proposed project (CEQA Guidelines Section 15164 [e]). This Addendum has been prepared because the Revised HEU is consistent with the Originally Adopted HEU evaluated in the Final IS/ND (State Clearinghouse No. 2021110408).

The Revised HEU does not require major revisions to the Final IS/ND because no new significant impacts would occur. The anticipated environmental impacts of the Revised HEU, as explained in detail in the following analysis and checklist, have been analyzed accordingly in the Final IS/ND prepared for the Originally Adopted HEU in January 2022, and there have been no new circumstances since that time that would result in new significant environmental impacts.

Per CEQA Guidelines Section 15164(c), an Addendum need not be circulated for public review, but can be included in or attached to the Final IS/ND. Prior to approval of the Revised HEU, the City will consider this Addendum together with the Final IS/ND when making a decision regarding the Revised HEU.

1.3 Project Overview
On March 22, 2022, the City Council adopted the City of Manhattan Beach General Plan Amendment: 6 th Cycle Housing Element Update and Final IS/ND with the approval of City Council Resolution Nos. 22-0014 and 22-0015.

The purpose of the Originally Adopted HEU is to provide an update to the Housing Element of City’s General Plan. The HEU is a policy document that conceptualizes how the City will provide the capacity for a total of 774 housing units, as assigned by the Southern California Association of Governments (SCAG) during the 2021 thorough 2029 Regional Housing Needs Allocation (RHNA) planning period, referred to as the “6th Cycle RHNA”. No development is proposed under the Originally Adopted HEU; however, implementation of the Originally Adopted HEU is designed to facilitate construction of 774 new dwelling units (“units”) throughout the City. Additionally, the Originally Adopted HEU ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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includes programs that support the existing and future residents of the City, including future rezoning necessary to accommodate a community-wide “shortfall” of lower-income units, as discussed in further detail below.

The City is proposing to revise the Originally Adopted HEU per the June 3, 2022, HCD Review Letter (provided as Appendix A of this Addendum) to bring the City’s General Plan Housing Element into compliance with Article 10.6 of the Government Code. The Originally Adopted HEU includes an adequate sites program (i.e., Program 2, Adequate Sites), which establish es an overlay district adhering to the standards set forth in Government Code Sections 65583.2 (h) and (i) to address shortfall and create opportunity for at least 406 units of multifamily housing for lower-income households. Sites identified for the adequate sites program overlay may be subject to future rezoning to accommodate additional housing necessary to satisfy the 6 th Cycle RHNA. The Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would increase the number of lower-income RHNA units ultimately required to be accommodated though the adequate site program overlay from 406 to 412 (representing an increase of 6 units). Additionally, the Originally Adopted HEU identifies a total of 34 underutilized sites with the potential to accommodate 1,018 lower income units1 and 5 buffer rezone sites with the potential to accommodate 26 lower-income units.

The Revised HEU would add one new site to the adequate sites program overlay (i.e., 1700 North Sepulveda Boulevard, Assessor Parcel Number [APN] 4166023016) identified within Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU and would include other slight revisions to the list of sites, APNs, and potential capacity identified in Table 15 and Table 16, Rezone Sites to Accommodate the Buffer , of Appendix E of the Originally Adopted HEU. These revisions would reduce the total capacity (i.e., the “realistic” lower- income unit capacity) on potential underutilized sites from 1,018 units to 844 (provided Table 15 of the Revised HEU) units and would increase the total capacity on 7 potential low-income buffer sites from 26 to 115 (provided in Table 16 of the Revised HEU). The Originally Adopted HEU identified a surplus of sites (i.e., 1,018) which could potentially be rezoned as part of a future action to accommodate additional lower-income RHNA units. Although the Revised HEU would add one site to this list (i.e., 1700 North Sepulveda Boulevard), most of the lower-income units required to satisfy RHNA in the Revised HEU would still be accommodated from amongst sites previously identified in Table 15 of the Originally Adopted HEU.

In addition to the above proposed changes, the Revised HEU would also do the following:
• Modify Program 3, Affordable Housing Streamline, of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the Local Commercial District ( CL), Downtown Commercial District (CD) , and North End Commercial District (CNE) zones;
• Add a brief analysis to each of the implementation program discussions within Section 6, Prog ram Implementation, to identify and evaluate “contributing factors” to fair housing issues, as outlined in HCD’s Affirmatively Furthering Fair Housing Guidance Memo (HCD 2021); and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

1 As provided in Table 15 of Appendix E, Sites Analysis and Inventory, of the Revised HEU, “realistic” lower -income unit capacity is identified as 20 dwelling units per acre.

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Proposed changes to the Originally Adopted HEU that could potentially result in physical impacts to the environment are discussed in further detail in Section 2.3, Revised HEU, of this Addendum.

The City, as lead agency for the Revised HEU, has the responsibility for reviewing, processing, and approving the Revised HEU. This document is an Addendum to the Final IS/ND to accommodate a subsequent discretionary action for the proposed HCD mandated revisions to the HEU. As such, the City will consider the following discretionary action:
▪ Approval of the City of Manhattan Beach General Plan Amendment: 6 th Cycle Revised Housing Element Update

1.4 Previously Adopted Final IS/ND
As stated previously, the Final IS/ND for the Originally Adopted HEU was adopted on March 22, 2022. The Final IS/ND evaluated and analyzed the potential environmental impacts associated with the implementation of the Originally Adopted HEU. The Final IS/ND concluded that the Originally Adopted HEU would not result in any potentially significant environmental impacts. A Notice of Intent (NOI) was circulated for 34 days, from November 24, 2021, to December 27, 2021 . During that time, one comment letter was received from the California Department of Transportation. A subsequent Notice of Determination (NOD) was filed on April 18, 2022.

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2 Project Description

2.1 Project Location and Setting
The City of Manhattan Beach (City) is in the southwest portion of Los Angeles County (County) along the Pacific Ocean, approximately 19 miles southwest of Downtown Los Angeles. The City is bordered by the City of El Segundo and the Chevron Oil Refinery to the north, the cities of Redondo Beach and Hawthorne to the east, the City of Hermosa Beach to the south, and the Pacific Ocean to the west. The City is almost entirely built out and contains vegetation that is ornamental.

The City is made up primarily of low-density, single-family residential development, designated in the City’s General Plan Land Use Element as Low -Density Residential and zoned as Single-Family Residential District (RS). Medium- Density Residential District (RM) zone and High-Density Residential District (RH) zone areas extend eastward from the City’s coastline and comprise much of the City’s Local Coastal Program (LCP) planning area. Other land use types include commercial, mixed-use, industrial, parks and open space, and public facilities.

Zoning districts potentially impacted by the Revised HEU include: the RM zone, in only Area District 3; RH zone in all Area Districts; the Local Commercial (CL), Downtown Commercial (CD), and North End Commercial (CNE) zones in all Area Districts; the Planned Development (PD) zone; and the General Commercial (CG) zone.

2.2 Originally Adopted HEU
Each local government must demonstrate that it has planned to accommodate all its regional housing need allocation in its Housing Element. The City has been assigned total of 774 units for the 6 th Cycle RHNA, which are further broken down by income level. Of the 774 total units, the City must plan to accommodate 322 units for very low-income households, 165 units for low -income households, 155 units for moderate -income households, and 132 units for above-moderate-income households.

Summ ary of Capacity to Accommodate RHNA
The Originally Adopted HEU identified an existing capacity for 81 lower-income units, 163 moderate-income units, and 133 above-moderate income units within the residential pipeline of projects, underutilized sites, and through the expected number of accessory dwelling units (ADUs) and junior accessory dwelling units (JADUs). Because the City does not have large swaths of land available for development, there were no opportunities to identify new housing capacity on undeveloped lands. With no vacant sites, the City’s housing capacity was identified in the form of underutilized sites that are most suitable for redevelopment. To accommodate the 6th Cycle RHNA, the City prepared an analysis and inventory of sites within City limits that were suitable for residential development during the planning period. These sites were identified as a part of Program 2, Adequate Sites, of the Originally Adopted HEU. As provided below in Table 2 -1, after calculating the City’s existing capacity via the sites analysis, the City determined there was existing capacity to accommodate a total of 377 units (including lower -, moderate-, and above-moderate-income units). However, the City also determined that there existed a shortfall of 406 units for the ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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lower-income RHNA category, plus the need to accommodate an additional 73 lower -income unit “buffer,”2 for a collective shortfall of 479 units.

Table 2-1. Originally Adopted HEU: Total RHNA Compared to Credits and Capacity Identified
Category Total Units
Lower-Income
Units
Moderate-Income
Units
Above Moderate-
Income Units
RHNA 774 487 155 132
Underutilized Site
Capacity (No New Units)
201 24 158 19
Vacant Site Capacity 0 0 0 0
Pipeline Residential
Development Credited
Toward RHNA
93 7 0 86
Projected Accessory
Dwelling Units
83 50 5 28
Totals 377 81 163 133
Capacity Deficit (-)/
Surplus (+)
— - 406 +8 +1
Additional Capacity for
Buffer Through Rezoning
and Overlay
73 73
Source: City of Manhattan Beach 2022
To accommodate the remaining lower -income RHNA, the City identified potential sites to be made available to accommodate residential uses appropriate for lower-income households within three years and 120 days from the beginning of the 6th Cycle RHNA eight-year planning period. This process, together with the potential sites identified to accommodate future lower-income RHNA units, is part of the Originally Adopted HEU’s “adequate sites program” (i.e., Program 2). As proposed in the adequate sites program, the City would establish an “overlay” which is a regulatory planning tool that creates special provisions or makes allowances over an existing base zoning district to guide development within a specific area. The adequate sites program overlay established in the Originally Adopted HEU (as illustrated in Figure 2.2-1, Potential Sites to Accommodate the Lower-Income Shortfall, of the Final IS/ND) would permit residential uses at a minimum of 20 dwelling units per acre within the G eneral Commercial (CG) and Planned Development (PD) districts to accommodate the RHNA shortfall of 406 lower -income units. In accordance with current state housing law, the sites would allow 100% residential use and require residential use to occupy at least 50% of the floor area in a mixed-use project. 3 Furthermore, through implementation of Program 1 8, Multifamily Residential Development Standards and Streamlining in the Mixed-Use (CL, CD, and CNE) Commercial Districts, and to further incentivize affordable housing

2 The capacity to accommodate an additional “buffer” of approximately 15% is recommended by HCD to ensure sufficient capacity exists to accommodate the RHNA throughout the eight-year planning period and comply with the provisions of Senate Bill 166 (SB-166) (2017). SB-166 requires a city, county, or city and county to ensure that its housing element inventory can accommodate its share of the regional housing need throughout the planning period. 3 For the purposes of CEQA, it is necessary to clarify that not all the sites identified in the adequate sites program overlay district would ultimately support additional residential development. Sites identified may be subject to future land use changes (e.g., zone changes) to accommodate the RHNA, however, these land use changes would be implemented through future actions, which are not considered part of the Originally Proposed HEU nor the Revised HEU.

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in the City, the Originally Adopted HEU proposes to remove the discretionary requirements for multifamily housing meeting the minimum requirements for a state density bonus in the CL, CD, and CNE zones (as detailed in the Originally Adopted HEU’s Program 11, Density Bonus). The underutilization of existing sites, paired with programs identified in the Originally Adopted HEU were intended to ensure that the City would realistically meet the RHNA targets at all income levels during the required eight-year planning period.

Summary of Housing Plan
As required by state housing element law, the Originally Adopted HEU includes a Housing Plan to facilitate and encourage the provision of housing. The goals, objectives, policies, and implementing programs of the Housing Plan emphasize: methods of encouraging and assisting in the development of new housing for all income levels; providing and maintaining adequate capacity to meet the housing need; removing government constr aints to development, where feasible and legally possible; conserving and improving existing housing; providing increased opportunities for home ownership; reducing impediments to fair housing choice; and monitoring and preserving units at risk of converti ng from affordable to market rate. The Housing Plan also include s numerous policies to better guide decisions and achieve desired outcomes related to the development, improvement, preservation, and maintenance of housing. The implementation programs (speci fically Program 1 through Program 31) in the Originally Proposed HEU are detailed in the Final IS/ND.

Scope of Analysis
No development is proposed under the Originally Adopted HEU, however, implementation of the Originally Adopted HEU is designed to facilitate construction of 774 new units throughout the City. Additionally, the Originally Adopted HEU includes programs intended to support the existing and future residents of the City, including the adequate sites program, which is necessary to accommodate the City’s lower -income RHNA shortfall. Given the developed and built out nature of the City, new housing units facilitated as a result implementation for the Originally Adopted HEU may qualify for one or more categorical exemptions under CEQA —such as Class 3, Small Structures or Class 32, Infill Development Project—consistent with State CEQA Guidelines Section 15332, or for CEQA Streamlining and and/or other state laws to promote the development of infill affordable housing. As appropriate, the Final IS/ND analysis addressed the potential physical impacts associated with implementation of the Originally Adopted HEU.

2.3 Revised HEU
As previously discussed above in Section 1.1, Purpose of Addendum, state law empowers HCD to review and certify cities’ housing elements to ensure compliance with state housing element law (as codified in Government Code Article 10.6). In accordance with the HCD’s June 3, 2022, review letter—provided as Appendix A of this Addendum— the City is proposing to revise the Originally Adopted HEU to fully comply with state housing element law. Proposed revisions include updates to Section 5, Goals and Policies, and Section 6 , Implementation Programs, of the Originally Adopted HEU, as well as to the HEU’s Appendix C, Constraints and Zoning Analysis, Appendix D, Affirmatively Furthering Fair Housing, and Appendix E, Sites Analysis and Inventory, as further detailed, below.

The Revised HEU would continue implementation of the Originally Adopted HEU, including the adequate sites program, but would increase the total number of units required to accommodate the lower-income RHNA from 406 to 412 (representing an increase of 6 units) . This increase in units is not due to an increase in the overall RHNA (which remains at 774). Rather, upon further analysis, it was determined that a City owned parking structure (i.e., Table ID No. 1, Rosecrans Avenue/Highland Avenue, within Table 7, Lower Income Sites Identified, of Appendix E, ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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of the Originally Adopted HEU ) does not have capacity to support six net new lower-income units under existing conditions. Thus, the total existing capacity identified to support lower-income RHNA units would be reduced from 24 net new units in the Originally Adopted HEU to 18 net new units in the Revised HEU . The Revised HEU would also remove one site previously identified as having capacity to support six moderate-income RHNA units (i.e., Table ID No. 26, Highland/Rosecrans, in Table 8, Moderate Income Sites Identified, of Appendix E of the Originally Adopted HEU). As the Originally Adopted HEU identifies an existing surplus capacity of eight moderate-income units, the six unit decrease in existing moderate-income site capacity identified in the Revised HEU would not impact the total number of adequate sites program units required to satisfy the City’s moderate-income RHNA. Pursuant to the Revised HEU, there would be an existing surplus capacity of two moderate income units. The underutilized sites capacity, total capacity, total capacity deficit/surplus , and additional capacity to accommodate a buffer in the Revised HEU are provided below in Table 2-2.

Table 2-2. Revised HEU: Total RHNA Compared to Credits and Capacity Identified Category Total Units
Lower-Income
Units
Moderate-Income
Units
Above Moderate-
Income Units
RHNA 774 487 155 132
Underutilized Site
Capacity
189* / (201) 18* / (24) 152* / (158) 19
Vacant Site Capacity 0 0 0 0
Pipeline Residential
Development Credited
Toward RHNA
93 7 0 86
Projected Accessory
Dwelling Units
83 50 5 28
Totals 365* / (377) 75* / (81) 157* / (163) 133
Capacity Deficit (-)/
Surplus (+)
— - 412* / (-406) +2* / (+8) +1
Additional Capacity for
Buffer Through Rezoning
and Overlay
73 73
Source: City of Manhattan Beach 2022
Notes: Numbers provided in parentheses in the above Table 2.3-1 denote number of units included in the Originally Adopted HEU. * Denotes a change compared to the Originally Adopted HEU.

As previously discussed in Section 1.3, Project Overview, of this Addendum, the Revised HEU would add one new site to the adequate sites program overlay (i.e., 1700 North Sepulveda Boulevard , APN 4166023016, with a realistic capacity of 89 lower-income units) and would include slight revisions to sites and/or APNs and the potential capacity identified in Table 15 and Table 16 of Appendix E of the Originally Adopted HEU. The sites identified in Table 15 and 16 of the Revised HEU are illustrated in Figure 1, Potential Sites to Accommodate Lower -Income Shortfall and Buffer. These proposed revisions in the Revised HEU would reduce the total capacity (i.e., the “realistic” lower-income unit capacity) from 1,018 units to 844 units and would increase the total capacity on 7 potential low-income buffer sites from 26 to 115. The two sites added to Table 16 of the Revised HEU were originally identified in Table 15 of the Originally Adopted HEU. The total acreage of land included within the adequate sites program overlay district would be reduced from 50.49 acres in the Originally Adopted HEU, to 42.75 acres in the Revised HEU, while the total acreage of land identified within the potential buffer sites would be increased from

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as part of a future action to accom modate additional lower-income RHNA units. Although the Revised HEU would add one site to this list (i.e., 1700 North Sepulveda Boulevard ), most of the 412 lower-income units required to satisfy the RHNA under the Revised HEU would still be accommodated from amongst sites previously identified in Table 15 of the Originally Adopted HEU.

In addition to minor revisions affecting existing capacity and adequate sites, the Revised HEU would modify Program 3, Affordable Housing Streamline, of the Originally Adopted HEU to remove discretionary review requirements for future multifamily projects within the CL, CD, and CNE zones, regardless of whether these projects would qualify for a density bonus. The removal of the density bonus qualification would result in slightly more development review streamlining than initially considered in the Final IS/ND for the Originally Approved HEU. The Revised HEU would also add discussion and analysis to each of the implementation programs (i.e., Section 6 of the Re vised HEU) related to fair housing issues and would incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

The purpose of this Addendum is to evaluate the difference(s) between the Originally Adopted HEU and the Revised HEU and to determine if proposed changes would result in new significant environmental effects. The proposed increase of six lower-income RHNA units required to be accommodated through the adequate sites program, the addition of one site to the adequate sites program overlay, and the additional streamlining of future multifamily projects within commercial zones will be the focus of the analysis provided in Chapter 3, Initial Study Checklist, of this Addendum.

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3 Initial Study Checklist

1. Project title:

City of Manhattan Beach General Plan Amendment: 6th Cycle Housing Element Update

2. Lead agency name and address:

City of Manhattan Beach
1400 Highland Avenue
Manhattan Beach, California 90266

3. Contact person and phone number:

Talyn Mirzakhanian, Planning Manager
310.802.5510

4. Project location:

Citywide

5. Project sponsor’s name and address:

City of Manhattan Beach
1400 Highland Avenue
Manhattan Beach, California 90266

6. General plan designation:

Not applicable to the Housing Element Update or Addendum.

7. Zoning:

Not applicable to the Housing Element Update or Addendum.

8. Description of project. (Describe the whole action involved, including but not limited to later phases of the project, and any secondary, support, or off-site features necessary for its implementation. Attach additional sheets if necessary):

In response to the California Department of Housing and Community Development’s (HCD’s) June 3, 2022, review letter—provided as Appendix A, HCD Review Letter (June 3, 2022), of this Addendum —the City of Manhattan Beach is proposing to revise its recently adopted General Plan Housing Element ( referred to herein as th e “ Originally Adopted H ousing Element Update [HEU] ”) to fully comply with state housing element law (Government Code Article 10.6). Proposed revisions include updates to Section 5, Goals and Policies, and Section 6, Implementation Programs, of the Originally Adopted HEU, as well as to the HEU’s Appendix C, Constraints and Zoning Analysis, Appendix D, Affirmatively Furthering Fair Housing and ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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Appendix E, Sites Analysis and Inventory. The proposed revisions made to the previously adopted Housing Element will be referred to as the “Revised HEU” in this Addendum.

The Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay, but would increase the total number of lower-income RHNA units ultimately required to be accommodated within the adequate site program overlay district from 406 units to 412 units, which represents an increase of 6 RHNA “shortfall” units over the Originally Adopted HEU. The land use changes required to facilitate additional development on the sites identified in the adequate sites program overlay district would require future actions, which are not considered part of the “project” under review in the Final IS/ND or this proposed Addendum.

In addition to minor revisions affecting existing capacity and adequate sites, the Revised HEU would modify Program 3, Affordable Housing Streamline, of the Originally Adopted HEU to remove discretionary review requirements for future multifamily projects within the CL, CD, and CNE zones, regardless of whether these projects would qualify for a density bonus. The Revised HEU would also: add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues, as outlined in HCD’s Affirmatively Furthering Fair Housing Guidance Memo (HCD 2021); and incorporate other administrative changes to fix minor gramm atical errors, maintain internal consistency, and provided improved clarity for readers.

9. Surrounding land uses and setting (Briefly describe the project’s surroundings):

The City of Manhattan Beach is in the southwest portion of Los Angeles County along the Pacific Ocean, approximately 19 miles southwest of Downtown Los Angeles. The City is bordered by the City of El Segundo and the Chevron Oil Refinery to the north, the cities of Redondo Beach and Hawthorne to the east, the City of Hermosa Beach to the south, and the Pacific Ocean to the west. The City is almost entirely built out and contains vegetation that is ornamental.

The City is made up primarily of low-density, single-family residential development, designated in the City’s General Plan Land Use Element as Low-Density Residential and zoned as Single-Family Residential District (RS). Medium-Density Residential District (RM) zone and High-Density Residential District (RH) zone areas extend eastward from the City’s coastline and comprise much of the City’s Local Coastal Program (LCP) planning area. Other land use types include commercial, mixed-use, industrial, parks and open space, and public facilities. Zoning districts potentially impacted by the Revised HEU include: the RM zone, in only Area District 3; RH zone in all Area Districts; the Local Commercial (CL), Downtown Commercial (CD), and North End Commercial (CNE) zones in all Area Districts; the Planned Development (PD) zone; and the General Commercial (CG) zone.

10. Other public agencies whos e approval is required (e.g., permits, financing approval, or participation agreement):

Approval from the California Department of Housing and Community Development is required for the Housing Element Update.

Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan for consultation ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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that includes, for example, the determi nation of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.?
Not Applicable. Assembly Bill (AB) 52 requires that tribal cultural resources be evaluated under CEQA.

However, pursuant to Public Resources Code Section 21080.3.1(b), AB 52 consultation does not apply in this case because the environmental document is not a Negative Declaration, Mitigated Neg ative Declaration, or Environmental Impact Report and is instead an Addendum to a previously prepared CEQA document.

Environmental Factors Potentially Affected
New significant environmental effects or substantially more severe significant environmental effects compared to those identified in the previous CEQA document. The subject areas checked below were determined to be new significant environmental effects or to be previously identified effects that have a substantial increase in severity either due to a change in project, change in circumstances or new information of substantial importance, as indicated by the checklist and discussion on the following pages.

Aesthetics Agriculture and
Forestry Resources
Air Quality
Biological Resources Cultural Resources Energy
Geology and Soils Greenhouse Gas
Emissions
Hazards and Hazardous
Materials
Hydrology and Water Quality Land Use and
Planning
Mineral Resources
Noise Population and
Housing
Public Services
Recreation Transportation Tribal Cultural Resources Utilities and Service Systems Wildfire Mandatory Findings of Significance

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Determination (To be completed by the Lead Agency)
On the basis of this initial evaluation:

No substantial changes are proposed in the project and there are no substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous approved ND or MND or certified EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects. In addition, there is no "new information of substantial importance" as defined in CEQA Guidelines Section 15162(a)(3). Therefore, the previously adopted ND or MND or previously certified EIR adequately discusses the potential impacts of the project without modification.

No substantial changes are proposed in the project and there are no substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous approved ND or MND or certified EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects. In addition, there is no "new information of substantial importance" as defined in CEQA Guidelines Section 15162(a)(3). Therefore, the previously adopted ND, MND or previously certified EIR adequately discusses the potential impacts of the project; however, minor changes require the preparation of an ADDENDUM.

Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous adopted ND, MND or certified EIR due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or, there is "new information of substantial importance," as defined in CEQA Guidelines Section 15162(a)(3). However, all new potentially significant environmental effects or substantial increases in the severity of previously identified significant effects are clearly reduced to below a level of significance through the incorporation of mitigation measures agreed to by the project applicant. Therefore, a SUBSEQUENT MND is required.

Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous ly certified EIR due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or, there is "new information of substantial importance," as defined in CEQA Guidelines Section 15162(a)(3). However, only minor changes or additions or changes would be necessary to make the previously certified EIR adequate for the project in the changed situation. Therefore, a SUPPLEMENTAL EIR is required.

Substantial changes are proposed in the project or there are substantial changes in the circumstances under which the project will be undertaken that will require major revisions to the previous certified EIR due to the involvement of significant new environmental effects or a substantial increase in the severity of previously identified significant effects. Or, there is "new information of substantial importance," as defined in CEQA Guidelines Section 15162(a)(3). Therefore, a SUBSEQUENT EIR is required.

Signature Date
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Evaluation of Environmental Impacts
A finding of “No New Impact/No Impact” means that the potential impact was fully analyzed and/or mitigated in the prior CEQA document and no new or different impacts will result from the proposed activity. A brief explanation is required for all answers except "No New Impact/No Impact" answers that are ad equately supported by the information sources a lead agency cites in the parentheses following each question. A "No New Impact/No Impact" answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g. the project falls outside a fault rupture zone). A "No New Impact/No Impact" answer should be explained where it is based on project -specific factors as well as general standards (e.g. the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).

A finding of “New Mitigation is Required” means that the project have a new potentially significant impact on the environment or a substantially more severe impact than analyzed in the previously approved or certified CEQA document and that new mitigation is required to address the impact.

A finding of “New Potentially Significant Impact” means that the project may have a new potentially significant impact on the environment or a sub stantially more severe impact than analyzed in the previously approved or certified CEQA document that cannot be mitigated to below a level of significance or be avoided.

A finding of “Reduced Impact” means that a previously infeasible mitigation measure i s now available, or a previously infeasible alternative is now available that will reduce a significant impact identified in the previously prepared environmental document.

All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.

Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063(c)(3)(D). In this case, a brief discussion should identify the following:
a. Earlier Analysis Used. Identify and state where they are available for review. b. Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. Describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the proposed action. c. Infeasible Mitigation Measures. Since the previous EIR was certified or previous ND or MND was adopted, discuss any mitigation measures or alternatives previously found not to be feasible that would in fact be feasible or that are considerably different from those previously analyzed and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measures or alternatives.
d. Changes in Circumstances. Since the previous EIR was certified or previous ND or MND was adopted, discuss any changes in t he project, changes in circumstances under which the project is undertaken and/or “new information of substantial importance” that cause a change in conclusion regarding one or more effects discussed in the original document.

Lead agencies are encouraged t o incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated.

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• Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion.
• This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project’s environmental effects in whatever format is selected.
• The explanation of each issue should identify:
o The significance criteria or threshold, if any, used to evaluate each question; o Differences between the proposed activity and the previously approved project described in the approved ND or MND or certified EIR; and
o The previously approved mitigation measure identified, if any, to r educe the impact to less than significance

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3.1 Aesthetics
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
I. AESTHETICS – Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a
scenic vista?
b) Substantially damage scenic resources,
including, but not limited to, trees, rock
outcroppings, and historic buildings within a
state scenic highway?

c) In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those that
are experienced from publicly accessible
vantage point). If the project is in an
urbanized area, would the project conflict
with applicable zoning and other regulations
governing scenic quality?

d) Create a new source of substantial light or
glare which would adversely affect day or
nighttime views in the area?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
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• Modify Program 3, Affordable Housing Streamline, of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL , CD, and CNE zones;
• Add a brief analysis to eac h of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues, as outlined in HCD’s Affirmatively Furthering Fair Housing Guidance Memo (HCD 2021); and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

The changes identified within the Revised HEU would not result in aesthetic changes associated with implementation of the HEU. The identified changes would modify text of the HEU document, and as outlined in the Final IS/ND for the Originally Adopted HEU, aesthetic-related impacts are location specific and cannot be assessed in a meaningful way until the location of pr oject sites are known and the development planned on those sites is defined. Under the Revised HEU, impacts would remain less than significant related to scenic vistas, degradation of visual character, and light and glare; no impacts would occur relative to state scenic highways. For these reasons, the Revised HEU would not result in any new or different aesthetic-related environmental impacts when compared to the Originally Adopted HEU.

3.2 Agriculture and Forestry Resources
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
II. AGRICULTURE AND FORESTRY RESOURCES – In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on the maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non-agricultural use?

b) Conflict with existing zoning for agricultural
use, or a Williamson Act contract?
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New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
c) Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code section 12220(g)),
timberland (as defined by Public Resources
Code section 4526), or timberland zoned
Timberland Production (as defined by
Government Code section 51104(g))?

d) Result in the loss of forest land or
conversion of forest land to non-forest use?
e) Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland, to non-agricultural use or
conversion of forest land to non-forest use?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6 to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

As there are no agriculture or forestry resources in the City, the changes identified within the Revised HEU would have no impacts related to conversion of Farmland to non-agricultural use, existing zoning for agricultural use (or a ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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Williamson Act contract), existing zoning for forestland or timberland, the loss or conversion of forest or timberland to non-forest use, or other changes in the existing environment which would result in conversion or farmland to non- agricultural use or forestland to non-forest use. As the proposed changes are not related to agriculture and forestry resources, and as these resources are not present in the City, the Revised HEU would not result in any new or different agriculture or forestry-related environmental impacts when compared to the Originally Adopted HEU.

3.3 Air Quality
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
III. AIR QUALITY – Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of
the applicable air quality plan?
b) Result in a cumulatively considerable net
increase of any criteria pollutant for which
the project region is non-attainment under
an applicable federal or state ambient air
quality standard?

c) Expose sensitive receptors to substantial
pollutant concentrations?
d) Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
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• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammati cal errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximatel y 1.5% increase in units compared to the Originally Adopted HEU, which does not constitute a substantial change. The changes identified within the Revised HEU would not result in changes to the total number of RHNA units (i.e., 774) associated with implementation of the HEU. As such, there would be no substantial changes to the previously identified and evaluated air quality impacts associated with HEU implementation . The identified changes in the Revised HEU would modify text of the HEU document, and as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA units . Adoption of the HEU would not, in and of itself, result in environmental impacts . Under the Revised HEU, impacts would remain less than significant related to conflicts with the applicable air quality plan, a net increase in criteria pollutants, and exposure of sensitive receptors to pollutants; no impacts would occur related to other emissions, such as those leading to odors . For these reasons, the Revised HEU would not result in any new or substantially different air-quality-related environmental impacts when compared to the Originally Adopted HEU.

3.4 Biological Resources
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
IV. BIOLOGICAL RESOURCES – Would the project:
a) Have a substantial adverse effect, either
directly or through habitat modifications, on
any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations, or
by the California Department of Fish and
Game or U.S. Fish and Wildlife Service?

b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, regulations, or by the
California Department of Fish and Game or
U.S. Fish and Wildlife Service?

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New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
c) Have a substantial adverse effect on state
or federally protected wetlands (including,
but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal, filling,
hydrological interruption, or other means?

d) Interfere substantially with the movement
of any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors,
or impede the use of native wildlife
nursery sites?

e) Conflict with any local policies or ordinances
protecting biological resources, such as a
tree preservation policy or ordinance?

f) Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and tot al acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Add a brief analysis to each of the implementation program discussions within Section 6, Prog ram Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

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As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximately 1.5% increase compared to the Originally Adopted HEU, which is not a substantial change. The changes identified within the Revised HEU would not change the total number of RHNA units (i.e., 774) associated with implementation of the HEU . Further, while the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard) as having the potential to accommodate future lower-income RHNA units, subject to rezoning , this site is currently paved and built-out with hotel uses and does not support any sensitive habitat, wetlands, or other undisturbed habitat likely to support special status plant or wildlife species. All sites identified in Table 16 of the Revised HEU were previously identified in the Originally Adopted HEU. Although the Revised HEU could result in additional streamlining for future multifamily projects, these projects would be located primarily on previously disturbed infill parcels, which would help avoid potential impacts to biological resources, and would continue to be subject to existing local, state, and federal regulatory requirements.

The changes proposed by the Revised HEU would not result in biological resource changes associated with implementation of the HEU. The Revised HEU changes would modify text of the HEU document, and as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA units, and adoption would not, in and of itself, result in environmental impacts. Under the Revised HEU, impacts would remain less than significant related to candidate, sensitive, or special status species , riparian habitat or other sensitive natural community , movement of native wildlife species, wildlife corridors, or policies or ordinances protecting biological resources, such as a tr ee preservation policy or ordinance; no impacts would occur related to an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation pla n, or state or federally protected wetlands. For these reasons, the Revised HEU would not result in any new or different biological resource-related environmental impacts when compared to the Originally Adopted HEU.

3.5 Cultural Resources
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
V. CULTURAL RESOURCES – Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource
pursuant to §15064.5?

b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5?

c) Disturb any human remains, including those
interred outside of formal cemeteries?
Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:

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• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximately 1.5% increase compared to the Originally Adopted HEU, which is not a substantial change. The rezoning necessary to accommodate these units would still take place under a future, separate action . The Revised HEU would not change the total number of RHNA units (i.e., 774) associated with implementation of the HEU. Further, while the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard) as having the potential to accommodate future lower -income RHNA units, subject to rezoning, this site is previously disturbed and currently built -out with hotel uses . This site does not support any known historic resources or undisturbed terrain where an inadvertent archeological find or uncovering human remains would be likely to occur. All sites identified in Table 16 of the Revised HEU were previously identified in the Originally Adopted HEU. Although the Revised HEU could result in additional streamlining for future multifamily projects, these projects would be located primarily on previously disturbed and/or graded infill parcels, which would help avoid potential impacts to cultural resources, and would continue to be subject to existing local, state, and federal regulatory requirements. Streamlining for multifamily and/or affordable housing is currently permitted in the City, pursuant to state law and the previous (i.e., 2013-2021 or “5th Cycle”) Housing Element (City of Manhattan Beach 2014). Implementation of the Revised HEU would not constitute a substantial change in streamlining policy as compared to existing conditions, or to proposed conditions analyzed under the Originally Adopted HEU.

The changes identified within the Revised HEU would not result in changes to cultural resources or cultural resource impacts associated with implementation of the HEU. The identified changes would modify text of the HEU document, and as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA and lower-income buffer units.

Adoption of the HEU would not, in and of itself, result in environmental impacts. Under the Revised HEU, impacts would remain less than significant related to historic resources, archeological resources, and human remains. For these reasons, the Revised HEU would not result in any new or different cultural resource-related environmental impacts when compared to the Originally Adopted HEU.

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3.6 Energy
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
VI. Energy – Would the project:
a) Result in potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption of
energy resources, during project
construction or operation?

b) Conflict with or obstruct a state or local plan
for renewable energy or energy efficiency?
Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammati cal errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximatel y 1.5% increase compared to the Originally Adopted HEU, which is not a substantial change. The changes identified above would not result in changes to the number of ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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RHNA units (i.e., 774) associated with implementation of the HEU . As such, there would be n o changes to the previously identified and evaluated energy impacts associated with HEU implementation. The identified changes in the Revised HEU would modify text of the HEU document, and as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA units. Adoption of the HEU would not, in and of itself, result in environmental impacts.

Under the Revised HEU, impacts would remain less than significant related to wasteful, inefficient, or unnecessary consumption of energy resources or a conflict with a state or local plan for renewable energy or energy efficiency.

For these reasons, the Revised HEU would not result in any new or different energy-related environmental impacts when compared to the Originally Adopted HEU.

3.7 Geology and Soils
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
VII. GEOLOGY AND SOILS – Would the project:
a) Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:

i) Rupture of a known earthquake
fault, as delineated on the most
recent Alquist-Priolo Earthquake
Fault Zoning Map issued by the
State Geologist for the area or
based on other substantial
evidence of a known fault? Refer to
Division of Mines and Geology
Special Publication 42.

ii) Strong seismic ground shaking?
iii) Seismic-related ground failure,
including liquefaction?
iv) Landslides?
b) Result in substantial soil erosion or the loss
of topsoil?
c) Be located on a geologic unit or soil that is
unstable, or that would become unstable as
a result of the project, and potentially result
in on- or off-site landslide, lateral spreading,
subsidence, liquefaction or collapse?

d) Be located on expansive soil, as defined in
Table 18-1-B of the Uniform Building Code
(1994), creating substantial direct or
indirect risks to life or property?

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New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
e) 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?

f) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning a ction represent an approximately 1.5% increase compared to the Originally Adopted HEU, which is not a substantial change. The changes identified in the Revised HEU would not change the total number of required RHNA units (i.e., 774) associated with implementation of the HEU. Further, while the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard) as having the potential to accommodate future lower-income RHNA units, subject to rezoning, this site is flat, previously graded, paved, and built-out with hotel uses . Any land use changes (i.e., zone changes resulting in an increase in allowable residential density) incorporating this parcel would be subject to future environmental review, as required under CEQA, once sufficient ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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information is made available. All sites identified in Table 16 of the Revised HEU were previously identified in the Originally Adopted HEU. Although the Revised HEU could result in additional streamlining for future multifamily projects, these projects would be located primarily on previously disturbed and/or graded infill parcels, which would help avoid potential impacts to geology and soils , and would continue to be subject to existing local, state, and federal regulatory requirements.

As outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA units, and adoption would not, in and of itself, result in environmental impacts. The Revised HEU would not result in changes to geology and soils associated with HEU implementation. Under the Revised HEU, impacts would remain less than significant related to known earthquake faults, seismic shaking, ground failure, liquification, lateral spreading, collapse, landslides, erosion, unstable soil, or expansive soils. For these reasons, the Revised HEU would not result in any new or different geology or soils-related environmental impacts when compared to the Originally Adopted HEU.

3.8 Greenhouse Gas Emissions
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
VIII. GREENHOUSE GAS EMISSIONS – Would the project:
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment?

b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of
reducing the emissions of greenhouse
gases?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and to tal acreage from 50.49 ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation progra m discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximately 1.5% increase compared to the Originally Adopted HEU, which is not a substantial change. The changes identified above would not change the total number of RHNA units (i.e., 774) associated with implementation of the HEU. As such, there would be no changes to the previously identified and evaluated greenhouse gas ( GHG) emission impacts associated with HEU implementation . The identified changes in the Revised HEU would modify text of the HEU document, and as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the C ity will go about providing adequate capacity for the future provision of RHNA units. Adoption of the HEU would not, in and of itself, result in environmental impacts. Under the Revised HEU, impacts would remain less than significant related to GHG emissions, or conflicts with an applicable plan, policy or regulation adopted for the purpose of reducing GHG emissions. For these reasons, the Revised HEU would not result in any new or substantially different GHG-related environmental impacts when compared to the Originally Adopted HEU.

3.9 Hazards and Hazardous Materials
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
IX. HAZARDS AND HAZARDOUS MATERIALS – Would the project:
a) Create a significant hazard to the public or
the environment through the routine
transport, use, or disposal of hazardous
materials?

b) Create a significant hazard to the public or
the environment through reasonably
foreseeable upset and accident conditions
involving the release of hazardous materials
into the environment?

c) Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within one-quarter
mile of an existing or proposed school?

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New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
d) Be located on a site that is included on a list
of hazardous materials sites compiled
pursuant to Government Code Section
65962.5 and, as a result, would it create a
significant hazard to the public or the
environment?

e) For a project located within an airport land
use plan or, where such a plan has not been
adopted, within two miles of a public airport
or public use airport, would the project
result in a safety hazard or excessive noise
for people residing or working in the project
area?

f) Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan?

g) Expose people or structures, either directly
or indirectly, to a significant risk of loss,
injury or death involving wildland fires?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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• Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximately 1.5% increase compared to the Originally Adopted HEU, which is not a substantial change. The Revised HEU would not change the total number of RHNA units (i.e., 774) associated with implementation of the HEU. Further, while the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard ) as having the potential to accommodate future lower -income RHNA units, subject to rezoning, this site is currently built-out with hotel uses. Any land use changes (i.e., zone changes resulting in an increase in allowable residential density) incorporating this parcel would be subject to future environmental review, as required under CEQA, once sufficient information is made available. All sites identified in Table 16 of the Revised HEU were previously identified in the Originally Adopted HEU. Although the Revised HEU could result in additional streamlining for future multifamily projects, these projects would be located primarily on previously disturbed and/or graded infill parcels, which would help avoid potential impacts related to hazards and hazardous materials, and would continue to be subject to existing local, state, and federal regulatory requirements.

The changes proposed by the Revised HEU would not result in hazards or hazardous material changes associated with implementation of the HEU. The Revised HEU changes would modify text of the HEU document, and as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA units, and adoption would not, in and of itself, result in environmental impacts. Under the Revised HEU, impacts would remain less than significant related to the routine transport, use, or disposal of hazardous materials; reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment ; and emissions or handling of hazardous materials near an existing or proposed school; significant hazards to the public or environment due to location on a hazardous materials site. There would continue to be no impact related to safety hazards or excessive noise near an airport, an adopted emergency response or evacuation plan, and wildland fires. For these reasons, the Revised HEU would not result in any new or different hazards and hazardous materials-related environmental impacts when compared to the Originally Adopted HEU.

3.10 Hydrology and Water Quality
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
X. HYDROLOGY AND WATER QUALITY – Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or ground
water quality?

b) Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the project
may impede sustainable groundwater
management of the basin?

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New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
c) Substantially alter the existing drainage
pattern of the site or area, including through
the alteration of the course of a stream or
river or through the addition of impervious
surfaces, in a manner which would:

v) result in substantial erosion or siltation
on- or off-site;
vi) substantially increase the rate or
amount of surface runoff in a
manner which would result in
flooding on- or offsite;

vii) create or contribute runoff water
which would exceed the capacity of
existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted runoff; or

viii) impede or redirect flood flows?
d) In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation?

e) Conflict with or obstruct implementation of
a water quality control plan or sustainable
groundwater management plan?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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• Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximately 1.5% increase in units compared to the Originally Adopted HEU, which is not a substantial change. The Revised HEU would not change the total number of RHNA units (i.e., 774) associated with implementation of the HEU. Further, while the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard ) as having the potential to accommodate future lower -income RHNA units, subject to rezoning, this site is almost entirely paved and built-out with hotel uses. Any land use changes (i.e., zone changes resulting in an increase in allowable residential density) incorporating this parcel would be subject to future environmental review, as required under CEQA, once sufficient information is made available. All sites identified in Table 16 of the Revised HEU were previously identified in the Originally Adopted HEU. Although the Revised HEU could result in additional streamlining for future multifamily projects, these projects would be located primarily on previously disturbed infill parcels, which would help avoid potential impacts related to hydrology and water quality, and would continue to be subject to existing local, state, and federal regulatory requirements.

The changes proposed by the Revised HEU would not result in hydrology and water quality changes associated with implementation of the HEU. The Revised HEU changes would modify text of the HEU document, and as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA units, and adoption would not, in and of itself, result in environmental impacts. Under the Revised HEU, impacts would remain less than significant related to surface or groundwater quality, sustainable groundwater management, alteration of existing drainage patterns, release of pollution due to inundation; or potential conflicts with a water quality control plan or sustainable groundwater management plan. For these reasons, the Revised HEU would not result in any new or substantially different hydrology or water-quality-related environmental impacts when compared to the Originally Adopted HEU.

3.11 Land Use and Planning
Revised HEU Impact Determination Table

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
XI. LAND USE AND PLANNING – Would the project:
a) Physically divide an established community?
b) Cause a significant environmental
impact due to a conflict with any land use
plan, policy, or regulation adopted for the
purpose of avoiding or mitigating an
environmental effect?

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Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

The changes proposed by the Revised HEU would not result in a new or substantially different land use and planning impacts associated with implementation of the HEU. As identified above, the six additional lower -income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximately

1.5% increase in units compared to the Originally Adopted HEU, which is not a substantial change. The Revised HEU would not change the total number of RHNA units (i.e., 774) associated with implementation of the HEU. Further, while the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard) as having the potential to accommodate future lower-income RHNA units, subject to rezoning, any land use changes (i.e., zone changes resulting in an increase in allowable residential density) incorporating this parcel would be subject to future environmental review, as required under CEQA, once sufficient information is made available. All sites identified in Table 16 of the Revised HEU were previously identified in the Originally Adopted HEU.

Although the Revised HEU would result in a dditional streamlining for future multifamily projects, these projects would be located primarily on infill parcels, and would be help bring the City into compliance with state housing law and SCAG’s Connect SoCal regional plan. Streamlining for multifamil y and/or affordable housing is currently permitted in the City, pursuant to state law and the previous (i.e., 2013-2021 or “5th Cycle”) Housing Element (City of Manhattan Beach 2014). Implementation of the Revised HEU would not constitute a substantial cha nge in streamlining policy as compared to existing conditions, or to proposed conditions analyzed under the Originally Adopted HEU. For these reasons, the Revised HEU would not result in any new or substantially different land use and planning-related environmental impacts when compared to the Originally Adopted HEU.

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3.12 Mineral Resources
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
XII. MINERAL RESOURCES – Would the project:
a) Result in the loss of availability of a known
mineral resource that would be of value to
the region and the residents of the state?

b) Result in the loss of availability of a locally-
important mineral resource recovery site
delineated on a local general plan, specific
plan or other land use plan?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and to tal acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

As there are no mineral resources in the City, the changes identified within the Revised HEU would have no impacts related to the loss or availability of a known or locally important mineral resource. As the proposed changes are not related to mineral resources, and as these resources are not present in the City, the Revised HEU would not result ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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in any new or different mineral resource-related environmental impacts when compared to the Originally Adopted HEU.

3.13 Noise
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
XIII. NOISE – Would the project result in:
a) Generation of a substantial temporary or
permanent increase in ambient noise levels
in the vicinity of the project in excess of
standards established in the local general
plan or noise ordinance, or applicable
standards of other agencies?

b) Generation of excessive groundborne
vibration or groundborne noise levels?
c) For a project located within the vicinity of a
private airstrip or an airport land use plan
or, where such a plan has not been
adopted, within two miles of a public airport
or public use airport, would the project
expose people residing or working in the
project area to excessive noise levels?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would r educe the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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• Add a brief analysis to each of the impleme ntation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

The changes identified within the Revised HEU would not result in changes to noise impacts associated with implementation of the HEU. While the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard) as having the potential to accommodate future lower-income RHNA units, subject to rezoning, this site is in an urban location and is currently built-out with hotel uses, which currently generates noise from sources such as cars and HVAC equipment. Further, any land use changes (i.e., zone changes resulting in an increase in allowable residential density) incorporating this parcel would be subject to future environmental review, as required under CEQA, once sufficient information is made available. The identified changes would modify text of the HEU document, and as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RH NA units, and adoption would not, in and of itself, result in environmental impacts. Under the Revised HEU, impacts would remain less than significant related to ambient noise levels or groundborne vibration or groundborne noise levels. There would continue to be no impact related to excessive noise in the vicinity of an airport or airport land use plan . For these reasons, the Revised HEU would not result in any new or substantially different noise-related environmental imp acts when compared to the Originally Adopted HEU.

3.14 Population and Housing
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
XIV. POPULATION AND HOUSING – Would the project:
a) Induce substantial unplanned population
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example,
through extension of roads or other
infrastructure)?

b) Displace substantial numbers of
existing people or housing, necessitating
the construction of replacement
housing elsewhere?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:

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• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and tot al acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximately 1. 5% increase in units compared to the Originally Adopted HEU, which is not a substantial change and would not result in substantial unplanned growth. The changes identified within the Revised HEU would not result in changes to the total number of RHNA units (i.e., 774) associated with implementation of the HEU. Further, while the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard) as having the potential to accommodate future lower -income RHNA units, subject to rezoning, this site, any land use changes (i.e., zone changes resulting in an increase in allowable residential density) incorporating this parcel would be subject to future environmental review, as required under CEQA, once sufficient information is made available. All sites identified in Table 16 of the Revised HEU were previously identified in the Originally Adopted HEU. Although the Revised HEU would result in additional streamlining for future multifamily projects, these projects would be located primarily on underutilized infill parcels, which would not displace substantial numbers of existing people or housing. Streamlining for multifamily and/or affordable housing is currently permitted in the City, pursuant to state law and the previous (i.e., 2013 -2021 or “5 th Cycle”) Housing Element (City of Manhattan Beach 2014). Implementation of the Revised HEU would not constitute a substantial change in streamlining policy as compared to existing conditions, or to proposed conditions analyzed under the Originally Adopted HEU. As such, there would be no substantial changes to the previously identified and evaluated population and housing impacts associated with HEU implementation.

The identified changes in the Revised HEU would modify text of the HEU document, and , as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA units. Adoption of the HEU would not, in and of itself, result in environmental impacts. Under the Revised HEU, impacts would remain less than significant related to unplanned population growth or the potential for displacement of people or housing. For these reasons, the Revised HEU would not result in any new or substantially different population and housing -related environmental impacts when compared to the Originally Adopted HEU.

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3.15 Public Services
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
XV. PUBLIC SERVICES
a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

Fire protection?
Police protection?
Schools?
Parks?
Other public facilities?
Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions w ithin Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

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As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximately 1.5% increase in units compared to the Originally Adopted HEU, which is not a substantial change as compared to the project conditions analyzed in the Final IS/ND for the Originally Adopted HEU. The changes identified within the Revised HEU would not result in changes to the total number of RHNA units (i.e., 774) associated with implementation of the HEU. Further, while the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard) as having the potential to accommodate future lower-income RHNA units, subject to rezoning, this site is in an urban area served by existing public services. Any land use changes (i.e., zone changes resulting in an increase in allowable residential density) incorporating this parcel would be subject to future environmental review, as required under CEQA, once sufficient informatio n is made available. All sites identified in Table 16 of the Revised HEU were previously identified in the Originally Adopted HEU. Although the Revised HEU would result in additional streamlining for future multifamily projects, these projects would be located primarily on underutilized infill parcels in areas already served by existing public service institutions and facilities . Implementation of the Revised HEU would not constitute a substantial change in streamlining policy as compared to existing condit ions, or to proposed conditions analyzed under the Originally Adopted HEU. As such, there would be no substantial changes to the previously identified and evaluated public services impacts associated with HEU implementation.

The identified changes in the Revised HEU would modify text of the HEU document, and , as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA units. Adoption of the HEU would not, in and of itself, result in environmental impacts. Under the Revised HEU, impacts would remain less than significant re lated to fire protection, police protection, parks, schools, or other public facilities. For these reasons, the Revised HEU would not result in any new or substantially different public services-related environmental impacts when compared to the Originally Adopted HEU.

3.16 Recreation
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
XVI. RECREATION
a) Would the project increase the use of
existing neighborhood and regional parks or
other recreational facilities such that
substantial physical deterioration of the
facility would occur or be accelerated?

b) Does the project include recreational
facilities or require the construction or
expansion of recreational facilities which
might have an adverse physical effect on
the environment?

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Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximately 1.5% increase in units compared to the Originally Adopted HEU, which is not a substantial change as compared to the project conditions analyzed in the Final IS/ND for the Originally Adopted HEU. The changes identified within the Revised HEU would not result in changes to the total number of RHNA units (i.e., 774) associated with implementation of the HEU. Further, while the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard) as having the potential to accommodate future lower-income RHNA units, subject to rezoning, any future zone change s affecting this parcel would require subsequent environmental review under CEQA. All sites identified in Table 16 of the Revised HEU were previously identified in the Originally Adopted HEU. Although the Revised HEU would result in additional streamlining for future multifamily projects, these changes would not constitute a substantial change in streamlining policy as compared to existing conditions, or to proposed conditions analyzed under the Originally Adopted HEU. As such, there would be no substantial changes to the previously identified and evaluated recreation impacts associated with HEU implementation.

The identified changes in the Revised HEU would modify text of the HEU document, and , as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA units. Adoption of the HEU would not, in and of itself, result in environmental impacts. Under the Revised HEU, impacts would remain less than significant re lated to use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. There would continue to be no impacts related to the construction or ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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expansion of recreational facilities. For these reasons, the Revised HEU would not result in any new or substantially different recreation-related environmental impacts when compared to the Originally Adopted HEU.

3.17 Transportation
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
XVII. TRANSPORTATION – Would the project:
a) Conflict with a program, plan, ordinance, or
policy addressing the circulation system,
including transit, roadway, bicycle, and
pedestrian facilities?

b) Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision (b)?
c) Substantially increase hazards due to a
geometric design feature (e.g., sharp curves
or dangerous intersections) or incompatible
uses (e.g., farm equipment)?

d) Result in inadequate emergency access?
Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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• Incorporate other administrative changes to fix minor grammati cal errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximatel y 1.5% increase in units compared to the Originally Adopted HEU, which is not a substantial change and would not result in substantial unplanned growth. The changes identified within the Revised HEU would not result in changes to the total number of RHNA u nits (i.e., 774) associated with implementation of the HEU. Further, while the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard) as having the potential to accommodate future lower -income RHNA units, subject to rezoning, any land use changes (i.e., zone changes resulting in an increase in allowable residential density) incorporating this parcel would be subject to future environmental review, as required under CEQA, once sufficient information is made available. All sites identified in Table 16 of the Revised HEU were previously identified in the Originally Adopted HEU. Although the Revised HEU would result in additional streamlining for future multifamily projects, these projects would be located primarily on underutilized in fill parcels and would need to be consistent with appliable zoning. As such, there would be no substantial changes to the previously identified and evaluated transportation impacts associated with HEU implementation.

The identified changes in the Revised HEU would modify text of the HEU document, and , as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA units. Adoption of the HEU would not, in and of itself, result in environmental impacts. Under the Revised HEU, impacts would remain less than significant related to a transit plan, program, ordinance, or policy, transportation system demands, transportation hazards, and/or emergency access.

For these reasons, the Revised HEU would not result in any new or different transportation-related environmental impacts when compared to the Originally Adopted HEU.

3.18 Tribal Cultural Resources
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
XVIII. TRIBAL CULTURAL RESOURCES
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a) Listed or eligible for listing in the California
Register of Historical Resources, or in a
local register of historical resources as
defined in Public Resources Code section
5020.1(k), or

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New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
b) A resource determined by the lead agency,
in its discretion and supported by
substantial evidence, to be significant
pursuant to criteria set forth in subdivision
(c) of Public Resources Code Section
5024.1? In applying the criteria set forth in
subdivision (c) of Public Resources Code
Section 5024.1, the lead agency shall
consider the significance of the resource to
a California Native American tribe.

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation progra m discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximately 1.5% increase in units compared to the Originally Adopted HEU, which is not a substantial change. The rezoning necessary to accommodate these units would still take place under a future, separate action. The Revised HEU would not change the total number of RHNA units (i.e., 774) associated with implementation of the HEU. Further, while the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard ) as having the potential to accommodate future lower -income RHNA units, ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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subject to rezoning, this site is previously disturbed and currently built-out with hotel uses. This site does not support any undisturbed terrain where an inadvertent TCR find or uncovering of burial remains would be likely to occur.

Although the Revised HEU could result in additional streamlining for future multifamily projects, these projects would be located primarily on previously disturbed infill parcels, which would help avoid potential impacts related to TCRs, and would continue to be subject to existing local, state, and federal regulatory requirements.4 The changes identified within the Revised HEU would modify text of the HEU document, and as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA and lower-income buffer units. Adoption of the HEU would not, in and of itself, result in environmental impacts. Under the Revised HEU, impacts would remain less than significant related to historic resources and/or TCRs, including burial artifacts and human remains. For these reasons, the Revised HEU would not result in any new or substantially different TCR-related environmental impacts when compared to the Originally Adopted HEU.

3.19 Utilities and Service Systems
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
XIX. UTILITIES AND SERVICE SYSTEMS – Would the project:
a) Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects?

b) Have sufficient water supplies available to
serve the project and reasonably
foreseeable future development during
normal, dry, and multiple dry years?

c) Result in a determination by the wastewater
treatment provider which serves or may
serve the project that it has adequate
capacity to serve the project’s projected
demand in addition to the provider’s
existing commitments?

d) Generate solid waste in excess of State or
local standards, or in excess of the
capacity of local infrastructure, or
otherwise impair the attainment of solid
waste reduction goals?

4 . Pursuant to California Health and Safety Code Section 7050.5 and Public Resource Code Section 5097.98, California law protects Native American burials, skeletal remains, and associated grave goods, regardless of their antiquity, and provides for the sensitive treatment and disposition of those remains.

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New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
e) Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs i dentified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and tota l acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximately 1. 5% increase in units compared to the Originally Adopted HEU, which is not a substantial change. The Revised HEU would not change the total number of RHNA units (i.e., 774) associated with implementation of the HEU. Further, while the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard ) as having the potential to accommodate future lower -income RHNA units, subject to rezoning, this site is in an urban area served by utilities. Any land use changes (i.e., zone changes resulting in an increase in allowable residential density) incorporating this parcel would be subject to future environmental review, as required under CEQA, once sufficient information is made available. All sites identified in Table 16 of the Revised HEU were previo usly identified in the Originally Adopted HEU. Although the Revised HEU could result in additional streamlining for future multifamily projects, these projects would be located primarily on infill parcels within existing service areas and with access to existing utility connections, which would help avoid ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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potential impacts related to utilities and service systems, and would continue to be subject to existing local, state, and federal regulatory requirements.

The Revised HEU changes would modify text of the HEU document, and , as outlined in the Final IS/ND for the Originally Adopted HEU, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA units, and adoption would not, in and of itself, result in environmental impacts. Under the Revised HEU, impacts would remain less than significant related to the relocation or construction of new or expanded stormwater drainage, electric power, natura gas, or telecommunications facilities; water supplies; wastewater treatment; and/or solid waste. For these reasons, the Revised HEU would not result in any new or substantially different utilities and service system-related environmental impacts when compared to the Originally Adopted HEU.

3.20 Wildfire
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
XX. WILDFIRE – If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency
response plan or emergency evacuation
plan?

b) Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks, and
thereby expose project occupants to,
pollutant concentrations from a wildfire or
the uncontrolled spread of a wildfire?

c) Require the installation or maintenance of
associated infrastructure (such as roads,
fuel breaks, emergency water sources,
power lines or other utilities) that may
exacerbate fire risk or that may result in
temporary or ongoing impacts to the
environment?

d) Expose people or structures to significant
risks, including downslope or downstream
flooding or landslides, as a result of runoff,
post-fire slope instability, or drainage
changes?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:

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• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation progra m discussions within Section 6 to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammatical errors, maintain internal consistency, and provided improved clarity for readers.

As the City is not located near any stat e responsibility area or within a VHFHSZ , the changes identified within the Revised HEU would have no impacts related to wildfire. Therefore, the Revised HEU would not result in any new or different wildfire-related environmental impacts when compared to the Originally Adopted HEU.

3.21 Mandatory Findings of Significance
Revised HEU Impact Determination

New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
XXI. MANDATORY FINDINGS OF SIGNIFICANCE
a) Does the project have the potential to
substantially degrade the quality of the
environment, substantially reduce the
habitat of a fish or wildlife species, cause a
fish or wildlife population to drop below self-
sustaining levels, threaten to eliminate a
plant or animal community, substantially
reduce the number or restrict the range of a
rare or endangered plant or animal or
eliminate important examples of the major
periods of California history or prehistory?

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New
Potentially
Significant
Impact
New Mitigation
is Required
No New/No
Impact
Reduced
Impact
b) Does the project have impacts that are
individually limited, but cumulatively
considerable? (“Cumulatively considerable”
means that the incremental effects of a
project are considerable when viewed in
connection with the effects of past projects,
the effects of other current projects, and the
effects of probable future projects.)

c) Does the project have environmental effects
which would cause substantial adverse
effects on human beings, either directly or
indirectly?

Revised HEU Analysis
As detailed in Section 2.3, the Revised HEU would continue implementation of the Originally Adopted HEU, including sites identified for the adequate sites program overlay. The Revised HEU would:
• Increase the number of lower -income RHNA units accommodated through a future rezoning action from 406 to 412 (which could still be accommodated among site previously identified in the Originally Adopted HEU);
• Add one new site to the adequate sites program overlay identified in Table 15, Potential Underutilized Sites for Overlay, of Appendix E of the Originally Adopted HEU; • Revise several sites and/or APNs identified in Table 15 and Table 16, Potential Buffer Rezone Sites for Lower-Income Units, of Appendix E of the Originally Adopted HEU, which would reduce the total capacity identified on potential underutilized sites from 1,018 units to 844 units (and total acreage from 50.49 acres to 42.75 acres) and increase the total capacity on potential buffer rezone sites from 26 to 115 (and total acreage from 3.96 to 8.47);
• Modify Program 3 of the Originally Adopted HEU to remove discretionary review requirements for multifamily projects that do not qualify for state density bonus law within the CL, CD, and CNE zones; • Add a brief analysis to each of the implementation program discussions within Section 6, Program Implementation, to identify and evaluate “contributing factors” to fair housing issues; and • Incorporate other administrative changes to fix minor grammati cal errors, maintain internal consistency, and provided improved clarity for readers.

As identified above, the six additional lower-income RHNA units in the Revised HEU required to be accommodated through a future rezoning action represent an approximatel y 1.5% increase in proposed units compared to the Originally Adopted HEU, which is not a substantial change. The changes identified within the Revised HEU would not change the total number of RHNA units (i.e., 774) associated with implementation of the HEU . Further, while ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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the Revised HEU identifies one additional site (i.e., 1700 North Sepulveda Boulevard ) as having the potential to accommodate future lower-income RHNA units (subject to rezoning), any future zone changes affecting this parcel would be subject to subsequent environmental review under CEQA. All sites identified in Table 16 of the Revised HEU were previously identified in the Originally Adopted HEU. Although the Revised HEU could result in additional streamlining for future multifamily projects, these projects would be located primarily on previously disturbed infill parcels, which would help avoid potential impacts to topics such as aesthetics, air quality, biological resources, cultural resources, hazards and hazardous materials, noise, public services, TCRs or transportation. Streamlined projects would also continue to be subject to existing local, state, and federal regulatory requirements.

As with the Originally Adopted HEU, the Revised HEU would not substantially degrade the quality of the environment, reduce habitat, cause habitat population decline, threaten plant and animal communities or substantially reduced the range of a species, or eliminate important examples of the major periods of California’s history or prehistory, and impacts w ould remain less than significant. As discussed in Sections 3.1 through 3.20 of this Addendum, impacts associated with the adoption of the Revised HEU would remain less than significant or would continue to have no impact. The Revised HEU itself would not exceed any significance thresholds or result in significant impacts in the environmental categories typically associated with indirect or direct effects to human beings, such as aesthetics, air quality, hazards and hazardous materials, noise, public servic es, or transportation. For these reasons, the Revised HEU would not result in any new or substantially different environmental impacts when compared to the Originally Adopted HEU.

The Revised HEU changes would modify text of the HEU document, and as discussed throughout this Addendum, the HEU is a policy document identifying how the City will go about providing adequate capacity for the future provision of RHNA units, and adoption would not, in itself, re sult in environmental impacts . Compliance with applicable land use and environmental regulations would ensure that environmental effects associated with the accommodation of future housing development under the Revised HEU would not combine with effects fr om reasonably foreseeable future development in the City to cause cumulatively considerable significant impacts.

Thus, cumulative impacts under the Revised HEU would remain less than significant. For these reasons, the Revised HEU would not result in any n ew or different cumulative environmental impacts when compared to the Originally Adopted HEU.

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4 References and Preparers

4.1 References Cited
City of Manhattan Beach. 2014. City of Manhattan Beach Housing Element 2013-2021. February 2014.

Accessed September 11, 2022.
https://www.manhattanbeach.gov/home/showpublisheddocument/16921/635434710882970000//.

City of Manhattan Beach. 2022. City of Manhattan Beach 6th Cycle Housing Element. August 2022. Accessed September 5, 2022. https://www.manhattanbeach.gov/home/showpublisheddocument/50649/ 637955913884070000.

HCD (California Department of Housing and Community Development). 2021. Affirmatively Furthering Fair Housing: Guidance for All Public Entities and for Housing Elements. April 2021 Update. Accessed September 5, 2022. https://www.hcd.ca.gov/community-development/affh/docs/ AFFH_Document_Final_4-27-2021.pdf

4.2 List of Preparers
City of Manhattan Beach
Talyn Mirzakhanian, Planning Manager
Dudek
Nicole Cobleigh, Senior Project Manager
Samantha Robinson, Environmental Planner

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56 Existing Zoning
Addendum to the Manhattan Beach Housing Element Update IS/ND FIGURE 1
Path: \\dudek.int\data\GISData\Projects\j1356201\DOCUMENT\CEQA SOURCE: City of Manhattan Beach
Potential Sites to Accommodate Lower-Income Shortfall and Buffer ADDENDUM TO THE CITY OF MANHATTAN BEACH GENERAL PLAN AMENDMENT: 6TH CYCLE HOUSING

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58 Appendix A
HCD Review Letter (June 3, 2022)

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

June 03, 2022

Bruce Moe, City Manager
City of Manhattan Beach
1400 Highland Avenue
Manhattan Beach, CA, 90266

Dear Bruce Moe:

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

Thank you for submitting the City of Manhattan Beach’s (City) housing element adopted March 22, 2022 and received for review on April 4, 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. In addition, HCD considered comments from Californians for Homeownership and Matthew Gelfand pursuant to Government Code section 65585, subdivision (c).

The adopted housing element addresses some statutory requirements described in HCD’s December 14, 2021 review; however, additional revisions are necessary to fully comply with State Housing Element Law (Article 10.6 of the Gov. Code), see enclosed Appendix.

For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), as the City failed to adopt a compliant housing element within 120 days of the statutory deadline (October 15, 2021), Program 2 (Adequate Sites) to rezone 406 units to accommodate the regional housing needs allocation (RHNA) must 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).

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. During the housing element revision process, the City must continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available while considering and incorporating comments where appropriate. Please be aware, any revisions to the element must be posted on the local government’s website and to email a link to all individuals and organizations that have previously requested

Bruce Moe, City Manager

notices relating to the local government’s housing element at least seven days before submitting to HCD.

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.

HCD appreciates the effort that the housing element team, provided throughout the course of the housing element review. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Tristan Lanza, of our staff, at [email protected]
.

Sincerely,

Paul McDougall
Senior Program Manager

Enclosure

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APPENDIX

CITY OF MANHATTAN BEACH

The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at http://www.hcd.ca.gov/community-development/housing-element/housing-element- memos.shtml. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at
http://www.hcd.ca.gov/community-development/building-blocks/index.shtml and includes the Government Code addressing State Housing Element Law and other resources.

A. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)

Integration and Segregation: While the element was revised to add trends, it must analyze patterns related to race across census tracts within the City. In addition, the element must analyze the census tract with a much lower income than the rest of the City including any local knowledge or contributing factors leading to fair housing issues.

Lastly, the element must analyze the familial status and contributing factors leading to the one census tract where 40-60 percent of residents live alone compared to less than 20 percent for the rest of the City.

Disproportionate Housing Needs including Displacement: While the element was revised to include an analysis of cost-burden and persons experiencing homelessness, the element must still address overcrowding and displacement. The element must include a regional analysis for overcrowded households (comparing the City to the region). In addition, the analysis must address patterns and trends for displacement including displacement due to investment, disinvestment, and disaster driven displacement.

Local Data and Knowledge and Other Relevant Factors: While the element provided local data on homeownership loans and “mansionization”, it should address the local voter initiative that limits multifamily developments. For example, the element could include a program that identifies potential remedies and modify and remove the constraint.

Goals, Priorities, Metrics, and Milestones: While the element highlighted programs that correspond to the contributing factors, goals and actions must create meaningful impact to overcome contributing factors to address fair housing issues. The element must be revised to add or modify goals and actions. Goals and actions must be significant and

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meaningful enough to overcome identified patterns and trends. Actions must have metrics and milestones as appropriate and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place- based strategies for community preservation and revitalization and displacement protection.

2. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)

Sites Inventory: While the element clarified compliance with the Surplus Lands Act in Program 30 and described the City owned sites in the inventory, the element must describe how and when the City will support development of City owned lands within the planning period in the sites identified for rezoning, including the Manhattan Country Club site which pursuant to third party correspondence, was recently sold to a national operator and maintains operation. In addition, the electronic sites inventory submitted with the housing element identified a much higher number of units for rezoning than what were included in the analysis section. The element and electronic sites inventory must be revised to include the same assumptions and programs should be added or modified as appropriate based on the outcomes of a complete analysis.

Realistic Capacity: While the element was revised to include two examples of residential development in commercial zones, it must provide additional support to address the likelihood of residential development in zones allowing 100 percent non-residential uses. For example, the element could indicate the number of applications received for 100 percent commercial development in comparison with applications for projects with a housing component in these areas.

Small Sites: The element was revised to include one example of a proposed project that has a total of 14 units with one affordable unit within the City and generally states that small sites have been developed in nearby cities to support feasibility assumptions of small site development. However, the element must provide specific examples of nearby cities with similar characteristics (e.g., sites with 0.06 acres) and affordability levels. To support the consolidation of parcels, especially for lower income, the element should provide information on the example projects such as the number of parcels consolidated, size of parcels before and after consolidation and affordability levels and relate them to the sites in the inventory (such as similar number of parcels consolidated into one site at similar affordability levels).

Suitability of Nonvacant Sites: While the element was revised to describe the methodology used to determine the additional development potential within the planning period for lower-income sites with existing zoning, it must include a similar analysis for candidate sites for rezoning. The element also states that building age is considered in identifying sites because it is correlated to housing conditions, but to further support the redevelopment potential of the sites identified, the element should also include

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information on structural conditions or other site specific factors such as whether the use is operating or marginal instead of solely relying on age for this factor. In addition, it is assumed that chosen sites will be consolidated due to trends, but there were only two pipeline projects used to identify trends and the projects do not have similar conditions to the sites identified (i.e. number of parcels being consolidated and similar affordability assumptions). Furthermore, the element states that there is owner and developer interest in the area of the Masonic Center but it should clarify whether there is owner and developer interest on the identified site or other nearby parcels. In addition, as stated above, the element must include additional information on the redevelopment potential of the Manhattan Country Club within the planning period.

While the element analyzes feasibility of nonvacant sites identified for lower income, the element must also analyze feasibility of development of nonvacant sites identified for moderate and above moderate sites, and the candidate rezone sites. The element must also commit to rezoning the sites identified to meet the lower-income RHNA shortfall and describe the feasibility of the sites (e.g., feasibility based on use or any expressed interest in redevelopment). Lastly, the element must describe the feasibility of sites identified as surplus, including feasibility of removing existing residential uses.

In addition, specific analysis and actions are necessary because the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households and any candidate sites for rezone. For your information, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period including identified rezone sites. (Gov. Code, § 65583.2, subd. (g)(2).) The subsequent adopted element must also include findings (e.g., adoption resolution) based on substantial evidence, or the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.

Accessory Dwelling Units (ADU): While the element was updated to reference Programs 1 and 19, it must still include supporting analysis for potential ADU production at levels higher than previous trends.

3. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures... (Gov. Code, § 65583, subd. (a)(5).)

Land Use Controls: While the element was revised to address some of the findings in the prior review, the analysis should address the height limit of 30 feet for all zones. The element should also discuss how residential developments can achieve maximum allowable densities with the restrictions and the inability to provide flexibility per the voter initiative, and whether there is a standard of higher heights outside the coastal

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zone. While the element states that the City does not feel that local voter initiative constrains affordable housing through density bonus, it should discuss the initiative as a constraint on all housing, including affordable housing not utilizing density bonus particularly as the City does identify a site in the RH zone covered by the voter initiative to accommodate a portion of the RHNA for lower-income.

Fees and Exaction: While this section was revised, there are fees listed in Appendix A that are not included in the analysis of fees in Table 9. The element must clarify how the table showing combination permit fees for multifamily interacts with the data provided in Table 9. In addition, the analysis should describe the $20,000 neighborhood overlay district application. Lastly, Appendix A identifies fees specifically for emergency shelters and reasonable accommodation application; a program must be added to remove both fees as they act as a constraint to the provision of housing for persons experiencing homelessness and persons with disabilities.

Local Coastal Program: While the element was revised to analyze constraint in permitting timeframes for single-family development, it must also analyze multifamily development. In addition, it must clarify whether coastal commission approval will be required for the one site identified for lower-income housing in the coastal zone.

Design Review: While this section was revised, the element must describe who approves the projects in the design overlay districts and describe the approval process.

Constraints on Housing for Persons with Disabilities: The element discusses licensed residential care facilities for both six or fewer or seven or more. The element must also describe how non-licensed facilities are allowed. For your information, zoning should simply implement a barrier-free definition of family instead of subjecting, potentially persons with disabilities, to special regulations such as the number of persons, population types and licenses. These housing types should not be excluded from residential zones, most notably low-density zones, which can constrain the availability of housing choices for persons with disabilities. Requiring these housing types to obtain a special use or conditional use permit (CUP) could potentially subject housing for persons with disabilities to higher discretionary standards where an applicant must demonstrate compatibility with the neighborhood, unlike other residential uses. Program 28 (Specialized Housing Types to Assist Persons with Special Needs) should describe in what zones will the facilities be allowed and clarify that they will be allowed in the same zones that allow residential care facilities for six or fewer persons.

B. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element... (Gov. Code, § 65583, subd. (c).)

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Programs must demonstrate that they will have a beneficial impact within the planning period. Beneficial impact means specific commitment to deliverables, measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation.

Deliverables should occur early in the planning period to ensure actual housing outcomes. Programs should be evaluated to ensure meaningful and specific actions and objectives. Programs containing unclear language (e.g., “evaluate”; “consider”; “encourage”; “as needed”, etc.) should be amended to include specific and measurable actions. For example, programs to be revised include but are not limited to, the following:

• Program 3 (Affordable Housing Streamlining): While the program was revised to remove discretionary requirements in the precise development plan for projects with six or more units that qualify for state density bonus law, the element must also remove the discretionary requirements for multifamily projects that do not qualify for state density bonus law.

• Program 28 (Specialized Housing Types to Assist Persons with Special Needs):

The program must include specific timing for the action related to revising the zoning code relative to residential care facilities.

2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory... (Gov. Code, § 65583, subd. (c)(1).)

As noted in Finding A2, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

• Program 19 (No Net Loss): While the element commits to revising ADU assumptions, the development and affordability assumptions should be monitored and modified if needed more than once in the planning period (e.g., every two years).

• Program 16 (Lot Consolidation Incentive): The program should be revised to state how often affordable housing providers will be noticed and whether proactive outreach will occur annually.

3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable

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accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)

As noted in Finding A3, the element requires a complete analysis of potential governmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. In addition, the element should be revised as follows:

• Program 22 (Parking): While Program 22 was revised to include other uses in addition to religious institutions, the program only commits to studying parking outside the coastal zone. The program should also address parking standards within the coastal zone. The program should also include a commitment to reduce parking standards that require two spaces per multifamily unit regardless of bedroom size.

• Program 18 (Multifamily Residential Development Standards and Streamlining in the Mixed-Use (CL, CD, and CND) Commercial Districts): While the timeframe was revised, the program must remove the CUP for all multifamily developments in the identified zones, not just projects that meet the requirements for a density bonus.

4. P romote 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... (Gov. Code, § 65583, subd. (c)(5).)

As noted in Finding A1, the element must include a complete analysis of affirmatively further fair housing (AFFH). Based on the outcomes of that analysis, the element must add or modify programs.