Redlands City Council
February 1, 2022

that required by individuals with intellectual disabilities; however, it does not include other handicapping conditions that are solely physical in nature.

Many developmentally disabled persons can live and work independently within a conventional housing environment. More severely disabled individuals require a group living environment where supervision is provided. The most severely affected individuals may require an institutional environment where medical attention and physical therapy are provided. Because developmental disabilities exist before adulthood, the first issue in supportive housing for the developmentally disabled is the transition from the person’s living situation as a child to an appropriate level of independence as an adult. In Redlands, the most commonly occurring disability amongst seniors 65 and older was an ambulatory disability, experienced by

18.5 percent of Redlands' seniors
The California Department of Developmental Services (DDS) supports approximately 330,000 children and adults with developmental disabilities and 41,000 infants at risk of developmental delay or disability throughout the state. Services are provided through state- operated developmental centers and community facilities, as well as through contracts with 21 nonprofit agencies called regional centers. The Inland Regional Center located in San Bernardino is the largest regional center in California providing services to more than 25,000 individuals with developmental disabilities in San Bernardino and Riverside counties. The regional center is a private, nonprofit community agency that contracts with local business to offer a wide range of services to individuals with developmental disabilities and their families.

Table 2-43 below summarizes persons with development disabilities in Redlands. Persons with development disabilities represent less than 0.7 percent of the city’s population.

TABLE 2-44: PERSONS WITH DEVELOPMENTAL DISABILITIES IN REDLANDS By Residence Home of Parent/Family/Guardian 466
Independent/Supported Living 56
Community Care Facility 21
Intermediate Care Facility 56
Foster/Family Home 10
Other 10
By Age 0-17 Years 619
18+ Years 273
Total 1,511
Source: SCAG Precertified Housing Data, 2021.

There are a number of housing types appropriate for people living with a development disability: rent subsidized homes, licensed and unlicensed single-family homes, inclusionary housing, Section 8 vouchers, special programs for home purchase, HUD housing, and SB 962 homes. The design of housing-accessibility modifications, the proximity to services and transit, and the availability of group living opportunities represent some of the types of considerations that are important in serving the needs of this gro up.

Incorporating ‘barrier-free’ design in all, new multi-family housing (as required by California and federal

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Fair Housing laws) is especially important to provide the widest range of choices for disabled residents.

Special consideration should also be given to the affordability of housing, as people with disabilities may be living on a fixed income.

LARGE HOUSEHOLDS
Large households are characterized as a special needs group because they require a greater number of rooms per dwelling unit to avoid overcrowding. In addition, many large households are low-income and cannot afford dwelling units with three or more bedrooms without paying more than 30 percent of their income for housing expenses.

According to the 2014-2018 ACS, 11 percent of households had five or more persons (approximately 2,705 households). In total, about 11 percent of all households in Redlands had fi ve or more persons in 201 9.

Thus, the vast majority of households over five were made up of related persons. In 2011, around 55 percent of large households in Redlands owned their own home. About 45 percent of large households are renters, primarily because they are lower-income and cannot afford to purchase a home.

The ACS also indicates that approximately 17 percent (2,479 units) of rental units had three or more bedrooms ( Table 2-44). The SCAG Certified Housing Data indicates there were 1501 large renter households (with five or more people) . While these could be family and non- family households, it is not relevant to address the needs of large households, as familial status is not included in the definition of a large household . Moreover, assuming that these households rent apartments with three or more bedrooms, large households in Redlands would inhabit approximately over half of the city’s rental units with three or more bedrooms.

While the preceding information indicates that housing for large households does exist in Redlands, available affordable units may be difficult to find. For example, a low-income five-person household would be able to afford a housing expenditure of $1,448 per month. According to the survey of Craigslist listings, the median rent for a three -bedroom unit in Redlands was $ 2,275. Given that there are households in Redlands that have even lower incomes, many large households may have difficulty finding housing in the city. A steady increase in household size since 1990 may be correlated with an increase in large families and low -income large families in need of subsidized housing as well as the increasing trend of multi- generational living arran gements. Moreover, as a group, large households have a higher incidence of overcrowding because it is more difficult to secure affordable rental housing of adequate size to meet a large household’s needs.

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TABLE 2-45: UNITS WITH THREE OR MORE BEDROOMS BY TENURE Number of Bedrooms Owner-Occupied Units Renter-Occupied Units Total Three bedrooms 6,374 1,509 7,883
Four bedrooms 6,369 252 6,621
Five or more bedrooms 1,124 155 1,279
Total 3+ bedrooms 13,867 1,916 15,783
Percent of Total 87.9 12.1 100
Source: 2019 American Community Survey.

EXTREMELY LOW-INCOME HOUSEHOLDS
Extremely low-income households are those with incomes less than 30 percent of the AMI. In 2019, t he AMI in San Bernardino County was $63,362, while the AMI in the City of Redlands was $74,839. An income under $26,000 is considered extremely low-income.

Extremely low-income households have disproportionate and unique housing needs when it comes to housing supply, cost, and size . An analy sis of household characteristics examin ing trends and the availability of resources is shown in Table 2-45.

Table 2-46: Extremely Low-Income Households experiencing Cost Burden or Overcrowding by Tenure
Cost-Burdened Overcrowding
Owner-Occupied 91.1% 2.6%
Renter-Occupied 83.05 14.7%
All 85.3% 11%
Source: HUD CHAS Data 2014-2018.

FEMALE-HEADED HOUSEHOLDS
The 2000 Census shows 1,823 female-headed households with children under 18, about 23 percent of all households with children. By 2010, this number had slightly decreased to 1,715, making up 23 percent of all households with children. By 2018, this number again slightly decreased to 1,683, making up 20 percent of all households with children. The Housing Authority of San Bernardino County reports the vast majority of the Section 8 households in Redlands are headed by women.

A large share of female -headed households with children are economically disadvantaged. Table 2-46 identifies that a significant number of female-headed households (primarily single mothers) were below the poverty level in 2011. There were approximately 54 percent more impoverished female-headed households as married couple families below the poverty level, even though the number of married couples was much greater. Although the percentage of all Redlands households below the poverty level was fairly low, about 28 percent of female-headed households with children were below the poverty level.

These households made up 13 percent of all female-headed households. These households have a need

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for low- cost housing, suitable for children located near schools and childcare. Innovative shared living arrangements that might include congregate cooking and childcare facilities would also be suitable.

TABLE 2-47: HOUSEHOLDS BELOW POVERTY LEVEL, 2020
Family/Householder
Percent of Total
Households
Total households in poverty. 1,373 5.7%
Female householder, no husband present.

With related children under 18 years. 477 3.0%
Source: 2019 American Community Survey.

THE HOMELESS
The SCAG defines the homeless as those "sleeping out" in makeshift shelters, in cars and under freeway overpasses, and those who are "at risk" of homelessness in that they are sharing housing on a temporary basis, are living in single-room occupancy hotels, or their Calworks or other general relief stipend has been canceled twice within one year because they had no forwarding address.

According to the 2020 San Bernardino County Homeless Count and Subpopulation Survey Report there were 3,125 persons who were counted as homeless in the county on Thursday, January 23, 2020. In Redlands a total of 186 homeless people were counted, the majority of which were unsheltered (141) persons. Of the unsheltered homeless population in Redlands , 55 percent were substance abusers, 32 percent were mentally ill, 8.4 percent were victims of domestic violence, 25 percent were persons released from jails or prison during the past 12 months, 62 percent were chronically homeless, 11 percent were youth under 18 years of age (unaccompanied by an adult), 50 percent were youth ages 18 to 24, and

8.4 percent were US veterans. In total, the Redlands homeless population makes up 3 percent of the county total.

TABLE 2-48: HUD 2020 CONTINUUM OF CARE SAN BERNARDINO COUNTY HOUSING INVENTORY COUNT Total Year
Round Beds
Seasonal
Beds
Overflow /
Voucher
Emergency, Safe Haven and Transitional
Housing
693 79 0
Emergency Shelter 483 79 0
Safe Haven 24 n/a n/a
Transitional Housing 186 n/a n/a
Permanent Housing 3,704 n/a n/a
Permanent Supportive Housing* 1,603 n/a n/a
Rapid Re-Housing 2,101 n/a n/a
Grand Total 4,397 79 0
Source: HUD 2020 Continuum of Care Homeless Assistance Programs Housing Inventory Count Report.

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Non profit Services
Several nonprofit organizations in and near Redlands attempt to address/assist the homeless on a daily basis. The majority of these organizations tend to focus on the homeless family. These entities include the Redlands Family Service Association, the Frazee Shelters, Inland Temporary Homes, Option House, and the Salvation Army. In addition, the 2-1-1 referral line operated by the Inland Empire United Way services the city.

Family Service Association provides transitional housing for families via rental assistance and shelter vouchers. Additionally, through the Housing Advocacy Program , Family Service Association provides emergency support, case management, and education to families and individuals in Redlands.

The Blessing Center provides free food and clothing to over 900 families each week. One large food box, worth in excess of $75 of quality food products, is distributed to each family once a week. Client families can shop for free clothing, baby care and other items, which are also available during food distribution.

The Blessing Center also provides client families with much needed medical and dental services by a team of doctors and nurses, dentists, and dental technicians. Services to homeless individuals and families include bagged lunches, clothing, hygiene items and other resources. Dinner for the Homeless is every last Wednesday of the month.

The Blessing Center’s Resource Center serves to assist job seekers in pursuing potential employment opportunities through resume writing, filling out employment applications, interview coaching and even providing proper clothing for job interviews. Classes in job training, E.S.L, G.E.D, and S.A.T. tutorial are also offered. A dedicated team of coaches and mentors are available to help clients obtain basic requirements such as an identification card, social security cards, etc.

The Frazee Shelters are part of a larger organization —the Frazee Community Center. The Community Center provides a wide range of services to low-income and homeless persons in the San Bernardino area.

Services include housing assistance, clothing, nutrition, as well as referral services. Frazee is a nonprofit corporation and receives funds from United Methodist Churches and other denominations as well as Arrowhead United Way, East Valley United Way, and the City and County of San Bernardino, City of Highland, City of Redlands. Frazee also receives grants and donations from individuals, corporations, and other organizations. Frazee operates three shelters — two veteran’s shelters for men in San Bernardino and one women’s shelter in Highland. In addition, Frazee offers a no-cost lunch to those in need during the weekdays.

Inland Temporary Homes operates a homeless shelter that provides housing to six families with a maximum stay of 90 days as well as transitional housing to 20 families (16 single family units and four attached units) with a maximum stay of two years. Inland Temporary Homes also provides various services including case management, career counseling, mental health counseling, and follow -up services for families that complete the shelter program but do not enter the transitional housing program.

Option House provides services to women and children who are victims of domestic violence. In addition to shelter services, Option House offers in -house classes, legal advisors, support groups, and treatment for a range of issues. The organization helps over 300 people in its shelter and over 200 with legal services.

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The Salvation Army provides the homeless (families, individuals with children, and women) with daily meals, day care, and some monetary assistance. In addition, they assist families with counseling, motel vouchers, money for gasoline, prescriptions, utility bills, and toiletries. Currently, the San Bernardino location provides 48 families with transitional housing ranging from 30 days to three years as well as 14 emergency shelter units that are made available on a day -to-day basis. The Redlands location is a cold weather shelter that operates December 31 to March 31 and has capacity for 52 individuals and families.

Central City Lutheran Mission is a cold weather shelter that operates during the months of Novem ber through April. The shelter provides meals and bedding to 72 men each night.

In addition to these local organizations, the Community Action Partnership provides a number of programs and services aimed at low-income and homeless populations.

The Inland Empire United Way runs a hotline for San Bernardino and Riverside Counties. Those who are in danger of homelessness or already homeless can call 2 -1-1 if they are in need of food, shelter, or assistance paying their rent and utilities. The 2 -1-1 service also makes referrals for animal care, disaster resources, help for elderly veterans, clothing, disability programs, low -cost child and medical care, job training, and governmental programs.

Public Programs
The housing and social service needs of homeless persons are as varied as their reasons for being homeless. These include unemployment, eviction, physical or mental illness, and substance abuse. Many homeless persons need counseling, employment assistance, and shelter. Some need only temporary, transitional shelter. Others may need only short -term financial assistance such as a loan for the first month's rent and security deposit.

The City of Redlands currently has no public programs for serving the homeless. The City, however, is able to have some impact upon availability of housing via its General Plan and related policies. As the problem of homelessness continues to grow statewide, City policy makers may need to consider potential public programs to assist with the homeless. Emphasis is currently aimed at assisting those agencies already in the community through financial assistance from CDBG funds. Currently, the City has allocated CDBG funds to Inland Temporary Homes and the Family Service Association of Redlands.

FARMWORKERS
The City of Redlands is known for its citrus groves which bring employment to agricultural workers in the area. The 2010 US Census indicated there were 176 residents of Redlands employed in the a griculture, forestry, and fishing industry, and in 2019 this population was estimated to be 128 people. Of the City’s 138 total jobs in the agriculture, forestry, fishing, and hunting industry, 55 may be considered full- time, year-round, non-seasonal positions. Agriculture, forestry, and fishing industry does not make up a large percentage of employment in the City; therefore, farmworker housing need can be met through general affordable housing programs.

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The most recent d ata from the US Department of Agriculture’s National Agriculture Statistics Service indicates that in San Bernardino County there are an estimated 2,246 people hired as farmworkers in the year 2017.2 Of these, an estimated 546 were migrant workers.

Pursuant to Health and Safety Code 17021.5 and 17021.6, farmworker housing for fewer than six individuals should be treated as a single -family home and not require a discretionary approval.

Agricultural employee housing with no more than 36 beds in a group quarters or 12 units designed for the use of a single household is permitted by right in agricultural land-use designations. Redlands’ code does not currently allow farmworker housing within its agricultural districts. Program 1.2-18 is included to amend the code to allow for farmworker housing within all agricultural zones throughout the City in compliance with the Employee Housing Act.

STUDENTS
The University of Redlands, located north of Interstate 10, has approximately 4, 931 students. About 65 percent of these (3,206) are undergraduates, the vast majority of whom live on campus. Undergraduates are only allowed to live off campus if they are married, their parents live in town, or if they have some other extenuating circumstance. The University has graduate programs in business and education, making up the remaining 3 5 percent (1,725) of the student body. M any of these students live in Redlands and seek rental units.

OVERCROWDING
The Census Bureau defines “overcrowding” as 1.01-1.50 persons per room and “extreme overcrowding” as 1.51 or more persons per room. Overcrowding typically results when either: 1) the costs of available housing with a sufficient number of bedrooms for larger families exceeds the ability to afford such housing, or 2) un related individuals (such as students or low -wage single adult workers) share dwelling units due to high housing costs. This can lead to overcrowded situations if the housing unit is not large enough to accommodate all of the people. In general, overcrowding—a measure of the ability of existing housing to adequately accommodate residents—can result in deterioration of the quality of life within a community.

Table 2-48 and Table 2-49 summarize the overcrowding status in the City. In 2000, 7 percent of the City’s occupied housing units were overcrowded. In 2011, according to ACS estimat es, this number had fallen to 4 percent, and in 2018 this number was remained approximately 4 percent.

In Redlands, 369 owner-occupied and 865 renter-occupied households had more than 1.0 occupants per room, which meets the ACS definition for overcrowding . About 67 owner-occupied households and 277 renter-occupied households had more than 1.5 occupants per room, which meets the ACS definition for severe overcrowding.

In 2000, according to Table 2-48, 4 percent of Redlands households were overcrowded and 3 percent were extremely overcrowded. By 2011, according to ACS estimates, 3 percent of households were

2 US Department of Agriculture National Agriculture Statistics Service, San Bernardino County:
https://quickstats.nass.usda.gov/results/5504D8CE-0FB5-35D3-A1A4-ECBEB702FCD2

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overcrowded and less than 1 percent were extremely overcrowded. And by 201 9, according to ACS estimates, 2 percent of households were overcrowded and another 2 percent were extremely overcrowded.

TABLE 2-49: OVERCROWDING: PERSONS PER ROOM
Persons
2000 2011 2018
Households Percent Households Percent Households Percent

1.00 or less 22,000 93% 23,362 96% 25,088 97%

1.01 to 1.50 873 4% 693 3% 441 2%

1.51 or more 796 3% 202 1% 389 2%
Sources: 2000 US Census, 2011 and 2019 American Community Surveys.

Note: 2019 data is approximate.

TABLE 2-50: OVERCROWDED HOUSING BY TENURE

San Bernardino County Redlands
Owner
Occupied
Renter
Occupied
Owner
Occupied
Renter
Occupied
Total: 386,204 252,443 16,172 9,745

0.50 or less occupants per
room
238,685 107,481 12,508 5,573

0.51 to 1.00 occupants per
room
125,456 107,301 3,486 3,523

1.01 to 1.50 occupants per
room
15,721 27,239 0 429

1.51 to 2.00 occupants per
room
5,197 8,737 178 220

2.01 or more occupants per
room
1,145 1,685 0 0
Source: 2019 American Community Survey.

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3 HOUSING RESOURCES & SITES INVENTORY

3.1 INTRODUCTION
The purpose of the adequate sites inventory and analysis is to identify specific sites suitable for residential development to allow for a comparison of the Regional Housing Needs Allocation (RHNA) with realistic development capacity. The RHNA is broken down by income group into four categories: very low (less than 50 percent of area median income [AMI]), low (50 -80% of AMI), moderate (8 1-120% of AMI), and above moderate (over 120% of AMI). While a jurisdiction must show that it has adequate sites in total to meet its RHNA, it must also show that it can meet the allocation at each of these income categories.

3.2 REGIONAL HOUSING NEEDS ASSESSMENT (RHNA)
A housing element must identify specific parcels of land that are available for residential development.

HCD guidance also states that the inventory can include sites that are in the process of being made available for residential development, “provided th e housing element includes a program that commits the local government to completing all necessary administrative and legislative actions early in the planning period.” The RHNA projection period for this Housing Element is from October 2021 to October 2029.

SCAG adopted its RHNA in March 2021 for the 6th Cycle Housing Element. The housing allocation is not a production requirement but illustrates the goals for each community to accommodate through appropriate policies and land-use regulations. Allocations are intended to ensure that adequate sites and zoning are made available to address anticipated housing demand during the planning period.

The City of Redlands’ share of the RHNA requirement for 2021-2029 is:

TABLE 3-1: RHNA ALLOCATION (2021-2029)
Very
Low Low Moderate Above Moderate Total
967 615 652 1,282 3,516

3.2.1 Buffer
Recent changes to state law have required cities to continually maintain adequate capacity in their sites inventories to meet their RHNA. In the event that a site is developed below the density projected in the element, or at a different income than projected, or that a site is developed with a nonresidential project, the City must have adequate sites available to accommodate the remaining balance of the RHNA, or it must identify and rezone for new sites that can accommodate the remaining need. For these reasons the City is including an additional buffer of 20 percent above the RHNA in each category. Redlands is planning to accommodate a total of 4,218 new units through its sites inventory to provide an adequate buffer to avoid and minimize the risk of “no net loss.”

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TABLE 3-2: RHNA WITH BUFFER
Very Low Low Moderate
Above
Moderate Total
RHNA 967 615 652 1,282 3,516
20% Buffer 193 123 130 256 703
Total with
Buffer
1,160 738 782 1,538 4,219

3.3 CREDITS TOWARD THE RHNA
Housing units that are approved, under construction, or developed with building permits issued after June 30, 2020, can be credited toward the 6th Cycle RHNA.

3.3.1 Entitled Projects
Projects that were approved but had not been issued building permits prior to July 1, 2021, are included in the RHNA as credits. The list of approved projects by income level is included in Table 3-3. In total, the City has recently approved 791 units (711 above-moderate units and 80 low -income units), which are expected to be constructed during the 6th Cycle production period.

TABLE 3-3: APPROVED UNITS
Project
Name Description Status
Number
of Units Income
Luxview
Apartments
328 unit apartment
complex on 21.8-acre
site.

Approved by City Council in
October 2019. Not yet built.
328 Above
Moderate
Bouye Tract
(TTM 20065)
29 single-family homes on

10.44 acres.

Approved by City Council in
September 2019. Not yet
built.
29 Above
Moderate
Liberty Lane1 Approved low-income
units. Developer stated
intent to maintain
affordability of units for
low income veterans,
particularly those needing
assistance.

Approved in 2017. Not Yet
Built.
80 Lower
Heritage
Specific Plan
207 above moderate-
income units.

Approved. Not yet built. 207 Above
Moderate
Casa Loma
Apartments
147 multi-family
residential units on 5.7
acres.

Approved. Not yet built. 147 Above
Moderate
Total 791
Source: City of Redlands, Development Services Department.

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The Liberty Lane Project is approved for 80 affordable units for low -income veterans. Multiple approvals, including the Conditional Use Permit, a Memorandum of Understanding between the Developer and US Veterans Initiative specify that the units are to remain affordable for lower-income veterans.

3.4 PENDING PROJECTS
In addition to projects that have already been approved, the City is currently processing entitlements for another 1,325 units. The City anticipates that these projects will be approved and constructed during the 6th Cycle planning period. The list of projects undergoing review is included in Table 3-4. These will be counted as above-moderate units.

TABLE 3-4: APPLICATIONS IN REVIEW
Project
Name Description Status
Number
of Total
Units
Citrus
Greens
Specific
Plan
20 units of age-restricted senior single-
family housing on 5 acres in a gated
community.

Application complete. 20
Bergamot
Specific
Plan
Subdivide the approximately 58 acres
into 317 single-family residential lots.

The project is divided into three
neighborhoods: Neighborhood 1 is
approximately 15 acres, has a
minimum lot size of 7,200 square feet
and contains 53 lots; Neighborhood 2
is approximately 12 acres, has a
minimum lot size of 3,500 square feet
and contains 144 lots; and
Neighborhood 3 is approximately 19
acres, has a minimum lot size of 1,900
square feet and contains 120 lots.

Entitlement in process. Not yet
approved.
317
Redlands
Mall
Transit-oriented development with
mixed uses (residential, retail, and
office) on 11 acres in downtown
Redlands.

Development proposed,
undergoing entitlement review,
not yet approved.
700
City Center
Mixed Use
Mixed use project with residential,
retail, and restaurant uses.

Development proposed,
undergoing entitlement review,
not yet approved.
138
The Grand
Apartments
Multifamily residential project
downtown near the train station.

Development proposed,
undergoing entitlement review,
not yet approved.
150
Total 1,325

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3.4.1 Redlands Mall Redevelopment
The Redlands Mall site is located within the City’s downtown core . It is ripe for redevelopment and is a prominent opportunity site for housing. It is approximately 11.15 acres in size and bounded by Redlands Boulevard (north), Orange Street (east), Citrus Avenue (south), and Eureka Street (west). T he project proposal includes an adjacent 1.1-acre parcel at the southeast corner of Citrus Avenue and Eureka Street for the proposed relocation of CVS Pharmacy, which currently holds a long-term lease at the Mall site.

Presently, the Mall site is limited to 18 dwelling units per acre (du/ac) and a maximum building height of three stories. The policy regulating these standards, Measure U, provides certain exceptions, one of which is to exempt “development directly related to proposed Metrolink/ Arrow light rail stations in the City of Redlands, including one at the University of Redlands .” The Mall site is approximately 650 feet south of the Santa Fe Depot train station at its closest point (with three routes of pedestrian access available along Third Street, Orange Street, and Eureka Street), and approximately 1,200 feet south of the Santa Fe Depot train station at its farthest point. The property at the southeast corner of Citrus Avenue and Eureka Street is approximately 1,300 feet south of the Santa Fe Depot train station at its farthest point, which is no more than one-quarter mile from the Metrolink/Arrow train platforms.

On May 18, 2021, the Redlands City Council adopted Resolution 8215 determining that a proposed mixed- use and transit -oriented development project for the Redlands Mall site and associated adjacent properties qualify for exemption from the Redlands General Plan provisions established by Measure U.

This decision enables the City to consider project entitlements that would exceed the 18 du/ac and 3 - story building height for high-density residential developments.

The development proposed for the Mall site includes the following components:
• Demolition of existing on-site buildings and improvements • Multiple mixed-use buildings with a n average of four stories, with actual heights ranging from three to five stories
• Up to 700 multi-family dwelling units (apartments and condominiums), to include live/work, studio, one-bedroom, two-bedroom, and three -bedroom units ranging between 475 and 1,500 square feet each
• A 6,000-square-foot recreational amenity building including pool • Up t o 73,000 square feet of commercial floor area on ground floors to include retail and restaurant uses, as well as a rooftop restaurant
• Up to 12,000 square feet of office space on upper floors • A pedestrian plaza totaling approximately 16,500 square feet on Third Street • A parking structure with 780 spaces on four levels aboveground level (i.e., approximately four stories high with rooftop parking on fifth level)
• Two subterranean parking structures
• Public and private open space areas to include landscaping, shade trees, street trees, and pedestrian improvements
• Related site improvements to include sidewalks, driveways, landscape, lighting, flood prevention, and public and private utility connections

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The proposal includes an extension of State Street westerly of Orange Street to reestablish its historical connection to Third Street. A new extension of Third Street (north -south) will reestablish a public street between Redlands Boulevard and Citrus Avenue. This will result in smaller blocks with shorter block lengths more amenable to pedestrian traffic (similar to the existing historical blocks along East State Street) and should also result in slowing motor vehicle traffic through the site.

The project will act as a catalyst for additional residential and mixed u se development downtown and demonstrates the desire and feasibility of achieving higher densities around the three train station sites in Redlands consistent with the community’s vision in the 2035 General Plan.

3.5 ACCESSORY DWELLING UNITS
State laws passed in 2017 and 2019 have legalized accessory dwelling units (ADUs) across California. Since these laws were passed, the City has seen increased interest and ADU construction. In 2017, the City issued two ADU permits, three in 2018, eleven in 2019, and fifteen in 2020. The significant growth in ADUs indicates that the City can reasonably expect increased ADU production above the 2020 rate through the duration of the cycle, especially since the COVID-19 pandemic essentially shut down most permitting and construction during the second quarter of 2020. However, for the purposes of the sites inventory, the City is utilizing an annual approval rate of 15 ADUs based on the most recent evidence in 2020. The most recent annual production rate of 15 ADUs indicates that a pproximately 120 ADUs will be constructed in the City over the 6
th Cycle. While the City’s average permitted ADUs from 2017 to 2020 was lower than 15, additional changes in state law in 2019 accelerated ADU production. The City experienced robust ADU permitting during 2021 at roughly 15 units. Production during 2020 and 2021 is most representative of the future production, given the similar regulations and growing homeowner interest.

To spur further production of ADUs, the City is including programs specifically designed to continue progress on ADU production. Programs 1.6 -1 will create a comprehensive ADU education campaign, providing easy, how-to guides for homeowners interested in ADUs, and direct promotion of ADUs and City assistance to residents. Program 1.6-2 will develop preapproved ADU plan sets that residents will be able to use for free, reducing the cost and time necessary to obtain an ADU permit. Pr ogram 1.6-3 will update the ADU ordinance to match the most recent changes in state law. Most importantly, Program

1.6-4 includes a commitment to carefully track ADU production by income, and to implement additional strategies or revise the RHNA estimates if production does not meet the expectations presented below.

The recent ADU production, resources, incentives, and contingency plan for lower production all demonstrate that the assumption of 15 ADUs per year is feasible and realistic for the 6 th Cycle.

Importantly, the City will meet its RHNA for all income levels without ADUs —the ADUs credited towards the RHNA demonstrate realistic expectations based on recent trend data . Additionally, the City is committing to monitoring its ADU permitting throughout the cycle. If the trends indicate that ADU production is significantly less than anticipated and additional sites are needed, the City will adjust its RHNA strategy as necessary to ensure that adequate sites are available for all income levels throughout the planning period.

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TABLE 3-5: RECENT ADU PRODUCTION
Year 2017 2018 2019 2020 2021*
ADUs Permitted 2 3 11 14 11
* As of June 1, 2021.

In December 2020, SCAG published a study estimating the affordability of ADUs in Southern California.

Table 3-6 illustrates the total ADUs anticipated by income category over the 6th Cycle, based on the SCAG ADU affordability analysis for San Bernardino County and a production rate of 15 ADUs/year.

TABLE 3-6: PROJECTED ADUS BY AFFORDABILITY
Income Level
Extremely
Low/Very
Low Low Moderate
Above
Moderate Total
Percent of
ADUs1

22.7% 34.8% 34.8% 7.7% 100%
Projected ADUs 27 42 42 9 120
Source: SCAG Regional Accessory Dwelling Unit Affordability Analysis. December 2020.

3.6 SITE CAPACITY ANALYSIS

3.6.1 Recent Developments and Project History
The City has experienced a variety of both single -family and multi-family residential projects in recent years. While many projects have been larger single -family tract homes developed through the City’s Planned Residential Development program (codified in Title 18, Zoning Regulations, of the Redlands Municipal Code), several multi-family projects have also been constructed or proposed.

3.6.2 Multi-Family Trends
The City allows multi- family development in its R -2, R -3, C -3, C -4, A -P (Administrative & Professional Office), and T (Transitional) zones. R -2 and R -3 are exclusively residential zones; no commercial or industrial development is allowed. The remaining zones allow for full commercial/office, full residential (in A -P and T zones), or mixed residential and commercial uses. While the City did not experience significant production of mixed-use residential during the 5 th Cycle, the anticipated Transit Villages Specific
Plan will catalyze redevelopment adjacent to the new Metrolink /Arrow light rail stations and incentivize new housing development in downtown Redlands.

The City has recently approved/permitted six multi -family developments totaling 830 units, achieving a range of densities and affordability levels (Table 3-7).

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TABLE 3-7: RECENT MULTI-FAMILY PROJECTS
Housing
Type
Project Name
&
Affordability Zoning
General
Plan Density
Acres
(Gross) Units
Yield
% Status
MFR HACSB SP 61
Affordable
Housing
SP61 MDR 15 19.2 228 79% Built
MFR Luxview
Apartments
Market Rate
Housing
EV/2500RM MDR 15 21.8 328 100% Approved
2019
MFR Villa Bonita
Condominiums
Market Rate
Housing
EV 3000 RM MDR 18 4.2 39 51% Built
MFR Brookside
Apartments
Market Rate
Housing
A-P Office 10 0.34 8 80% Approved
2019
MFR Liberty Lane
Affordable
Housing for
veterans,
individuals with
special needs,
and low-income
families
R-2 MDR 15 4.72 80 113% Approved
2017,
pending
financing
MFR Casa Loma
Apartments
Market Rate
Housing
Proposed R-
3 Proposed
HDR
Proposed
27 5.7 147 95.5% Approved
2021
Average
Yield

86.41 %

Two projects affordable to lower- income residents are identified in Table 3-7. The Liberty Lane project was approved in 2017 but has yet to be constructed. Liberty Lane took advantage of a density bonus to achieve a yield of 113 percent of the maximum allowed by the underlying zoning. The Housing Authority of the County of San Bernardino constructed 228 units of housing affordable to lower-income households in “Housing A uthority of the County of San Bernardino Specific Plan No. 61” and achieved a yield of 79 percent. Together, these affordable projects averaged a yield of 96 percent allowed by the zoning.

Overall, multi- family projects have average yields of 86.4 percent of the maximum allowed by the underlying zoning. While most of the recent multi -family developments have been at medium densities, the Casa Loma Apartments project, recently approved by City Council , has a higher yield at nearly 96

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percent. Based on these recent trends, the City presumes a realistic yield of approximately 80 percent of the maximum for sites in multi-family residential zones for the 6th Cycle sites inventory.

3.6.3 Tract Maps and PRD Trends
Most recent residential growth in Redlands has occurred through the City’s Planned Residential Development (PRD) permit process, which allows developers to achieve consolidated development in exchange for a comprehensive review and protection of natural and agricultural resources. PRD projects may achieve between 3 -6.5 units per acre (depending on the underlying zoning designation) and are required to preserve between 20 to 40 percent (depending on the underlying zoning designation) of the gross acreage for agricultural land, recreational open space, and/or natural resources areas. A review of recent PRDs found that these sites achieved an average yield of 75.9 percent. Several of the developments exceeded 80 percent of the potential yield, and the City will implement a policy review and constraint reduction programs to ensure that each of these PRD sites are developed at 80 percent of the maximum density.

Based on this trend and future policies, it is anticipated that future PRD growth will generally match 80 percent of the maximum allowed by zoning.

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TABLE 3-8: PRD DEVELOPMENTS IN R-E ZONE
Categor
y Project Zoning
General
Plan
Maximum
Density
(du/ac)
Acres
(Gross) Units
Yield
%
Statu
s

PRD TTM
19975
(Diversifie
d Pacific)
PRD R-E VLDR 3 24.9 67 89.7% Built

PRD TTM
16465
(Judson
Ranch -
West)

PRD R-E VLDR

3 30.4 61 66.9% Built

PRD TTM
16627
(Judson
Ranch -
East)

PRD R-E VLDR

3 12.1 20 55.1% Built

PRD TTM
18882
(Patterson
Ranch)

PRD R-E VLDR

3 9 26 96.3% Built

PRD TTM
15937
(University
Grove)

PRD R-E VLDR

3 61.27 164 89.2% Built

PRD TTM
18979
(Diversifie
d Pacific)

PRD R-E VLDR

3 32.3 55 56.8% Built

PRD TM 20079 PRD R-E VLDR

3 6.03 14 77.4% Built

Average 75.9
%

3.7 YIELD ASSUMPTIONS
TABLE 3-9: YIELD ASSUMPTIONS
Type Assumed Yield
Residential 80%
Nonresidential/Mixed-Use 50%

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3.7.1 Residential Zones
Pursuant to the analysis above, an estimated yield factor of 80 percent is assumed on residentially zoned land.

3.7.2 Mixed-Use Zones
The City allows residential development at 30 du/ac throughout its C -3, C-4, and A-P commercial zones (by reference to the R-3 density), as well as its Downtown Specific Plan (Specific Plan 45). Consequently, these zones can meet a substantial portion of the City’s lower-income RHNA.

Much of the City’s RHNA may be accommodated through mixed-use and nonresidential zones around the future Metrolink/Arrow light rail Stations, located near the Esri campus, Tri- City Center, downtown Redlands, and the University of Redlands. These mixed -use zones will allow for full residential development, a combination of residential and commercial, or full commercial development. While most incoming development is anticipated to be residential and mixed uses, it is possible that some sites will be developed for commercial uses, or otherwise below the maximum capacity. To account for this, the City is projecting yields in the mixed-use areas at 50 percent of the maximum allowed by the zoning.

3.8 DENSITIES AND AFFORDABILITY
Pursuant to state law, Redlands must plan for lower -income units on higher -density sites. Redlands is considered a Jurisdiction in a Metropolitan County and has a “default density” of 30 du/ac for lower - income sites. Therefore, all lower-income sites are located in zones that allow at least 30 du/ac.

To identify sites to accommodate the moderate-income capacity, the City used zones with densities between 12 du/ac and 30 du/ac. These zones support lower-intensity multi-family development, such as townhomes and garden apartments.

Above-moderate sites are located in zones that allow fewer than 12 du/ac. These zones typically support single-family developments.

TABLE 3-10: DENSITY AND AFFORDABILITY
Income Category Density (du/ac)
Above-Moderate 0-11
Moderate 12-30
Lower 30+

3.9 SIZE
Pursuant to state law, sites that are used to accommodate lower- income housing must be between 0.5 and 10 acres. The City also considered adjacent parcels less than 0.5 acres in size with common ownership as eligible to accommodate lower- income units. Whil e these individual parcels do not meet the size requirements, they collectively function as a single site and add up to over half an acre and would not require consolidation. Since the sites have common ownership, there would be no constraint or required

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parcel assembly in order to achieve the size of half an acre , which is presumed to be a realistic size for lower-income sites pursuant to state law. Additionally, the City can meet its lower-income RHNA without these sites, but they are included due to their high potential and likelihood of redevelopment during the near future.

Overall, the City has 46 sites smaller than 0.5 acres that can accommodate lower-income units. There are generally three clusters: within the Tri-City Center, in downtown Redlands, and around the University of Redlands. All of the small sites are adjacent to other lower -income sites, and have combined areas of at least half an acre, indicating that they are suitable for lower- income housing development. Additionally, these sites only accommodate 117 total unit s, and the City has significant excess capacity for lower- income housing elsewhere. However, given the adjacency, common ownership, and locations of these sites adjacent to jobs, amenities, and public services, these small sites are ideal locations for lower-income housing development. The small individual sizes of the parcels will not preclude or prevent any development of lower-income housing production. Finally, the City is including Program 1.1-8 to provide incentives for small site consolidation and development.

3.10 SITES INVENTORY
To meet the RHNA, the City has identified land available for residential development under existing and future zoning. The City will rezone land to provide for up to 4,219 units (RHNA + 20% buffer) within three years from the date of adoption . The proposed inventory includes additional capacity beyond what is necessary to meet the RHNA + 20% buffer. Some of the rezone candidate sites identified in the RHNA may not be rezoned or will be zoned differently than illustrated in the sites inventory based on the results of additional public engagement and environmental review. Regardless of any final decisions on the specific sites to rezone, Redlands will have adequate capacity to meet the RHNA for all income levels after rezoning within three years of Housing Element adoption.

3.11 SITE IDENTIFICATION CRITERIA AND PRIORITIZATION

3.11.1 Infrastructure
The City prioritized identifying sites in areas served by existing infrastructure. The sites either already have infrastructure service or are located close to other properties with existing services. Some infrastructure expansion may be necessary to accommodate the large numbers of units in the areas of the East Valley Corridor (west side of Redlands) or Lugonia Avenue (north side of Redlands). In these instances, infrastructure such as water, sewer, and dry utilities run along major roadways adjacent to potential sites and are av ailable to support new residential development . Recent projects across the City have demonstrated that minor infrastructure expansion is not a constraint to development, and the sites included in the inventory are appropriate for residential use. The only expansion necessary would be the extension of laterals to connect to the water and sewer mains, a standard and inexpensive component of nearly all housing construction. Due to the high quality and extensive coverage of the City’s infrastructure, infrastructure is not expected to constrain housing development on any of the RHNA sites.

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As seen in Figure 3-1, all of the RHNA sites have direct access to sewer infrastructure. The City’s water lines generally run parallel to the sewer infrastructure, demonstrating that the sites have adequate access, and any investment needed in extending laterals will be limited.

FIGURE 3-1: RHNA SITES AND SEWER INFRASTRUCTURE

3.11.2 Access to Jobs
The City contains or is adjacent to several job clusters. For example, the Esri campus is located in central Redlands. Esri is one of the City’s primary employers and provides well- paying jobs at different incomes.

Another employment center is the University of Redlands, which has jobs for academic and support staff.

Another employment area is the industrial/warehouse district in northwest Redlands and unincorporated County pocket. This area is home to a numbe r of distribution facilities, along with more traditional industrial and corporate/office uses. Finally, portions of the western city are close to Loma Linda University Medical Center (in the City of Loma Linda to the west), which are also sources of high- quality jobs. When developing the sites inventory, proximity to these employment centers was considered and contributed to the selection of the identified sites. The sites proposed for high -density housing and

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rezoning are all within close proximity to one or more of these employment centers, expanding access to opportunity for households at different income levels.

3.11.3 Environmental Constraints
The City has several environmental constraints that make certain areas challenging or less ideal for new housing development. In particular, high and very high fire hazard zones in the southern hills of the City create conditions that generally preclude these areas from significant new housing. The City’s growth is anticipated to take place around the new Metrolink stations (not in a high/very high fire zone), so the fire risk will not act as a constraint to achieving the housing on RHNA sites.

The City also has open space designated areas with sensitive habitat in the southern hills. The City did not plan for any housing on areas with known sensitive habitat, so habitat impacts are not expected to constrain or limit the development of any RHNA sites.

Significant portions of the City’s downtown are within a 100-year flood zone. The flood zone could impose a constraint in this area, but the City has seen several successful and proposed development s in and around downtown. Residential development is still allowed within the floodplain, provided that the residential spaces are located above the flood elevation. Achieving this typically involves minor grading and retaining walls to elevate finish floors 2 feet above the 100-year flood elevation, or by locating parking on the ground floor, as is typical in popular podium-style building typology (also known as Type 5 over Type 1 construction). A podium-style development is normally constructed with four or five wood-frame stories above a concrete podium (usually for retail or resident amenity space).

The downtown area will also be regulated by the TVSP, which will provide flexibility and other incentives for transit-oriented development, even within the floodplain. Moreover, the City has recently received three development proposals within the d owntown Redlands floodplain area containing multi- family housing components totaling approximately 950 units. For these reasons, the floodplain is not currently acting as a constraint to residential development as the demand to develop within the floodplain area is strong, and is not expected to act as a constraint in the future. Sites located within the floodplain are both feasible and appropriate for residential development due to proximity to transit, high -quality retail, employment, services, cultural amenities, and educational opportunities . Additionally, Program 1.2-16 will further remove governmental constraints from developments in the f loodplain, adding to the near - term viability of these sites.

3.12 RHNA SITE CLUSTERS

3.12.1 Transit Villages Specific Plan Area
The TVSP area is proposed to cover approximately 931 total acres in the City’s historic downtown, around the Esri campus, and adjacent to the University of Redlands. The TVSP will facilitate smart growth around the City’s three planned Metrolink/Arrow light rail stations by implementing a flexible, form -based code and allowing for high- density residential uses throughout the area. New developments will be able to achieve 30 du/ac in the proposed TVSP’s Village Center and Village General districts (which allow up to three or four stories high) , allowing eligible sites to be counted toward the lower- income capacity. The

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form-based code will create regulations that make it feasible to develop at higher densities such as 30 du/ac, ensuring that the assumed yield percentages are highly conservative and realistic.

The plan is expected to facilitate the recycling of older and less profitable commercial/industrial uses to mixed uses including high-density housing. Despite the entire area allowing for high-density housing, the City is only including properties that are considered “likely to develop” in the sites inventory. The low- income sites in the TVSP area include vacant lots, underutilized commercial properties, older single-family homes, and parking lots. Overall, the TVSP is anticipated to contain capacity for 1,364 housing units in the sites inventory.

3.12.2 East Valley Corridor Specific Plan (EVCSP) Area
The City has identified candidate rezone sites in the East Valley Corridor area. Currently designated for commercial, agricultural, and industrial uses, the City will consider rezoning several of these properties to accommodate capacity for lower-income and moderate -income households. Many of the rezone candidate sites are vacant or are being used for agricultural purposes with no permanent structures on- site. A few properties have single -family homes on site, and others are used for industrial storage. The sites identified in East Valley Corridor area are adjacent to multiple schools and parks and have excellent access to regional job centers, including the Esri headquarters and Loma Linda University Medical Center.

Additionally, these sites are accessible to the future Metrolink/Arrow light rail stations.

3.12.3 Tri-City Center Development
The Tri -City Center is located at 1380 In dustrial Park Avenue and is bounded by I -10 to the north, Tennessee Street to the east, Colton Avenue to the south, and Alabama Street to the west. This 39-tenant shopping center consists of inline spaces and pad buildings with expansive parking areas over approximately 50 acres (over multiple individual properties) . The Center, constructed in 1981, has experienced decline over the last two decades. In 2004, the Center was purchased by new ownership and plans were shared with the City in 2006 for a revitalizing program to reinvigorate the Center. 3 The economic recession stymied planned progress and the Center has remained underutilized. The development of the Citrus Plaza shopping center just north of the Tri -City Center within the unincorporated area known as the “doughnut hole” has drawn activity away from the Tri-City Center, with some tenants relocating to Citrus Plaza, or closing shop entirely.

There has been recent interest from developers to redevelop the Tri -City Center with a mixed -use residential/commercial concept. Based on the existing utilization of the Center and developer interest, the City has included 500 units from the Tri- City Center in the RHNA. This is substantially less than what would be allowed for the property under the d raft TVSP. The Tri -City Center would be able to accommodate these units by redeveloping only a portion of the site; existing operating uses would likely be able to remain while vacant buildings or underutilized surface parking could accommodate new housing development.

3 Redlands Daily Facts. https://www.redlandsdailyfacts.com/2006/02/07/new-name-new-look-for-tri-city-center/

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Most parcels in the Tri-City Center are between 0.5 and 10 acres, meeting the statutory requirements for lower-income RHNA eligibility. Six parcels have acreages smaller than 0.5 acres, but these sites all have common ownership, and are adjacent to other properties that ensures the cumulative acreage is greater than 0.5 acres. As these sites have adjacent common ownership, true lot consolidation/acquisition is not necessary for redevelopment, and the smaller sites will not add any constraint o r inhibit housing development for households at any income level.

3.12.4 Other Sites
The City has sites suitable for residential development elsewhere in the City. These consist of vacant lots that have existing zoning and infrastructure to support new housing development. Typically, these vacant lots are in single -family neighborhoods and can accommodate some of the above moderate -income RHNA.

3.13 NON-VACANT SITES ANALYSIS
State law presumes that non-vacant sites are subject to constraints based on the existing use, and findings are required to demonstrate the feasibility of non -vacant sites for housing. 4 This analysis may include a description of the existing use, market conditions, and previous redevelopment experience, as well as any new programs and incentives to promote reuse and redevelopment.

Importantly, if non -vacant sites are used to accommodate more than 50 percent of the lower -income RHNA, in addition to the detailed site-specific review, the City Council must adopt a resolution stating that existing uses on non-vacant sites are likely to be discontinued during the planning period.

Overall, the City can acc ommodate 1,760 units on vacant sites, including 682 lower-income units.

Combined with recently entitled projects (80 units) and ADUs (69 units), the City can accommodate more than 50 percent (831 of 1,582) of its entire lower-income RHNA without relying on use of non-vacant sites.

The City can fully accommodate its moderate- and above moderate-income units on vacant sites, ADUs, and approved/proposed projects. Therefore, the City is not subject to the required findings pursuant to AB 1397.

Despite the fact that the City can accommodate most of its RHNA on vacant sites, infill on non-vacant sites presents clear opportunities and capacity for additional residential development, particularly around the planned Metrolink/Arrow light rail stations. Overall, the City is anticipating over 1,961 units on non-vacant sites. Of these, 1,779 would be included as lower-income capacity due to the potential under the zoning.

Table 3-11 illustrates the distribution of the 3,721 identified units by the existing use and income.

4 Government Code Sections 65583.2(b) and 65583.(g)

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TABLE 3-11: IDENTIFIED SITES BY EXISTING USE
Income/Use Typology Lower Moderate
Above
Moderate Grand Total
Agriculture 550 550
Commercial and Services 549

549
Multi-Family Residential 7

7 Multi-Use Residential Agriculture 105

105
Parking Lot 31

31 Schools 28

28 Single Family Residential 614 77

691
Vacant 682 870 208 1,760
Grand Total 2,461 1,052 208 3,721
Most of the capacity on non -vacant sites is met through sites with existing single -family residential, commercial and services, and agriculture uses. Collectively, these sites can accommodate approximately 1,790 units of lower-income capacity. Other types, such as parking lots, multi-use residential agriculture, schools, and multi-family residential can accommodate 171 units.

3.13.1 Single-Family Residential
There are 16 sites (691 units) with existing single-family residential uses included in the inventory. These properties are all characterized by large lots (generally above 0.5 acres) with most of the property undeveloped. Some of these properties may also contain accessory uses, such as storage or agriculture.

While some of the properties appear to be well uti lized, a change in the zoning to allow high -density residential will make the existing uses significantly underutilized relative to the zoning potential. These sites have access to existing water, sewer, and dry utilities.

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Lower Income Sites 20,21,22,23,24
Lower Income Sites 20, 21, 22, 23, 24 are currently residential spaces each occupied by a single -family unit. The sites are located in the TVSP on Judson St and Stillman Ave. Each single -family unit takes up about 20 percent of the total si te it occupies, leaving substantial room for increased density and residential development. These residential sites are adjacent to multi-family, single-family, and mobile- home residential uses. Additionally, these sites are close to the University of Redlands and planned Metrolink/Arrow light rail station.

The sites are currently designated for
High Density Residential in the
General Plan at 30 du/ac. Three of the
parcels are larger than 0.5 acres,
indicating that they are suitable for
lower-income development. The
other two sites (23 and 24) have single
ownership and have a cumulative
acreage larger than 0.5 acres , also
making them suitable for lower-
income development . Given the
residential location, transit
accessibility, and high po tential for
increased development, th ese sites
are likely to be developed for housing
in the near term.

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Lower Income Site 28
Lower Income Site 28 is a group of five parcels with common ownership at 337 Cook St in the TVSP that contains a single building but is majority vacant space, rendering it prime for further development. This residential site is directly adjacent to multi -family developments and the University of Redlands, which make it likely to be redeveloped over the 6th Cycle. The site is currently designated for High Density Residential in the City’s general at 30 du/ac and will be included in the TVSP . The site is 1.6 acres and has a maximum capacity of 48 lower- income units, but a realistic capacity of 22 units. Given the residential location, transit accessibility, high potential for increased development, this site is likely to be developed for housing in the near term.

Lower Income Site 12
Lower Income Site 12 in downtown Redlands contains one single-family residence at 523 Ruiz St but is otherwise almost completely vacant. The site consists of 14 parcels (13 vacant) with common ownership, making the site eligible for low-income development. This site is currently zoned for commercial use but will be rezoned for multifamily residential at 30 du/ac as part of the TVSP. This site is adjacent to an existing
residential area and another site designated for
multifamily residential development in the upcoming
cycle, which combined with the underutilization of the
land makes it highly likely to be developed. The site is approximately 2.5 acres and has a maximum capacity of
77 lower-income units, with an assumed realistic capacity of 31 units.

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Moderate Income Site 21
Moderate Income Site 21 at 11030 Nevada St is
majority occupied by a parking lot and industrial
storage. The site is adjacent to a school and park, as
well as a newer multifamily complex. It is also near
an employment hub around the Loma Linda Medical
Center. The site is currently single family residential but has more potential for utilization and will be
rezoned to medium density . The site is 4.26 acres
and has a realistic capacity of 50 moderate-income units. Given the location near employment hubs and underutilization this site is likely to be developed for housing in the near term.

Moderate Income Site 23
Moderate Income Site 23 at 169 Alabama St is currently
occupied for single-family uses and is adjacent to an upcoming multifamily complex currently in construction direct ly to the south of the site. Most of the property is vacant/unused . The site is currently zoned industrial / commercial in the EVCSP but has significant residential potential and will be rezoned to medium density residential. The site is 2.3 acres and has a realistic capacity of 27 moderate-income units. Given the location near other multifamily developments and underutilization, this site is likely to be developed for housing in the near term.

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Above Moderate Income Site 25
Above Moderate Income Site 25 is at the corner of
Wabash Ave and E Colton Ave and is currently
completely vacant, rendering it prime for further
development. This site is adjacent to a commercial
strip and a large single -family residential
neighborhood, in addition to a school and a park,
making it likely to be developed in the 6th Cycle. The
site is currently designated for Low Density
Residential in the City’s General Plan. The site is 9.01 acres and has a maximum capacity of 54 above
moderate-income units, but a realistic capacity of 43
units. Given the residential location and high
potential for development, this site is likely to be
developed for housing in the near term.

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3.13.2 Agriculture
Four sites solely used for agricultural purposes are included in the sites inventory. These sites have existing citrus groves, but generally lack significant structures. In recent years, the City has seen many examples of agricultural uses discontinued and converted to residential, largely due to changes in the agricultural economy locally as well as the cost and difficulty associated with maintaining active groves in the area.

The agricultural sites in the inventory will be rezoned for high -density residen tial use, which will incentivize the conversion and development of housing. Additionally, the agricultural sites are located with close access to high-quality employment, schools, and the new Metrolink/Arrow light rail stations.

Lower Income Sites 41, 42, 44
Sites 41, 42, and 44 are currently used for the
Agricultural industry and are some of Redlands’
many sites for growing citrus trees. Site 41 is
currently residential with a single unit amidst
existing agricultural use. S ites 42 and 44 are
currently zoned for industrial use in the East Valley
Specific Plan , but will be used as mixed -use high
density residential at a density of 30 du/ac as a part
of the housing element implementation. Once the properties are rezoned to allow for high density residential uses, they will provide 426 units of realistic lower-income capacity. Additionally, these sites have access to existing sewer, water, and dry utilities that extend adjacent to the sites on Citrus Avenue and Iowa Street.

3.13.3 Commercial and Services
Nearly all of the sites with existing commercial uses are within the Tri- City Center, which is described in Section 3.12.3, above and below as aggregated Sites 5 and 6 . The Tri -City Center has had developers recently express interest in residential development, and could accommodate 500 lower-income units in the inventory.

The other 50 commercial units are located in downtown along Redlands Boulevard on three adjacen t parcels. One of the properties is owned by a residential developer who is waiting until the TVSP is adopted to propose a project. The other adjacent properties have a vacant restaurant building and vacant bank building. As there are no businesses currently operating on these properties, the existing uses will not act as constraints on development.

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Lower Income Sites 5 and 6 (Tri- City Center)
Sites 5 and 6 are
currently commercial
spaces home to a
shopping mall, an
indoor playground,
and a car dealership
located at the Tri -City
Center. This site is
primarily occupied by
surface parking lots,
with less than half of
the available land
developed. It is central
to a commercial area
with storage facilities,
restaurants, and shops,
making this location for
housing ideal for
access to community serving amenities. The site is currently zoned commercial in the City’s General Plan but will be rezoned to allow for mixed- use residential at 30 du/ac as a part of the TVSP . The included properties are approximately 33.5 cumulative acres and has a realistic capacity of 500 lower-income units.

Given the central location, transit accessibility, and underutilized conditions, as well as stated developer interest, this site is likely to be developed for housing in the near term.

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Lower Income Sites 7 and 16
Sites 7 and 16 are currently vacant
commercial spaces that were
previously occupied by a restaurant,
bank, and real -estate firm. The site is
in downtown Redlands, within the
TVSP on Redlands Blvd and Orange St.

These sites are each over 3/4 surface
parking lot which could be converted
or fully redeveloped int o a high
density residential use. It is central to
a commercial area with libraries,
restaurants, and shops, making this location for housing ideal for access to community serving amenities.

The site itself currently allows residential at 30 du/ac in the City’s General Plan and will be rezoned to higher intensity multi-family residential as a part of the TVSP. The sites are 1.85 acres combined and have a realistic capacity of 28 lower-income units. Given the central location, transit accessibility, and minimal existing development, this site is likely to be developed for housing in the near term.

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Lower Income Site 15
Site 15 currently homes a commercial
building at 120 W Redlands Blvd. The
existing building takes up the large
majority of the parcel with the
exception of a small surface parking lot.

It is central to a commercial area with
restaurants and entertainment, making
this location for housing ideal for access
to community serving amenities. The
site currently allows for residential at 30
du/ac, but will be rezoned to even
higher density through the TVSP . The
site is 1.47 acres and has a realistic
capacity of 22 lower-income units. Given the central location , existing vacancy, and future transit accessibility, this site is likely to be developed for housing in the near term.

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Lower Income Sites 7, 8, 9
Lower Income sites 7, 8, and 9 in the transit village contain one building on parcel 9 at 619 New York St but are
otherwise vacant. This site is currently zoned for
commercial use but will be rezoned for multifamily
residential through the TVSP. These sites have immediate proximity to both d owntown Redlands and the Esri
campus, making them excellent candidates for future
infill and transit oriented residential development.

Additionally, these sites are directly adjacent to the new Esri Metrolink Station at New York Street. These sites combined are 5.78 acres and have a maximum capacity of
173 lower -income units , with a realistic capacity of 86 units.

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Lower Income Site 13
Lower Income Site 13 in the transit
village contains one building at
535 W Stuart Ave but is otherwise
almost completely vacant. The
site consists of 14 separate
parcels, each smaller than 0.18
acres. The parcels have common
ownership, so complicated lot
acquisition or consolidation
processes would not be necessary to construct a project on the site. The site has a cumulative area of 2.07 acres, making it eligible to be included as a lower-income site. This site is currently zoned for commercial use but will be rezoned for multifamily residential at 30 du/ac as through the TVSP. This site is central to a commercial area with grocery stores, restaurants, and religious facilities, making this location for housing ideal for access to community serving amenities. The has a maximum capacity of 62 lower-income units, and a realistic capacity of 31 units. The underutilized nature of the existing use, along with excellent location, makes this site likely for residential development in the near term.

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3.13.4 Parking Lots
The inventory contains five parcels completely occupied by parking lots, which are expected to have capacity for 31 lower- income units. Of these, two are a part of the Tri -City Center. Another parking lot provided overflow parking for a movie theater, which has currently ceased operations, but may eventually resume use. The third lot consists of two parcels that provide overflow parking for a small commercial development on Ruiz Street. These parcels will all be upzoned with the transit villages, making residential development more a ttractive and feasible within the near future. Additionally, the lots included act as surplus/overflow, and are not the only parking options for the centers.

Lower Income Site 14
Lower Income Site 14 in the transit village is
currently a 1.56 -acre gated, unused parking
lot. The site is currently zoned for
commercial/industrial use but will be rezoned
to allow high density multifamily residential
through the TVSP . This site is central to the
downtown Redlands commercial core, with
excellent access to resta urants, medical
facilities, and planned transit. Based on the existing vacancy, new capacity through the TVSP, and proximity to community resources, this site is anticipated to be redeveloped during the 6th Cycle.

Lower Income Site 11
Lower Income Site 11 consists of four parcels. The two northern parcels are developed with a small, underutilized parking lot, and the southern parcels are vacant. The four lots are contiguous and have common ownership, and collectively add up to 0.61 acres, making them eligible for the lower-income RHNA. The site is located in d owntown Redlands, with excellent access to commercial amenities, employment opportunities, and the downtown Metrolink/Arrow light rail s tations. The property will be upzoned to allow for transit oriented development and multi -family residential through the TVSP. The site has a realistic capacity of 9 lower - income units and is likely to be redeveloped during the 6 th Cycle.

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3.13.5 Multi-Use Residential Agriculture
The City has one property considered “Mul ti-Use Residential Agriculture” which is anticipated to accommodate 105 units of moderate -income housing. The property is currently occupied by an existing citrus grove, single-family unit, and accessory agricultural storage. Based on the limited nature of existing improvements and high potential under proposed zoning, the existing uses are likely to be discontinued in favor of residential redevelopment.

Site 40
Site 40 is an existing Mixed -Use residential
and agricultural site at Citrus Ave and Iowa
St. which is majority agricultural land with a
single-family residence built in 1906. The
site is currently zoned for commercial
industry but will be rezoned for high density
residential for the Housing Element
Implementation. Given the proximity to
existing residential development and
schools, and underutilization of the land,
this site is likely to be developed for housing
in the near term. The site is not encumbered
by an Agricultural Preserve or Williamson
Act Contract. This site is directly served by existing wet and dry infrastructure services.

3.13.6 School
The sites inventory includes one school. It is an existing preschool, with a single small structure covering less than 10 percent of the site. Half of the property is vacant, and the balance has a lightly used surface parking lot. The property is close to the Esri campus and proposed Metrolink/Arrow light rail stations and is significantly underutilized. Based on the current conditions on the site and proposed zoning, the property is likely to be redeveloped during the 6th Cycle.

Lower Income Site 49
Lower Income Site 49 is currently a preschool with a large surface parking lot and unused vacant space located at 15 N Center St.

The site is currently designated high density residential in the City’s and will be included in the TVSP. The site is 1.88 acres and has a maximum capacity of 56 lower-income units, but a realistic capacity of only 28 units, which is highly conservative based on existing utilization and site condition. Given the location and minimal existing development, this site is likely to be developed for housing in the near term. This site is fully served by existing wet and dry infrastructure services.

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3.13.7 Multi-Family Residential
Lower Income Site 33
The City generally avoided including any type of multi-family residential in its sites inventory; however, it did include a single duplex with significant residential potential under the TVSP. The property is mostly undeveloped, with two units occupying approximately 20 percent of the site. It is anticipated that the site could accommodate seven additional units, which could likely be constructed without requiring any demolition of the existing building. Based on these considerations, the property is likely to add units during the 6th Cycle. Additionally, this property is adjacent to other vacant properties under the same ownership, making it a strong ca ndidate for lot consolidation and redevelopment. The property is 0.57 acres, making it eligible to be coun ted towards the lower -income RHNA. This site is directly served by existing wet and dry utilities.

3.14 ADEQUATE SITES
The City will have adequate capacity to meet its RHNA after rezoning, as shown in Table 3-12, which summarizes residential development potential for ADUs, pending projects, approved projects, and site capacity. The City has identified capacity for up to 2,610 lower-income units, most of which are included in the sites inventory (not including ADUs, entitled or pending projects). The City can accommodate 1,094 moderate-income units, which are also mostly met on sites in the inventory. The above moderate RHNA can be fully accommodated by recently entitled and pending projects, though the City identified additional eligible vacant sites to provide additional capacity and buffer if necessary.

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TABLE 3-12: ADEQUATE SITES
Income/Category Lower Moderate Above Total
RHNA (+20% Buffer) 1,898 782 1,538 4,218
Identified Sites 2,461 1,052 208 3,721
ADUs 69 42 9 120
Recently Entitled Projects 80

711 791
Pending Projects

1,325 1,325
Total Identified Capacity 2,610 1,094 2,253 5,957
Surplus 712 312 715 1,738

3.15 LOWER INCOME SHORTFALL
Under existing zoning, the sites currently accommodating lower-income development have a yield of approximately 155 units, creating a lower-income shortfall of 1,427 units. Sites that will be rezoned to accommodate the lower-income shortfall will be subject to by-right approval for projects with 20 percent or more housing for low and very low income households and will have minimum densities of 20 du/ac and allow a minimum of 16 units per site pursuant to GC 65583.2(h).

To accommodate the s hortfall, the City is relying both on mixed -use sites within the TVSP, as well as rezoning outside of the TVSP area. The City will upzone to provide for additional capacity for 1,376 units in the R-3 (residential only) zone. These 1,376 units account for more than 96 percent of the lower-income shortfall. Because more than 50 percent of the lower -income shortfall is met through residential (not mixed-use) zoning, the City is not required to establish minimum residential floor areas in the TVSP pursuant to GC 65583.2(h).

A list and map of all sites included in the inventory is included in Appendices A and B.

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3.16 FINANCING AND OTHER SUBSIDIES
The City, the County, and HACSB all provide funding and subsidies for the construction, acquisition, and rehabilitation of housing units for lower-income households in Redlands. Many of these programs capture funding from the state and the federal governments and administer the money for local tenants, owners, and developers of affordable housing.

3.16.1 City of Redlands

3.16.1.1 Mob ile -home Rent Stabilization
Mobile home parks built prior to October 1, 1981, are subject to rent stabilization, according to City Municipal Code Chapter 5.48. This policy covers three mobile home parks: Sylvan Mobile Estates, Orange Grove Mobile Estates, and Lugonia Fountains. Taken together, 500 housing units are covered.

Other mobile home parks in the City that are not covered by the Rent Stabilization policy are:
 Royal Trailer Park – 1409 W Redlands Blvd.
 Redlands Ranch – 1721 E Colton Ave.

3.16.1.2 Community Development Block Grant Programs
The City of Redlands is a Participating Jurisdiction in the County of San Bernardino’s CDBG and HOME Consortium. Program administration is provided by the County’s Department of Community Development and Housing with input from the City. The City receives an annual allocation of CDBG funds through the County each year.

CDBG funds are provided by HUD and are meant to be a flexible way of providing communities with the resources to provide suitable housing, improve livability, and enhance economic opportunity, with the provision of affordable housing being one of the program’s major goals. Eligible activities include acquisition, rehabilitation, homebuyer assistance, economic development, homeless assistance, and public services.

The City has implemented CDBG funding to make neighborhood improvements and fund service providers including:
 Alleyway Improvement Paving in CDBG Target Areas
 Removal of architectural barriers at various public city facilities (Americans with Disabiliti es Act [ADA] improvements)
 Sylvan Park restroom rehabilitation
 Funding to service providers:
o Family Service Association of Redlands
o YMCA of the East Valley

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o Inland Temporary Homes
o Boys and Girls Club
o San Bernardino Sexual Assault Services
o Steps 4 Life (Rapid Re-Housing Program)
In fiscal year 2020-2021, HUD allocated $427,405 in CDBG funds to the City of Redlands.

3.16.2 San Bernardino County
Despite the City’s eligibility for direct receipts of HUD money, the City passes much of its federal and state funding to the County for administration and distribution. The County works with the City in directing the use of these funds. For programs that provide assistance to eligible households who apply, such as rental and repair aid, the County relies on the City to advertise and direct local households to these programs.

3.16.2.1 Mortgage Revenue Bond Program
San Bernardino County sells bonds to finance the construction of affordable rental units throughout the County. Proceeds from the sale of the tax-free bonds (and sometimes taxable bonds) are used to provide loans at interest rates below market rate for the construction, acquisition, and/or rehabilitation of multifamily housing developments. A specified number of units are required to remain affordable to eligible, low-income households for a specified number of years after the initial financing is provided.

In recent years, this program has not been used much due to the low interest rates available in the marketplace, removing much of the cost benefit of using tax -exempt bo nds. However, an increase in interest rates or in tax rates would likely increase usage of the program. The County of San Bernardino Department of Community Development and Housing estimates that market interest rates need to rise above 5.5-6.0 percent for tax-exempt bonds to be attractive. Past usage of the program has resulted in 100 multi-family units supported by the bonds built in Redlands.

3.16.2.2 Emergency Solutions Grant (ESG) Program
ESG funds are used to provide shelter and related services to the homeless. The County distributes funds to agencies that operate shelters or provide hotel vouchers. Family Service Association of Redlands, which helps people stay in their homes by helping pay utilities, is one of the recipients of ESG grants.

According to the 2018-2019 CAPER, the County received $1,074,413 in ESG funds in fiscal year 2018-2019.

3.16.2.3 HOME Investment Partnership Program
The County’s HOME Grant is administered by the County of San Bernardino Department of Community Development and Housing.

The County uses HOME funds toward four different programs:

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1. Community Housing Development Organization (CHDO) Program. CHDOs are funded by the HOME Program, which is obligated to reserve 15 percent of its annual funding to support housing construction, acquisition, or rehabilitation projects by certified CHDOs. Redlands has two active CHDOs: Housing Partners I and Redlands Christian Home.

2. Rental Property Acquisition and Rehabilitation Assistance Program . This program provides low - interest loans to developers of rental properties, in order to allow them to acquire or rehabilitate existing housing units and make them available to low-income households.

3. Tenant Based (Rental) Assistance Program (TBA). The TBA Program assists qualifying households earning less than 50 percent of the AMI with rent payments on an ongoing basis, and may also provide one-time assistance toward a security deposit.

3.16.2.4 Neighborhood Initiative Program
This HUD-based economic development program consists of grants assigned to specific entities by the Congress.

3.16.2.5 San Bernardino County Rent Relief Program
As a result of the COVID-19 pandemic, San Bernardino County established the San Bernardino County Rent Relief Partnership, an emergency rental assistance program that will leverage more than $46.8 million in US Treasury funds to provide rental assistance to County residents impacted by the COVID-19 pandemic.

Payments from the program are based on 12 months of past due rent balance from March 13, 2020, and households must have an income at or below 50 percent of AMI.

3.16.2.6 Housing Authority of the County of San Bernardino HACSB administers the Housing Services programs, which include the Housing Choice Voucher and the Five-Year Lease Assistance programs. At present, HACSB owns 120 housing units in the City of Redlands.

Housing Choice Voucher Program
The Housing Choice Voucher program is a rental assistance program that helps very low-income families to live in market -rate housing units rather than public housing. Households are provided with vouchers that are paid to private market-rate landlords, who are then reimbursed by HUD. In addition to the regular voucher program, HACSB administers special housing programs. These programs include the Veterans Affairs Supportive Housing (VASH) Program, Mainstream Program, Housing Opportunity Persons with Aids (HOPWA), and Shelter Plus Care.
 The VASH Program is for homeless veterans with severe psychiatric or substance abuse disorders.

HACSB and Veterans Administration Medical Center (VAMC) have partnered to provide rental vouchers and supportive services to eligible veterans. The veteran must demonstrate to the VAMC that he/she is homeless (has been living outdoors, in a shelter, in an automobile, etc.) before being evaluated for this program.

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 The Mainstream Program is designed to provide assisted housing to persons with disabilities to enable them to rent suitabl e and accessible housing in the private rental market. Mainstream applicants are offered a voucher as allocations become available.

Participants must be participating in programs of rehabilitation and/or support services within the community that are directly related to their disability.  HOPWA was established by HUD to address the specific needs of persons with HIV/AIDS and their families. HACSB has partnered with Foothill AIDS Project to offer rental assistance and supportive services to individuals with HIV/AIDS. Participants are given housing choice vouchers and ongoing assistance with medical and emotional needs.
 The Shelter Plus Care Program was designed to contribute to the countywide public/private partnership system to strengthen services available to homeless families and individuals. Families are referred to HACSB by the Department of Behavioral Health and must comply with supportive service providers. Linking affordable housing to resources and services ranging from job training, health care, day care, and education allows the tenants an opportunity to attain economic and social independence.

Term-Limited Lease Assistance Program
Implemented in 2012, the Term -Limited Lease Assistance Program provides non -elderly/non-disabled households with a five -year term limit on rental assistance —hardship exemptions are available.

Designated staff is available to provide coaching and refer families to supportive services and employment opportunities. Families assisted by this program include new non-senior/non-disabled households pulled from the Tenant-Based Voucher Rental Assistance Program waiting list; port -in households; and certain households that move out of certain Project-Based Voucher housing programs.

Project-Based Voucher Program
The Project-Based Voucher Program provides rental assistance to households living in specific housing sites. Because the rental assistance is tied to the unit, a family who moves (voluntarily or through eviction) no longer qualifies to receive housing assistance. The Housing Authority administers different waiting lists by bedroom size for each project-based housing site. These housing sites are either multi-family or senior housing developments. At this time, there are 553 housing units utilizing the Voucher Program in the City of Redlands.

Steps 4 Life Community Services- Transitional Supportive Housing Steps 4 Life is a public service project that provides various services to low and moderate income persons, including people who are homeless. The total project budget is $13,106. The City of Redlands will use $12,200 for project implementation and $906 for Activity Delivery Costs incurred by San Bernardino County.

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Pilot Homeless Programs
Administered by HACSB, families receiving rental assistance from more than one year can apply The Housing Authority has the following pilot homeless programs. Homeless individuals and families are referred to these programs through the County’s Coordinated Entry System.  No Child Left Unsheltered - Focuses on housing street homeless families with children. Goals are to improve educational and well -being of the children and economic advancement of the parent(s).
 Golden Apartments - Permanent supportive housing site for homeless individuals/families.

Golden Apartment residents are housed using the Housing First approach which is a model that connects homeless individuals to permanent housing without preconditions to entry.  Desert Haven Apartments - Permanent supportive housing site for homeless individuals/families.

Desert Haven Apartment residents are housed using the Housing First approach which is a model that connects homeless individuals to permanent housing without preconditions to entry.

Public Housing Program
The Public Housing Program—also known as the Affordable Housing Program—provides rental assistance to households living in housing units that are owned and managed by the Housing Authority. At this time, the Housing Authority does provide any public housing in the City of Redlands.

Home Ownership Preparation and Education (HOPE) Program Administered by HACSB, families receiving rental assistance from more than one year can apply for HOPE, which includes classes and aid toward assisting with home ownership. Subsidies include a voucher to help meet monthly home ownership expenses and a deduction on mortgage loan interest.

3.16.2.7 CALHFA Mortgage Assistance Corporation
The California Housing Finance Agency Mortgage Assistance Corporation (CalHFA MAC) is a nonprofit corporation separate from CalHFA. CalHFA MAC was created specifically to receive and disburse federal funding to qualifying California homeowners as part of the “Keep Your Home California” program.

Keep Your Home California is a federally funded program to help California homeowners struggling to pay their mortgages due to financial hardships. California has received nearly $2 billion in federal funding and works with housing counselors, servicers and housing advocates to provide assistance that will help prevent avoidable foreclosures. Funding is currently available through 2017. There are four types of assistance under the Keep Your Home California program including: (1) Unemployment Mortgage Assistance, (2) Mortgage Reinstatement Assistance, (3) Principal Reduction, and (4) Transition Assistance.  Unemployment Mortgage Assistance Program. Provides mortgage assistance of up to $3,000 per month for unemployed homeowners who are collecting or approved to receive unemployment benefits from the State of California’s Employment Development Department (EDD).

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 Mortgage Reinstatement Assistance Program. Provides funding of up to $25,000 to help qualified homeowners catch up on their mortgage payments.
 Principal Reduction Program. Provides financial assistance to help pay down the principal balance of a mortgage loan and allow for a more affordable monthly payment.  Transition Assistance Program. Provides financial help to make a smooth transition into stable and affordable housing.
4 CONSTRAINTS

4.1 GOVERNMENT CONSTRAINTS
The Redlands General Plan and Zoning Ordinance establish locations where housing can be built and identify housing density, lot size, setbacks, and required site improvements. These land use controls can be viewed as constraints in that they determine the amount of land to be developed for housing and establish a limit on the number of units that can be built on a site.

4.1.1 General Plan Policies & Ballot Measures

4.1.1.1 Growth Management Ordinance
The Growth Management Ordinance grew out of the first growth management voter initiative, Proposition R, which Redlands voters passed in 1978. The Growth Management Ordinance is located in Title 19 of the Redlands Municipal Code and was included in direct response to the ballot measures.

4.1.1.2 Annual Development Limitation and Recent Growth Proposition R was amended by Measure N (a zoning ordinance) in 1987; this policy restricts the development of residential dwelling units to 400 units a year within the city, and the extension of utilities to 150 units per year outside the existing city limits (within the Sphere of Influence, and therefore in the County of San Bernardino’s jurisdiction). Of the 400 units within the city, 50 are, by resolution, reserved for single family homes, duplexes, triplexes and four-plexes on existing lots; the remainder are allocated on a point system (adopted as Ordinance No. 2036), which emphasizes design amenities. (This point system is described in the Residential Development Allocation section that follows.) However, as noted in the State Law Preemption section below, these provisions have been rendered null and void while SB 330 is in effect. The City Council adopted Resolution 8082 in 2020 suspending enforcement of the annual building permit limit as long as SB330 is in effect.

Measure U, adopted by the voters in 1997, further articulated growth management policies. This General Plan Amendment reinforced and modified certain provisions of Measure N, adopted Principles of Managed Growth, and reduced the development density of San Timoteo and Live Oak canyons by creating a new land use category: Resource Preservation. This particular aspect of Measure U has a negligible effect on the ability of the City to accommodate future residential development because it concerns an area of

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the city with steep hillsides, natural resources, limited utility infrastructure, and other conditions that would limit the development potential of this part of Redlands, regardless of governmental controls.

In addition, under Measure U, no land designated by the General Plan as Urban Reserve as of June 1, 1987, is to be re-designated for a higher density than the R -E designation as the same existed on June 1, 1987 unless specified findings are made by a four -fifths vote of the City Council. The slowing of population growth in the City (see Table 2-1: Redlands Population Since Incorporation 1888-2020) coincides with the implementation of Measure U. While these occur simulta neously, it is not likely that Measure U was responsible for the slowing growth. Other factors such as the Great Recession and its effect on the housing market and the maturing of the City likely played a more significant role in slowing population growth.

Regardless, provisions limiting growth have a negative effect on the provision of housing across income levels.

4.1.1.3 Density and Super Majority
Measure U limits high -density residential land uses to 27 dwelling units per gross acre (du/ac) of development and requires a City Council supermajority (4/5) to approve any proposed developments in excess of 18 du/ac, or with heights in excess of 2.5 stories or 35 feet. Additionally, Measure U specifies required findings that the developments provide “substantial and overriding economic or social benefits to the City.”
The supermajority vote and required findings could potentially create a significant constraint on the development of lower - and moderate-income housing, much of which would fall between 12 -30 du/ac (townhomes and garden-style apartments). However, no residential projects have been denied based on inability to achieve a 4/5 vote. Nevertheless, as detailed in Program 1.1-2, the City will be evaluating this along with other provisions of Measure U for consistency with recent changes in state housing law.

4.1.1.4 Level of Service
Measure U also specifies that a level of service (LOS) of C is required for new developments and that in areas already below a LOS C, no new development may be approved that worsens the LOS. Another part of the measure (5.20c) requires that development proposed for an area already below a LOS C is required to improve the LOS to a LOS C.

The requirement that a proposed development in a congested area mitigate all existing traffic could potentially create a significant barrier for redevelopment in the urbanized core . However, the City has established a process by which residential projects in the core, the most transit-rich area of the City, can apply for an exemption from Measure U, which effectively removes this constraint. This exemption process is discussed in more detail in Section 4.1.1.8 below (Meeting the RHNA Under Measure U).

The City will be evaluating this requirement in Program 1.1-2, which will evaluate all Measure U provisions for consistency with state housing law.

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4.1.1.5 Socioeconomic Cost/Benefit Study
Measure U requires that a socioeconomic cost/benefit analysis (SCBS) be prepared for discretionary projects and projects involving structures larger than 5,000 square feet. City staff have an economic model that is used for this analysis. The fee assessed for this analysis is relatively small ($3,265) and minimal staff time is required to analyze a project using the economic model. No proposed housing project has been denied based on the outcome of its SCBS analysis.

For the above reasons, the SCBS does not pose a significant constraint on new development. Residential development that has been determined to be exempt from Measure U pursuant to the process outlined in Section 4.1.1.8 below is not subject to this requirement. Nevertheless, the City will be evaluating this requirement in Program 1.1-2, which will evaluate all Measure U provisions for consistency with state housing law.

4.1.1.6 Housing Type Balance
Measure U also amended the Redlands General Plan Land Use Element to “plan for” a housing mix of 75 percent single-family and 25 percent multi-family dwelling units at buildout. The City Council has adopted a clarifying resolution of this policy that further adjust s these numbers by determining that “for -sale” condominiums (which are considered multi -family dwellings by the Census and the Department of Finance) will be considered single-family dwellings for purposes of maintaining the Housing Type Balance.

The City Council has requested that staff monitor the housing mix periodically and provide reports to the City Council. Staff evaluated and prepared a report to the City Council based upon data as of June 4, 2019.

It was found that as a result of development activity that the 75/25 housing mix ratio was being achieved.

The report identified the housing mix to be 74.31 percent single family and 25.69 percent multifamily as of 2019. According to City staff, no new development has been recorded that would significantly affect the housing mix ratio reported in 2019.

However, meeting current RHNA requirements at the densities allocated for low- and very low-income housing could cause the Housing Element to come into conflict with the General Plan Land Use Element if the Housing Type Balance shifts to accommodate new housing units accommodated under the 6th Cycle RHNA. While the City is only required to “plan for” a housing mix of 75 percent single -family and 25 percent multi-family dwelling units, this legislative discrepancy can be a potential constraint.

The Growth Management Ordinance, more so than the 75/25 ratio, could limit development. Government Code Section 65589.5 5 stipulates that low- and moderate-income housing may not be constrained in a way that makes it infeasible (such as through design review or growth management regulations), unless:
the project is not necessary to meet the city’s RHNA; it would have specific negative impacts on health and safety; it is infeasible due to state or federal law; it is proposed on a site zoned for agriculture, resource preservation, or lacking utility infrastructure; or if it is inconsistent with the zoning and land use designation defined in the Zoning Ordinance and General Plan, respectively. The City could not, therefore,

5 Report E-5; California Department of Finance.

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reject an application for a low- or moderate-income housing development on the basis that the City would exceed the planning ratio of 75 percent single family to 25 percent multifamily.

Furthermore, the 75/25 ratio is not meant to be applied to individual development projects, but rather is a broad planning goal the City has as it conducts long -range planning, such as preparing specific plans. It has never been used as a consideration in review of individual applications, nor has it been presented as information in staff reports for development projects consistent with General Plan and zoning designations. Furthermore, the precise ratio will always change and fluctuate slightly as development projects and housing units are built throughout the city. Since Meas ure U was adopted in 1997, it has never been the basis of denying a multi-family project. Additionally, the ratio is a planning target used to guide the General Plan’s land uses, but will not prevent the City from effectively planning for its RHNA.

Therefore, this Measure U requirement is a potential constraint on housing. City staff will continue to monitor the ratio of single -family units to multi- family units. Please see Program 7.1 -7 in Chapter 7 for further clarification of the 75:25 ratio.

The City will be evaluating this requirement in Program 1.1-2, which will evaluate all Measure U provisions for consistency with state housing law.

4.1.1.7 No Environmental Impact
Measure U requires a finding that “the proposed density increase will not cause adverse environmental impacts, either individually or cumulatively, directly or indirectly.” This requirement does not include any qualifier of “significant” and is virtually impossible to meet, literally given that all projects will have some form of impact. This finding also is in conflict with the California Environmental Quality Act (CEQA) and does not acknowledge that significant adverse impacts can be mitigated or allowed subject to findings of overriding consideration. In practice, the City has relied on the environmental documentation prepared under CEQA to make this finding, accepting mitigation measures identified in the project Mitigated Negative Declaration. It is unclear how the City would make the finding when significant and unavoidable impacts are present.

Residential development that has been determined to be exempt from Measure U pursuant to the process outlined in Section 4.1.1.8 below is not subject to this requirement. Nevertheless, the City will be evaluating this requirement in Program 1.1-2, which will evaluate all Measure U provisions for consistency with state housing law.

4.1.1.8 Meeting the RNHA Under Measure U
The growth management system constrains Redlands’ ability to accommodate its RHNA. During the eight years of the RHNA projection period (2021 to 2029), 3,516 units would need to be accommodated, or about 440 units per year for Redlands to meet its RHNA. This development rate would not be feasible with the Measure U limit of 400 units per year within City limits (plus unlimited additional SRO and congregate care facilities). However, t he City Council adopted Resolution No. 8082 to suspend the Residential Development Allocation program while SB 330 is in effect ; therefore, during the time that SB 330 is in

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effect (through at least 2030) , there is no 400-unit limit or competitive evaluation system. Thus, Resolution No. 8082 eliminates any impact on the City’s ability to meet its RHNA caused by Measure U or the Residential Development Allocation program.

The Redlands City Council took steps to meet the City’s allocation by determining that congregate care and single room occupancy (SRO) units will not count against Measure U’s limitations as long as group dining facilities and a meal program are provided. City staff has defined SRO units as one-room apartments without kitchen facilities although an SRO ordinance has not be en adopted by the City at the time of preparation of this Element
Measure U, moreover, could potentially restrict the City’s ability to meet its housing needs obligations, and restricts multi-family housing development through the requirement of a 4/5 vote of the City Council for densities above 18 du/ac or housing products greater than two and half stories in height. Additionally, the 75 percent single family to 25 percent multi- family ratio identified in the City’s General Plan via Measure U would, in theory, preclude the City from meeting its RHNA. Therefore, during the time that SB 330 is in effect (likely through 2030), the City is not obligated to track/monitor the 75/25 ratio target, so as to eliminate any impact on the City’s ability to meet its RHNA.

Measure U provides for an exemption for development “directly related” to the three rail stations being developed and scheduled to open in Redlands in 2022: the New York Street station near the Esri campus, which is the City’s largest employer; the do wntown station; and the University of Redlands station. If a development project is determined to be exempt from Measure U, then the development is not subject to the aforementioned requirements. This exemption process includes a determination by the City Council that a proposed development is “directly related” to the rail station. In making this determination, the City Council has utilized the following two criteria:
• The project site is located within one-quarter mile of a transit station and a clear pedestrian route is available from the project site to the transit station; and • The project provides residential units at a density of a minimum of 20 units per acre.

The City Council has recently approved exemptions to Measure U for three residential projects in the downtown that will provide over 950 residential units.

4.1.2 State Law Preemption

4.1.2.1 Housing Crisis Act
The Housing Crisis Act (SB 330/ Government Code Section 66300 et seq. and 65589.5) significantly curtails the authority of local governments to delay, deny, or reduce the density of housing projects that comply with objective standards. Additionally, until 2030, the law supersedes local growth management ordinances that limit the number of units that can be permitted or constructed. From SB 330:
“(E) Notwithstanding subparagraph (D), an affected county or affected city may enforce a limit on the number of approvals or permits or a cap on the number of housing units that can be approved or constructed if the provision of law imposing the limit was approved by voters prior to January 1, 2005, and the affected county or affected City is located in a predominantly agricultural county. For the purposes of

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this subparagraph, “predominantly agricultural county” means a county that meets both of the following, as determined by the most recent California Farmland Conversion Report produced by the Department of Conservation:
i. Has more than 550,000 acres of agricultural land.
ii. At least one-half of the county area is agricultural land.

Any development policy, standard, or condition enacted on or after the effective date of this section that does not comply with this section shall be deemed void.” The above section directly overrides the 400 unit/year limit, as well as the Residential Development Allocation point system used to prioritize the proposed projects until 2025. The Housing Crisis Act also supersedes the single family to multifamily unit ratio, as this in effect creates a cap that will not allow the City to achieve the RHNA allocation.

Additionally, the potential bill SB 8 (2021) could extend SB 330’s provisions until 2030.

4.1.3 Urban Growth Boundary
The City does not have an adopted urban growth boundary, but the growth management policies limit development outside of city boundaries. The City of Redlands is roughly 36 square miles. The City’s Sphere of Influence extends east of the city, spanning nearly 45 square miles, but excludes a 1,100-acre “island” of unincorporated county land in the northwestern portion of the City. 6 (The City provides services to this
area in exchange for a 90 percent share of sales tax revenues.) Proposition R, as amended, allows 150 dwelling units per year within the SOI (but outside city boundaries) to apply for annexation. Although the City may only regulate development wit hin its boundaries, the San Bernardino County General Plan policies commit the County to support annexation of land designated for urban development.

4.1.3.1 City Design and Preservation
The City has established a number of design and preservation policies to improve the livability of Redlands.

To a large extent this involves design and not necessarily additional cost to the developer. Additional time in designing developments is generally offset by the quality of the end project. Still, it is recognized that additional time for preparing a project and amenities added to a project to meet the design standards may add to the housing costs, and thus serve as a potential constraint.

Under the 1995 General Plan update, the City has a City Design and Preservation Element. Under the 2017 General Plan update, that element was removed and the entire General Plan restructured. The policies in the Livable Community chapter of the General Plan (Land Use Element) describe the City’s priorities within specific communities and, as a result, where future residential development is and is not appropriate.

While some of these policies are implemented via ordinance, others follow from the General Plan itself.

The Livable Community chapter includes specific land use designations meant to limit development in environmentally sensitive areas such as in and around San Timoteo Creek. City design policies specifically

6 The Island was removed from the City’s Sphere of Influence several years ago as a result of Assembly Bill 1544, which was sig ned into law by Governor Gray Davis in 2000.

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seek to preserve agricultural land, particularly Redlands’ iconic citrus groves; however, there are very few protections for privately owned groves/orchards within the City limits. As a result, much of the City’s newer development in N orth Redlands has occurred on former citrus groves . Moreover, the land use designations work synerg istically with the City design policies to protect valuable land. For example, in Crafton (within the SOI), citrus groves are protected through the Rural Living General Plan land use designation that permits up to one unit per 2.5 gross acres on slopes under 15 percent and one unit per 5 gross acres on slopes 15 percent or greater.

Some policies within the General Plan are intended to protect the unique character of existing neighborhoods. Future development in the San Timoteo/Live Oak canyons area is limit ed in order to maintain the “backcountry” character of the area while also protecting sensitive habitats and landscapes and having the additional benefit of limiting development in a very high fire hazard area. By prohibiting grading of canyon walls, exceeding 50 percent slopes and protecting “signature ridges,” the policies in the General Plan and the Southeast Area Plan limit opportunities for residential growth. Similarly, a housing conservation overlay district was applied in parts of South Redlands in order to maintain existing scale and character where homes and neighborhoods have been identified and registered as local areas of historical significance. In addition to older established neighborhoods, historic structures and districts are also protected within the General Plan through ordinances that require Historic and Scenic Preservation Commission review and only permit designs, and uses that preserve their character and amenities. While these requirements create potential constraints on the producti on of housing, they are essential to preserve the City’s historic character and high quality of life.

Properties in h istoric districts or having been individually designated as historic must first obtain a Certificate of Appropriateness prior to obtaining a building permit. This process increases the amount of time between application and permit issuance; however, it also helps to maintain the iconic character of historic Redlands’ neighborhoods. City staff aids applicants and guides them through design and materials selection. The City also administers the Mills Act program to reduce costs for property owners in historic districts.

While review of projects in historic districts does require consideration by the Historic and Scenic Preservation Commission, the City has recently demonstrated its commitment to weigh the need for housing over community character. In December 2021, the City Council voted unanimously to approve a small subdivision on a historic citrus grove that is home to a Victorian grove house.

To mitigate the impact of these policy requirements, policies to reduce processing time (Programs 7.4- 5 and 7.4-10), and, where possible, increase density of projects (Programs 7.2 -10 and 7.9-1) have already been adopted to provide for lower -cost housing and to lessen the potential financial impact caused by design considerations. Furthermore, some of the General Plan policies listed below, under “Historic and Scenic Preservation,” could potentially aide in the preservation of affordable housing units in the city’s historic neighborhoods as several large historic homes have been converted into multi-family apartments.

4.1.4 Zoning Ordinance Requirements
The City has established standards for each of its residential zoning districts. Zoning requirements can serve as a constraint to housing production by limiting or prohibiting various types and styles of

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development. However, the lot size, unit density, height, lot coverage, setbacks, open spaces, design review, and parking standards are decided upon to ensure a certain quality of life for residents within and adjacent to a development.

4.1.4.1 Residential Zoning Districts
Table specifies development standards for various residential zones. If conflicts with the zoning criteria arise (generally with development applications), the City evaluates standards in different, comparable zones. As a standard or set of standards is found to be inappropriate, it is reevaluated and amended to reflect current needs (see Program 7.4-6).

The City permits mobile homes in all of its residential zones subject to a plan check and the requirement the mobile home is situated on a permanent foundation. Mobile home parks are permitted subject to the granting of a conditional use permit. As of March 2021, the city contained approximately 764 mobile homes.
7 Mobile homes are a reliable source of affordable housing and the City has a rent stabilization policy for mobile home parks.

The City has a second unit ordinance (Chapter 18.156, Article VII (Second Residential Dwelling Units) that is preempted by state law. These secondary units are independent units on existing single -family lots.

About 13 second units per year were built during the last year. To better promote the option of creating second units amongst homeowners, the City will continue its public awareness campaign of promoting ADU development in the City, as well as adopting an ADU Ordinance to guide the development of ADUs within the City. (See Program 7.1-6).

7 Based on Redlands’ Parcel Data (ExistingUnitsField).

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TABLE 4-1: CITY OF REDLANDS: RESIDENTIAL ZONING CLASSIFICATIONS Zoning District
Min
Lot
Size
(sf
unless
noted)
Dwelling
Units
per Acre
Max Lot
Coverage
Min
Width
Min
Depth
Max
Height
Min Yards (feet)
Front Side Back
Rural Residential
(R-R/R-R-A) 1 acre 1 10 125 125

2.5 stories
or 35
feet
25 10 25
Residential
Estate
(R-A/R-A-A)
20,000 2 20 100 120
Residential
Estate (R-E) 14,000 3 25 100 120
Suburban
Residential (R-S) 10,000 4 30 85 100
Single-Family
Residential (R-1) 7,200 6 30 60 100
Single-Family
Residential
(R-1- D)
8,100 10 35 50 160 25 5 25
Multiple-Family
Residential (R-2) 8,000 14 45 80 100 25 5-
10 25
Multiple-Family
Residential
(R-2- 2000)
12,000 17-222 45 100 120 3
stories3 25 5-
10 25
Multiple-Family
Residential (R-3) 10,000 272 60 80 120 4
stories3
15-
25 5-
10 25
Source: City of Redlands Municipal Code.

1. Density calculated from minimum lot size and dwelling units per lot and rounded down to nearest whole number up to what is permitted by the 2035 General Plan.

2. A 4/5 majority of the City Council is required to approve projects with densities above 18 du/ac.

3. A 4/5 majority of the City Council is required to approve projects with proposed height above 2.5 stories or 35 feet.

Minimum Lot Size Requirements
As shown in Table 4-1, minimum lot sizes for the R -2, R-2-2000, and R-3 multifamily residential districts are 8,000, 12,000, and 10,000 square feet, respectively. While these minimums are quite low and do not typically limit development on smaller lots, minimum lot sizes act as potential constraints on development of small multi-family projects.

Additionally, the Rural Residential and Residential Estate minimum lot sizes of 1 acre and 14,000/20,000 square feet may be a constraint by limiting new housing due to the large lot sizes. While most of the City’s housing growth is not anticipated to occur in the more rural areas of the City, the minimum lot sizes in these districts directly limits density and affordability.

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Planned Residential Developments (PRDs) provide more flexibility to housing developments approved as subdivisions, allowing for zero lot line development and small lot subdivisions (see Program 7.4 -6). PRDs require Conditional Use Permits and for a minimum of 20 percent (depending on the zone) of the subdivision to be preserved as open space. This may be applied to any residential or agricultural district that allows residential development. These requirements could potentially be constraints on new housing; however, as the PRD acts to ensure that open space is preserved, and also allows for more flexible design and lot configuration. Therefore, the PRD program is not considered a constraint on housing production.

Nonresidential Zoning Districts That Permit Residential Uses Several other districts permit residential development. Generally, residential uses within non- residential districts will follow the provisions in the adjacent residential district or a district with comparable lot sizes.  A-1 Agricultural District: Single-family residences with no more than two dwellings units per each parcel of five acres or more, or one dwelling for each lot, if less than five acres.  A-1-20 Agricultural District: Single-family residences with no more than two dwelling units per each parcel of 20 acres or more, or one dwelling for each lot, if less than five acres.  A-2 Estate Agricultural District: Single-family dwellings with no more than one dwelling per each lot.
 MF Medical Facility District : Residential uses, subject to the requirements and property development standards of the nearest residential zone.
 T Transitional District: Residential uses that are permitted in the residential district adjacent to the T district, subject to the requirements and property development standards for the particular residential district.
 A-P Administrative and Professional Office District : Residential uses permitted in the R - 3 Multiple Family Residential district, subject to the regulations of that district.  A-P-C Administrative Professional Commercial District : Residential uses permitted in the R -3 Multiple Family Residential district, subject to the regulations of the R-3 district.  Downtown Specific Plan, TC Town Center District : Single -family, multi-family, and mixed -use residential uses permitted.
 Downtown Specific Plan, TC-H Town Center Historic District : Single -family, multi-family, and mixed-use residential uses permitted.
 Downtown Specific Plan, SC Service Commercial District: Single-family, multi-family, and mixed- use residential uses permitted.8
The A-P, A-P-C, TC, TC -H, and SC districts, as listed above, allow mixed -use, residential development. In the A-P and A-P-C districts, residential development is allowed subject to the regulations of the R-3 district

8 The TC, TC-H, and SC are zones within the Transit Villages Specific Plan.

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(see Table 4-1). In 2010, City Council adopted Ordinance No. 2739, which increased the density allowed in the R -3 and equivalent districts to 30 units per acre. The R -3 district has a 60 percent maximum lot coverage requirement and allows up to four stories.

Other nonresidential districts allow residential uses as a conditional use. Requiring a conditional use permit for residential uses constrains the development of multi-family housing in these districts.  C-3 General Commercial District: Residential uses conditionally permitted as long they are combined with nonresidential uses in an existing or new building and provided that they comply with the regulations of the R-3 Multiple Family Residential district.  C-4 Highway Commercial District: Permits conditional us es allowed in the C -3 district; therefore residential uses are conditionally permitted as long they are combined with nonresidential uses in an existing or new building and provided that they comply with the regulations of the R -3 Multiple Family Residential district.

While zoning designations described above serve to restrict residential development in non - residential zones, the City is actively promoting the Transit Villages Specific Plan that contains opportunities for mixed-use and transit-oriented development. The City has identified housing sites in downtown, many of which are ideal for very low - and low -income housing development, because of the high densities permitted in this area; however, the constraints of Measure U persist with the requirement of a 4/5th vote of the City Council to approve projects above 18 du/ac or above 2.5 stories/35 feet high.

4.1.4.2 Transit Villages Specific Plan Zoning Districts The City strives to revitalize the downtown as part of citywide economic development objectives. During the 1980s, the Downtown Revitalization Program strengthened the downtown and brought significant private investment. The current Downtown Specific Plan contains three zoning districts: Town Center, Town Center-Historic, and Service-Commercial. All three districts allow single, multi- family, and mixed- use residential projects as a permitted use.

The City has prepared a draft Transit Villages Specific Plan (TVSP) and environmental review is currently underway. The 2035 General Plan introduced the Transit Villages Concept and a substantial portion of the Livable Community chapter is devoted to establishing the policy framework to implement the future transit villages within approximately a one-half mile radius of each of the three train stations in Redlands.

Section 4.5 of the General Plan provides that “Transit Villages” have the following characteristics:
 Densities and intensities that promote working and living environments proximate to transit;  Pedestrian and bicycle access to the station, with safe and comfortable pathways; and  A transportation system that encourages and facilitates intermodal service and access.” Section 4.5 of the Livable Community chapter states, “The Transit Village Areas Strategy consists of the following:

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 A Transit Village Overlay Zone (TVOZ) of mixed uses, which includes an area of focused streetscape and public realm improvements.
 Base land uses consistent with the land use classifications described in Section 3.1 of the General Plan, designed to foster higher intensities and compact development patterns.  A Mixed Use Core where a mix of uses and higher densities and intensities would be encouraged through policies and standards in the Transit Village Plan.” Based on the 2035 General Plan, the draft TVSP refines those policies into a detailed set of rules and development standards so that future projects can achieve the community’s vision for compact and walkable transit villages. The TVSP has the intention of accommodating a mix of uses such as residential, retail, commercial, and office types of land uses within an approximately half- mile radius with sufficient density and intensity to support self-sustaining neighborhoods. Density and intensity of uses (in terms of numbers of workers, shoppers, visitors , and residents) are also very important elements, because a sufficient number of people need to be present and utilizing the villages so that they are self -sustaining and financially feasible.

The TVSP covers 947 acres, or approximately 4 percent of the total land area of the City. Approximately 85 percent of land within the TVSP area is developed. In comparison to residential zoning districts (development standards for which are listed in Table 4-1), the TVSP zoning districts provide form based development standards and allow for dense development, subject to Measure U requirements, and promote a mix of uses. Eight zones would be established under the plan:

1. Village Center (VC) – applies to the parcels immediately surrounding the three stations. Buildings may reach a height of four stories and are mixed-use, all residential, or all office. Parking is located behind buildings or subterranean.

2. Downtown (DT) – applies to parcels facing State Street east of Orange Street and along the east side of Orange Street between the railroad right of way and State Street. New buildings up to three stories in height accommodate a mix of uses with commercial ground floors and residential or commercial upper floors. Parking is located behind buildings, subterranean, or in park -once lots or structures.

3. Village General (VG) – applies to parcels located around the periphery of the three stations. This zone enables multi-family and mixed-use buildings with an average height of three stories. Parking is located behind buildings or subterranean.

4. Village Corridor (COR) – applies to parcels along the north side of Colton Avenue, both sides of Orange Street north of the I-10 freeway, and both sides of Olive Avenue. This zone enables small- scale mixed -use buildings up to two stories in he ight with commercial ground floors and residential or commercial upper floors. Parking is located behind and to the sides of buildings, subject to minimum street-facing building frontage requirements.

5. Neighborhood General 1 (NG1) – applies to parcels loc ated between Sixth Street and Church Street. It enables small -scale commercial and house -form buildings up to 2 stories high that

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accommodate commercial, light industrial, and live -work uses. Parking is allowed behind and to the side of buildings, subject to minimum street-facing building frontage requirements.

6. Neighborhood General 2 (NG2) – This zone enables house -form buildings that accommodate residential and office uses. New buildings are up to two stories in height and are set back from the sidewalk behind yards. Parking is located behind new buildings.

7. Special District (SD1) – applies to school and other institutional sites. New buildings accommodate educational, religious, and other civic uses. Parking is located in surface parking lots or garages.

8. Civic Space (CS) – applies to parks, plazas, greens, and other open spaces within the Specific Plan area. These open spaces accommodate small structures such as gazebos, restrooms, and community centers.

As for parking requirements, minimum off-street parking spaces are provided in the TVSP and, for residential uses, are based on unit size, and gross floor area for commercial uses. Generally, the parking requirements in the TVSP are slightly lower than the parking requirements provided in the Municipal Code due to the transit-oriented character and convenient pedestrian access within the transit villages.

4.1.4.3 Affordable Housing
The Housing Resources section identifies different zones and suitable sites that may accommodate affordable housing need. The City inten ds for the TVSP to facilitate smart growth and new residential development around the new Metrolink/Arrow light rail stations. The plan contains progressive mixed - use development standards that will increase the sites available for affordable housing. Additionally, the City is including programs to upzone the RHNA sites outside of the TVSP area to further improve capacity for affordable housing. The City also has examples of two recent affordable housing projects that occurred in medium-density multi-family areas. These recent projects support that land zoned for less than 30 du/ac can also support affordable housing.

4.1.4.4 Multi -Family Development
Pursuant to the Zoning Ordinance (Section 18.192.020), all multi- family developments containing 35 or more dwelling units are subject to a conditional use permit (CUP). The findings of approval for a CUP are as follows:
 That the proposed development will not adversely affect the applicable land use plans of the City;  That the proposed development will not be detrimental to the public health, safety and welfare;  That the proposed development will comply to the maximum extent feasible with the regulations of the City’s General Plan, the applicable zoning district and the City’s development standards; and
 That the proposed development is appropriate at the proposed location.

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These requirements were adopted because of the potential for neighborhood conflicts due to traffic, noise, and aesthetic concerns. A public hearing, which is a requirement of the CUP, gives neighborhoods the opportunity to participate, voice their concerns, and ensure that the projects are as compatible as possible with existing development . Conditional Use Permits are a potential constraint by adding uncertainty and extending the potential for delay in project processing. Multi-family developments within the TVSP are permitted uses (unless greater than 35 units), and processed through a Commission Review.

Approval is required of all new construction over 500 square feet and the 4/5 th City Council vote ma y apply for density and height approval. There is currently no difference in the permitting process for multi- family rental developments from other, for-sale, multi-family developments in the City.

Program 1.2-13 is included to remove the CUP requirement for multi -family developments greater than 35 units.

4.1.4.5 Density Bonus Provisions
The state density bonus law provides a maximum density bonus of 50 percent. To be eligible for the maximum bonus, a project must set aside at least 15 percent of total units for very low income households, 24 percent of total units for low income households, or 44 percent of for -sale units for moderate income households. Levels of bonus density between 35 percent and 50 percent are granted on a sliding scale, depending on the number of affordable units.

4.1.4.6 Housing Type Variety
The City’s Zoning Ordinance allows for a variety of housing types. Moreover, “dwelling unit” definitions do not distinguish between constructed and factory -built housing. As per state law, the City does not regulate the number of individuals living in a dwelling unit that is state licensed if that numbe r is six or fewer, nor does the City distinguish between permanent and transitional housing. Therefore, supportive and transitional housing are treated the same as other residential uses in the same zone.

In October 2013, City Council adopted Resolution N o. 7322, which allow ed for emergency shelter and transitional housing to be constructed in the SC (Service Commercial) district of the Downtown Specific Plan by right. The SC district is 38.1 acres and the most recent point in time count of unsheltered homeless individuals in the City is 47. The SC District could easily support homeless shelters that would meet the City’s need. Many properties in the district are highly underutilized, with existing uses consisting of surface parking lots and small or aging structures. Additionally, the district contains 20 vacant parcels, with a total area of 2.9 acres. As the SC district is a part of the Downtown Specific Plan, it has excellent access to employment, commercial and recreational amenities, and educational ins titutions. This district is also located within 2 blocks of the downtown Metrolink Station . These conditions make the SC district appropriate for emergency shelters.

The Downtown Specific Plan contains a number of specific standards that apply to emergency shelters.

The plan specifies requirements for on -site security, parking, storage, pets, on-site management, operational hours, among others. There are no spacing requirements or development standards for emergency shelters that would pose a constraint to development. Program 1.2-1 amends the code for AB 139 compliance. The City has identified Program 7 .2-1 to amend the Downtown Specific Plan/proposed

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TVSP to comply with the requirements of AB 139 – Emergency and Transitional Housing. The City will reduce the parking requirements, and review all other emergency shelter standards to ensure that they are expressly permitted by AB 139 or are consistent with other uses in the same zone.

Redlands has six single -family and three multi -family residential districts (Table 4-1 ). Furthermore, the 3,723 total available sites are located in a range of zoning districts. The development standards for these districts generally do not serve to restrict the development of single -family residential structures. The requirements for lot size and private open space are a constraint to small lot multi-family development.

Housing is allowed in 10 different nonresidential districts. While only single-family homes are allowed in the agricultural districts and the R-1, R-E, and R-S districts, the minimum lot area, height, and front, side and rear yard standards are not burdensome. The Administrative & Professional Office (A -P) and Downtown Specific Plan/proposed TVSP districts permit single-family and multi-family housing of various types including mixed-use, live/work, emergency shelters, and group homes.

The City’s development fees are found in Table 4-2. The fees the City charge s do not serve to restrict housing variety.

4.1.4.7 Hillside Slope Standards
The southeastern portion of Redlands contain steep hillsides and canyons. The City initially restricted growth in these areas through Measure N, in order to protect ridgelines from significant grading and preserve scenic vistas. These restrictions have the additional purpose of minimizing flood hazards, erosion from residential and road construction, exposure to wildfire , evacuation efficiency , and potential for groundwater deterioration. The Zoning Ordinance defines a Hillside Development District (HD) for parcels with average cross-slopes greater than 15 percent. In this district, densities are limited to 1 unit per every

2.5 acres in areas with 15 to 30 percent slopes, and 1 unit per every five to ten acres in areas with 30 to 40 percent slopes, respectively. Since the majority of this area is zoned as single -family residential and agriculture uses, the permitted density of the General Plan land use designation of Very Low Density Residential would permit up to 6 du/ac, thus the hillside policy results in fewer dwelling units per acre than would otherwise be permitted by the General Plan. While a constraint in terms of achievable dwelling units, the hillside policy is both practical and necessary to protect valuable environmental resources, limit exposure to hazards, and is generally in line with smart growth practices.

4.1.4.8 Parking Standards
Off-street parking facilities are required for all new dwelling units. Single-family residential dwellings are required to have at least two covered parking spaces per unit. Multi -family residential dwellings require a range depending on the housing type a nd number of bedrooms. Outside of the proposed TVSP, one - bedroom units are required to provide one parking space, two bedroom units are required to provide one and a half parking spaces, and units that are three bedrooms or more are required to provide two parking spaces. Additionally, all multi-family projects containing more than two units on a lot must provide one uncovered off street parking space for every two units. The parking requirements for multi-family development can serve as a constraint on dev elopment by requiring more land area to accommodate surface parking. Ordinance No. 2688 provides reduced off -street parking requirements for mixed -use

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projects. The TVSP proposes more streamlined and less burdensome parking requirements that are not viewed as a constraint to development and are suitable for transit oriented development.

While parking standards can constrain residential development, requirements of the state density bonus law allow for reductions in parking requirements in multi- family housing developments, often where housing affordable to very low- and low-income households is located. Tandem parking (where two cars are parked, one in front of the other) and uncovered parking satisfies the parking requirement for second units, another good source of affordable housing.

4.1.4.9 Building Codes
Redlands currently requires residential construction to comply with the 2019 California Uniform Building Code and other standard codes. The City has not amended the building code in a way that would increase the costs of developing housing or increase the time for permitting. Fire sprinkler systems are also a requirement on all new residential units or when an addition of 500 sf or more is constructed (such as an ADU, JADU), which adds a cost between $0.81 and $2 .47 ($1.35 on average) per square foot, depending on the unit type.
9 The City has two full-time Code Enforcement Officers to conduct a proactive code enforcement program, but also responds to complaints or notices received through the City’s Redlands 311 reporting app . The City also has a Rental Dwelling Unit Ordinance that was adopted in 2012 and is implemented by the Code Enforcement Division of the Facilities and Community Services Department. The ordinance requires that every rental property obtain a rental dwelling unit permit. The permit must be renewed on an annual basis and the owners are required to keep the rental dwelling unit(s) in compliance with specific standards, particularly those regarding life safety, hazards, and maintenance. The intent of the ordinance is to ensure that the City’s rental housing stock is kept and maintained according to state and local health and safety laws. The cost of this permit ranges from $80 to $116 depending on the rental property typology. This fee may pose a financial constraint to property owners of rental housing.

4.1.4.10 Off -site Improvements
Off-site improvements, including public streets, curbing, sidewalks, streetlights, water, sewer, and drainage requirements, have an impact on the cost of residential development.

Section 17.17.020 of the Municipal Code describes a set of required improvements in addition to those stipulated under the tentative map, including upgrades to infrastructure, utility hookups and site design.

1. Frontage Improvements: Street structural sections, curbs, sidewalks, driveway approaches and transitions.

2. Storm Drainage: Storm drain system improvements to collect and convey on -site storm water run-off; system should not adversely affect abutting and off-site properties.

9 Home Fire Sprinkler Cost Assessment – 2013, https://www.nfpa.org/News -and-Research/Data-research-and-tools/Suppression/Home-Fire- Sprinkler-Cost-Assessment-Final-Report.

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3. Sanitary Sewers: Each unit or lot must be served by an approved sanitary sewer system.

4. Water Supply: Each unit or lot must be served by an approved domestic water system.

5. Utilities: Each unit or lot must be served by gas, electric, telephone and cablevision facilities.

6. Underground Utilities: All existing and proposed utilities within the subdivision and along peripheral streets must be placed underground except those facilities exempted by the Public Utilities Commission regulations or if impractical due to physical constraints.

7. Fencing: Each parcel or lot within the subdivision that is adjacent to a public facility must have an approved fence or wall adequate to prevent unauthorized access between properties.

8. Other Improvements: The City Engineer, in accordance with this Code, the General Plan and City standards and specifications may require other improvements, such as grading, streetlights, fire hydrants, signs, street lines and markings, street trees and shrubs, landscaping, monuments, bicycle facilities, fences and smoke detectors, or in lieu fees.

These off-site improvements are either installed by the developer as part of the project or paid for by impact fees assessed on larger regional or area wide facilities. Off- site improvements are assessed to determine appropriateness of improvements based on need. While these are not unique requirements, they do increase the cost of development. To mitigate the constraint that off-site improvements can place on housing, adjustments and modifications to standard requirements have been granted for PRDs, hillside developments, and rural projects. Furthermore, the vast majority of sites included in the inventory are already adjacent to dedicated streets and have necessary sewer and water infrastructure.

4.1.5 Development Review Process

4.1.5.1 Permit Processing
Residential construction involving individual single-family homes on existing lot, mobile homes, and two- to four-unit multi-family projects are approved at a staff level (ministerial review). Projects are evaluated relative to zoning and building code standards and receive approvals within two to four weeks of application. The City’s plan check policy is to complete first submittal plan checks within 10 business days and resubmittal checks within 5 business days.

The City offers a “Preliminary Review” service where plans may be submitted for review and comment by all relevant City departments prior to formal application. However, the City staffs a “One Stop Permit Center” where customers can talk with representatives from Planning, Building, and Municipal Utilities and Engineering to receive guidance and obtain standards for development.

Residential construction involving tracts and larger multi-family projects utilize the following processing schedule.
10 10 In the case of a developer who wishes to build in an already approved subdivision, often a Planned Residential Development (a conditional use permit) application is processed concurrently with other permits. If the subdivision meets all of the development standards of the zone,

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For projects not requiring legislative actions the entitlement process can take as little as 100 calendar days (approximately) if an Initial Study is not required under the California Environmental Quality Act. 11 Steps are:
 (1) submission of complete application,
 (2) Development Review (40 days),
 (3) Planning Commission (30 days).

During this formal application phase, the applicant submits ten sets of plans, appropriate application forms and all required fees. Completeness review by Planning staff and committee review by the Development Review Co mmittee occurs within the first 30 days following application submittal. The applicant then provides additional information and prepares plan revisions (if needed) based on Development Review Committee comments/corrections. Conditions of approval are prepa red and any final issues are addressed before the project moves on to public hearing. For the public hearing phase, proposed projects must be included on an agenda in advance. Staff prepares and presents reports on each project. The applicant and members of the public have the opportunity to comment. As for multi -family development, the Z oning Ordinance allows up to 34 units to be approved under a site plan approval process called a Commission Review and Approval (CRA). The site plan proceeds through the same process except that CRAs do not require a public notice or hearing (if a SCBS is required for the project, then Municipal Code Section 16.02.040 requires a public hearing for the SCBS) , but do proceed to Planning Commission review.

If the project is su bject to CEQA, then an Initial Study must be prepared by the city’s environmental consultant(s) and typically requires an additional 90 to 180 days including a 30-day public comment period on the environmental document (e.g., a Mitigated Negative Declarati on). Consideration of the project environmental document is part of a public hearing on the entire project. This threshold is a matter of City policy, and could be adjusted upward, although it has not been a factor in inhibiting affordable housing in the past.

For projects requiring legislative actions (General Plan Amendment, Zone Change, Agricultural Preserve Removal, etc.) processing takes approximately 140 calendar days, plus any CEQA environmental review processing requirements. Steps are the same as above plus (4) City Council (40 days).  Once the entitlements are granted developers prepare for approval of their final map and submit for Residential Development Allocations (RDA).
12 With the RDA process (described below) there
is another step that residential developers go through that is not required in neighboring cities.

The RDA process takes approximately 60 calendar days ; however, it typically is occurring when

there is no further review other than the Residential Development Allocation (RDA) process. All subdivisions of five or more units are required to go through the RDA process unless the subdivision in question is a lot sale subdivision. 11 Projects requiring CEQA review may take an additional 180 days or more to allow for preparation of the environmental document. 12 The RDA process has been temporarily suspended by SB 330 until 20 30. (City Council Resolution No. 8082 adopted on 5/19/2020 suspended the competitive evaluation and selection system contained in Municipal Code 19.04.040). The proposed SB 8 may extend this to 2030.

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the developer is completing final engineering and completing the final map (as well as finalized home designs), so the timing is not significantly different than in other communities.  A residential project with five or more units must receive an RDA before it may be granted a building permit. Once an application is filed, it is processed and reviewed and allocations are determined by the City Council.
 Note: With implementation of SB 330 provisions through at least January 1, 2025 (and adoption of City Council Resolution No. 8082 suspending the RDA’s competitive evaluation and selection system contained in Municipal Code Section 19.04.040 for the duration of SB 330), the evaluation and approval of multifamily residential dwelling units now occurs simultaneous with the individual project’s CRA and/or CUP entitlement process.

The development review process is not different for residential projects included as part of a mixed- use project.

Given that permit processing times are generally in line with other communities in the area, the Redlands development review process does not represent a constraint that is significant, although additional staff resources would enable staff to process projects more quickly. Regulations to include additional environmental assessment, requirements of SB 18, and water quality requirements (all federal, state and regional requirements), etc. have added to the processing time and cost of development in all cities, not just in Redlands. These additional requirements are not generally reflected in the timelines above because this information and requirements are required at time of application submittal and determination of completeness.

Developers can face delays in obtaining building permits after entitlement due to the need to create more detailed plan sets after entitlement approval. Those plans may take several weeks to develop and submit for plan check review; however, the City accepts plan checks “at risk” and many developers take advantage of this option to expedite the permitting process. This process allows the developer to submit their project for plan check review prior to entitlement approval. The plan check is “at risk” as the project may be modified prior to entitlement, but the ability to initiate the plan check process early can result in developers obtaining building permits at the conclusion of the entitlement appeals period.

4.1.5.2 Postings and Notices
The City is compliant with requirements for posting notices of public hearings and discretionary land use decisions. This includes CUPs, variances, zone changes, General Plan a mendments, and e nvironmental review, among others. The City has an internal process to track projec ts and submit notices in the appropriate format to the local newspaper, posting on the City’s website, and posting in physical locations in the City’s buildings, including outside the Council Chambers and at the City Clerk’s office.

4.1.5.3 SB 35 Ministerial Appro val Procedure
SB 35 (Wiener, 2017) requires a Streamlined Ministerial Approval Process for developments in jurisdictions that have not made sufficient progress towards their RHNA.

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The City of Redlands has yet to receive an SB 35 application. If the City were to receive an SB 35 application, it would follow state law procedure. The City would provide a layout summary and other materials upfront, as well as an optional precomputation to review standards and objective standards.

The following permitting procedure that the City will follow is from the Streamlined Ministerial Approval Process guidelines outlined by HCD.
13 1. After receiving a notice of intent to submit an application for a S treamlined Ministerial Approval Process, and prior to accepting an application for a Streamlined Ministerial Approval process, the City will complete the tribal consultation process outlined in Government Code section 65913.4(b).

2. The City will perform a determination of consistency with regards to objective zoning, subdivision, and design review standards.

3. The City will perform a determination of consistency with density requirements.

The City will complete the design review within the following timeline:

1. Within 60 calendar days of submittal of the application to the City if the development contains 150 or fewer housing units.

2. Within 90 calendar days of submittal of the application to the City if the development contains more than 150 housing units
The City will determine whether the applicant for Streamlined Ministerial Approval complies with requirements, and will approve or deny the application, within the following timeline:

1. Within 90 calendar days of submittal of the application to the City if the develo pment contains 150 or fewer housing units

2. Within 180 calendar days of submittal of the application to the City if the development contains more than 150 housing units.

While the City has yet to receive an SB 35 application, the City will facilitate the process and support any future applicants, as outlined in Program 1.2-19.

4.1.5.4 Residential Development Allocation
The Residential Development Allocation (RDA) process discussed below has been temporarily invalidated by SB 330 until 2025, and potentially until 2030 based on SB 8. Also, the City Council adopted Resolution No. 8082 on May 19, 2020, suspending the competitive evaluation and selection system contained in Municipal Code 19.04.040 for the duration of the state’s applicable legislation.

Required by voter initiatives, the RDA determines which projects may move through the development process to receive building permits. Projects (involving more than four units) compete against each other for an allocation of housing units from the pool of 400 dwelling units allowed each year within the city limits and 150 utility connections permitted in the SOI. The City Council makes allocations four times each year, 117 dwelling unit allocations in each of the first three quarters and then the remainder of dwelling

13 HCD Updated Streamlined Ministerial Approval Process: https://www.hcd.ca.gov/policy-research/docs/sb-35-guidelines-update-final.pdf

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units in the fourth quarter. Staff assists applicants in preparing applications. Unused dwelling unit allocations cannot be carried forward into the next year. Moreover, a project must obtain at least ninety points in order to be eligible to receive an allocation award.

Admittedly, it is a procedure that adds time to the total development approval process by requiring that homebuilders first receive an allocation before proceeding with building permits. Once entitlements are granted, the RDA process takes approximately 60 calendar days. However, this typically occurs when the developer is completing final engineering, completing the final map, finalizing the home design s (after selecting a home builder), and processing building permits. Therefore the projects are not held in hiatus when they are going through the RDA process and there typically is no significant time loss. Furthermore, the RDA application fee is $2,828 per development application.

The City’s RDA system is not anticipated to create significant barriers to the approval of affordable housing developments. In fact, the City currently encourages the construction of affordable and senior housing units by awarding up to 20 points for providing such housing. (This is ten points more than the original points system permitted.) Specifically, two points per unit are awarded for projects with 15 percent of dwelling units restricted for very low- and low-income residents and up to six points are given to projects with 90 percent or more of the dwelling units restricted for seniors. While low -income or senior housing developments may not qualify for the maximum points in all rating categories, the City believes that most such projects will score high enough in most of the rating categories to be more than competitive with market-rate housing proposals. The City can address the cost implications of location and design factors included in the evaluation system through other regulatory incentives (such as density bonuses with reductions in certain development standards) and stabilized fees via Development Agreements with affordable housing developers. In addition, a substantial percentage of affordable housing is anticipated to be provided in mixed -income projects in which the majority of dwelling units are market rate. Such projects will have a greater capacity to absorb marginal increases in costs from the application of the City’s RDA system.

4.1.5.5 Socioeconomic Study and Cost Be nefit Analysis
This requirement was added with the passage of Measure U in 1997. The Growth Management Element of the General Plan states that any development project proposal requiring a General Plan Amendment, Zoning Amendment, Subdivision Map, Specific Plan, CUP approval, or with a building or development area exceeding a cumulative total of 5,000 square feet shall submit a socioeconomic study and cost -benefit analysis (SCBS; see Section 4.1.1.5) . However, it was decided that it was not the intent of the Growth Management Element to evaluate a single-family residence on an existing lot of record that is over 5,000 square feet in area.
14 This requirement is not discriminatory as it applies to all development projects — residential and nonresidential, single-family as well as multi-family units.

Projects must submit additional information, including absorption schedule or rate, proposed asse ssed value, and proposed public improvements. The review is conducted by City staff using a standard checklist and a spreadsheet-based model, and the cost is $3,265 per project (regardless of project size or number

14 Reference from 5 th Cycle Housing Element update, Email exchange with Jeff Shaw, City of Redlands Community Development Director, 3/12/2008.

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of housing units). The average single-family project is about 50 units, and the average multi-family project is 90 units, so this would come out to $65 and $36 per unit, respectively. Thus, the monetary cost of this requirement is quite low. City staff prepares the socioeconomic study and cost -benefit analysis that is reviewed by the Planning Commission/City Council along with the Initial Study (per CEQA).

The study requires the evaluation of how the development project in question will affect:
 Agricultural/Citrus Removal : will the project affect agricultural resources or operations (e.g. , impacts to soils or farmlands, or impacts from incompatible land uses)? Will the project remove active citrus groves—a hallmark of the city—from production?  Wildlife Habitat: will the project eliminate or have a negative impact on wildlife corridors? Will it tend to urbanize open space, impacting preservation and conservation of natural resources? Will it interfere with the use of recognized trails used by joggers, hikers, equestrians or bicyclists? Will it eliminate, reduce, or have any negative impact on wildlife habitat areas including fringe or buffer areas?
 Traffic: will the project result in increased vehicle trips or congestion? Will it create additional traffic so as to be in conflict with the policies of the General Plan? Will it impact the livability of a residential neighborhood on streets which, due to design or terrain features, street side development, or other factors, have greater than usual sensitivity to increased traffic? Will it create additional traffic so as to increase the level of service on roadways that are adjacent to or in the vicinity of the project?
 Fire and Paramedic Services: will the project require fire and paramedic services that are beyond the current capabilities of the Fire Department? Will it result in an increase in response time for essential fire or paramedic services to the remainder of the community? Will it result in the need for additional fire or paramedic facilities or equipment?  Police Services: will the project require police services that are beyond the current capabilities of the Police Department? Will it result in an increase in response time for essential police services to the remainder of the community? Will it create a need for additional police facilities or equipment? Will it increase crime as a result of the type of business?  Downtown Impacts: will the project result in a reduction of the number or types of businesses located in the downtown? Will it cause an unfair or unreasonable competitive disadvantage to existing businesses downtown? Will it create vacant buildings and the potential for blight? Will it cause an unreasonable increase in traffic downtown? Will it adversely affect downtown businesses?
 Residential Design: will the project conflict with existing codes and/or standards? Will it meet minimum point standards of the Residential Development Allocation process?  Cultural Facilities : will the project impact a historic residential structure, neighborhood, or district? Will it impact a historic commercial structure or district? Will it impact cultural facilities such as the Smiley Library, Redlands Bowl, Lincoln Shrine, Joslyn Center, Community Center, etc.?

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Will it have the potential to cause a physical change that would affect unique ethnic cultural values? Will it have the potential to disturb, impact or restrict religious or sacred facilities or uses?  Park and Recreational Facilities : will the project result in the increase use or demand for park facilities or programs (including manpower, facilities and equipment)? Will it result in a ratio of parkland to population that exceeds standards and/or goals established by the General Plan?  Land Use Compatibility: will the project result in land uses that are incompatible or inconsistent with the General Plan? Will it create economic impacts on businesses and small property owners? Will it physically separate or divide an existing community? Will it create job losses in the community? Will it create overcrowding of housing?
 Schools: will the project create an overcapacity in schools? Will it create the need for additional school facilities or equipment? Will it result in land uses that are inconsistent or incompatible with existing educational facilities in the community? Will it result in social or academic imp acts on students because of school closures?
The findings listed above are rated as having a potentially significant, potentially significant unless mitigation incorporated, less than significant, or no impact. Redlands Municipal Code Chapter 16.02 provides the SCBS requirements, and Section 16.02.040 states, “The approving body for the development proposal shall conduct at least one public hearing at which the public may appear and be heard to consider the socioeconomic cost/benefit study after providing ten (10) days' prior notice, published once in a newspaper of general circulation within the city.” In some cases that may not otherwise require a public hearing (such as a simple CRA approval), this provision may trigger a public noticing and hearing requirement for the entire project.

In a basic sense, the requirement for the s tudy tasks Planning st aff with performing a quick checklist to verify that, for instance, the parcel(s) in question are not in the habitat area of a protected species or that the developer is prepared to pay impact fees related to police, fire, and schools. In other words, the bulk of the findings simply require that staff check that the project in question adheres to policies in the General Plan and/or Zoning Ordinance—information that otherwise would normally be provided in a staff report; this process standardizes this review to enable those who are interested in the project to view, at a glance, how well the project in question complies with the General Plan and City codes.

Studies are done concurrently with the processing of projects (residential or otherwise), and therefore do not have any impact on a residential project proceeding or the length of processing time (for a lower income multi-family or other type of residential development). Additionally, residential developments generally have a positive socio -economic impact because a sales tax factor is included. Therefore, while there is a direct relationship between the cost of the residential unit and the tax benefit provided, this requirement does not serve to constrain development. Since 1997, hundreds of socioeconomic s tudies have been performed and no project has been denied because of a study’s results. Please see Program

7.4-14 in Chapter 7 for further clarification regarding how the study is used.

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4.1.5.6 Impact Fees and Exactions
Fees are collected by the Building Division , Municipal Utilities and Engineering Department through the One-Stop Permit Center, and by the Redlands Unified School District at their offices by appointment. Fees are updated every several years, as needed. Planning application fees and Municipal Utilit ies and Engineering fees were last updated in August 2018; both are available online on the City’s website. Current School District fees, last updated in June 2012, are also available online on the District’s website. To obtain Building & Safety Division fees, applicants must call the department or visit the One Stop Permit Center , since fees depend on specific project types. Because current fees are assessed per unit and very low- and low-income units are not exempt, the fees constitute a significant share of the cost of producing housing at market minimum prices. This effect is amplified by Redlands' allocation system, which awards up to 72 points for design and energy efficiency considerations. Developers who want to increase their chances of winning an allocation will include more amenities; these then drive up the cost of their product. This is somewhat offset by provisions that allow 20 points to be awarded for very low - and low-income and senior citizen housing.

Total fees for a single-family home, assuming a 2,200-square-foot home on a 7,200-square-foot lot, in a 6 du/acre tract, add up to approximately $16,641. Total fees for a multi- family home are about $11,638.

Total fees for an ADU can range between $5,224 and $6,856.

While these fees may seem hi gh, Redlands is a “full- service” city and therefore charges impact fees to include water, sewer, landfill, public facilities, etc. Conversely, in other cities, certain fees are not paid to the City but rather to a water company, waste disposal company, or other entity that provides a service.

Table 5.1 -6 shows the fee breakdown. All developers will not be charged all of the fees shown. For example, amending the General Plan or changing the zoning designation of a particular property may not be necessary for many projects. Additionally, Table 4-2 contains planning/processing fees, building and safety fees, and development impact fees, all of which serve distinct and necessary purposes.

Furthermore, while fees are generally applied equally within the city, usually the infrastructure costs of extending water lines, sewer lines, streets, etc. are greater for developments on the outskirts versus infill projects. For example, if an infill site that was once retail is being converted into apartments, because the City gives credits for trips previously attributed to the site, the apartment complex developer would have greatly reduced transportation fees. Developers can also receive credits for certain fees if improvements such as roadways, traffic signals, drainage systems are installed as part of the project.

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TABLE 4-2: REDLANDS DEVELOPMENT FEES (PER UNIT)

ADU
700+ sq
feet
ADU
< 700 sq
feet
Single Family Multi-
Family TOD
Development Impact Fees
Open Space and Parks $2,454.85 $1,841.14 $3,959.94 $3,624.62 $2,454.85 Library $164.02 $123.01 $264.58 $242.18 $164.02
Storm Drain $700.00 $343.00 $343.00
Public Facilities Fee $425.55 $319.16 $686.45 $628.33 $425.55 Fire Protection Fee $357.74 $268.31 $577.08 $528.21 $357.74 Police Facilities Fee $18.67 $14.00 $30.11 $27.56 $18.66 Transportation Fee $937.54 $703.16 $1,512.36 $1,048.32 $1,074.63 Sewer Capital Fee $824.65 $618.49 $3,130.00 $2,295.00 $366.00 Water Capital Fee $1,146.08 $859.56 $4350.00 - $9431.00 (depending on acreage) $2,181.00 $1,096.00
Solid Waste Fee $325.00 $325.00 $650.00 $325.00
Water Rights $206.29 $154.72 $783.00 - $1701.00
(depending on acreage) $397.00 $167.00
DIF Total $6,860.39 $5,226.55 $16,643.52 -
$22,642.52 $11,640.22 $6,467.45
Building and Safety Fees
Building Permit $736
Building Plan Check $4,093
Plumbing $63.85
DIF + Building
and Safety Total $11,753.24 $5,226.55 $21,536.37 - $27,535.37 $11,640.22 $6,467.45 Environmental Review
(Negative Declaration) $392.00
General Plan
Amendment $3,797.00
Zone Change $1,066.00
New Construction
Conditional Use Permit $1,066.00
Commission Review
and Approval $12,493.00
Tentative Tract Map
Review $2,567.00
Final Tract Map Review $3,857.00
Residential
Development Allocation
$392.00
Total (with GPA
and Zone Change)
$11,753.24 $5,226.55 $47,166.37 -
$53,165.37
$37,270.22 $32,097.4
5 Source: City of Redlands Resolution No 7951, 2018. .

Accessory Dwelling Unit Development Impact Fee Memorandum, 2018

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In calculating the fees in Table 4-2, several assumptions were made. It was assumed that single -family homes are on average 2,200 square feet at a density of 6 dwelling units per acre. Similarly, the following assumptions were made for multi -family housing scenarios: townhouses are 1,200 square feet at 10 units/acre, multi- family units of 1,000 square feet are at 20 units/acre, and multi- family units of 800 square feet are at 30 units/acre. The average project size for these developments was assumed to be 50 dwelling units for single-family homes, 60 dwelling units for townhouses, 75 dwelling units for multi-family units at 20 units/acre, and 90 dwelling units at 30 units/acre. For sewer and water frontage fees, it was assumed that frontage for a single-family home or a townhouse is 50 feet and frontage for a multi-family home is 30 feet. Sewer frontage fees are $30/foot across the board, and water frontage fees are $30/foot for 8-inch pipes and an average of $46/foot for 12-inch pipes.

The City recognizes that development fees, although necessary to pay for facilities and services required by new development, add significantly to the cost of housing and affect the feasibility of constructing affordable housing. For this reason, to mitigate this constraint, the City has used, and will continue to use, grant funds to pay for development fees if necessary, to maintain the financial feasibility of an affordable housing development proposal.

4.1.6 Constraints to Housing for Special Needs Groups
Single-family homes, which comprise three -quarters of the housing stock in Redlands, are often too expensive for low-income persons and others with special needs. Therefore, it is necessary for the City to establish policies and processes that facilitate other housing types. This section addresses policy constraints and opportunities that affect special needs groups, including seniors, people with disabilities, the homeless, large families, female-headed households and low-income individuals and families.

As described in the zoning section earlier in this chapter, the City has several stipulations within its policies to encourage alternative housing types.

4.1.6.1 Emergency Shelters, Transitional Housing, and Supportive Housing In January 2008, SB 2 went into effect, requiring that every jurisdiction in the state identify one or more zoning districts that allow emergency shelters and that transitional housing and supportive housing be treated as any other residential use, subject only to those restrictions on residential uses contained in the same type of structure. The law also requires that the identified zones contain sufficient capacity to provide shelter for homeless persons that have unmet housing needs. On October 1, 2013, City Council adopted Resolution No. 7322, which permits emergency shelters in the SC (Service Commercial) District of the Downtown Specific Plan by right and establishes development standards for emergency shelters.

The City has 38.1 acres of land in the SC district and a curre nt unsheltered homeless population of 141.

The 38.1 acres is more than sufficient to fulfill the need for emergency shelters for the City’s unsheltered homeless population. The City continues to permit transitional and supportive housing by right in all zones that allow residential uses, and projects are not subject to any restrictions not imposed on similar residential uses in the same zone. Program 1.2-3 will ensure the City is compliant with supportive housing regulations pursuant to Government Code Section 65651.

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4.1.6.2 Single -Room Occupancy (SRO) Units
SROs represent another affordable housing alternative. City policies regulate the location of SRO units (they are only permitted in the R -2 Multiple Family Residential District with a conditional use permit).

However, programs in this Housing Element seek to clarify the definition (Program 7.1 -1) and create standards for SROs (Program 7.1 -2). In general, the City views SROs as single -room apartments without full kitchen facilities (although often they have a microwave in each room and/or shared kitchen facilities).

Furthermore, SROs are exempted from the city’s annual 400 dwelling unit cap imposed by Measure U, and therefore may be used to fulfill regional housing needs over this limit. The City initiated the process of considering appropriate zoning districts for SROs and developing criteria for the review of projects.

Staff held one workshop with the Planning Commission and had begun preparing a draft ordinance for their review. Staffing constraints have since stymied progress on the SRO Ordinance and the City will maintain this program in this current policy cycle.

4.1.6.3 Manufactured Housing and Mobile Homes
Municipal Code Chapter 18.140 regulates the location of manufactured housing and mobile homes.

Manufactured homes and mobile homes are considered single-family homes and therefore are permitted in all residential zones, as long as they comply with the density and other requirements within that zone.

Mobile home parks, developments designed and constructed as a single land use complex, are subject to CUPs. The City believes that mobile homes are an important source of affordable housing and therefore mandates rent control in several of the larger complexes (Lugonia Fountains Mobile Home Park, Orange Grove Mobile Estates, and Sylvan Mobile Estates). The City’s rent control policy is detailed in Municipal Code Chapter 5.48, Rent Stabilization for Mobile Home Parks and ties rent increases to the Consumer Price Index (CPI).

4.1.6.4 Constraints to Housing for Large Households and Female -Headed Households Large households and female-headed households may require more traditional housing types; the SROs, mobile homes and shelters described above are not well suited for families. In 2011, approximately 7 percent of households in Redlands were female -headed households and 11 percent were large households (defined as five or more persons per household). These populations are described in more detail in Chapter 2.

Multi-family housing, a more affordable housing option, is permitted in the R -2, R -2-2000, and R -3 Multiple Family R esidential as well as Administrative Professional, Town Center, Town Center- Historic, and Service Commercial districts and some nonresidential zones adjacent to these districts. Multi- family housing is also permitted in the C -3 and C-4 commercial districts, but is constrained by the requirement for a conditional use permit. Although the zoning code does not restrict the number of bedrooms per unit, the market often does.

Furthermore, of the total existing housing stock in Redlands, over half is made up of three and four - bedroom units. Additionally, overcrowding does not appear to be a substantial problem in Redlands; according to the 2019 American Community Survey, 5.1 percent of households were considered overcrowded (defined as more than one occupant per room ). Program 7.3 -8 has been added to study

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overcrowding conditions in Redlands in more detail, as well as the inventory and availability of large (3+ bedroom) units, and make further recommendations to the City Council based on the findings.

4.1.6.5 Constraints to Housing for Persons with Disabilities As noted in the Special Needs S ection (Section 2.9.3) of the Housing Element, persons with disabilities have a number of housing needs related to accessibility of dwelling units; access to transportation, employment, and commercial services; and alternative living arrangements that include on-site or nearby supportive living services.

The City ensures that new housing developments comply with California building standards (Title 24 of the California Code of Regulatio ns) and federal (Americans with Disabilities Act) requirements for accessibility. The City also permits educational, residential, health care, and other supportive services (defined as institutional services in the zoning code) of the type that could benefit persons with disabilities in residential zones. Sites zoned for multi -family use, administrative professional, and C -3 and C -4 Commercial zones, which all permit mixed- use developments, are located along arterial streets and transportation corridors to facilitate access and accessibility for persons with disabilities.

Seniors-only housing currently exists in Redlands and provides many of the features that meet the needs of persons with disabilities. The City’s current development standards permitting mix ed-use developments will allow a wide variety of housing types that could meet the needs of, and provide accessibility to services and transportation to, individuals with disabilities.

Group Homes – 6 or fewer people
The State of California has removed City discretion for review of small group home projects (six or fewer residents). The City does not impose additional zoning, building code, or permitting procedures other than those allowed by state law. There are no City-initiated constraints on housing for persons with disabilities.

The City’s Municipal Code permits group homes of 6 or few er people in any residential zone ; however, the code implies that group homes must be licensed by the state. To prevent unnecessary constraints on group homes and to improve housing choice within the community, the City has included Program 1.2-5 that would clarify that a group home of 6 or fewer people may be permitted in any residential zone regardless of state licensing.

Group Homes – 7 or more people
The City’s Municipal Code identifies group homes of 7 or more people as being permitted in multi-family and agricultural zones with the approval of a CUP. This is inconsistent with other similar uses and present a constraint to providing group homes that serve people with disabilities or who otherwise require assistance which subsequently leads to reduced housing choice. With a CUP , the certainty of approval is limited. CUPs require a public hearing and notices mailed to all property owners within 300 feet of the proposed group home. In some cases, the potential exists for neighborhood organization against the application and NIMBY-like behavior. The City has included Program 1.2-5 to address these constraints on group homes and will amend the Municipal Code to permit group homes in all residential zones.

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In light of current planning policies and zoning regulations, the City believes that it has mitigated any potential constraints to the availability of housing for persons with disabilities.

Procedures for Ensuring Reasonable Accommodations
The City of Redlands has established procedures to ensure that reasonable accommodations are made for persons with disabilities. Any person with a disability may submit an application for reasonable accommodation or variance from the requirements of City zoning or building codes by submitting an application to the city’s Development Services Director who may deny, approve or conditionally approve the request or pass the request along to a designated city committee (Ord. 2656 § 1, 2007). The City provides assistance to applicants who need help completing the application. A notice of the filing of the application is sent to owners of all properties within 300 feet of the property that is the subject of the application. The notice contains information about the nature of the accommodation request and provides instructions for notification of any decisions that are made or hearings scheduled regarding the application. The Development Services Director or the committee acting in the capacity of the Director makes the following findings:
 The person who will use the subject property is protected under the fair housing laws;  The requested exception to the zoning code, law, regulation, procedure or policy is necessary to make specific housing available to persons occupying the subject property;  The requested accommodation will not impose an undue f inancial or administrative burden on the City; and
 The requested accommodation will not require a fundamental alteration of the city’s zoning or building laws, policies and/or procedures.

In practice, the requirement to notify property owners within 300 feet does not slow down requests.

There is no cost to submit an application for reasonable accommodations; the only cost is a building permit (for a small addition to a home, a permit costs less than $ 500). The Zoning Ordinance establishes a time frame of 30 days to make a decision on an application and the notification of neighbors within 300 feet is handled within this time frame.

Typically, smaller-scale ADA retrofit requests are processed over the counter. A request for a ramp to accommodate a wheelchair takes approximately two to three weeks, while a bathroom modification only takes two to three days. Building permit fees for these types of procedures are less than 100 dollars for bathroom modifications and approximately 30 dollars for a wheelchair ramp.

Efforts to Remove Regulatory Constraints for Persons with Disabilities The City allows residential retrofitting to increase the suitability of homes for persons with disabilities in compliance with ADA requirements. Such retrofitting is permitted under C hapter 11 of the 1998 version of the California Code. The City works with applicants who need special accommodations in their homes to ensure that application of building code requirements does not create a constraint. The City’s z oning code has been reviewed for Chapter 11 compliance and was found to be compliant.

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Information Regarding Accommodation for Zoning, Permit Processing, and Building Codes
The City implements and enforces the ADA and applicable California law regarding access and accommodations fo r persons with disabilities. The City provides information to applicants or those inquiring of City regulations regarding accommodations in zoning, permit processes, and application of building codes for persons with disabilities.

Zoning and Other Land Use Regulations
A comprehensive review of the City’s zoning laws, policies, and practices for compliance with fair housing law has been conducted and is included in the Affirmatively Fair Housing Chapter of the Housing Element.

The City has not identified any zoning or other land use regulatory practices that could discriminate against persons with disabilities and impede the availability of such housing for these individuals.

Examples of the City of Redlands General Plan: Housing Element ways in which the City facilitates housing for persons with disabilities through its regulatory and permitting processes are:
 The City has no authority to approve or deny state-licensed group homes of six or fewer people in zones allowing residential uses, except for compliance with building code requirements, which are governed by the State of California. Similar homes serving seven or more persons are only permitted in the Multiple-Family Residential and Agricultural zones, subject to a conditional use permit. However, Program 7.1-1 in Chapter 5 calls for a thorough evaluation of where such homes are most appropriate. For example, because individuals living in group homes often rely on transit to access social services, it may make more sense to allow group homes in downtown or in other high density or mixed-use areas.
 The City permits housing for special needs groups, including for individuals with disabilities, without regard to distances between such uses or the number of such uses in any part of the City.

The Livable Community Element of the General Plan does not restrict the siting of special needs housing.

Permits and Processing
The City does not impose special permit procedures or requirements that could impede the retrofitting of homes for accessibility. The City’s requirements for building permits and inspections are the same as for other residential projects and are fairly simple and straightforward. City officials are not aware of any instances in which an applicant experienced delays or rejection of a retrofitting proposal for accessibility to persons with disabilities.

A significant number of group homes operate in the City of Redlands. As discussed above, the City allows group homes of six or fewer persons by right, as required by state law. No conditional use permit or other special permitting requirements apply to such homes.

The City does not impose special occupancy permit requirements for the establishment or retrofitting of structures for residential use by persons with disabilities. If structural improvements are required for a group home, a building permit is required. If a new structure were proposed for a group home use for

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more than six persons, design review would be required as for any other new residential use with five or more units. The hearing process is the same for group homes and special needs housing for persons with disabilities as for other residential projects of five or more units. The Planning Commission examines permitted uses, architecture, landscaping, and site design. To the City’s knowledge, its design review process has not been used to deny or substantially modify a housing project for persons with disabilities or otherwise. Furthermore, no reductions in density have been required because of design review.

The City’s zoning and permit processes also allow for on-site supportive services, with no additional special conditions. The City’s permit process allows conversion of residential structures to include these supportive services as accessory to the primary residential use.

Building Codes
The City provides reasonable accommodation for persons with disabilities in the enforcement of building codes and issuance of building permits through its flexible approaches to retrofitting or converting existing buildings and construction of new buildings that meet the shelter needs of persons with disabilities. The City of Redlands has adopted and implements the 2019 California Uniform Building Code..

4.1.7 Development Densities below those Anticipated in the RHNA As seen in the 5
th Cycle, sites identified in the RHNA were either not developed with residential uses or were developed at lower densities. For the 6 th Cycle RHNA, the City is implementing a 20 percent buffer when planning for residential capacity. This 20 percent additional capacity addresses the possibility that some sites may not develop as anticipated. Should that occur, the City would still be well within its ability to accommodate its RHNA obligation before needing to identify and rezone additional land. Additionally, the City has weighted its 20 percent toward the very low and low income categories as this unit classification is generally the most difficult to see to fruition.

In November 2021, the City Council mad e findings to exempt three different projects in the downtown from Measure U requirements. Each of these sites are included in the City’s RHNA for the 6 th Cycle. The
total proposed unit count from these projects is 950 units, indicating that interest in developing higher- density housing is gaining traction.

4.1.8 2022 Ballot Measure Amending the Principles of Managed Development of the General Plan
On June 7, 2021, Redlanders for Responsible Growth Management filed with the R edlands City Clerk a petition for an initiative measure titled “An Initiative Ordinance of the People of Redlands Amending the Principles of Managed Development of the Redlands General Plan ” (Initiative). The initiative is an effort to ensure that future d evelopment within the City occurs in a manner that is consistent with the values and standards enacted by the people of Redlands through the establishment of the City’s Growth Management System. More specifically, the Initiative would amend various section s of the previously adopted Measure U as follows:

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1. Requirements for a socioeconomic analysis and cost benefit study will be modified to include a formula that is applicable to residential components of a project in order to determine costs necessary for inclusion in the cost benefit study.

2. Exempts those properties located within the Transit Village Overlay Zone from vote requirements related to density increases and establishes new height limits and parking requirements for Transit Village areas.

3. Provides certain categories of development from the Principles of Managed Development previously established by Measure U and exemptions for development related to the Metrolink stations and for new developments within the Downtown Specific Plan 45 will be deleted;

4. The City Council’s vote requirement related to redesignating or rezoning lands previously designated as Urban Reserve or Urban Reserve (Agriculture) will be amended from a requirement of a 4/5th vote to a 5/5th vote. Measure U’s density limitation on lands designated as Urban Reserve would also be deleted.

5. Establishes exemptions for projects which have acquired vested rights in accordance with criteria established by the initiative from the Initiative’s requirements. The I nitiative further details that actions taken by a developer to expedite a development project due to the pending Initiative will not qualify for exemption from the provisions of the Initiative.

6. Require that any interpretation of the Initiative’s provisions shall be done in a manner which most vigorously and effectively accomplishes its purpose and operative provisions.

Preemption by Senate Bill 330 (SB 330) – Housing Crisis Act The courts use the following four-step test when determining the issue of preemption:

1. Does ordinance/initiative regulate a ‘municipal affair’ a. The regulation of zoning through an initiative directed at changing the City’s General Plan is considered a municipal affair

2. Must be an actual conflict between local and state law a. The Initiative conflicts with the Act by its imposition of height restrictions, new parking regulations, and the imposition of third -party approvals of certain development proposals by adjacent landowners.

3. The State law must address a matter of ‘statewide concern’ a. The legislature has specifically deemed the provision of adequate housing a matter of statewide concern

4. Must be determined that the initiative is ‘reasonably related to…resolution’ of the statewide concern and is ‘narrowly tailored’ to avoid unnecessary interference in local governance a. SB 330 is narrowly tailored to the type of land use restrictions which reduce or restrict the development of housing
Based on this four -step test, the Initiative is highly likely to be preempted by SB 330 because it imposes new land use restrictions beyond what w as found in the City’s General Plan 2035, and those restrictions would have the effect of reducing the development of affordable housing opportunities.

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Conflict with SB 330 - Housing Crisis Act and Legal Review Conclusions Based on analysis considering the sufficiency of the proposed Initiative, the following components of the Initiative may be prohibited by the Housing Crisis Act:

1. Established height restrictions in the Transit Villages

2. Requirement for written agreement from adjacent single-family dwelling owners for buildings with more than two stories

3. Additional parking requirements

4. Revised vote requirement to 5/5th vote for the redesignation or rezoning of land designated as Urban Reserve or Urban Reserve (Agriculture).

Any development policy, standard, or condition that does not comply with the Housing Crisis Act is considered to be void. Therefore, the above- mentioned provisions would likely be deemed void if challenged and if the Initiative passes , as they have been determined to lessen the intensity of housing.

Furthermore, the proposed revisions to parking standards under the Initiative would also conflict with the state density bonus law’s parking requirements for 1.5 spaces for units with two bedrooms or more, since the Initiative proposes to require two covered parking spaces for two or more bedroom units.

The City’s RHNA strategy was developed under the assumption that development would occur at densities up to 27 du/ac and up to 3 stories in height. In the event that the Initiative passes, the Initiative would not have an effect on the City’s ability to meet its RHNA obligation.

4.2 NON-GOVERNMENTAL CONSTRAINTS
Market forces and environmental considerations can have a substantial impact on the local economy and housing stock. These forces, such as land and construction costs, availability of financing and local economic conditions are outside the control of government; however, local governments can help to mitigate negative consequences of market forces through programs and policy initiatives.

4.2.1 Environmental Constraints
Fire
In Redlands, the highest wildfire risk areas are in San Timoteo and Live Oak Canyons and their neighboring ridgelines. Prolonged droughts coupled with high winds and dry vegetation during summertime creates the highest fire risk in these areas. Left uncontrolled, these fires have the potential to damage or destroy structures, roadways, and utility systems, and disrupt the economy.

The potential for wildland fires can be considered a constraint to development in this portion of Redlands.

Thus, programs have been included in this Housing Element u pdate to direct development away from areas at higher risk of wildland fires and closer to areas less prone to wildfires.

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Flood
Flooding has historically been a concern in Redlands, where moderate to heavy storms can overwhelm the area’s drainages and intermittent waterways. Redlands is drained by four streams, each of which represents a potential flood hazard at peak flows: the Santa Ana River/Mill Creek, the Mill Creek Zanja (also known as Mission Zanja and Mission Storm Drain), San Timoteo Creek, and Live Oak Creek. The Santa Ana River/Mill Creek and the Mission Zanja pose particular flooding hazards to the Redlands.

In order to combat this significant flood risk, the City has been proactive with its building code. The Redlands Zoning Ordinance implements the policies of the General Plan. It contains provisions to mitigate potential hazards on floodplains. Chapter 18.136 establishes the Floodplain District (F P), which prohibits occupancy or encroachment of any structure or development that would obstruct the natural flow of floodwaters within a designated floodway (like the San Timoteo Creek or Santa Ana River) ; ensures that developments in the floodplain outs ide of the floodway remain above the design flood flow elevation; and prevents economic loss of loss of life or property from excessive flooding.

Much of the TVSP area is within a 100-year flood zone. The City’s Municipal Code provides standards for building within the floodplain that includes standards for both new and repurposed buildings. No special approval or entitlement is needed to construct in the flood zone, only that the building pad be elevated at least 2 feet above the 100 -year flood elevation. Because any new or repurposed building would be constructed above the flood elevation, the risk of flood damage is no greater than for dwelling units outside the flood zone.

Thus, compliance with existing building codes would not pose an environmental con straint to housing development.

4.2.2 The Local Housing Market
The value of housing in Redlands has gone up dramatically since 2000. Between 2000 and 2018, median home sales prices in Redlands increased 300 percent. In 2020 the median home sales prices in Redla nds were $499,105.
15 Overall, Redlands has the highest median home sales price compared to communities nearby. In 2020, the average price of a 3-bedroom home is approximately 2.25 times more expensive than in 2003.

According to the City’s Annual Progress Reports (APRs) the vast majority of housing produced in the City in recent years has been a bove moderate-income housing. While the City has little control over market perceptions and orientation, it can affect how that orientation is translated into housing products through its efforts to encourage the construction of affordable housing and to provide a regulatory climate to support that effort.

15 https://www.zillow.com/redlands-ca/home-values/)

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TABLE 4-3: MEDIAN HOME SALE PRICES IN REDLANDS AND NEARBY COMMUNITIES City 2000 2012 2020
San Bernardino $94,300 $119,536 $324,881
Highland $122,200 $180,000 $365,250
Redlands $152,200 $241,898 $456,332
Yucaipa $116,400 $190,000 $404,175
Loma Linda $151,300 $191,000 $450,890
Source: DQNews.com; 2013 CityData; Zillow 2020.

TABLE 4-4: REDLANDS MEDIAN HOME SALES, 2003, 2007, 2012, 2020 Number of
Beds
Year
2003 2007 2012 2020
Condominiums
1 $100,000 $160,000 $55,000 $139,000
2 $249,500 $255,500 $97,000 $195,000
3 $225,000 $290,000 $130,000 $305,000
Single Family Homes
1 $187,000 $382,500 $125,750 -
2 $153,000 $325,000 $165,250 $345,000
3 $220,000 $380,000 $200,000 $499,000
4 $207,000 $431,750 $280,000 $639,000
5 $610,000 $635,000 $401,000 $942,500
Sources: First American Real Estate Solutions (from County Assessor Data); HR&A, Inc; DQNews.com, 2013; Zillow 2020.

4.2.2.1 Land Costs
Land costs are one of the major components of housing development costs. Land prices vary to such an extent that it is difficult to give average prices within small geographic regions. Factors affecting the costs of land include overall availability within a given subregion; environmental site conditions and constraints; public service and infrastructure availability; aesthetic considerations such as views, terrain, and vegetation; the proximity to urban areas; and parcel size.

Rising costs of land are often related to the limited availability of buildable land. In San Bernardino County, which has large expanses of buildable land, this has not historically been considered a problem. Recent sales data indicates that in Redlands the price per square foot of raw land ranges from $0.15 in rural, hillside areas of the City to $25.25 in the downtown area. 16 16 ( www.zillow.com Accessed April 15, 2021)

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4.2.2.2 Construction Costs
The cost of construction depends primarily on the cost of materials and labor, which are influenced by market demand. The cost of construction will also depend on the type of unit being built and on the quality of product being produced. The cost of labor is based on a number of factors, including housing demand, the number of contractors in the area, and the unionization of workers.

The construction cost of housing affects the affordability of new housing and may be considered a constraint to affordable housing in San Bernardino County. A reduction in construction costs can be brought about in several ways. A reduction in amenities a nd quality of building materials in new homes (still above the minimum acceptability for health, safety, and adequate performance) may result in lower sales prices. State housing law provides that local building departments can authorize the use of materials and construction methods if the proposed design is found to be satisfactory and the materials or methods are at least equivalent to that prescribed by the applicable building codes.

In addition, prefabricated, factory-built housing may provide lower-priced products by reducing labor and material costs. As the number of units built at once increases, savings in construction costs over the entire development are generally realized as a result of an economy of scale, particularly when combined with density bonus provisions.

Using current pricing sources, the average costs for a newly constructed 2,000 -square-foot single-family home (not including land) in the Redlands region would cost between $228,000 and $338,000. At the time of the writing of this Housing Element update, materials costs are increasing, namely lumber prices.

Lumber prices have risen more than 250 percent in the last year and the National Association of Homebuilders noted the increases added more than $24,000 to the price of the average sing le-family home.
17 This price increase is a result of limited domestic supply because of the COVID-19 pandemic. Until the domestic lumber supply can catch up to the demand, prices will remain high and home builders will likely continue to pass the cost to homebuyers.

4.2.2.3 Interest Costs and Availability of Financing
Interest rates are determined by national policies and economic conditions, and there is little that local governments can do to affect these rates. Jurisdictions can, however, offer interest rate write -downs to extend home purchase opportunities to lower-income households. In addition, government-insured loan programs may be available to reduce mortgage down-payment requirements.

It can be difficult for very low-, low-, and moderate-income first-time homebuyers to acquire sufficient savings and income to pay for a down payment, closing costs, monthly mortgage, and tax and insurance payments.

4.2.2.4 Consumer Interest Rates
Even small increases to home loan interest rates can substantially affect monthly housing costs and reduce affordability to low - and moderate-income households. Table 4-5 shows how changes in interest rates

17 https://markets.businessinsider.com/news/stocks/lumber-prices-hit-record-highs-soaring-past-year-2021-4-1030299977

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affect borrowing costs. For each one percentage point increase in the interest rate, borrowing costs increase by 6 to 7 percent for a 15 -year home loan and 20 percent if the increase is from five to eight percentage points. For a 30-year loan, the effects are even more pronounced: each one percentage point increases the monthly payment 10 to 11 percent— nearly 37 percent if the increase is from five to eight percentage points.

TABLE 4-5: IMPACT OF INTEREST RATES ON MONTHLY MORTGAGE PAYMENTS

Monthly Payment on a 15-Year Loan Monthly Payment on a 30-Year Loan 5% 6% 7% 8% 5% 6% 7% 8%
$100,000 $791 $844 $899 $956 $537 $600 $665 $734
$150,000 $1,187 $1,266 $1,349 $1,434 $806 $900 $998 $1,101 $200,000 $1,582 $1,688 $1,798 $1,912 $1,074 $1,200 $1,330 $1,468 $250,000 $1,978 $2,110 $2,248 $2,390 $1,343 $1,500 $1,663 $1,835 $300,000 $2,373 $2,532 $2,697 $2,868 $1,611 $1,800 $1,995 $2,202 $350,000 $2,769 $2,954 $3,147 $3,346 $1,880 $2,100 $2,328 $2,569 $400,000 $3,164 $3,376 $3,596 $3,824 $2,148 $2,400 $2,660 $2,936 $450,000 $3,560 $3,798 $4,046 $4,302 $2,417 $2,700 $2,993 $3,303 $500,000 $3,955 $4,220 $4,495 $4,780 $2,685 $3,000 $3,325 $3,670 Source: City of Redlands 5th Cycle Housing Element.

Many consumers mitigate the impact of rising interest rates by purchasing adjustable rate mortgages that typically begin with substantially lower introductory rates. Adjustable rate mortgages allow a borrower’s interest cost, and monthly payment, to rise or fall with market rates. In a rising interest rate climate, adjustable rate mortgages can offer substantial short-term savings over a fixed-rate loan. In a declining or highly volatile interest rate climate, adjustable rate mortgages can lead to higher short -term costs, as demonstrated in 2007. Presently, interest ra tes are at near historic lows which has increased the purchasing power of homebuyers; however this advantage has been offset by the increasing cost of new housing and has fanned the rapid increase of existing home prices.

4.2.2.5 Developer Interest Rates
Higher interest rates increase the cost of doing business for developers in two ways: (1) construction costs rise (most residential development is financed, at least in part, through construction loans), and (2) permanent borrowing costs increase. Table 4-6 shows the impact of changes in loan rates on the monthly rent for hypothetical apartment projects that are privately financed and that receive state and/or federal funds. Three per-unit project costs are assumed: (1) a small apartment complex with minimal amenities that costs $80,000 per unit to construct, (2) a medium quality apartment complex with average amenities that costs $90,000 per unit to construct, and (3) a luxury apartment complex that costs $100,000 per unit to construct. In each case the properties include a mix of one- and two -bedroom apartments. These examples assume that 75 percent of the project is financed at a commercial lending rate for a term of 15 years.

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Therefore, a three percentage point increase in interest rates for permanent financing, from 6 percent to 9 percent, will increase the per unit borrowing cost by 20 percent and the overall per unit cost (accounting for operation and maintenance expenses) by about 10 percent.

TABLE 4-6: IMPACT OF INTEREST RATES ON COMMERCIAL BORROWING COSTS Per Unit Loan
Amount (75%
Financed)
Interest Rates
6% 7% 8% 9% 10%
$60,000 $506 $539 $574 $608 $645
$67,500 $570 $607 $645 $684 $726
$75,000 $633 $674 $717 $761 $806
Source: City of Redlands 5th Cycle Housing Element.

4.2.2.6 Financing Availability and Distribution
Given the increase in defaults on mortgages in Redlands and elsewhere in the region that resulted from the 2008 financial crisis, as well as the subsequent reaction from the Federal Reserve, the ability to borrow money has become more difficult. According to the 5th Cycle Housing Element, the most severe lending problem appeared to be with long- time homeowners in North Redlands who have substantial deferred maintenance on their properties. These owners often have trouble accessing capital to make improvements on their homes. Home Mortgage Disclosure Act data from 2019 supports this assertion as a continuing condition . The rate of approval for home improvement loans in North Redlands was 20 percent lower compared with approval rates for home purchase loans. In census tract 78 (Lugonia Colony area), no home improvement loans were originated in 2019. 18 As for new homebuyers, there does not seem to be a problem obtaining loans from the bank, as long as the borrower has good credit. The Home Mortgage Disclosure Act data confirms that borrowing rates are fairly consistent throughout the city. On average, 72 percent of home pu rchase loans were approved in the city, up 2 percent from 2013; the rate in North Redlands is lower at 68.5 percent, although one census tract in the neighborhood reports approval rates at 67 percent, the same as 2013. With the recent sub - prime mortgage crisis, lenders may be unwilling or not permitted under new standards to offer mortgages to individuals with low credit ratings. On the other hand, recent cuts to short -term interest rates by the Federal Reserve may lead to a decrease in mortgage rates, encouraging borrowing for mortgages and construction loans. In addition, deferred maintenance has become an issue with resales as well, since homes being purchased must be up to code.

18 Federal Financial Institutions Examination Council. Home Mortgage Disclosure Act. 2019 Mortgage Application and Approval Data by Census Tract.

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5 QUANTIFIED OBJECTIVES, HOUSING GOALS, POLICIES, AND

PROGRAMS
The goals, policies, and programs delineated in this chapter serve to support the State of California’s overarching aim of providing “decent housing and a suitable living environment for every Californian…is a priority of the highest order” (Government Code Section 65580). This Housing Element updates the prior list of programs by removing those that no longer serve the mission of providing housing for all, and includes new programs aimed at implementing meaningful and impactful change. Specifically, several of these new policies are tailored to the Transit Villages Specific Plan (TVSP) that the City is currently developing.

According to Government Code Section 65583 (b), local governments ’ housing elements are required to establish quantified objectives for the maximu m number of housing units which can be constructed, rehabilitated, and conserved over a five-year time frame. The objective for units to be conserved should include a subtotal for the number of at-risk units developed pursuant to Government Code Section 65583 (a)(9)(A).

Table 5-1 presents the Housing Element’s quantified housing objectives pursuant to Government Code Section 65583 (a)(9)(A).

TABLE 5-1: QUANTIFIED OBJECTIVES, 2021-2029
Category
Extremely
Low
Income
Very
Low
Income
Low
Income
Moderate
Income
Above-
Moderate
Income
Total
Objective
New Construction 160 160 320 480 480 1,600
Rehabilitation 20 20 100 0 0 140
Preservation of Units at
Risk
30 30 0 0 0 60
Note: Populated figures are estimated averages for each category.

The housing goals, policies, and programs that follow were created for the purpose of meeting the housing needs of the citizens of Redlands throughout the 2021-2029 planning period.  Goals are the results that the City desires to achieve over the housing p lanning period. They are general expressions of values and aspirational outcomes and as a result, may not be fully attained.

The goals are the foundation of the policies and actions to be implemented over the housing planning period.
 Policies are specific statements that guide decision -making. Policies serve as the fundamental tenets that support the overarching goal, and are statements of broad direction, philosophy, or standards to be achieved.
 Programs are the core of the City’s housing strategy, translating goals and policies into actions.

These include ongoing programs, Z oning Ordinance changes, procedural changes, and other

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actions that implement the housing policies and help the City achieve its goals. Each program identifies the responsible agency, funding source, time frame for implementation, and specific objectives.

5.1 GOAL: HOUSING DEVELOPMENT AND VARIETY
A housing stock comprising of a variety of housing and tenancy types at a range of prices, within close proximity to services and opportunity, which meets the varied needs of existing and future City residents, who represent a full spectrum of age, income, and other demographic characteristics.

5.1.1 Policies

1.1 Provide adequate capacity to meet the Sites Inventory for Regional Housing Needs Assessment (RHNA).

1.2 Increase capacity and access to opportunities and services through the adoption of the Transit Villages Specific Plan.

1.3 Provide housing capacity near public services.

1.4 Realize capacity potential through minimum densities.

1.5 Maintain an up -to-date reside ntial sites inventory and provide to interested developers with information on available development incentives.

1.6 Support the assembly of small vacant or underutilized parcels to enhance the feasibility of infill development.

1.7 Ensure that residential development sites have appropriate and adequate services and facilities, including water, wastewater, and neighborhood infrastructure.

1.8 Incentivize the development of Accessory Dwelling Units as a means of providing a diversity in housing types in all areas within the City.

1.9 Incentivize efficient buildings and conservation.

5.2 GOAL: REMOVAL OF CONSTRAINTS TO THE PRODUCTION OF

HOUSING
Removal of governmental policies or regulations that unnecessarily constrain the development, improvement, or conservation of market -rate or affordable housing. Also includes the sharing of information related to environmental and market constraints to identify challenges early in the development process.

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5.2.1 Policies

2.1 Periodically review and update the Zoning Ordinance to stay abreast of updates to State law to reduce constraints to emergency shelters, low barrier navigation centers, supportive housing, and group homes.

2.2 Periodically review and update the Zoning Ordinance to address constraints on housing yield posed by development standards.

2.3 Establish objective design standards to facilitate streamlined project permitting.

2.4 Evaluate fee structures and permit costs to incentivize housing production.

2.5 Allow by -right approval of projects containing 20% or more units affordable to lower- income households.

2.6 Facilitate the production of mixed- use housing by clarifying development standards and evaluating the public review process for mixed-use development.

2.7 Continue to provide pre -application services and assistance to developers to identify non - governmental constraints early in the development process.

5.3 GOAL: PRIORITIZATION OF HOUSING FOR LOWER AND MODERATE

INCOME AND SPECIAL NEEDS POPULATIONS
Adequate provision of housing for lower and moderate income and special needs populations requires special attention and prioritization from identifying sites, facilitating the development process, and maintaining and preserving housing. Includes services directed at homelessness and education for property owners and landlords.

5.3.1 Policies

3.1 Incentivize development of affordable housing by leveraging density bonuses.

3.2 Prevent displacement through the provision of replacement units at the same income level.

3.3 Prioritize water and wastewater service for affordable housing developments.

3.4 Working with the Housing Authority of San Bernardino County, provide outreach and education for tenants and landlords.

3.5 Working with the Housing Authority of San Bernardino County, a ctively address h omelessness through coordination with service providers.

3.6 Examine an inclusionary housing ordinance as a means of providing affordable housing.

3.7 Prioritize surplus lands for affordable housing development.

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5.4 GOAL: INCENTIVIZE AND PRESERVE HOUSING
Programs that conserve housing currently available and affordable to lower- income households, and programs that prevent or reverse deterioration in areas exhibiting symptoms of physical decline.

5.4.1 Policies

4.1 Coordinate with the Housing Authority of the County of San Bern ardino to m onitor, track and encourage preservation of affordable housing at-risk of loss or conversion to market rate housing.

4.2 Connect owners to resources to rehabilitate and improve the condition of existing affordable housing stock.

5.5 GOAL: AFFIRMATIVELY FURTHERING FAIR HOUSING
Promote equal opportunity for all residents to reside in the housing of their choice regardless of their special characteristics as protected under State and Federal fair housing law.

5.5.1 Policies

5.1 Prohibit discrimination in the sale or rental of housing with regard to characteristics protected under State and Federal fair housing laws.

5.2 Encourage the development of residential units that are accessible to disabled persons or are adaptable for conversion to residential use by disabled persons.

5.3 Reasonably accommodate persons with disabilities who seek waiver or modification of land use controls and/or development standards pursuant to procedures and criteria set forth in the Zoning Ordinance.

5.4 Accommodate emergency shelters, low barrier navigation center, transitional housing, supportive housing, residential care facilities, and community care facilities in compliance with State laws.

5.5 Improve awareness, access, and use of education, training, complaint investigation, mediation services of the fair housing service provider, particularly in areas sensitive to displacement, low- income, racial/ethnic concentration, disability or other fair housing considerations.

5.6 GOAL: VARIED AND ADEQUATE FUNDING SOURCES
Identification of funding streams from a variety of sources to provide financial assistance to service providers and to fund programs.

5.6.1 Policies

6.1 Identify and review opportunities for funding.

6.2 Share funding opportunities with the development community/service providers.

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5.7 HOUSING PROGRAMS

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TABLE 5-1: PROPOSED PROGRAMS
Index
Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g

1.1 RHNA/Community
Planning

1.1-1 1.1-1 RHNA Rezoning Within three years of Housing Element adoption, rezone
land to provide adequate
capacity for at least 4,219
units on suitable sites.
- 1,898 very low and low
income units
- 782 moderate Income units
- 1,538 above moderate
income units
The rezoning program would
rezone a minimum of 119
acres and provide for 30
du/ac with a minimum
density of 20 du/ac for lower-
income sites. Each site will be
able to accommodate a
minimum of 16 units. The
City will incorporate a
replacement housing
provision for any sites with
existing residential use and
will permit multifamily uses
without discretionary action.

October
2024
- 1,898 very low
and low income
units
- 782 moderate
Income units
- 1,538 above
moderate income
units
-119 acres rezoned
City of
Redlands
Developmen
t Services
Department
Staff time

1.1-2 1.1-2 Measure U Analysis The City will conduct a detailed legal analysis of all
2022 Adopted Resolution
by City Council
City of
Redlands
City

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Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
aspects of Measure U to
evaluate the consistency of
Measure U provisions with
State housing laws.
making
determinations on
Measure U
implementation
Developmen
t Services
Department
and City
Attorney’s
Office

1.1-3 1.1-3 Transit Villages
Specific Plan
Adopt the Transit Villages
Specific Plan by the end of
2022 to allow for greater
residential development
around the three new light
rail stations, and implement
objective design standards
with a form-based code. Use
the TVSP to facilitate smart-
growth planning principles,
downtown revitalization, and
infill development. The TVSP
will allow for residential
densities per the 2035
General Plan and 6
th Cycle
Housing Element and allow
multi-family residential uses.

TVSP area is a total of 947
acres.

Currently 60 acres of vacant
land available for mixed-use
development within TVSP
area.

December
2022
Adopted specific
plan
City of
Redlands
Developmen
t Services
Department
Staff time

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Index
Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
Draft TVSP use list allows
multiple housing types by-
right (Permitted use)
including supportive and
transitional housing.

1.1-4 1.1-4 By-Right Approval of
Projects with 20
Percent Affordable
Units on “Reused”
Site
Pursuant to AB 1397, amend
the Zoning Ordinance to
require by-right approval of
housing development that
includes 20 percent of the
units as housing affordable to
lower-income households, on
sites being used to meet the
6th Cycle RHNA that
represent “reuse sites”
previously identified in the
4th and 5th Cycles Housing
Element, and on sites that
are being rezoned to
accommodate the lower-
income RHNA.

October
2024
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff time

1.1-5 1.1-5 No Net Loss
Monitoring
Pursuant to SB 166 (No Net
Loss), the City will develop a
procedure to track:
• Unit count and
income/affordability assumed
on parcels included in the
sites inventory.
• Actual units constructed and
income/affordability when
parcels are developed.

Developme
nt of the
procedure
by October
2022,
ongoing
maintenanc
e thereafter
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff time

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Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
• Net change in capacity and
summary of remaining
capacity in meeting remaining
RHNA.

1.1-6 1.1-6 Minimum Densities Amend the Zoning Ordinance to establish minimum
densities for residential and
mixed-use zones to ensure
that residential projects are
developed close to their
maximum densities (70% of
the maximum allowed by
base-zoning).

October
2024
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff time

1.1-7 1.1-7 Achieving the General
Plan Densities
Amend the zoning ordinance
to ensure it is consistent with
the Redlands 2035 General
Plan. Specifically, ensure each
implementing zone allows up
to the maximum permitted by
the General Plan, pursuant to
AB 3194.

October
2024
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff time

1.1-8 1.1-8 Development on Non-
Vacant Sites
Establish an outreach and
coordination program through
the Economic Development
Division to connect
developers, builders, and
owners of non-vacant sites.

Program shall:
(1) Emphasize reaching out
to owners of on-vacant sites
to discuss any interest in
Initiate by
October
2022, and
maintain
throughout
planning
period on a
quarterly
basis.

Engage with 10
property owners of
high-potential non-
vacant sites each
year.

City of
Redlands
Economic
Developmen
t Division
Staff Time

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Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
redeveloping and available
incentives.
(2) Marketing and advertising
these sites to the
development community
along with any incentives that
might be available.
(3) Establish quarterly
meetings with developers and
builders.

1.1-9 1.1-9 Lot Consolidation and
Small Site
Development
The City may consider
incentives to achieve orderly
development, improve
pedestrian activity, and
implement the goals, policies,
and objectives of the Housing
Element. The following
incentives may be considered
at the discretion of the
(Planning Commission/City
Council):
(1) Parking reduction
(2) Alternative parking
arrangements
(3) Signage bonus. City shall
advertise and promote lot
consolidation provisions to
existing property owners and
prospective mixed-use
developers.

Develop
incentives
by October
2022 and
adopt
Zoning
Ordinance
Amendmen
t by
October
2023
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff Time

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Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g

1.2 Removal of
Constraints to the
Production of
Housing

1.2-1 1.2-1 Emergency Shelters Update the zoning ordinance to amend standards for
emergency shelters to comply
with recent changes to state
law (AB 139).

October
2022
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff time

1.2-2 1.2-2 Low Barrier
Navigation Centers
Update the zoning ordinance
to provide opportunities for
Low Barrier Navigation
Centers to comply with recent
changes to state law (AB
101).

October
2022
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff time

1.2-3 1.2-3 Transitional and
Supportive Housing
Update the zoning ordinance
to comply with changes to
state law regarding
Transitional and Supportive
Housing, including allowing
supportive housing by-right in
zones where multifamily and
mixed uses are permitted,
pursuant to Government
Code section 65651. (SB 745
and AB 2162).

October
2022
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff time

1.2-4 1.2-4 SRO Ordinance Adopt a Single Room
Occupancy (SRO) ordinance
to provide additional housing
opportunity for low- and very
low-income households near
October
2022
Adopted code
amendments
City of
Redlands
Developmen
Staff time

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m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
the planned Metrolink/Arrow
light rail stations.
t Services
Department

1.2-5 1.2-5 Group Homes Review zoning provisions for
large group homes (7+
persons) and implement
mitigating strategies to
remove potential constraints
on the production of large
group homes. Ensure zoning
standards facilitate approval
certainty and objectivity in
the development of large
group homes.

Amend the Zoning Ordinance
to allow group homes in all
zones that allow residential
uses.

Amend Zoning Ordinance to
clarify group homes/
community care facilities of 6
or fewer people do not need
to be licensed by the State.

October
2022
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff time

1.2-6 1.2-6 FAR based
development fees
Study and consider FAR
based development fees (as
opposed to unit based fees)
to create financial incentives
for the creation of additional
units.

June 2025 Adopted code or
free schedule
amendments
City of
Redlands
Developmen
t Services
Department
/ Finance
Department
Staff time

1.2-7 1.2-7 Amend Development
Standards
Amend parking requirements,
open-space standards, and
December
2023
Adopted code
amendments
City of
Redlands
Staff time

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Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
setbacks for multi-family
properties to further
incentivize and encourage
higher density development.

Developmen
t Services
Department

1.2-8 1.2-8 Ballot Measures:

SECBS
Ensure that Socio Economic
Cost Benefit Studies are
reviewed and analyzed in an
objective manner. Develop
objective standards and
thresholds for the SECBS
checklist.

By October 2024, complete a
City-initiated study that
evaluates the effectiveness of
measures and consider
alternative actions if needed.

October
2023
Adopted code
amendments or
official
interpretation
City of
Redlands
Developmen
t Services
Department
Staff time

1.2-9 1.2-9 Ballot Measures:

Environmental
Impacts
Clarify and implement the "no
environmental impact"
provision of the ballot
measures to allow and
mitigate potentially significant
impacts as allowed by CEQA .

October
2023
Adopted code
amendments or
official
interpretation
City of
Redlands
Developmen
t Services
Department
Staff time

1.2-10 1.2-10 Objective Design
Standards: SB 330
Pursuant to SB 330, review
and revise development
standards and design
guidelines by the end of 2023
to ensure City requirements
are objective, neutral, and
feasible. Prior to the adoption
of objective standards, City
will continue to apply current
December
2023
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff time

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Index
Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
standards in an objective
manner.

1.2-11 1.2-11 Density Bonus
Update
Amend the Density Bonus
Ordinance to comply with
recent changes to state law
(AB 2345).

October
2024
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff time

1.2-12 1.2-12 Mixed Uses in
Commercial Zones
Amend the City's C-3, C-4,
and A-P zones to create
objective standards for
mixed-uses and facilitate the
redevelopment of commercial
sites to mixed-use.

October
2024
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff time

1.2-13 1.2-13 Remove CUP
Requirement for
Multi-Family
Developments
Amend the zoning ordinance
to remove the conditional use
permit requirement for multi-
family developments of 35
units or more.

October
2024
Adopted code
amendments
City of
Redlands
Developmen
t Services
Department
Staff time

1.2-14 1.2-14 Waive preapplication
fee for affordable
housing projects
Mitigate non-governmental
and financial constraints by
waiving pre-application
meeting fees and providing
technical assistance to
housing projects that propose
to provide below market-rate
units.

Provide expedited processing
for projects that propose low-
income, extremely low-
October
2022
Amended fee
schedule
City of
Redlands
Developmen
t Services
Department
Staff time

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Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
income, or special needs
units.

1.2-15 1.2-15 Non-governmental
constraints.

Environmental
Information Mapped.

Continue to provide
information and maps of
known environmental
constraints at the planning
and zoning counter to provide
additional clarity and certainty
and mitigate non-
governmental constraints for
project applicants.

Ongoing Annually re-
examine
information and
maps of known
environmental
constraints and
update
informational
materials for the
public.

City of
Redlands
Developmen
t Services
Department
Staff time

1.2-16 1.2-16 Floodplain
Development
Review the City’s
development standards (such
as setbacks, lot dimensions,
etc.) within the floodplain to
reduce the need for variances
for projects needing to
elevate structures to meet
FEMA floodplain
requirements. Current code
requires buildings to be sited
near the sidewalk for urban
development, however this
presents challenges with
elevating building pads out of
the flood zone.

December
2023
Adopted code
amendments;
adopt and
implement Transit
Village Specific Plan
City of
Redlands
Developmen
t Services
Department
Staff time

1.2-17 1.2-17 Definition of Family Amend the definition of family to comply with state law.

December
2022
Adopted Code
Amendments
City of
Redlands
Developmen
Staff time

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Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
t Services
Department

1.2-18 1.2-18 Employee and
Farmworker Housing
Pursuant to Health and Safety
Code section 17021.5, define
and permit employee housing
in compliance with the
Employee Housing Act. Revise
zoning to allow farmworker
housing in all agricultural
zones throughout the City.

Pursuant to Health and Safety
Code section 17021.6,
employee housing for six or
fewer employees is treated as
a single-family structure and
permitted in the same
manner as other dwellings of
the same type in the same
zone. Employee housing
consisting of no more than 12
units or 36 beds to be
permitted in the same
manner as other agricultural
uses in the same zone. Revise
zoning to allow employee
housing in all applicable
zones throughout the City.

December
2022
Adopted Code
Amendments
City of
Redlands
Developmen
t Services
Department
Staff time

1.2-19 1.2-19 Streamlined
Ministerial Approval
Permit Procedures
The City will review its
approval processes to ensure
it accommodates streamlined
applications, pursuant to
Senate Bill 35.

Ongoing City of
Redlands
Developmen
t Services
Department
Staff Time

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Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
/ Facilities
and
Community
Services
Department

1.2-20 1.2-20 Extend Affordability
Covenant Time
Length
The City will extend the
affordability covenant time
length from 55 years to 99
years
Adopted Code
Amendments
City of
Redlands
Developmen
t Services
Department
/ Facilities
and
Community
Services
Department
Staff time

1.3 Prioritization of
Housing for Lower
and Moderate
Income and
Special Needs
Populations

1.3-1 1.3-1 Surplus Lands Annually review and assess
City-owned properties and
determine if they are
considered "surplus lands"
pursuant to the Surplus Lands
Act. Dispose of any surplus
property pursuant to the act
and HCD guidance. City will
initiate zone changes as
Annually Annual report City of
Redlands
Developmen
t Services
Department
/ Facilities
and
Community
Services
Department
Staff time

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Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
necessary to facilitate housing
development.

1.3-2 1.3-2 Inclusionary Housing
Ordinance
Conduct a feasibility study on
the financial viability and
potential of an inclusionary
housing ordinance. If
appropriate and financially
feasible, adopt an
inclusionary ordinance.

October
2023
Draft report and
code amendments
City of
Redlands
Developmen
t Services
Department
Staff time

1.3-3 1.3-3 Displacement
Prevention (SB 330
and AB 1397)
Pursuant to State law, amend
the Zoning Ordinance by the
end of 2022 to require the
replacement of units
affordable to the same or
lower income level as a
condition of any development
on a non-vacant site
consistent with those
requirements set forth in the
State Density Bonus Law.

December
2022
No net loss of lower
income units
City of
Redlands
Developmen
t Services
Department
Staff time

1.3-4 1.3-4 Priority Water and
Wastewater Service
for Affordable
Housing
Developments
Adopt written policies and
procedures consistent with
State law. .

Adopt by
October
2022.

City of
Redlands
Developmen
t Services
Department
/ Municipal
Utilities and
Engineering
Department
Staff Time

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Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g

1.3-5 1.3-5 Rental Inspection
Program / Landlord
Registration
The Rental Inspection
Program enhances the quality
of rental properties and
thereby the quality of life for
tenants throughout the City
and ensures that all rental
properties are maintained in
accordance with City
standards. City inspectors
inspect rental properties for
exterior code violations and
will issue corrective reports to
property owners/landlords.

Examples of reportable issues
include: roof leaks, unsafe
fire conditions, unsafe stairs,
unmaintained landscaping or
parking/driving areas.

Ongoing Annually updated
registry
City of
Redlands
Facilities
and
Community
Services
Department
Staff Time

1.3-6 1.3-6 Outreach and
Education
Educate and inform landlords
about AFFH through
continuation of the Crime
Free Program. Provide
information and educational
materials for Housing Choice
Vouchers, foreclosure
assistance programs, the
state’s new source of income
protection (SB 329 and SB
222) on the City website and
at the public counter.

Initiate by
October
2022.

Provide
materials
on an on-
going
basis. The
website will
be updated
annually.

Updated website
and counter
materials
City of
Redlands
Police
Department
/ Facilities
and
Community
Services
Department
Staff time

1.3-7 1.3-7 Homeless Support Administer CDBG funds
received from the County to
Ongoing Allocate between
$10,000 to $12,000
City of
Redlands
Staff time

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Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
service providers including
local nonprofits.

Prioritize funds that will assist
with the development of
housing for the unhoused
population.
of CDBG funds to
provide supportive
and transitional
housing support to
populations in need
including the
homeless
population.

Developmen
t Services
Department
CDBG

1.3-8 1.3-8 Homeless Assistance
Program
Continue the operation of
homeless assistance program
through the Police
Department. Assist in
connecting homeless
individuals to local service
providers, as well as continue
to fund for shelter beds with
available grant funding and
donations.

Ongoing
The city funds 3
shelter beds that
are operated by
Steps 4 Life
through grant
funding, as well as
annual donation
from an
anonymous annual
donation in the
amount of $18,000.

City of
Redlands
Police
Department
General
Fund,
Donation

1.3-9 1.3-9 Facilitate Tenant
Protection Act of
2019 (AB 1482 )
Compliance
Ensure compliance with new
state tenant protection
measures, including
maximum annual rent
increases, just cause
evictions, and financial
compensation requirements
to stabilize residents living in
areas at risk of displacement,
including the area of high
segregation and poverty in
downtown Redlands.

Ongoing

Post
information
within 6
months of
housing
element
adoption
Make information
about the Facilitate
Tenant Protect Act
of 2019 available at
the planning
counter and during
outreach events.

Refer inquiries to
Inland Fair Housing
and Mediation
Board, the City’s
contracted fair
City of
Redlands
Developmen
t Services
Department
Staff Time

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m
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Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
In coordination with Program

1.5-11, provide information to
landlords and tenants
regarding tenant protections
and post information online
and in community centers.
housing service
provider.

1.4 Incentivize and
Preserve Housing

1.4-1 1.4-1 Preservation of at risk
housing
The City has an inventory of
120 publicly assisted housing
units affordable to lower
income households. These
units are deed restricted for
long-term affordability.

Between October 15, 2021
and October 2029, 60 publicly
assisted units at the Citrus
Arms development are on a
5-year contract which has
historically been renewed,
however are considered at
risk of converting to market
rate housing.
- Monitor Project Status
Annually
- Ensure property owners
comply with extended
noticing requirements under
state law.

Annually No net loss of
publicly assisted
housing units –
work with property
owners and
operators to extend
the period of
affordability.

City of
Redlands
Developmen
t Services
Department
Staff time

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Index
Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
- Include preservation as an
eligible use in notices of
funding availability.
- Proactively coordinate with
qualified entities.
-Assist with funding or
support funding applications.
-Educate, support and assist
tenants.

1.4-2 1.4-2 Rehabilitate and
improve condition of
existing affordable
housing stock
Make available on the City
website and at the Planning
Department information on
programs and resources
available to property owners
for assistance with home
repairs and improvements.

Ongoing Provide information
to assist the
rehabilitation low-
income homes.

City of
Redlands
Developmen
t Services
Department
Staff time

1.5 Affirmatively
Furthering Fair
Housing

1.5-1 1.5-1 Place Based
Improvements
The City applies for and
receives an annual allocation
of CDBG funds from the
County. These funds are used
to install and upgrade public
facilities (sidewalks,
alleyways, ADA accessibility
improvements) in lower
income neighborhoods or
where civic services are
offered.

Annually
apply for
CDBG
funds
List of priority
capital
improvements
City of
Redlands
Municipal
Utilities and
Engineering
CDBG

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Index
Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
Prioritize CDBG funds for the
development of low income
housing and special needs
housing, with place based
improvements surrounding
those projects.

1.5-2 1.5-2 Coordinate with
Inland Fair Housing
and Mediation Board
Continue to utilize the
County's contract with the
Inland Fair Housing and
Mediation Board to provide
fair housing services, testing,
and resources to residents of
Redlands.

Ongoing Provide fair housing
services to 100
residents of
Redlands over the
2021-2029 planning
period.

City of
Redlands
Developmen
t Services
Department
Staff time

1.5-3 1.5-3 Promotion of Fair
Housing Information
Publicize Fair Housing
Information, including
information about tenants’
rights, landlord requirements,
and recent litigation on the
City's website, social media
platforms, and through
physical promotional material
(e.g., flyers, posters).

Ongoing Clear and easily
accessible fair
housing resources
City of
Redlands
Developmen
t Services
Department
Staff time

1.5-4 1.5-4 Expand fair housing
outreach in
communities with
disproportionate
needs
Amend and expand fair
housing outreach to facilitate
dialogue with communities
facing disproportionate
needs.

Host a community feedback
meeting annually to obtain
resident feedback on
community planning issues,
Ongoing One fair housing
workshop per year
City of
Redlands
Developmen
t Services
Department
Staff time

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Index
Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
fair housing topics, and
ongoing City programs.

1.5-5 1.5-5 Fair Housing
Reporting
Acquire and analyze data
from Inland Fair Housing and
Mediation Board annually to
review potential areas of fair
housing issues.

Ongoing Conduct analysis
and report
results/findings of
any potential fair
housing issues in
Redlands annually
City of
Redlands
Developmen
t Services
Department
Staff time

1.5-6 1.5-6 Regional Coordination Participate in regional efforts and coordination to respond
to discrimination and fair
housing issues, and monitor
progress towards addressing
impediments to fair housing
choice.

Ongoing City of
Redlands
Developmen
t Services
Department
Staff time

1.5-7 1.5-7 Enforcement of Fair
Housing Laws
Accept Fair Housing violation
complaints and forward to the
Fair Housing and Mediation
Board for enforcement.

Ongoing Track and annually
report the number
and nature of fair
housing questions,
complaints and
referrals to the
service provider.

City of
Redlands
Developmen
t Services
Department
/ Facilities
and
Community
Services
Staff time

1.5-8 1.5-8 Increasing Residential
Development and
Opportunity in Transit
Accessible and Smart
Growth Areas
Through the Transit Villages
Specific Plan, provide
additional capacity for
residential development in
the City's highest opportunity
areas. Implement the TVSP to
revitalize the City's downtown
2023 Annual progress
report on TVSP
implementation.

City of
Redlands
Developmen
t Services
Department
SB2 funds,
Staff time

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Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
and areas around the train
stations, and transform areas
with disproportionate needs
and environmental risks to
areas of high opportunity and
wellbeing.

1.5-9 1.5-9 Mobile Home Park
Preservation
Continue to implement the
Mobile Home Rent Control
ordinance to prevent
displacement of lower-income
and at risk populations.

Ongoing Assist 200 mobile
home unit owners
per year
City of
Redlands
Developmen
t Services
Department
Staff time

1.5-10 1.5-10 NOFA/Nonprofit
Housing Development
Identify funding from federal,
State, and local sources to
expand affordable housing
opportunities within the City
and share these opportunities
with local service providers
and the development
community.

Prioritize these opportunities
to identified developers of
low-income housing and
supportive housing.

Identify
and share
information
by October
2022.

Provide
materials
on a
quarterly
basis.

Updated list of
funding resources.

Send letters to
affordable housing
developers twice a
year to inform the
developers about
the City’s RHNA
inventory.

City of
Redlands
Developmen
t Services
Department
Staff time

1.5-11 1.5-11 Provide training for
multi-family housing
landlords
Continue to provide 2-day
Crime-Free Multi-
Housing/Rental Property
Training to multi-family
landlords in the City to
educate landlords on a wide
range of issues including
eviction process, Fair Housing
Ongoing Minimum of once
per year
City of
Redlands
Police
Department
Staff time
with
volunteer
assistance

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Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
issues, tenant screening,
acceptance of HCVs as a
legitimate source of income,
and others. Ensure that
landlords are aware of new
source of income
discrimination laws.

1.6 Accessory Dwelling
Units

1.6-1 1.6-1 Educational
Campaign and
Information
Promote information and
tools available to facilitate
ADU construction. Provide
easily accessible information
on the City's website, at the
zoning counter. Coordinate
with SBCTA to utilize regional
resources and adopt policies,
procedures, and standards
consistent with neighboring
jurisdictions to streamline
ADU applications.

Encourage ADU and SB 9
production in southern
Redlands and high resource
areas.

Identify
information
resources
and tools
by October
2022 and
provide
information
on an
ongoing
basis.

Increase ADU
production
annually.

Revise fee
structures to
reduce cost for
constructing ADUs.

City of
Redlands
Developmen
t Services
Department
Staff time

1.6-2 1.6-2 Pre-Approved Plan
Sets
Make a variety of example
ADU plan sets available to
facilitate reduced applicant
cost and expedited review for
ADUs. Ensure example plans
October
2022
3 example or model
ADU plan sets
City of
Redlands
Developmen
t Services
Department
Staff time
SBCTA
REAP
funded

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Index
Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g
provide choices and diversity
in size to accommodate a
variety of household sizes
and types.

ADU
program

1.6-3 1.6-3 Updated ADU
Regulations to meet
state law
Amend the Zoning Ordinance
to address multiple recent
changes to state law
regarding ADUs (including AB
587, AB 671, AB 68, and SB
13). Monitor state law on an
ongoing basis and revise the
Zoning Ordinance as
appropriate.

October
2024
Annual assessment
for consistency
City of
Redlands
Developmen
t Services
Department
Staff time

1.6-4 1.6-4 ADU Tracking and
Monitoring
Annually monitor the
development and affordability
of ADUs. If trends indicate a
potential shortfall in meeting
the estimated ADUs in the
sites inventory, consider
additional efforts to
incentivize ADU production
and reassess and revise the
overall sites strategy for the
RHNA within one year
through adjusting ADU
capacity assumptions with
actual permitted units, and/or
identifying additional sites to
expand site capacity to the
extent necessary to
accommodate the RHNA.

Ongoing Annual Progress
Report and ADU
construction
City of
Redlands
Developmen
t Services
Department
Staff time

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Index
Number
Progra
m
Number Program Title
Program/Action
Description
Completio
n Time
Frame
Quantified
Objective
Responsibl
e Agency
Financin
g

1.7 Efficient Buildings
and Conservation

1.7-1 1.7-1 Reclaimed Water Continue to require the
installation of reclaimed water
infrastructure by new
development when feasible.

Ongoing Approve reclaimed
water for 500 units.

City of
Redlands
Municipal
Utilities and
Engineering
Staff time

1.7-2 1.7-2 Lighting efficiency Make available and distribute informational materials during
the building permit process
about energy-efficient lighting
for residential buildings.

Ongoing
activity,
post
information
on City
website by
October
2022
Retrofit lighting
efficiency for at
least 100
residential units.

City of
Redlands
Building and
Safety
Division
Staff time

1.7-3 1.7-3 Pursue Energy
Efficient/Alternative
Energy Funding
Increase efficiency and
pursue alternative energy
opportunities.

Ongoing 100 residential
units retrofitted for
emergency
efficiency.

City of
Redlands
Building and
Safety
Division
Staff time

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6 REVIEW OF PAST ACCOMPLISHMENTS

6.1 PURPOSE OF REVIEW
State law (California Government Code S ection 65588(a)) requires that each jurisdiction “ review its housing element as frequently as appropriate to evaluate all of the following:
(1) The appropriateness of the housing goals, objectives, and policies in contributing to the attainment of the state housing goal.
(2) The effectiveness of the housing element in attainment of the community’s housing goals and objectives.
(3) The progress of the city, county, or city and county in implementation of the housing element. (4) The effectiveness of the housing element goals, policies, and related actions to meet the community’s needs, pursuant to paragraph (7) of subdivision (a) of Section 65583.”

According to the California Department of Housing and Community Development (HCD), the three areas of requisite analysis are:
 Review the results of the previous housing element’s goals, objectives, and programs. The results should be quantified where possible but may be qualitative where necessary.  Compare what was projected or planned in the previous housing element to what was actually achieved. Determine where the previous housing element met, exceeded, or fell short of what was anticipated.
 Based on the above analysis, describe how the goals, objectives, policies, and programs in the updated housing element are being changed or adjusted to incorporate what has been learned from results of the previous housing element.

6.2 HOUSING PRODUCTION, REHABILITATION, AND CONSERVATION The Housing Element establishe d quantified objectives for new, rehabilitated, and preserved housing stock, as shown in Exhibit 1, Quantified Objectives of the 5 th Cycle Housing Element. Ultimately, the objective identified a total o f 2,880 new, rehabilitated, and conserved units over the 5 th Cycle (Housing Element, page 7-2), which is consistent with and exceeded the Regional Housing Needs Allocation (RHNA) goal of 2,429 units across all income levels.

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EXHIBIT 1: QUANTIFIED OBJECTIVES OF THE 5TH CYCLE HOUSING ELEMENT Source: Table 7.1-1: Quantified Objectives in 5th Cycle Housing Element .

6.3 HOUSING PRODUCTION: 2013-2019
The 2019 Housing Element Annual Progress Report (APR) demonstrates that the City has not met these quantified objectives. Table 6-1 demonstrates that the City has permitted a total of 469 units since 2013, including 1 unit of very low-income housing, 18 units of low-income housing, 4 units of moderate-income housing, and 446 units of above -moderate housing. There are 1,960 total remaining units in the RHNA.

The City has also approved many units that are still pending construction, including 80 deed -restricted units for lower-income veterans.

6.4 REHABILITATION
In 2016, the City of Redlands began to utilize the ‘City Works’ program to track records pertaining to home rehabilitation. Since 2016, 11 homes have been substantially rehabilitated, all of which were single-family dwellings. Of these, 5 were deemed to be unsafe structures. Of these 5 unsafe/uninhabitable structures, 3 were unsafe/inhabitable due to fire damage, and 2 became unsafe/uninhabitable structures after unpermitted work was performed to the structure. Additionally, the APRs from 2014 to 2019 indicate that no units were rehabilitated. This is short of the goal of 140 rehabilitated units.

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6.5 CONSERVATION/PRESERVATION
The APRs from 2014 to 2019 indicate that no units were conserved/preserved, short of the goal of 60 units.

6.6 EFFECTIVENESS AT ASSISTNG SPECIAL NEEDS POPULATIONS In the previous element, the City included many programs to address the needs of special needs populations, including the populations described below. The following describes the efforts of the City in meeting these special needs.

6.6.1 CBDG Funds
The City has utilized CDBG funds to make neighborhood improvements, including accessibility improvements. In the 2020 -2021 fiscal year, HUD allocated $427,405 in CDBG funds to the City of Redlands.

Funds used included the following neighborhood improvements:
• Alleyway Improvements Paving in CDBG Target Areas
• ADA improvements consisting of removal of architectural barriers at various public facilities • Sylvan Park restroom rehabilitation
Additionally, the City provides CDBG funding to the following service providers:
• Family Service Association of Redlands
• YMCA of the East Valley
• Inland Temporary Homes
• Boys and Girls Club
• San Bernardino Sexual Assault Services
• Steps 4 Life (rapid re-housing program)

6.6.2 Extremely Low Income Population
The City has maintained the Mobile Home Rent Control Ordinance, which limits rent increases to no more than the CPI index in each given year. This ordinance will continue into the next cycle. This ordinance supports the special needs of the population residing in Redlands’ seven mobile home parks.

The City allocates CDBG funds to Inland Temporary Homes . Inland Temporary Homes provides eviction prevention assistance due to COVID-19 related impacts for anyone with up to 80 percent AMI, which can prevent COVID-19 related displacement.

Redlands Family Service Association received CDBG grants from the City. Redlands Family Service provides rental assistance to qualifying families.

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6.6.3 Homeless
The City allocated CDBG funds to Inland Temporary Homes and the Family Service Association of Redlands.

Inland Temporary Homes used these funds to provide services such as housing navigation, security deposit, rental assistance, utility deposits, case management, mental health services, life s kills classes, and follow-up services with rapidly rehoused individuals. Redlands Family Service Association provides emergency rental assistance, food assistance, clothing, bus passes, gas cards, hygiene kits, classes, a computer lab, and employment referrals.

In 2018 the Redlands Police Department launched a Homeless Outreach Program that created the role of the Community Outreach Coordinator. The Community Outreach Coordinator partners with local service providers and faith-based organizations to provide resources to and seek positive long-term solutions for persons experiencing homelessness in Redlands.

6.6.4 Elderly
The City runs a Redlands Senior Citizen Hotline that support residents 55 years or older in crisis. The elderly may contact this line for support with meals, groceries, routine calls as part of the “Never Alone” project, and health and safety verification.

The City also runs a senior transportation program that provides discounted rides to elderly residents who are unable to provide their own transportation for necessary services.

The City allocates CDBG funds to Inland Temporary Homes, which provides eviction prevention assistance due to COVID-19 related impacts. This support assisted the elderly with finding solutions to maintain their homes while maintaining their health.

6.7 ADEQUATE SITES FOR 5TH CYCLE RHNA
For the 5th Cycle Housing Element, the City was allocated 2,429 housing units as its share of the regional housing need. Table 6-1, 5 th Cycle RHNA Allocation and Production by Income Category , shows the distribution of this regional share into four income categories.

TABLE 6-1: 5TH CYCLE RHNA ALLOCATION AND PRODUCTION BY INCOME CATEGORY Very Low Low Moderate
Above
Moderate Total
5th Cycle
Allocation
579 396 453 1,001 2,429
Units Permitted 1 18 4 446 469
Remaining
Allocation
578 378 449 555 1,960
The 5th Cycle provided capacity for 3,849 units (Table 4.1 -1 of the 5th Cycle Housing Element). At the beginning of the 5 th Cycle, the City amended the Downtown Specific Plan allow for high density multi -

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family housing by-right. These amendments significantly increased zoned capacity for all income levels in Redlands.

The City reviewed its previous RHNA sites, past approvals, and the zoning code and determined that it has maintained adequate sites to meet the RHNA for all income levels throughout the 5th Cycle.

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6.8 HOUSING ELEMENT PROGRAMS: ASSESSMENT OF ACCOMPLISHMENTS The 5th Cycle Housing Element contains 60 programs, many of which are simply routine services and staff functions that need not be identified as Housing Element programs. Many housing programs are repetitive and represent specific activities that can be grouped into on e program. For ease of annual reporting and tracking of measurable actions, the 6th Cycle Housing Element programs were modified as shown below.

Three criteria were considered when evaluating the performance of programs in the 5th Cycle:

1. The lack of timely implementation

2. Actions the City will take to better implement programs in the 6th Cycle

3. The effectiveness of programs
In 2012, the State abolished redevelopment in California. The City’s Redevelopment Agency, as was the case in most cities statewide, was most involved with housing and housing programs. The elimination of redevelopment removed the City’s only dedicated funding source for affordable housing. This affected not just programs but also staff for administering affordable housing activities, such as the variety of programs included in the 5th Cycle Housing Element. Going forward, for the 6 th Cycle, the City will be dedicating certain staff resources to affordable housing activities and will be able to implement the Housing Element more effectively.

This section evaluates the programs identified in the 5th Cycle Housing Element and evaluates the progress of the programs using the 2019 APR.

Evaluation notes and recommendations are in the accomplishments column.

TABLE 6-2: 5TH CYCLE PROGRAMS
Name of Program Objective
Time
Frame Status (2019 APR)
Accomplishments: Results and
Evaluation

7.1-1 Make Zoning
Ordinance Changes for
Group Homes,
Boardinghouses, and Single
Room Occupancy (SRO)
Units
Evaluate and modify the
zoning ordinance.
8/1/2014 Development Services
Department staff plans to
accomplish this task in 2020.

No accomplishments due to lack of
staffing resources.

Continued Appropriateness:

Retained and modified. See
Programs 1.2-4 and 1.2-5.

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7.1-2 Implement Zoning
Ordinance to Include
Standards for Single Room
Occupancy (SRO) Housing
within the Downtown
Specific Plan Area
Provide a valuable source of
affordable, low-cost
housing.
10/1/2020 The City is working on
adopting a Transit Villages
Specific Plan for land areas
close to the City's three rail
stations. Once adopted, the
Transit Villages Specific Plan
will replace the Downtown
Specific Plan. Standards for
SRO are expected to be
addressed in the Transit
Villages Specific Plan.

Staff is currently developing the
Transit Villages Specific Plan, which
will revise SRO standards within in
the current Downtown Specific Plan
area.

Continued Appropriateness:

Revised. See Program 1.1-3.

7.1-3 Treat Transitional
Housing the Same as Other
Residential Uses in the
Same Zone
Continue current practice to
treat transitional and
supportive housing the
same as any other
residential use in the same
zone.
10/1/2021 Development Services
Department is initiating an
effort to amend the zoning
code to address transitional
and supportive housing so
that they are treated the
same as other residential
uses in the same zone.

Continued Appropriateness: Modify.

See Programs 1.2-3 and 1.2-5.

7.1-4 Encourage Limited
Equity Cooperatives. Retain
Existing Policy of
Encouraging Formation of
Limited Equity Stock
Cooperatives
Encourage and support
cooperatives in Redlands.
10/1/2021 Ongoing. The City has not
received any applications for
a Limited Equity Cooperative.

If the City receives an
application, it will work with
the applicant to facilitate
creation of a cooperative.

No accomplishments. There are
existing cooperatives in the City;
however, there were no new
applications for housing
cooperatives during the 5th Cycle.

Continued Appropriateness:

Remove.

7.1-5 Maintain Second Unit
Dwelling Unit Ordinance
Maintain the existing
ordinance and keep track of
second units being
developed under the
ordinance.
10/1/2021 The City is enforcing the
state's Accessory Dwelling
Unit ordinance while initiating
a zoning code amendment to
adopt the City's own
Accessory Dwelling Unit
ordinance.

The City has not adopted revisions
to the Second Dwelling Unit
ordinance (RMC 18.156.440). The
ordinance has been drafted and
reworked by Development Services
staff and sent to the City Attorney
for review. This review is pending.

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In the interim, the City is
implementing State law.

Continued Appropriateness: Modify
The City is including Program 1.6
to update the ADU ordinance to
meet state requirements, track
ADUs, and facilitate ADU production
for lower-income households.

7.1-6 Launch Second
Dwelling Unit Public
Awareness Campaign
Inform the public about the
opportunity to build second
units in any residential zone
on a parcel with an existing
single-family unit.
10/1/2021 The City is enforcing the
state's Accessory Dwelling
Unit ordinance while initiating
a zoning code amendment to
adopt the City's own
Accessory Dwelling Unit
ordinance. The public
awareness campaign will be
included in the public
comment/review process of
ordinance adoption.

The City has updated its website to
provide clear, accessible, and
relevant information regarding the
ability to build ADUs.

The City has not adopted revisions
to the Second Dwelling Unit
ordinance (RMC 18.156.440).

Continued Appropriateness: Modify.

See Program 1.6-1.

7.1-7 75/25 Ratio Maintain as a long-term
planning goal, in
accordance with Measure U,
75% single-family units to
25% multifamily units at
General Plan buildout.
10/1/2021 Ongoing. Continued Appropriateness:

Remove
This program does not further
housing access in the City, and is a
requirement based on the Measure
U referendum. The program is
superseded by Housing Element
law.

7.2-1 Support Housing
Providers
Support efforts of for-profit
and nonprofit housing
sponsors in constructing,
acquiring, and improving
10/15/2021 Ongoing. No accomplishments.

There are no verifiable City-initiated
efforts to create a partnership or
support housing developers in
Redlands. The City did approve an

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low- and moderate-income
housing.
80-unit affordable housing project
(deed restricted). City staff assisted
the developer through the
application process and
recommended approval, though no
partnership was established.

Continued Appropriateness:

Remove.

The City is including many
programs specifically designed to
facilitate low and moderate-income
housing production through
Programs 1.1-, 1.3-, and 1.4-.

7.2-2 Continue Use of
Mortgage Revenue Bonds
Participate in mortgage-
revenue bond programs
undertaken by the County
of San Bernardino.
8/1/2014 The County of San
Bernardino is currently not
pursuing use of mortgage
revenue bonds at this time.

Due to historically low
interest rates on the open
market the program is not
competitive.

No accomplishments. This program
proved to not be viable in current
market conditions.

Continued Appropriateness:

Remove.

7.2-3 Determine the
Feasibility of Using
Mortgage Credit Certificates
Determine the feasibility for
a program in Redlands.
8/1/2014 Ongoing. No accomplishments. It is unknown
if staff contacted agencies within six
months of adoption of the 5th Cycle
Housing Element. Due to staff
turnover, this information is not
available.

Continued Appropriateness:

Remove.

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7.2-4 Participate in the
(HUD) HOME Investment
Partnership Program for
Multi-Family Housing
Provide funds for new
construction, acquisition or
rehabilitation of multifamily
housing.
10/1/2021 The City continues to explore
all available resources and
partnership opportunities.

No accomplishments.

Continued Appropriateness:

Remove
The City does not administer or
facilitate acquisition of HOME or
CDBG funding.

7.2-5 Promote the Use of
Low-Income Housing Tax
Credits
Provide assistance in
accessing low-income
housing tax credits and a
means of financing low-
income housing
development.
10/1/2021 Ongoing. The City assists
developers in applying for
low-income housing tax
credits when there is an
opportunity.

No accomplishments.

Continued Appropriateness:

Remove.

This program is a standard city
process. The City will continue to
assist developers in applying for
low-income tax credits as
opportunities arise.

7.2-6 Continue Public
Housing and Section 8
Programs
Develop, maintain, and
improve extremely low-,
very low-, and low-income
housing.
10/1/2021 The City cooperates with the
Housing Authority of San
Bernardino County (HASBC)
in locating suitable sites or
existing properties that can
be rehabilitated, and in
obtaining funding to create
public housing or Authority-
owned Section 8 units.

No accomplishments. The APRs
indicate that there have been no
units of housing that have been
rehabilitated/improved. It is not
clear that the City has directly
facilitated acceptance or
construction of units that allow
Section 8 funding. With the
cessation of redevelopment
agencies, the City transferred many
of its housing duties to the Housing
Authority of the County of San
Bernardino.

Continued Appropriateness: Modify
The City has modified this program
through programs 1.4-, which will

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incentivize and preserve at-risk
housing.

7.2-7 Continue Mobile
Home Rent Control
Limit rent increase in
existing parks to no more
than the CPI index for that
year.
10/1/2021 Ongoing. The City continues implementation
of rent control ordinance.

Continued Appropriateness: Retain
Program 1.5-9.

7.2-8 Implement Housing
Referral and Placement
Program
Link those needing housing
with those wanting to share
their homes or take
advantage of the City's
Second Dwelling Unit
ordinance.
2/1/2016 Delayed due to a lack of staff
resources. However, the City
is enforcing the state's ADU
ordinance and has been
approving ADUs subject to
development standards set
forth by the state.

No accomplishments.

Continued Appropriateness:

Remove.

The City is continuing to facilitate
lower-income ADU occupancy
through Program 1.6.

7.2-9 Remove Constraints
to Affordable Housing
Development in Downtown
No longer require a CUP for
housing development in
Zones C-3 and C-4 in
Downtown.
12/1/2014 The City was awarded a
Caltrans grant to work on the
Transit Villages Specific Plan
in anticipation of the
Metrolink/ Arrow light rail
trains coming to three new
train stations in the City,
including a new station at
downtown Redlands. Once
the plan is adopted, it will
replace the Downtown
Specific Plan. Removal of
constraints to affordable
housing development in
downtown will be analyzed
and incorporated into the
Specific Plan.

Staff is currently developing the
Transit Villages Specific Plan, which
will replace the Downtown Specific
Plan.

Continued Appropriateness:

Combine
Combine all programs involving the
Transit Villages/downtown area into
a single program (Program 1.1-3).

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7.2-10 Transit Oriented
Development (TOD)
Promote TOD in Redlands
by providing a 25% housing
density/FAR bonus to
projects located within a
half-mile of the proposed
transit station.
12/1/2015 Ongoing. City offers density
bonus consistent with the
state law. The City is
currently developing a Transit
Villages Specific Plan to
replace the Downtown
Specific Plan.

No accomplishments. This program
was originally intended for a
comprehensive update of the
current Downtown Specific Plan.

This has been replaced with the
new Transit Villages Specific Plan,
currently undergoing environmental
review.

Continued Appropriateness:

Combine
Combine all programs involving the
Transit Villages/downtown area into
a single program. See Program 1.1-

3. 7.2-11 Assist with
Foreclosure Prevention
Help Redlands homeowners
avoid foreclosure by
promoting available
assistance programs.
10/1/2021 Ongoing. City includes and
provides information about
foreclosure assistance
programs at the counter and
City website.

Implemented. A record was not
kept of updates to the foreclosure
prevention resources.

Continued Appropriateness: Modify.

See Program 1.3-6.

The City will change its practices to
review the website annually. This
information will continue to be
provided at the counter. The City’s
6th Cycle Housing Element proposed
several cross-coordinated programs
to better provide information and
materials to residents by way of
website updates, hard copy
materials at the Planning counter,
and outreach events.

Redlands Regular Meeting of 02-01-22

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