Cities Index.
Exhibit F - 6th Cycle Housing Element

Rialto City Council
February 24, 2026

Document
Exhibit F - 6th Cycle Housing Element
Meeting
February 24, 2026
Body
Rialto City Council
Pages
13
Original file
60.2 MB
Text extracted from the city's file for reading and search. Open the original on legistar.granicus.com. That file is the official record.

Plan to House Our Rialto:
2021-2029 Housing Element Update
Phase 2: Online Community Survey
On June 14th, 2021, the City released a community survey online to solicit feedback and input on potential locations for housing and on possible housing policies. A total of 119 survey responses were gathered through August 5th, 2021; they are summarized below.

1. What type(s) of housing would you like to see added in Rialto? (Please select all that apply)

2. Would you like to see more housing units for rent or for sale?

11.9%

60.2%

24.6%

27.1%

37.3%

44.9%

27.1%

32.2%

60.2%

21.2%

12.7%
0% 10% 20% 30% 40% 50% 60% 70%
Accessory Dwelling Units
Affordable Housing
Apartments/Condos for Rent
Apartments/Condos for Sale
Housing for Persons with Disabilities
Mixed-Income Housing
Multi-Generation Housing
Senior Housing
Single-Family Housing
Supportive or Transitional Housing
Other

11.0%

45.0%

44.0%
Rental Housing
For-Sale Housing
Both

Page 2 ends

Plan to House Our Rialto:
2021-2029 Housing Element Update

3. What locations are best suited for adding new housing? (Please select all that apply)

4. To accommodate housing for all incomes, the City of Rialto will need to plan for multi-family developments that may exceed 3 stories. What locations are suitable for residential buildings more than 3 stories high?
21%
15%
20%
14%
11%
19%
0% 5% 10% 15% 20% 25%
Near Regional Shopping Center
In and around Downtown
In major Corridors (such as Bloomington Ave, Foothill Blvd, Riverside Ave, or Baseline Ave)
Near Public Facilities
In existing Neighborhoods (more ADUs, duplexes, triplexes, and similar type of dwellings)
Near Public Transportation
23%
16%
17%
12%
15%
17%
0% 5% 10% 15% 20% 25%
Near Regional Shopping Center
In and around Downtown
In major Corridors (such as Bloomington Ave, Foothill Blvd, Riverside Ave, or Baseline Ave)
Near Public Facilities
In existing Neighborhoods (more ADUs, duplexes, triplexes, and similar type of dwellings)
Near Public Transportation

Page 3 ends

Plan to House Our Rialto:
2021-2029 Housing Element Update

5. To respond to a variety of lifestyle needs and choices, the City of Rialto may plan for mixeduse housing. Mixed-use housing refers to developments that include residential units along with retail, neighborhood services, public facilities, entertainment, offices, or other uses.

What locations are suitable for mixed-use housing?

6. Do you have any recommendations on areas where housing could be added? Recommendations on Where Housing Could be Added
Near old Rialto airport.

Rancho Verde Golf Course, across from Ayala Park, Riverside Ave. & Sierra Avenue, single family homes in the empty lots near Carter H.S.

North Rialto El Rancho country club
Rialto, has so many areas that are not used, lots, old buildings...all those places should be used Rialto, Near the new Shopping Center
The empty fields near baseline and fitzgerald.

Apartments townhouse and condos near renaissance
Definitely no additional section -8 needed. Rialto crime rate needs to decrease not increase Along 210 fwy
By the original Walmart
22%
19%
17%
12%
10%
20%
0% 5% 10% 15% 20% 25%
Near Regional Shopping Center
In and around Downtown
In major Corridors (such as Bloomington Ave, Foothill Blvd, Riverside Ave, or Baseline Ave)
Near Public Facilities
In existing Neighborhoods (more ADUs, duplexes,
triplexes, and similar type of dwellings)
Near Public Transportation

Page 4 ends

Plan to House Our Rialto:
2021-2029 Housing Element Update
Recommendations on Where Housing Could be Added
Rialto, Colton, Ontario, rancho Cucamonga, North riverside Ave, etc.

Downtown Rialto, Airport area
Duncan canyon rd.

The wash off of Riverside Avenue
there are areas throughout the City that can be rehabilitated into new housing. or the pockets of vacant land that can help beautify the city with new housing.

I think Baseline and Foothill Blvd's but also Northern Rialto for larger home developments Near the riverbed on foothill
Areas around Renaissance Marketplace, Land that is north of Baseline Ave (North Rialto).

En los lotes vacantes de la ciudad.

MIXED USE ALONG MAJOR CORRIDORS AND NEAR SHOPPING CENTERS WITH INFILL SFR THROUGHOUT THE CITY. Near schools and public transportation.

Housing through the city, no pockets of poverty that include mixed income housing integration.

By Renaissance and Downtown.

Cedar above Baseline near the Renaissance Market Place.

South end of Rialto to generate economic strength, while updating the city's visual appearance.

Mixed use along major corridors and near shopping centers with infill SFR throughout the city.

Baseline by current homes
Housing through the city, no pockets of poverty that include mixed income housing integration.

Updating electric/lower water. Add more parks.

Riverside Ave and San Bernardino Ave
No mas (casas) viviendas hay demasiadas.

Near schools
On Riverside below Walnut
More around empty locations
Up Riverside Avenue close to 15 fwy & downtown area
On empty lots of land near Ayala & Renaissance -On plots of land near parks all vacant lots

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Plan to House Our Rialto:
2021-2029 Housing Element Update
Recommendations on Where Housing Could be Added
En el norte de Rialto, donde hay mas espacios disponibles.

Near the Renaissance Marketplace
Near the Renaissance Shopping area (Rialto Renaissance Marketplace) and the old golf course Closer to San Bernardino on Foothill Blvd.

The area north by the TaD office
North end of the 210
more housing can be added to areas where there is less traffic for the safety of kids

7. Do you have any recommendations on areas where housing should NOT be added? Recommendations on Where Housing Should NOT be Added
flood-prone areas
definitely not near companies that service trucking or waste processing, trains, and concrete/dirt plants.

Not near freeways because people later complain about sound and limits expansion in the future.

No transitional housing in current single-family neighborhoods. Those should be built near public transportationand public facilities.

Riverside avenue or baseline
Yes, not in back yards, that will create slums
In or near upper income, existing neighborhoods.

No more low-income housing. Bring back a clean, respectable, attractive city.

Downtown area. The block of Riverside-foothill and Eucalyptus-Merrill Any area that would actually do more harm than good for the families and individuals already living in that area.

San Bernardino ca
NOT in major corridors. It will make traffic so much worse.

Near parks and current neighborhoods
Riverside dr. To busy already
Downtown. It needs to stay with the older historical housing that speaks to our history and the businesses downtown.

Downtown Historic Area

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Plan to House Our Rialto:
2021-2029 Housing Element Update
Recommendations on Where Housing Should NOT be Added
I’m already build neighborhood
Suburban neighborhood
South Rialto. This area is NOT suitable for new housing until the area has been improved. Spend money improving streets, downtown area, and transportation. South rialto is run down and undesirable.

En la section sur del la ciudad donde estan todas las fabricas.

Away from warehouses and major truck routes to keep community safe.

The southern part of Rialto no affordable housing or housing in general should go where there are warehouses. We need to have other community development plan and projects surveyed by the community.

Riverside Avenue is already too busy.

Downtown
Near warehouses!
In the north end.

The southern part of Rialto no affordable housing or housing in general should go where there are warehouses. We need to have other community development plan and projects surveyed by the community.

The southern part of Rialto no affordable housing or housing in general should go where there are warehouses. We need to have other community development plan and projects surveyed by the community.t
NOT near schools
By warehouses, freeways, train tracks!
Downtown
Downtown Rialto -Near poverty stricken/bum infested areas baseline/Jackson street -Near railroad tracks
Lots of vacant lots
En el centro, ya esta muy saturado.

Cercca de bodegas
South of Foothill
Already crowded residential areas
All the open space, our neighborhoods have turned into highways high traffic and places where there are too many people

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Plan to House Our Rialto:
2021-2029 Housing Element Update

8. Community Assistance Policies and Programs - Please rate the following based on importance to the community. (1 being the least important and 5 being the most important) Homebuyers assistance (Identify funding assistance and
resources for first time home buyers)
Housing rental assistance (Identify funding assistance for renters)
Property maintenance (Programs to provide funding for
home maintenance rehabilitation and upkeep)
Housing information (Information on affordable housing
opportunities and funding available to the public)

9. Fair Housing Policies and Programs- Please rate the following based on importance to the community. (1 being the least important and 5 being the most important) Promote fair housing (Provide programs and policies to
address fair housing issues)
Senior Housing Programs (Encourage the development of
senior supportive housing)
Persons with disabilities (Encourage the development of housing accessible to persons with disabilities)
Supportive Housing Programs (Provide for emergency, short and long-term housing needs)

Page 8 ends

Plan to House Our Rialto:
2021-2029 Housing Element Update

10. Please describe your vision of housing in Rialto.

Vision of Housing in Rialto
Senior and new ownership program
diverse mix of home types available which provide more affordable options for the community It would involve priority being Transitional housing as well as housing for seniors and the disabled.

Homeowners not renters, homeownerstake care of their investment.

A mixture of single-family residents and affordable townhomes. Each new community would include lots of plants and nature possibly walking trails and parks. I see a senior community of affordable single-storyhomes on the Rancho Verde Golf Course land with a fountain, walking trails, and community center. I see multi-generational homes finally being apart of the existing Rialto communities and apart of new communities for younger families. I see transitional housing being a part of the mixed-use community to give them access to public services and public transportation.

Low income housing for families
Possible HOA within the housing since code enforcement is worthless in Rialto, they do a horrible job holding homeowners accountable to upkeep their properties/yards More Affordable single-family homes and multifamily homes Available assistance for home buyers
I want to see housing for families like mine. Parents (husband deceased) who has two disabled adult children who require 24/7 care from me and my eldest son. Not only do we need housing (for purchase) to fit our family, but we need it with access for the disabled and affordable down payment.

I can afford the payments, just getting the down payment is difficult.

Upkeep the houses in the downtown area and make better homes near Las Colinas.

Yes Rialto needs housing. Yet there are problems that needs to be address before building more homes. Homes affordable to match residence to income. Jobs and not just warehouse. Access to quality grocery stores, transportation. Parking, need tow away abandon vehicles make Rialto a more desirable place to live then build from there.

I would love to see some of the vacant land be use for affordable housing and not so many manufacturing buildings.

I would love to see Rialto become a more upscale community with a reputation for having safe, clean neighborhoods, California Distinguished Schools for children of residents and shopping centers and grocery stores that are nicely maintained and conveniently located near housing.

Fair and affordable housing for ALL COMMUNITY MEMBERS focusing MORE on those with credit challenges and/or evictions.
a mixture of single-family homes with larger yards, in some areas and multi-use in areas like Downtown to revitalize that area.

Mixed use downtown; new buildings, mixed use near renaissance. Single family in the north, some townhomes in the Lytle Creek specific plan
Clean, attractive, safe community that does NOT support homelessness or irresponsible residents who chose to live off government aid indefinitely.

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Plan to House Our Rialto:
2021-2029 Housing Element Update
Vision of Housing in Rialto
Rialto would ideally keep its downtown and surrounding blocks original while adding more usable modern updating. (Think Fullerton’s downtown). The rest of Rialto would likely want to keep their houses original and kept up to maintain the city’s clean appearance.

Long term Rialto residents would get assistance in purchasing homes whether it be affordable townhomes or single-family housing
A rialto where families and individuals who have grown up here won’t be displaced is an ideal vision for the future. Affordable housing for marginalized groups would surely be beneficial for rialto as a whole.

My vision is Second chance tenants, applicants, for affordable housing, low income. No wait list, have great security, decent credit accepted. No Fee to apply. But deposit required if accepted Building more homes in the neighborhood area.

I pray we Don return to the mistakes made in the 70 and 80 with low income housing.

I feel the failure in housing has come with not enforcement of the code enforcement laws.

Property owners should be responsible whither they live in Rialto or somewhere else. If it's yours, you own it. Take care of it. It's called a "Good Neighbor " Would prefer NO low-income housing. Senior housing is preferred Naturally people take better care of homes they own vs rentals. More home buying opportunities a must or help with renovation loans to help improve the current/outdated homes.

A tighter community. People taking care of each other. Also making sure each property is well taken care and the city needs to enforce a clean a property/lot/tract.

We need multi-generational housing. More families are taking care of elderly relatives or having young adult relatives live with them. I believe we have a lot of senior housing and I understand the ongoing need. But we need working families living and shopping in Our City. This helps with our growth.

Affordable, good quality and not on top of each other. Decent size lots.

Single story homes
I would like to see programs and funding for our older downtown and historic area renovation of homes. I see this as being one of our main priorities for improving our city. Next, I see new multiuse and condo/apartment housing on our main Blvd's like Foothill and Baseline. I would also like to see new larger homes developed in the norther part of Rialto and the linking of the new housing areas with the historic downtown area of our city.

The more population the more trouble. Let’s keep Rialto safe and clean. Rialto is good with building a bright future for our children and let’s keep it like that A city where everyone could have a roof over their head and a safe place to call home regardless of income.

Middle - high housing, update/ improve downtown, improve school system performance/ rating.

Regular single-familyhomes not bird cages
Multifamily and diversity in needs

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Plan to House Our Rialto:
2021-2029 Housing Element Update
Vision of Housing in Rialto
We need at least one homeless shelter we currently have none in rialto.

Single family housing with a yard. MILLENIALS DO WANT HOMES. I hear this all the time that we do not want home, we want to rent. This is a HUGE misconception and incorrect. We want homes with yards however with rising prices of homes and the cost of living and stagnant cost wages, this is just not feasible. Condos and apartments are desirable for this reason but please add patios and outdoor spaces. Many younger generation adults have pets and want to accommodate for such.

Housing should be built near beautiful new shopping areas and accessible to public transportation.

I would like to see Rialto continue improvement and development of the city. Rialto could be a place where low income earners could potentially move up the social ladder and potentially stay in Rialto as they do so.

Mi vision es una cuidad que incorpore nuevas viviendas con assistencia para rehabilitar las areas de nuestra ciudad historicas.

Housing priced so the people of Rialto's housing costs are less than 30% of the wages paid to people who work in Rialto.

My vision for Rialto is for the city to be more responsible when it comes to residential and agricultural zoning. Rezoning from residential/agricultural to industrial to allow warehouses to come in must stop.

We want to see permanent affordable housing not just renting but have programs in place where families can buy their forever home. Assistance to our houseless population that provides shelter first and services they need to help reincorporate to society. Programs for single parents to afford housing for their families.

More modern housing availability, like mixed use housing/zoning and incorporation and preservation downtown Rialto. For the city to play a role of creating programs for helping its residents build community wealth through homeownership (co-ops, condos, community land trust) Follow up on their mobile homes purchasing program.

Housing Element Policy recommendations
Have housing throughout the city. Area medium income: Very Low Income, Low Income and Moderate-Income communities to be planned and zoned in a mixed income/integrated community.

The city should see itself as an entity that helps build community wealth for permanent affordability housing.

For the city to be a resource for providing information and funding assistance for homeownership like mobile home program/manufacturing housing programs that came from the 5th cycle housing element.

Mixed use housing in downtown to revitalize downtown Rialto and major corridors.

Land inventory: build community wealthand permanent affordability housing/homeownership Also to have strong fair housing policies. Fair Housing recommendation would be for Code Enforcement to be held more accountable to addressing tenant issues with repairs and going after negligent landlords - imposing fees, aggressively pursuing the same way they do code violations committed by underserved communities.

Additional Questions:

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Plan to House Our Rialto:
2021-2029 Housing Element Update
Vision of Housing in Rialto
When will the city amend their zoning code to include state requirements for manufacturing housing based on their programs from the 5th cycle? Any updates of programs or policies related to what needed to get done on the 5th cycle?
Affordable for all incomes
Por favor describe el tipo de viviendas que le gustaria ver en Rialto. --> Please describe the type of housing you would like to see in Rialto.

I would like to see redevelopment in downtown. I used to live in Covina and their downtown area is nice, safe and has plenty to do. A nice downtown can be a great source of tax revenue and give people pride in their city. Downtown Rialto is run down and doesn't seem safe. More mixed-use housing should be built, and two and three story (or more) housing units should build for sale. On a side note I would like to see the schools in Rialto improved too.

Providing sufficient parking for residents. For example, if building a 5-bedroom home, provide parking for 5 or more vehicles. Many new neighborhoods lack sufficient parking.

My vision of housing in Rialto I find it nice.

Rialto seems to be on the rise. So any improvement in housing would be awesome! I like "old" feel of downtown area so don't change that please.

More close theaters. More parks. Entertainment safe placesfor teens to hangout. Skate parks. More pools for the public.

Smaller homes than a single family can afford.

A strong economic community for all parts of the city that attracts big business brands into our community. Also, a cleaned-up city (South end) in the downtown/Foothill region.

More modern housing availability, like mixed use housing/zoning and incorporation of revitalization and preservation downtown Rialto homes.

More modern housing availability, like mixed use housing/zoning and incorporation and preservation downtown Rialto. For the city to play a role of creating programs for helping its residents build community wealth through homeownership (co-ops, condos, community land trust) Follow up on their mobile homes purchasing program.

Housing Element Policy recommendations:

Have housing throughout the city. Area medium income: Very Low Income, Low Income and Moderate-Income communities to be planned and zoned in a mixed income/integrated communities. The city should see itself as an entity that helps build community wealth for permanent affordability housing.

For the city to be a resource for providing information and funding assistance for homeownership like mobile home program/manufacturing housing programs that came from the 5th cycle housing element.

Mixed use housing in downtown to revitalize downtown Rialto and major corridors.

Land inventory: build community wealth and permanent affordability housing/homeownership.

Also to have strong fair housing policies. Fair Housing recommendation would be for Code Enforcement to be held more accountable to addressing tenant issues with repairs and going after negligent landlords - imposing fees, aggressively pursuing the same way they do code violations committed by underserved communities.

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Plan to House Our Rialto:
2021-2029 Housing Element Update
Vision of Housing in Rialto
Additional Questions:

When will the city amend their zoning code to include state requirements for manufacturing housing based on their programs from the 5th cycle? Any updates of programs or policies related to what needed to get done on the 5th cycle?
Affordable home well maintained homes more school update schools. parks trees sidewalk fixed.

Update electricity power.

There would-be single-family dwellings with big yards and parking on the property, not on the street.

Less apartments and multifamily dwellings.

More single-family homes with larger backyards for children to play and pets.

Less homeless encampments
Accessible housing with transportation and sidewalks throughout the entire city. I imagine a hiking trail/running trail in Rialto as well!
Nice welcoming neighborhoods.

More development in the north sectors.

Safe and inclusive
New housing available to responsible individuals, home ownership instead of landlords renting out Rialto properties. Caring for new homes & communities, community enforcing laws to keep communities safe & looking well, less graffiti, abandoned vehicles & pet overpopulation at houses/homes in Rialto.

People can afford their housing and be comfortable and at peace in their home.

Single family neighborhoods
Larger complex on main corridors
Me gusteria que personas que actualmente residen en Rialto tengan la oportunidad de comprar propiedades en esta ciudad. Hacer que las propiedades sean mas accesibles para nuestros residentes.

My vision for Rialto is mixed housing throughout the entire city.

Para personas con descapasidades. Para personas mayores. Para primer compradores.

Similar to Fontana, Victoria Gardens
variety of places. CD for all
Double Stories House
Leave it alone - too much eating up the open space that drew us to rialto My vision for housing is to stop seeing, meeting ex-foster youth out here in the streets maybe not all but the ones who need it
Country Style, Farm, Ranch

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Plan to House Our Rialto:
2021-2029 Housing Element Update

11. Do you live in Rialto? 12. Do you work in Rialto?

13. Are you a renter or homeowner?

14. What is your age range?

30.8%

62.6%

2.8% 1.9% 1.9%
Renter
Homeowner
I own property that I rent to
others
I am currently unhoused
Other
3%
25%
41%
22%
10%
Less than 18
18-34
35-49
50-64
65 or older

83.5%

16.5% Live in Rialto
Do not live in
Rialto

39.4%

59.6%
Work in
Rialto
Do not work
in Rialto

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Plan to House Our Rialto:
2021-2029 Housing Element Update
Phase 2 Community Survey

1. Name: ____________________________________________

2. Email: ____________________________________________

3. What types of housing would you like to see added in Rialto? (Please select all that apply)
Accessory Dwelling Units (ADUs)
Affordable Housing
Apartments/Condos for Rent
Apartments/Condos for Sale
Housing for Persons with Disabilities
Mixed-Income Housing
Multi-Generational
Senior Housing
Single-Family Housing
Supportive or Transitional housing
Other: ____________________________________________________ ____________________________________________________________

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Plan to House Our Rialto:
2021-2029 Housing Element Update

4. Would you like to see more housing units for rent or for sale? Rent
Sale
Both

5. What locations are best suited for adding new housing? (Please select all that apply)
Near regional shopping centers
In and around downtown
In major corridors (such as Bloomington Avenue, Foothill Boulevard, Riverside Avenue, or Baseline Avenue)
Near public facilities
In existing neighborhoods (more Accessory Dwelling Units, duplexes, triplexes, and similar types of dwellings)
Near public transportation

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Plan to House Our Rialto:
2021-2029 Housing Element Update

6. To accommodate housing for all incomes, the City of Rialto will need to plan for multi-family developments that may exceed 3 stories. What locations are suitable for residential buildings more than 3 stories high? Near regional shopping centers
In and around downtown
In major corridors (such as Bloomington Avenue, Foothill Boulevard, Riverside Avenue, or Baseline Avenue)
Near public facilities
In existing neighborhoods (more Accessory Dwelling Units, duplexes, triplexes, and similar types of dwellings)
Near public transportation

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Plan to House Our Rialto:
2021-2029 Housing Element Update

7. To respond to a variety of lifestyle needs and choices, the City of Rialto may plan for mixed-use housing. Mixed-use housing refers to developments that include residential units along with retail, neighborhood services, public facilities, entertainment, offices, or other uses. What locations are suitable for mixed-use housing?
Near regional shopping centers
In and around downtown
In major corridors (such as Bloomington Avenue, Foothill Boulevard, Riverside Avenue, or Baseline Avenue)
Near public facilities
In existing neighborhoods (more Accessory Dwelling Units, duplexes, triplexes, and similar types of dwellings)
Near public transportation

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Plan to House Our Rialto:
2021-2029 Housing Element Update

8. Do you have any recommendations on areas where housing could be added?
____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________

9. Do you have any recommendations on areas where housing should NOT be added?
____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________

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Plan to House Our Rialto:
2021-2029 Housing Element Update
Community Assistance Policies and Programs - Please rate the following based on importance to the community.
(1 being the least important and 5 being the most important)

10. Homebuyers assistance (Identify funding assistance and resources for first time home buyers)
1 2 3 4 5

11. Housing rental assistance (Identify funding assistance for renters) 1 2 3 4 5

12. Property maintenance (Programs to provide funding for home maintenance rehabilitation and upkeep)
1 2 3 4 5

13. Housing information (Information on affordable housing opportunities and funding available to the public)
1 2 3 4 5

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Plan to House Our Rialto:
2021-2029 Housing Element Update
Fair Housing Policies and Programs - Please rate the following based on importance to the community.
(1 being the least important and 5 being the most important)

14. Promote fair housing (Provide programs and policies to address fair housing issues)
1 2 3 4 5

15. Senior Housing Programs (Encourage the development of senior supportive housing)
1 2 3 4 5

16. Persons with disabilities (Encourage the development of housing accessible to persons with disabilities)
1 2 3 4 5

17. Supportive Housing Programs (Provide for emergency, short and longterm housing needs) 1 2 3 4 5

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Plan to House Our Rialto:
2021-2029 Housing Element Update
Vision for the Future

18. Please describe your vision of housing in Rialto.
____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________

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Plan to House Our Rialto:
2021-2029 Housing Element Update
Thank You!
Thank you for taking the time to provide input on this important update. The following questions will allow us to learn about who is responding to the survey. Your private information will be kept private.

For more information, please check the Plan to House Our Rialto webpage:
www.yourrialto.com/HouseOurRialto. If you have any questions about the survey or the Plan to House Our Rialto, please contact Siri Champion by email at [email protected] or by phone at 909-421-8072.

19. Do you live in Rialto?
Yes
No

20. Do you work in Rialto?
Yes
No

21. Are you a renter or homeowner?
Renter
Homeowner
I own property in Rialto that I rent to others
I am currently unhoused
Other: ____________________________________________________

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Plan to House Our Rialto:
2021-2029 Housing Element Update

22. What is your age range?
Less than 18 years old
18-34 years
35-49 years
50-64 years
65 years or older
Thank you for taking our survey, please return this to staff to record your responses. Stay tuned for more information about the Plan to House our Rialto and visit www.yourrialto.com/HouseOurRialto!

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Plan de Viviendas en Nuestro Rialto:

Actualización del Elemento de Vivienda 2021-2029
Fase 2 Encuesta Comunitaria

1. Nombre: ____________________________________________

2. Email: ____________________________________________

3. ¿Qué tipo(s) de vivienda le gustaría que se añadieran en Rialto? (Por favor elija todas las respuestas que apliquen)
Unidades de Viviendas Accesorias (ADUs)
Viviendas Asequibles
Apartamentos/Condominios para Renta
Apartamentos/Condominios para Venta
Viviendas para Personas con Discapacidades
Viviendas para Ingresos Mixtos
Multigeneracionales
Viviendas para Personas Mayores
Unifamiliares
Viviendas de Apoyo o Transitorias
Otras: ____________________________________________________ ____________________________________________________________

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Plan de Viviendas en Nuestro Rialto:

Actualización del Elemento de Vivienda 2021-2029

4. ¿Ler gustaría ver más unidades de vivienda para renta o para venta? Renta
Venta
Ambas

5. ¿Cuáles son los sitios más adecuados para añadir nuevas viviendas? (Por favor seleccione todas las respuestas que apliquen) Cerca de centros comerciales regionales
Dentro y alrededor del centro
En pasillos principales (tales como Bloomington, el Bulevar Foothill, la Avenida Riverside, o la Avenida Baseline)
Cerca de instalaciones públicas
En vecindarios existentes (Más Unidades de Viviendas Accesorias, duplexes, triplexes, y tipos de viviendas similares)
Cerca del transporte público

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Plan de Viviendas en Nuestro Rialto:

Actualización del Elemento de Vivienda 2021-2029

6. Para acomodar viviendas para todos los ingresos, la ciudad de Rialto deberá planificar desarrollos multifamiliares que superen los 3 pisos. ¿Qué ubicaciones son adecuadas para edificios residenciales de más de 3 pisos de altura?
Cerca de centros comerciales regionales
Dentro y alrededor del centro
En pasillos principales (tales como Bloomington, el Bulevar Foothill, la Avenida Riverside, o la Avenida Baseline)
Cerca de instalaciones públicas
En vecindarios existentes (Más Unidades de Viviendas Accesorias, duplexes, triplexes, y tipos de viviendas similares)
Cerca del transporte público

Page 4 of 10 ends

Plan de Viviendas en Nuestro Rialto:

Actualización del Elemento de Vivienda 2021-2029

7. Para responder a una variedad de necesidades y opciones de estilo de vida, la ciudad de Rialto puede planificar viviendas de uso mixto. La vivienda de uso mixto se refiere a desarrollos que incluyen unidades residenciales junto con tiendas minoristas, servicios para el vecindario, instalaciones públicas, entretenimiento, oficinas u otros usos.
¿Qué ubicaciones son adecuadas para viviendas de uso mixto? Cerca de centros comerciales regionales
Dentro y alrededor del centro
En pasillos principales (tales como Bloomington, el Bulevar Foothill, la Avenida Riverside, o la Avenida Baseline)
Cerca de instalaciones públicas
En vecindarios existentes (Más Unidades de Viviendas Accesorias, duplexes, triplexes, y tipos de viviendas similares)
Cerca del transporte público

Page 5 of 10 ends

Plan de Viviendas en Nuestro Rialto:

Actualización del Elemento de Vivienda 2021-2029

8. ¿Tiene alguna recomendación de áreas en dónde puedan añadirse más viviendas?
____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________

9. ¿Tiene alguna recomendación de áreas en dónde NO deban añadirse más viviendas?
____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________

Page 6 of 10 ends

Plan de Viviendas en Nuestro Rialto:

Actualización del Elemento de Vivienda 2021-2029
Políticas y Programas de Asistencia Comunitaria- Por favor califique lo siguiente según la importancia para la comunidad.
(1 es el menos importante y 5 el más importante)

10. Asistencia para compradores de vivienda (Identifique la asistencia financiera y los recursos para compradores de vivienda por primera vez) 1 2 3 4 5

11. Asistencia para el alquiler de viviendas (Identifique la asistencia financiera para inquilinos)
1 2 3 4 5

12. Mantenimiento de la propiedad (Programas para proporcionar fondos para la rehabilitación y el mantenimiento de las viviendas) 1 2 3 4 5

13. Información sobre viviendas (Información sobre oportunidades de viviendas asequibles y financiación disponible para el público) 1 2 3 4 5

Page 7 of 10 ends

Plan de Viviendas en Nuestro Rialto:

Actualización del Elemento de Vivienda 2021-2029
Políticas y Programas para la Vivienda Justa- califique lo siguiente según la importancia para la comunidad.
(1 es el menos importante y 5 el más importante)

14. Promover la vivienda justa (Proporcionar programas y políticas para abordar los problemas de la vivienda justa)
1 2 3 4 5

15. Programas de Viviendas para Personas Mayores (Fomentar el desarrollo de viviendas de apoyo para personas mayores) 1 2 3 4 5

16. Personas con discapacidad (Fomentar el desarrollo de viviendas accesibles para personas con discapacidad)
1 2 3 4 5

17. Programas de Viviendas de Apoyo (para necesidades de vivienda de emergencia, a corto y largo plazo)
1 2 3 4 5

Page 8 of 10 ends

Plan de Viviendas en Nuestro Rialto:

Actualización del Elemento de Vivienda 2021-2029
Visión para el Futuro

18. Por favor describa su visión para la vivienda en Rialto. ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________ ____________________________________________________________

Page 9 of 10 ends

Plan de Viviendas en Nuestro Rialto:

Actualización del Elemento de Vivienda 2021-2029
¡Gracias!
Gracias por tomarse el tiempo para brindar información sobre esta importante actualización. Las siguientes preguntas nos permitirán conocer quién está respondiendo a la encuesta. Su información privada se mantendrá privada.

Usted puede obtener más información en el sitio web del proyecto:
www.yourrialto.com/HouseOurRialto. Si tiene alguna pregunta sobre la encuesta o la Actualización del Elemento de Vivienda, por favor comuníquese con Siri Champion por correo electrónico a
[email protected] o por teléfono al 909-421-8072.

19. ¿Vive usted en Rialto?
Sí
No

20. ¿Trabaja usted en Rialto?
Sí
No

21. ¿Es usted arrendatario o propietario?
Arrendatario
Propietario
Soy propietario en Rialto y rento a otros
Actualmente no tengo vivienda
Otras: ____________________________________________________

Page 10 of 10 ends

Plan de Viviendas en Nuestro Rialto:

Actualización del Elemento de Vivienda 2021-2029

22. ¿Cuál es su rango de edad?
Menor de 18 años
18-34 años
35-49 años
50-64 años
65 o Mayor de 65 años
Gracias por participar en nuestra encuesta, por favor devuélvala al personal para registrar sus respuestas. Manténgase en contacto para recibir más información acerca del Plan de Viviendas para Nuestro Rialto y visite el sitio web www.yourrialto.com/HouseOurRialto!
2021-2029 City of Rialto Housing Element – Appendix C: Summary of Community Engagement C-9 C.3 City Council Meeting
This section contains all materials available for the July 13, 2021, City Council meeting. A recording of the meeting is available on the City’s website.

REGULAR MEETING
of the

CITY OF RIALTO

CITY COUNCIL
City of Rialto, acting as Successor Agency to the
Redevelopment Agency

MINUTES
July 13, 2021
A regular meeting of the City Council of the City of Rialto was held in the City Council Chambers located at 150 South Palm Avenue, Rialto, California 92376, on Tuesday, July 13, 2021.
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This meeting was called by the presiding officer of the Rialto City Council in accordance with the provisions of Government Code §54956 of the State of California.
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CALL TO ORDER Mayor Robertson called the meeting to order at 5:00 p.m. 0o0
The roll was called, and the following were present: Mayor Deborah Robertson, Mayor Pro Tem Ed Scott, Council Member Rafael Trujillo, Council Member Andy Carrizales and Council Member Karla Perez.

Also present were City Manager Marcus Fuller, City Attorney Eric Vail, and City Clerk Barbara McGee.

City Treasurer Edward Carrillo was absent.
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CLOSED SESSION 1. CONFERENCE WITH REAL PROPERTY NEGOTIATORS Pursuant to Government Code section 54956.8
Property: : 1432 S. Riverside Avenue, Rialto, CA 92376
Agency Negotiator: City Manager Marcus Fuller;
City Attorney Eric Vail
Negotiating Parties: NewMark Merrill Companies, LLC;
City of Rialto
Under Negotiation: Price and Terms of Sale

DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 2 CLOSED SESSION 2. CONFERENCE WITH REAL PROPERTY NEGOTIATORS Pursuant to Government Code section 54956.8
Property: 261 S. Palm Avenue
Agency Negotiator: City Manager Marcus Fuller;
City Attorney Eric Vail
Negotiating Parties: The Forum Blues Cafes (Terrance Harper); City of Rialto
Under Negotiation: Price and Terms of Lease

3. CONFERENCE WITH LEGAL COUNSEL –

ANTICIPATED LITIGATION
Significant exposure to litigation Pursuant to
Government Code section 54956.9(d)(2)
Number of matters: three (3)

4. CONFERENCE WITH LEGAL COUNSEL –

EXISTING LITIGATION
Pursuant to Government Code section 54956.9(d)(1)
Name of Case: Cynthia Balderas v. City of Rialto, CIV SB 2105830

5. CONFERENCE WITH LABOR NEGOTIATORS
Pursuant to Government Code section 54957.6
Agency Designated Representatives: City Manager Marcus Fuller Employee Organizations:
• City Government Management Association
• Rialto Fire Management Association
• Rialto Mid-Management & Confidential Employee’s
Association
• Rialto Policy Benefit Association – Management
• Rialto City Employee’s Association
• Rialto Police Benefit Association – General
• Rialto Professional Firefighters of California - Local 3688 • Executive Management Team
• Management Unrepresented Employees
• Unrepresented Employees

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Motion by Council Member Trujillo, second by Council Member Perez and carried by 5-0 vote to go into Closed Session at 5:02 p.m. 0o0
City Council returned from Closed Session at 6:36 p.m.
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DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 3 CALL TO ORDER Mayor Deborah Robertson called the meeting to order at 6:45 p.m. 0o0
The roll was called, and the following were present: Mayor Deborah Robertson, Mayor Pro Tem Ed Scott, Council Member Rafael Trujillo, Council Member Andy Carrizales and Council Member Karla Perez.

Also present were City Manager Marcus Fuller, City Attorney Eric Vail, and City Clerk Barbara McGee.

City Treasurer Edward Carrillo was present via Zoom.
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Pledge of Allegiance
and Invocation
Council Member Karla Perez led the Pledge of Allegiance.

Pastor Harry Bratton – Greater Faith Grace Bible Church 0o0
City Attorney’s Report on
Closed Session

1. CONFERENCE WITH REAL PROPERTY NEGOTIATORS
Pursuant to Government Code section 54956.8
Property: : 1432 S. Riverside Avenue, Rialto, CA 92376
Agency Negotiator: City Manager Marcus Fuller;
City Attorney Eric Vail
Negotiating Parties: NewMark Merrill Companies, LLC;
City of Rialto
Under Negotiation: Price and Terms of Sale

2. CONFERENCE WITH REAL PROPERTY NEGOTIATORS
Pursuant to Government Code section 54956.8
Property: 261 S. Palm Avenue
Agency Negotiator: City Manager Marcus Fuller;
City Attorney Eric Vail
Negotiating Parties: The Forum Blues Cafes (Terrance Harper); City of Rialto
Under Negotiation: Price and Terms of Lease

3. CONFERENCE WITH LEGAL COUNSEL –

ANTICIPATED LITIGATION
Significant exposure to litigation Pursuant to
Government Code section 54956.9(d)(2)
Number of matters: three (3)
.

4. CONFERENCE WITH LEGAL COUNSEL –

EXISTING LITIGATION
Pursuant to Government Code section 54956.9(d)(1)
Name of Case: Cynthia Balderas v. City of Rialto, CIV SB 2105830 DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 4 City Attorney’s Report on
Closed Session

5. CONFERENCE WITH LABOR NEGOTIATORS
Pursuant to Government Code section 54957.6
Agency Designated Representatives: City Manager Marcus Fuller Employee Organizations:
• City Government Management Association
• Rialto Fire Management Association
• Rialto Mid-Management & Confidential Employee’s
Association
• Rialto Policy Benefit Association – Management
• Rialto City Employee’s Association
• Rialto Police Benefit Association – General
• Rialto Professional Firefighters of California - Local 3688 • Executive Management Team
• Management Unrepresented Employees
• Unrepresented Employees
City Attorney Vail stated that the City Council was able have a discussion and give direction on each of the five items. There was no reportable action on any of the five items.
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PRESENTATIONS AND

PROCLAMATIONS
Introduction of New Employee by City Manager Marcus Fuller City Engineer - David Hammer
Certificate of Recognition to Azyah Rice for Wrestling Championship - Mayor Robertson
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ORAL COMMUNICATIONS None.
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City Council to Consider removing or
continuing any items on the agenda
Mayor Robertson abstained from Voucher 218721 from Warrant Resolution No. 51 (07/01/2021) made out to the National Council of Negro Women.
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E.4 Water Infrastructure Finance
Innovation Act Program
Council Member Trujillo would like to pull Item E.4 for discussion.

He asked at what point are we going to start working on helping residents with that particular infrastructure.
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Tom Crowley, Utilities Manager, stated some areas were identified that could be converted from septic to sewer. It’s finding the design and the financial ability to install the infrastructure to get to the homes. The WIFIA application is for innovative-type projects in water and wastewater and the reason for the four projects identified and further along in the process than we’re at with septic to sewer. 0o0
DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 5 E.4 Water Infrastructure Finance
Innovation Act Program
Council Member Trujillo stated that is a good clarification. 0o0
Mr. Crowley stated we’re still pursuing grant funding for some of projects that we got identified for the septic to sewer and continue to figure out how to install the infrastructure to get to those residents. 0o0
Mayor Robertson asked how many of the Rialto residents are on septic and what our process is. We have talked about it. We were provided a grant to review. This may be good opportunity to partner with the County on this application for the infrastructure in the Rancho Verde area. We already have a major project. And we won’t be able to carry that. I would love to have a robust application. If we counted those numbers we can improve water quality in our region, but we could not afford the bill.
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Council Member Trujillo stated the focus is on the Linden/Carter neighborhood.
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Mr. Crowley stated we got that identified to go after that with the Proposition 1.
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CONSENT CALENDAR A. WAIVE FULL READING OF ORDINANCES

1. Waive reading in full, all ordinances considered at this meeting. 0o0
B. APPROVAL OF WARRANT RESOLUTIONS
B.1 Warrant Resolution No.50 (06/24/2021)
B.2 Warrant Resolution No.51 (07/01/2021)
B.3 Warrant Resolution No.52 (07/08/2021)
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C. APPROVAL OF MINUTES
C.1 Regular City Council Meeting - June 8, 2021
C.2 Regular City Council Meeting - June 22, 2021
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D. CLAIMS AGAINST THE CITY
Adrian Jones - Vehicle Damage
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DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 36 TAB 4
Second Amendment to the Professional
Services Agreement Between City of
Rialto and Bureau Veritas North America,
Inc. for Building Official Services
Mayor Pro Tem Scott stated we need to speak with the former Interim City Manager and ask why it was allowed to happen.
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Mayor Robertson asked or did Mr. Hamilton inform the Interim City Manager.
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Mayor Pro Tem Scott recommended anything that is not currently in plan check at Veritas will go somewhere else tomorrow. New plan checks go with somebody that can be negotiated based on the four or five proposals. And we continue with the contract with Trang Huynh. 0o0
Mayor Robertson requested the total workload in the plan checks. How long they have been there, status, number of reviews. If more than two, it needs to return to the applicant.
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Motion by Mayor Pro Tem Scott, second by Council Member Trujillo and carried by a 4-1 vote to Continue the contract with Trang Huynh until the new person is in place. Any remaining plan checks at Veritas currently not being plan checked will be collected tomorrow along with any new plan checks and sent to a new contract vendor selected by Mr. Fuller based on the four proposals in place. Mr. Fuller has the City Council’s authorization to negotiate that on a short-term basis until all proposals are back before the City Council and enter into a contract.

Mayor Robertson voted no.
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TAB 5
Plan to House Our Rialto:2021-2029
Housing Element Update
Siri Champion, Senior Planner and Dave Barquist with Kimley-Horn & Associates presented staff report to Request City Council to Discuss the “Plan to House Our Rialto: 2021-2029 Housing Element Update” Presentation.
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Public Comment Marven Norman with CCAEJ Center for Community Action and Environmental Justice expressed his support with the Plan. He wanted to make certain that the housing and zoning provided will not infringe any new injustices.
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Jeffrey Scott with Southwest Regional Council of Carpenters recommended hiring local, skilled and trained workforce because of its impact it can do on the community.
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DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 37 TAB 5
Plan to House Our Rialto:2021-2029
Housing Element Update
Ana Gonzalez with Center for Community Action and Environmental Justice, CCAEJ, complimented Siri Champion and her team for being accessible and engaging with the community. She is impressed with the site location but expressed concerns with low-income housing in close proximity to freeways. They look forward to continue working with Siri and providing input from the community. She thanked the City Council for taking this matter seriously and moving in the right direction. 0o0
Maribel Nuñez provided a written statement and will be kept on file. 0o0
Mayor Pro Tem Scott asked about more opportunities north of the 210 Freeway.
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Ms. Champion stated she will defer to Mr. Barquist. However, there are very specific State requirements for candidate sites. Rialto falls short north of the 210 Freeway.
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Mayor Pro Tem Scott asked what the criteria is.
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Mr. Barquist stated as part of the process of identification of sites, there’s a Goldilocks provision. Not too big; not too small. There’s an issue related to some of the sites that are in specific plan areas that are still in need in being brought into the City through the process of annexation. Some of those issues that will preclude that. We want to note that in the specific plan or other areas, for example, north of 210 Freeway, those are existing opportunities that are reflected in the policies that you have of available sites, so the sites that you see in the areas just are to get the remaining pieces of that.

Mr. Barquist stated that you still have opportunities of growth and residential above the 210 Freeway, but it’s not a new or revised policy.

It’s existing policy that you have.
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Mayor Pro Tem Scott stated he is not certain he understands what was communicated. He believes there are smaller sites north of the 210 Freeway. To say everything needs to happen south of the 210 Freeway sends a bad message to this community. He requested to look deeper north of the 210 Freeway.

He inquired about Opportunity Area 1 – Foothill Boulevard. Everything in the blue has the potential of being housing, correct? 0o0
Mr. Barquist stated it will be evaluated as a site for opportunity, yes. 0o0
DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 38 TAB 5
Plan to House Our Rialto:2021-2029
Housing Element Update
Mayor Pro Tem Scott asked if there is existing businesses along there, they will be rezoned as potential housing. Will there be an overlay? 0o0
Mr. Barquist stated it can be done in both ways. There are considerations that you can have in the next interim period as you adopt zoning as you preserve existing foundational policy. Overlay adds on residential opportunities.
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Mayor Pro Tem Scott asked if you own a business in a blue area, does the owner have an opportunity to build housing or keep it as commercial property.
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Ms. Champion stated the Foothill Boulevard Specific Plan currently reads, residential is allowed in all the blue parcels. The change for the housing element would be to increase the allowed density for projects that are smaller size.
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Mayor Pro Tem Scott stated that there is a perception in the community that these areas picked will be forced to build housing on them and eliminate what’s currently on them. I want to make certain that’s not accurate.
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Ms. Champion stated you are correct. That is not accurate. 0o0
Mayor Pro Tem Scott stated that message is out in the community, and I have received many calls about it.
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Mayor Pro Tem Scott inquired about Opportunity Area 2 – North Riverside Avenue. If that property, a church, chose to sell it, somebody could build housing on it, but the church is not going to be forced to sell the property.
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Ms. Champion stated correct. The church would not be forced to sell the property. Existing uses would remain legal. They would not be expected to change. The reason churches were included in these opportunity sites, is that in other communities’ churches are finding themselves having a difficult time with their revenues due to decreases in participation in local churches. Churches are choosing to add housing to their sites to have new constituencies to their sites. 0o0
DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 39 TAB 5
Plan to House Our Rialto:2021-2029
Housing Element Update
Mayor Pro Tem Scott stated on the west side where there is a water tank. Is it suggested we remove a water tank to build houses? 0o0
Ms. Champion stated we will review and remove that.
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Mayor Pro Tem Scott inquired about Opportunity Area 3 & 4 – Gateway Specific Plan. He’s not sure the property will accommodate 251 units.

Developers are estimating 150 to 200 units. He asked if there is anything from keeping us from allowing a developer to build 150 housing units versus 251 units.
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Ms. Champion stated there is not. Mr. Barquist will expand on that. The potential to address is no net loss.
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Mr. Barquist stated that if there is a site identified for “X” number of units, you will have to make up for that deficiency somewhere else. At the point that it is approved, you have to demonstrate that the remaining sites that you have in your community can accommodate your unaccommodating need at that point in time.
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Mayor Pro Tem Scott inquired on Opportunity 5 – Central Area. There’s an overlay over the Metrolink Station. Is there a possibility to build houses in the Metrolink Station parking lot.
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Ms. Champion, stated those are City owned.
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Mayor Pro Tem Scott stated I don’t believe the parking lot is City owned.

I think Metrolink owns the parking lot.
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Ms. Champion stated she will double check.
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Mayor Pro Tem Scott stated some properties may have been missed north of the tracks that are not indicated on the slide including Orange Avenue.
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Ms. Champion stated we will look into it. It is possible that some sites have been identified in the fifth cycle. The opportunity areas for discussion tonight are new opportunities.
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DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 40 TAB 5
Plan to House Our Rialto:2021-2029
Housing Element Update
Mayor Pro Tem Scott stated he is glad that was brought up. 0o0
Council Member Trujillo asked how market forces play into the arena allocation.
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Ms. Champion stated the City is only responsible for creating opportunity for development. How it gets developed is up to the property owner.
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Mr. Barquist explained further market forces.
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Council Member Trujillo asked if there is a notification process to inform owners they’re in an opportunity zone.
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Ms. Champion stated if it is the pleasure of the City Council to begin reaching out to property owners, they can. When the plan amendments take place, zone changes, at that point, the City will be notifying property owners.
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Council Member Trujillo stated he understands the challenges building north of the 210 Freeway, have those areas been captured in the previous plan.
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Ms. Champion stated yes. That is the reason why the slide does not show north of the 210 Freeway in the five opportunity areas because we do have fifth cycle sites that are located north of the 210 Freeway.

Council Member Trujillo asked if shopping centers are magnets for opportunity zones.
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Ms. Champion stated it is a preference seen and feedback received from community members.
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Council Member Trujillo stated Baseline Avenue is also a business corridor but have not been seen as a focus of an opportunity zone. 0o0
DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 41 TAB 5
Plan to House Our Rialto:2021-2029
Housing Element Update
Ms. Champion stated they are open to any suggestions. It has not been recommended from the input received. Baseline Avenue does not have larger parcels or parcels likely to redevelop in the planning period. We can continue to study Baseline and return with more options if they become available.
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Council Member Perez asked once categories are identified and opportunities are created, will owners have a set category that they are supposed to be set for.
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Mr. Barquist stated yes and no. The State law provisions require to identify the assumed affordability when sites are identified. Ideas and assumptions are made at the forefront. The law cannot mandate developers affordability, but you still have to have a finding to makeup for that somewhere else.
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Council Member Carrizales asked about feasibility studies on housing within shopping centers.
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Ms. Champion stated there are examples that discuss repurposing older shopping centers. Foothill Boulevard is part of an idea that could happen. We can provide examples.
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Council Member Carrizales suggested renovating older shopping centers to create a new environment. He believed all the zones identified were great and thanked Ms. Champion for her work. 0o0
City Attorney Vail clarified as it relates to opportunity zones. I want to make sure we are not talking about these areas becoming Federal opportunity zones that have preferable tax treatment. That’s not what we’re talking about, correct.
0o0
Mayor Robertson stated they are not. The one on Valley would be some concerns because of the proximity to the freeway.

She asked for clarification on the 8,000 plus unit designation and its income level category distribution across the metrics.
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Ms. Champion stated that 8,000 plus number is distributed across all four different income categories from very low income to above moderate income, which is the full spectrum.
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DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 42 TAB 5
Plan to House Our Rialto:2021-2029
Housing Element Update
Mayor Robertson requested to see what was captured in the fifth cycle.

She inquired on Opportunity Area 2 – North Riverside Avenue and asked how does the coordination occur when you have old water infrastructure, and it is not under our jurisdiction since most of the water infrastructure north of Baseline Avenue is under the West Valley Water District. How do we coordinate when those projects happen? How do we ensure that they will address their old water infrastructure? We can only assure that our water infrastructure is addressed south of Baseline.

We need to think about those things when you have multiple jurisdictions servicing the community.
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Ms. Champion stated there are two points in which to address the concerns. If we learn of infrastructure problems that would seem to be insurmountable that would make development within the next eight years infeasible, we could take that off the list. In terms of going through the development process, we would look at infrastructure during the entitlement process and coordinate utilities at that point in time. 0o0
Mayor Robertson asked how many participants in the City from a 111,000 population have you had in this process. Ten? Five? One percent participation?
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Ms. Champion stated that for a project like this, cities across the State will clamor to obtain one percent participation. Over 500 residents were contacted directly by mail and 30 community-based organizations were invited. Approximately, 50-85 participants responded between surveys.

More participation is expected from Spanish speaking participants who have not been as active.
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Mayor Robertson encouraged the community to participate in the workshop. She also asked about the “free parking” reference. 0o0
Ms. Champion stated the “free parking” comment came from a range of comments from the participants from “Your Vision for the Future of Rialto”. It was part of a wide-range of comments in that category that may not have been related.
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Council Member Trujillo stated in this area inter-generational homes with multiple families are common which make parking a problem. Was that taken into account when housing numbers were created? 0o0
Mayor Pro Tem Scott stated no. It reduces the parking.
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DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 43 TAB 5
Plan to House Our Rialto:2021-2029
Housing Element Update
Council Member Trujillo stated everyone has cars. The public transportation is not the same as other bigger cities.
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Ms. Champion stated no. Proximity to transit is one the features aimed for intended to help resolve transportation issues. 0o0
Mayor Pro Tem Scott believed property owners need to be contacted sooner than later and inform them of what is being suggested. 0o0
Council Member Perez reiterated Mayor Pro Tem Scott’s suggestion that the property owners need to be informed in a timely manner. 0o0
Ms. Champion extended her assistance to the public to bring better understanding of the project.
0o0
Mayor Robertson requested a distribution of those who have participated to be able to increase participants and make others aware of the conversation.
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TAB 6
Service Agreement with Soto Resources
to Provide a Funding Research for Lake
Rialto Project and As-Needed Grant
Writing Assistance for Utility Authority
and Utilities Division
Marcus Fuller, City Manager, presented staff report to Request City Council/Rialto Utility Authority Board to Approve the Professional Services Agreement with Soto Resources to Provide a Funding Research and Strategy Report for the Lake Rialto Project and AsNeeded Grant Writing Assistance for Rialto Utility Authority and Utilities Division in an Amount Not to Exceed $50,250.
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Council Member Trujillo asked if Waterwise Community Center is what was being thought of for the Lake Rialto Project.
0o0
Mayor Robertson stated there is an opportunity for the facility we would be able to have. The San Joaquin Marsh is an area for an educational platform.
0o0
Council Member Trujillo shared he has visited the Chino Basin Conservation District and envisions something like that with this project. 0o0
DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________ Rialto City Council Meeting Minutes – July 13, 2021 Page 47 TAB 15
Continued Local Emergency COVID-19
Outbreak
City Manager Marcus Fuller presented staff report to Request City Council to Receive an Update on, Confirm the Continued Existence of, and Provide any Further Direction in Relation to the Local Emergency Throughout the City of Rialto in Response to the COVID-19 Outbreak. 0o0
Council Member Trujillo gave an update on State COVID-19 funds. He reported $625,000 which turned out to be $1.2 million and approved in the last City budget. He stated the City will receive gain benefit in the near future.
0o0
Motion by Council Member Perez, second by Council Member Trujillo and carried by a 5-0 vote to Receive an Update on, Confirm the Continued Existence of, and provide any further direction in relation to the Local Emergency Throughout the City of Rialto in Response to the COVID-19 Outbreak.
0o0
REPORTS The City Council gave their reports.
0o0
ADJOURNMENT Motion by Mayor Pro Tem Scott second by Council Member Perez and carried by a 5-0 vote to adjourn the City Council Meeting at 11:18 p.m.

_______________________________

MAYOR DEBORAH ROBERTSON
ATTEST:
_____________________________
CITY CLERK BARBARA A. McGEE
DocuSign Envelope ID: 8F83067D-2222-4539-B89A-CC1B3112407F Plan to House Our Rialto:
2021-2029 Housing Element Update
City Council Study Session – June 23, 2021
City of Rialto – 2021-2029 Housing Element Update
Agenda
• Background
• Housing Element Background
• Community Engagement
• Sites Analysis
• Next Steps
Background
City of Rialto – 2021-2029 Housing Element Update
Housing Element Background
• Required element of the City’s General Plan
• Requires adoption by the State Department of
Housing and Community Development (HCD)
• Updated on 8-year cycles
• Requires a General Plan Amendment and at least
one public hearing by Planning Commission and
City Council
• Statutory Deadline: October 15, 2021
• 120-day grace period beyond October 15
City of Rialto – 2021-2029 Housing Element Update
New Legislation for Housing Elements
• Funding Measures:
• SB 2
• SB 3
• Streamlining Measures:
• SB 35
• SB 540
• AB 73
• AB 2753
• SB 765
• SB 330
• AB 1485
• SB 744
• Accountability Measures:
• SB 167
• AB 678
• AB 1515
• ADU Measures:
• AB 68
• AB 881
• SB 13
• AB 587
• AB 670
• AB 671
• Other Measures:
• AB 1505
• AB 879
• AB 1397
• AB 72
• AB 2372
• SB 1227
• AB 2797
• AB 3194
• SB 765
• And more
City of Rialto – 2021-2029 Housing Element Update
Housing Element Components
• Population and housing profile
• Evaluation of housing constraints and resources
• Evaluation of current programs and policies
• Analysis and identification of sites to
accommodate the City’s RHNA allocation
• Policies, programs, and quantified objectives to
achieve the City’s identified housing goals
City of Rialto – 2021-2029 Housing Element Update
Rialto 2021-2029 RHNA Allocation
Income Category
% of Area
Median Income
(AMI)
Income Range1 RHNA Allocation
(Housing Units)
Minimum Maximum
Very Low Income 0 - 50% AMI -- $38,750 2,218 units
Low Income 51 – 80% AMI $38,751 $62,000 1,206 units
Moderate Income 81 – 120% AMI $62,001 $93,000 1,371 units Above Moderate Income >120% AMI $93,001 -- 3,477 units
TOTAL: 8,272 units

1. Income range is based on the 2021 HUD Area Median Income (AMI) for San Bernardino County of $77,500 for a family of 4.

City of Rialto – 2021-2029 Housing Element Update
Housing Element Certification
What Does it Mean to Have a “Certified” Housing Element? • Reviewed for compliance with state law by the Department of Housing and Community Development (HCD)
• “Certification” demonstrates substantial compliance with state law Benefits of Certification
• Access to state-sponsored grants and alternative funding sources • Protects the City from state penalties and fines due to non-compliance City of Rialto – 2021-2029 Housing Element Update
Certification Non-Compliance
• Non-compliance risks:
• Potential loss of eligibility for certain future State grant funds • Potential loss of some level of local control over development • A court may suspend the City’s authority to issue building permits or other approvals
• HCD may forward a noncompliance case to the California Office of the Attorney General
• Outside groups may sue the City for a non-compliant Housing Element
City of Rialto – 2021-2029 Housing Element Update
Affirmatively Furthering Fair Housing (AFFH)
• Fair and equitable distribution of housing
throughout the community
• Protects against communities being
overburdened
• Takes into consideration:
• A variety of housing types (single-family house,
apartment, townhome, etc.)
• Mix of affordability levels
• Access to transportation and employment
• Considers access to public transit and
community resources
Community Engagement
City of Rialto – 2021-2029 Housing Element Update
Summary of Outreach Efforts
• Completed Outreach:
• Virtual community workshop on May 19th, 2021
• Self-Guided Workshop - in person and online
• Informational postcards sent to the community
• Community surveys – in person and online
• In progress
• Spanish translations provided
• Online advertising on social media and the
City’s website
City of Rialto – 2021-2029 Housing Element Update
Virtual Community Workshop
• Date: May 19, 2021
• Spanish translation available
• Overview:
• Housing Element Update Process
• Baseline demographics and housing data
• Participant activities
• Feedback received:
• Community needs affordable housing
• Interest in mixed-use housing
• Need for multi-generational housing and
larger housing units
• Focus on improving historic downtown
• Access to public amenities (parks, etc.)
and walking trails/bike lanes is important
City of Rialto – 2021-2029 Housing Element Update
House Our Rialto Webpage
• Webpage providing information on
the Housing Element Update and
opportunities for the community to
participate
• Email list
• Self-Guided Workshop
• Become and “Engagement Partner”
• Contact information
Sites Analysis & Identification
City of Rialto – 2021-2029 Housing Element Update
Sites Analysis
• Determine capacity for residential development at different levels of affordability under current regulations
• Accounts for:
• Projects in the pipeline
• Vacant parcels zoned for residential
• Non-vacant parcels zoned for residential
• Accessory Dwelling Units
• 5
th Cycle sites
City of Rialto – 2021-2029 Housing Element Update
Estimated Residential Dwelling Unit Potential
Low- and VeryLow IncomeModerate- and
Above-Moderate
Income
Pipeline projects 0 0
Vacant residentially zoned parcels 289 11,789
Non-vacant residential parcels 228 5,265
Accessory Dwelling Units 72 53
TOTAL EXISTING CAPACITY 589 17,107
RHNA Allocation 3,415 4,837
Surplus/Shortfall -2,826 12,270
City of Rialto – 2021-2029 Housing Element Update
Estimated Residential Dwelling Unit Potential
Low- and VeryLow IncomeModerate- and
Above-Moderate
Income
Pipeline projects 0 0
Vacant residentially zoned parcels 289 11,789
Non-vacant residential parcels 228 5,265
Accessory Dwelling Units 72 53
TOTAL EXISTING CAPACITY 589 17,107
RHNA Allocation 3,415 4,837
Surplus/Shortfall -2,826 12,270
State law requires minimum of
30 dwelling units per acre
City of Rialto – 2021-2029 Housing Element Update
Density Examples – 20-35 DU/Acre
Walk-up Townhomes Larger Apartments/ Condos Townhomes/ Apartments Photo Credit: KTGY Architecture
21 du/ac 30 du/ac 36 du/ac (Affordable)
City of Rialto – 2021-2029 Housing Element Update
Density Examples – 30 DU/Acre
Walk-up Townhomes Larger Apartments/ Condos Townhomes/ Apartments Photo Credit: KTGY Architecture
30 du/ac 30 du/ac 31 du/ac
City of Rialto – 2021-2029 Housing Element Update
Senior Housing Mixed-Use Apartments/ Condos
Photo Credit: KTGY Architecture
21 du/ac 30 du/ac 36 du/ac
Density Examples – 21-36 DU/Acre
City of Rialto – 2021-2029 Housing Element Update
Density Examples – 21-36 DU/Acre
Mixed-Use Apartments/ Condos Apartments/ Condos
Photo Credit: KTGY Architecture
21 du/ac 30 du/ac 36 du/ac
City of Rialto – 2021-2029 Housing Element Update
Sites Identification Process
• Site characteristics:
• Vacant/underutilized
• Lot size
• Proximity to transit
• Potential to develop at higher density
• City-owned properties
• Potential of existing non-residential sites
capable to develop for residential use
• Consider the existing use and its
realistic likelihood to redevelop for
residential uses within the planning
period
City of Rialto – 2021-2029 Housing Element Update
Opportunity
Areas 2
1 4 3
5 City of Rialto – 2021-2029 Housing Element Update
Opportunity Area 1 – Foothill Boulevard
• Foothill Boulevard Specific Plan Amendment
• Allow 30-dwelling units per acre on projects of all sizes City of Rialto – 2021-2029 Housing Element Update
Opportunity Area 2 – North Riverside Ave
• Zoning Code Amendment
• C-1 Neighborhood
Commercial Zone and A-P
Administrative-ProfessionalInstitutional Zone to R-4 High Density Multiple Family Zone
City of Rialto – 2021-2029 Housing Element Update
Opportunity Area 3 & 4 – Gateway Specific Plan
• Gateway Specific Plan
Amendment
• Establish a new land use
category and
development standards
for lots currently identified
as Retail Commercial,
Office Park, and Industrial
Park
City of Rialto – 2021-2029 Housing Element Update
Opportunity Area 5 – Central Area
• Central Area Specific
Plan Amendment
• Change parcels from
Core Commercial, Office
Services, Support
Facilities, and Cottage
Commercial to Increased
Density Residential
City of Rialto – 2021-2029 Housing Element Update
Key Policy Considerations
• Plan for higher density residential uses in five opportunity areas • Buffer for No Net Loss provisions in anticipation of project approvals with fewer units than shown in the Housing Element • Explore additional areas such as Baseline Avenue and
Bloomington Avenue Next Steps
City of Rialto – 2021-2029 Housing Element Update
Next Steps
Workshop #2 Interactive web
map
Finalize Housing
Constraints,
Resources,
Sites Analysis,
and Housing
Plan
Release Public
Review Draft
Housing
Element
Review Public
Feedback
HCD Review
Draft Housing
Element
Local Adoption
of the Housing
Element
City of Rialto – 2021-2029 Housing Element Update
Thank You!
Questions?
Please contact:

Siri Champion, Project Manager
Email: [email protected]
Phone: (909) 820-8072
For more information, please visit the City’s Housing Element Update webpage: www.yourrialto.com/HouseOurRialto
2021-2029 City of Rialto Housing Element – Appendix C: Summary of Community Engagement C-10 C.4 Planning Commission Study Session
This section contains all materials available for the July 14, 2021, Planning Commission Study Session. A recording of the Study Session is available on the City’s website.

Planning Commission
City of Rialto
Special Meeting - Final
Council Chambers,150 S. Palm Ave., Rialto, CA
92376
Wednesday, July 14, 2021 5:00 PM

HOUSING ELEMENT UPDATE STUDY SESSION
Public Participation Procedures

NOTICE IS GIVEN THAT THE CITY COUNCIL OF THE CITY OF RIALTO HAS DECLARED A LOCAL EMERGENCY RELATED TO COVID-19, AND IN COMPLIANCE WITH SOCIAL DISTANCING PROTOCOLS REQUIRED BY GOVERNOR NEWSOM’S EXECUTIVE ORDER N-29-20 AND THE STATE DEPARTMENT OF PUBLIC HEALTH, THE COUNCIL CHAMBERS WILL BE OPEN TO THE PUBLIC WITH LIMITED SEATING INSIDE. THE PUBLIC WILL HAVE AN OPPORTUNITY TO SPEAK USING THE PODIUM INSIDE THE COUNCIL CHAMBERS.

IF YOU ARE UNABLE TO ATTEND THE MEETING, YOU MAY SUBMIT COMMENTS BEFORE THE MEETING TIME, AS FOLLOWS:
- IN WRITING VIA MAIL TO: CITY OF RIALTO “ATTN: PLANNING COMMISSION, C/O COMMUNITY DEVELOPMENT,” 150 S PALM AVE, RIALTO, CA 92376; OR
- BY EMAIL TO [email protected].

Call To Order
Pledge of Allegiance
Roll Call
Chair Frank Gonzalez, Vice-Chair Jerry Gutierrez, John Peukert, Artist Gilbert, Al Twine, Dale Estvander, BarBara Chavez
Study Session
PC-21-0437 Plan to House Our Rialto: 2021-2029 Housing Element Update Study Session
Adjournment

Page 1 ends

1 City of Rialto
Legislation Text
File #: PC-21-0437, Version: 1, Agenda #:

For Planning Commission Study Session [July 14, 2021]
TO: Honorable Chairman and Planning Commissioners
APPROVAL: Karen Peterson, Community Development Manager FROM: Siri Champion, Senior Planner
Plan to House Our Rialto: 2021-2029 Housing Element Update Study Session

BACKGROUND
The intent of this study session is to provide background information, give an update on community engagement, and obtain policy direction regarding the City’s approach to meeting the City’s 2021- 2029 RHNA allocation.

HOUSING ELEMENT REQUIREMENT
In compliance with State law and in support of housing production, jurisdictions, including the City of Rialto, are required to include a Housing Element in the General Plan. The purpose of the Housing Element Update is to adequately plan to meet anticipated housing needs of all incomes. As a policy plan, the Housing Element neither requires nor authorizes any housing units to be built. Instead, it identifies opportunities for for-profit and not-for-profit residential developers.

CERTIFICATION BY HOUSING AND COMMUNTIY DEVELOPMENT (HCD) As part of the update process, the Housing Element is submitted to the California State Department of Housing and Community Development (HCD) for review and determination of compliance. By statute Housing Elements are required to be updated on a regular cycle. At this time, Rialto’s Housing Element must be updated every four years. Provided that the City adopts the 6th Cycle Housing Element Update by October 15, 2021, the City may return to an eight-year schedule. The adoption process includes at least one Public Hearing by the Planning Commission and one public hearing by the City Council.

REGIONAL HOUSING NEEDS ASSESSMENT (RHNA)
The Plan to House Our Rialto will comply with State law and include goals, policies, objectives, and programs to preserve, improve, and promote the production of housing for all income levels. The plan will also address the City’s share of the Regional Housing Needs Assessment (RHNA) and demonstrate how it can be accommodated. Overall, the Southern California Association of Governments (SCAG) region must accommodate 1,341,827 total units, which have been allocated by SCAG to all the jurisdictions in the region. Rialto’s share is 8,252 dwelling units, which is more than three times the City’s 5th Cycle allocation of 2,715.

RHNA allocations are broken into income categories as shown in Table 1.

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Table 1. 2021-2029 (6th Cycle) Regional Housing Needs Assessment Allocation by Income Level* for City of Rialto
Very-low income
$37,650
Low income
$60,250
Moderate Income
$75,300
Above-moderate Income
$90,350
Total
2,212 1,203 1,368 3,469 8,252
* 2020 State Income Limits for 4-person households in San Bernardino County

COMMUNITY ENGAGEMENT AND CONTEXT
Public engagement is an important source of information to understand local housing conditions and potential approaches to meeting housing need. The engagement process initiated in March with the virtual Phase 1 Community Workshop
Major themes from the workshop include:
· Need for affordable housing
· Need for diverse housing options such as
o Multi-generational housing
o Large homes
o Mixed use housing in commercial areas for young people o Homes for seniors and those who are disabled
· Visions of neighborhoods that are safe, equitable, revitalized, and with access to public amenities, transit, walking trails, and bike lanes
· A desire for programs to rehabilitate older homes and revitalize older areas such as the historic downtown
Other comments include a desire for environmentally friendly housing and good air quality as well as concerns about equity for BIPOC (black, indigenous, people of color) and transgender people when seeking a home.

ANALYSIS/DISCUSSION
The Plan to House Our Rialto team has completed a preliminary sites analysis following HCD’s Site Inventory Guidebook. The results of the analysis are provided in this section. In short, the City has sufficient land zoned for residential to satisfy the RHNA allocation for moderate and above-moderate income dwelling units. However, the City does not have enough land zoned for residential to satisfy the RHNA allocation for the low- and very-low income categories.

Through this item, the project team seeks direction regarding where to accommodate residential uses at higher densities as required by HCD to accommodate low and very low income.

SITES ANALYSIS
To plan for the needs of current and future residents as anticipated by the City’s RHNA, the Plan to House Our Rialto team has conducted a citywide analysis of sites for potential residential development. That analysis took into consideration state requirements for sites by income ranges. As shown in Table 2, the City has ample existing sites, meaning parcels already zoned appropriately, to meet and exceed the RHNA allocation for moderate income and above-moderate income dwelling units.

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Table 2. Estimated Residential Dwelling Unit Potential Moderate Income and Above-Moderate Income Vacant residentially zoned parcels 11,789
Non-vacant residential parcels with propensity to develop 5,265 Accessory Dwelling Units 53
Total 17,107
Allocation 4,837
Sites Surplus 12,270
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However, the City does not have sufficient sites to meet state requirements for low income categories. The state requires that sites be zoned for residential at a minimum of 30 dwelling units per acre to accommodate the development of housing affordable to lower-income households. While height, bulk, and aesthetic character can vary significantly, a few examples in the 30-35 dwelling unit per acre range appear below.

As shown in Table 3, Rialto’s existing residential dwelling unit potential in the very-low and lowincome categories has a shortfall of 2,826 dwelling units.

Table 3. Estimated Residential Dwelling Unit Potential Very-Low and Low Income Dwelling Units Vacant residentially zoned parcels 289
Non-vacant residential parcels with propensity to develop 228 Accessory Dwelling Units 72
Total 589
Allocation 3,415
Dwelling Unit Shortfall -2,826

OPPORTUNITY AREAS
To make up the 2,836 dwelling unit shortfall, the City must identify opportunities to upzone and/or rezone parcels. By upzoning, the City may increase the allowed density to 30 dwelling units per acre or more. By rezoning, the City may change a non-residential parcel to a residential parcel. For example, commercially zoned parcels may be changed to create opportunities for multiple family residential development.

To identify potential opportunities, the Plan to House Our Rialto team conducted a citywide analysis of parcel characteristics including existing zoning, existing use (vacant/underutilized), lot size, proximity to transit, and surrounding development patterns. As a result of that analysis, five opportunity areas have been identified for further consideration. The five opportunity areas are listed in Table 4.

Table 4. Estimated Dwelling Unit Potential in Opportunity Areas Under Consideration of Upzone/Rezo 1 - Foothill Boulevard 1,470
2 - North Riverside Avenue near 210 Freeway678
3 - South Riverside Avenue (southeast of San Bernardino Avenue and Riverside Avenue)
570
4 - Rialto Marketplace II 251
5 Central Area Specific Plan 184
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Table 4. Estimated Dwelling Unit Potential in Opportunity Areas Under Consideration of Upzone/Rezo 1 - Foothill Boulevard 1,470
2 - North Riverside Avenue near 210 Freeway678
3 - South Riverside Avenue (southeast of San Bernardino Avenue and Riverside Avenue)
570
4 - Rialto Marketplace II 251
5 - Central Area Specific Plan 184
Total 3,153
For each of the five opportunity areas, the City would need to implement Specific Plan or zoning code amendments. Those implementation activities are summarized as follows.

Opportunity Area 1 would require an amendment to the Foothill Boulevard Specific Plan. Currently, residential development is allowed in all land use districts. However, the allowed density varies with the project size. Currently, on projects over 3 acres, 30 dwelling units per acre are allowed. To meet state requirements and achieve more low- and very-low income dwelling units, the City would need to increase residential density for project sizes less than 3 acres.

Opportunity Area 2 - North Riverside Avenue
Opportunity Area 2 would require a change of zoning from C-1 Neighborhood Commercial Zone and A-P Administrative-Professional-Institutional Zone to R-4 High Density Multiple Family Zone.

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Opportunity Area 3 and 4 - South Riverside Avenue and Rialto Marketplace II Opportunity Area 3 and 4 would require an update to the Gateway Specific Plan. Opportunity Area 3 is in the vicinity of the Grace Vargas Senior Center and Rialto Assisted Living and Opportunity Area 4 is a portion of the Rialto Marketplace II development. Currently, the opportunity areas are identified as Retail Commercial (R-C), Office Park (O-P), and Industrial Park (I-P). Through a Specific Plan Amendment, the City would establish a new land use category and accompanying development standards.

Opportunity Area 5 - Central Area
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Opportunity Area 5 would require an amendment to the Central Area Specific Plan to change several parcels from Core Commercial, Office Services, Support Facilities, and Cottage Commercial to Increased Density Residential.

NO NET LOSS
The City should consider identifying an excess of opportunity sites due to SB 166, which requires no net loss. SB 166 is intended to ensure development opportunities remain available throughout the planning period to accommodate a jurisdiction’s RHNA. As a result of SB 166, if the City approves development of a parcel identified in the Housing Element sites inventory with fewer units than shown in the Housing Element, it must either make findings that the Housing Element’s remaining sites have City of Rialto Page 7 of 8 Printed on 7/9/2021
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sufficient capacity to accommodate the remaining unmet RHNA by income level or identify and make available sufficient sites to accommodate the remaining unmet RHNA for each income category.

NEXT STEPS
The next steps in the development of the Plan to House Our Rialto includes continued analysis of opportunity sites and public engagement. During July, the Plan to House Our Rialto team will complete the site inventory and identification and draft the Housing Plan. The draft plan will be available for review during the month of August. A Public Hearing on the draft is planned for the Planning Commission September and a Public Hearing on the draft plan is planned for the City Council on October 12.

Phase 2 Community Survey and Interactive Mapping
The Phase 2 Community Survey opened on June 14 and is currently live. The survey includes questions about housing type, location, and policy priorities.

As requested by City Council and public stakeholders, the Plan to House Our Rialto team is preparing an interactive map to illustrate candidate sites and receive comments from the public.

Phase 3 Community Workshop
The Phase 3 Community Workshop is scheduled for July 15, 2021. The meeting will include a report on public input to date, an introduction to the Plan to House Our Rialto, and a demonstration of the interactive map.

GENERAL PLAN CONSISTENCY
The Housing Element and its implementation plan are a required component of the General Plan.

This activity is consistent with Goal 6-2, which is to “promote and encourage housing development that adequately meets the needs of all socioeconomic segments of the community and region.”

RECOMMENDATION
Staff recommends that the Planning Commission receive and file this report and provide direction to staff regarding the five opportunity areas which may be used to meet the state’s RHNA allocation for low-income categories.

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Plan to House Our Rialto:
2021-2029 Housing Element Update
City Council Study Session – June 23, 2021
10 City of Rialto – 2021-2029 Housing Element Update
Agenda
• Background
• Housing Element Background
• Community Engagement
• Sites Analysis
• Next Steps
11 Background
12 City of Rialto – 2021-2029 Housing Element Update
Housing Element Background
• Required element of the City’s General Plan
• Requires adoption by the State Department of
Housing and Community Development (HCD)
• Updated on 8-year cycles
• Requires a General Plan Amendment and at least
one public hearing by Planning Commission and
City Council
• Statutory Deadline: October 15, 2021
• 120-day grace period beyond October 15
13 City of Rialto – 2021-2029 Housing Element Update
New Legislation for Housing Elements
• Funding Measures:
• SB 2
• SB 3
• Streamlining Measures:
• SB 35
• SB 540
• AB 73
• AB 2753
• SB 765
• SB 330
• AB 1485
• SB 744
• Accountability Measures:
• SB 167
• AB 678
• AB 1515
• ADU Measures:
• AB 68
• AB 881
• SB 13
• AB 587
• AB 670
• AB 671
• Other Measures:
• AB 1505
• AB 879
• AB 1397
• AB 72
• AB 2372
• SB 1227
• AB 2797
• AB 3194
• SB 765
• And more
14 City of Rialto – 2021-2029 Housing Element Update
Housing Element Components
• Population and housing profile
• Evaluation of housing constraints and resources
• Evaluation of current programs and policies
• Analysis and identification of sites to
accommodate the City’s RHNA allocation
• Policies, programs, and quantified objectives to
achieve the City’s identified housing goals
15 City of Rialto – 2021-2029 Housing Element Update
Rialto 2021-2029 RHNA Allocation
Income Category
% of Area
Median Income
(AMI)
Income Range1 RHNA Allocation
(Housing Units)
Minimum Maximum
Very Low Income 0 - 50% AMI -- $38,750 2,218 units
Low Income 51 – 80% AMI $38,751 $62,000 1,206 units
Moderate Income 81 – 120% AMI $62,001 $93,000 1,371 units Above Moderate Income >120% AMI $93,001 -- 3,477 units
TOTAL: 8,272 units

1. Income range is based on the 2021 HUD Area Median Income (AMI) for San Bernardino County of $77,500 for a family of 4. 16 City of Rialto – 2021-2029 Housing Element Update
Housing Element Certification
What Does it Mean to Have a “Certified” Housing Element? • Reviewed for compliance with state law by the Department of Housing and Community Development (HCD)
• “Certification” demonstrates substantial compliance with state law Benefits of Certification
• Access to state-sponsored grants and alternative funding sources • Protects the City from state penalties and fines due to non-compliance 17 City of Rialto – 2021-2029 Housing Element Update
Certification Non-Compliance
• Non-compliance risks:
• Potential loss of eligibility for certain future State grant funds • Potential loss of some level of local control over development • A court may suspend the City’s authority to issue building permits or other approvals
• HCD may forward a noncompliance case to the California Office of the Attorney General
• Outside groups may sue the City for a non-compliant Housing Element
18 City of Rialto – 2021-2029 Housing Element Update
Affirmatively Furthering Fair Housing (AFFH)
• Fair and equitable distribution of housing
throughout the community
• Protects against communities being
overburdened
• Takes into consideration:
• A variety of housing types (single-family house,
apartment, townhome, etc.)
• Mix of affordability levels
• Access to transportation and employment
• Considers access to public transit and
community resources
19 Community Engagement
20 City of Rialto – 2021-2029 Housing Element Update
Summary of Outreach Efforts
• Completed Outreach:
• Virtual community workshop on May 19th, 2021
• Self-Guided Workshop - in person and online
• Informational postcards sent to the community
• Community surveys – in person and online
• In progress
• Spanish translations provided
• Online advertising on social media and the
City’s website
21 City of Rialto – 2021-2029 Housing Element Update
Virtual Community Workshop
• Date: May 19, 2021
• Spanish translation available
• Overview:
• Housing Element Update Process
• Baseline demographics and housing data
• Participant activities
• Feedback received:
• Community needs affordable housing
• Interest in mixed-use housing
• Need for multi-generational housing and larger housing units • Focus on improving historic downtown
• Access to public amenities (parks, etc.) and walking trails/bike lanes is important 22 City of Rialto – 2021-2029 Housing Element Update
House Our Rialto Webpage
• Webpage providing information on
the Housing Element Update and
opportunities for the community to
participate
• Email list
• Self-Guided Workshop
• Become and “Engagement Partner”
• Contact information
23 Sites Analysis & Identification
24 City of Rialto – 2021-2029 Housing Element Update
Sites Analysis
• Determine capacity for residential development at different levels of affordability under current regulations
• Accounts for:
• Projects in the pipeline
• Vacant parcels zoned for residential
• Non-vacant parcels zoned for residential
• Accessory Dwelling Units
• 5th Cycle sites
25 City of Rialto – 2021-2029 Housing Element Update
Estimated Residential Dwelling Unit Potential
Low- and VeryLow IncomeModerate- and
Above-Moderate
Income
Pipeline projects 0 0
Vacant residentially zoned parcels 289 11,789
Non-vacant residential parcels 228 5,265
Accessory Dwelling Units 72 53
TOTAL EXISTING CAPACITY 589 17,107
RHNA Allocation 3,415 4,837
Surplus/Shortfall -2,826 12,270
26 City of Rialto – 2021-2029 Housing Element Update
Estimated Residential Dwelling Unit Potential
Low- and VeryLow IncomeModerate- and
Above-Moderate
Income
Pipeline projects 0 0
Vacant residentially zoned parcels 289 11,789
Non-vacant residential parcels 228 5,265
Accessory Dwelling Units 72 53
TOTAL EXISTING CAPACITY 589 17,107
RHNA Allocation 3,415 4,837
Surplus/Shortfall -2,826 12,270
State law requires minimum of
30 dwelling units per acre
27 City of Rialto – 2021-2029 Housing Element Update
Sites Identification Process
• Site characteristics:
• Vacant/underutilized
• Lot size
• Proximity to transit
• Potential to develop at higher density
• City-owned properties
• Potential of existing non-residential sites
capable to develop for residential use
• Consider the existing use and its
realistic likelihood to redevelop for
residential uses within the planning
period
28 City of Rialto – 2021-2029 Housing Element Update
Opportunity
Areas 2
1 4 3
5 29
City of Rialto – 2021-2029 Housing Element Update
Opportunity Area 1 – Foothill Boulevard
• Foothill Boulevard Specific Plan Amendment
• Allow 30-dwelling units per acre on projects of all sizes 30 City of Rialto – 2021-2029 Housing Element Update
Opportunity Area 2 – North Riverside Ave
• Zoning Code Amendment
• C-1 Neighborhood
Commercial Zone and A-P
Administrative-ProfessionalInstitutional Zone to R-4 High Density Multiple Family Zone
31 City of Rialto – 2021-2029 Housing Element Update
Opportunity Area 3 & 4 – Gateway Specific Plan
• Gateway Specific Plan
Amendment
• Establish a new land use
category and
development standards
for lots currently identified
as Retail Commercial,
Office Park, and Industrial
Park
32 City of Rialto – 2021-2029 Housing Element Update
Opportunity Area 5 – Central Area
• Central Area Specific
Plan Amendment
• Change parcels from
Core Commercial, Office
Services, Support
Facilities, and Cottage
Commercial to Increased
Density Residential
33 City of Rialto – 2021-2029 Housing Element Update
Key Policy Considerations
• Plan for higher density residential uses in five opportunity areas • Buffer for No Net Loss provisions in anticipation of project approvals with fewer units than shown in the Housing Element • Explore additional areas such as Baseline Avenue and
Bloomington Avenue
34 Next Steps
35 City of Rialto – 2021-2029 Housing Element Update
Next Steps
Workshop #2 Interactive web
map
Finalize Housing
Constraints,
Resources,
Sites Analysis,
and Housing
Plan
Release Public
Review Draft
Housing
Element
Review Public
Feedback
HCD Review
Draft Housing
Element
Local Adoption
of the Housing
Element
36 City of Rialto – 2021-2029 Housing Element Update
Thank You!
Questions?
Please contact:

Siri Champion, Project Manager
Email: [email protected]
Phone: (909) 820-8072
For more information, please visit the City’s Housing Element Update webpage: www.yourrialto.com/HouseOurRialto
37 2021-2029 City of Rialto Housing Element – Appendix C: Summary of Community Engagement C-11 C.5 Community Workshop #2
This section contains all available materials created for the virtual community workshop and following inperson outreach. Public comments for the workshop were received verbally and through the Zoom chat function. The recorded workshop is available for viewing on the Housing Element Update webpage:https://www.rialtoca.gov/633/Plan-to-House-Our-Rialto-Housing-Element.

For questions, please contact Siri Champion, Project Planner by email at [email protected]
The City of Rialto is preparing to release the draft “Plan to House Our Rialto:
2021-2029 Housing Element Update.” The plan will guide decisions about and create opportunities for developers to build new housing. Please join us for virtual a workshop to learn about the different parts of the plan and provide feedback.

WHEN: July 15, 2021, 6-8 p.m.

WHERE: Online via Zoom at: https://bit.ly/3An3yCK
WEBSITE: www.yourrialto.com/HouseOurRialto
Upcoming Public Meetings
City Council Meeting - July 13, 2021, at 6:30 p.m.

Planning Commission Study Session - July 14, 2021, at 5:00 p.m.

PLAN TO HOUSE OUR RIALTO
City of Rialto 2021-2029 Housing Element Update
Community Workshop #2
Si tiene alguna pregunta, por favor comuníquese con Siri Champion, Planificadora del Proyecto por correo electrónico a [email protected] La ciudad de Rialto se está preparando para publicar el borrador del “Plan de Viviendas en Nuestro Rialto.” El plan guiará y creará oportunidades para que los desarrolladores inmobiliarios construyan nuevas viviendas. Únase a nosotros en un taller virtual para aprender sobre las diferentes partes del borrador y cómo puede proporcionar comentarios durante el período de revisión pública.

FECHA Y HORA: 15 de julio del 2021, 6-8 p.m.

LUGAR: Reunión en línea: https://kimley-horn.zoom.us/j/98352198501 SITIO WEB: www.yourrialto.com/HouseOurRialto
Próxima Reunión Pública
Reunión del Concejo de la Ciudad - 13 de julio del 2021, 6:30 p.m.

Sesión de Estudio de la Comisión de Planificación - 14 de julio del 2021, 5:00 p.m.

PLAN DE VIVIENDAS EN NUESTRO RIALTO
ACTUALIZACIÓN DEL ELEMENTO DE VIVIENDA DE LA CIUDAD DE RIALTO 2021-2029 Taller Comunitario #2
2021-2029 City of Rialto Housing Element – Appendix C: Summary of Community Engagement C-12 C.6 Interactive Feedback Map
This section contains all available data and information collected through the interactive map.  





   


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2021-2029 City of Rialto Housing Element – Appendix C: Summary of Community Engagement C-13 C.7 Spanish-Speaking Workshop
This section contains all available materials created for the in-person community workshop. The workshop was held solely in Spanish and presented the same information as the workshop on July 15, 2021. 1 Plan de Vivienda de Nuestro Rialto:

Actualización del Elemento de Vivienda 2021-2029
Taller Comunitario Virtual #2 – 15 de julio de 2021
City of Rialto – 2021-2029 Housing Element Update
Agenda de Esta Noche
• Antecedentes del Elemento de Vivienda
• Esfuerzos de Participación Comunitaria Hasta la Fecha • Análisis del Inventario de Sitios y Estrategia Potencial • Comentarios de la Comunidad
• Borrador de Políticas y Programas
• Próximos Pasos
1 2
2 Antecedentes del Elemento
de Vivienda
City of Rialto – 2021-2029 Housing Element Update
Antecedentes del Elemento de Vivienda
• Es un Elemento Requerido por El Plan General de
la Ciudad
• Requiere la adopción por parte del Departamento
de Vivienda y Desarrollo Comunitario del Estado
(HCD por sus siglas en inglés)
• Periodo de planificación de 8 años
• Requiere una Enmienda al Plan General y al
menos una audiencia pública por parte de la
Comisión de Planificación y el Concejo Municipal
3 4
3 City of Rialto – 2021-2029 Housing Element Update
Componentes del Elemento de la Vivienda
• Perfil de población y vivienda
• Restricciones y recursos de vivienda
• Evaluación de programas y políticas actuales
• Análisis e identificación de sitios para
acomodar la distribución de RHNA de la
ciudad
• Políticas, programas y objetivos para lograr las
metas de vivienda identificadas por la ciudad
City of Rialto – 2021-2029 Housing Element Update
Distribución 2021-2029 de RHNA para Rialto
Categoría de Ingresos
% del Ingreso
Medio del Área
(AMI)
Escala de Ingresos1 Distribución de RHNA (Unidades
Habitacionales)
Mínimo Máximo
Ingresos Muy Bajos 0 - 50% AMI -- $38,750 2,218 unidades Ingresos Bajos 51 – 80% AMI $38,751 $62,000 1,206 unidades Ingresos Moderados 81 – 120% AMI $62,001 $93,000 1,371 unidades Ingresos Superiores a
Ingresos Moderados >120% AMI $93,001 -- 3,477 unidades
TOTAL: 8,272 unidades

1. La escala de ingresos se basa en el Ingreso Medio del Área (AMI) del HUD de 2021 para el Condado de San Bernardino de $77,500 considerando una familia de 4. 5 6
4 City of Rialto – 2021-2029 Housing Element Update
Promoción Afirmativa de la Vivienda Justa (AFFH)
• Distribución justa y equitativa de la vivienda en
toda la comunidad
• Promueve las comunidades inclusivas
• Aborda los patrones de segregación
• Consideraciones :
• Una variedad de tipos de vivienda (casas unifamiliares, apartamentos, casas adosadas, etc.) • Combinación de niveles de asequibilidad
• Acceso al transporte Público y al empleo
• Considera el acceso al Transporte Público y a
los recursos comunitarios
Esfuerzos de Participación
Comunitaria hasta la Fecha
7 8
5 City of Rialto – 2021-2029 Housing Element Update
Actividades de Participación– Taller Fase 1 Taller Comunitario de mayo 19 36 participantes
Taller Autoguiado
en Línea
3 participantes
Taller Autoguiado en Persona
5 participantes
City of Rialto – 2021-2029 Housing Element Update
Actividades de Participación– Encuesta
Comunitaria Fase 2
Junio 23 Farmers Market 12 participantes
Julio 9 Pop It Up BBQ
26 participantes Encuesta en Línea55 participantes
9 10
6 City of Rialto – 2021-2029 Housing Element Update
Actividades de Participación – Divulgación y
Publicidad
• Sitio Web del Proyecto
• Correo Electrónico (128 contactos)
• 20 Socios Participantes
• Postales/volantes informativos
enviados por correo a casi 20,000
personas
• Residentes en vecindarios de
ingresos bajos e ingresos
moderados
• Solicitantes de financiamiento CARES
• Publicidad en línea en las redes
sociales y en el sitio web de la
ciudad
City of Rialto – 2021-2029 Housing Element Update
Taller Comunitario Virtual
• Comentarios Recibidos: • La comunidad necesita viviendas asequibles
• Interés por la vivienda de uso mixto
• Necesidad de viviendas
multigeneracionales y unidades de
vivienda más grandes
• Enfocarse en mejorar el centro
histórico
• Es importante el acceso a servicios
públicos (parques, etc.) y senderos
para caminar / carriles para
bicicletas
Diversidad
Zonas verdes rurales Tranquilo
Paz antes de los almacenes
Buenos vecinos
Parques nuevos
Parques cercanos Estacionamiento gratis
Con sentido familiar
Sensación de un
vecindario antiguo
Pequeñas empresas
Pequeños
terrenos grandes
Lugares para Compras cercanos
11 12
7 City of Rialto – 2021-2029 Housing Element Update
Encuesta Comunitaria de Fase 2
Participantes de la Encuesta
• El 83% vive en Rialto
• El 44% trabaja en Rialto
• El 28% son arrendatarios
• El 66% son propietarios
5%
18%
42%
23%
12%
Edad de los Participantes en la Encuesta Menores de 18 Less than 18 18-34 35-49 50-64 65 or older 65 o Mayores City of Rialto – 2021-2029 Housing Element Update
Respuestas a la Encuesta – Tipos de Vivienda

15.4%

53.8%

16.9%

32.3%

36.9%

41.5%

29.2%

35.4%

67.7%

21.5%

20.0%
0% 10% 20% 30% 40% 50% 60% 70% 80%
Unidades de Vivienda Accesorias Viviendas Asequibles
Apartamentos/Condominios para Renta
Apartamentos/Condominios para Venta
Viviendas para personas con discapacidades
Viviendas de Ingresos Mixtos
Viviendas Multigeneracionales
Viviendas para Personas Mayores Viviendas Unifamiliares Viviendas Transitorias o de Apoyo Otros
Tipos de Viviendas que a la Comunidad le gustaría ver en Rialto Tenencia de Vivienda Necesaria
Viviendas para Renta Viviendas para Venta Ambas
13 14
8 City of Rialto – 2021-2029 Housing Element Update
Respuestas a la Encuesta – Ubicación de las
Viviendas

56.9%

44.6%

44.6%

35.4%

46.2%

52.3%

12.3%

0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0%
Cerca de los centros comerciales de la región
Dentro y al rededor del centro
En corredores principales (tales como la Avenida Bloomington, el Boulevard Foothil, la Avenida Riverside, o la Avenida Baseline Cerca de las instalaciones públicas
En vecindarios existentes (Más ADUs (Casas Accesorias), duplexes, triplexes, y otros tipos de vivienda similares Cerca de los Transportes Públicos
Otras
Ubicaciones Más Adecuadas para Viviendas Nuevas
)
)
City of Rialto – 2021-2029 Housing Element Update
Respuestas a la Encuesta – Ubicación de las
Viviendas

0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0%
Cerca de los centros comerciales de la región
Dentro y al rededor del centro
En corredores principales (tales como la Avenida Bloomington, el Boulevard Foothil, la Avenida Riverside, o la Avenida Baseline Cerca de las instalaciones públicas
En vecindarios existentes (Más ADUs (Casas Accesorias), duplexes, triplexes, y otros tipos de vivienda similares
Cerca de los Transportes Públicos
Otras
Ubicaciones para Desarrollos de Más de 3 Pisos y de Uso Mixto Locations for Mixed-Use Housing Locations for Multi-Family Developments Over 3-Stories )
)
15 16
9 Análisis del Inventario de
Sitios y Estrategia Potencial
City of Rialto – 2021-2029 Housing Element Update
Paso 1: ¿Cuál es nuestra capacidad actual para el
desarrollo residencial?
Ingresos Bajos
y Muy Bajos
Ingresos
Moderados y
Superiores a los
Moderados
Proyectos en proceso 0 0
Parcelas desocupadas divididas en
zonas residenciales
289 11,789
Parcelas residenciales no desocupadas 228 5,265
Unidades de Viviendas Accesorias 72 53
CAPACIDAD EXISTENTE TOTAL 589 17,107
Distribución de RHNA 3,415 4,837
Excedente/Déficit -2,826 12,270
17 18
10 City of Rialto – 2021-2029 Housing Element Update
• Criterio para la identificación de Sitios:
• Sitios vacantes
• Parcelas con baja utilización
• Sitios residenciales existentes con capacidad
para un desarrollo de mayor densidad
• Sitios propiedad de la ciudad
• Sitios no residenciales existentes con
capacidad para su rezonificación para uso
residencial
• Sitios evaluados para determinar si
existe una probabilidad realista de volver
a desarrollarlos para uso residencial
dentro del período de planificación
Paso 2: ¿Qué sitios podrían usarse para
compensar el déficit de RHNA?
City of Rialto – 2021-2029 Housing Element Update
Ejemplos de Densidad– 20-36 Unidades/Acre
Más GrandesApartmentos/ Condos Casas Adosadas/Apartamentos Crédito de la Fotografía: KTGY
Architecture
30 unidades/ac 36 unidades/ac (Asequible)
Uso Mixto
30 unidades/ac
19 20
11 City of Rialto – 2021-2029 Housing Element Update
Mission Meridian Village South Pasadena, California
Crédito de la Fotografía : Moule & Polyzoides
67 condominios en un Desarrollo de uso mixto orientado al tránsito – 40 unidades/acre City of Rialto – 2021-2029 Housing Element Update
Áreas de
Oportunidad 2
1 4 3
5 21
22 12
City of Rialto – 2021-2029 Housing Element Update
Área de Oportunidad 1 – Foothill Boulevard
• Enmienda al Plan Específico de Foothill Boulevard
• Permite 30 unidades de vivienda por acre en proyectos de todos los tamaños
City of Rialto – 2021-2029 Housing Element Update
Área de Oportunidad 2 – North Riverside Ave
• Enmienda al Código de
Zonificación
• Zona Commercial del
Vecindario C-1 y Zona
Administrativa-ProfesionalInstitucional A-P a la Zona
Multifamiliar de Alta Densidad
R-4
23 24
13 City of Rialto – 2021-2029 Housing Element Update
Área de Oportunidad 3 y 4 – Plan Específico de
Gateway
• Enmienda al Plan
Específico de Gateway
• Establecer una nueva
categoría de uso del
terreno y estándares de
desarrollo para los lotes
actualmente identificados
como Comercial
Minorista, Centro de
Oficinas y Centro
Industrial.

City of Rialto – 2021-2029 Housing Element Update
Área de Oportunidad 5 – Área Central
• Enmienda al Plan
Específico del Área
Central
• Cambiar las parcelas que
son Principalmente
Comerciales, los
Servicios de Oficina, las
Instalaciones de Apoyo y
la Cabaña Comercial a
las de tipo Residencial de
Mayor Densidad
25 26
14 Oportunidad para Comentarios
City of Rialto – 2021-2029 Housing Element Update
Comentarios de la Comunidad – Mapa Interactivo
• El mapa interactivo
permite a los
participantes:
• Recomendar ubicaciones
para posibles futuros
desarrollos de viviendas
• Ver áreas de oportunidad
• Disponible en la página
web de la Actualización
del Elemento de
Vivienda:
www.yourrialto.com/HouseOurRialto
27 28
15 City of Rialto – 2021-2029 Housing Element Update
Mapa Interactivo
Borrador de Políticas y
Programas
29 30
16 City of Rialto – 2021-2029 Housing Element Update
Metas Propuestas para la Política de Vivienda
• Las acciones para la política de vivienda del 5to Ciclo de 2014- 2021 que actualmente funcionan bien, continúan para el 6to Ciclo 2021-2029
• Se agregaron nuevas acciones de política para acomodar nuevas disposiciones de la ley estatal
• Se han agregado acciones de política adicionales basadas en el análisis de vivienda justa
City of Rialto – 2021-2029 Housing Element Update
Metas de Vivienda Existentes
• Objetivo 1: Mantener y mejorar la calidad de las viviendas y los vecindarios existentes en Rialto
• Objetivo 2: Promover y fomentar el desarrollo habitacional que satisfaga adecuadamente las necesidades de todos los segmentos
socioeconómicos de la comunidad y la región
• Objetivo 3: Maximizar el uso de los recursos financieros disponibles y buscar métodos creativos e ingeniosos para reducir el costo total de la vivienda
• Objetivo 4: Aliviar las posibles limitaciones gubernamentales a la producción y asequibilidad de la vivienda
• Objetivo 5: Promover la igualdad de oportunidades para que todos los residentes residan en la vivienda de su elección.
31 32
17 City of Rialto – 2021-2029 Housing Element Update
Ejemplo de una Política de Vivienda
Programa 5.4A - Bonificación por Densidad
Para facilitar el desarrollo, la ciudad ofrece a los desarrolladores la oportunidad de aprovechar el Programa de Bonificación por Densidad, que es un aumento de densidad del 35 por ciento más los incentivos de desarrollo para proyectos asequibles calificados. La ciudad proporcionará información sobre el Programa de Densidad en las oficinas del concejo de la ciudad y en el sitio web de la ciudad.

La ciudad actualizará su ordenanza de bonificación por densidad para cumplir con la ley estatal actual.

Plazo: En curso, 2014-2021; Proporcionar una actualización anual sobre el progreso de la Ordenanza de Bonificación de densidad como parte de la revisión y documentación del Informe anual de la ciudad.

Agencia Responsable: División de Planificación
Fuentes de Financiación: Fondo General
Próximos Pasos
33 34
18 City of Rialto – 2021-2029 Housing Element Update
Próximos Pasos
Taller #2
Finalizar las
Restricciones de
Vivienda, los
Recursos, el
Análisis de los
Sitios y el Plan de
Vivienda
Publicar el
Elemento de
Vivienda
Preliminar de
Revisión Pública
Revisar los
Comentarios del
Público
Revisión del HCD
del Borrador del
Elemento de
Vivienda
Adopción Local
del Elemento de
Vivienda
City of Rialto – 2021-2029 Housing Element Update
¡Gracias!
Si tiene preguntas o comentarios, por favor comuníquese con:

Siri Champion, Gerente del Proyecto
Correo Electrónico: [email protected]
Teléfono: (909) 820-8072
Para proporcionar sus comentarios en el mapa interactivo o para más información, visite el sitio web de La Actualización del Elemento de Vivienda: www.yourrialto.com/HouseOurRialto
35 36
2021-2029 City of Rialto Housing Element – Appendix C: Summary of Community Engagement C-14 C.8 Stakeholder Meeting
This section contains all available materials created for the virtual stakeholder meeting, including the presentation and the Zoom chat.

The City of Rialto has recently released the Public Review Draft of the 2021-2029 Housing Element. The Draft Housing Element includes the strategies the City will undertake to meet the RHNA allocation, the policies and programs that will implement these strategies, as well as background analysis on the City of Rialto.

The City is requesting stakeholder feedback on the Draft document. Please join us and fellow community experts for a virtual meeting to discuss the different parts of the Draft Housing Element and provide feedback.

WHEN: September 15, 2021, 3-4 p.m.

WHERE: Zoom (kimley-horn.zoom.us/j/96589096839)
WEBSITE: www.yourrialto.com/HouseOurRialto
Please visit the Housing Element Update website to view the Public Review Draft and learn more about the update process.

For questions, please contact Siri Champion, Project Planner at [email protected] or (909) 820-8072

PLAN TO HOUSE OUR RIALTO
City of Rialto 6th Cycle Housing Element Update
Stakeholder Meeting
La Ciudad de Rialto ha publicado recientemente el plan preliminario de Revisión Pública del Elemento de Vivienda 2021-2029. El plan preliminario del Elemento de Vivienda incluye las estrategias que la ciudad emprenderá para cumplir con la distribución de RHNA, las políticas y programas que implementarán estas estrategias, así como el análisis de antecedentes sobre la ciudad de Rialto.

La Ciudad está solicitando comentarios de las partes interesadas acerca del plan preliminario del documento. Por favor únase a nosotros y a otros expertos de la comunidad en una reunión virtual para discutir las diferentes partes del Proyecto de Elemento de Vivienda y para proporcionar sus comentarios.

FECHA: 15 de septiembre de 2021, 3-4 p.m.

LUGAR: Zoom (kimley-horn.zoom.us/j/96589096839)
SITIO WEB: www.yourrialto.com/HouseOurRialto
Por favor visite el sitio web de la Actualización del Elemento de Vivienda para ver el plan preliminario de la Revisión Pública y obtener más información acerca del proceso de actualización.

Si tiene preguntas, por favor comuníquese con Siri Champion, Planificadora del Proyecto en [email protected] o (909) 820-8072.

PLAN DE VIVENDAS EN NUESTRO RIALTO
6o Ciclo de la Actualización del Elemento de Vivienda
Reunión de Partes Interesadas
1 Plan to House Our Rialto:
2021-2029 Housing Element Update
Stakeholder Workshop
City of Rialto – 2021-2029 Housing Element Update
Agenda
• Housing Element Update Background
• Community Engagement
• Candidate Housing Sites and Strategy
• Goals, Policies, and Programs
• Next Steps
1 2
2 Housing Element Update
City of Rialto – 2021-2029 Housing Element Update
Housing Element Background
• Required element of the
City’s General Plan
• Requires adoption by the
State Department of
Housing and Community
Development (HCD)
• Updated on 8-year cycles
• Statutory Deadline: October 15, 2021
Income
Category
% of Area
Median Income
(AMI)
Income Range1 RHNA Allocation
(Housing Units)
Minimum Maximum
Very Low Income 0 - 50% AMI -- $38,750 2,218 units
Low Income 51 – 80% AMI $38,751 $62,000 1,206 units
Moderate Income 81 – 120% AMI $62,001 $93,000 1,371 units Above Moderate
Income >120% AMI $93,001 -- 3,477 units
TOTAL: 8,272 units

1. Income range is based on the 2021 HUD Area Median Income (AMI) for San Bernardino County of $77,500 for a family of 4. 3 4
3 City of Rialto – 2021-2029 Housing Element Update
New Legislation for Housing Elements
• Funding Measures:
• SB 2
• SB 3
• Streamlining Measures:
• SB 35
• SB 540
• AB 73
• AB 2753
• SB 765
• SB 330
• AB 1485
• SB 744
• Accountability Measures:
• AB 167
• AB 678
• AB 1515
• ADU Measures:
• AB 68
• AB 881
• SB 13
• AB 587
• AB 670
• AB 671
• Other Measures:
• AB 1505
• AB 879
• AB 1397
• AB 72
• AB 2372
• SB 1227
• AB 2797
• AB 3194
• SB 765
• And more
City of Rialto – 2021-2029 Housing Element Update
Affirmatively Furthering Fair Housing (AFFH)
• Fair and equitable distribution of housing
throughout the community
• Protects against communities being
overburdened
• Takes into consideration:
• A variety of housing types (single-family house,
apartment, townhome, etc.)
• Mix of affordability levels
• Access to transportation and employment
• Considers access to public transit and
community resources
5 6
4 City of Rialto – 2021-2029 Housing Element Update
Housing Element Components
• Section 1 - Introduction
• Section 2 - Population and housing profile
• Section 3 - Evaluation of housing constraints and resources • Section 4 - Policies, programs, and quantified objectives to achieve the City’s identified housing goals
• Appendix A - Evaluation of current programs and policies • Appendix B - Analysis and identification of sites to
accommodate the City’s RHNA allocation
• Appendix C - Summary of Community Outreach
• Appendix D - Glossary of Housing Terms
Community Engagement
7 8
5 City of Rialto – 2021-2029 Housing Element Update
Summary of Outreach Efforts
• Completed Outreach:
• Virtual community workshop #1 - May 19th, 2021
• Virtual community workshop #2 - July 15th, 2021
• Spanish-speaking workshop – July 17th, 2021
• Self-Guided Workshop - in person and online
• Informational postcards sent to the community
• Community surveys – in person and online
• Interactive Map
• Public comments at City Council and Planning Commission meetings • Spanish translations provided
• Online advertising on social media and the City’s website Candidate Housing Sites and
Strategy
9 10
6 City of Rialto – 2021-2029 Housing Element Update
Sites Analysis
• Projects “In-the-Pipeline”
• Projected ADU development
• 5th Cycle sites
• Existing capacity in entitled Specific Plan (Lytle Creek Ranch and Renaissance)
• Capacity under existing zoning in identified Opportunity Areas Very Low
Income Low
Income Moderate Income Above Moderate
Income Total RHNA (2021-2029) 2,218 1,206 1,371 3,477 8,272 City of Rialto – 2021-2029 Housing Element Update
Opportunity Areas
• 6 areas identified for upzone/rezone
• 1 – Foothill Blvd. Specific Plan
• 2 – North Riverside Ave.
• 3 – Gateway Specific Plan
• 4 – Rialto Central Area Specific Plan
• 5 – Baseline Parcels
• 6 – Baseline Shopping Center
• Default density for lower-income
housing: 30 dwelling units/acre
11 12
7 City of Rialto – 2021-2029 Housing Element Update
1 - Foothill Blvd. Specific Plan
Opportunity Area 1 - Foothill Boulevard Specific Plan Analysis Feasible
Acreage
Assumed
Density
Capacity of Sites
Low/Very Low Moderate Above
Moderate Total
162 acres 35 du/acre 3,096 284 2,242 5,622
City of Rialto – 2021-2029 Housing Element Update
2 – North Riverside Ave
Opportunity Area 2 – North Riverside Avenue Analysis
Feasible
Acreage
Assumed
Density
Capacity of Sites
Low/Very Low Moderate Above
Moderate Total
17 acres 39 du/acre 220 19 160 399
13 14
8 City of Rialto – 2021-2029 Housing Element Update
3 – Gateway Specific Plan
Opportunity Area 3 – Gateway Specific Plan Analysis
Feasible
Acreage
Assumed
Density
Capacity of Sites
Low/Very Low Moderate Above
Moderate Total
38 acres 35 du/acre 734 67 531 1,332
City of Rialto – 2021-2029 Housing Element Update
4 – Rialto Central Area Specific Plan
Opportunity Area 4 – Rialto Central Area Specific Plan Analysis Feasible
Acreage
Assumed
Density
Capacity of Sites
Low/Very Low Moderate Above
Moderate Total
14 acres 38 du/acre 255 11 204 470
15 16
9 City of Rialto – 2021-2029 Housing Element Update
5 – Baseline Parcels
Opportunity Area 5 – Baseline Parcels Analysis
Feasible
Acreage
Assumed
Density
Capacity of Sites
Low/Very Low Moderate Above
Moderate Total
9 acres 35 du/acre 112 8 84 204
City of Rialto – 2021-2029 Housing Element Update
6 – Baseline Shopping Center
Opportunity Area 6 – Baseline Shopping Center Analysis
Feasible
Acreage
Assumed
Density
Capacity of Sites
Low/Very Low Moderate Above
Moderate Total
57 acres 30 du/acre 466 44 336 846
17 18
10 City of Rialto – 2021-2029 Housing Element Update
Sites Buffer
• Sites strategy considers future developments may be at lower densities than permitted
• Future development may be at different affordability levels than assumed
• Avoids “no-net loss” implications
Very Low
Income Low Income Moderate Income Above Moderate
Income Total RHNA (2021-2029) 2,218 1,206 1,371 3,477 8,272 Total Potential Development Capacity 4,957 1,505 10,520 16,982 Sites Surplus/Shortfall
(%) 45% 10% 203% 105%
Sites Surplus/Shortfall
(#) 1,533 134 7,043 8,710
Goals, Policies, and Programs
19 20
11 City of Rialto – 2021-2029 Housing Element Update
Housing Element Goals
• Housing Goal #1: Maintain and improve the quality of existing housing and neighborhoods in Rialto. • Housing Goal #2: Promote and encourage housing development that adequately meets the needs of all socioeconomic segments of the community and region. • Housing Goal #3: Maximize the use of available financial resources and pursue creative and resourceful methods to reduce the overall cost of housing. • Housing Goal #4: Alleviate potential governmental constraints to housing production and affordability. • Housing Goal #5: Promote equal opportunity for all residents to reside in the housing of their choice.

City of Rialto – 2021-2029 Housing Element Update
Policy Program – ADU Monitoring
Housing Program 2C: Accessory Dwelling Unit Monitoring Program • The City will establish an ADU Monitoring Program during the 2021-2029 Housing Element Planning Period to formally track ADU development. The analysis will track applications for ADUs, location, and other important features.

The intent of the Monitoring Program is to track progress in meeting 2021-2029 ADU construction goals and to evaluate the need to adjust programs and policies if the pace of construction is less than anticipated.

Timeframe: Annually, 2021-2029
Responsible Agency: Planning Division
Funding Sources: General Fund
21 22
12 City of Rialto – 2021-2029 Housing Element Update
Sample Policy Programs
• Promotion of Accessory Dwelling Unit (ADU)
and Junior Accessory Dwelling Unit (JADU)
Development
• Objective Development Standards
• SB 35 Streamlining
• Emergency Shelters, Transitional and
Supportive Housing, and Lower Barrier
Navigation Centers
• Housing for Persons with Developmental
Disabilities
City of Rialto – 2021-2029 Housing Element Update
Sample Policy Programs
• Farmworker Housing
• Funding and Rental Assistance Programs
• Preserve and Monitor At-Risk Units
• Mobile Home Park Preservation
• Housing Voucher Program
• Density Bonus
• Remove Development Constraints
• Fair Housing
23 24
13 Next Steps
City of Rialto – 2021-2029 Housing Element Update
Next Steps
Send Housing
Element to HCD
for first review
Adopt the
Housing Element
Locally
• Removes Mid-Cycle
Review requirement
Review potential
comments/edits
from HCD and resubmit final
document
Adopt locally an
amendment with
the corrections
from HCD
25 26
14 City of Rialto – 2021-2029 Housing Element Update
Thank You!
Questions?
Please contact:

Siri Champion, Project Manager
Email: [email protected]
Phone: (909) 820-8072
For more information, please visit the City’s Housing Element Update webpage: www.yourrialto.com/HouseOurRialto
27 file:///kimley-horn.com/...ment/Community%20Outreach/Stakeholder%20Meeting/Recordings/GMT20210915-220422_Recording%20(1).txt[9/28/2021 9:26:57 AM] 01:08:54 Pablo Ramirez: Thank you. I have another meeting, but i will send Siri my questions. 01:13:24 Maria Delgado: I also noticed that in the AFFH section the city’s analysis is focused at a local level.

Under the new AFFH requirement, the city must also analyze components at a regional level. 01:13:59 Ines Galmiche: Thank you Maria for your comment, we've taken note of it. 01:14:16 Maria Delgado: Thank you!
01:14:23 Jeff Green Inland Equity Community Land Trust:Thank you 2021-2029 City of Rialto Housing Element – Appendix C: Summary of Community Engagement C-15 C.9 Planning Commission Public Hearing
This section contains all materials available for the September 29, 2021, Planning Commission Public Hearing. A recording of the hearing is available on the City’s website.

Planning Commission
City of Rialto
Regular Meeting - Final
Wednesday, September 29, 2021 6:00 PM
Public Participation Procedure

NOTICE IS GIVEN THAT THE CITY COUNCIL OF THE CITY OF RIALTO HAS DECLARED A LOCAL EMERGENCY RELATED TO COVID-19, AND IN COMPLIANCE WITH SOCIAL DISTANCING PROTOCOLS REQUIRED BY GOVERNOR NEWSOM’S EXECUTIVE ORDER N-29-20 AND THE STATE DEPARTMENT OF PUBLIC HEALTH, THE COUNCIL CHAMBERS WILL BE OPEN TO THE PUBLIC WITH LIMITED SEATING INSIDE. THE PUBLIC WILL HAVE AN OPPORTUNITY TO SPEAK ON ANY ITEM USING THE PODIUM INSIDE THE COUNCIL CHAMBERS.

IF YOU ARE UNABLE TO ATTEND THE MEETING, YOU MAY SUBMIT COMMENTS ON ANY AGENDA ITEM AT LEAST TWO (2) HOURS BEFORE THE MEETING TIME, AS FOLLOWS:
- IN WRITING VIA MAIL TO: CITY OF RIALTO “ATTN: PLANNING COMMISSION, C/O COMMUNITY DEVELOPMENT,” 150 S PALM AVE, RIALTO, CA 92376; OR
- BY EMAIL TO [email protected].

Call To Order
Pledge of Allegiance
Roll Call
Chair Frank Gonzalez, Vice-Chair Jerry Gutierrez, John Peukert, Artist Gilbert, Al Twine, Dale Estvander, BarBara Chavez
Oral Communications from the Audience on items not on the Agenda Planning Commission Minutes
PC-21-0666
Minutes from the July 14, 2021 Special Workshop meeting.

Attachments: PC Minutes 7-14-2021 Special Workshop Meeting.docx

Page 1 ends

Planning Commission Regular Meeting - Final September 29, 2021 PC-21-0671
Minutes from the July 28, 2021 Planning Commission meeting.

Attachments: PC Minutes 7-28-2021.docx
Public Hearings
PC-21-0670 Conditional Development Permit No. 2021-0033: A request to allow the establishment and operation of an undergraduate college within approximately 11,000 square feet of an existing church development located 2759 North Ayala Drive (APNs: 1133-361-01) within the Single Family Residential (R-1A 10,000) zone. This project is categorically exempt from the California Environmental Quality Act (CEQA) pursuant to Section 15301 (Existing Facilities Projects) of the State CEQA Guidelines (Environmental Assessment Review No. 2021-0036).

EXHIBIT A - Location Map
EXHIBIT B - Project Site
EXHIBIT C - Floor Layout
EXHIBIT D - Draft Resolution
Attachments:

Presentation
PC-21-0677 Request the Planning Commission receive and file a status update on the Draft 6th Cycle Housing Element Update 2021-2029
Attachment 1 - Draft 6th Cycle Housing Element Update.pdf Attachment 2 - Letter to Property Owners.pdf
Attachment 3 - Property Owner Responses.pdf
Attachment 4 - Comment Letter.pdf
Attachments:

Planning Division Comments
PC-21-0672
Planning Commission - Miscellaneous Items Tracking Report Attachments: PC Misc. Items Tracking Report - 9-29-2021 Commissioner Reports

Page 2 ends

Planning Commission Regular Meeting - Final September 29, 2021 Adjournment

Page 3 ends

2021-2029 City of Rialto Housing Element – Appendix C: Summary of Community Engagement C-16 C.10 City Council Public Hearing
This section contains all materials available for the October 12, 2021, City Council Public Hearing. A recording of the hearing is available on the City’s website. 2021-2029 City of Rialto Housing Element – Appendix C: Summary of Community Engagement C-17 C.11 Additional Public Comments
This section contains all additional public comments received by the City during the 2021-2029 Housing Element Update process. Comments received through surveys, workshops, and meetings are included in the previous sections.

City of Rialto
California
150 South Palm Avenue ● Rialto, California 92376
August 13, 2021
<<Mailing Address>>
RE: RIALTO HOUSING ELEMENT UPDATE – HOUSING OPPORTUNITY SITES Dear Property Owner:

The City of Rialto is in the process of updating the General Plan Housing Element for the 2021-2029 planning period. Under State mandate, all cities are required to plan for future housing need, including affordable housing. As part of this update, the City will identify potential sites that might accommodate more residential development in the future. It is important to understand, the Housing Element will not affect property rights or change what is currently allowed on your property; it will only identify your property as having the potential to accommodate residential development should you or a future property owner want to pursue such development – entirely at your choice.

We have identified your property at <<Site Address>> as a potential “Opportunity Site” for future residential development. This will not change the existing land use or your current property rights. More importantly, being identified as a potential “Opportunity Site” does not indicate that the City is considering the acquisition of your property for construction of new housing. The City through the Housing Element Update process is not acquiring any property. The Housing Element Update will only identify potential sites where residential development might occur in the future. As property owner, you will retain your right to choose what to do with your property and identifying your property for potential housing development will not mandate or require you or future owners to do or change anything.

The purpose of this letter is to provide you the opportunity to review and comment on the City’s public draft 2021-2029 Housing Element Update and the identification of your property as a potential “Opportunity Site.” We are very interested to hear from you. Please contact me via email, phone, or letter at:

Siri Champion, Senior Planner
City of Rialto
150 S Palm Avenue
Rialto, CA 92376
[email protected]
909-820-8072
We hope to hear from you by September 13. Please contact us at your earliest convenience. To view the public draft “Plan to House Our Rialto: 2021-2029 Housing Element Update”, please visit www.yourrialto.com/HouseOurRialto.

Thank you for your time and attention to this matter.

Respectfully,
Siri A. Champion, Senior Planner
From: julies418 <[email protected]>
Sent: Tuesday, August 17, 2021 9:40 AM
To: Siri Champion <[email protected]>
Subject: RE: 230 S Orange
We are open to selling 230 s orange to the city for future development.

Thank you
Julie Salazar
From: jose vindel <[email protected]>
Sent: Thursday, August 26, 2021 11:03 AM
To: Siri Champion <[email protected]>
Subject: Responding to your letter: Rialto Methodist Church as potential "Opportunity Site" for future residential development
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

Dear Siri
Thank you for your letter identifying Rialto United Methodist Church at 1230 N. Lilac Ave as a potential "Opportunity Site" for future development. When the time comes, and if considered by the city, Rialto UMC is willing enter in conversation regarding this matter.

Thank you very much for you letter
Rev. Jose Vindel
Pastor, Rialto UMC
From: Jared Sopko <[email protected]>
Sent: Friday, September 17, 2021 1:43 PM
To: Siri Champion <[email protected]>
Subject: Housing Opportunity Site: APN 012725114
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

Dear Ms. Champion,
Thank you for your outreach and interest in including our site, APN: 012725114, into the Housing Opportunity Sites. We are interested in the offer to add our parcel to consideration for an eventual overlay zone that would allow residential development.

Please contact me should you need any additional information.

Regards,
Jared Sopko
Project Manager,
Cloverfield Management, LLC,
Manager for Allied Farms, Inc.
--
Jared Sopko, LEED AP
[email protected]
O: (424) 214-2164
1 Galmiche, Ines
From: Siri Champion <[email protected]>
Sent: Thursday, October 7, 2021 4:19 PM
To: Galmiche, Ines
Cc: Barquist, Dave
Subject: FW: Rialto Parcels
Categories: External
Hi Ines,
Please find William Lee’s request to include his parcels below.

Thanks,
Siri
Siri A. Champion
Community Development – Planning Division

CITY OF RIALTO
150 S. Palm Avenue, Rialto, CA 92376
Office: 909-820-8072 | Email: [email protected] | Website: www.yourrialto.com From: William Lee <[email protected]>
Sent: Thursday, October 7, 2021 4:17 PM
To: Siri Champion <[email protected]>
Subject: Re: Rialto Parcels
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

Siri, appreciate the prompt response. Yes please include our properties on the opportunity area list. The 6 APNs are below:
0132-021-03
0132-021-12
0132-021-13
0132-021-14
0132-021-15
0132-021-04
Thank you,
William Lee
(626) 922-7799
On Thu, Oct 7, 2021 at 3:27 PM Siri Champion <[email protected]> wrote:
2 Hi William,
Inclusion in the housing element as an opportunity area does not change the zoning. If your properties are included, they will be considered for a rezone in the future. That rezone could, but would not necessarily, establish a minimum density. If your properties are not included, you still have the opportunity as the property owner to request a zone change in the future. If you’d like to be included, we need something from you in writing by tomorrow.

Many thanks,
Siri

Siri A. Champion
Community Development – Planning Division

CITY OF RIALTO
150 S. Palm Avenue, Rialto, CA 92376
Office: 909-820-8072 | Email: [email protected] | Website: www.yourrialto.com

From: William Lee <[email protected]>
Sent: Thursday, October 7, 2021 3:20 PM
To: Siri Champion <[email protected]>
Subject: Re: Rialto Parcels

CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

Hi Siri,
Thanks for following up. I've been reading your Draft Housing Element Update and doing some research. I've been trying to understand if being included in these potential changes means that future development MUST meet a minimum density? For example, if the zoning is changed to R4, and in the future we wanted to do something in the 12-21 DU/acre range, is that still allowed? Or does any new development have to be at 3 least in the 30DU/acre range? Any further info you can give me would be greatly appreciated.

Also, is there a deadline you need this request by?
Thanks,
William Lee
(626) 922-7799

On Wed, Oct 6, 2021 at 9:30 PM Siri Champion <[email protected]> wrote:

Hi William,
I am writing in regards to the six parcels you own in Rialto south of Randall Avenue and between Lilac Ave and S.

Millard Avenue. We corresponded about them previously and discussed the Housing Element Update. Do you want those properties incorporated in the Housing Element as an opportunity area for increased density residential? If so, would you please prepare an email that lists the parcels and requesting that they be included? Many thanks,
Siri

Siri A. Champion
Community Development – Planning Division

CITY OF RIALTO
150 S. Palm Avenue, Rialto, CA 92376
Office: 909-820-8072 | Email: [email protected] | Website: www.yourrialto.com C U S T O M E R C A R E | S A M E D A Y R E S P O N S E Real Estate Development, Acquisition and Management
17 Corporate Plaza Drive, Suite 250, Newport Beach CA, 92660 | t. 949.566.8021 | [email protected] September 21, 2021
Ms. Siri Champion
Senior Planner
Community Development Department
City of Rialto
150 S. Palm Avenue, Rialto, CA 92376
Re: Housing Element Update, Gateway Specific Plan Amendment, Site Inventory #122-123 Dear Ms. Champion:

We are an established Southern California real estate development firm that is under contract to acquire and develop the two properties consisting of 18 +/- acres on the Southeast corner of South Riverside Avenue and East San Bernardino Avenue (APNs 0132-092-01 & 0132-252-01) in South Rialto (the “Property”). It has come to our attention that the City is in the process of updating the Housing Element of its General Plan, which will ultimately result in changes in policy as well as amendments to both the City’s General Plan and the Gateway Specific Plan (which applies to our Property). We appreciate the opportunity to review and comment on the proposed Housing Element Update.

To begin, we appreciate and support the City’s interest in allowing the development of residential on the Property. Housing demand is at historic levels, and providing developers the ability to develop more housing for the City’s constituents is essential to meet such demands and combat the rising costs of home ownership and rental. It also happens to be a good use for a substantial portion of our Property.

Retail is the best and highest use for the part closest to Riverside Avenue, but neither retail nor office are economically viable uses for the rear or East portion of the Property. Residential would be a good fit behind the retail since it is surrounded by other residential and in close proximity to freeway access and regional retail and services. As a result, we are currently in the process of preparing plans to submit to the City for the development of retail on the portion of the Property adjacent to Riverside Avenue and residential for the balance of the Property.

We are writing this letter, however, because we are deeply concerned about the City’s proposed identification of our Property as a suitable site for high-density and affordable housing in the General Plan’s Housing Element Update. High density and affordable housing in this South Rialto submarket – and in particular on this Property – are not economically feasible now or in the forseeable future. The construction costs for this type of product require a rent structure or sale price that is not achievable in this submarket. Further, projects of this size and type typically require structured debt financing, and such financing is almost uniformly not available for this type of product in the Inland Empire (exceptions being premium rent / sale price locations such as TOD sites and affluent denser areas like in Rancho Cucamonga). Enclosed for your consideration is a letter from Land Advisors – residential brokers with 17 Corporate Plaza Drive, Suite 250, Newport Beach CA, 92660 | t. 949.566.8021 | [email protected] Real Estate Development, Acquisition and Management
extensive experience in the IE residential market – in support of our view that such residential product type is not feasible in this submarket and won’t be in the forseeable future.

This is especially true for our Property. In addition to general market challenges, our Property will be more costly to develop because of mitigation costs associated with the federally-protected endangered species, the Delhi Flower-Loving Sand Fly (the “Sand Fly”). Habitat assessments have identified significant suitable Sand Fly habitat on the Property. As such, we will have to purchase sufficient Sand Fly conservation land elsewhere to mitigate the displacement of Sand Fly habitat on our Property in order to develop it. Our environmental consultant is in the process of working with the US Fish and Wildlife to determine the full extent and cost of such mitigation, but the range of such mitigation costs based on current mitigation agreements with surrounding landowners are all in the several millions of dollars. This additional financial burden to develop our Property makes it one of the least likely locations in this submarket for a high density / affordable housing project. In fact, based on the above and our/Land Advisor’s experience and market analysis, the only economically viable residential development that can be pursued at this location is a market rate one with a density of 8 and 16 units per acre. Higher densities make a residential development here uneconomic and therefore infeasible.

And without the residential development, the retail component of the development will also not be viable.

For the reasons stated above, we strongly encourage the City to reconsider its identification of the Property for high density and affordable housing in the Housing Element Update and plan amendments.

Such designation may satisfy paper mandates from the State, but it is simply not realistic. More importantly, it might complicate the City’s ability to approve our mixed use project with an economically viable residential component (especially in light of the recently passed laws, including SB-8 (https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220SB8)). At the very least, we urge the City to remove any reference to a potential minimum density on our Property, even if it’s not binding, and allow for lower densities between 8-16 du/ac. This would allow the City to comply with the State’s RHNA requirements without unnecessarily complicating the City’s policies and its ability to maintain local control and flexibility in determining whether to approve our forthcoming plan amendments and project application. By doing the above, the City avoids the potential for misuse and abuse of the State law’s “consistency” requirement as a tool to frustrate the City’s efforts to address the immediate need of housing and additional retail/services for its constituents.

Thank you for your consideration of our concerns and comments. Please don’t hesitate to contact us if you would like to discuss this further or need any additional information.

Best Regards,
Chris Costanzo
Managing Member
September 21, 2021
Siri Champion
Senior Planner
Community Development Department
City of Rialto
150 South Palm Avenue
Rialto, CA  92376
RE: Housing Element Update, Gateway Specific Plan, Site Inventory #122‐123 Assessor’s Parcel Numbers: 0132‐092‐01, 0132‐252‐01
Dear Ms. Siri,
We are residential land brokers with approximately 40 years of experience focused exclusively on the Inland Empire. We are currently engaged by the County of San Bernardino as consultants to assist in its sale of 2,900 units in Rancho Cucamonga. This week, we hosted the auction and sale of more than 1,600 acres in the City of Highland on behalf of the County of Orange. And, last year, we managed the sale of 328 units in the City of Loma Linda on behalf of its Success Agency. We are intimately familiar with the goals proposed by the Regional Housing Needs Allocation (RHNA) and the municipalities needs to update their Housing Elements accordingly.

We received notification that the above‐referenced parcels (“Subject Property”) have been identified as an opportunity area within the Housing Element Update currently in process by the City of Rialto. It is our understanding the Housing Element Update plans an amendment to the Gateway Specific Plan to add a new residential zoning district to facilitate high‐density residential development. This new residential zone would assume an average density for the Subject Property of 35 dwelling units per acre — yielding an estimated 635 units on approximately 18 acres.

The proposed density does not fit with current or anticipated market conditions. In the last five years, there have been zero new residential developments to achieve the proposed density. There has been only one community with a density over 20 dwelling units per acre. Built in December 2017, Santa Barbara Luxury Apartments, located at 606 South Riverside Avenue, yields a density of approximately 22 dwelling units per acre. Otherwise, all recent and anticipated new home development in this submarket has consisted of conventional single‐family residences or attached townhomes with densities less than 12 dwelling units per acre. Higher density product at the Subject Property is unachievable because base home pricing does not support its development, nor do we see any prospect of this changing in the near or forseeable future.

We understand and support the City’s need to meet its RHNA goals. We recommend the City propose a density for the Subject Property ranging from 8 to 16 dwelling units per acre. Any density above 16 dwelling units per acre will result in attached three‐story product, which is not financially feasible for the Subject Property in the current market. If the City proposed a density up to 16 dwelling unit per acre for the Subject Property, then it would generate much needed new housing in the near future.

We want to see new housing built on the Subject Property; however, the proposed density will not achieve that goal. Any high‐density or affordable housing designation will have a substantial negative impact on the Subject Property’s land value. We believe the recommended density (8‐16 du/ac) will better contribute to the fulfillment of the City’s vision as established in the General Plan Update.

We thank you for your time and consideration. We have enclosed a copy of our biographies. Please feel free to contact us with any questions.

Sincerely,
Doug Jorritsma Ian Sinderhoff
Doug Jorritsma           Ian Sinderhoff
Senior Vice President         Vice President
Land Advisors Organization       Land Advisors Organization d. (949) 656‐8004         d. (949) 656‐8005
e. [email protected]    e. [email protected] Enclosed: Land Advisors Organization, West San Bernardino Team Flyer Team Stats

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Mitchell M. Tsai
Attorney At Law
139 South Hudson Avenue
Suite 200
Pasadena, California 91101

VIA E-MAIL
September 7, 2021
Siri Champion
Senior Planner
City of Rialto
150 South Palm Avenue
Rialto, CA 92376
Em: [email protected]
RE: City of Rialto 6th Cycle RHNA Housing Element Update.

Dear Ms. Champion
On behalf of the Southwest Regional Council of Carpenters (“Commenter” or “Carpenter”), my Office is submitting these comments on the City of Rialto’s (“City”) 6th Cycle Draft Housing Element Update (“Project”).

The Southwest Carpenters is a labor union representing more than 50,000 union carpenters in six states and has a strong interest in well ordered land use planning and addressing the environmental impacts of development projects.

Individual members of the Southwest Carpenters live, work and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts.

Commenters expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearings and proceedings related to this Project. Cal. Gov. Code § 65009(b); Cal. Pub. Res. Code § 21177(a); Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121.

Commenters incorporates by reference all comments raising issues regarding the EIR submitted prior to certification of the EIR for the Project. Citizens for Clean Energy v City of Woodland (2014) 225 Cal. App. 4th 173, 191 (finding that any party who has objected City of Rialto – 6th Cycle Housing Element Update
September 7, 2021

Page 2 of 5 ends

to the Project’s environmental documentation may assert any issue timely raised by other parties).

Moreover, Commenter requests that the Lead Agency provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (“CEQA”), Cal Public Resources Code (“PRC”) § 21000 et seq, and the California Planning and Zoning Law (“Planning and Zoning Law”), Cal. Gov’t Code §§ 65000–65010. California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body.

The City should require the use of a local skilled and trained workforce to benefit the community’s economic development and environment. The City should require the use of workers who have graduated from a Joint Labor Management apprenticeship training program approved by the State of California, or have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a state approved apprenticeship training program or who are registered apprentices in an apprenticeship training program approved by the State of California.

Community benefits such as local hire and skilled and trained workforce requirements can also be helpful to reduce environmental impacts and improve the positive economic impact of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing localized economic benefits. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:
[A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling.

City of Rialto – 6th Cycle Housing Element Update
September 7, 2021

Page 3 of 5 ends

Skilled and trained workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the UC Berkeley Center for Labor Research and Education concluded:
. . . labor should be considered an investment rather than a cost – and investments in growing, diversifying, and upskilling California’s workforce can positively affect returns on climate mitigation efforts. In other words, well trained workers are key to delivering emissions reductions and moving California closer to its climate targets.1
Local skilled and trained workforce requirements and policies have significant environmental benefits since they improve an area’s jobs-housing balance, decreasing the amount of and length of job commutes and their associated greenhouse gas emissions. Recently, on May 7, 2021, the South Coast Air Quality Management District found that that the “[u]se of a local state-certified apprenticeship program or a skilled and trained workforce with a local hire component” can result in air pollutant reductions.2
Cities are increasingly adopting local skilled and trained workforce policies and requirements into general plans and municipal codes. For example, the City of Hayward 2040 General Plan requires the City to “promote local hiring . . . to help achieve a more positive jobs-housing balance, and reduce regional commuting, gas consumption, and greenhouse gas emissions.”3
In fact, the City of Hayward has gone as far as to adopt a Skilled Labor Force policy into its Downtown Specific Plan and municipal code, requiring developments in its Downtown area to requiring that the City “[c]ontribute to the stabilization of regional construction markets by spurring applicants of housing and nonresidential 1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https://laborcenter.berkeley.edu/ wp-content/uploads/2020/09/Putting-California-on-the-High-Road.pdf 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http://www.aqmd.gov/docs/defaultsource/Agendas/Governing-Board/2021/2021-May7-027.pdf?sfvrsn=10 3 City of Hayward (2014) Hayward 2040 General Plan Policy Document at p. 3-99, available at https://www.hayward-ca.gov/sites/default/files/documents/General_Plan_FINAL.pdf.

City of Rialto – 6th Cycle Housing Element Update
September 7, 2021

Page 4 of 5 ends

developments to require contractors to utilize apprentices from state-approved, joint labor-management training programs, . . .”4 In addition, the City of Hayward requires all projects 30,000 square feet or larger to “utilize apprentices from state-approved, joint labor-management training programs.”5
Locating jobs closer to residential areas can have significant environmental benefits. As the California Planning Roundtable noted in 2008:

People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.6
In addition, local hire mandates as well as skill training are critical facets of a strategy to reduce vehicle miles traveled. As planning experts Robert Cervero and Michael Duncan noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions since the skill requirements of available local jobs must be matched to those held by local residents.7 Some municipalities have tied local hire and skilled and trained workforce policies to local development permits to address transportation issues. As Cervero and Duncan note:

In nearly built-out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing.” The city’s First Source program encourages businesses to hire local residents, especially for entry- and intermediate-level jobs, and sponsors vocational training to ensure residents are employment-ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When 4 City of Hayward (2019) Hayward Downtown Specific Plan at p. 5-24, available at https://www.hayward-ca.gov/sites/default/files/Hayward%20Downtown% 20Specific%20Plan.pdf. 5 City of Hayward Municipal Code, Chapter 10, § 28.5.3.020(C). 6 California Planning Roundtable (2008) Deconstructing Jobs-Housing Balance at p. 6, available at https://cproundtable.org/static/media/uploads/publications/cpr-jobshousing.pdf 7 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: JobsHousing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT825.pdf.

City of Rialto – 6th Cycle Housing Element Update
September 7, 2021

Page 5 of 5 ends

needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.

The City should consider utilizing skilled and trained workforce policies and requirements to benefit the local area economically and mitigate greenhouse gas, air quality and transportation impacts.

Sincerely,
______________________
Mitchell M. Tsai
Attorneys for Southwest Regional
Council of Carpenters
Attached:

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); and Air Quality and GHG Expert Matt Hagemann CV (Exhibit C).

EXHIBIT A
1 2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
March 8, 2021
Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101
Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling Dear Mr. Tsai,
Soil Water Air Protection Enterprise (“SWAPE”) is pleased to provide the following draft technical report explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of greenhouse gas (“GHG”) emissions. The report will also discuss the potential for local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.

Worker Trips and Greenhouse Gas Calculations
The California Emissions Estimator Model (“CalEEMod”) is a “statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects.”1 CalEEMod quantifies construction-related emissions associated with land use projects resulting from off-road construction equipment; on-road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on-road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving.2
The number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.3 1 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 2 “California Emissions Estimator Model.” CAPCOA, 2017, available at: http://www.aqmd.gov/caleemod/home. 3 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 2 Specifically, the number and length of vehicle trips is utilized to estimate the vehicle miles travelled (“VMT”) associated with construction. Then, utilizing vehicle-class specific EMFAC 2014 emission factors, CalEEMod calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction-related VMT, including personal vehicles for worker commuting.4
Specifically, in order to calculate VMT, CalEEMod multiplies the average daily trip rate by the average overall trip length (see excerpt below):
“VMTd = Σ(Average Daily Trip Rate i * Average Overall Trip Length i) n Where:
n = Number of land uses being modeled.”5
Furthermore, to calculate the on-road emissions associated with worker trips, CalEEMod utilizes the following equation (see excerpt below):
“Emissionspollutant = VMT * EFrunning,pollutant
Where:

Emissionspollutant = emissions from vehicle running for each pollutant VMT = vehicle miles traveled
EFrunning,pollutant = emission factor for running emissions.” 6 Thus, there is a direct relationship between trip length and VMT, as well as a direct relationship between VMT and vehicle running emissions. In other words, when the trip length is increased, the VMT and vehicle running emissions increase as a result. Thus, vehicle running emissions can be reduced by decreasing the average overall trip length, by way of a local hire requirement or otherwise.

Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CalEEMod to calculate emissions associated with the on-road vehicle trips required to transport workers to and from the Project site during construction.7In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CalEEMod default worker trip parameters. CalEEMod provides recommended default values based on site-specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input projectspecific values, but the California Environmental Quality Act (“CEQA”) requires that such changes be justified by substantial evidence.8 The default number of construction-related worker trips is calculated by multiplying the 4 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14-15. 5 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 23. 6 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 7 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 8 CalEEMod User Guide, available at: http://www.caleemod.com/, p. 1, 9. 3 number of pieces of equipment for all phases by 1.25, with the exception of worker trips required for the building construction and architectural coating phases.9Furthermore, the worker trip vehicle class is a 50/25/25 percent mix of light duty autos, light duty truck class 1 and light duty truck class 2, respectively.”10 Finally, the default worker trip length is consistent with the length of the operational home-to-work vehicle trips.11 The operational home-to-work vehicle trip lengths are:
“[B]ased on the location and urbanization selected on the project characteristic screen. These values were supplied by the air districts or use a default average for the state. Each district (or county) also assigns trip lengths for urban and rural settings” (emphasis added). 12 Thus, the default worker trip length is based on the location and urbanization level selected by the User when modeling emissions. The below table shows the CalEEMod default rural and urban worker trip lengths by air basin (see excerpt below and Attachment A).13
Worker Trip Length by Air Basin
Air Basin Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Minimum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
9 “CalEEMod User’s Guide.” CAPCOA, November 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/01_user-39-s-guide2016-3-2_15november2017.pdf?sfvrsn=4, p. 34. 10 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 11 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 14. 12 “Appendix A Calculation Details for CalEEMod.” CAPCOA, October 2017, available at:
http://www.aqmd.gov/docs/default-source/caleemod/02_appendix-a2016-3-2.pdf?sfvrsn=6, p. 21. 13 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-84 – D-86. 4 As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8- to 19.8- miles, with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8- to 14.7- miles, with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban worker trip lengths tend to be shorter in length. Based on these trends evident in the CalEEMod default worker trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent upon the urbanization of the project site, as well as the project location.

Practical Application of a Local Hire Requirement and Associated Impact To provide an example of the potential impact of a local hire provision on construction-related GHG emissions, we estimated the significance of a local hire provision for the Village South Specific Plan (“Project”) located in the City of Claremont (“City”). The Project proposed to construct 1,000 residential units, 100,000-SF of retail space, 45,000-SF of office space, as well as a 50-room hotel, on the 24-acre site. The Project location is classified as Urban and lies within the Los Angeles-South Coast County. As a result, the Project has a default worker trip length of 14.7 miles.14 In an effort to evaluate the potential for a local hire provision to reduce the Project’s construction-related GHG emissions, we prepared an updated model, reducing all worker trip lengths to 10 miles (see Attachment B). Our analysis estimates that if a local hire provision with a 10-mile radius were to be implemented, the GHG emissions associated with Project construction would decrease by approximately 17% (see table below and Attachment C).

Local Hire Provision Net Change
Without Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,623
Amortized Construction GHG Emissions (MT CO2e/year) 120.77 With Local Hire Provision
Total Construction GHG Emissions (MT CO2e) 3,024
Amortized Construction GHG Emissions (MT CO2e/year) 100.80 % Decrease in Construction-related GHG Emissions 17%
As demonstrated above, by implementing a local hire provision requiring 10 mile worker trip lengths, the Project could reduce potential GHG emissions associated with construction worker trips. More broadly, any local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

This serves as an example of the potential impacts of local hire requirements on estimated project-level GHG emissions, though it does not indicate that local hire requirements would result in reduced construction-related GHG emission for all projects. As previously described, the significance of a local hire requirement depends on the worker trip length enforced and the default worker trip length for the project’s urbanization level and location.
14 “Appendix D Default Data Tables.” CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/defaultsource/caleemod/05_appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85. 5 Disclaimer
SWAPE has received limited discovery. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.

Sincerely,
Matt Hagemann, P.G., C.Hg.

Paul E. Rosenfeld, Ph.D.

EXHIBIT B

SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.

Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: [email protected]

Paul E. Rosenfeld, Ph.D. Page 1 of 10 June 2019
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling Principal Environmental Chemist Risk Assessment & Remediation Specialist Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.

M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.

B.A. Environmental Studies, U.C. Santa Barbara, 1991. Thesis on wastewater treatment.

Professional Experience

Dr. Rosenfeld has over 25 years’ experience conducting environmental investigations and risk assessments for evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.

Rosenfeld has evaluated and modeled emissions from unconventional oil drilling operations, oil spills, landfills, boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, and many other industrial and agricultural sources. His project experience ranges from monitoring and modeling of pollution sources to evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities.

Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents, pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, perchlorate, asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance impacts and technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr. Rosenfeld directs air dispersion modeling and exposure assessments. He has served as an expert witness and testified about pollution sources causing nuisance and/or personal injury at dozens of sites and has testified as an expert witness on more than ten cases involving exposure to air contaminants from industrial sources.

Paul E. Rosenfeld, Ph.D. Page 2 of 10 June 2019
Professional History:

Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher) UCLA School of Public Health; 2003 to 2006; Adjunct Professor UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator UCLA Institute of the Environment, 2001-2002; Research Associate Komex H2O Science, 2001 to 2003; Senior Remediation Scientist National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor Anteon Corp., San Diego, 2000-2001; Remediation Project Manager Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager Bechtel, San Diego, California, 1999 – 2000; Risk Assessor King County, Seattle, 1996 – 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist Publications:

Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48 Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C., (2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632.

Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.

Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.

Procedia Environmental Sciences. 113–125.

Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal of Environmental Health. 73(6), 34-46.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.

Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.

Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air Pollution, 123 (17), 319-327.

Paul E. Rosenfeld, Ph.D. Page 3 of 10 June 2019
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.

Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, 70, 000527- 000530.

Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near a Former Wood Treatment Facility. Environmental Research. 105, 194-197.

Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.

Rosenfeld, P. E., M. Suffet. (2007). The Anatomy Of Odour Wheels For Odours Of Drinking Water, Wastewater, Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.

Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food, Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science and Technology. 49(9),171-178.

Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffet (2004). The Value of An Odor-Quality-Wheel Classification Scheme For The Urban Environment. Water Environment Federation’s Technical Exhibition and Conference (WEFTEC) 2004. New Orleans, October 2-6, 2004.

Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated With Compost, Biomass Facilities, and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.

Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science and Technology, 49( 9), 171-178.

Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.

Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management Board Public Affairs Office, Publications Clearinghouse (MS–6), Sacramento, CA Publication #442-02-008.

Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water Soil and Air Pollution. 127(1-4), 173-191.

Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal of Environmental Quality. 29, 1662-1668.

Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affect on biosolids odor emissions and microbial activity. Water Environment Research. 73(4), 363-367.

Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and Biosolids Odorants. Water Environment Research, 73, 388-393.

Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.

Water Environment Research. 131(1-4), 247-262.

Paul E. Rosenfeld, Ph.D. Page 4 of 10 June 2019
Chollack, T. and P. Rosenfeld. (1998). Compost Amendment Handbook For Landscaping. Prepared for and distributed by the City of Redmond, Washington State.

Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).

Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users Network, 7(1).

Rosenfeld, P. E. (1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.

Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters thesis reprinted by the Sierra County Economic Council. Sierra County, California.

Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third World. Bachelors Thesis. University of California.

Presentations:

Rosenfeld, P.E., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American Chemical Society. Lecture conducted from Santa Clara, CA.

Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom-Stack, T.; Sahai, R.K.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water.

Urban Environmental Pollution. Lecture conducted from Boston, MA.

Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom-Stack, T.; Sahai, R.K.; La, M.; Hesse, R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis, Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.

Rosenfeld, P.E. (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS) Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting, Lecture conducted from Tuscon, AZ.

Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United States” Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting. Lecture conducted from Tuscon, AZ.

Wu, C., Tam, L., Clark, J., Rosenfeld, P. (20-22 July, 2009). Dioxin and furan blood lipid concentrations in populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and Management of Air Pollution. Lecture conducted from Tallinn, Estonia.

Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing Facility. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium-Contaminated Water Into A Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst MA.

Paul E. Rosenfeld, Ph.D. Page 5 of 10 June 2019
Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment Facility Emissions. The 23rd Annual International Conferences on Soils Sediment and Water. Lecture conducted from University of Massachusetts, Amherst MA.

Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3- Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting. Lecture conducted from San Diego, CA.

Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala, Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 – 25, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on Halogenated Persistent Organic Pollutants – DIOXIN2006. Lecture conducted from Radisson SAS Scandinavia Hotel in Oslo Norway.

Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And Human Blood Samples Collected Near A Former Wood Treatment Facility. APHA 134 Annual Meeting & Exposition. Lecture conducted from Boston Massachusetts.

Paul Rosenfeld Ph.D. (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

Mealey’s C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel, Philadelphia, PA.

Paul Rosenfeld Ph.D. (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel, Irvine California.

Paul Rosenfeld Ph.D. (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.

Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey’s Groundwater Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.

Paul Rosenfeld Ph.D. (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.

International Society of Environmental Forensics: Focus On Emerging Contaminants. Lecture conducted from Sheraton Oceanfront Hotel, Virginia Beach, Virginia.

Paul Rosenfeld Ph.D. (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related Perfluorochemicals. 2005 National Groundwater Association Ground Water And Environmental Law Conference.

Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld Ph.D. (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.

Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust.

Lecture conducted from Phoenix Arizona.

Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.

Meeting of tribal representatives. Lecture conducted from Parker, AZ.

Paul E. Rosenfeld, Ph.D. Page 6 of 10 June 2019
Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.

Drycleaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento, California.

Rosenfeld, P. E., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.

Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus Conference. Water Supply and Emerging Contaminants.. Lecture conducted from Hyatt Regency Phoenix Arizona.

Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.

Paul Rosenfeld, Ph.D. (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.

Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and Industrial Processes. Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.

Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture conducted from Barcelona Spain.

Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting For Coastal Sage Restoration.

Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington..

Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High-Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Soil Science Society Annual Conference. Lecture conducted from Indianapolis, Maryland.

Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water Environment Federation. Lecture conducted from Anaheim California.

Rosenfeld. P.E. (October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted from Ocean Shores, California.

Rosenfeld, P.E. (2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery Association. Lecture conducted from Sacramento California.

Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.

Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil Science Society of America. Lecture conducted from Salt Lake City Utah.

Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.

Rosenfeld, P.E., C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.

Paul E. Rosenfeld, Ph.D. Page 7 of 10 June 2019
Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur Emissions Following Biosolids Incorporation With High-Carbon Wood-Ash. Water Environment Federation 12th Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue Washington.

Rosenfeld, P.E., C.L. Henry, R. B. Harrison, and R. Dills. (1997). Comparison of Odor Emissions From Three Different Biosolids Applied to Forest Soil. Soil Science Society of America. Lecture conducted from Anaheim California.

Teaching Experience:

UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science 100 to students, including undergrad, medical doctors, public health professionals and nurses. Course focused on the health effects of environmental contaminants.

National Ground Water Association, Successful Remediation Technologies. Custom Course in Sante Fe, New Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage tanks.

National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1, 2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.

California Integrated Waste Management Board, April and May, 2001. Alternative Landfill Caps Seminar in San Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.

UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation Technologies focusing on Groundwater Remediation.

University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry, Organic Soil Amendments, and Soil Stability.

U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.

Academic Grants Awarded:

California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.

Goal: To investigate effect of high carbon wood ash on volatile organic emissions from compost. 2001.

Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.

Goal: investigate effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.

King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on VOC emissions. 1998.

Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate effect of polymers and ash on VOC emissions from biosolids. 1997.

James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered Poplar trees with resistance to round-up. 1996.

United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the Tahoe National Forest. 1995.

Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts in West Indies. 1993

Paul E. Rosenfeld, Ph.D. Page 8 of 10 June 2019
Deposition and/or Trial Testimony:

In the United States District Court For The District of New Jersey Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.

Case No.: 2:17-cv-01624-ES-SCM
Rosenfeld Deposition. 6-7-2019
In the United States District Court of Southern District of Texas Galveston Division M/T Carla Maersk, Plaintiffs, vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS “Conti Perdido” Defendant.

Case No.: 3:15-CV-00106 consolidated with 3:15-CV-00237 Rosenfeld Deposition. 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants Case No.: No. BC615636
Rosenfeld Deposition, 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles – Santa Monica The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants Case No.: No. BC646857
Rosenfeld Deposition, 10-6-2018; Trial 3-7-19

In United States District Court For The District of Colorado Bells et al. Plaintiff vs. The 3M Company et al., Defendants Case: No 1:16-cv-02531-RBJ
Rosenfeld Deposition, 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112th Judicial District Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants Cause No 1923
Rosenfeld Deposition, 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa Simons et al., Plaintiffs vs. Chevron Corporation, et al., Defendants Cause No C12-01481
Rosenfeld Deposition, 11-20-2017
In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants Case No.: No. 0i9-L-2295
Rosenfeld Deposition, 8-23-2017

In The Superior Court of the State of California, For The County of Los Angeles Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC Case No.: LC102019 (c/w BC582154)
Rosenfeld Deposition, 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants Case Number: 4:16-cv-52-DMB-JVM
Rosenfeld Deposition: July 2017

Paul E. Rosenfeld, Ph.D. Page 9 of 10 June 2019
In The Superior Court of the State of Washington, County of Snohomish Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants Case No.: No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial, March 2017
In The Superior Court of the State of California, County of Alameda Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants Case No.: RG14711115
Rosenfeld Deposition, September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants Case No.: LALA002187
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Jerry Dovico, et al., Plaintiffs vs. Valley View Sine LLC, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Doug Pauls, et al.,, et al., Plaintiffs vs. Richard Warren, et al., Defendants Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.

Civil Action N0. 14-C-30000
Rosenfeld Deposition, June 2015
In The Third Judicial District County of Dona Ana, New Mexico Betty Gonzalez, et al. Plaintiffs vs. Del Oro Dairy, Del Oro Real Estate LLC, Jerry Settles and Deward DeRuyter, Defendants
Rosenfeld Deposition: July 2015
In The Iowa District Court For Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant Case No 4980
Rosenfeld Deposition: May 2015
In the Circuit Court of the 17th Judicial Circuit, in and For Broward County, Florida Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.

Case Number CACE07030358 (26)
Rosenfeld Deposition: December 2014
In the United States District Court Western District of Oklahoma Tommy McCarty, et al., Plaintiffs, v. Oklahoma City Landfill, LLC d/b/a Southeast Oklahoma City Landfill, et al. Defendants.

Case No. 5:12-cv-01152-C
Rosenfeld Deposition: July 2014

Paul E. Rosenfeld, Ph.D. Page 10 of 10 June 2019
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.

Case Number cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial: April 2014
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987) Rosenfeld Deposition: October 2012
In the United States District Court of Southern District of Texas Galveston Division Kyle Cannon, Eugene Donovan, Genaro Ramirez, Carol Sassler, and Harvey Walton, each Individually and on behalf of those similarly situated, Plaintiffs, vs. BP Products North America, Inc., Defendant.

Case 3:10-cv-00622
Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013
In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, II et al., Plaintiffs vs. Two Farms, Inc. d/b/a Royal Farms, Defendants Case Number: 03-C-12-012487 OT
Rosenfeld Deposition: September 2013

EXHIBIT C
1640 5th St.., Suite 204 Santa
Santa Monica, California 90401
Tel: (949) 887‐9013
Email: [email protected]
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Industrial Stormwater Compliance
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
CEQA Review
Education:

M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.

B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.

Professional Certifications:

California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:

Matt has 25 years of experience in environmental policy, assessment and remediation. He spent nine years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of the assessment of seven major military facilities undergoing base closure. He led numerous enforcement actions under provisions of the Resource Conservation and Recovery Act (RCRA) while also working with permit holders to improve hydrogeologic characterization and water quality monitoring.

Matt has worked closely with U.S. EPA legal counsel and the technical staff of several states in the application and enforcement of RCRA, Safe Drinking Water Act and Clean Water Act regulations. Matt has trained the technical staff in the States of California, Hawaii, Nevada, Arizona and the Territory of Guam in the conduct of investigations, groundwater fundamentals, and sampling techniques.

Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present); • Geology Instructor, Golden West College, 2010 – 2014; • Senior Environmental Analyst, Komex H2O Science, Inc. (2000 ‐‐ 2003); • Executive Director, Orange Coast Watch (2001 – 2004); • Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989– 1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000); • Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 – 1998);
• Instructor, College of Marin, Department of Science (1990 – 1995); • Geologist, U.S. Forest Service (1986 – 1998); and
• Geologist, Dames & Moore (1984 – 1986).

Senior Regulatory and Litigation Support Analyst:

With SWAPE, Matt’s responsibilities have included:
• Lead analyst and testifying expert in the review of over 100 environmental impact reports since 2003 under CEQA that identify significant issues with regard to hazardous waste, water resources, water quality, air quality, Valley Fever, greenhouse gas emissions, and geologic hazards. Make recommendations for additional mitigation measures to lead agencies at the local and county level to include additional characterization of health risks and implementation of protective measures to reduce worker exposure to hazards from toxins and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at industrial facilities. • Manager of a project to provide technical assistance to a community adjacent to a former Naval shipyard under a grant from the U.S. EPA.
• Technical assistance and litigation support for vapor intrusion concerns. • Lead analyst and testifying expert in the review of environmental issues in license applications for large solar power plants before the California Energy Commission. • Manager of a project to evaluate numerous formerly used military sites in the western U.S. • Manager of a comprehensive evaluation of potential sources of perchlorate contamination in Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the review of releases of gasoline to sources drinking water at major refineries and hundreds of gas stations throughout California.
• Expert witness on two cases involving MTBE litigation. • Expert witness and litigation support on the impact of air toxins and hazards at a school. • Expert witness in litigation at a former plywood plant.

With Komex H2O Science Inc., Matt’s duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony by the former U.S. EPA Administrator and General Counsel. • Senior researcher in the development of a comprehensive, electronically interactive chronology of MTBE use, research, and regulation.
• Senior researcher in the development of a comprehensive, electronically interactive chronology of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking water treatment, results of which were published in newspapers nationwide and in testimony against provisions of an energy bill that would limit liability for oil companies. • Research to support litigation to restore drinking water supplies that have been contaminated by MTBE in California and New York.
2 • Expert witness testimony in a case of oil production‐related contamination in Mississippi. • Lead author for a multi‐volume remedial investigation report for an operating school in Los Angeles that met strict regulatory requirements and rigorous deadlines. 3 • Development of strategic approaches for cleanup of contaminated sites in consultation with clients and regulators.

Executive Director:

As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange County beaches from multiple sources of contamination including urban runoff and the discharge of wastewater. In reporting to a Board of Directors that included representatives from leading Orange County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the development of countywide water quality permits for the control of urban runoff and permits for the discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business institutions including the Orange County Business Council.

Hydrogeology:

As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army Airfield, and Sacramento Army Depot. Specific activities were as follows:
• Led efforts to model groundwater flow and contaminant transport, ensured adequacy of monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and groundwater.
• Initiated a regional program for evaluation of groundwater sampling practices and laboratory analysis at military bases.
• Identified emerging issues, wrote technical guidance, and assisted in policy and regulation development through work on four national U.S. EPA workgroups, including the Superfund Groundwater Technical Forum and the Federal Facilities Forum.

At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to show zones of vulnerability, and the results were adopted and published by the State of Hawaii and County of Maui.

As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for the protection of drinking water.
• Managed the Sole Source Aquifer Program and protected the drinking water of two communities through designation under the Safe Drinking Water Act. He prepared geologic reports, conducted public hearings, and responded to public comments from residents who were very concerned about the impact of designation.
4 • Reviewed a number of Environmental Impact Statements for planned major developments, including large hazardous and solid waste disposal facilities, mine reclamation, and water transfer.

Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance with Subtitle C requirements.
• Reviewed and wrote ʺpart Bʺ permits for the disposal of hazardous waste. • Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed the basis for significant enforcement actions that were developed in close coordination with U.S.

EPA legal counsel.
• Wrote contract specifications and supervised contractor’s investigations of waste sites.

With the National Park Service, Matt directed service‐wide investigations of contaminant sources to prevent degradation of water quality, including the following tasks:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the Clean Water Act to control military, mining, and landfill contaminants. • Conducted watershed‐scale investigations of contaminants at parks, including Yellowstone and Olympic National Park.
• Identified high‐levels of perchlorate in soil adjacent to a national park in New Mexico and advised park superintendent on appropriate response actions under CERCLA. • Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while serving on a national workgroup.
• Co‐authored two papers on the potential for water contamination from the operation of personal watercraft and snowmobiles, these papers serving as the basis for the development of nation‐ wide policy on the use of these vehicles in National Parks. • Contributed to the Federal Multi‐Agency Source Water Agreement under the Clean Water Action Plan.

Policy:

Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection Agency, Region 9. Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking water supplies.
• Shaped EPA’s national response to these threats by serving on workgroups and by contributing to guidance, including the Office of Research and Development publication, Oxygenates in Water: Critical Information and Research Needs.
• Improved the technical training of EPAʹs scientific and engineering staff. • Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in negotiations with the Administrator and senior management to better integrate scientific principles into the policy‐making process.
• Established national protocol for the peer review of scientific documents. 5 Geology:

With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical models to determine slope stability.
• Coordinated his research with community members who were concerned with natural resource protection.
• Characterized the geology of an aquifer that serves as the sole source of drinking water for the city of Medford, Oregon.

As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern Oregon. Duties included the following:
• Supervised year‐long effort for soil and groundwater sampling. • Conducted aquifer tests.
• Investigated active faults beneath sites proposed for hazardous waste disposal.

Teaching:

From 1990 to 1998, Matt taught at least one course per semester at the community college and university levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater contamination.
• Served as a committee member for graduate and undergraduate students. • Taught courses in environmental geology and oceanography at the College of Marin.

Matt taught physical geology (lecture and lab and introductory geology at Golden West College in Huntington Beach, California from 2010 to 2014.

Invited Testimony, Reports, Papers and Presentations:

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public Environmental Law Conference, Eugene, Oregon.

Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.

EPA Region 9, San Francisco, California.

Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and Public Participation. Brownfields 2005, Denver, Coloradao.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las Vegas, NV (served on conference organizing committee).

Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at schools in Southern California, Los Angeles.
6 Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.

Presentation to the Ground Water and Environmental Law Conference, National Groundwater Association.

Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Phoenix, AZ (served on conference organizing committee).

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy of Sciences, Irvine, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a tribal EPA meeting, Pechanga, CA.

Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a meeting of tribal repesentatives, Parker, AZ.

Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water Supplies. Invited presentation to the Inter‐Tribal Meeting, Torres Martinez Tribe.

Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.

Invited presentation to the U.S. EPA Region 9.

Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited presentation to the California Assembly Natural Resources Committee.

Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental Journalists.

Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater (and Who Will Pay). Presentation to a meeting of the National Groundwater Association.

Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and State Underground Storage Tank Program managers.

Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished report.
7 Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.

Unpublished report.

Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage Tanks. Unpublished report.

Hagemann, M.F., and VanMouwerik, M., 1999. Potential Water Quality Concerns Related to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.

VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft Usage. Water Resources Division, National Park Service, Technical Report.

Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright Society Biannual Meeting, Asheville, North Carolina.

Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.

Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.

Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui, October 1996.

Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu, Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air and Waste Management Association Publication VIP‐61.

Hagemann, M.F., 1994. Groundwater Characterization and Cleanup a t Closing Military Bases in California. Proceedings, California Groundwater Resources Association Meeting.

Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of Groundwater.

Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐ contaminated Groundwater. California Groundwater Resources Association Meeting. 8 Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.

Other Experience:

Selected as subject matter expert for the California Professional Geologist licensing examination, 2009‐ 2011.
9 SENT VIA EMAIL ONLY TO [email protected];
[email protected]
September 28, 2021
Planning Commission, City of Rialto
Siri Champion, Community Development Department
150 S. Palm Avenue
Rialto, CA 92376
Re: City of Rialto’s Draft 6
th Cycle Housing Element (2021-2029)
Dear Planning Commission and Ms. Champion,
Inland Counties Legal Services (ICLS) writes to provide comments regarding the City of Rialto’s Draft Sixth Cycle Housing Element, dated August 2021 (Draft).

While we are pleased that the City has prepared a Draft and is moving toward adoption of its Sixth Cycle Housing Element, we have identified multiple substantive deficiencies in the Draft, described below. We provide these comments to the City to encourage the City’s correction of these deficiencies before adopting the Draft. We also encourage the City to submit its draft housing element to the California Department of Housing and Community Development (HCD) for review prior to adoption of the Draft. ICLS previously commented by email of September 1, 2021, that the City’s plan to adopt the Draft before submitting it to HCD is in violation of Government Code section 65585(b)(1).

1. Sites Inventory Analysis
The inventory of sites available for housing development does not satisfy the requirements of Housing Element law. “The inventory shall specify for each site the number of units that can realistically be accommodated on that site and whether the site is adequate to accommodate lower-income housing, moderateincome housing, or above moderate-income housing.” Gov. Code § 65583.2(c).

The Draft does not identify adequate sites with a realistic capacity to accommodate the lower income Regional Housing Needs allocation (RHNA) during the current planning period consistent with its duty to affirmatively further fair housing.
a. Realistic Capacity
For all sites identified, the housing element must describe the methodology used to determine the number of units calculated based on following factors: (1) land use controls and site improvements requirements, (2) realistic development 2 | P a g e
capacity for the site, (3) typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction, (4) the current or planned availability and accessibility of sufficient water, sewer, and dry utilities. Government Code section 65583.2(c)(2); see also Housing Element Sites Inventory Guidebook (June 10, 2020), 19. The realistic capacity calculation must be adjusted to reflect capacity limits, especially when the site has a potential to be developed with nonresidential uses or has an overlay zone. Housing Element Sites Inventory Guidebook, 20. The Draft relies on six opportunity areas, described below, which require rezoning programs or overlay zoning to allow residential development.

Foothill Boulevard Specific Plan. According to Table B-1: Summary of RHNA Status and Sites Inventory in Appendix B, Inventory of Adequate Sites, the Draft relies on 1,472 low income and very-low income units within the Foothill Boulevard Specific Plan with the existing zoning.

Draft, B-3. The current zoning allows for 30 dwelling units per acre when developing on at least three acres. Draft, B-15. According to Table B-1: Summary of RHNA Status and Sites Inventory, the Draft also relies on 1,624 units within the Foothill Boulevard Specific Plan with an rezone/upzone programs. While the Draft mentions that an amendment to 35 dwelling units per acre “would create the opportunity for 2,532 very low-/low-income housing units” in Appendix B, Inventory of Adequate Sites, the programs included in the Draft do not include any specific action to rezone/upzone the Foothill Boulevard area. Draft, B-15. Without a specific program that includes concrete steps to make sites available for lower income households, the City cannot rely on the additional 1,624 units in the Foothill Boulevard Specific Plan.

North Riverside Avenue. According to Table B-1: Summary of RHNA Status and Sites Inventory, the Draft relies on 1 low income or very-low income unit in North Riverside Avenue with existing commercial zoning, and 219 low income and very-low income units with rezone/upzone programs, a total of 220 units. Draft, B-3. However, on page B-17 of the Appendix B, Inventory of Adequate Sites, the Draft states that this opportunity area “has potential to accommodate 399 housing units, including 179 housing units affordable to very low- /low-income households. This would require the creation of an overlay . . . to allow residential development at a maximum density of 48.4 dwelling units per acre and an assumed density of 39 dwelling units per acre”. Draft, B-17. But the programs included in the Draft do not include any specific action for an overlay with a specific timeframe for completion. Without a program to adopt an overlay zone to make sites available for lower income households, the City cannot rely on the 219 units for low income and very-low income households.

Gateway Specific Plan. The Draft relies on 734 low income and very-low income units in the Gateway Specific Plan. However, the current zoning in the Gateway Specific Plan allows for office, industrial parks, and commercial use only. Draft, B-19. The Draft acknowledges that this opportunity area would require a change to the zoning on the parcels, but it does not include a specific rezoning program. Without a rezoning program including concrete steps and timeframes, the City cannot rely on the 734 lower income household units in the Gateway Specific Plan. 3 | P a g e
Central Area Specific Plan. Sites smaller than one half acre may only count toward lower income units when the Draft demonstrates “that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income household units” or other evidence that demonstrates the sites are adequate to accommodate lower income units. Gov. Code Section 65583.2(c)(2)(A). The Draft relies on the Central Area Specific Plan to accommodate 255 lower income units, only 15 units of which could be accommodated with the existing zoning, according to Table B-1: Summary of RHNA Status and Sites Inventory. Draft, B-3. The Draft acknowledges that an overlay district is required to accommodate more lower income units, including 255 lower income household units; however, the programs in the Draft do not include a specific program with overlay requirements. Moreover, the Draft relies on 58 sites that are smaller than one half acre within the Central Area Specific Plan. Draft, B-21. The Draft does not include the analysis required under Government Code Section 65583.2(c)(2)(A) for sites smaller than one half acre.

Baseline Parcels and Baseline Shopping Center. Finally, the Draft is also relying on rezone programs in Baseline Parcels and a Baseline Shopping Center to accommodate lower income household units. Most of the parcels in Baseline Parcels are less than one half acre. However, the Draft does not include a program to facilitate the consolidation of small lots in the Baseline Parcels opportunity area, nor does it include a program to rezone commercial zoning in the Baseline Shopping Center. California Department of Housing and Community Development, Housing Element Site Inventory Guidebook (Site Inventory Guidebook), page 16 (available at https://www.hcd.ca.gov/community-development/housingelement/docs/sites_inventory_memo_final06102020.pdf).

Therefore, the sites inventory does not identify sufficient available sites with the capacity to accommodate the lower income RHNA in the sixth cycle planning period. b. Infrastructure Availability
The housing element must include an analysis “describing existing or planned water, sewer, and other dry utilities supply, including the availability and access to parcels on the site inventory, distribution facilities, general plan programs or other mandatory program or plan (including a program or plan of a public or private entity to secure water or sewer service) to support housing development on the site.” Sites Inventory Guidebook, page 8. The Sites Inventory in Appendix B of the Draft does not provide specific information about infrastructure availability for each identified site. HCD’s Sites Inventory Form, now mandatory pursuant to SB 6, requires this analysis be included on a site-specific basis. The Draft mentions infrastructure as a potential constraint because it can increase costs of new construction; however, it does not evaluate the infrastructure availability for the sites identified. The Draft must include an analysis of its infrastructure availability.
4 | P a g e
c. Affirmatively Furthering Fair Housing
The Draft fails to evaluate adequately the identified sites relative to the City’s duty to affirmatively further fair housing required by Government Code section 65583(c)(10)(A). The Draft does not include a discussion of whether or how development the selected sites will integrate the community; nor does it discuss how such development will transform racially and ethnically concentrated areas of poverty into areas of opportunity. See California Department of Housing and Community Development, Affirmatively Furthering Fair Housing Guidance (AFFH Guidance), pg. 21 (available at https://www.hcd.ca.gov/communitydevelopment/affh/docs/affh_document_final_4-27-2021.pdf); Gov. Code §§ 65583(c)(5). Further analysis is necessary to ensure that development of the identified sites will affirmatively further fair housing.

2. Assessment of Fair Housing
Assembly Bill 686 now requires that housing elements include a robust assessment and analysis of contributing factors to fair housing issues that limit or deny fair housing choice or access to opportunity, including (1) ongoing and concentrated segregation and integration, (2) disparities in access to opportunity, (3) racially concentrated areas of poverty, and (4) disproportionate housing needs and displacement risk. See https://www.hcd.ca.gov/communitydevelopment/affh/index.shtml. The Draft needs more analysis of these contributing factors to comply with the requirements of AB 686, as set forth below. a. Ongoing and Concentrated Segregation and Integration The analysis must address areas of ongoing and concentrated segregation and integration and compare concentrations of protected characteristics and incomes at both a regional and local level. AFFH Guidance, pg. 31, citing Gov. Code §§ 65583(c)(10). The Draft identifies native Hawaiians as experiencing the highest levels of segregation at 40.6%. Draft, 3-36. However, the Draft does not provide an analysis of the trends and factors contributing to segregation, nor does it include an analysis of ongoing and concentrated segregation and integration at a regional level.

The Draft also acknowledges high concentrations of Latinx population based on HCD’s AFFH data and mapping resources, but it does not include an analysis of the contributing factors. Draft, 3-57. Moreover, the Draft mentions integration and segregation for race and ethnicity, but there is no discussion of integration and segregation for income, familial status, persons with disabilities.
b. Racially Concentrated Areas of Poverty
The analysis in the Draft must include racially and ethnically concentrated areas of poverty on a regional and a local level, where concentrated areas of poverty are discussed relative to concentrated areas of affluence. AFFH Guidance, pg. 32, citing Gov. Code §§ 65583(c)(10). The 5 | P a g e
Draft identifies one racially or ethnically concentrated areas of poverty in the City’s downtown area, where it partly relies on to accommodate lower income household units. Draft, 3-37. The Draft does not analyze racially and ethnically concentrated areas of poverty at a regional level, nor does it include a discussion of local concentrated areas of poverty relative to concentrated areas of affluence.
c. Disparities in Access to Opportunity
The Draft must identify and analyze significant disparities in access to opportunity for education, transportation, economic development, and environment at a regional and local level. AFFH Guidance, pg. 34-35. According to the Draft, majority of the City is classified as low to moderate opportunity. Draft, 3-39. However, it does not analyze access to opportunity for education, transportation, economic development, and environment.
d. Disproportionate Housing Needs/Displacement Risk
The Draft acknowledges higher rates of overcrowding and severe overcrowding compared to the County and the State, but does not address it relative to the City’s duty to affirmatively further fair housing. Draft, 3-49. The Draft also identifies disability, household income, and household characteristic as “most commonly” shaping the City’s housing needs, without further analysis.

Draft, 3-47.

3. Review of Fifth Cycle Housing Programs
The housing element must evaluate the effectiveness of the prior Housing Element’s programs, including “the actual results or outcomes of the prior housing-element’s goals (what happened), objectives, policies, and programs. The results should be quantified where possible (e.g., number of units rehabilitated) and may be qualitative where necessary (e.g., mitigation of governmental constraints).” See HCD Building Blocks, https://www.hcd.ca.gov/communitydevelopment/building-blocks/getting-started/review-revise.shtml. The Draft does not properly evaluate all of its housing programs from the fifth cycle. For example, the Draft omits “Program

5.2D – Pursue Annexation of County Islands” from the Fifth Cycle Housing Element, and it does not evaluate the completion of the annexation of the five north Rialto islands. The Draft does not report on its “formal monitoring program” to monitor availability of existing identified sites from Program 5.2A Provide Adequate Sites, nor does it report on its Program 5.4B, Remove development constraints. Draft, A-7, A-16. The Draft should evaluate the Fifth Cycle programs against their stated goals and objectives, and it should analyze whether changes to programs, policies, and practices could increase the City’s effectiveness in meeting the community’s housing needs.
6 | P a g e

4. Sixth Cycle Housing Programs
Housing Element law requires that a housing element contain “a statement of the community’s goals, quantified objectives, and policies relative to the maintenance, preservation, improvement, and development of housing.” Gov. Code § 65583(b)(1). Each program should set forth “a schedule of actions during the planning period, each with a timeline for implementation, that may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element through the administration of land use and development controls, the provision of regulatory concessions and incentives, [and] the utilization of appropriate federal and state financing and subsidy programs when available.” Gov. Code § 65583(c). The Draft does not provide adequate programs to address the lower income housing needs during the sixth cycle planning period.

The Draft includes timeframes for the implementation of the following programs as “ongoing”, rather than providing concrete timeframes which would promote the development of lower income housing. Program 2B: Accessory Dwelling Unit Construction, Program 4A: Density Bonus 4C: Water and Sewer Service Providers, and Program 5A: Affirmatively Furthering Fair Housing. Draft, 4-7, 4-14 to 4-16. Additionally, the Draft’s housing program 1F: Targeted Neighborhood Approach, which addresses “problem neighborhoods” including “distressed, poorly managed multi-family properties”, will be “initiate[d] during the planning period”. Draft, 4-5. These timeframes demonstrate a lack of commitment to implement their housing programs.

Moreover, housing programs 2A: Provide Adequate Sites to Accommodate the RHNA and 2L:

Alternative Housing Concepts are too vague. Program 2A provides that “to facilitate development of affordable housing to accommodate the 2021-2029 RHNA as identified in Appendix A of this Housing Element, the City has identified approximately 289.10 acres of underutilized and vacant residential land within the City. The identified land inventory allows a range of residential densities ranging from 25 to 48 dwelling units per acre. To demonstrate adequate sites, the City has provided an analysis of recent development within the City and realistic development capacity of identified sites as detailed in Section 4 of this Housing Element.” Draft, 4-6. Because the Draft relies heavily on rezoning programs with different conditions for different opportunity areas to meet the lower income RHNA, the Draft must be revised to include specific rezoning programs with specific dates within the current planning period. Otherwise, the program is inadequate.

Program 2L is also too vague because it states that “to provide more potential housing opportunities in Rialto, the City will review and research alternative housing concepts such as live-work developments, small lot developments, two master-bedroom housing units, and co-op housing. The City will review the applicability of these housing types in Rialto and review and revise the Zoning Code, as appropriate, to encourage development.” Draft, 4-10 to 4-11. The 7 | P a g e
Draft must include a separate program to facilitate the consolidation of small lots because it relies on parcels smaller than half an acre in areas such as Central Area Specific Plan and Baseline Parcels. Therefore, the programs included in the Draft are inadequate to address the lower income housing needs during the sixth cycle planning period.

Conclusion
The City’s housing element must include adequate rezoning program to rely on the proposed identified opportunity areas, analyze the sites to ensure that development will affirmatively further fair housing, and demonstrate a commitment to implement housing programs that will encourage and facilitate development of housing that meets the needs of all economic segments of the community.

Thank you for considering these comments. We look forward to discussing our comments with you. Should you have any questions, please contact me via email at [email protected] or by phone at (951) 320-7515.

Sincerely,

INLAND COUNTIES LEGAL SERVICES
Maria Delgado, Esq.

SENT VIA EMAIL ONLY TO [email protected]
October 12, 2021
Mayor Deborah Robertson
City of Rialto, City Council
150 S. Palm Avenue
Rialto, CA 92376
Re: October 12, 2021, City Council Agenda TAB 5
Request to approve submittal of the Draft 6th Cycle Housing Element (2021-2029) to the California Department of Housing and Community Development
Dear Mayor Robertson and members of the City Council,
Inland Counties Legal Services (ICLS) writes to provide comments on the City’s Draft Sixth Cycle Housing Element, proposed for submittal to the California Department of Housing and Community Development at tonight’s City Council meeting. We previously provided comments to the City regarding substantive deficiencies in the City’s Draft Sixth Cycle Housing Element by letter of September 28, 2021. A copy of our September 28 letter is attached for ease of reference as Exhibit 1. We have not heard from the City about any revisions to the Draft Sixth Cycle Housing Element to address the deficiencies in our letter.

We provide these comments to urge the City to correct the deficiencies in the City’s Draft Sixth Cycle Housing Element, submit the Draft Sixth Cycle Housing Element to the California Department of Housing and Community Development, and adopt a Sixth Cycle Housing Element that substantially complies with Housing Element Law.

Sincerely,
INLAND COUNTIES LEGAL SERVICES—ONTARIO
Maria Delgado
CC: Siri Champion, Community Development Department
California Department of Housing and Community Development EXHIBIT 1
SENT VIA EMAIL ONLY TO [email protected];
[email protected]
September 28, 2021
Planning Commission, City of Rialto
Siri Champion, Community Development Department
150 S. Palm Avenue
Rialto, CA 92376
Re: City of Rialto’s Draft 6
th Cycle Housing Element (2021-2029)
Dear Planning Commission and Ms. Champion,
Inland Counties Legal Services (ICLS) writes to provide comments regarding the City of Rialto’s Draft Sixth Cycle Housing Element, dated August 2021 (Draft).

While we are pleased that the City has prepared a Draft and is moving toward adoption of its Sixth Cycle Housing Element, we have identified multiple substantive deficiencies in the Draft, described below. We provide these comments to the City to encourage the City’s correction of these deficiencies before adopting the Draft. We also encourage the City to submit its draft housing element to the California Department of Housing and Community Development (HCD) for review prior to adoption of the Draft. ICLS previously commented by email of September 1, 2021, that the City’s plan to adopt the Draft before submitting it to HCD is in violation of Government Code section 65585(b)(1).

1. Sites Inventory Analysis
The inventory of sites available for housing development does not satisfy the requirements of Housing Element law. “The inventory shall specify for each site the number of units that can realistically be accommodated on that site and whether the site is adequate to accommodate lower-income housing, moderateincome housing, or above moderate-income housing.” Gov. Code § 65583.2(c).

The Draft does not identify adequate sites with a realistic capacity to accommodate the lower income Regional Housing Needs allocation (RHNA) during the current planning period consistent with its duty to affirmatively further fair housing.
a. Realistic Capacity
For all sites identified, the housing element must describe the methodology used to determine the number of units calculated based on following factors: (1) land use controls and site improvements requirements, (2) realistic development 2 | P a g e
capacity for the site, (3) typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction, (4) the current or planned availability and accessibility of sufficient water, sewer, and dry utilities. Government Code section 65583.2(c)(2); see also Housing Element Sites Inventory Guidebook (June 10, 2020), 19. The realistic capacity calculation must be adjusted to reflect capacity limits, especially when the site has a potential to be developed with nonresidential uses or has an overlay zone. Housing Element Sites Inventory Guidebook, 20. The Draft relies on six opportunity areas, described below, which require rezoning programs or overlay zoning to allow residential development.

Foothill Boulevard Specific Plan. According to Table B-1: Summary of RHNA Status and Sites Inventory in Appendix B, Inventory of Adequate Sites, the Draft relies on 1,472 low income and very-low income units within the Foothill Boulevard Specific Plan with the existing zoning.

Draft, B-3. The current zoning allows for 30 dwelling units per acre when developing on at least three acres. Draft, B-15. According to Table B-1: Summary of RHNA Status and Sites Inventory, the Draft also relies on 1,624 units within the Foothill Boulevard Specific Plan with an rezone/upzone programs. While the Draft mentions that an amendment to 35 dwelling units per acre “would create the opportunity for 2,532 very low-/low-income housing units” in Appendix B, Inventory of Adequate Sites, the programs included in the Draft do not include any specific action to rezone/upzone the Foothill Boulevard area. Draft, B-15. Without a specific program that includes concrete steps to make sites available for lower income households, the City cannot rely on the additional 1,624 units in the Foothill Boulevard Specific Plan.

North Riverside Avenue. According to Table B-1: Summary of RHNA Status and Sites Inventory, the Draft relies on 1 low income or very-low income unit in North Riverside Avenue with existing commercial zoning, and 219 low income and very-low income units with rezone/upzone programs, a total of 220 units. Draft, B-3. However, on page B-17 of the Appendix B, Inventory of Adequate Sites, the Draft states that this opportunity area “has potential to accommodate 399 housing units, including 179 housing units affordable to very low- /low-income households. This would require the creation of an overlay . . . to allow residential development at a maximum density of 48.4 dwelling units per acre and an assumed density of 39 dwelling units per acre”. Draft, B-17. But the programs included in the Draft do not include any specific action for an overlay with a specific timeframe for completion. Without a program to adopt an overlay zone to make sites available for lower income households, the City cannot rely on the 219 units for low income and very-low income households.

Gateway Specific Plan. The Draft relies on 734 low income and very-low income units in the Gateway Specific Plan. However, the current zoning in the Gateway Specific Plan allows for office, industrial parks, and commercial use only. Draft, B-19. The Draft acknowledges that this opportunity area would require a change to the zoning on the parcels, but it does not include a specific rezoning program. Without a rezoning program including concrete steps and timeframes, the City cannot rely on the 734 lower income household units in the Gateway Specific Plan. 3 | P a g e
Central Area Specific Plan. Sites smaller than one half acre may only count toward lower income units when the Draft demonstrates “that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower income household units” or other evidence that demonstrates the sites are adequate to accommodate lower income units. Gov. Code Section 65583.2(c)(2)(A). The Draft relies on the Central Area Specific Plan to accommodate 255 lower income units, only 15 units of which could be accommodated with the existing zoning, according to Table B-1: Summary of RHNA Status and Sites Inventory. Draft, B-3. The Draft acknowledges that an overlay district is required to accommodate more lower income units, including 255 lower income household units; however, the programs in the Draft do not include a specific program with overlay requirements. Moreover, the Draft relies on 58 sites that are smaller than one half acre within the Central Area Specific Plan. Draft, B-21. The Draft does not include the analysis required under Government Code Section 65583.2(c)(2)(A) for sites smaller than one half acre.

Baseline Parcels and Baseline Shopping Center. Finally, the Draft is also relying on rezone programs in Baseline Parcels and a Baseline Shopping Center to accommodate lower income household units. Most of the parcels in Baseline Parcels are less than one half acre. However, the Draft does not include a program to facilitate the consolidation of small lots in the Baseline Parcels opportunity area, nor does it include a program to rezone commercial zoning in the Baseline Shopping Center. California Department of Housing and Community Development, Housing Element Site Inventory Guidebook (Site Inventory Guidebook), page 16 (available at https://www.hcd.ca.gov/community-development/housingelement/docs/sites_inventory_memo_final06102020.pdf).

Therefore, the sites inventory does not identify sufficient available sites with the capacity to accommodate the lower income RHNA in the sixth cycle planning period. b. Infrastructure Availability
The housing element must include an analysis “describing existing or planned water, sewer, and other dry utilities supply, including the availability and access to parcels on the site inventory, distribution facilities, general plan programs or other mandatory program or plan (including a program or plan of a public or private entity to secure water or sewer service) to support housing development on the site.” Sites Inventory Guidebook, page 8. The Sites Inventory in Appendix B of the Draft does not provide specific information about infrastructure availability for each identified site. HCD’s Sites Inventory Form, now mandatory pursuant to SB 6, requires this analysis be included on a site-specific basis. The Draft mentions infrastructure as a potential constraint because it can increase costs of new construction; however, it does not evaluate the infrastructure availability for the sites identified. The Draft must include an analysis of its infrastructure availability.
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c. Affirmatively Furthering Fair Housing
The Draft fails to evaluate adequately the identified sites relative to the City’s duty to affirmatively further fair housing required by Government Code section 65583(c)(10)(A). The Draft does not include a discussion of whether or how development the selected sites will integrate the community; nor does it discuss how such development will transform racially and ethnically concentrated areas of poverty into areas of opportunity. See California Department of Housing and Community Development, Affirmatively Furthering Fair Housing Guidance (AFFH Guidance), pg. 21 (available at https://www.hcd.ca.gov/communitydevelopment/affh/docs/affh_document_final_4-27-2021.pdf); Gov. Code §§ 65583(c)(5). Further analysis is necessary to ensure that development of the identified sites will affirmatively further fair housing.

2. Assessment of Fair Housing
Assembly Bill 686 now requires that housing elements include a robust assessment and analysis of contributing factors to fair housing issues that limit or deny fair housing choice or access to opportunity, including (1) ongoing and concentrated segregation and integration, (2) disparities in access to opportunity, (3) racially concentrated areas of poverty, and (4) disproportionate housing needs and displacement risk. See https://www.hcd.ca.gov/communitydevelopment/affh/index.shtml. The Draft needs more analysis of these contributing factors to comply with the requirements of AB 686, as set forth below. a. Ongoing and Concentrated Segregation and Integration The analysis must address areas of ongoing and concentrated segregation and integration and compare concentrations of protected characteristics and incomes at both a regional and local level. AFFH Guidance, pg. 31, citing Gov. Code §§ 65583(c)(10). The Draft identifies native Hawaiians as experiencing the highest levels of segregation at 40.6%. Draft, 3-36. However, the Draft does not provide an analysis of the trends and factors contributing to segregation, nor does it include an analysis of ongoing and concentrated segregation and integration at a regional level.

The Draft also acknowledges high concentrations of Latinx population based on HCD’s AFFH data and mapping resources, but it does not include an analysis of the contributing factors. Draft, 3-57. Moreover, the Draft mentions integration and segregation for race and ethnicity, but there is no discussion of integration and segregation for income, familial status, persons with disabilities.
b. Racially Concentrated Areas of Poverty
The analysis in the Draft must include racially and ethnically concentrated areas of poverty on a regional and a local level, where concentrated areas of poverty are discussed relative to concentrated areas of affluence. AFFH Guidance, pg. 32, citing Gov. Code §§ 65583(c)(10). The 5 | P a g e
Draft identifies one racially or ethnically concentrated areas of poverty in the City’s downtown area, where it partly relies on to accommodate lower income household units. Draft, 3-37. The Draft does not analyze racially and ethnically concentrated areas of poverty at a regional level, nor does it include a discussion of local concentrated areas of poverty relative to concentrated areas of affluence.
c. Disparities in Access to Opportunity
The Draft must identify and analyze significant disparities in access to opportunity for education, transportation, economic development, and environment at a regional and local level. AFFH Guidance, pg. 34-35. According to the Draft, majority of the City is classified as low to moderate opportunity. Draft, 3-39. However, it does not analyze access to opportunity for education, transportation, economic development, and environment.
d. Disproportionate Housing Needs/Displacement Risk
The Draft acknowledges higher rates of overcrowding and severe overcrowding compared to the County and the State, but does not address it relative to the City’s duty to affirmatively further fair housing. Draft, 3-49. The Draft also identifies disability, household income, and household characteristic as “most commonly” shaping the City’s housing needs, without further analysis.

Draft, 3-47.

3. Review of Fifth Cycle Housing Programs
The housing element must evaluate the effectiveness of the prior Housing Element’s programs, including “the actual results or outcomes of the prior housing-element’s goals (what happened), objectives, policies, and programs. The results should be quantified where possible (e.g., number of units rehabilitated) and may be qualitative where necessary (e.g., mitigation of governmental constraints).” See HCD Building Blocks, https://www.hcd.ca.gov/communitydevelopment/building-blocks/getting-started/review-revise.shtml. The Draft does not properly evaluate all of its housing programs from the fifth cycle. For example, the Draft omits “Program

5.2D – Pursue Annexation of County Islands” from the Fifth Cycle Housing Element, and it does not evaluate the completion of the annexation of the five north Rialto islands. The Draft does not report on its “formal monitoring program” to monitor availability of existing identified sites from Program 5.2A Provide Adequate Sites, nor does it report on its Program 5.4B, Remove development constraints. Draft, A-7, A-16. The Draft should evaluate the Fifth Cycle programs against their stated goals and objectives, and it should analyze whether changes to programs, policies, and practices could increase the City’s effectiveness in meeting the community’s housing needs.
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4. Sixth Cycle Housing Programs
Housing Element law requires that a housing element contain “a statement of the community’s goals, quantified objectives, and policies relative to the maintenance, preservation, improvement, and development of housing.” Gov. Code § 65583(b)(1). Each program should set forth “a schedule of actions during the planning period, each with a timeline for implementation, that may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element through the administration of land use and development controls, the provision of regulatory concessions and incentives, [and] the utilization of appropriate federal and state financing and subsidy programs when available.” Gov. Code § 65583(c). The Draft does not provide adequate programs to address the lower income housing needs during the sixth cycle planning period.

The Draft includes timeframes for the implementation of the following programs as “ongoing”, rather than providing concrete timeframes which would promote the development of lower income housing. Program 2B: Accessory Dwelling Unit Construction, Program 4A: Density Bonus 4C: Water and Sewer Service Providers, and Program 5A: Affirmatively Furthering Fair Housing. Draft, 4-7, 4-14 to 4-16. Additionally, the Draft’s housing program 1F: Targeted Neighborhood Approach, which addresses “problem neighborhoods” including “distressed, poorly managed multi-family properties”, will be “initiate[d] during the planning period”. Draft, 4-5. These timeframes demonstrate a lack of commitment to implement their housing programs.

Moreover, housing programs 2A: Provide Adequate Sites to Accommodate the RHNA and 2L:

Alternative Housing Concepts are too vague. Program 2A provides that “to facilitate development of affordable housing to accommodate the 2021-2029 RHNA as identified in Appendix A of this Housing Element, the City has identified approximately 289.10 acres of underutilized and vacant residential land within the City. The identified land inventory allows a range of residential densities ranging from 25 to 48 dwelling units per acre. To demonstrate adequate sites, the City has provided an analysis of recent development within the City and realistic development capacity of identified sites as detailed in Section 4 of this Housing Element.” Draft, 4-6. Because the Draft relies heavily on rezoning programs with different conditions for different opportunity areas to meet the lower income RHNA, the Draft must be revised to include specific rezoning programs with specific dates within the current planning period. Otherwise, the program is inadequate.

Program 2L is also too vague because it states that “to provide more potential housing opportunities in Rialto, the City will review and research alternative housing concepts such as live-work developments, small lot developments, two master-bedroom housing units, and co-op housing. The City will review the applicability of these housing types in Rialto and review and revise the Zoning Code, as appropriate, to encourage development.” Draft, 4-10 to 4-11. The 7 | P a g e
Draft must include a separate program to facilitate the consolidation of small lots because it relies on parcels smaller than half an acre in areas such as Central Area Specific Plan and Baseline Parcels. Therefore, the programs included in the Draft are inadequate to address the lower income housing needs during the sixth cycle planning period.

Conclusion
The City’s housing element must include adequate rezoning program to rely on the proposed identified opportunity areas, analyze the sites to ensure that development will affirmatively further fair housing, and demonstrate a commitment to implement housing programs that will encourage and facilitate development of housing that meets the needs of all economic segments of the community.

Thank you for considering these comments. We look forward to discussing our comments with you. Should you have any questions, please contact me via email at [email protected] or by phone at (951) 320-7515.

Sincerely,

INLAND COUNTIES LEGAL SERVICES
Maria Delgado, Esq.

SENT VIA EMAIL TO [email protected]; [email protected] March 8, 2022
Mayor Deborah Robertson
City of Rialto, City Council
150 S. Palm Avenue
Rialto, CA 92376
Re: March 8, 2022, City Council Agenda TAB 2 Item 22-173 Request City Council to Conduct a Public Hearing to Adopt Resolution No.7845 Adopting a Mitigated Negative Declaration (Environmental Assessment Review No. 2021-0044) for and Approving the City of Rialto 2021-2029 (Sixth Cycle) General Plan Housing Element Update.

Dear Mayor Robertson and members of the City Council,
Inland Counties Legal Services (ICLS) and the Public Interest Law Project (PILP) write to provide comments on the City’s Draft Sixth Cycle Housing Element (Current Draft), proposed for adoption at the March 8, 2022 City Council meeting. The City submitted its Draft Sixth Cycle Housing Element to the Department of Housing and Community Development (HCD) for review on October 14, 2021. On December 13, 2021, HCD found that the City’s Draft Sixth Cycle Housing Element did not substantially comply with Housing Element Law.

HCD’s December 13, 2021, findings letter (HCD’s findings) is attached as Exhibit 1. HCD’s findings identified multiple substantial deficiencies in the City’s Draft Sixth Cycle Housing Element. PILP and ICLS raised many of these deficiencies in our earlier comments of November 19, 2021 and September 28, 2021. We now provide comments on the City’s February 2, 2022 revisions to the Draft Sixth Cycle Housing Element in response to HCD’s findings.

1. The Current Draft does not provide an adequate fair housing analysis.

The Current Draft fails to include data and analysis relevant to fair housing issues, including integration and segregation, racially or ethnically concentrated areas of poverty, disparities in access to opportunity for education and economic development, and disproportionate housing needs and displacement.

Integration and Segregation. As discussed in HCD’s findings, and in our prior comment letters, the Current Draft is missing data and analysis about ongoing segregation and integration. HCD’s Findings, p. 2. In response to HCD’s findings, the Current Draft includes local and regional maps to compare racial demographics in 2010 and in 2018 generally, and it concludes that the City and the region have experienced racial diversification. Draft, p. 3-48 to 3-50. 2 | Page
The Current Draft identifies Native Hawaiian and “Other” with the highest level of segregation, without further discussion, and it does not address the high concentration of Latinx populations (74.3 %) within the City. Draft, p.3-51. Further, the Current Draft must also include a discussion of levels of integration and segregation for income, familial status, persons with disabilities, and identify the groups that experience the highest levels of segregation. See California Department of Housing and Community Development, Affirmatively Furthering Fair Housing Guidance (AFFH Guidance), pg. 31 (available at https://www.hcd.ca.gov/communitydevelopment/affh/docs/affh_document_final_4-27-2021.pdf).

Racially & Ethnically Concentrated Areas of Poverty (R/ECAP). HCD’s findings instruct the City to analyze the trends and patterns in addition to local data and knowledge and factors that contributed to the conditions of the two tracts within the City that have been designated by TCAC as areas of high segregation and poverty. HCD’s findings, p. 2; See HCD AFFH Data Viewer https://affh-data-resources-cahcd.hub.arcgis.com/. In response, the Current Draft added local data and knowledge1, but does not include trends and patterns, nor does it evaluate factors that contributed to the conditions of these areas. Draft, p. 3-51 to 3-52, 3-64.

Disparities in Access to Opportunities. HCD’s findings instruct the City to independently analyze trends and patterns related to access to educational and economic opportunities at a local and regional level. HCD’s Findings, p. 2. The Current Draft now includes a map showing access to educational opportunities at a local and regional level and a map showing access to economic opportunities at a local and regional level. Draft, p. 3-65 to 3-67. For access to educational opportunities, the Current Draft fails to describe differences amongst schools, analyze proximity of proficient and less proficient schools to areas of high segregation and poverty, and evaluate the presence or lack of policies, practices, investments to promote access to more proficient schools that affect access to opportunity. See AFFH Guidance, p. 34-35. For economic opportunities, the Current Draft fails to describe any disparities in access to jobs by protected groups, it fails to address where protected groups live and how that affects their ability to obtain a job; and evaluate employment trends by protected groups. See AFFH Guidance, p. 35.

Disproportionate Housing Needs and Displacement. HCD’s findings instructed the City to consider and analyze more data for displacement risk, including trends and patterns related to people experiencing homelessness at a local and regional level. HCD’s findings, p. 2. The City added UC Berkeley’s Urban Displacement Project data, which shows low-income/susceptible to displacement areas where the City has identified sites to accommodate the lower-income RHNA.

Draft, p. 3-81 to 3-83. Additionally, in Section 2.F.7., the Current Drafts identifies resources for people experiencing homelessness at a local and regional level, but it does not provide an analysis of trends and patterns.
1 The Current Draft continues to provide inconsistent information about high segregation and poverty.

The Current Draft states that there are no R/ECAPs located within Rialto; therefore, no proposed sites are located in a R/ECAP. Current Draft, p. 3-97.
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Contributing Factors. HCD’s letter indicates that the Current Draft does not provide a conclusion of fair housing issues and it does not identify, describe, and prioritize contributing factors to fair housing issues. HCD’s findings, p. 3; See AFFH Guidance, p. 49. In response, the Current Draft adds the two high segregation census tracts and two other factors, but as indicated in HCD’s findings the low resourced census tracts are not contributing factors. HCD’s finding, p.

3. Site inventory’s consistency with the obligation to affirmatively furthering fair housing.

HCD’s findings points out that the City’s analysis clearly demonstrates that the sites identified to accommodate the lower income RHNA will either maintain the status quo or further worsen of fair housing conditions, which requires strong reasoning and “commensurate programs with strong place-based strategies for community revitalization and new opportunities in higher opportunity areas to result in an equitable qualify of life.” HCD’s Findings, p. 2-3. The Current Draft, as revised, does not provide a strong reasoning for identifying lower income RHNA sites in low resource areas with high segregation and poverty and with the highest percentage of Latinx population. It states only that the sites provide access to transportation and services and “the City seeks to revitalize the area and facilitate the development of mixed income residential projects in conjunction with new community opportunities.” Draft, p. 3-91, 3-93, 3-95.

Moreover, the additions to Program 5A do not adequately address strong place-based strategies for community revitalization, nor do they provide new opportunities in higher opportunity areas.

The Current Draft’s evaluates the RHNA sites as identified “throughout the City”; however, it does not evaluate whether the RHNA by income or race is concentrated in areas of the community. Draft, s. 3-53, 3-65, 3-81. As such, the Current Draft does not explain how development within the identified sites will transform racially and ethnically concentrated areas of poverty into areas of opportunity. See AFFH Guidance, p. 21, 45. Accordingly, the Current Draft continues to fail to adequately evaluate the identified sites relative to the City’s duty to affirmatively further fair housing required by Government Code sections 65583(c)(10)(A) and 65583.2(a).

2. The Current Draft does not identify adequate sites to accommodate the City’s Sixth Cycle RHNA.

Realistic Capacity. HCD’s December 13, 2021 findings regarding the City’s prior draft determined that the inventory of sites did not reflect the realistic capacity of the sites because the buildable and gross acreage are the same, such that the Element assumes that sites will be developed at the maximum allowable density. HCD findings, p. 4. The Current Draft now addresses the realistic capacity of sites directly, but continues to assume the certain “Opportunity Areas” will continue to “include a redevelopment percentage of 100%” based on recent projects that were developed. Draft, B-35. However, of the examples included in Table B-16, 12 of 13 projects were in the city of Fontana, not Rialto. Also, the examples are primarily affordable projects that would qualify for a density bonus, which is not an acceptable methodology to estimate capacity. See HCD Site Inventory Guidebook, p. 14. The single affordable project developed in the City of Rialto at the Metrolink Station was zoned “Rialto Central Area Specific Plan – Commercial Support” which is not defined in terms of the either the minimum or 4 | Page
maximum density allowed, nor the assumed density, so that there is no information about the realistic capacity compared to actual development for any development in the City.

The sites inventory continues to list the gross acreage and buildable acreage as the same values for all 7 out of 8 planning areas, comprising 308 of 313 sites, including all of the sites in the Foothill Boulevard Specific Plan area, the Gateway Specific Plan Area, the Central Area Specific Plan, the Baseline areas, Randall Avenue sites, Lytle Creek Specific Plan and Renaissance Specific Plan. For the single North Riverside Avenue area the Current Draft makes reductions only on five properties with existing uses, where development is proposed to be feasible for areas such as parking lots, sites 113-115, 117-118. This does not reflect a realistic capacity for the overwhelming majority of sites in the inventory. The revised Current Draft does not remedy HCD’s findings regarding realistic capacity of the sites.

Zoning and Minimum Densities. The Current Draft does not include information on the current zoning of many parcels included in the sites inventory, labeling most sites with zoning for one of several “Specific Plans” that does not provide for what uses are currently allowed. For example, this is the case for all 111 sites in the Foothill Boulevard Specific Plan area, both the land use designation and zoning are listed as “Specific Plan” despite the fact that there are four separate land use designations listed at p. 2 of the Foothill Specific Plan, available at the City’s website: https://www.yourrialto.com/DocumentCenter/View/564/Foothill-Boulevard-SpecificPlan. The Specific Plan land use designations should be included in the inventory so that it describes the existing permitted uses. Also, the sites inventory should distinguish between sites that are relied upon for their existing zoning capacity and sites that are subject to rezoning, rather than only inferring the intent to rezone from the varied densities in the rezone/upzone column in the inventory.

The Current Draft does not commit to minimum densities in the sites inventory. The narrative for Gateway Specific Plan and the Baseline plan area suggest they might have a “a zone that could have a minimum density of 20 du/ac” but does not commit to any minimum density. Draft p. B24, B-28. The Foothill Specific Plan discussion does not review or commit to any minimum densities, despite being the area where the Current Draft proposes to accommodate over 3,000 lower income dwelling units. Draft, B-20. Without a commitment to minimum densities, the Current Draft must engage in “an evaluation of the typical densities of existing or approved residential development at a similar affordability level” pursuant to Gov. Code § 65583.2(c)(2).

See Sites Inventory Guidebook, 19. However, this analysis is also missing. For example, the description of the Lytle Creek Specific Plan does include an average density for existing development of 3.44 units per acre, but this figure was not employed when estimating the realistic capacity of the sites. See Draft, Table B-2, p. B-10 (this page is mis-labeled as C-10).

Excessive Non-Vacant Sites. The Current Draft relies on non-vacant sites to satisfy more than 50 percent of its lower income RHNA, thus requiring additional justification and analysis for such reliance, pursuant to AB 1397, at Gov Code Sec 65583.2(g)(2). Draft, p. 3-105. The Element now addresses non-vacant sites in a summary fashion at p. B-17, but does not provide “findings based on substantial evidence that the use is likely to be discontinued during the planning period” as required by the statute.
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For example, Site 26 in the Foothill Specific Plan Area is a 4.05 acre parcel that is the location of the San Bernardino County Social Service office, for which the Current Draft assumes will be developed for 78 units of very low/low housing, yet there is no indication the County will be closing or moving its Social Services office. Without evidence that such uses will be discontinued during the planning period, all such sites must be removed.

The review of non-vacant sites also includes a list of projects that were developed for residential uses on non-vacant sites, Table B-7, yet all of these projects appear to be in the City of Fontana.

See Draft, p. B-18. No explanation is offered why the same conditions exist in Rialto as the Fontana developments, nor is there an explanation why no housing developments on non-vacant sites have occurred in Rialto. Indeed, the fact that the Draft can point to eight development on non-vacant parcels occurred in the “region” yet none occurred in Rialto, seems to indicate that conditions are not feasible for non-vacant development in the City.

Program 2F acknowledges that 19 non-vacant sites in the inventory were also relied upon in the 5th Cycle, so that the City must permit development at 30 units per acre and allow residential use by right for housing development when at least 20 percent of the proposed units are affordable to lower income households. Draft, p. 4-9. There are a number of parcels included in the inventory for the 5th Cycle that have parking lots that are in active use that are not analyzed for the City’s parking requirements, Rialto Municipal Code Chapter 18.58. Examples of such sites are for County Social Services office and the U.S. Post Office, sites 95 and 133. Furthermore, Program 2F proposes completing the required rezone within 3 years of adoption of the Housing Element, but since Rialto has not adopted its Element until more than 120 days after the October 15, 2021 deadline, the programs to rezone sites must be completed within 1 year of the statutory deadline, or no later than October 15, 2022. Gov. Code § 65583(c)(1)(A).

As required for non-vacant sites, the Current Draft now has Program 2C to provide for replacement housing, as required by § 65583.2(g)(3), however this program lacks specificity for implementation and delays its application for 3 years. Draft, p. 4-8.

By-Right Zoning for Multifamily Housing. The Current Draft now acknowledges the City’s obligation to allow multifamily use by right on sufficient sites to meet its lower income RHNA, however, the language added to Program 2B merely recites the language of Gov. Code § 65583.2(h) and (i) without any effort to apply these standards to the Specific Plan areas that are relied upon to meet the lower income RHNA. Draft, p. 4-8.

For example, in Foothill Specific Plan area includes three designations that all permit 13-30 du/ac, yet there are different minimum development sizes, the Commercial Mixed-Use areas require a 3 acre minimum, the Residential Mixed Use has unspecified minimum parcel sizes consistent with design requirements and Residential High Density has both a 3 acre minimum that must also be consistent with design standards. Foothill Specific Plan, 22-24. The Commercial Mixed-Use areas only permit residential multifamily development above the first floor. Foothill Specific Plan, 29, 35. The review process for all types of development does not allow any process of “by right” development, instead focusing on the obligation to have a “precise plan” developed by the applicant reviewed by the City prior to any development permits. Foothill Specific plan, 27, section 18.111.040. 6 | Page
The Current Draft does not propose how to harmonize these planning restrictions in the Foothill Specific Plan with the requirements of Housing Element Law to permit multifamily development by right in such zones. Merely reciting the requirements of the statute is insufficient to plan how the City will comply with the law.

City Owned Sites. In our prior comments from November 19, 2021, we noted that the earlier draft did not provide information about the City’s intention to sell City owned sites included in the inventory. The Current Draft does not correct this deficiency. Housing Element Law requires that the City provide this information: “if a site included in the inventory is owned by the city or county, the housing element must include a description of whether there are any plans to sell the property during the planning period and how the jurisdiction will comply with the Surplus Land Act.” Gov. Code § 65583.2(b)(3) (added by AB 1486 (2019)). While the Current Draft does now include a new program to comply with the Surplus Land Act, Program 2S, it does not include any information on the City’s intention to dispose of the City owned sites.

It is critical to understand the City’s intention with respect to the parcels it owns. For example, a series of small sites near City Hall in the Central Area Specific Plan area are controlled by the City, and would affect development near the center of City operations. See Draft Figure B-9, p.

B-27, and sites 124, 129, 147, 149, 161 through 179, and182 through 191. (Note that the Draft does not include sites as “City owned” in the inventory when the entity holding the property is the former Redevelopment Agency of the Rialto, despite the fact that City is the Successor Agency, and thus controls these parcels, see https://www.yourrialto.com/279/SuccessorAgency.) Residential development will not be possible on these sites unless the City makes the determinations agrees to dispose of the properties. The new Program 2S, to comply with the Surplus Land Act, does not commit the City to make the required determination under the SLA whether the properties are excess surplus, such that they would be make available to developers of lower income housing.

All but two of the 31 sites owned by the City in the Central Area Specific Plan area are less than ½ acre, requiring a consolidation program in order to make multifamily housing feasible, and now required to make additional showing of prior history of small site development or that they can be developed. Gov. Code § 65583.2(c)(2)(A), as amended by AB 1397 (2017). The Current Draft now has two lot consolidation programs that addresses such small sites, Programs 2O and 2P, yet neither of these programs commits the City to consolidating the lots it owns, rather “encourage and incentivize developers to consolidate these parcels”. Draft, p. 4-13. The City acknowledges it has “total site control to consolidate” the parcels it owns, yet fails to make any commitment to either consolidate small sites nor make them available for housing development.

See p. B-15 on Smaller Sites Parcels (this page is mis-labeled C-15). As the owner of the parcels, the City should consolidate the lots and make them available for housing development as Surplus Land.

Specific Plans. HCD’s findings instruct the City to indicate whether projects in the Specific Plans have been approved or pending, and if not, to list the sites by parcel number size, general plan designation, zoning and include a calculation of the realistic capacity of each site. HCD’s findings, p. 5. The Current Draft lists three criteria for review and approval of proposed developments and financing information for Specific Plans. Current Draft, p. B-6. The Current 7 | Page
Draft indicates that it has received one Precise Plan of Design application without further information. Current Draft, p. B-7.

Foothill Boulevard Specific Plan. The Current Draft continues to rely greatly on sites within the Foothill Boulevard Specific Plan, including 1,442 low income and very-low income units with the current zoning, and an additional 1,603 low income and very-low income units after rezoning. Draft, p. B-3; Table B-1. The Current Draft does not mention any pending or approved projects in the Foothill Boulevard Specific Plan. As such, HCD’s findings instruct the City to list sites by parcel number, size, general plan designation, zoning and include a calculation of realistic capacity of each site. HCD’s findings, p. 5. As mentioned above, the sites inventory in Appendix B of the Current Draft does not include the required information, including land use designation and zoning, and the calculation of realistic capacity is inadequate. Moreover, the Current Draft does not include an analysis of any requirements such as phasing or timing requirements in the Foothill Boulevard Specific Plan that impact development in the planning period, as mentioned in HCD’s findings. HCD’s findings, p. 5.

Central Area Specific Plan. The Current Draft relies on the Central Area Specific Plan to accommodate 240 lower income units after rezoning, and 15 lower income units with the existing zoning, according to Table B-1. Draft, p. B-3.2 The Current Draft suggests that “the creation of a new overlay district” or “similar policy strategy” could permit up to 48 dwelling units per acre in the Central Area Specific Plan area. Draft, p. B-26. This appears to coincide with the 48 du/ac proposed in Program B2, yet there is no language in the Program describing an any overlay zone, nor the scope and terms of an overlay zone. The Current Draft should be revised to clarify what rezoning will take place, which parcels would be rezoned, and whether such rezoning will be in an overlay district or utilize existing or modified zoning designations.

The inventory of sites in the Central Area Specific Plan area include 60 of 67 sites that are smaller than ½ acre, but nonetheless are included in the inventory of sites as accommodating lower income RHNA. Draft p. B-64 to B-75. AB 1397 prohibits including such small sites for meeting lower income RHNA “unless the housing element demonstrates development of housing affordable to lower income households on these sites is realistic or feasible.” HCD Sites Inventory Guidebook, p. 15. While Programs 2O and 2P identify some measures the City “will evaluate the appropriateness” of taking to incentivize consolidation, the commitments to such measures are too vague to result in the level of consolidation needed to make development realistic. Draft, p. 4-13.
2 The Central Area Specific Plan narrative on page B-26 and Table B-12 continue to provide inconsistent information about the number of lower income units relied upon in the Central Area Specific Plan (255 instead of 240 lower income units).
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Furthermore, the City or the former Redevelopment Agency owns 31 sites in the Central Area Specific Plan, all but two of which are less than ½ acre. See above for comments on the City Owned sites.

Gateway Specific Plan. Th Current Draft relies on 384 low income and very-low income units in the Gateway Specific Plan after rezoning two sites, sites 120 (9.86 acres) and 121 (10.08).

Draft, B-3, p. B-64. However, the Current Draft does not provide evidence that site 121, which the Current Draft identifies as a large site because it is over 10 acres, is realistic and feasible for lower income housing. Draft, p. B15 (mis-labeled as p. C-15).

Baseline Parcels and Baseline Shopping Center. The Current Draft is also relying on 80 lower income units within the Baseline Parcels area and 464 lower income units within the Baseline Shopping Center area after rezoning. Draft, p. B-3. However, as mentioned above in the Zoning and Minimum Densities section, the Current Draft does not specify the proposed new zoning, nor does it specify any modification to the general plan designation. More importantly, listing the gross acreage and buildable acreage as the same values within the Baseline Shopping Center is not realistic capacity. For example, sites 208, 211, 216, 220, 222, 226, and 227 all list the gross acreage and buildable acreage as the same where the City intends to use only a “significant portion of the parking lot” to accommodate lower income units. Draft, p. B-78 to B-85.

North Riverside Avenue. The Current Draft relies on 220 low income and very-low income units in North Riverside Avenue after rezoning. Draft, p. B-3. As mentioned in our prior comments, the rezoning program included in the Current Draft, Program 2B, is inadequate because it fails to specify the proposed general plan designation and minimum densities allowed.

Draft, p. 4-7 to 4-8.

Randall Avenue Sites. The Current Draft relies on 65 lower income units within Randall Avenue Sites after rezoning. Draft, p. B-3. Program 2B is inadequate because it fails to specify the proposed new zoning for the Randall Avenue Sites. Moreover, four out of the six sites identified sites in Randall Avenue are smaller than .5 acres. Draft, p. B-88 to B-89. While Program 2P indicates that the City will adopt provisions in its Zoning Code to facilitate small lot consolidation, it does not specify the provisions and a discrete timeline. Draft, p. 4-13.

3. The Current Draft does not include infrastructure availability for the sites inventory.

The City continues to fail its statutory obligation to include HCD’s Sites Inventory Form in the Current Draft, which would include information about infrastructure availability with the current zoning for each identified site.

4. The Current Draft does not address the constraints on Housing for Persons with Disabilities.

As HCD’s findings noted, the Current Draft does not adequately analyze constraints on development of housing for people with disabilities. HCD’s findings, p. 7. In response to HCD’s 9 | Page
findings, the Current Draft added language to Program 5F purporting to commit to review its reasonable accommodations findings to identify any potential constraints to persons seeking accessible housing. Draft, p. 4-25. However, this does not correct the deficiency. The City must analyze reasonable accommodation findings and process and revise programs to address this constraint. HCD’s findings, p. 7. Moreover, the Current Draft does not address the requirement to describe and analyze any definition of family used in zoning and land use. HCD’s findings, p.

7. 5. Public Participation
Prior to adoption of the Housing Element, planning staff must provide all public comments from the public on the adoption of the Element to the City Council. § 65585(b)(2). While the Current Draft acknowledges this obligation, and includes hundreds of pages of surveys, presentations and other letters in Appendix C, the letters provided by Inland Counties Legal Services on October 12, 2021 and November 19, 2021 are not included. Draft, p. 1-9. Further, these letters are not attached as exhibits to the agenda item for today’s City Council meeting.

Conclusion
We provide these comments to urge the City to correct the remaining deficiencies in the City’s Draft Sixth Cycle Housing Element before adopting and submitting to HCD, and adopt a Sixth Cycle Housing Element that substantially complies with Housing Element Law.

Sincerely,
Maria T. Delgado Craig Castellanet
INLAND COUNTIES LEGAL SERVICES, INC. PUBLIC INTEREST LAW PROJECT CC: Sohab Mehmood ([email protected]), Paul McDougall ([email protected]) California Department of Housing and Community Development Siri Champion ([email protected]),
City of Rialto, Community Development Planning Division EXHIBIT 1
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
December 13, 2021
Daniel Casey, Acting Community Development Manager
Community Development Department
City of Rialto
150 South Palm Avenue
Rialto, CA 92376
Dear Daniel Casey:

RE: City of Rialto’s 6th Cycle (2021-2029) Draft Housing Element Thank you for submitting the City of Rialto’s (City) draft housing element received for review on October 14, 202. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. HCD considered comments from Inland Counties Legal Services pursuant to Government Code section 65585, subdivision (c).

The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code). The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

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

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

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower- Daniel Casey, Acting Community Development Manager

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