Agenda packet — Santa Clarita City Council, May 10, 2022 (part 2 of 2)

Element consist of updates as required by state law. No changes to the land use map or zoning map were necessary to accommodate the City’s RHNA allocation. Future residential development is expected to occur in those areas already identified for residential uses. Furthermore, the City conducted outreach with public protection service and utility providers as a part of the Project and incorporated comments received in the Housing and Safety Element Updates. Nothing in the proposed amendments would increase the need for fire or police protection services, or increase demand for utilities.

SECTION 4. FINDINGS FOR GENERAL PLAN AMENDMENT 21-001. Based on the above findings of fact and recitals and the entire record, including, without limitation, oral and written testimony and other evidence received at the public hearings, reports and other transmittals from City staff to the City Council, and upon studies and investigations made by the City Council, the City Council finds as follows:

a. The proposed General Plan amendment meets all of the findings per Section 17.06.130 (Findings and Decision).

The proposed General Plan amendment meets all of the findings per Section 17.06.130, as summarized in Section 3, above.

b. Properties which benefit from increased density or intensity of development resulting from the General Plan amendment shall fully mitigate their increased sewer impact at the time that development occurs on the properties.

The proposed amendments to the Housing Element and Safety Element consist of updates as required by state law. No changes to the land use map or zoning map were necessary to accommodate the City’s RHNA allocation. Future residential development is expected to occur in those areas already identified for residential uses.

c. In addition, the City Council shall make at least one of the following findings:

1. The proposed General Plan amendment is consistent with other elements of the City’s General Plan pursuant to Government Code Section 65300.5.

2. The proposed General Plan amendment, if applicable, responds to changes in state and/or federal law pursuant to Government Code Section 65300.9.

3. The proposed General Plan amendment has been referred to the County of Los Angeles and any adjacent cities abutting or affected by the proposed action, the Local Agency Formation Commission, and any federal agency whose operations or lands may be affected by the proposed decision pursuant to Government Code Section 65352.

The proposed General Plan amendment consisting of updates to the Housing Element and Safety Element include revisions to ensure consistency with all requirements of the State of California Government Code. The amendments to the Housing Element and Safety Element are consistent with the other elements of the City’s General Plan. As a part of the outreach for the General Plan amendment and the CEQA process, the proposed

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amendments were referred to the applicable county, state, and federal agencies. Input received, if any, was incorporated into the applicable documents.

d. Additional findings for the Housing Element Update include the following:

1. The proposed amendments to the Housing Element are consistent with Government Code Section 65583, which states that a Housing Element is a mandatory element of the General Plan and shall consist of an identification and analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives, financial resources, and a schedule of programs for the preservation, improvement, and development of housing.

2. The proposed General Plan amendment is necessary to update the Housing Element in order to reflect the adequate sites for housing, including rental housing, factory- built housing, and mobile homes, and shall make adequate provisions for the existing and projected needs of all economic segments of the community.

3. The Housing Element describes existing and projected housing inventories and opportunities for additional housing within the planning area.

4. The Housing Element determines the extent of housing needs in the community and planning area.

5. The Housing Element describes methods for solving housing deficiencies and providing the City and its planning area with sufficient housing at all income levels.

6. The information which is the subject of this General Plan amendment is consistent with all other provisions of the Housing Element.

SECTION 5. The City Council hereby approves Master Case 21-088, consisting of General Plan Amendment 21-001, adopting the Negative Declaration prepared for the project and allowing for the amendment of the Housing Element and Safety Element, as shown in the Housing Element Update (Exhibit A) and the Safety Element Update (Exhibit B).

SECTION 6. The City Clerk shall certify to the adoption of this resolution and certify this record to be a full, complete, and correct copy of the action taken.

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PASSED, APPROVED, AND ADOPTED this 10th day of May, 2022.

MAYOR
ATTEST:

CITY CLERK

DATE:________________________

STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) ss

CITY OF SANTA CLARITA )

I, Mary Cusick, City Clerk of the City of Santa Clarita, do hereby certify that the foregoing Resolution No. 22-__ was duly adopted by the City Council of the City of Santa Clarita at a regular meeting thereof, held on the 10th of May, 2022, by the following vote:

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

CITY CLERK

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EXHIBIT A

HOUSING ELEMENT UPDATE (HEARING DRAFT)

INCORPORATED BY REFERENCE

DOCUMENT CAN BE FOUND AT
https://www.santa-clarita.com/housingelement

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EXHIBIT B

SAFETY ELEMENT UPDATE (HEARING DRAFT)

INCORPORATED BY REFERENCE

DOCUMENT CAN BE FOUND AT
https://www.santa-clarita.com/home/showdocument?id=21018&t=637858886604113876

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Attachment: Resolution (Housing Element and Safety Element Update) Attachment
HCD Findings Letter
Master Case 21-088

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Attachment: HCD Findings Letter (Housing Element and Safety Element Update) STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, G overnor

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
Tom
Cole, Director
Community Development Department
City of Santa Clarita
23920 W. Valencia Blvd. Suite 302
Santa Clarita, CA 91355
D
ear Tom Cole:

R
E: City of Santa Clarita’s 6th Cycle (2021-2029) Draft Housing Element T
hank you for submitting the City of Santa Clarita’s (City) draft housing element received for review on November 12, 2021. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation on January 7, 2022 with consultants Jane Riley, Elliot Pickett, and Jackie Criger. In addition, HCD considered comments from Cindy Russo, Herb Johnston, Malissa Cindrich, and John Zirkel pursuant to Government Code section 65585, subdivision (c).

T
he 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.

A
s 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.

F
or 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, January 11, 2022

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and H
CD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i).

P
ublic 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-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate.

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

F
or your information, some general plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
http://opr.ca.gov/docs/OPR_Appendix_C_final.pdf
and
http://opr.ca.gov/docs/Final_6.26.15.pdf.

H
CD appreciates the hard work and dedication the City’s housing element team provided during the review. We are committed to assist the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Reid Miller, of our staff, at [email protected]
.

S
incerely,
P
aul McDougall
Senior Program Manager
E
nclosure

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APPENDIX

CITY OF SANTA CLARITA

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

Housing element technical assistance information is available on HCD’s website at http://www.hcd.ca.gov/community-development/housing-element/housing-element-memos.shtml .

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

A. Review and Revision

Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)

A thorough program-by-program review is necessary to evaluate City's performance in addressing housing goals. While the element generally describes the results of the prior element’s programs, the element must also provide an explanation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness). Programs should be revised as appropriate to reflect the results of this evaluation. The element should also be revised as follows:

Program H 1.1 (Affordable Housing Density Bonus): The analysis should explain why the program was not advertised, and how the new program will provide adequate advertising to make it more successful in the current housing element.

Program H 1.5 (Inclusionary Housing Program- Mixed Income Housing): Analysis of this program should include an explanation of why this program was deemed infeasible, as well as why the updated iteration of the program will be more successful.

Special Needs Populations: As part of the review of programs in the past cycle, the element must provide cumulative evaluation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness).

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B. Housing Needs, Resources, and Constraints

Enforcement & Outreach: The element generally describes past outreach efforts and fair housing services with the Housing Rights Center (HRC). However, largely, the element does not address this requirement. For example, the element describes outreach from 2019 but provides no information on the results of that outreach and how it relates to affirmatively furthering fair housing (AFFH). Also, the element contains little information on fair housing enforcement nor local knowledge from the fair housing service provider. Enforcement should include data and evaluation (e.g., characteristics of complaints) of any past or current fair housing lawsuits, findings, settlements, judgements, and complaints as well as compliance with fair housing laws and a description of ongoing outreach. The analysis could also evaluate data and the results from any fair housing testing.

Integration and Segregation: The element provided some data on integration and segregation across racial groups, familial status, disabilities, and income, but the element must discuss and analyze this data for trends over time and patterns across areas such as census tracts. Additionally, it must evaluate patterns at a regional basis, comparing the City to the region.

Areas of Concentrated Poverty and Affluence: While the element included data on Racially and Ethnically Concentrated Areas of Poverty (R/ECAP), it must provide an analysis and tie the analysis to the concentrations of poverty in the segregation and integration section. In addition, while the element included a map of Racially Concentrated Areas of Affluence, it must also analyze it. The combination of the R/ECAP and areas of affluence analyses will help guide goals and actions to address fair housing issues. The analysis should evaluate the patterns and changes over time at a local (e.g., neighborhood to neighborhood) and regional level (e.g., city to region).

Disparities in Access to Opportunity: While the element does provide data on disparities in access to opportunity for residents of Santa Clarita, it should provide analysis on access to transit throughout different areas of the City, as well as an analysis of access to transit by protected group. This same methodology should be employed to access to economic opportunity throughout the City. Access to economic opportunity analysis should also include information on job proximity and employment trends in relation to other factors such as patterns of segregation and poverty. In addition, the education analysis should include a map to support the analysis. The environmental analysis should address place-based strategies for Newhall and Canyon Country.

Disproportionate Housing Needs including Displacement Risks: The element includes some local and county data on cost burdened households (overpayment) and

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overcrowding (pp. 3-52 to 3-57). However, the element must evaluate trends and patterns within the City for these subtopics. The element must also provide a local and regional analysis for substandard housing and homelessness. In addition, the element briefly mentions displacement but must still provide data, analysis and conclusions, including analysis of displacement risk relating to disinvestment and disasters.

Site Inventory: The element must include an analysis demonstrating whether sites identified to meet the RHNA are distributed throughout the community in a manner that affirmatively furthers fair housing. A full analysis should address the income categories of identified sites with respect to location, the number of sites and units by all income groups and how that effects the existing patterns for all components of the assessment of fair housing (e.g., segregation and integration, access to opportunity). The element should also discuss whether the distribution of sites improves or exacerbates conditions. If sites exacerbate conditions, the element should identify further program actions that will be taken to mitigate this (e.g., anti-displacement strategies).

Local Data and Knowledge, and Other Relevant Factors: The element must include local data, knowledge, and other relevant factors to discuss and analyze any unique attributes about the City related to fair housing issues. The element should complement federal, state, and regional data with local data and knowledge where appropriate to capture emerging trends and issues, including utilizing knowledge from local and regional advocates and service providers. Also, the element must include other relevant factors that contribute to fair housing issues in the jurisdiction. For instance, the element can analyze historical land use and investment practices or other information and demographic trends.

Contributing Factors to Fair Housing Issues: While the element identifies contributing factors to fair housing issues, it should prioritize these factors to better formulate policies and programs and carry out meaningful actions to AFFH. The element should link contributing factors to specific programs where possible. In addition, many of the strategies “consider” actions but do not provide implementation components to mitigate the fair housing issues identified in the analysis.

Goals, Actions, Metrics, and Milestones: The element must be revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, metrics and milestones as appropriate, and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection.

2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).)

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Extremely Low-Income (ELI) Households: The element incudes some basic information regarding ELI households such as the methodology of calculating the number of projected ELI households for the 6th cycle RHNA. However, the element should also clearly state the projected number of ELI households. Additionally, given the unique and disproportionate needs of ELI households, the element must include analysis to better formulate policies and programs.

Housing Costs: While the element includes information on sales prices, the element must also include average rental cost information. Please note that the American Community Survey does not fully reflect current market conditions and the element should include additional data sources.

Overpayment: While the element identifies the total number of households overpaying for housing, it must also quantify and analyze the number of households overpaying by tenure (i.e., renter and owner), including lower-income households.

3. Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)

Housing Conditions: The element identifies the age of the housing stock (p. 53 & 54).

However, it must include analysis of the condition of the existing housing stock and estimate the number of units in need of rehabilitation and replacement. For example, the analysis could include estimates from a recent windshield survey or sampling, estimates from the code enforcement agency, or information from knowledgeable builders/developers, including non-profit housing developers or organizations.

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

The City has a regional housing need allocation (RHNA) of 10,031 housing units, of which 5,131 are for lower-income households. To address this need, the element relies on vacant and nonvacant sites, including sites in Specific Plan Areas and within Mixed- Use areas. To demonstrate the adequacy of these sites and strategies to accommodate the City’s RHNA, the element must include complete analyses:

Progress in Meeting the RHNA: The City’s RHNA may be reduced by the number of new units built since June 30, 2021. The element indicates (p. 57) 9,135 planned, approved pending units toward the RHNA, but it must indicate where each project is in the development process. It must also demonstrate the affordability of the units.

Specifically, the element must assign these units to the various income groups based on actual or anticipated sales price or rent level of the units or other mechanisms

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ensuring affordability (e.g., deed-restrictions) and demonstrate their availability in the planning period.

Sites Inventory: The element must include the general plan designation for all sites listed in the sites inventory. In addition, the element should include a map of the sites.

Realistic Capacity: The element (p. 58) mentions an assumption of 75 percent of maximum allowable densities to calculate residential capacity on identified sites and includes a few examples of recent developments. However, the element should include supporting information on typical densities of existing or approved residential developments at a similar affordability level for all affordability levels. For example, the element could clearly list other recent projects, the zone, acreage, built density, allowable density, level of affordability and presence of exceptions such as a density bonus. The realistic capacity analysis should provide examples to support development assumptions for all income levels and must also clarify whether the assumptions are for both vacant and nonvacant sites. The estimate of the number of units for each site must be adjusted as necessary, based on the land use controls and site improvements, typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction, and on the current or planned availability and accessibility of sufficient water, sewer, and dry utilities.

In addition, the element appears to assume residential development on sites with zoning that allow 100 percent nonresidential uses. The element must account for the likelihood of nonresidential uses. For example, the element could analyze all development activity in these nonresidential zones, how often residential development occurs and adjust residential capacity calculation, policies and program accordingly.

The element should include analysis based on factors such as development trends, performance standards or other relevant factors.

Suitability of Nonvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. The description of existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period. In addition, the element needs to analyze the extent that existing uses may impede additional residential development. The element can summarize past experiences converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. The element could also consider indicators such as age and condition of the existing structure expressed developer interest, low improvement to land value ratio, and other factors.

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these examples to the sites identified to accommodate the RHNA for lower-income households to demonstrate that these sites can adequately accommodate the City’s lower-income housing need. Based on a complete analysis, the City should consider adding or revising programs to include incentives for facilitating development on small sites.

Replacement Housing Requirements: If the sites inventory identifies sites with existing residential uses, it must identify whether the current residential uses are affordable to lower-income households or describe whether the additional residential development on the site requires the demolition of the existing residential use. For nonvacant sites with existing, vacated, or demolished residential uses and occupied by, or subject to an affordability requirement for, lower-income households within the last five years there must be a replacement housing program for units affordable to lower-income households. (Gov. Code, § 65583.2, subd. (g)(3).) Absent a replacement housing program, these sites are not adequate sites to accommodate lower-income households. The replacement housing program has the same requirements as set forth in Government Code section 65915, subdivision (c)(3). The housing element must be revised to include such analysis and a program, if necessary.

• sites must meet the density requirements for housing for lower income households, and
• allow by-right approval for housing developments that include 20 percent or more of its units affordable to lower income households. (Gov. Code, § 65583.2, subd. (c).)

Accessory Dwelling Units (ADU): The element projects 400 ADUs over the planning period or approximately 50 ADUs per year over the eight-year planning period. Given that the City has only produced an average of 28 units per year since 2018, it is not clear if this production level will be achievable in the planning period. As a result, the element should be updated to include a realistic estimate of the potential for ADUs and include policies and programs that incentivize the production of ADUs. Depending on the analysis, the element must commit to monitor ADU production throughout the course of the planning period and implement additional actions if not meeting target numbers anticipated in the housing element. In addition to monitoring production, this program should also monitor affordability. Additional actions, if necessary, should be taken in a timely manner (e.g., within six months). Finally, if necessary, the degree of additional actions should be in stride with the degree of the gap in production and affordability. For example, if actual production and affordability of ADUs is far from anticipated trends, then rezoning or something similar would be an appropriate action.

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If actual production and affordability is near anticipated trends, then measures like outreach and marketing might be more appropriate.

Availability of Infrastructure: The element includes some discussion on water and sewer providers in the City. However, it must also clarify whether sufficient total water, sewer, and dry utility capacity (existing and planned) can accommodate the regional housing need for each income category and include programs if necessary. In addition, the element must clarify when the two new sewer facilities will be available and whether the water reclamation plants (p. 109) are needed to accommodate wastewater to meet RHNA over the planning period.

Environmental Constraints: While the element generally describes a few environmental conditions within the City (p. 64), it must relate those conditions to identified sites and describe any other known environmental or other constraints that could impact housing development on identified sites in the planning period.

Zoning for a Variety of Housing Types:

• Emergency Shelters: The element should describe the development standards of the P/I zone that allows emergency shelters by-right and must also describe the characteristics and suitability of the zone. In addition, the element should describe how emergency shelter parking requirements are in line with AB139/Government Code section 65583, subdivision (a)(4)(A) or include a program as necessary.
• Transitional and Supportive Housing: The element includes some information on transitional housing (p. 70 & 97), but the City only allows the use in residential zoning districts. Transitional housing and supportive housing must be permitted as a residential use in all zones allowing residential uses and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd. (a)(5).) The element must add or revise programs to comply with the statutory requirements.
• Permanent Supportive Housing: Supportive housing shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651.

The element must demonstrate compliance with this requirement and include programs as appropriate.
• Low Barrier Navigation Centers: Low Barrier Navigation Centers shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65660. The element must demonstrate compliance with this requirement and include programs as appropriate.
• Employee Housing: The element must demonstrate zoning is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.), specifically, sections 17021.5 and 17021.6. Section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone.

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Section 17021.6 requires employee housing consisting of no more than 12 units or 36 beds to be permitted in the same manner as other agricultural uses in the same zone. The element should add programs as appropriate. • Manufactured Housing: Table 21 (p. 95) must clarify that manufactured housing is allowed as a single-family residence if on a permanent foundation. If the zoning does not comply, a program should be added.
• Accessory Dwelling Units (ADUs): After a cursory review of the City’s ordinance, the department discovered several areas which were not consistent with State ADU law. This includes, but is not limited to, not allowing ADUs by right in all residential zones, and side and rear setback requirements. The Department will provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the element should add a program to update the City’s ADU ordinance in order to comply with State law. For more information, please consult HCD’s ADU Guidebook, published in December 2020, which provides detailed information on new state requirements surrounding ADU development.

5. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures. The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need in accordance with Government Code section 65584 and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7).

Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other land use controls. The element must specifically include requirements related to heights, set- backs, lot coverage, unit sizes and limits on allowable densities. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints. In addition, the element discusses parking requirements including enclosed spaces, two spaces for one-bedroom units for multifamily development, high guest parking requirements, and specific parking standards for residential care services. These parking requirements must be analyzed as a constraint and addressed with a program.

The element should describe typical total fees for single-family and multifamily development as a percent of the total cost of the development. Lastly, the element identifies impact fees as a constraint and therefore must add a program to mitigate it.

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Local Processing and Permit Procedures: While the element includes information about processing times, it should also describe the procedures for a typical single family and multifamily development. The analysis should address the approval body, the number of public hearing if any, approval findings and any other relevant information. The analysis should address impacts on housing cost, supply, timing and approval certainty. The element should also address whether permits and other requirements can be processed concurrently, whether processing times are the same for single and multifamily developments, as well as address the long length of time to process reasonable accommodation and conditional use permits. Additionally, while the element provides a description (p. 104) of the Conditional use permit (CUP) required for housing developments, it must describe and analyze the CUP process, including typical findings and approval procedures by zone and housing type. The analysis must evaluate the processing and permit procedures’ impacts as potential constraints on housing supply and affordability. Lastly, the element should describe the process and findings for a development review permit.

Design Review: The element must describe and analyze the design review guidelines and process, including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and guidelines improve development certainty and mitigate cost impacts. The element must demonstrate this process is not a constraint or it must include a program to address this permitting requirement, as appropriate.

On/Off-Site Improvements: The element must identify subdivision level improvement requirements, such as minimum street widths (e.g., 40-foot minimum street width) and analyze their impact as potential constraints on housing supply and affordability.

Constraints on Housing for Persons with Disabilities: The element excludes group homes for seven or more persons from some residential zones and subjects the use to a conditional use permit, unlike other similar uses. The element should specifically analyze these constraints for impacts on housing supply and choices and approval certainty and objectivity for housing for persons with disabilities and include programs as appropriate. The element also requires a development review permit, not an administrative permit for group homes with six or fewer persons. The element must include a program to revise the requirements for group homes. Additionally, the element briefly describes its reasonable accommodation procedures, but it should also describe the process and decision-making criteria such as approval findings and analyze any potential constraints on housing for persons with disabilities. The element should also provide a clear definition of “family”. Lastly, the element must clarify whether specific plans allow for residential care facilities as well as transitional and supportive housing.

Zoning, Development Standards and Fees: The element must clarify compliance with new transparency requirements for posting all zoning, development standards and fees on the City’s website and add a program to address these requirements, if necessary.

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Local Ordinances: The element must specifically analyze locally adopted ordinances such as short-term rental ordinances that directly impact the cost and supply of residential development. The analysis should demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters.

SB 35 Streamlined Ministerial Approval Process: The element must clarify whether there are written procedures for the SB 35 (Chapter 366, Statutes of 2017) Streamlined Ministerial Approval Process and add a program to address these requirements.

6. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584. The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing. (Gov. Code, § 65583, subd. (a)(6).)

Land Costs: The element describes the median home value but must list the cost of land zoned for single and multifamily developments.

Approval Time and Requests Lesser Densities: The element must be revised to include analysis of requests to develop housing at densities below those anticipated, and the length of time between receiving approval for a housing development and submittal of an application for building permits that potentially hinder the construction of a locality’s share of the regional housing need. The analysis should also include efforts by the City to address identified nongovernmental constraints.

7. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).)

While the element quantifies (Appendix A) the City’s special needs populations, it must also analyze their special housing needs. For a complete analysis of each population group, the element should discuss challenges faced by the population, the existing resources to meet those needs (availability senior housing units, number of large units, number of deed restricted units, etc.,), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps.

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8. Analyze the opportunities for energy conservation with respect to residential development. (Gov. Code, § 65583(a)(8).)

The element must provide an analysis of opportunities for energy conservation in residential development. For example, the element could describe the “green Santa Clarita” program and could include incentives the City offers to encourage green building practices, or policies the City implements to encourage higher density developments and compact infill development, or passive solar design.

9. Analyze existing assisted housing developments that are eligible to change to nonlow- income housing uses during the next 10 years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).).

The element must clarify when the use restriction for Orchard Arms expires. If the restriction ends within the next 10 years, the element must include an at-risk analysis (Gov. Code, § 65583, subd. (a)(9).).

C. Housing Programs

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

To address the program requirements of Gov. Code section 65583, subd. (c)(1-6), and to facilitate implementation, programs should include: (1) a description of the City’s specific role in implementation; (2) definitive implementation timelines (i.e. month and year); (3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials. Programs to be revised include the following:

Program HP-1.4 (Affordable Housing Density Bonus): Program should clarify if the existing density bonus ordinance will be updated and/or implemented by 2023. If not, the program should include a timeline of when the ordinance will be updated. The portion of the program that will be “considered” should also be modified to include a more discrete implementation component.

Program HP-1.5 (Mixed Use Overlay Zone): If the program is continuing from the past element, the element should describe what will be implemented by 2024. It should also specify whether the listed incentives are currently in place, or if they are yet to be

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implemented. If they are not currently in place, the program should include a timeline as to when they will be available.

Program HP-1.6 (Graduated Density Zoning and Site Consolidation—Old Town Newhall): Program should be revised to provide a clear timeline as to what will be accomplished by 2024. Specifically, this program should clarify whether the offered incentives are only applicable if the whole block develops, and how likely this is.

Program HP-1.7 (Inclusionary Housing Program- Mixed Income Housing): The program should be revised to include implementation element, not just “consider”, as well as what incentives are being considered, and what will be accomplished by 2024.

Program HP-1.8 (Affordable Sites Incentive Program): The program should clarify if the City already offers the incentives described in the program, whether the approval of incentives is discretionary and include an implementation date for the incentives.

Program HP-1.12 (First Time Homebuyer Programs and Developers): This program should describe the implementation goal of the program, and whether any proactive outreach has or will be included as a part of this implementation.

Program HP-2.1 (Funding Priority to Extremely Low-income Affordable Housing): This program should describe how projects be prioritized, which programs are included, and also describe how often programs will be reviewed or added as a part of this program.

Program HP-2.3 (Collaboration with Non-Profit Affordable Housing Developers): This program should clarify when the RFP will be made available, as well as how often it will occur. The program should also include a proactive outreach component.

Program HP-2.4 (Flexible Development Standards): This program should clarify whether the incentives included in the program are currently in place, and if not, it should give a date as to when such incentives will be available. The program should include a specific timeline for implementation and a proactive outreach component.

Program HP-2.5 (Fee Reductions or Deferrals for Affordable and Special Needs Housing): This program should describe what determines eligibility and whether the eligibility determination is discretionary. The program should also strengthen the implementation language beyond “consider” being that fees were identified as a constraint. A specific timeframe for implementation should also be included.

Program HP-2.6 (Expedited Processing for Affordable Housing Projects): The program should be modified to include outreach to developers as well as how often.

Program HP-3.2 (Handyworker Program): The program should be modified to explain if there will be proactive outreach to residents, clarify if the program will occur annually, and include a specific timeframe for implementation.

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Program HP-3.3 (Property Rehabilitation Program): The program should be modified to provide proactive outreach to residents as well as often outreach will be conducted.

Program HP-3.6 (Workforce Housing Program): This program should include proactive outreach, a description of how often properties will be considered for the program, and specific implementation timing.

Program HP-4.2 (Monitoring of Codes and Ordinances to Remove Barriers): The program should be revised to include an implementation component and should discuss if codes and ordinances be revised, and how often they will be monitored.

Program HP-4.3 (Homeless Case Management): The program timeframe should be revised to state how often the City will apply for financial assistance.

Program HP-4.10 (Proactive Community Preservation): The program should describe how repairs and maintenance are funded, quantify how many houses will be assisted by the program (e.g. is it only available in listed neighborhoods?), as well as specify how often program activities will occur.

2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single- room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)

As noted in Finding B4, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types.

While the element includes programs to assist in the development of very low-, low-, and moderate-income households, it must also include a program(s) to assist in the development of housing for all special needs households (e.g., elderly, homeless, farmworkers, persons with disabilities, female-headed households). Program actions could include proactive outreach and assistance to non-profit service providers and developers, prioritizing some funding for housing developments affordable to special

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needs households and offering financial incentives or regulatory concessions to encourage a variety of housing types.

4. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)

As noted in Findings B5 and B6, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints. In addition, the following programs must be revised:

Program HP-4.4 (Housing for Persons with Disabilities): The program should describe how the City will encourage development and whether the offered incentives are already in place. It should also describe any proactive outreach plans for developers, and how often funding for the program will be sought.

Program HP-4.7 (Administrative Process for Reasonable Accommodations): This program should be modified to eliminate fees for applicants in the reasonable accommodation process.

5. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).)

As noted in Finding B1, the element must include a complete analysis of AFFH. The element must be revised to add goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, metrics and milestones as appropriate and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection. Currently the element addresses AFFH in Program HP-4.12. while this program includes some action items, many are vague and include actions that will only be considered. Program HP-4.12 must also include implementation components, timeframes, responsible parties, as well as metrics and milestones. In addition, Program 5A should also describe how all the City’s housing programs comply with and further the requirements and goals of Government Code

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section 8899.50, subdivision (b). Lastly, Program HP-4.6 (Fair Housing Programs) should describe how often training and outreach be provided.

6. The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (Gov. Code, § 65583, subd. (c)(6).)

Program HP-3.5 (Preservation of At-Risk Housing) should include proactive outreach to owners at least three years before expiration of affordability to inform owners of state preservation notice law requirements (Gov. Code Sections 65863.10, 65863.11, 65863.13). It should also assist in outreach to qualified entities with potential interest to try and maintain affordability levels and clarify how often funding will be monitored.

7. Develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate-income households. For purposes of this paragraph, “accessory dwelling units” has the same meaning as “accessory dwelling unit” as defined in paragraph (4) of subdivision (i) of Section 65852.2. (Gov. Code, § 65583, subd. (c)(7).)

Programs must be expanded to include incentives to promote the creation and affordability of ADUs. Examples include exploring and pursuing funding, modifying development standards and reducing fees beyond state law, increasing awareness, pre-approved plans and homeowner/applicant assistance tools. In addition, given the City’s assumptions for ADUs exceed recent trends, the element should include a program to monitor permitted ADUs and affordability every other year and take appropriate action such as adjusting assumptions or rezoning within a specified time period (e.g., six months).

D. Quantified Objectives

Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)

Quantified objectives should take into account the impact of all programs on the estimated number of housing units to be constructed. Additionally, the element must include the number of ELI units for new construction in the quantified objectives analysis.

E. Public Participation

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Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(8).)

While the City made effort to include the public through workshops and surveys, moving forward, the City should employ additional methods for public outreach efforts to include all economic segments of the community, particularly lower-income and special needs households and neighborhoods with higher concentrations of lower-income and special needs households. For example, the City could conduct targeted stakeholder interviews or establish a committee representative of lower-income and special needs households in future public outreach efforts. In addition, the element must clarify when the draft was made available to the public. If the City did not make the draft available to the public prior to submitting to HCD, the City has not yet complied with statutory mandates to make a diligent effort to encourage the public participation in the development of the element and it reduces HCD’s ability to consider public comments in the course of its review. The availability of the document to the public and opportunity for public comment prior to submittal to HCD is essential to the public process and HCD’s review. The City must proactively make future revisions available to the public, including any commenters, prior to submitting any revisions to HCD and diligently consider and address comments, including making revisions to the document where appropriate. HCD’s future review will consider the extent to which the revised element documents how the City solicited, considered, and addressed public comments in the element. The City’s consideration of public comments must not be limited by HCD’s findings in this review letter.

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Attachment: HCD Findings Letter (Housing Element and Safety Element Update) Attachment
City Responses to HCD Letter
Matrix
Master Case 21-088

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Draft City of Santa Clarita Responses to HCD Letter Matrix City of Santa Clarita’s 6th Cycle (2021-2029) Draft Housing Element

HCD Comment Response
A. Review and Revision
A thorough program-by-program review is necessary to
evaluate City's performance in addressing housing goals.

While the element generally describes the results of the prior element’s programs, the element must also provide an explanation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness). Programs should be revised as appropriate to reflect the results of this evaluation. The element should also be revised as follows:

Added new section 1.14.2 elaborating further on the
City’s effectiveness in meeting the housing needs of
special needs populations

Program H 1.1 (Affordable Housing Density Bonus): The
analysis should explain why the program was not
advertised, and how the new program will provide adequate advertising to make it more successful in the current
housing element.

Additional information was added related to program
implementation and lessons learned into Table 7: 2013-
2021 Housing Element Program Implementation Status
and to 1.14.4 Lessons Learned

Program H 1.5 (Inclusionary Housing Program- Mixed
Income Housing): Analysis of this program should include an explanation of why this program was deemed infeasible, as well as why the updated iteration of the program will be more successful.

Additional information was added related to program
implementation and lessons learned into Table 7: 2013-
2021 Housing Element Program Implementation Status
and 1.14.4 Lessons Learned. Based on this analysis,
Program HP-1.5 was revised to better reflect the work
that must occur prior to reconsideration of an inclusionary program (see new Program HP-1.7)
Special Needs Populations: As part of the review of
programs in the past cycle, the element must provide
cumulative evaluation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness).

Added new section 1.14.2 elaborating further on the
City’s effectiveness in meeting the housing needs of
special needs populations, including a cumulative
evaluation.

B. Housing Needs, Resources, and Constraints

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1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of
Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)
In general, all subsections of the Assessment of Fair
Housing now include additional data and analysis. Each
subsection now concludes with a list of contributing
factors and, where fair housing issues are identified in the assessment, the issues are linked to policies,
programs, and specific actions that address the identified issues.

Enforcement & Outreach: The element generally describes past outreach efforts and fair housing services with the Housing Rights Center (HRC). However, largely, the
element does not address this requirement. For example, the element describes outreach from 2019 but provides no information on the results of that outreach and how it relates to affirmatively furthering fair housing (AFFH). Also, the element contains little information on fair housing
enforcement nor local knowledge from the fair housing
service provider. Enforcement should include data and
evaluation (e.g., characteristics of complaints) of any past or current fair housing lawsuits, findings, settlements,
judgements, and complaints as well as compliance with fair housing laws and a description of ongoing outreach. The analysis could also evaluate data and the results from any fair housing testing
Additional information was added under 4.5.2 Fair
Housing Services and Enforcement at a Local Level to
explain compliance with fair housing laws, how the City provides fair housing services, and an overview of fair housing outreach methods.

Additional information was added under 4.5.2 Fair
Housing Discrimination Complaints including a table of
fair housing complaints, cases, findings, and outcomes
from 2017-2021 based on data from HRC (the City’s fair
housing service provider) and local knowledge from City staff and the City Attorney.

Additional information was added under 4.5.2 Public
Outreach including a complete write up from HRC (local
knowledge) that describe the results of outreach efforts and how it relates to affirmatively furthering fair housing.

Integration and Segregation: The element provided some
data on integration and segregation across racial groups, familial status, disabilities, and income, but the element must discuss and analyze this data for trends over time and patterns across areas such as census tracts. Additionally, it must evaluate patterns at a regional basis, comparing the City to the region.

Additional information was added under 4.5.3
Segregation and Integration Patterns and Trends to
analyze data over time, across census tracts, and
regionally.

New analysis, maps, and tables have been included to
produce a more robust assessment of the trends and
patterns related to the integration and segregation of
populations across racial groups, familial status,
disabilities, income, and poverty statuses.

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The combination of the R/ECAP and areas of affluence
analyses will help guide goals and actions to address fair housing issues. The analysis should evaluate the patterns and changes over time at a local (e.g., neighborhood to neighborhood) and regional level (e.g., city to region).

Additional information was added under 4.5.6
Racially/Ethnically Concentrated Areas of Poverty and
Affluence including maps and analysis discussing
patterns and changes over time at the local and regional levels

This same methodology should be employed to access to
economic opportunity throughout the City. Access to
economic opportunity analysis should also include
information on job proximity and employment trends in
relation to other factors such as patterns of segregation and poverty. In addition, the education analysis should include a map to support the analysis. The environmental analysis should address place-based strategies for Newhall and
Canyon Country.

Additional information was added under 4.5.4 Disparities in Access to Opportunities, including:
-HUD opportunity index values from 2019 A.I.,
-Additional mapping and analysis of transit opportunities with data about ride-dependent populations from 2019
Transit Development Plan,
-Economic opportunity analysis includes job proximity
and additional discussion about how it relates to findings from segregation trends analysis, and how major
employers are serviced by public transit
-Additional mapping added to support educational
opportunity analysis
- Place-based strategies for Newhall and Canyon
Country are included in Fair Housing Program HP- 4.11
and discussed in the analysis
Disproportionate Housing Needs including Displacement
Risks: The element includes some local and county data on cost burdened households (overpayment) and overcrowding (pp. 3-52 to 3-57). However, the element must evaluate
trends and patterns within the City for these subtopics. The element must also provide a local and regional analysis for substandard housing and homelessness. In addition, the
element briefly mentions displacement but must still provide Additional information was added under 4.5.5
Disproportionate Housing Needs including:
-Analysis of overpayment and overcrowding across
census tracts within the City
-Local and regional analysis of substandard housing and homelessness
- Analysis of areas at risk of displacement from
investment and disaster

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data, analysis and conclusions, including analysis of
displacement risk relating to disinvestment and disasters.

Site Inventory: The element must include an analysis
demonstrating whether sites identified to meet the RHNA are distributed throughout the community in a manner that affirmatively furthers fair housing. A full analysis should address the income categories of identified sites with
respect to location, the number of sites and units by all income groups and how that effects the existing patterns for all components of the assessment of fair housing (e.g., segregation and integration, access to opportunity). The element should also discuss whether the distribution of sites improves or exacerbates conditions. If sites exacerbate conditions, the element should identify further program actions that will be taken to mitigate this (e.g., anti- displacement strategies).

Sites have been evaluated and analyzed in relationship
to the findings of each subsection of the Assessment of Fair Housing. The sites are analyzed in such a way to
demonstrate that their distribution affirmatively furthers fair housing. Improvement and exacerbation of conditions is discussed.

Local Data and Knowledge, and Other Relevant Factors:

The element must include local data, knowledge, and other relevant factors to discuss and analyze any unique
attributes about the City related to fair housing issues. The element should complement federal, state, and regional
data with local data and knowledge where appropriate to capture emerging trends and issues, including utilizing knowledge from local and regional advocates and service providers. Also, the element must include other relevant factors that contribute to fair housing issues in the
jurisdiction. For instance, the element can analyze historical land use and investment practices or other information and demographic trends.

Additional information is included throughout the
Assessment of Fair Housing that includes local data
sources and local knowledge to further the discussion
and analysis of Fair Housing in Santa Clarita. This is
summarized in 4.5.2 Local Data, Knowledge, and Other
Relevant Factors
Contributing Factors to Fair Housing Issues: While the
element identifies contributing factors to fair housing issues, it should prioritize these factors to better formulate policies and programs and carry out meaningful actions to AFFH.

The element should link contributing factors to specific programs where possible. In addition, many of the
strategies “consider” actions but do not provide
Contributing factors have been identified at the
conclusion of each subsection.

Contributing factors are linked to specific, actionable programs.

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implementation components to mitigate the fair housing
issues identified in the analysis.

Contributing factors are now summarized and prioritized under section 4.5.1
Goals, Actions, Metrics, and Milestones: The element must be revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome
identified patterns and trends. Actions must have specific commitment, metrics and milestones as appropriate, and
must address housing mobility enhancement, new housing
choices and affordability in high opportunity areas, place- based strategies for community preservation and
revitalization and displacement protection.

Goals and actions have been added and modified to
address identified needs, and additional analysis has
been provided. Actions are linked to contributing factors and have specific commitments, metrics, and milestones
to address fair housing issues.

2. Include an analysis of population and employment
trends and documentation of projections and a
quantification of the locality's existing and projected needs for all income levels, including extremely low-income
households. (Gov. Code, § 65583, subd. (a)(1).)

Extremely Low-Income (ELI) Households: The element
incudes some basic information regarding ELI households such as the methodology of calculating the number of
projected ELI households for the 6th cycle RHNA. However, the element should also clearly state the projected number of ELI households. Additionally, given the unique and
disproportionate needs of ELI households, the element must include analysis to better formulate policies and programs.

Element now includes a quantification and analysis of
extremely low-income housing needs within section

1.9.2, Household Incomes and Housing Affordability, and references existing analysis in section 4.5 that led to the formation of policies and programs to address needs of
ELI households.

The section also references these programs:

Policy H2.2: Funding Preference to Extremely-Low
Income Housing
Policy H2.10: Affordable Housing Incentives
Program HP-2.4: Continuing Affordability
Program HP-2.5: Collaboration with Non-Profit Affordable Housing Developers
Program HP-2.6: Fee Reductions or Deferrals for
Affordable and Special Needs Housing

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Element now includes information on rental costs in
current market conditions, as well as a comparison
between the City’s rental costs and those of the region.

This section uses market-based sources in addition to
American Community Survey data.

Overpayment: While the element identifies the total number of households overpaying for housing, it must also quantify and analyze the number of households overpaying by
tenure (i.e., renter and owner), including lower-income households.

Element now includes additional analysis on
overpayment and quantification of households
overpaying by tenure.

3. Include an analysis and documentation of household
characteristics, including level of payment compared to ability to pay, housing characteristics, including
overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)

Housing Conditions: The element identifies the age of the housing stock (p. 53 & 54). However, it must include
analysis of the condition of the existing housing stock and estimate the number of units in need of rehabilitation and replacement. For example, the analysis could include
estimates from a recent windshield survey or sampling,
estimates from the code enforcement agency, or information from knowledgeable builders/developers, including non-
profit housing developers or organizations.

Added text and data table into section 1.10.3 on Housing Conditions with data, analysis, and identified actions to address need.

4. An inventory of land suitable and available for
residential development, including vacant sites and sites having realistic and demonstrated potential for
redevelopment during the planning period to meet the
locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
The City has a regional housing need allocation (RHNA) of 10,031 housing units, of which 5,131 are for lower-income

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households. To address this need, the element relies on vacant and nonvacant sites, including sites in Specific Plan Areas and within Mixed- Use areas. To demonstrate the
adequacy of these sites and strategies to accommodate the City’s RHNA, the element must include complete analyses:

Progress in Meeting the RHNA: The City’s RHNA may be
reduced by the number of new units built since June 30, 2021. The element indicates (p. 57) 9,135 planned,
approved pending units toward the RHNA, but it must
indicate where each project is in the development process.

It must also demonstrate the affordability of the units.

Specifically, the element must assign these units to the various income groups based on actual or anticipated sales price or rent level of the units or other mechanisms ensuring affordability (e.g., deed-restrictions) and demonstrate their availability in the planning period.

Table 11 identifies whether projects are entitled, pending, or annexed and entitled. Footnotes have been added to
this Table to provide additional information about where each project is in the development process. Information on the affordability mechanism of the two projects with lower-income units has been added to the paragraph
before the table, and information demonstrating the
availability of the units in the planning period was added to the paragraph after the table.

Sites Inventory: The element must include the general plan designation for all sites listed in the sites inventory. In addition, the element should include a map of the sites.

Appendix D (sites inventory) has been updated to include General Plan Designations. Element contains a map of
all sites in inventory. Additional maps have been added to reflect the location of sites relative to AFFH Resource Areas and Fire Hazard Severity Zones
Realistic Capacity: The element (p. 58) mentions an
assumption of 75 percent of maximum allowable densities to calculate residential capacity on identified sites and includes a few examples of recent developments. However, the element should include supporting information on typical densities of existing or approved residential developments at a similar affordability level for all affordability levels. For example, the element could clearly list other recent projects, the zone, acreage, built density, allowable density, level of affordability and presence of exceptions such as a density bonus. The realistic capacity analysis should provide
examples to support development assumptions for all
income levels and must also clarify whether the
assumptions are for both vacant and nonvacant sites. The estimate of the number of units for each site must be

Section 3.4 has been revised to include more information on the criteria used to calculate realistic residential capacity, including improvement to land value ratio,
existing use vs zoned use, age of structure, floor-to-area ratios, and ownership patterns.

Table 11 in the Element lists densities and percent of
maximum density achieved for planning, approved, and
pending projects, along with zoning, residential units, and level of affordability for each project.

A new section has been added about redevelopment
trends and describes recently built, under construction, and entitled projects, including unit total, acreage, built

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adjusted as necessary, based on the land use controls and site improvements, typical densities of existing or approved residential developments at a similar affordability level in that jurisdiction, and on the current or planned availability and accessibility of sufficient water, sewer, and dry utilities.

In addition, the element appears to assume residential
development on sites with zoning that allow 100 percent nonresidential uses. The element must account for the
likelihood of nonresidential uses. For example, the element could analyze all development activity in these
nonresidential zones, how often residential development occurs and adjust residential capacity calculation, policies and program accordingly.

The element should include analysis based on factors such as development trends, performance standards or other
relevant factors.
density, percent of maximum density achieved, other
uses, previous uses, zones, and project photos.

Recycling trends have been included that show projects
developed during the 5th Cycle at all income levels.

Recycling trends show 100% residential development in
nonresidential zones, indicating a strong trend for this the projected residential uses occurring. This analysis of
100% residential development on non-residential sites,
combined with the conservative estimates used to project future development on these sites, indicate that an
additional reduction in residential capacity calculations is not necessary.

Suitability of Nonvacant Sites: The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. The description of existing uses should be sufficiently detailed to facilitate an analysis demonstrating the potential for additional development in the planning period. In addition, the element needs to analyze the extent that existing uses may impede additional residential
development. The element can summarize past
experiences converting existing uses to higher density
residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current
information on development trends and market conditions in the City and relate those trends to the sites identified. The element could also consider indicators such as age and
condition of the existing structure expressed developer interest, low improvement to land value ratio, and other factors.

A new section has been added about redevelopment
trends; the section describes recently built, under
construction, and entitled projects, including unit total, acreage, built density, percent of maximum density
achieved, other uses, previous uses, zones, and project photos.

Detailed existing use descriptions were added to the
Sites Inventory. As discussed in Section 3, the Housing Element takes into consideration a wide range of factors in its nonvacant suitability analysis.

Additionally, 58% of the City’s Lower income remaining
need and 100% of the City’s moderate income remaining
need is accommodated on vacant sites. All of the City’s Above Moderate RHNA is accommodated through RHNA
credits. Therefore, existing uses of nonvacant sites is not an impediment to additional residential development.

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Small and Large Sites: Sites larger than ten acres in size or smaller than a half-acre in size is deemed inadequate to accommodate housing for lower-income households unless
it is demonstrated, with sufficient evidence, that sites are suitable to accommodate housing for lower-income
households. The element must provide specific examples of sites with similar densities and affordability and should relate these examples to the sites identified to
accommodate the RHNA for lower-income households to
demonstrate that these sites can adequately accommodate the City’s lower-income housing need. Based on a complete analysis, the City should consider adding or revising
programs to include incentives for facilitating development on small sites.

The Element has been updated to clarify that there are
no sites in inventory that are larger than 10 acres; where larger parcels exist, only a 10-acre portion is used to calculate development potential. The City does regularly develop housing on sites of greater than 10 acres (see
Villa Metro, page 98). The analysis has also been
updated to provide examples of recent housing
developments on sites of about ½ acre and less (Kansas
Street Apartments; Valley Street; and Salazar 11th Street (pending), pages 98-104), and those examples are now
tied back to similar sites in inventory. Based on this
analysis, the City has concluded that sites of ½ acre or less are regularly developed with housing and that
additional programs to incentivize development on small sites will not be necessary.

Replacement Housing Requirements: If the sites inventory identifies sites with existing residential uses, it must identify whether the current residential uses are affordable to lower- income households or describe whether the additional
residential development on the site requires the demolition of the existing residential use. For nonvacant sites with existing, vacated, or demolished residential uses and
occupied by, or subject to an affordability requirement for, lower-income households within the last five years there must be a replacement housing program for units affordable to lower-income households. (Gov. Code, § 65583.2, subd. (g)(3).) Absent a replacement housing program, these sites are not adequate sites to accommodate lower-income
households. The replacement housing program has the
same requirements as set forth in Government Code
section 65915, subdivision (c)(3). The housing element
must be revised to include such analysis and a program, if necessary.

There are very few sites in inventory that have existing residential uses, and these are limited to single family homes only. A Program has been added (Program HP-

2.7) to require replacement housing pursuant to State
law:

HP-2.7: Replacement Housing Program for Selected
Sites
The City will require replacement housing units subject to the requirements of Government Code Section 65915,
subdivision (c) (3) on all sites identified in the 6th cycle sites inventory when any new development occurs on a
site in the housing sites inventory if that site meets the following conditions: 1) currently has residential uses or within the past five years has had residential uses that have been vacated or demolished; and 2) was subject to
a recorded covenant, ordinance, or law that restricts
rents to levels affordable to persons and families of low or very-low income, or 3) subject to any form of rent or price control through a public entity’s valid exercise of its

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police power, or 4) occupied by low or very-low income
households.

Prior to the end of 2022, Community Development
Department staff will provide a pop-up “Notice” in Accela for each inventoried parcel subject to these requirements.

A training session will be held to ensure that all staff are aware of applicable replacement housing requirements
for all sites occupied by residential uses.

Sites Identified in Multiple Planning Periods: The element must include a program for vacant sites identified in two of more consecutive planning periods’ housing elements or
nonvacant sites identified in a prior housing element, that are currently identified to accommodate housing for lower income households. The program must be implemented
within the first three years of the planning period and commit to zone for the following:
• sites must meet the density requirements for
housing for lower income households, and
• allow by-right approval for housing developments
that include 20 percent or more of its units affordable to lower income households. (Gov. Code, § 65583.2, subd.
(c).)
A new Program HP-1.13 has been added to address this
requirement, as follows: Program HP-1.13: Sites
Identified in Multiple Planning Periods:

Government Code § 65583 requires analysis and
justification of the sites included in the sites inventory of the City’s Housing Element. The Housing Element may
only count non-vacant sites included in one previous
housing element inventory and vacant sites included in
two previous housing elements if the sites are subject to a program that allows affordable housing by right. Some sites within this Housing Element were used in previous cycles and this program is included to address the by-
right approval requirement. Per Government Code §
65583, the use by right of these sites during the planning period is restricted to developments in which at least 20 percent of the units in the development are affordable to lower income households, provided that these sites have sufficient water, sewer, and other dry utilities available and accessible or that they are included in an existing general plan program or other mandatory program or
plan to secure sufficient water, sewer, dry utilities supply to support housing development.

Prior to the end of 2022, Community Development
Department staff will provide a pop-up “Notice” in Accela for each inventoried parcel subject to these requirements.

The Notice will prompt staff to not require a Conditional Use Permit application for a residential development
project on that site if at least 20% of the units are

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provided as affordable. A training session will be held to ensure that all staff are aware of the by-right allowances for projects providing at least 20% of units as affordable on these specific sites. Within the first three years of the planning period, a future amendment to the Unified
Development Code and/or creation of an overlay zone
will be completed to ensure compliance with Government
Code § 65583.2(c).

Additional actions, if necessary, should be taken in a timely manner (e.g., within six months). Finally, if necessary, the degree of additional actions should be in stride with the degree of the gap in production and affordability. For
example, if actual production and affordability of ADUs is far from anticipated trends, then rezoning or something similar would be an appropriate action. If actual production and affordability is near anticipated trends, then measures like outreach and marketing might be more appropriate.

ADU projections have been updated to reflect the “safe
harbor” average number of ADUs permitted annually
since 2018. With data now available for 2021, the
average now includes 2021 permits, resulting in an
average of 31.25 ADUs per year from 2018-2021. The
Housing Element now projects 31.25 ADUs per year, or
250 ADUs over the planning period, consistent with
HCD’s guidance to calculate a realistic estimate of
potential ADU development.

In addition, a new program (New Program number HP-

2.6) has been added to incentivize and promote
Accessory Dwelling Units, as follows:

Program HP-2.6: Provide for Accessory Dwelling Units
and Junior Accessory Dwelling Units (GC 65583, c (7))

Increase awareness of the by-right opportunities for
Accessory Dwelling Units and Junior Accessory Dwelling
Units by producing an informational brochure/handout, a simplified application, process, and a dedicated phone
number and/or email for questions about and assistance
with Accessory Dwelling Units by the end of 2022 in
order to promote the development of ADUs and JADUs.

Add an ADU page to the City’s website with all of the
above information, as well as with a link to the LA ADU website to provide information about permitting,

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assistance tools, financing and lending programs
(https://www.laadu.org/) by the end of 2023
Annually report out on the City’s successes in the
production of ADUs and JADUs with the City’s APR.

Availability of Infrastructure: The element includes some discussion on water and sewer providers in the City.

However, it must also clarify whether sufficient total water, sewer, and dry utility capacity (existing and planned) can accommodate the regional housing need for each income
category and include programs if necessary. In addition, the element must clarify when the two new sewer facilities will be available and whether the water reclamation plants (p. 109) are needed to accommodate wastewater to meet
RHNA over the planning period.

The Section on Infrastructure Considerations now
includes additional information from the local sanitation district on the availability of wastewater infrastructure and clarifies that there is sufficient infrastructure availability and capacity to meet the RHNA over the planning period.

Environmental Constraints: While the element generally
describes a few environmental conditions within the City (p. 64), it must relate those conditions to identified sites and describe any other known environmental or other
constraints that could impact housing development on
identified sites in the planning period.

The Section on Environmental Considerations now
describes identified sites in relation to flood, fire, and seismic hazard zones. New graphics are also included.

Zoning for a Variety of Housing Types:

Emergency Shelters: The element should describe the
development standards of the P/I zone that allows
emergency shelters by-right and must also describe the
characteristics and suitability of the zone. In addition, the element should describe how emergency shelter parking
requirements are in line with AB139/Government Code
section 65583, subdivision (a)(4)(A) or include a program as necessary.

The Element now describes the development standards
of the PI zone, parking requirements including
compliance with AB 139, and describes characteristics
and suitability of the PI and Homeless Shelter Overlay
zones where Emergency Shelters are allowed by right.

Transitional and Supportive Housing: The element includes some information on transitional housing (p. 70 & 97), but the City only allows the use in residential zoning districts.

Transitional housing and supportive housing must be
permitted as a residential use in all zones allowing
residential uses and only subject to those restrictions that The element now clarifies the State requirements and
references the program included to bring the City’s code into compliance:
“Program HP-2.1 is included in this Housing Element to
modify the City’s UDC to be compliant with the
requirements of Government Code Section 65583(a)(5)

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apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd. (a)(5).) The
element must add or revise programs to comply with the
statutory requirements.
as amended by SB 2 and Government Code 65651 as
amended by AB 2126.”

Permanent Supportive Housing: Supportive housing shall
be a use by-right in zones where multifamily and mixed
uses are permitted, including nonresidential zones
permitting multifamily uses pursuant to Government Code section 65651. The element must demonstrate compliance
with this requirement and include programs as appropriate. (AB 2162)
The element now clarifies the State requirements and
references the program included to bring the City’s code into compliance:
“Program HP-2.1 is included in this Housing Element to
modify the City’s UDC to be compliant with the
requirements of Government Code Section 65583(a)(5)
as amended by SB 2 and Government Code 65651 as
amended by AB 2126”.

Low Barrier Navigation Centers: Low Barrier Navigation
Centers shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential
zones permitting multifamily uses pursuant to Government Code section 65660. The element must demonstrate
compliance with this requirement and include programs as appropriate.

The element now clarifies the State requirements and
references the program included to bring the City’s code into compliance.
“Program HP-2.1 is included in this Housing Element to modify the City’s UDC to be compliant with the
requirements of Government Code Section 65660 as
amended by SB 48.”

Employee Housing: The element must demonstrate zoning
is consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.), specifically, sections
17021.5 and 17021.6. Section 17021.5 requires employee
housing for six or fewer employees to be treated as a
single-family structure and permitted in the same manner as other dwellings of the same type in the same zone. Section 17021.6 requires employee housing consisting of no more than 12 units or 36 beds to be permitted in the same
manner as other agricultural uses in the same zone. The element should add programs as appropriate.

The element now clarifies the State requirements and
references the program included to bring the City’s code into compliance.

“The Employee Housing Act was amended by AB 107 in
2020, changing the definition of ‘agricultural employee housing’ and establishing new zoning, application, and
review requirements for agricultural employee housing.

Santa Clarita’s Unified Development Code currently does not include a definition for agricultural employee housing.

Program HP-2.1 is included in this Housing Element to
modify the City’s UDC to be compliant with the
requirements of the Employee Housing Act in Health and
Safety Code Sections 17021.5 and 12021.6.”

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Manufactured Housing: Table 21 (p. 95) must clarify that manufactured housing is allowed as a single-family
residence if on a permanent foundation. If the zoning does not comply, a program should be added.

The element now clarifies the State requirements,
clarifies the City’s compliance with these requirements, and references where the Unified Development Code
provides relevant development standards.

“The Santa Clarita UDC includes requirements and
development standards for manufactured homes on
residential lots in sections 17.42 and 17.57.020Q, which clarifies that manufactured homes shall be installed on permanent foundations on individual lots. The City allows manufactured housing as a single-family residence
subject to the development standards in the UDC, is
compliant with Section 65852.3 of the California
Government Code and does not pose a constraint to
development.”
Accessory Dwelling Units (ADUs): After a cursory review of the City’s ordinance, the department discovered several areas which were not consistent with State ADU law. This includes, but is not limited to, not allowing ADUs by right in all residential zones, and side and rear setback
requirements. The Department will provide a complete
listing of ADU non-compliance issues under a separate
cover. As a result, the element should add a program to update the City’s ADU ordinance in order to comply with State law. For more information, please consult HCD’s ADU Guidebook, published in December 2020, which provides
detailed information on new state requirements surrounding ADU development
Upon HCD completing its review of the City’s ADU
ordinance, applicable revisions will be completed.

Additionally, a Program has been added to update the
City's Accessory Dwelling Unit Ordinance as an action
item under Program HP-2.1 :
“Update Accessory Dwelling Unit Ordinance pursuant to
HCD’s ADU Guidebook, including allowing such units by-
right in all residential zones and reduction of side and rear setbacks, as well as to reflect changes in these laws made by AB 2345.”

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developers, and local processing and permit procedures.

The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from
meeting its share of the regional housing need in
accordance with Government Code section 65584 and from
meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7).

Land Use Controls: The element must identify and analyze all relevant land use controls impacts as potential
constraints on a variety of housing types. The analysis should analyze land use controls independently and
cumulatively with other land use controls. The element must specifically include requirements related to heights, set- backs, lot coverage, unit sizes and limits on allowable densities. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and
include programs to address identified constraints. In
addition, the element discusses parking requirements
including enclosed spaces, two spaces for one-bedroom
units for multifamily development, high guest parking
requirements, and specific parking standards for residential care services. These parking requirements must be
analyzed as a constraint and addressed with a program.

Additional information has been provided on lot
development standards, typical densities of development, parking requirements, and density bonus programs.

A section has been added at the end of the previous
development standards section within Section 4.2.2
analyzing the impact of land use controls on housing
development, including an analysis of their cumulative
impact.

Additional text has been added to Parking Requirements
section of Constraints Analysis:

AB 2345 (2020) made significant changes to the State
Density Bonus Law for projects providing affordable
units, including requirements for the granting of a larger density bonus, more incentives, and reduced parking
requirements. Programs HP-2.1 and HP-2.3 obligate the
City to review and amend its UDC and Specific Plans as
necessary to comply with new State laws, and Program
HP-2.2 obligates the City to create and publish
explanatory documents to delineate the different parking requirements for muti-family housing projects, including those providing affordable units and those located close to transit.

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Fees and Exaction: The element should clarify if all fees are the same for single and multifamily developments, and
whether multifamily fees listed are per unit. In addition, the element must list fees for subdivisions, specific plans, and environmental review. The element should describe typical total fees for single-family and multifamily development as a percent of the total cost of the development. Lastly, the element identifies impact fees as a constraint and therefore must add a program to mitigate it.

The Element clarifies that fees are different for single and multifamily development. Table 26 now shows which fees
are currently charged by unit and by area.

Subdivision fees are included under tentative tract map and tentative parcel map fees. Specific Plan fees are
shown with Zone Change with General Plan Amendment.

Environmental review fees are shown under
Environmental Impact Report, and Environmental Initial
Study. These fees are all shown on Table 25: Santa
Clarita Development and Permitting Fees.

The Element now has information from stakeholder
outreach identifying that the fees as a percentage of total development costs do not pose a constraint.

The Element also includes corrections to clarify that
school fees are lower for multifamily development than
for single family. This new lower total corroborates the stakeholder feedback that these fees do not pose a
constraint and the Element is updated to reflect that.

The Element also now includes and references Program
HP-2.2 related to development impact fees.

4.4.2) related to procedures for a typical single family and multifamily development, including approval bodies,
public hearings, and approval findings, and analyses the impacts of these requirements. The Element now clarifies that permits can be processed concurrently with other
entitlements, that processing times are similar for single and multifamily developments, and amends Table 27 to
clarify that the reasonable accommodation timeline is
shorter than previously stated in the original HCD Draft

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long length of time to process reasonable accommodation and conditional use permits. Additionally, while the element provides a description (p. 104) of the Conditional use permit (CUP) required for housing developments, it must describe and analyze the CUP process, including typical findings and approval procedures by zone and housing type. The
analysis must evaluate the processing and permit
procedures’ impacts as potential constraints on housing supply and affordability. Lastly, the element should describe the process and findings for a development review permit.

Housing Element. Program HP-4.6 commits the City to
reducing or eliminating its processing fee for Reasonable Accommodation requests.

The added section on permitting processes for typical
single and multifamily developments now describes the
process and findings for the development review permit
and the CUP, and the impacts of these processes are
analyzed.

Design Review: The element must describe and analyze the design review guidelines and process, including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and guidelines improve development certainty and mitigate cost impacts. The
element must demonstrate this process is not a constraint or it must include a program to address this permitting requirement, as appropriate.

Information and analysis have been provided within the
Local Processing and Permitting Procedures (Section

4.4.2) to describe the Design Review process and
concludes that use of the City’s adopted guidelines
provide certainty to developers and a faster approval
time, which in turn reduces costs. The design review
process is not long or burdensome, is performed at a
staff level, and does not pose a constraint.

On/Off-Site Improvements: The element must identify
subdivision level improvement requirements, such as
minimum street widths (e.g., 40-foot minimum street width) and analyze their impact as potential constraints on housing supply and affordability.

Text has been added to Section 4 to describe and
analyze subdivision level improvement requirements,
including street widths. While total right-of-way for large public residential arterials and collectors may exceed the requirements made by some other communities, in Santa
Clarita’s case there are few remaining parcels that would accommodate large residential streets with parkways.

Most remaining subdivisions are anticipated to consist of mainly local residential streets, which have a lesser right of way requirement, or of exempt private streets such as occur with planned developments. Additionally, the City’s UDC allows the City Engineer to grant a modification to the required road dedication and relieve the applicant
from compliance with all or a portion of the provisions if certain conditions are met, if the construction of

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additional roadway improvements is deemed to be
unnecessary, or if deems the requirement for additional improvement creates an unreasonable hardship.

Constraints on Housing for Persons with Disabilities: The element excludes group homes for seven or more persons
from some residential zones and subjects the use to a
conditional use permit, unlike other similar uses. The
element should specifically analyze these constraints for impacts on housing supply and choices and approval
certainty and objectivity for housing for persons with
disabilities and include programs as appropriate. The
element also requires a development review permit, not an administrative permit for group homes with six or fewer persons. The element must include a program to revise the requirements for group homes. Additionally, the element briefly describes its reasonable accommodation procedures, but it should also describe the process and decision-making criteria such as approval findings and analyze any potential constraints on housing for persons with disabilities. The element should also provide a clear definition of “family”.

Lastly, the element must clarify whether specific plans allow for residential care facilities as well as transitional and supportive housing.

Details and analysis have been added about permitting
requirements for community care facilities (group homes for 7+ persons) and concludes that they do not pose a
constraint on housing for persons with disabilities and are necessary to ensure that these facilities are located in suitable areas with appropriate services and amenities.

Table 21 in the Draft HCD submittal inaccurately stated that a Development Review Permit is required for a group home for 6 or fewer persons. The Element has now been
updated to correctly state that the same administrative permit required for a single-family home is required for construction of a group home for 6 or fewer persons. A
change of use from a single-family home to a group
home for 6 persons or less is permitted by right.

The Element now describes the process and finding for
Reasonable Accommodations requests and
Requests for Reasonable Accommodations are subject
to an administrative permit fee ($872) and approved
through an administrative permit process that takes
approximately two weeks to process. Upon review of an
application, the Director of Community Development will grant the request based on the following findings.

That the requested accommodation is intended to be
used by an individual with a disability who resides or will reside on the property
That the requested accommodation is necessary to
afford an individual with a disability equal opportunity to use and enjoy a residential use
The requested accommodation will not impose an undue
financial or administrative burden on the City; and that

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the requested accommodation will not require a
fundamental alteration in the nature of the land use and zoning.

While the process for requesting a reasonable
accommodation is administrative and does not pose a
constraint, the permit fee for these requests may pose a constraint to housing for persons with disabilities.

Program HP-4.6 to reduce or remove this fee has been
now been included to address this constraint.

The Element now provides a clear definition of family:

The City’s Unified Development Code uses the following
definition of family:
“Family” means one (1) or more individuals living
together as a single housekeeping unit in a single
dwelling unit. “Family” shall also mean the persons living together in a licensed “residential facility” as that term is defined in California Health and Safety Code Section
1502(a)(l), which services six (6) or fewer persons,
excluding staff.”

The element now includes additional information in the
Specific Plan discussion about allowed uses in specific and corridor plan areas, and references the new program added to address any discrepancies between existing
allowed uses and those that must be allowed under State law:

As the City contains many specific and corridor plan
areas and new State laws have been past regarding
zones where certain uses must be allowed by right,
Program HP-2.3 has been included to review these plans
and modify where necessary to comply with State law,
including those related to the residential care facilities, transition and supportive housing, emergency shelters,
low barrier navigation centers.

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Zoning, Development Standards and Fees: The element
must clarify compliance with new transparency
requirements for posting all zoning, development standards and fees on the City’s website and add a program to
address these requirements, if necessary.

Location: Permitting Procedures within Governmental
Constraints Planning and Zoning Programs and Program
HP-2.2

The element now describes new transparency
requirements for posting all zoning, development
standards and fees on the City’s website and references the program included to bring the City’s code into
compliance.

Local Ordinances: The element must specifically analyze locally adopted ordinances such as short-term rental
ordinances that directly impact the cost and supply of
residential development. The analysis should demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need and from meeting the need for housing for persons
with disabilities, supportive housing, transitional housing, and emergency shelters.

The Element has been updated to describe and analyze
local ordinances and provisions related to mixed use,
senior residences in mobilehome parks, job creation, and development standards. The analysis concludes that the
locally adopted ordinances reduce constraints to housing by enhancing affordability, and simplify the development application process by providing clear information on
development standards and processes.

The analysis has been updated in 4.3.7 to clarify that the City does not have a growth management ordinance or a
vacation rentals ordinance.

SB 35 Streamlined Ministerial Approval Process: The
element must clarify whether there are written procedures for the SB 35 (Chapter 366, Statutes of 2017) Streamlined Ministerial Approval Process and add a program to address these requirements.

Local Permit Procedures section now includes:
“In addition, Program HP-2.2 will ensure the City
develops and publishes written standards for the SB 35
Streamlined Ministerial Process."

Program HP-2.2 has been added as follows:
“The City will develop an SB 35 application process,
including the pre-application and the procedure that will be used to provide a streamlined ministerial approval
process to qualified residential and mixed-use
development projects. The written procedures and
checklists shall be developed and made available on the City’s website no later than July 30, 2022. The City will

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develop Objective Design and Development Standards
for multi-family and mixed-use projects by July 30, 2023."

6. An analysis of potential and actual nongovernmental
constraints upon the maintenance, improvement, or
development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by
subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the
construction of a locality’s share of the regional housing need in accordance with Government Code section 65584.

The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing. (Gov.

Code, § 65583, subd. (a)(6).)

Land Costs: The element describes the median home value but must list the cost of land zoned for single and multifamily developments.

The “Land Costs” section of the 4.4 Housing Constraints analysis has been expanded to provide the cost of vacant land zoned for residential uses, including an estimated cost for land zoned for single and multifamily
development.

Approval Time and Requests Lesser Densities: The element must be revised to include analysis of requests to develop housing at densities below those anticipated, and the length of time between receiving approval for a housing
development and submittal of an application for building permits that potentially hinder the construction of a locality’s share of the regional housing need. The analysis should also include efforts by the City to address identified
nongovernmental constraints.

Text has been added to 4.4.2 to provide this analysis:
“The time between entitlement approval and submittal of building permit applications is developer-driven and
varies between projects. Motivated developers can
access comments and draft Conditions of Approval
through the City’s Development Review Committee
process and in some cases, developers have applied for
building permits at their own risk prior to final project approvals. In the case of the recently approved Golden
Triangle apartment project (164 units), the applicant
submitted a rough grading permit application and final

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map approximately one month following the entitlement
of the project. The 2015 Kansas Street 10-unit multi-
family complex submitted building permit applications
within a month of entitlement approval. In some other
cases, especially those involving a subdivision map,
developers who have received a project entitlement do
not build right away but seek applicable extensions of the entitlement before submitting for building permits.”

7. Analyze any special housing needs such as elderly;
persons with disabilities, including a developmental
disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).):

While the element quantifies (Appendix A) the City’s special needs populations, it must also analyze their special
housing needs. For a complete analysis of each population group, the element should discuss challenges faced by the population, the existing resources to meet those needs
(availability senior housing units, number of large units, number of deed restricted units, etc.), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps.

In addition to quantification of special needs populations within Appendix A, Section 1.9.3 includes analysis and
information on resources available to meet needs. This
section has been expanded to include additional
analysis, additional resources, and identified proposed policies, and programs that address the identified needs.

8. Analyze the opportunities for energy conservation
with respect to residential development. (Gov. Code, §
65583(a)(8).)

The element must provide an analysis of opportunities for energy conservation in residential development. For
example, the element could describe the “green Santa
Clarita” program and could include incentives the City offers to encourage green building practices, or policies the City implements to encourage higher density developments and compact infill development, or passive solar design.

A new section (4.3.8) has been added to analyze
opportunities for energy conservation:

The City of Santa Clarita actively implements a variety of policies and programs that encourage green building
practices, higher density projects, compact infill
development and energy efficiency. These policies and
programs are found within the City of Santa Clarita’s
Unified Development Code (UDC), the implementation of
various specific and corridor plans, the City’s
implementation of the California Green Building Code,
and via the City’s Green Santa Clarita Program.

The City of Santa Clarita’s UDC defines specifications
and provides design standards for three distinct mixed

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use zones. Mixed use zones provide a combination of
design incentives for projects that include both
commercial and residential improvements. The design
incentives prescribe a mix of commercial square footage and allow for as many as 50 residential units per acre. All 3 of these mixed-use zones allow all-residential projects.

In addition to the mixed-use zones, the City has also
adopted several specific plans and two corridor plans.

Each of these provides design standards and
contemplates land uses that focus on improving
underutilized sites with more dense, compact infill
development, a rich mixture of uses, enhanced
pedestrian connectivity and access, and more efficient
traffic circulation.

For purposes of energy conservation, the City of Santa
Clarita fully implements the requirements of the California Green Building Code. This code standard roughly
equates to a LEED Silver certification for each new
residential structure permitted and built. Importantly, it requires each new single-family housing unit to have
roof-top solar panels fully installed prior to first
occupancy. Further, the City works closely with local
utilities and other partner agencies via the Green Santa Clarita program to provide energy efficiency upgrades
and incentives to residents. These programs can be
found at www.greensantaclarita.com.

9. Analyze existing assisted housing developments that
are eligible to change to nonlow- income housing uses
during the next 10 years due to termination of subsidy
contracts, mortgage prepayment, or expiration of use
restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).).

Orchard Arms is owned and operated by the County of
Los Angeles / Housing Authority of the County of LA.

Information has been provided in Section 4.3.6 to clarify that the Orchard Arms restrictions do not expire within the next 10 years, as it was built as conventional public housing and is considered affordable in perpetuity.

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The element must clarify when the use restriction for
Orchard Arms expires. If the restriction ends within the next 10 years, the element must include an at-risk analysis (Gov.

Code, § 65583, subd. (a)(9).).

Program 3.5 has been changed to address the
government code requirements for early notification
beginning 3 years prior to expiration.

C. Housing Programs

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

Code section 65583, subd. (c)(1-6), and to facilitate
implementation, programs should include: (1) a description of the City’s specific role in implementation; (2) definitive implementation timelines (i.e. month and year); (3)
objectives, quantified where appropriate; and (4)
identification of responsible agencies and officials.

Programs to be revised include the following:

Program HP-1.4 (Affordable Housing Density Bonus):

Program should clarify if the existing density bonus
ordinance will be updated and/or implemented by 2023. If not, the program should include a timeline of when the
ordinance will be updated. The portion of the program that will be “considered” should also be modified to include a more discrete implementation component.

Program has been changed to add the requested
timeline, and to better reflect the concurrent review and study that will be necessary to bring forth a proposal for both a new inclusionary program and, at the same time,
incentives to complement and work together to support
the construction of affordable housing while still
supporting market production. The revised Program
reads as follows:

Program HP-1.4: Affordable Housing Density Bonus

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Administer the City’s existing density bonus program
pursuant to Government Code Section 65915 (State
Density Bonus Law), as may be amended from time to
time, to meet changing statutory requirements. Provide
additional incentives as provided in Unified Development Code Section 17.68.030. Developers requesting to use
the density bonus must submit applications on a form
approved by the Community Development Director at the
time of submitting any entitlement application for a
housing development where a density bonus is
requested. The application shall include, at a minimum, the following information:

A description of how the proposed project meets the
criteria for a density bonus under Section 65915;
Concession(s), including parking adjustments, requested by the applicant;
A depiction of the location of the affordable housing units within the proposed development.

In addition to the above, consider adopting an extended density bonus program that addresses Santa Clarita’s
identified housing needs in conjunction with consideration of an inclusionary ordinance. The City will complete a
study to determine the appropriate additional densities and incentives to development projects that meet the
City’s identified housing needs, including but not limited to extremely low-income units, senior housing, mixed use zoning, and family housing for first-time homebuyers.

Time frame: Ordinance updates to comply with new state
laws, 2023; Complete study by 2024
Responsibility: Community Development Department
Funding: Departmental Budget; REAP

Program HP-1.5 (Mixed Use Overlay Zone): If the program is continuing from the past element, the element should describe what will be implemented by 2024. It should also Program has been changed to clarify that the program is a continuation from the last Element, and to provide the requested information, as follows:

Program HP-1.5: Mixed Use Overlay Zone

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specify whether the listed incentives are currently in place, or if they are yet to be
Continue to implement the City’s Mixed Use provisions
as set forth in the General Plan Land Use Element,
Mixed Use Zones, and the Mixed Use Overlay Zone (MU)
to encourage a mix of residential, commercial,
employment and institutional opportunities within activity centers along identified corridors throughout the City. The purposes of the mixed use overlay zone are: (1) to
provide a mechanism to revitalize older commercial
corridors and specific individual properties; (2) to
increase opportunities for infill housing; (3) aesthetically improve transportation corridors; (4) reduce automobile dependence by creating pedestrian-oriented
neighborhoods where local residents have services,
shops, employment, and access to transit within walking distance of their homes. Incentives for Mixed Use
Development are already in place and are to be
continued including accelerated plan check review;
increased residential and commercial density
opportunities; increased building heights, reduced
parking requirements, and reduced setbacks along public streets. (Timeframe ongoing)
Program HP-1.6 (Graduated Density Zoning and Site
Consolidation—Old Town Newhall): Program should be
revised to provide a clear timeline as to what will be
accomplished by 2024. Specifically, this program should clarify whether the offered incentives are only applicable if the whole block develops, and how likely this is.

The activities delineated in this Program continue to be implemented as a part of the Old Town Newhall Specific
Plan (ONSP). Incentives related to permitted-by-right
height of up to 55 feet for full block development projects continue to be in place and are available for property
owners and developers. The City continues to see
developer interest in these types of developments and
incentives throughout the Old Town Newhall Plan area.

Program 1.6 has been updated to include updates to the
ONSP that would include a mechanism to allow for
additional building height above the 35-foot height limit for non-full block development projects and a timeline
added:

Program HP-1.6: Graduated Density Zoning and Site
Consolidation— Old Town Newhall

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Redevelopment of portions of Old Town Newhall is
constrained by the small parcel sizes created by small-lot subdivisions in the past. The City will continue the
incentives granted to full block development projects in this target area. This tool would continue to offer
increased density based on the size of the site, thereby encouraging owners of adjoining properties to collaborate in combining parcels to form a larger development site
that provides community amenities. The City will further review and revise the Old Town Newhall Specific Plan
(ONSP) to create a permit process that could allow for
additional building height above the 35-foot and three- story height limit for projects not involving full block developments.

Program HP-1.7 (Inclusionary Housing Program- Mixed
Income Housing): The program should be revised to include implementation element, not just “consider”, as well as what incentives are being considered, and what will be
accomplished by 2024.

Program has been significantly revised to better reflect the nature of the work that will need to take place before reconsideration of an inclusionary program. Timeframes
are also provided:

Program HP-1.7: Inclusionary Zoning Feasibility Study
The City will conduct a two-phased feasibility study to analyze the financial and programmatic feasibility of an inclusionary zoning policy. The City will complete a
detailed analysis of current and projected development
patterns and will explore how such requirements could
complement and work alongside existing and proposed
incentive programs and the types of program changes
that would be needed to result in more affordable
housing while still supporting market production. Once
the study is complete, a report back on the findings will be prepared and presented to the City Council
Development Committee for direction. The report to the
CCDC will include recommendations consistent with
economic feasibility study requirements of AB 1505,
including the percentage of affordable units that might be

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required and alternate means of compliance as well as
exempt project types.

Time frame: Feasibility Study completed by 2024;
presentation to Council for direction by early 2025.

Responsibility: Community Development Department
Funding: Departmental Budget; REAP for feasibility study Program HP-1.8 (Affordable Sites Incentive Program): The program should clarify if the City already offers the
incentives described in the program, whether the approval of incentives is discretionary and include an implementation date for the incentives.

Program has been completed and incentives are already
offered. Program HP-1.8 has been converted to a
“continue to” policy , as follows:

Policy H1.8:

The City will continue to encourage land divisions and
specific plans resulting in parcels sizes that facilitate developments affordable to lower income households
including lots set aside for multifamily development or to be donated to a non-profit organization (1 acre
minimum), first-time homebuyers including sweat equity
ownership projects, lots donated to Habitat for Humanity, and similar programs. Incentives will continue to be
offered to projects that include the provision of affordable housing on-site. Incentives include but are not limited to priority processing of subdivision maps that include
affordable housing units or land to be donated; expedited review where the development application is consistent
with the General Plan, applicable Specific Plan and
master environmental impact report; financial assistance, based on funding availability; and modification of
development requirements, such as reduced parking
standards for seniors, assisted care, and special needs housing. Requests for incentives shall be made with the application and shall be determined on a case-by-case
basis.

Program HP-1.12 (First Time Homebuyer Programs and
Developers): This program should describe the
Program (renumbered HP-1.11) has been amended to
address this comment, as follows: “Beginning in 2022,

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implementation goal of the program, and whether any
proactive outreach has or will be included as a part of this implementation.
the City will complete one proactive outreach per year to contact local land trusts and housing providers such as Habitat for Humanity to determine available programs for first-time homebuyers, collaborate on measures to
advertise and promote these programs, and to facilitate their development on available housing sites.”

Program HP-2.1 (Funding Priority to Extremely Low-income Affordable Housing): This program should describe how
projects be prioritized, which programs are included, and also describe how often programs will be reviewed or added as a part of this program.

Program HP-2.1 reflects current practices and thus has
been converted to a “continue to” policy H2.9, specifying that preference for available funding is given to those that provide the greatest assistance to extremely low income households.

Program (now Program 2.5) has been amended to add
the following clarification and outreach: “The RFP/RFQ
for this program will be posted by summer 2023 and will include at least one outreach meeting/event to gauge the interest of housing developers. The RFP/RFQ process,
once posted, will be made available to potential
respondents for a minimum of 60 days and include
interviews with at least the top two firms. Ultimately, the City, at a minimum, will make a concerted effort to
execute an agreement with the non-profit developer to
identify suitable land within the City for the development of an affordable housing complex consistent with the
City’s RNHA needs. Should a proposal be brought forth,
at a minimum, the proposal will be presented to the City’s Council Development Committee, Planning Commission,
or City Council, whichever is deemed the appropriate
review body.”
Program HP-2.4 (Flexible Development Standards): This
program should clarify whether the incentives included in the program are currently in place, and if not, it should give a date as to when such incentives will be available. The Program HP-2.4 has already been achieved; flexible
development standards are already in place. The
Program has thus been converted to a “continue to”
Policy H2.10 as follows:

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program should include a specific timeline for
implementation and a proactive outreach component.
“Continue to provide incentives for affordable housing
projects including flexibility in development standards without need for a variance or other discretionary review.

Ensure that incentives are granted to qualified affordable projects under Section 65915 even if a density bonus is not sought. Consider tying the granting of additional
incentives, as allowed under Section 65915, to the level or depth of a project’s affordability.”

Clarification regarding fee deferrals is provided; the
Program has been converted to a "continue” policy H2.12

Program HP-2.2 includes changes necessary to bring the
City’'s fee deferral practices in line with new fees
transparency laws (AB 602 and SB 319)

Program HP-2.6 (Expedited Processing for Affordable
Housing Projects): The program should be modified to
include outreach to developers as well as how often.

Program HP-2.6 reflects existing practice and thus has
been changed to a “continue to” policy as follows:

Policy H2.11: The City will continue to expedite
processing for affordable housing projects, including one- stop preliminary review, concurrent application review, designation of a primary contact, and fast-tracking of
construction and grading plan review, permitting and
inspection.

Program HP-3.2 (Handyworker Program): The program
should be modified to explain if there will be proactive outreach to residents, clarify if the program will occur annually, and include a specific timeframe for
implementation.

Program has been modified to address this request by
adding the following language: "The City will continue to provide financial support for this Program annually,
contingent upon the availability of funds and approval
from the Department of Housing and Urban Development
(HUD). Upon approval of the annual allocation and
authorization from HUD, the Senior Center and City will conduct one outreach using, but not limited to, social
media, mailers, and other news platforms. Results of the Programs’ efforts (i.e. number of households assisted)
will be included in the APR.”

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Program HP-3.3 (Property Rehabilitation Program): The
program should be modified to provide proactive outreach to residents as well as often outreach will be conducted.

Program has been modified to include proactive
outreach, as follows: "Like the Handyworker Program,
the City will continue to provide financial support for this Program annually, contingent upon the availability of
funds and approval from the Department of Housing and
Urban Development (HUD). Upon approval of the annual
allocation and authorization from HUD, the Senior Center and City will conduct one outreach per year using, but not limited to, social media, mailers, and other news
platforms. Results of the Programs’ efforts (i.e. number of households assisted) will be included in the APR.“

Program HP-3.6 (Workforce Housing Program): This
program should include proactive outreach, a description of how often properties will be considered for the program, and specific implementation timing.

Program HP-3.6 reflects existing practice, and thus has been converted to a “continue to” Policy:

Policy H3.6: “At least once per year, during the life of this element, City staff will proactively reach out to the
California Municipal Finance Authority (CMFA) and the
California Statewide Communities Development
Authorities (CSCDA) to inquire about the status of
Workforce Housing in Santa Clarita. The City is an active member of both CMFA and CSCDA, including an
additional member of CMFA’s Special Finance Agency,
which is the primary agency used to for Workforce
Housing projects Citywide by CMFA“

Program HP-4.2 (Monitoring of Codes and Ordinances to
Remove Barriers): The program should be revised to
include an implementation component and should discuss if codes and ordinances be revised, and how often they will be monitored.

This Program has been folded into the larger “code
revision” program, reflected in Program HP-2.1. Code
revisions will be conducted every 2 years, on average.

Program HP-4.3 (Homeless Case Management): The
program timeframe should be revised to state how often the City will apply for financial assistance.

This Program has been amended to provide the
requested information, as follows: “The City will provide annual funding from its Public Services portion of its
annual CDBG Entitlement allocation for case
management services, which includes, but not limited to, support services, counseling, transportation assistance,

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referrals for various services, and educational programs, among others, contingent upon the availability of funds and approval from HUD.“
Program 4.4 (Housing for Persons with Disabilities) The program should describe how the City will encourage
development and whether the offered incentives are already in place. It should also describe any proactive outreach plans for developers, and how often funding for the program will be sought.

Program and incentives are already in place, so this
Program has been converted to a “continue to” Policy
and reference to the Program to comply with the new
impact fee requirements is provided. The new Policy
reads as follows:

Policy H4.9: Continue to encourage the provision of
housing to serve the developmentally disabled population in new affordable housing projects. Encourage affordable housing developers to set aside a portion of their units for the developmentally disabled and prioritize funding,
permit processing, and requests for fee waivers for
projects that do so. Continue to investigate dedicated
funding for developmentally disabled affordable housing construction and seek state and federal monies as they
become available. Facilitate any necessary HCD
Community Care licensing, streamline any required land
use approvals and support applications for construction funding for affordable housing for the developmentally
disabled.

HP-4.6 (Fair Housing Programs) should describe how often training and outreach be provided.

The Program (now HP-4.5) has been changed to add the
requested information, as follows: “Outreach will be
conducted through two outreach events per year.

Trainings and/or other items related to housing would be completed on an as-needed basis.”
HP-4.7 (Administrative Process for Reasonable
Accommodations) This program should be modified to
eliminate fees for applicants in the reasonable
accommodation process.

This Program (now HP-4.6) has been changed to
address this request, as follows: “Review typical
processing costs and reduce or eliminate the reasonable accommodation application fee (currently $872) by
2024.”

Program HP-4.10 (Proactive Community Preservation): The program should describe how repairs and maintenance are Program has been changed to add the requested
information, as follows: "As part of Santa Clarita 2025

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funded, quantify how many houses will be assisted by the program (e.g. is it only available in listed neighborhoods?), as well as specify how often program activities will occur.

Strategic Plan, staff from the Community Preservation
Division will lead a Neighborhood Rehabilitation and
Beautification Program, a proactive approach to
community preservation. The actions items will be
completed by the end of 2025, and will include, at a
minimum, one outreach event held at a public facility,
open to the public, for the rehabilitation and preservation of pre-selected areas of the Newhall and Canyon Country communities, which were identified based on data from
historical code enforcement cases and data collected
from Community Awareness Program meetings held in
the same communities during calendar years 2017-2019
(a key action item in Santa Clarita 2020, the City’s
previous five-year strategic plan). Funding for this project will come from a mix of CDBG, HOME, and General
Fund dollars, as well as services in-kind. Starting in 2023, the Program will aim to assist a minimum of 10
households per year and will continue through the
completion of Santa Clarita 2025. Progress will be
reported annually through the APR.” The City's
Quantified Objectives have been adjusted accordingly.

2. Identify actions that will be taken to make sites
available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the
inventory completed pursuant to paragraph (3) of
subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single- room occupancy units,
emergency shelters, and transitional housing.

As addressed through the responses to finding B4, the
Element now includes a complete site analysis.

Through the compete sites analysis, the City has
demonstrated adequate sites to accommodate the
regional housing need by income level. No additional
programs are needed to address a shortfall of sites.

Programs HP-2.1, HP-2.3, and HP-2.6 further addresses
the need to facilitate and encourage development of a
variety of housing for all income levels.

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(Gov. Code, § 65583, subd. (c)(1).)
As noted in Finding B4, the element does not include a
complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a
complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types.

3. The Housing Element shall contain programs which
assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-
income households. (Gov. Code, § 65583, subd. (c)(2).)
While the element includes programs to assist in the
development of very low-, low-, and moderate-income
households, it must also include a program(s) to assist in the development of housing for all special needs
households (e.g., elderly, homeless, farmworkers, persons with disabilities, female-headed households). Program
actions could include proactive outreach and assistance to non-profit service providers and developers, prioritizing some funding for housing developments affordable to
special needs households and offering financial incentives or regulatory concessions to encourage a variety of housing types.

The Element now includes a quantification and analysis
of extremely low-income housing needs within section

1.9.2, Household Incomes and Housing Affordability, and references existing analysis in section 4.5 that led to the formation of policies and programs to address needs of
ELI households. The Extremely Low-Income Households
section now references the following programs:

4. Address and, where appropriate and legally
possible, remove governmental and nongovernmental
constraints to the maintenance, improvement, and
development of housing, including housing for all income levels and housing for persons with disabilities. The
program shall remove constraints to, and provide
reasonable accommodations for housing designed for,
intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).) As noted in Findings B5 and B6, the element requires a
complete analysis of potential governmental and

As addressed through the responses to findings B5 and
B6, the Element now includes a complete analysis of
potential governmental and nongovernmental constraints.

Through the compete analysis, the City has
demonstrated that no additional programs are needed to
address, remove, or mitigate additional constraints.

Revisions to programs HP-4.4 and HP-4.7 from the
original submitted draft are described below and mitigate potential constraints.

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nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add
programs and address and remove or mitigate any identified constraints. In addition, the following programs must be revised:

Program HP-4.4 (Housing for Persons with Disabilities): The program should describe how the City will encourage
development and whether the offered incentives are already in place. It should also describe any proactive outreach plans for developers, and how often funding for the program will be sought.

Program HP-4.7 (Administrative Process for Reasonable
Accommodations): This program should be modified to
eliminate fees for applicants in the reasonable
accommodation process.

5. Promote and affirmatively further fair housing
opportunities and promote housing throughout the
community or communities for all persons regardless of
race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics In response to this request, the AFFH Program of
Actions, renumbered HP-4.11, now includes metrics and
milestones that reference timeframes and responsible
parties throughout.

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protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).)

As noted in Finding B1, the element must include a
complete analysis of AFFH. The element must be revised to add goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and
trends. Actions must have specific commitment, metrics and milestones as appropriate and must address housing
mobility enhancement, new housing choices and
affordability in high opportunity areas, place-based
strategies for community preservation and revitalization and displacement protection. Currently the element addresses AFFH in Program
HP-4.12. while this program includes some action items, many are vague and include actions that will only be
considered. Program HP-4.12 must also include
implementation components, timeframes, responsible
parties, as well as metrics and milestones. In addition, Program 5A should also describe how all the City’s housing programs comply with and further the requirements and
goals of Government Code section 8899.50, subdivision (b).

Lastly, Program HP-4.6 (Fair Housing Programs) should
describe how often training and outreach be provided.

Program (now HP-4.5) has been changed to add the
requested information, as follows: “Outreach will be
conducted through two outreach events per year.

Trainings and/or other items related to housing would be completed on an as-needed basis.”

The Element has also been revised to describe how all of the City’s housing programs comply with and further the requirements and goals of GC 8899.50 (b) by providing
the following text:
“The collective programs and policies administered by
the City of Santa Clarita and set forth in this Housing Element comply with and further the requirements and
goals of Government Code Section 8899.50(b). As
demonstrated in Program HP 4.11, the City is committed
to taking meaningful actions to fulfill its obligation to affirmatively further fair housing and will take no actions that would be materially inconsistent with that goal.”

6. The housing program shall preserve for low-income
household the assisted housing developments identified
pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in
Program HP-3.5 has been updated to reflect the
preservation notice requirements and to add specificity for reporting and monitoring, to read as follows:

Program HP-3.5: Preservation of At-Risk Housing

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paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding
sources are not available. The program may include
strategies that involve local regulation and technical
assistance. (Gov. Code, § 65583, subd. (c)(6).)

During the 2021 - 2029 planning period, Santa Clarita
has 89 affordable senior units at high risk and up to 559 affordable units at lower risk of converting to market
rents. The City will work to preserve these units as
affordable by undertaking the following specific actions:

Annually update the status of at-risk housing and
available funding beginning in 2022 and provide an
annual status update in the City’s APR
Proactively outreach to owners at least three years
before expiration of affordability to inform them of state preservation notice law requirements (Gov. Code
Sections 65863.10, 65863.11, 65863.13)
Proactively outreach to at least two qualified entities per year to try and maintain affordability levels
Continue investigating funding options for continuation of affordability agreements and pursue funding as available.

Timeline: Annual monitoring of status and available
funding; outreach to owners at least 3 years prior to
expiration of affordability restrictions; proactive outreach to qualified entities at least once per year beginning in 2022; contacts and discussions with owners and partners ongoing.

Responsibility: Community Development Department
Funding: TCAC, CA MFH Program, bonds, mortgage
funds

7. Develop a plan that incentivizes and promotes the
creation of accessory dwelling units that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate-income households. For purposes of this paragraph, “accessory
dwelling units” has the same meaning as “accessory
dwelling unit” as defined in paragraph (4) of subdivision (i) of Section 65852.2. (Gov. Code,
§ 65583, subd. (c)(7).)
ADU projections have been updated to reflect the
average number of ADUs permitted annually since 2018.

With data now available for 2021, the average now
includes 2021 permits, resulting in an average of 31.25 ADUs per year from 2018-2021. The Housing Element
now projects 250 ADUs over the planning period,
consistent with recent trends and with HCD’s guidance to calculate a realistic estimate of potential ADU
development.

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Programs must be expanded to include incentives to
promote the creation and affordability of ADUs. Examples include exploring and pursuing funding, modifying
development standards and reducing fees beyond state law, increasing awareness, pre-approved plans and
homeowner/applicant assistance tools. In addition, given the City’s assumptions for ADUs exceed recent trends, the
element should include a program to monitor permitted
ADUs and affordability every other year and take
appropriate action such as adjusting assumptions or
rezoning within a specified time period (e.g., six months).

Policy 2.8 has been amended to include Accessory
Dwelling Units and Junior Accessory Dwelling Units, as
follows:

Policy H2.8: Continue to expedite application review,
permitting, and inspection procedures for Accessory
Dwelling Units, Junior Accessory Dwelling Units, and
affordable housing projects.

Program HP-2.6 has been added to incentivize and
promote Accessory Dwelling Units, as follows:

Program HP-2.6: Provide for Accessory Dwelling Units
and Junior Accessory Dwelling Units (GC 65583, c (7))

Add an ADU page to the City’s website with all of the
above information, as well as with a link to the LA ADU website to provide information about permitting,
assistance tools, financing and lending programs
(https://www.laadu.org/) by the end of 2023
Annually report out on the City’s successes in the
production of ADUs and JADUs with the City’s APR.

D. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)

Quantified Objectives have now been updated to
reference the impact of specified programs.

Quantified objectives for new construction now include
ELI units.

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E. Public Participation
Local governments shall make a diligent effort to achieve public participation of all economic segments of the
community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(8).)

In addition, the element must clarify when the draft was made available to the public. If the City did not make the draft available to the public prior to submitting to HCD, the City has not yet complied with statutory mandates to make a diligent effort to encourage the public participation in the development of the element and it reduces HCD’s ability to consider public comments in the course of its review. The availability of the document to the public and opportunity for public comment prior to submittal to HCD is essential to the public process and HCD’s review. The City must proactively make future revisions available to the public, including any commenters, prior to submitting any revisions to HCD and diligently consider and address comments, including making revisions to the document where appropriate. HCD’s future The Element now describes when the Draft Housing
Element was made available to the public prior to
transmitting to HCD, as well as the City’s continued
efforts to make the revised adoption document available for public review and input.

The Element also references targeted outreach in
Newhall and Canyon Country.

A breakdown of public comments and the City’s response
and incorporation into the Element is provided in
Appendix B: Community Participation

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review will consider the extent to which the revised element documents how the City solicited, considered, and
addressed public comments in the element. The City’s
consideration of public comments must not be limited by HCD’s findings in this review letter.

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Attachment: City's Response to HCD Letter Matrix (Housing Element and Safety Element Update) Attachment
Comment Letters
Master Case 21-088

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Attachment: Comment Letters (Housing Element and Safety Element Update)

From: [See attached commenter list for June 2021]
Sent: Tuesday, June 2021
To: Mary Cusick
Subject: Santa Clarita housing element update

Hi, my name is [See attached commenter list for June 2021], I am a local carpenters union member. We would like to see Labor standards and or policy included in this plan. In future projects under this plan, the city should explicitly incorporate language requiring family supporting wages, skills training and job access to the community members rather then simply accepting projects founded on low costs and low wages. Specifically:

The construction workforce should require;
‐full family health plans
‐skilled and trained workforce standards through certified apprenticeship ‐paid sick leave. Pension, and vacation‐holiday pay.

High quality responsible bidder standards should be established to ensure high quality construction performance;
‐Construction contractors at every level comply with labor law and have no history of fraudulent or grossly negligent business practices.
‐General contractors should be required to self perform a minimum of 5% of all construction craft work for which they are responsible.

We believe all Santa Clarita residents deserve an innovative economic solution that puts them on the path to build better careers, increase access to family healthcare, and enrich the community at large.

Local Carpenters union member,
[See attached commenter list for June 2021]

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Attachment: Comment Letters (Housing Element and Safety Element Update) List of Commenters from the
Southwest Regional Council of Carpenters
June 2021
# Name Date Sent
1 Jordan Reyes Peter 6/29/2021
2 Emiliano Guidos 6/29/2021
3 Andrew Gonzalez 6/29/2021
4 Roberto De Paz 6/29/2021
5 Miguel Bedoy 6/29/2021
6 Antonio Zuniga 6/29/2021
7 Javier Hernandez 6/29/2021
8 Douglas Abarca 6/29/2021
9 Tatiana Depaz 6/29/2021
10 Sadie Lopez 6/29/2021
11 Leo Padron 6/29/2021
12 Ivan Jimenez 6/29/2021
13 Alberto Ramirez 6/29/2021
14 Brandon Solorzano 6/29/2021
15 David Hernandez 6/29/2021
16 Michael Cervantes 6/29/2021
17 Edward Mills 6/29/2021
18 Daniel Acosta 6/29/2021
19 Edgar Lara 6/29/2021
20 Andrew Kanamu 6/29/2021
21 Carlos Carbajal 6/29/2021
22 Elias Lopez 6/29/2021
23 Manny Martinez 6/29/2021
24 Josue Gil Zambrano 6/29/2021
25 Felix Campos 6/29/2021
26 Shaun Mieure 6/29/2021
27 Robert Moreno 6/29/2021
28 Alejandro Esqueda 6/29/2021
29 Roberto Villapondo 6/29/2021
30 Ryan Erickson 6/29/2021
31 Oscar Tirado 6/29/2021
32 Danny Gilchrist 6/29/2021
33 Ivan Burgara 6/29/2021
34 Arturo Becerra 6/29/2021
35 Quebin Vargas 6/29/2021
36 Gabriel Castaneda 6/29/2021
37 Yolanda Ochoa 6/29/2021
38 Jason Green 6/29/2021
39 Juan Hernandez 6/29/2021
40 Albert Dominguez 6/29/2021
41 Elias Echevarria 6/29/2021
42 Anibal Rios 6/29/2021
43 Dave Centeno 6/29/2021
44 Martin Sanchez‐Gomez 6/29/2021
45 Jack Rutkowski 6/29/2021

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Attachment: Comment Letters (Housing Element and Safety Element Update) List of Commenters from the
Southwest Regional Council of Carpenters
June 2021
46 Gustavo Felix 6/29/2021
47 Gianni Rossi 6/29/2021
48 Carlos Jimenez 6/29/2021
49 Carlos Alonso 6/29/2021
50 Enrique Apodaca 6/29/2021
51 Eliseo Jorge 6/29/2021
52 Stephanie Chavez 6/29/2021
53 Erwin Jackson 6/29/2021
54 Carlos Chavez 6/29/2021
55 Ramiro Reyes 6/29/2021
56 Priscilla Caro 6/29/2021
57 Bonifacio Rojas 6/29/2021
58 Aldo Antimo 6/29/2021
59 Katherine Hernandez 6/29/2021
60 Robert Miller 6/29/2021
61 Antonio Munoz 6/29/2021
62 Maria Coronado 6/29/2021
63 Jennifer Bonilla 6/29/2021
64 Crystal Sanchez 6/29/2021
65 Brian Hovet 6/29/2021
66 Franklin Arteta 6/29/2021
67 Alfredo Resendiz 6/29/2021
68 Fidel Espinoza 6/29/2021
69 Brandon Castaneda 6/29/2021
70 Paris Jernigan 6/29/2021
71 Jose Campos 6/29/2021
72 Jonathan Pardo 6/29/2021
73 Tom Cummings 6/29/2021
74 Juan Salazar 6/29/2021
75 Phillip Roberts 6/29/2021
76 Anthony Contreras 6/29/2021
77 Marlon Miranda 6/29/2021
78 Rudy Hernandez 6/29/2021
79 Herbert Hardy 6/29/2021
80 Elias Martinez 6/29/2021
81 Emilio Sandoval 6/29/2021
82 David Lopez 6/29/2021
83 Michael Guzman 6/29/2021
84 Bonifacio Rojas 6/29/2021
85 David Benzie 6/29/2021
86 Joel Perez 6/30/2021
87 Alex Sonne 6/30/2021
88 Daniel Langford 6/30/2021
89 Oscar Vargas 6/29/2021
90 Trishton Belisle 6/29/2021
91 Sean Mann 6/30/2021

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Attachment: Comment Letters (Housing Element and Safety Element Update) List of Commenters from the
Southwest Regional Council of Carpenters
June 2021
92 Joseph Ledesma 6/29/2021
93 Angel Tirado 6/29/2021
94 Josselyn Tirado 6/29/2021
95 Nicolas Reyes 6/29/2021
96 Katrina Powell 6/29/2021
97 Carolina Corona 6/29/2021
98 Kory Smith 6/29/2021
99 Ramiro Reyes 6/29/2021
100 Genoveva Reyes 6/29/2021
101 Consuelo Martinez 6/29/2021
102 Andres Martinez 6/29/2021
103 Jose Martinez 6/29/2021
104 Joe Ledesma 6/29/2021
105 Yvonne Vargas 6/29/2021
106 Pablo Ochoa 6/29/2021
107 Jeffrey Carranza 6/29/2021
108 Natali Mendoza 6/29/2021
109 Juan Medina 6/29/2021
110 Jesus Rodriguez 6/29/2021
111 Carlos Barrillas 6/29/2021
112 Eduardo Desantiago 6/29/2021
113 Madelio Vaca 6/29/2021
114 Neysa Gonzalez 6/29/2021
115 Luba Mirazadeh 6/29/2021
116 Michael Cabrera 6/29/2021
117 Stephenie Leiva 6/29/2021
118 Casey Lorenzen 6/29/2021
119 Corey Crockerham 6/29/2021
120 Ruben Anguiano 6/29/2021
121 Baldo Lopez 6/29/2021
122 Eduardo Desantiago 6/29/2021
123 Roberto Leiva 6/29/2021
124 Angel Martinez 6/29/2021
125 Gonzalo Vasquez 6/29/2021
126 Jose Salcedo 6/29/2021
127 Luis Jauregui 6/29/2021
128 Omar Arellano 6/29/2021
129 Anthony Cardona 6/29/2021
130 Blake Powell 6/29/2021
131 Rebeca Galindo 6/29/2021
132 German Guitron 6/29/2021
133 Mike Ortiz 6/29/2021
134 Alex Ortiz 6/29/2021
135 Carlos Perez 6/29/2021
136 George Duenas 6/29/2021
137 Denis A. 6/30/2021

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Attachment: Comment Letters (Housing Element and Safety Element Update) List of Commenters from the
Southwest Regional Council of Carpenters
June 2021
138 Susan Fuchs 6/30/2021
139 Robert Milewsky 6/30/2021
140 Byron Murray 6/30/2021
141 Eduardo Torres Garcia 6/30/2021
142 Jerred Langford 6/30/2021
143 Salvador Camacho 6/30/2021
144 David Copado 6/30/2021
145 Michael Marquez 6/30/2021
146 Ryan Jefferson 6/30/2021
147 Max Garcia Torres 6/30/2021
148 Andy Estrada 6/30/2021
149 Israel Pablo De Paz 6/30/2021
150 Anthonio Pablo 6/30/2021
151 Liliana Gomez 6/30/2021
152 Jorge Preciado 6/30/2021
153 Ron Diament 7/1/2021
154 Mike Simnowski 6/30/2021
155 Martin Virgen 6/30/2021
156 Yesenia Lopez 6/30/2021
157 Antonio Zamora 6/30/2021
158 Salina Guzman 6/30/2021
159 Leonel Serrano 6/30/2021
160 Alfredo Tapia 6/30/2021
161 Charles Lugo 6/30/2021
162 Cesar Banuelos 6/30/2021
163 Tim Glynn 7/1/2021

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Attachment: Comment Letters (Housing Element and Safety Element Update)

From: [See attached commenter list for April 2022]
Sent: April 2022
To: [email protected]
Subject: Santa Clarita housing element update

Hi, my name is [See attached commenter list for April 2022], I am a local carpenters union member. We would like to see Labor Standards and or policy included in this plan. In future projects under this plan, the city should explicitly incorporate language requiring family supporting wages, skills training and job access to the community members rather then simply accepting projects founded on low costs and low wages. Specifically:

The construction workforce should require;
‐Full family health plans
‐Skilled and trained workforce standards through certified apprenticeship ‐Paid sick leave. Pension, and vacation‐holiday pay.

High quality responsible bidder standards should be established to ensure high quality construction performance;
‐Construction contractors at every level comply with labor law and have no history of fraudulent or grossly negligent business practices.
‐ General Contractors should be required to self perform a Minimum of 5% of all construction craft work for which they are responsible.

Local Carpenters Union Member,
[See attached commenter list for April 2022]

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Attachment: Comment Letters (Housing Element and Safety Element Update) List of Commenters from the
Southwest Regional Council of Carpenters
April 2022
# Name Date Sent
1 Jose Tapia 4/4/2022
2 Andruw Aguilar 4/4/2022
3 Jose Gorrochotegui 4/5/2022
4 Rolando Galaviz 4/4/2022
5 Alexis Ramos 4/5/2022
6 Irvin Avelino 4/5/2022
7 Oscar Enciso 4/5/2022
8 Gustavo Ramirez Guerrero 4/5/2022
9 Carolos Ortega 4/5/2022
10 Mario Ramirez 4/5/2022
11 Carlos Cortez 4/5/2022
12 Clifford Kellgreen 4/5/2022
13 Jorge Barnadac 4/5/2022
14 Justin Alvarado 4/5/2022
15 Alfredo Hernandez 4/4/2022
16 Oscar Nunez 4/4/2022
17 Shane Lau 4/4/2022
18 Luis Jovel 4/4/2022
19 Alex Calderon 4/4/2022
20 Robert Hagen 4/4/2022
21 Omar Nevarez 4/4/2022
22 Robert Hagen 4/4/2022
23 Julian Jimenez 4/4/2022
24 Jose Hernandez 4/4/2022
25 Parker Pilney 4/4/2022
26 Christopher Larios 4/4/2022
27 Anthony Thompson 4/5/2022
28 Anthony Thompson 4/5/2022
29 Pedro Vizcaino 4/5/2022

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Attachment: Comment Letters (Housing Element and Safety Element Update)

P: (626) 381-9248
F: (626) 389-5414
E: [email protected]

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

VIA E-MAIL
November 23, 2021
Mary Cusick, City Clerk
City of Santa Clarita
23920 Valencia Blvd. Suite 120
Santa Clarita, CA 91355
Em: [email protected]
RE: City of Santa Clarita’s 6th Cycle Housing Element Update.

Dear Mary Cusick,
On behalf of the Southwest Regional Council of Carpenters (“Southwest Carpenter” or “SWRCC”), my Office is submitting these comments for the City of Santa Clarita’s (“City”) draft 2021-2029 update to the City’s General Plan Housing Element (“Project”).

The Southwest Carpenters is a labor union representing 50,000 union carpenters in six states, including California, 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.

SWRCC 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.

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

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Moreover, SWRCC requests that the City 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.

Skilled and trained workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce

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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 developments to require contractors to utilize apprentices from state-approved, joint labor-management training programs, . .

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/default-source/
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.

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.”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 shor ter. 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 bu ilt-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 needed, these carrots are matched by sticks, since the city is not shy about

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-jobs- housing.pdf
7 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: Jobs- Housing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT- 825.pdf.

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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).

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Attachment: Comment Letters (Housing Element and Safety Element Update) DOC 6409458.SCV
December 20, 2021
Ref. DOC 6364670
Mr. James Chow, Senior Planner
City of Santa Clarita
23920 Valencia Boulevard, Suite 302
Santa Clarita, CA 91355
Dear Mr. Chow:

Response to Santa Clarita Housing Element
The Santa Clarita Valley Sanitation District (District) received a notice for the subject project on November 3, 2021. The City of Santa Clarita (City) is located within the jurisdictional boundaries of the Santa Clarita Valley Sanitation District (District). We offer the following comments regarding sewerage service:

1. The District own, operate, and maintain the large trunk sewers that form the backbone of the regional wastewater conveyance system. Local collector and/or lateral sewer lines are the responsibility of the jurisdiction in which they are located. As such, the District cannot comment on any deficiencies in the sewerage system in the City except to state that presently no deficiencies exist in District’ s facilities that serve the City. F or information on deficiencies in the City sewerage system, please contact the City Department of Public Works and/or the Los Angeles County Department of Public Works.

2. The District should review individual developments within the City to determine whether sufficient trunk sewer capacity exists to serve each project and if District’s facilities will be affected by the project.

3. The District operates two water reclamation plants (WRPs), the Saugus WRP and the Valencia WRP, which provide wastewater treatment in the Santa Clarita Valley. These facilities are interconnected to form a regional treatment system known as the Santa Clarita Valley Joint Sewerage System (SCVJSS). The SCVJSS has a capacity of 28.1 million gallons per day ( mgd) and currently processes an average flow of

19.6 mgd.

4. In order to estimate the volume of wastewater the project will generate, go to www.lacsd.org , under Services, then Wastewater Programs and Permits, select Will Serve Program , and scroll down to click on the Table 1, Loadings for Each Class of Land Use link for a copy of the District ’s average wastewater generation factors.

5. The District is empowered by the California Health and Safety Code to charge a fee to connect facilities (directly or indirectly) to the District’s Sewerage System or to increase the strength or quantity of wastewater discharged from connected facilities. This connection fee is used by the District for its capital facilities. Payment of a connection fee may be required before this project is permitted to discharge to the District’s Sewerage System. For more information and a copy of the Connection Fee Information Sheet, go to www.lacsd.org, under Services, then Wastewater (Sewage) and select Rates & Fees. In determining the impact to the Sewerage System and applicable connection fees, the District will determine the user category (e.g. Condominium, Single Family home, etc.) that best represents the actual or anticipated use of the parcel(s) or facilities on the parcel(s) in the development. For more specific information regarding the

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connection fee application procedure and fees, the developer should contact the District’s Wastewater Fee Public Counter at (562) 908-4288, extension 2727.

6. In order for the District to conform to the requirements of the Federal Clean Air Act (CAA), the capacities of the District’s wastewater treatment facilities are based on the regional growth forecast adopted by the Southern California Association of Governments (SCAG). Specific policies included in the development of the SCAG regional growth forecast are incorporated into clean air plans, which are prepared by the South Coast and Antelope Valley Air Quality Management Districts in order to improve air quality in the South Coast and Mojave Desert Air Basins as mandated by the CAA. All expansions of District’s facilities must be sized and service phased in a manner that will be consistent with the SCAG regional growth forecast for the counties of Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial. The available capacity of the District’s treatment facilities will, therefore, be limited to levels associated with the approved growth identified by SCAG. As such, this letter does not constitute a guarantee of wastewater service, but is to advise the developer that the District intends to provide this service up to the levels t hat are legally permitted and to inform the developer of the currently existing capacity and any proposed expansion of District’s facilities.

If you have any questions, please contact the undersigned at (562) 908-4288, extension 2743 or [email protected].

Very truly yours,
Mandy Huffman
Environmental Planner
Facilities Planning Department
MNH:mnh

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MATTHEW GELFAND, COUNSEL
[email protected]
TEL: (213) 739-8206
March 24, 2022
Tom Cole
City of Santa Clarita
Email: [email protected]
RE: Santa Clarita’s failure to timely adopt a Sixth Cycle Housing Element.

Dear Tom Cole:

Californians for Homeownership is a 501(c)(3) non-profit organization that uses impact litigation to address California’s housing crisis. We are monitoring local compliance with the law governing housing elements. Our understanding is that the City has not adopted a sixth cycle housing element, which it was required to do by October 15, 2021. 1 It also missed the second compliance deadline of February 12, 2022, subjecting it to additional penalties.2 We are currently preparing for litigation against cities that have not timely adopted housing elements, like yours.

In light of the City’s failure to timely adopt its housing element, our organization could immediately sue the City under Code of Civil Procedure Section 1085 to compel it to adopt a compliant housing element.3 As a result of this litigation, in addition to being ordered to adopt a housing element on a short timeline, 4 the City could also face a number of serious penalties. For example, the court could suspend all non-residential permitting, 5 or could judicially approve housing development projects within the City.6 And the court could impose these penalties while the litigation is pending, even before reaching a final decision.7 Housing element litigation is given priority in the court system, 8 and a successful plaintiff can obtain attorneys’ fees under Code of Civil Procedure Section 1021.5. Indeed, in a recent case involving the City of Huntington Beach’s housing element, a court awarded another non-profit organization over $3.5 million in fees.9 The purpose of this letter is to offer the City a pathway to avoid immediate litigation by our organization. Enclosed is an Acknowledgment that sets forth some of the penalties to which the City is currently subject in light of the City’s failure to adopt a housing element. If the City signs and returns the Acknowledgment, we will not initiate litigation against the City at this time. 1 Gov. Code § 65588(e)(3).
2 Gov. Code §§ 65583(c)(1)(A), 65583.2(c), and 65588(e)(4)(C). 3 Gov. Code §§ 65587, 65751.
4 Gov. Code § 65754.
5 Gov. Code § 65755(a)(1).
6 Gov. Code § 65755(a)(4).
7 Gov. Code § 65757.
8 Gov. Code § 65752.
9 https://www.communitylegalsocal.org/kennedy-commission-awarded-3-5-million-in-attorneys-fees-for-advocacy- in-huntington-beach-low-income-housing-case/

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We ask that you return the Acknowledgement by April 1, 2022. If you decline to do so, understand that we may initiate litigation against the City, using the City’s refusal to acknowledge these basic requirements of state housing law to demonstrate the existence of a dispute necessitating judicial intervention. As part of the litigation, we would likely seek a judicial declaration that the City is subject to the same penalties described in the Acknowledgment, among other remedies. We have dedicated in-house resources sufficient to maintain at least 10 simultaneous housing element lawsuits as part of our commitment to enforcing this important aspect of state housing law.

Finally, while we acknowledge that it takes a significant dedication of resources to comply with the requirements of state housing element law, it is worth noting that many cities throughout the Southern California (SCAG) region, both big and small, have already adopted their sixth cycle housing elements after fully complying with state law mandates governing consultation with the public and the state Department of Housing and Community Development (HCD). We believe that, with appropriate planning, all of the SCAG cities could have adopted their housing elements by the October 15, 2021 deadline. For this reason, it would not be productive to respond to this letter by listing the steps the City has taken towards adoption, or the obstacles it has faced. Instead, we simply ask that the City sign the Acknowledgment. There are no statutory exceptions to the penalties identified in the Acknowledgment, and HCD does not have the authority to excuse the City from them.

We look forward to receiving the signed Acknowledgment. If you would like to discuss any of this with me, please do not hesitate to give me a call at (213) 739-8206.

Sincerely,
Matthew Gelfand
cc: Joseph Montes, Esq., City Attorney (by email to [email protected])

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ACKNOWLEDGMENT
The City of Santa Clarita hereby acknowledges that it has not timely adopted a sixth cycle revised housing element of its general plan within the deadline set forth in Government Code Section 65588, and that its housing element is therefore not in substantial compliance with Article

10.6 of the Government Code. As a result, the City is subject to the following:

1. Pursuant to Government Code Sections 65583(c)(1)(A), 65583.2(c), and 65588(e)(4)(C), the City will be required to complete any rezoning required under housing element law in connection with the City’s sixth cycle housing element by October 15, 2022.

2. The City is currently prohibited from rejecting housing development projects based on subdivisions (d)(1) and (d)(5) of the Housing Accountability Act (HAA), Government Code Section 65589.5. The City acknowledges that this means that, unless another exception within subdivision (d) applies, the City is prohibited from using its general plan and zoning standards to reject a proposal that meets the affordability requirements described in subdivision (h)(3) of the HAA.

The public, including without limitation any applicant to develop any project involving residential units, may rely on this Acknowledgment as the City’s binding commitment to comply with the provisions of state law described above.

DATED: ________________, 2022 CITY OF SANTA CLARITA
By: _____________________________
[Signature]
_____________________________
[Name]
Its: _____________________________
[Title]

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Santa Clarita City CouncilMay 10, 2022

Santa Clarita City Council
May 10, 2022