Santa Clarita City Council
June 27, 2023

Agenda Item: 17

1. CITY OF SANTA CLARITA

AGENDA REPORT

PUBLIC HEARINGS
CITY MANAGER APPROVAL:

DATE: May 10, 2022
SUBJECT: HOUSING ELEMENT AND SAFETY ELEMENT UPDATE ( MASTER CASE 21- 088)
DEPARTMENT: Community Development
PRESENTER: James Chow

RECOMMENDED ACTION
City Council:

1. Conduct the public hearing and receive testimony from the public; and

2. Adopt a resolution adopting the Negative Declaration prepared for the project and approve Master Case 21- 088 ( General Plan Amendment 21- 001) and adopt the Housing Element and Safety Element Updates.

BACKGROUND

STATE LAW
The City of Santa Clarita ( City) is mandated by California state law to prepare an update to its Housing Element for certification by the state. This update covers the planning period between 2021 and 2029, also referred to as the sixth Housing Element cycle. The sixth Housing Element cycle process unofficially began in October 2019 when the California Department of Housing and Community Development ( HCD) provided a Regional Housing Needs Assessment ( RHNA) allocation of 1. 34 million units to the Southern California Association of Governments ( SCAG).

In March 2021, SCAG adopted the final RHNA allocation plan and distributed an allocation of 10, 031 units to the City of Santa Clarita, for which the City is responsible to plan and zone. The proposed update to the Housing Element provides the capacity needed to accommodate the RHNA for the planning period under existing zoning, and thus does not require any re -zoning. It should also be noted that Housing Elements do not require or propose the actual construction of housing, but rather require the appropriate zoning to accommodate it.

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All cities in California are required by state law to produce, update, and certify their Housing Elements every eight years. The Housing Element is one of seven mandated elements that comprise a city' s General Plan. It is the only element of the General Plan that must be certified by a state agency. The HCD is the certifying agency that evaluates each city' s Housing Element.

The City' s General Plan contains eight elements, including Land Use, Economic Development nonmandatory), Circulation, Noise, Conservation and Open Space ( two elements combined), Safety, and Housing.

OVOV GENERAL PLAN AND 2013- 2021 HOUSING ELEMENT
A comprehensive update to the City' s General Plan was adopted by the City Council in June 2011, following years of planning and collaboration between the City and County of Los Angeles ( County), through the One Valley One Vision ( OVOV) process. The OVOV process reflected the City' s and County' s decision to coordinate land uses and future development of the Santa Clarita Valley.

A major component of the OVOV was an update to the General Plan land use map, which was developed by balancing the goals and requirements of reducing future greenhouse gas emissions e. g. Senate Bill 375) and planning for future regional housing needs. The General Plan land use map maximized opportunities for increasing jobs, redeveloping infill areas, and creating additional suitable housing sites near transit, while decreasing densities in the more environmentally sensitive areas at the City' s periphery.

Following the OVOV General Plan update, the 2013- 2021 Housing Element was adopted by the City Council in October 2013 and certified by HCD. The 2013- 2021 Housing Element provided adequate sites at a range of densities to accommodate future housing needs and planned for the maintenance and improvement of the existing housing stock. The City' s 2013- 2021 Housing Element RHNA allocation was 8, 322 units, which then increased to 10, 981 units through annexations. A summary and evaluation of the City' s progress towards achieving the implementation programs is provided in Section 1. 14 of the Draft Housing Element (attached). 2021- 2029 HOUSING ELEMENT
Following receipt of Senate Bill (SB) 2 grant funding, the City Council authorized a contract with the City' s consulting team, consisting of 4LEAF, Inc., and Rincon Consultants, Inc., on January 26, 2021, to prepare the update to the Housing Element ( hereafter " Housing Element Update" or " 2021- 2029 Housing Element"). Since that time, staff and the consultant team have been preparing the Housing Element Update for the 2021- 2029 planning period.

Extensive public outreach was conducted for the Housing Element Update between January and September 2021. Various public participation opportunities were provided, including the creation of the Housing Element Update webpage, stakeholder meetings, an online opinion survey, a virtual workshop, a study session before the Planning Commission, and a City Council Development Committee meeting. A thorough summary of the public participation conducted and how comments were incorporated can be found attached in Appendix B of the Housing Element Update.

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A draft of the Housing Element Update was published on the City' s website on October 29, 2021, for public review and was submitted to HCD on November 12, 2021. Following its 60- day review of the Draft Housing Element Update, HCD issued a letter to the City on January 11, 2022, finding that the " draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10. 6 of the Government Code)." A copy of this letter is attached.

Since receipt of the letter, staff and the consultant team have coordinated with HCD and prepared the necessary revisions to the Housing Element Update to ensure compliance with Housing Element Law. A draft response matrix summarizing HCD' s comments and how each of the comments are addressed in the public hearing Draft Housing Element is attached. State law requires the City Council to consider HCD' s comments and make appropriate findings as part of the Housing Element adoption process. City staff will then forward the final response matrix and Housing Element Update to HCD for its final review.

The City Council public hearing draft of the Housing Element Update that reflects the revisions required by HCD is attached. Included as part of the Housing Element Update are various implementing programs to ensure consistency with state laws and local planning objectives. Key components of the Housing Element Update are summarized under the Statutory Requirements section of this agenda report.

Key conclusions of the 2021- 2029 Housing Element are as follows:

No General Plan land use changes or zoning changes were necessary to accommodate the City' s RHNA allocation. Future residential development is expected to occur in those areas already identified for residential uses. No areas have been identified for re -zoning or up - zoning.

The Housing Element Update recommends minor modifications to the City' s current Housing Element goals and policies. Other updates to goals, policies, objectives, and programs are required to comply with state law.

The Housing Element Update includes a number of new programs to address state housing law, including future amendments to the Unified Development Code (UDC), new programs to support affirmatively furthering fair housing, and tracking and reporting requirements for housing sites.

SAFETY ELEMENT UPDATE
As required by state law, upon the next revision of the Housing Element on or after January 1, 2014, the Safety Element is required to be reviewed and updated as necessary to address the risk of wildfire for land classified as state responsibility areas and as very high fire hazard severity areas. The updated Safety Element is also required to include updates to address climate adaptation as required by SB 379. The proposed updates to the Safety Element incorporate goals, policies, objectives, and implementation measures to address climate adaptation and wildfire risks. The update of the Safety Element does not warrant a comprehensive rewrite, but rather, includes revisions to address new statutory requirements and incorporates information from the Local Hazard Mitigation Plan, which was adopted by the City Council on September 14, 2021.

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In accordance with California Government Code Section 65302.5, the updated Safety Element was submitted to the California Board of Forestry and Fire Protection ( BOF) and the California Geological Survey for review. On January 18, 2022, the Resource Protection Committee of the BOF completed its review and assessment of the updated Safety Element and determined it meets the requirements of Government Code Section 65302. The updated Safety Element and the redlines reflecting changes to the Safety Element are attached.

PLANNING COMMISSION RECOMMENDATION
On April 5, 2022, the Planning Commission conducted a duly -noticed public hearing on the proposed updates to the Housing Element and Safety Element. The Planning Commission, in a 5- 0 vote, recommended the City Council adopt the Negative Declaration prepared for the project and adopt the Housing Element and Safety Element Updates. Included in their recommendation was a request to make a minor revision to the Safety Element clarifying the service area for the Pitchess Detention Center. The Planning Commission Resolution and staff report are attached.

STATUTORY REQUIREMENTS

NEW HOUSING ELEMENT REQUIREMENTS
Recent changes to state law have imposed new requirements for the 2021- 2029 Housing Element. These more stringent requirements, combined with a high RHNA allocation, have presented various challenges with this Housing Element Update. Key new Housing Element requirements are described below:

1. Higher RHNA Allocations
As compared to the prior Housing Element cycle, RHNA allocations have increased significantly across the state, especially in the SCAG region. The SCAG region' s allocation increased threefold from 412, 000 units for the prior cycle to 1. 34 million units for this current cycle.

Although the City is seeing a 950- unit decrease in the RHNA (from 10,981 units to 10, 031 units) as compared to the last cycle, the relatively high RHNA allocation presents challenges due to new and more stringent requirements and the decreasing number of vacant and eligible sites to accommodate the RHNA. A detailed discussion of the City' s RHNA allocation is provided below and in Section 1. 13 of the Housing Element.

2. Eligibility of Sites (Assembly Bill (AB) 1397)
AB 1397 amended the Housing Element Law and places stricter requirements on local jurisdictions when identifying adequate and available sites to meet their RHNA allocations. This law resulted in added scrutiny and more eligibility requirements for identifying housing sites, including a strong justification threshold if non -vacant sites and sites smaller than one-half acre or greater than 10 acres are included. The legislation also includes new requirements for streamlining the permitting of projects on sites included in previous Housing Elements that are reused in the updated sites inventory.

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3. No Net Loss ( SB 166)
SB 166, the " No Net Loss" law, requires a jurisdiction to ensure a Housing Element sites inventory with continual capacity to accommodate the RHNA by income group throughout the eight -year planning period. If sites identified for lower -income housing are developed with less units than identified in the Housing Element, or are developed for a higher income group, the jurisdiction must demonstrate that there are sufficient remaining sites or additional substitute sites to meet the jurisdiction' s RHNA obligation in all income categories. Because of this requirement, HCD recommends an increased buffer of at least 15 to 30 percent more capacity than required, especially for the lower -income RHNA. The Housing Element sites inventory includes roughly a 23 percent surplus or buffer for lower -income units and utilizes conservative estimates for development capacity in order to account for this need.

4. Affirmatively Furthering Fair Housing ( AFFH) ( AB 686) AB 686 requires state and local agencies to take proactive measures to correct any housing inequalities related to race, national origin, color, ancestry, sex, marital status, disability, religion, or other protected characteristics. Agencies must ensure that their laws and programs affirmatively further fair housing, and that they take appropriate actions to do so.

Under state law, affirmatively furthering fair housing, or AFFH, means " taking meaningful actions, in addition to combatting discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics." Agencies must include a program in their Housing Elements that promotes fair housing opportunities for all persons. In the context of a community' s housing needs, AFFH is not just about the number of units needed, but also about where the units are located and who has access to them. A full assessment of fair housing can be found in Section

4. 5 of the Housing Element Update.

KEY COMPONENTS OF THE HOUSING ELEMENT

1. Public Participation
Despite restrictions on gatherings due to the COVID- 19 pandemic, extensive public outreach was completed during the preparation process, which resulted in meaningful public participation.

Various public participation opportunities were provided, including the creation of the Housing Element Update webpage, stakeholder meetings with various nonprofit housing providers and service providers, an online opinion survey, a virtual workshop, a study session before the Planning Commission, and a City Council Development Committee meeting. A thorough summary of the public participation conducted and how public comments were incorporated into the Housing Element Update can be found in Appendix B of the Housing Element Update.

Prior to the posting of the public review draft of the Housing Element, staff received 163 form letters from members of the Southwest Regional Council of Carpenters ( SWRCC) requesting that labor standards be incorporated into the plan. An additional 29 letters were provided to the Planning Commission at their meeting. Three additional comment letters were provided during the preparation of the Housing Element Update, including letters from the attorney representing

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SWRCC, Los Angeles County Sanitation District, and Californians for Homeownership. Copies of these letters are attached for the City Council' s consideration.

2. Housing Needs Assessment and RHNA Allocation
The Housing Element Update must include an analysis of current and projected housing needs in the City. Goals, policies, and programs are based on such an assessment. Detailed data on household characteristics, housing stock conditions, and demographic and employment trends are also required. Other data requirements include updated demographic information such as the following: 1) the total population; 2) the number of households overpaying for housing; 3) the number of households living in overcrowded conditions; and 4) special housing needs. It must also include the number of housing units that need rehabilitation, as well as assist affordable units at risk of converting to market rate.

The Housing Element Update must also discuss the City' s fair share of the RHNA established by SCAG. The RHNA allocation establishes the number of new units anticipated to be needed (by income category) to accommodate the expected population growth over the planning period.

State law requires that cities incorporate this allocation into their Housing Elements and plan accordingly. The Housing Element Update identifies the City' s RHNA, sets forth housing goals, policies, and programs and plans housing production for all household types and income categories, including seniors, large households, persons with disabilities, and the workforce.

Most importantly, the Housing Element Update must demonstrate that the City can accommodate its RHNA over the next eight -year planning period. Table 1 provides a summary of the City' s RHNA and its breakdown by income category:

Table 1: Regional Housing Needs Assessment Allocation for the City of Santa Clarita Above
Moderate- Moderate -
Very Low- Low- income income income
income 51- 80% 81- 120% above Total
0- 50% AMI) AMI) AMI) 120% AMI)
RHNA
Allocation 3, 397 1, 734 1, 672 3, 228 10, 031
Income Category ( based on AMI — Area Median Income for Los Angeles County)

3. Housing Sites and Inventory
The 2021- 2029 Housing Element Update must include a sites inventory demonstrating the City has enough suitable sites to accommodate the number of units by each income category included in the City' s RHNA allocation. The Housing Element sites inventory demonstrates that the City has adequate sites to meet its RHNA allocation under existing zoning. All sites included in the sites inventory are currently zoned appropriately for residential development; therefore, no rezoning of sites is required. Table 2 provides the City' s 2021- 2029 RHNA allocation and a summary of the sites inventory and RHNA surplus by income category.

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Maps and a corresponding table of the sites can be found in Figures 14 and 15 and Appendix D, respectively, in the Housing Element Update. Of the City' s 10, 031- unit total RHNA obligation, 186 lower-, 22 moderate-, and 9, 177 above moderate -income units are accounted for by approved and planned units (refer to Table 12 of the Housing Element Update) and through Accessory Dwelling Unit (ADU) development. After subtracting these units from the RHNA allocation, there is a sum of 6, 595 units needed to accommodate the City' s remaining RHNA allocation, including 3, 349 units affordable at the very low- and extremely low-income levels, and 1, 596 units affordable at the low-income level. The City has identified suitable sites to realistically accommodate an additional 9, 845 potential units under current zoning, with an approximately 23 percent buffer for the very low- and low-income categories and a 46 percent buffer for the moderate -income category, as shown in Table 2. More than 50 percent of the City' s low-income RHNA obligation can be met on vacant sites.

Table 2: RHNA Surplus by Income Group
Very
LowincomeLowincomeModerateincome
Above
Moderate -
income Total
RHNA Allocation 3, 397 1, 734 1, 672 3, 228 10, 031
Approved and Planned Units 0 53 0 9, 082 9, 135
ADUs 48 85 22 95 250
Remaining RHNA Allocation
After Credits 3, 349 1, 596 1, 650 0 6, 595
Units on Vacant Sites 1, 956 920 1, 777 4, 653
Units on Non -vacant Sites 2, 181 1, 027 625 1, 359 5, 192 Total Units After Credits 45137 1, 947 2, 402 1, 359 9, 845 Total Unit Surplus 788 351 752 7, 308 9, 199
Buffer above Remaining
RHNA After Credits 24% 22% 46% 100%

4. Housing Constraints
In compliance with Government Code Section 65583, sections 4. 4. 1 and 4.4. 2 of the Housing Element Update identify and analyze potential non -governmental and governmental constraints to the production and retention of housing.

Housing Element law requires local jurisdictions to identify governmental constraints to the production of housing, such as land use regulations, housing policies, fees, zoning, and other factors that influence the price and availability of housing. The Housing Element must analyze land use controls, fees and exactions, on- and off -site improvement requirements, building codes, permit and processing procedures, and potential constraints on the developments or improvements of housing for persons with disabilities. The Housing Element Update generally finds that the City' s land use controls do not create unnecessary constraints to housing development. In addition, non -governmental constraints must be analyzed, including the availability and cost of land, as well as construction. These constraints are often out of the City' s

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control and can result in housing that is not affordable to low- and moderate -income households.

5. Housing Resources
Section 4. 3 of the Housing Element Update identifies housing resources, including financial and administrative resources that are available to assist the City in meeting its housing needs.

Identified housing resources include housing assistance programs, resources for the homeless population, supportive and transitional housing resources, an inventory of assisted rental housing developments, and planning and zoning programs.

6. Goals and Policies
The Housing Element Update includes four goals that serve as the framework for implementing its housing policies and programs. The Housing Element Update recommends minor modifications to the City' s current Housing Element goals and policies. Other updates to goals, policies, objectives, and programs are required to comply with state law. The following is a summary of those goals. A complete list of the 35 policies that implement these goals is provided in Section 2. 1 of the Housing Element Update.

Goal Hl: Identify and maintain adequate sites to accommodate the City' s regional housing need through the planning period.

Goal H2: Promote the production of housing units, including affordable units, to meet the City' s identified housing needs.

Goal H3: Sustain and improve existing housing units and programs.

Goal H4: Ensure fair access to quality housing and services for all members of the community, including those with special needs.

7. Programs
The Housing Element Update includes 37 programs that implement the housing policies referenced above. Many of the programs are existing programs that will be continued. The update also includes a number of new programs to address state housing law, including future required updates to the UDC, new programs to support affirmatively furthering fair housing, and tracking and reporting requirements for housing sites. The following is a summary of the key implementing programs. A complete list of programs is provided in Section 2.2 of the Housing Element Update.

Housing Sites and No Net Loss
o HP- 1. 1 — Track units built on identified housing sites to ensure sufficient residential capacity is maintained to accommodate the RHNA for each income category. o HP- 1. 2 — Identify replacement sites and ensure compliance with SB 166.

Zoning Programs
o HP- 1. 4 — Complete a study to determine potential additional local density bonuses and incentives for affordable housing developments.
o HP- 1. 7 — Complete a feasibility study to determine the financial and programmatic feasibility of an inclusionary housing ordinance/requirement.

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o HP- 1. 5 — Continue incentives allowed for developments in the mixed use overlay zone. o HP- 1. 6 — Continue the density/height incentives granted to certain development projects in Old Town Newhall.
o HP- 1. 13—Amend the zoning code and/or create an overlay zone for housing sites used for multiple Housing Elements and allow by -right approval requirements if at least 20 percent of units are affordable to lower -income households. o HP- 2. 1— Amend the zoning code to address recent changes to state law; update the ADU ordinance to ensure compliance with state law.

Housing Rehabilitation, Preservation, and Affordable Housing Programs o HP- 2. 5 — Collaborate with non-profit affordable housing developers. Enter into an agreement with a developer to identify suitable land for the development of an affordable housing project.
o HP- 3. 2 — Continue to provide financial support to the handyworker program, which offers grants up to $5, 000 to lower -income households for home repairs. o HP- 3. 3 — Continue to provide financial support to the property rehabilitation program, which offers grants up to $ 1, 500 to lower -income households for property maintenance and repairs.
o HP- 3. 5 — Work to preserve the affordable units that are at risk of converting to market - rate rents.
o HP- 3. 6 — Continue to implement the mobilehome rent adjustment policies to protect park residents from unreasonable rent increases.

Fair Housing
o HP- 4. 4 — Continue to update the fair housing assessment every five years. o HP- 4. 5 — Continue to contract with the City' s fair housing services consultant and conduct outreach and education on fair housing.
o HP-4. 11—Implement the identified actions to address fair housing issues.

IMPLEMENTATION MEASURES
Several housing programs include implementation components that will require review by the Planning Commission and/or the City Council at a future date. Some of these include future amendments to the City' s UDC, as required by the state. A summary of these implementation measures is provided below:

Program HP- 1. 7: Inclusionary Housing Feasibility Study — Complete a feasibility study to determine the financial and programmatic feasibility of an inclusionary housing ordinance/requirement. Once completed, present the study to the City Council Development Committee by early 2025.

2. Program HP- 1. 4: Affordable Housing Density Bonus —As apart of the inclusionary housing feasibility study, a study will be completed by 2024 to determine the appropriate additional local densities and incentives, above those allowed by the state, to development projects that meet the City' s housing needs.

3. Program HP- 1. 13: Sites that were identified in prior Housing Elements and are used again in

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the Housing Element Update are subject to by -right approval requirements if at least 20 percent of units are affordable to lower -income households. A future UDC amendment and/or overlay zone to address this statute will be completed by 2024. By adopting a local ordinance, the City will be able to reserve its ability to apply design review to these projects.

4. Programs HP- 2. 1 and HP- 2. 3: Zoning Code and Specific Plan Amendments for a Variety of Housing Types:

Several new bills were recently signed into law that require revisions to permitting requirements for transitional and supportive housing, low barrier navigation centers, and employee and agricultural worker housing. UDC amendments will be completed by the end of 2023 to ensure consistency with state law.

The City submitted its adopted ADU ordinance to HCD in February 2021 but has not received a formal review letter; however, HCD indicates it will be providing a review letter and will be requiring amendments to the ADU ordinance to ensure consistency with state law.

CALIFORNIA DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

CERTIFICATION

BENEFITS OF CERTIFICATION AND RISKS OF NONCERTIFICATION Because housing needs are recognized as a matter of statewide concern, the state, through HCD, must certify the compliance of every jurisdiction' s Housing Element upon adoption.

Benefits of a certified Housing Element include maintaining eligibility for state funding, maintaining discretionary review over housing projects, and the presumption of legal adequacy if litigated. A noncompliant Housing Element, however, can result in consequences including loss of certain state funding sources, reduced local zoning control, and more abbreviated timelines for re -zoning. State Housing Element laws have been greatly strengthened in recent years and includes referring jurisdictions to the Office of the Attorney General. Cities could be fined by the Court and could also lose their ability to issue residential building permits; therefore, certification of the Housing Element is very important.

STATUTORY DEADLINE
The statutory deadline and the grace period for the City to adopt the 2021- 2029 Housing Element Update was October 15, 2021, and February 11, 2022, respectively. According to SLAG, 191 out of 197 Southern California jurisdictions, including the City, did not have certified Housing Elements as of February 11, 2022. Delays in adopting and certifying Housing Elements could be attributed to a number of factors including stringent new requirements, additional HCD scrutiny, record -high RHNA allocations, delayed final RHNA allocations, and the COVID- 19 pandemic.

The City posted the Draft Housing Element for public review and submitted it to HCD in October and November 2021, respectively, prior to the deadline. The City has made significant progress in addressing all of the comments provided by HCD following its review of the Draft Housing Element and remains committed to completing the public hearing process and

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diligently working with HCD to address its comments and complete the Housing Element Update.

NEXT STEPS
Following this public hearing, staff will work with the consultant team to incorporate any City Council direction into the final Housing Element Update. If adopted by the City Council, staff would then submit the final Housing Element to HCD for a 60- day review, where HCD should determine it is consistent with the state Housing Element Law and certify the Housing Element.

If HCD determines that the Housing Element needs additional analysis and revisions to comply with state Housing Element Law, staff will make the revisions and may bring the Housing Element back for re -adoption at future public hearings, if needed. Once HCD certifies that the Housing Element is compliant, the City' s 2021- 2029 Housing Element Update will be complete.

ENVIRONMENTAL REVIEW
A Draft Negative Declaration and Initial Study were prepared for the proposed project and made available for public review from December 16, 2021, to January 18, 2022, during which the Community Development Department received five comment letters. During the public review period, a copy of the Negative Declaration and all supporting documents were available on the City' s website and in the City Clerk' s Office. The Final Initial Study, including responses to comments, was made available for public review and sent to all commenters on March 18, 2022.

The Final Negative Declaration and Initial Study are attached.

PUBLIC NOTICING
All noticing requirements for the public hearing have been completed as required by Section

17. 06.110 of the UDC. A one-eigth page advertisement was placed in The Signal newspaper on April 19, 2022. An email notification was sent to the project notification list. The public hearing notice is attached.

ALTERNATIVE ACTION
Other action as determined by the City Council.

FISCAL IMPACT
There is no fiscal impact associated with this proposed project.

ATTACHMENTS
Public Hearing Notice
Resolution
HCD Findings Letter
City' s Response to HCD Letter Matrix

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Comment Letters
Housing Element Update ( available in the City Clerk's Reading File) Safety Element Update ( available in the City Clerk's Reading File) Safety Element Update Redlines ( available in the City Clerk's Reading File) Planning Commission Resolution and Staff Report (available in the City Clerk's Reading File) Draft Negative Declaration and Initial Study ( available in the City Clerk's Reading File) Final Negative Declaration and Initial Study (available in the City Clerk's Reading File)

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17. a

CITY OF SANTA CLARITA

COMMUNITY DEVELOPMENT DEPARTMENT
23920 Valencia Boulevard, Suite 302
Santa Clarita, CA 91355

NOTICE OF PUBLIC HEARING
APPLICATION: Master Case 21- 088: General Plan Amendment 21- 001 and Initial Study 21- 009 Housing Element and Safety Element Updates)
PROJECT APPLICANT: City of Santa Clarita
PROJECT LOCATION: Citywide
PROJECT DESCRIPTION: State law requires that all jurisdictions periodically update their Housing Element. In order to comply with this state requirement, the City of Santa Clarita ( City) has prepared an update to the General Plan Housing Element. The current Housing Element was adopted in October 2013 and the proposed update would serve as the City' s Housing Element for the sixth Housing Element cycle, through October 2029. State law also requires that upon this update of the Housing Element, the Safety Element be updated. An update ofthe Safety Element has also been prepared in compliance with state law.

Electronic versions of the draft Housing Element documents are available on the project website at santaclarita.com/ housingelement.

The City of Santa Clarita City Council will conduct a public hearing on this matter on the following date:

DATE: Tuesday, May 10, 2022
TIME: At or after 6: 00 p.m.

LOCATION: City Hall, Council Chambers
23920 Valencia Blvd., First Floor, Santa Clarita, CA 91355 PLANNING COMMISSION ACTION: On April 5, 2022, by a 5- 0 vote, the Planning Commission adopted Resolution P22- 04, recommending the City Council adopt the Negative Declaration prepared for the project and approve Master Case 21- 088 and adopt the Housing Element and Safety Element Updates.

ENVIRONMENTAL REVIEW: A Draft Negative Declaration and Initial Study was prepared for the proposed project and made available for public review from December 16, 2021 to January 18, 2022, during which the Community Development Department received comments. During the public review period, a copy of the Draft Negative Declaration and all supporting documents were available at the City Clerk' s Office, at 23920 Valencia Boulevard, Suite 120, Santa Clarita, CA 91355, and on the City' s website santaclarita.com/ planning). A Final Negative Declaration and Initial Study was made available on the City' s website on March 18, 2022.

If you wish to challenge the action taken on this matter in court, you may be limited to raising only those issues you or someone else raised at the public hearing described in this notice, or written correspondence delivered to the City of Santa Clarita at, or prior to, the public hearing.

For further information regarding this proposal, you may contact the project planner at the City of Santa Clarita, Permit Center, 23920 Valencia Blvd., Suite 140, Santa Clarita, CA 91355. Telephone: ( 661) 255- 4330. Website: www. santa- clarita. com/ planning. Send written correspondence via e- mail to jchow@santaclarita.com, or by US mail to: City of Santa Clarita Planning Division, 23920 Valencia Blvd., Suite 302, Santa Clarita, CA 91355. Project Planner: James Chow, Senior Planner.

Mary Cusick, MMC
City Clerk
Published: The Signal, April 19, 2022
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17b
RESOLUTION NO. 22-

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA CLARITA,

CALIFORNIA, ADOPTING THE NEGATIVE DECLARATION PREPARED FOR THE PROJECT AND APPROVING MASTER CASE 21- 088 ( GENERAL PLAN AMENDMENT 21- 001), AMENDING THE HOUSING ELEMENT AND THE SAFETY ELEMENT OF THE

CITY OF SANTA CLARITA' S GENERAL PLAN

THE CITY COUNCIL OF THE CITY OF SANTA CLARITA, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS:

SECTION 1. FINDINGS OF FACT. The City Council does hereby make the following findings of fact:

On June 14, 2011, the City Council adopted the Santa Clarita General Plan, by adoption of Resolution No. 11- 61. The General Plan includes the state mandated elements required by the State of California, including the Housing Element and the Safety Element.
b. On October 22, 2013, the City Council adopted the 2013- 2021 Housing Element. c. The State of California Government Code Section 65588 requires the review and adoption of a Housing Element that is updated according to the Southern California Association of Governments Regional Housing Needs Assessment (RHNA) planning cycle.
d. Following receipt of grant funding from the California Department of Housing and Community Development ( HCD) under the Planning Grants Program provisions of Senate Bill (SB) 2, the City Council authorized a contract with the City of Santa Clarita' s ( City) consulting team of 4LEAF, Inc., and Rincon Consultants, Inc., on January 26, 2021, to prepare the updates to the Housing Element (" Housing Element Update" or " 2021- 2029 Housing Element") and the Safety Element.

The proposed project is identified as Maser Case 21- 088 ( project), consisting of General Plan Amendment 21- 001, which includes updates to the Housing Element and the Safety Element of the City' s General Plan to ensure consistency with all State of California requirements.
f. The State of California Government Code Section 65583( c)( 9) requires that local jurisdictions make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the Housing Element must describe this effort. Public outreach was conducted to allow and encourage meaningful public participation. Staff and consultants made use of multiple digital platforms to facilitate public input. Public participation included the establishment of the Housing Element Update website in March 2021; stakeholder interviews between January 2021 and September 2021; an online community opinion

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17. b
survey that was conducted in English and Spanish in the spring of 2021; a virtual community workshop to introduce major elements of the Housing Element Update process on April 29, 2021; the distribution of informational flyers at City libraries and on the City' s buses; a study session meeting with the Planning Commission on June 15, 2021; and a City Council Development Committee meeting on March 30, 2022. Concerns raised during these public participation events were addressed in the 2021- 2029 Housing Element and Safety Element updates.
g. On October 29, 2021, the complete public review Draft Housing Element Update was released, emailed to interested parties, and made available on the City' s website. h. On November 12, 2021, a draft of the Housing Element Update was submitted to HCD for its 60- day review.

On January 11, 2022, a comment letter from HCD on their review of the Draft 2021- 2029 Housing Element was received by staff. Revisions to the Draft 2021- 2029 Housing Element have been made pursuant to HCD' s comments and the document has been updated to comply with State Housing Element Law. j. The City Council acknowledges that comments on the Draft Housing Element provided by HCD will be considered and incorporated as appropriate prior to final adoption of the 2021- 2029 Housing Element by City Council, in compliance with state law.
k. In accordance with California Government Code Section 65302.5, the updated Safety Element was submitted to the California Board of Forestry and Fire Protection ( BOF) and the California Geological Survey for review. On January 18, 2022, the Resource Protection Committee of the BOF completed its review and assessment of the updated Safety Element and determined it meets the requirements of Government Code Section 65302.

1. The Planning Commission held a duly -noticed public hearing on April 5, 2022, in accordance with the City' s noticing requirements. The public hearing for the Housing Element and Safety Element updates was advertised in The Signal newspaper on March 15, 2022. The public hearing was held at City Hall, 23920 Valencia Boulevard, Santa Clarita, at 6: 00 p.m.
m. At the public hearing held on April 5, 2022, the Planning Commission received City staff s presentation summarizing the proposed project, conducted the public hearing, and received public testimony regarding the project and the Negative Declaration prepared for the project. The Planning Commission, in a 5- 0 vote, recommended the City Council adopt the Negative Declaration prepared for the project and adopt the Housing Element and Safety Element Updates. Included in their recommendation was a request to make a minor revision to the Safety Element clarifying the service area for the Pitchess Detention Center.
n. The City Council held a duly -noticed public hearing on May 10, 2022, in accordance with the City' s noticing requirements. The public hearing for the Housing Element

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and Safety Element updates was advertised in The Signal newspaper on April 19, 2022. The public hearing was held at City Hall, 23920 Valencia Boulevard, Santa Clarita, at 6: 00 p.m.
o. At the public hearing held on May 10, 2022, the City Council received City staff s presentation summarizing the proposed project, conducted the public hearing, and received public testimony regarding the project and the Negative Declaration prepared for the project.
p. Based upon the staff presentation, staff report, and public comments and testimony, the City Council finds that the project will not adversely affect the health, peace, comfort, or welfare of persons residing in the area; nor will the project jeopardize, endanger or otherwise constitute a menace to the public health, safety, or general welfare.
q. The location of the documents and other materials that constitute the record of proceedings upon which the decision of the City Council is based for the Master Case 21- 088 project file is with the Community Development Department; the record specifically is in the custody of the Director of Community Development.

SECTION 2. CALIFORNIA ENVIRONMENTAL OUALITY ACT FINDINGS. Based upon the foregoing facts and findings, the City Council hereby find as follows:
a. An Initial Study and a Negative Declaration for this project have been prepared in compliance with the California Environmental Quality Act ( CEQA). b. The Draft Initial Study has been circulated for review and comment by affected governmental agencies and the public, and all comments received have been considered. The Draft Negative Declaration was advertised and posted on December 16, 2021, in accordance with CEQA. The public review period was open from December 16, 2021, through January 18, 2022.
c. A Final Initial Study, which includes responses to comments and revisions to the Draft Initial Study ( Errata), was prepared, published for public review, and sent to all commenters on March 18, 2022.
d. There is no substantial evidence that the project will have a significant effect on the environment. The Negative Declaration reflects the independent judgment of the City.

The documents and other material which constitute the record of proceedings upon which the decision of the City Council is made is the Master Case 21- 088 project file, located within the Community Development Department and is in the custody of the Director of Community Development.
f. The City Council, based upon the findings set forth above, hereby finds that the Negative Declaration for this project has been prepared in compliance with CEQA.

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SECTION 3. GENERAL FINDINGS FOR MASTER CASE 21- 088. Based on the foregoing facts and findings for Master Case 21- 088, the City Council hereby finds as follows:
a. The proposal is consistent with the General Plan.

The project is consistent with the General Plan' s objectives, policies, and procedures. The proposed update to the Housing Element and the Safety Element of the City' s General Plan ensures consistency with all requirements of the State of California Government Code. The amendments to the Housing Element and Safety Element would not result in amendments to any other elements of the General Plan.
b. The proposal is allowed within the applicable underlying zone and complies with all other applicable provisions ofthis code.

The proposed amendments to the Housing Element and Safety Element would not result in any General Plan land use changes or zoning changes. 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. The proposal will not endanger, jeopardize, or otherwise constitute a hazard to the public convenience, health, interest, safety, or general welfare, or be materially detrimental or injurious to the improvements, persons, property, or uses in the vicinity and zone in which the property is located.

Nothing contained in the proposed amendments would endanger, jeopardize, or otherwise constitute a hazard to the public. The proposed amendments to the Housing Element and Safety Element consist of updates as required by state law and would not be materially detrimental or injurious to the improvements, persons, property, or uses in the vicinity. d. The proposal is physically suitable for the site. The factors related to the proposal' s physical suitabilityfor the site shall include, but are not limited to, the following:

1. The design, location, shape, size, and operating characteristics are suitablefor the proposed use.

2. The highways or streets thatprovide access to the site are ofsufcient width and are improved as necessary to carry the kind and quantity oftraffic such proposal would generate.

3. Public protection service ( e.g., Fire protection, Sheriffprotection, etc.) are readily available.

4. The provision of utilities ( e.g. potable water, schools, solid waste collection and disposal, storm drainage, wastewater collection, treatment, and disposal, etc) is adequate to serve the site.

The proposal is physically suitable for the site in terms of location, shape, size, and operating characteristics. The proposed amendments to the Housing Element and Safety

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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 ofthe findings per Section] 7. 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 ofdevelopment resulting from the General Plan amendment shallfully 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 ofthefollowingfindings:

1. The proposed General Plan amendment is consistent with other elements ofthe City' s General Plan pursuant to Government Code Section 65300. 5.

2. The proposed General Plan amendment, ifapplicable, responds to changes in state and/orfederal law pursuant to Government Code Section 65300. 9.

3. The proposed General Plan amendment has been referred to the County ofLos 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 I01h 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 I01h of May, 2022, by the following vote:

AYES: COUNCIL, MEMBERS:

NOES: COUNCIL, MEMBERS:

ABSENT: COUNCIL, MEMBERS:

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/ housingelemen

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EXHIBIT B

SAFETY ELEMENT UPDATE ( HEARING DRAFT)

INCORPORATED BY REFERENCE

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

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Attachment
HCD Findings Letter
Master Case 21- 088
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STATE OF CALIFORNIA- BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
0 El
Sacramento, CA 95833
916) 263- 2911 / FAX ( 916) 263- 7453
www. hcd. ca. gov
January 11, 2022
Tom Cole, Director
Community Development Department
City of Santa Clarita
23920 W. Valencia Blvd. Suite 302
Santa Clarita, CA 91355
Dear Tom Cole:

RE: City of Santa Clarita' s 6th Cycle ( 2021- 2029) Draft Housing Element Thank 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).

The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10. 6 of the Gov. Code) The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

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

For your information, pursuant to Assembly Bill 1398 ( Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of the statutory deadline ( October 15, 2021), then any rezoning to accommodate the regional housing needs allocation ( RHNA), including for lower -income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government' s housing element will no longer comply with State Housing Element Law, Packet Pg. 151

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Tom Cole, Director

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

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower -income and special needs households, by making information regularly available and considering and incorporating comments where appropriate.

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

For 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.

HCD 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 Reid. Miller(a) hcd. ca. gov.

Sincerely,
ve( Z.-I 7
Paul McDougall
Senior Program Manager
Enclosure
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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 httD:// www. hcd. ca. aov/ communitv- development/ buildina- 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).

City of Santa Clarita' s 6t" Cycle Draft Housing Element Page 1 January 11, 2022
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B. Housing Needs, Resources, and Constraints

1. Affirmatively furtherfing] 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).) 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 City of Santa Clarita' s 6t" Cycle Draft Housing Element Page 2 January 11, 2022
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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 ofpopulation 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).)
City of Santa Clarita' s 6t" Cycle Draft Housing Element Page 3 January 11, 2022
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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 6t" 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 City of Santa Clarita' s 6t" Cycle Draft Housing Element Page 4 January 11, 2022
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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.

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 City of Santa Clarita' s 6t" Cycle Draft Housing Element Page 5 January 11, 2022
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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 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).)
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.

City of Santa Clarita' s 6t" Cycle Draft Housing Element Page 6 January 11, 2022
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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, setbacks, 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.

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.

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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 nonlowincome 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
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 City of Santa Clarita' s 6t" Cycle Draft Housing Element Page 11 January 11, 2022
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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.

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 City of Santa Clarita' s 6t" Cycle Draft Housing Element Page 13 January 11, 2022
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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 131, 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 City of Santa Clarita' s 6t" Cycle Draft Housing Element Page 14 January 11, 2022
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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
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
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:

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 Dersons experiencina homelessness).

B. Housing Needs, Resources, and Constraints
Added new section 1. 14. 2 elaborating further on the
City' s effectiveness in meeting the housing needs of
special needs populations
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
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)
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.

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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).)
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.

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.

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.

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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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 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. 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
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
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 Sites have been evaluated and analyzed in relationship demonstrating whether sites identified to meet the RHNA to the findings of each subsection of the Assessment of are distributed throughout the community in a manner that Fair Housing. The sites are analyzed in such a way to affirmatively furthers fair housing. A full analysis should demonstrate that their distribution affirmatively furthers address the income categories of identified sites with fair housing. Improvement and exacerbation of conditions respect to location, the number of sites and units by all is discussed. 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: Additional information is included throughout the The element must include local data, knowledge, and other Assessment of Fair Housing that includes local data relevant factors to discuss and analyze any unique sources and local knowledge to further the discussion attributes about the City related to fair housing issues. The and analysis of Fair Housing in Santa Clarita. This is element should complement federal, state, and regional summarized in 4. 5. 2 Local Data, Knowledge, and Other data with local data and knowledge where appropriate to Relevant Factors 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 Contributing factors have been identified at the element identifies contributing factors to fair housing issues, conclusion of each subsection. it should prioritize these factors to better formulate policies and programs and carry out meaningful actions to AFFH. Contributing factors are linked to specific, actionable The element should link contributing factors to specific programs. programs where possible. In addition, many of the
strategies " consider" actions but do not provide

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implementation components to mitigate the fair housing Contributing factors are now summarized and prioritized issues identified in the analysis. 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 Goals and actions have been added and modified to outcomes of a complete analysis. Goals and actions must address identified needs, and additional analysis has specifically respond to the analysis and to the identified and been provided. Actions are linked to contributing factors prioritized contributing factors to fair housing issues and and have specific commitments, metrics, and milestones must be significant and meaningful enough to overcome to address fair housing issues. 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).

Extremely Low -Income ( ELI) Households: The element Element now includes a quantification and analysis of incudes some basic information regarding ELI households extremely low- income housing needs within section such as the methodology of calculating the number of 1. 9. 2, Household Incomes and Housing Affordability, and projected ELI households for the 6th cycle RHNA. However, references existing analysis in section 4.5 that led to the the element should also clearly state the projected number formation of policies and programs to address needs of of ELI households. Additionally, given the unique and ELI households. disproportionate needs of ELI households, the element must The section also references these programs:
include analysis to better formulate policies and 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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Housing Costs: While the element includes information on Element now includes information on rental costs in sales prices, the element must also include average rental current market conditions, as well as a comparison cost information. Please note that the American Community between the City's rental costs and those of the region.

Survey does not fully reflect current market conditions and This section uses market - based sources in addition to the element should include additional data sources. American Community Survey data.

Overpayment: While the element identifies the total number Element now includes additional analysis on of households overpaying for housing, it must also quantify overpayment and quantification of households and analyze the number of households overpaying by overpaying by tenure. 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 Added text and data table into section 1. 10. 3 on Housing housing stock ( p. 53 & 54). However, it must include Conditions with data, analysis, and identified actions to analysis of the condition of the existing housing stock and address need. 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 nonprofit 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 a
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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.

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
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.

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 Severitv Zones
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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17. d
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.
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.

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.

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.

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'/ 2 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 '/2 acre or less are regularly developed with housing and that
additional programs to incentivize development on small sites will not be 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 HP2. 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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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. 4)
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.

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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17. d
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).

Accessory Dwelling Units ( ADU): The element projects 400 ADU projections have been updated to reflect the " safe ADUs over the planning period or approximately 50 ADUs harbor" average number of ADUs permitted annually per year over the eight -year planning period. Given that the since 2018. With data now available for 2021, the City has only produced an average of 28 units per year average now includes 2021 permits, resulting in an since 2018, it is not clear if this production level will be average of 31. 25 ADUs per year from 2018- 2021. The achievable in the planning period. As a result, the element Housing Element now projects 31. 25 ADUs per year, or should be updated to include a realistic estimate of the 250 ADUs over the planning period, consistent with potential for ADUs and include policies and programs that HCD' s guidance to calculate a realistic estimate of incentivize the production of ADUs. Depending on the potential ADU development. analysis, the element must commit to monitor ADU
production throughout the course of the planning period and In addition, a new program ( New Program number HP - implement additional actions if not meeting target numbers 2. 6) has been added to incentivize and promote anticipated in the housing element. In addition to monitoring Accessory Dwelling Units, as follows:
production, this program should also monitor affordability.

Additional actions, if necessary, should be taken in a timely Program HP- 2. 6: Provide for Accessory Dwelling Units manner ( e. g., within six months). Finally, if necessary, the and Junior Accessory Dwelling Units ( GC 65583, c ( 7)) degree of additional actions should be in stride with the degree of the gap in production and affordability. For Increase awareness of the by -right opportunities for example, if actual production and affordability of ADUs is far Accessory Dwelling Units and Junior Accessory Dwelling from anticipated trends, then rezoning or something similar Units by producing an informational brochure/ handout, a would be an appropriate action. If actual production and simplified application, process, and a dedicated phone affordability is near anticipated trends, then measures like number and/ or email for questions about and assistance outreach and marketing might be more appropriate. 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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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.
assistance tools, financing and lending programs
https:// www. laadu. ora/) by the end of 2023
Annually report out on the City' s successes in the
Droduction of ADUs and JADUs with the Citv' s APR.

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.

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

I Zonina for a Varietv of Housina Tvpes: I I
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 A13139/ Government Code
section 65583, subdivision ( a)( 4)( A) or include a program as necessa
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 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.

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 reauirements.

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)
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. 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.
as amended by SB 2 and Government Code 65651 as
amended by AB 2126."
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".

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."
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 The element now clarifies the State requirements, manufactured housing is allowed as a single- family clarifies the City' s compliance with these requirements, residence if on a permanent foundation. If the zoning does and references where the Unified Development Code not comply, a program should be added. provides relevant development standards.

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
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."
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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17. d
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 Additional information has been provided on lot all relevant land use controls impacts as potential development standards, typical densities of development, constraints on a variety of housing types. The analysis parking requirements, and density bonus programs. should analyze land use controls independently and
cumulatively with other land use controls. The element must A section has been added at the end of the previous specifically include requirements related to heights, set- development standards section within Section 4. 2. 2 backs, lot coverage, unit sizes and limits on allowable analyzing the impact of land use controls on housing densities. The analysis should address any impacts on cost, development, including an analysis of their cumulative supply, housing choice, affordability, timing, approval impact. certainty and ability to achieve maximum densities and
include programs to address identified constraints. In Additional text has been added to Parking Requirements addition, the element discusses parking requirements section of Constraints Analysis:
including enclosed spaces, two spaces for one -bedroom
units for multifamily development, high guest parking AB 2345 ( 2020) made significant changes to the State requirements, and specific parking standards for residential Density Bonus Law for projects providing affordable care services. These parking requirements must be units, including requirements for the granting of a larger analyzed as a constraint and addressed with a program. 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.

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 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.

The Element now contains information in the Local
Processing and Permit Procedures section ( Section

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.

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.

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.

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.

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

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.

Whilethe 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)( 1), 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:

Asthe 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.

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.

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

Location: Permitting Procedures within Governmental
Constraints Planning and Zoning Programs and Program
H P- 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.

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.

Local Permit Procedures section now includes:

In addition, Program HP- 2. 2 will ensure the City
develops and publishes written standards for the SIB 35 Streamlined Ministerial Process."
Program HP- 2. 2 has been added as follows:

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

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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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.

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.
map approximately one month following the entitlement
of the project. The 2015 Kansas Street 10- unit multifamily 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."
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.

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 Orchard Arms is owned and operated by the County of are eligible to change to nonlow- income housing uses Los Angeles / Housing Authority of the County of LA. during the next 10 years due to termination of subsidy Information has been provided in Section 4. 3. 6 to clarify contracts, mortgage prepayment, or expiration of use that the Orchard Arms restrictions do not expire within restrictions. ( Gov. Code, § 65583, subd. ( a)( 9) through the next 10 years, as it was built as conventional public 65583( a)( 9)( D).). housing and is considered affordable in perpetuity. a
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The element must clarify when the use restriction for Program 3. 5 has been changed to address the Orchard Arms expires. If the restriction ends within the next government code requirements for early notification 10 years, the element must include an at -risk analysis ( Gov. beginning 3 years prior to expiration.

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 has been changed to add the requested Program should clarify if the existing density bonus timeline, and to better reflect the concurrent review and ordinance will be updated and/ or implemented by 2023. If study that will be necessary to bring forth a proposal for not, the program should include a timeline of when the both a new inclusionary program and, at the same time, ordinance will be updated. The portion of the program that incentives to complement and work together to support will be " considered" should also be modified to include a the construction of affordable housing while still more discrete implementation component. 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 Program has been changed to clarify that the program is is continuing from the past element, the element should a continuation from the last Element, and to provide the describe what will be implemented by 2024. It should also 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
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.

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)
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 threestory height limit for projects not involving full block developments.

Program HP- 1. 7 ( Inclusionary Housing Program- Mixed Program has been significantly revised to better reflect Income Housing): The program should be revised to include the nature of the work that will need to take place before implementation element, not just " consider", as well as what reconsideration of an inclusionary program. Timeframes incentives are being considered, and what will be are also provided:
accomplished by 2024.

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 a
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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.
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 stud 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 Program ( renumbered HP- 1. 11) has been amended to Developers): This program should describe the 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.

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 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 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 bodv."
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 Continue to provide incentives for affordable housing implementation and a proactive outreach component. 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."
Program HP- 2. 5 ( Fee Reductions or Deferrals for Affordable Clarification regarding fee deferrals is provided; the and Special Needs Housing): This program should describe Program has been converted to a " continue" policy H2. 12 what determines eligibility and whether the eligibility determination is discretionary. The program should also Program HP- 2. 2 includes changes necessary to bring the strengthen the implementation language beyond " consider" City" s fee deferral practices in line with new fees being that fees were identified as a constraint. A specific transparency laws (AB 602 and SB 319) timeframe for implementation should also be included.

Program HP- 2. 6 ( Expedited Processing for Affordable Program HP- 2. 6 reflects existing practice and thus has Housing Projects): The program should be modified to been changed to a " continue to" policy as follows:
include outreach to developers as well as how often.

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 Program has been modified to address this request by should be modified to explain if there will be proactive adding the following language: " The City will continue to outreach to residents, clarify if the program will occur provide financial support for this Program annually, annually, and include a specific timeframe for contingent upon the availability of funds and approval implementation. 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 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 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 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"
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.

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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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.

HP-4. 6 ( Fair Housing Programs) should describe how often training and outreach be provided.

HP- 4. 7 ( Administrative Process for Reasonable
Accommodations) This program should be modified to
eliminate fees for applicants in the reasonable
accommodation process.
referrals for various services, and educational programs, among others, contingent upon the availability of funds and approval from HUD."
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.

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."
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 has been changed to add the requested program should describe how repairs and maintenance are information, as follows: " As part of Santa Clarita 2025

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17. d
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.

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.

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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17. d
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.

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
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:

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
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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17. d
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 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.

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."
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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17. d
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.

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 ( 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."
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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17. d
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).)
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
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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17. d
Programs must be expanded to include incentives to Policy 2. 8 has been amended to include Accessory promote the creation and affordability of ADUs. Examples Dwelling Units and Junior Accessory Dwelling Units, as include exploring and pursuing funding, modifying follows:
development standards and reducing fees beyond state law, increasing awareness, pre -approved plans and Policy H2. 8: Continue to expedite application review, homeowner/applicant assistance tools. In addition, given the permitting, and inspection procedures for Accessory City's assumptions for ADUs exceed recent trends, the Dwelling Units, Junior Accessory Dwelling Units, and element should include a program to monitor permitted affordable housing projects.

ADUs and affordability every other year and take Program HP- 2. 6 has been added to incentivize and appropriate action such as adjusting assumptions or promote Accessory Dwelling Units, as follows:
rezoning within a specified time period ( e. g., six months).

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,
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 Quantified Objectives have now been updated to can be constructed, rehabilitated, and conserved over a reference the impact of specified programs. five- year time frame. ( Gov. Code, § 65583, subd. ( b)( 1 & Quantified objectives for new construction now include 2).) ELI units.
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Packet Pg. 207

17. d
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
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 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

Packet Pg. 208

17. d
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.

Packet Pg. 209

17. e
Attachment
Comment Letters
Master Case 21- 088
r
Q
Packet Pg. 210

17. e
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], 1 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]
Packet Pg. 211
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45 List of Commenters from the

17. e
Southwest Regional Council of Carpenters
June 2021
Name Date Sent
Jordan Reyes Peter 6/ 29/ 2021
Emiliano Guidos 6/ 29/ 2021
Andrew Gonzalez 6/ 29/ 2021
Roberto De Paz 6/ 29/ 2021
Miguel Bedoy 6/ 29/ 2021
Antonio Zuniga 6/ 29/ 2021
Javier Hernandez 6/ 29/ 2021
Douglas Abarca 6/ 29/ 2021
Tatiana Depaz 6/ 29/ 2021
Sadie Lopez 6/ 29/ 2021
Leo Padron 6/ 29/ 2021
Ivan Jimenez 6/ 29/ 2021
Alberto Ramirez 6/ 29/ 2021
Brandon Solorzano 6/ 29/ 2021
David Hernandez 6/ 29/ 2021
Michael Cervantes 6/ 29/ 2021
Edward Mills 6/ 29/ 2021
Daniel Acosta 6/ 29/ 2021
Edgar Lara 6/ 29/ 2021
Andrew Kanamu 6/ 29/ 2021
Carlos Carbajal 6/ 29/ 2021
Elias Lopez 6/ 29/ 2021
Manny Martinez 6/ 29/ 2021
Josue Gil Zambrano 6/ 29/ 2021
Felix Campos 6/ 29/ 2021
Shaun Mieure 6/ 29/ 2021
Robert Moreno 6/ 29/ 2021
Alejandro Esqueda 6/ 29/ 2021
Roberto Villapondo 6/ 29/ 2021
Ryan Erickson 6/ 29/ 2021
Oscar Tirado 6/ 29/ 2021
Danny Gilchrist 6/ 29/ 2021
Ivan Burgara 6/ 29/ 2021
Arturo Becerra 6/ 29/ 2021
Quebin Vargas 6/ 29/ 2021
Gabriel Castaneda 6/ 29/ 2021
Yolanda Ochoa 6/ 29/ 2021
Jason Green 6/ 29/ 2021
Juan Hernandez 6/ 29/ 2021
Albert Dominguez 6/ 29/ 2021
Elias Echevarria 6/ 29/ 2021
Anibal Rios 6/ 29/ 2021
Dave Centeno 6/ 29/ 2021
Martin Sanchez - Gomez 6/ 29/ 2021
Jack Rutkowski 6/ 29/ 2021
Packet Pg. 212
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List of Commenters from the

17. e
Southwest Regional Council of Carpenters
June 2021
Gustavo Felix 6/ 29/ 2021
Gianni Rossi 6/ 29/ 2021
Carlos Jimenez 6/ 29/ 2021
Carlos Alonso 6/ 29/ 2021
Enrique Apodaca 6/ 29/ 2021
Eliseo Jorge 6/ 29/ 2021
Stephanie Chavez 6/ 29/ 2021
Erwin Jackson 6/ 29/ 2021
Carlos Chavez 6/ 29/ 2021
Ramiro Reyes 6/ 29/ 2021
Priscilla Caro 6/ 29/ 2021
Bonifacio Rojas 6/ 29/ 2021
Aldo Antimo 6/ 29/ 2021
Katherine Hernandez 6/ 29/ 2021
Robert Miller 6/ 29/ 2021
Antonio Munoz 6/ 29/ 2021
Maria Coronado 6/ 29/ 2021
Jennifer Bonilla 6/ 29/ 2021
Crystal Sanchez 6/ 29/ 2021
Brian Hovet 6/ 29/ 2021
Franklin Arteta 6/ 29/ 2021
Alfredo Resendiz 6/ 29/ 2021
Fidel Espinoza 6/ 29/ 2021
Brandon Castaneda 6/ 29/ 2021
Paris Jernigan 6/ 29/ 2021
Jose Campos 6/ 29/ 2021
Jonathan Pardo 6/ 29/ 2021
Tom Cummings 6/ 29/ 2021
Juan Salazar 6/ 29/ 2021
Phillip Roberts 6/ 29/ 2021
Anthony Contreras 6/ 29/ 2021
Marlon Miranda 6/ 29/ 2021
Rudy Hernandez 6/ 29/ 2021
Herbert Hardy 6/ 29/ 2021
Elias Martinez 6/ 29/ 2021
Emilio Sandoval 6/ 29/ 2021
David Lopez 6/ 29/ 2021
Michael Guzman 6/ 29/ 2021
Bonifacio Rojas 6/ 29/ 2021
David Benzie 6/ 29/ 2021
Joel Perez 6/ 30/ 2021
Alex Sonne 6/ 30/ 2021
Daniel Langford 6/ 30/ 2021
Oscar Vargas 6/ 29/ 2021
Trishton Belisle 6/ 29/ 2021
Sean Mann 6/ 30/ 2021
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List of Commenters from the

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Southwest Regional Council of Carpenters
June 2021
Joseph Ledesma 6/ 29/ 2021
Angel Tirado 6/ 29/ 2021
Josselyn Tirado 6/ 29/ 2021
Nicolas Reyes 6/ 29/ 2021
Katrina Powell 6/ 29/ 2021
Carolina Corona 6/ 29/ 2021
Kory Smith 6/ 29/ 2021
Ramiro Reyes 6/ 29/ 2021
Genoveva Reyes 6/ 29/ 2021
Consuelo Martinez 6/ 29/ 2021
Andres Martinez 6/ 29/ 2021
Jose Martinez 6/ 29/ 2021
Joe Ledesma 6/ 29/ 2021
Yvonne Vargas 6/ 29/ 2021
Pablo Ochoa 6/ 29/ 2021
Jeffrey Carranza 6/ 29/ 2021
Natali Mendoza 6/ 29/ 2021
Juan Medina 6/ 29/ 2021
Jesus Rodriguez 6/ 29/ 2021
Carlos Barrillas 6/ 29/ 2021
Eduardo Desantiago 6/ 29/ 2021
Madelio Vaca 6/ 29/ 2021
Neysa Gonzalez 6/ 29/ 2021
Luba Mirazadeh 6/ 29/ 2021
Michael Cabrera 6/ 29/ 2021
Stephenie Leiva 6/ 29/ 2021
Casey Lorenzen 6/ 29/ 2021
Corey Crockerha m 6/ 29/ 2021
Ruben Anguiano 6/ 29/ 2021
Baldo Lopez 6/ 29/ 2021
Eduardo Desantiago 6/ 29/ 2021
Roberto Leiva 6/ 29/ 2021
Angel Martinez 6/ 29/ 2021
Gonzalo Vasquez 6/ 29/ 2021
Jose Salcedo 6/ 29/ 2021
Luis Jauregui 6/ 29/ 2021
Omar Arellano 6/ 29/ 2021
Anthony Cardona 6/ 29/ 2021
Blake Powell 6/ 29/ 2021
Rebeca Galindo 6/ 29/ 2021
German Guitron 6/ 29/ 2021
Mike Ortiz 6/ 29/ 2021
Alex Ortiz 6/ 29/ 2021
Carlos Perez 6/ 29/ 2021
George Duenas 6/ 29/ 2021
Denis A. 6/ 30/ 2021
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List of Commenters from the

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Southwest Regional Council of Carpenters
June 2021
Susan Fuchs 6/ 30/ 2021
Robert Milewsky 6/ 30/ 2021
Byron Murray 6/ 30/ 2021
Eduardo Torres Garcia 6/ 30/ 2021
Jerred Langford 6/ 30/ 2021
Salvador Camacho 6/ 30/ 2021
David Copado 6/ 30/ 2021
Michael Marquez 6/ 30/ 2021
Ryan Jefferson 6/ 30/ 2021
Max Garcia Torres 6/ 30/ 2021
Andy Estrada 6/ 30/ 2021
Israel Pablo De Paz 6/ 30/ 2021
Anthonio Pablo 6/ 30/ 2021
Liliana Gomez 6/ 30/ 2021
Jorge Preciado 6/ 30/ 2021
Ron Diament 7/ 1/ 2021
Mike Simnowski 6/ 30/ 2021
Martin Virgen 6/ 30/ 2021
Yesenia Lopez 6/ 30/ 2021
Antonio Zamora 6/ 30/ 2021
Salina Guzman 6/ 30/ 2021
Leonel Serrano 6/ 30/ 2021
Alfredo Tapia 6/ 30/ 2021
Charles Lugo 6/ 30/ 2021
Cesar Banuelos 6/ 30/ 2021
Tim Glynn 7/ 1/ 2021
Packet Pg. 215

17. e
From: [ See attached commenter list for April 2022]
Sent: April 2022
To: housingelement@santa- clarita. com
Subject: Santa Clarita housing element update
Hi, my name is [ See attached commenter list for April 2022], 1 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 April 2022]
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29 List of Commenters from the

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Southwest Regional Council of Carpenters
April 2022
Name Date Sent
Jose Tapia 4/ 4/ 2022
Andruw Aguilar 4/ 4/ 2022
Jose G orrochotegui 4/ 5/ 2022
Rolando Galaviz 4/ 4/ 2022
Alexis Ramos 4/ 5/ 2022
Irvin Avelino 4/ 5/ 2022
Oscar Enciso 4/ 5/ 2022
Gustavo Ramirez Guerrero 4/ 5/ 2022
Carolos Ortega 4/ 5/ 2022
Mario Ramirez 4/ 5/ 2022
Carlos Cortez 4/ 5/ 2022
Clifford Kellgreen 4/ 5/ 2022
Jorge Barnadac 4/ 5/ 2022
Justin Alvarado 4/ 5/ 2022
Alfredo Hernandez 4/ 4/ 2022
Oscar Nunez 4/ 4/ 2022
Shane Lau 4/ 4/ 2022
Luis Jovel 4/ 4/ 2022
Alex Calderon 4/ 4/ 2022
Robert Hagen 4/ 4/ 2022
Omar Nevarez 4/ 4/ 2022
Robert Hagen 4/ 4/ 2022
Julian Jimenez 4/ 4/ 2022
Jose Hernandez 4/ 4/ 2022
Parker Pilney 4/ 4/ 2022
Christopher Larios 4/ 4/ 2022
Anthony Thompson 4/ 5/ 2022
Anthony Thompson 4/ 5/ 2022
Pedro Vizcaino 4/ 5/ 2022
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17e
P: ( 626) 381- 9248 139 South Hudson Avenue
F: ( 626) 389- 5414 Mitchell M. Tsai Suite 200
E: info@mitchtsailaw. com AttormeyAtLaw 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: mcusickgsanta- clarita. com
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 P. Bakersfield ( 2004) 124 Cal. App. 4th 1184, 1199- 1203; see Galante Vineyards v. Monterey hater 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 lFloodland ( 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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City of Santa Clarita — 6th Cycle Housing Element Update November 23, 2021

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 55 65000- 65010. California Public Resources Code Sections 21092.2, and 21167( 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 Packet Pg. 219
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City of Santa Clarita — 6th Cycle Housing Element Update November 23, 2021

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.'
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."' 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 athttps:// laborcenter. berkele, mti- content/ uploads /2020 / 09 / Putting-California-on-the-High-Road.pdf.

Z 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.admd.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.

Packet Pg. 220

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City of Santa Clarita — 6th Cycle Housing Element Update November 23, 2021

4 In addition, the City of Hayward requires all projects 30,000 square feet or larger to " utilize apprentices from state -approved, joint labor- management training programs."
5 Locating jobs closer to residential areas can have significant environmental benefits. .

As the California Planning Roundtable noted in 2008:

People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.

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.' Some municipalities have tied local hire and skilled and trained workforce policies to local development permits to address transportation issues. As Cervero and Duncan note:

In nearly built -out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing." The city' s First Source program encourages businesses to hire local residents, especially for entry- and intermediate -level jobs, and sponsors vocational training to ensure residents are employment -ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3, 000 city residents in local jobs since it was launched in 1986. When 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. ha= ard- ca. gov/ sites/ defauh/ files / Hayward% 20Downtown% 20S12ecific% 20PIan. 12df.
5 City of Hayward Municipal Code, Chapter 10, 28. 5. 3. 020( C). 6 California Planning Roundtable ( 2008) Deconstructing Jobs -Housing Balance at p. 6, available at https: / / cproundtable. org/ static/ media/ uploads / publications / cpr- jobshousing_pdf 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 athttp:// reconnectingamerica. org/ assets/ Uploads/ UTCT825.pdf.

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City of Santa Clarita— 6th Cycle Housing Element Update November 23, 2021

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,
Z. U'
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).

Packet Pg. 222

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ooms

LOS ANGELES COUNTY
Almo SANITATION DISTRICTS
Converting Waste Into Resources
Mr. James Chow, Senior Planner
City of Santa Clarita
23920 Valencia Boulevard, Suite 302
Santa Clarita, CA 91355
Dear Mr. Chow:

Robert C. Ferrante
Chief Engineer and General Manager
1955 Workman Mill Road, Whittier, CA 90601- 1400
Mailing Address: P. O. Box 4998, Whittier, CA 90607- 4998 562) 699- 7411 • www. lacsd. org
December 20, 2021
Ref. DOC 6364670
Response to Santa Clarita Housine 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:

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. For 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 ofthe 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 DOC 6409458. SCV
Packet Pg. 223
Mr. James Chow December 20, 2021

17. e
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 ofthe 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 that 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 mandyhuffinanklacsd. org.

Very truly yours,
Mandy Huffman
Environmental Planner
Facilities Planning Department
MNH: mnh
DOC 6409458. SCV
Packet Pg. 224

MATTHEW GELFAND, COUNSI
CALIFORNIANS FOR MATT@CAFORHOMES. OR
HOMEOWNERSHIP TEL: ( 213) 739- 82(
March 24, 2022
Tom Cole
City of Santa Clarita
Email: tcole@santa- clarita. com
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. 7Housing 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.

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 ofthe penalties to which the City is currently subject in light of the City' s failure to adopt a housing element. Ifthe City signs and returns the Acknowledgment, we will not initiate litigation against the City at this time.

Gov. Code § 65588( e)( 3).
2 Gov. Code §§ 65583( c)( 1)( A), 65583. 2( c), and 65588( e)( 4)( C). s Gov. Code §§ 65587, 65751.
a Gov. Code § 65754.
5 Gov. Code § 65755( a)( 1).
6 Gov. Code § 65755( a)( 4).

Gov. Code § 65757.
s Gov. Code § 65752.
9 https:// www. communitylegalsocal. org/kennedy- commission- awarded- 3- 5- million-in- attorneys- fees- for-advocacyin- huntington- beach- low- income- housing- case/ 525 S. Virgil Avenue
Los Angeles, CA 90020
March 24, 2022

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 ( SLAG) 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 b. 1 thehe steps the City has taken towards adoption, or the obstacles it has faced. Instead, we simply ask that the Ci . 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 imontes@bwslaw. com) 525 S. Virgil Avenue
Los Angeles, CA 90020 CALIFORNIANS FOR HOMEOWNER!

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]

CITY OF SANTA CLARITA

NEGATIVE DECLARATION
Proposed [ X] Final
MASTER CASE NO: Master Case 21- 088
PERMIT/ PROJECT: General Plan Amendment 21- 001, Initial Study 21- 009 APPLICANT: City of Santa Clarita, Community Development Department 23920 Valencia Blvd, Suite 302
Santa Clarita, CA 91355

LOCATION OF THE
PROJECT: Citywide

DESCRIPTION OF
THE PROJECT: The City of Santa Clarita ( City) is preparing an update to the General Plan Housing Element. State law requires that housing elements be updated every eight years ( California Government Code Sections 65580 to 65589. 8). The 2021- 2029 Housing Element identifies sites adequate to accommodate a variety of housing types for all income levels and needs of special population groups defined under state law (California Government Code Section 65583); analyzes governmental constraints to housing maintenance, improvement, and development; addresses conservation and improvement of the condition of existing affordable housing stock; and outlines policies that promote housing opportunities for all persons. The project involves an update to the City of Santa Clarita Housing Element as part of the sixth -cycle planning period, which spans from 2021 through 2029. The project also includes an update to the General Plan Safety Element, which is required by state law to be updated upon the next revision of the Housing Element. Areas of the Safety Element to be updated include fire hazards, stormwater management, and emergency response and preparedness, particularly as they relate to the City' s projected climate change exposure and vulnerability. The Safety Element would be updated to ensure alignment with the recently adopted 2021 Local Hazard Mitigation Plan.

Based on the information contained in the Initial Study prepared for this project, and pursuant to the requirements of Section 15070 of the California Environmental Quality Act (CEQA), the City of Santa Clarita X] City Council [ ] Planning Commission [ ] Director of Community Development finds that the project as proposed or revised will have no significant effect upon the environment, and that a Negative Declaration shall be adopted pursuant to Section 15070 of CEQA.

Mitigation measures for this project
X] Are Not Required [ ] Are Attached [ ] Are Not Attached Jason Crawford

PLANNING MANAGER
Prepared/ Approved by:

Signature)
James Chow, Senior Planner
Name/ Title)
Public Review Period From December 16, 2021 To January 18, 2022 Public Notice Given On December 16, 2021
X] Legal Advertisement [ ] Posting of Properties [ X] Written Notice CERTIFICATION DATE:

Final Initial Study - Negative Declaration
prepared by
City of Santa Clarita
Community Development Department
23920 Valencia Boulevard, Suite 302
Santa Clarita, California 91355
Contact: James Chow, Senior Planner
prepared with the assistance of
Rincon Consultants, Inc.
250 East 1st Street, Suite 1400
Los Angeles, California 90012
March 2022
RINCON CONSULTANTS, INC.

Environmental Scientists I Planners I Engineers
rinconconsultants. com
Final Initial Study - Negative Declaration
prepared by
City of Santa Clarita
Community Development Department
23920 Valencia Boulevard, Suite 302
Santa Clarita, California 91355
Contact: James Chow, Senior Planner
prepared with the assistance of
Rincon Consultants, Inc.
250 East 1st Street, Suite 1400
Los Angeles, California 90012
March 2022
RINCON CONSULTANTS, INC.

Environmental Scientists I Planners I Engineers
rinconconsultants. com
This report prepared on 50% recycled paper with 50% post -consumer content.

Table of Contents
Table of Contents
1 Introduction.................................................................................................................................... 1 2 Responses to Comments................................................................................................................ 3

2. 1 Letter 1............................................................................................................................. 15

2. 2 Letter 2............................................................................................................................. 20

2. 3 Letter 3............................................................................................................................. 26

2. 4 Letter 4........................................................................................................................... 292

2. 5 Letter 5........................................................................................................................... 296 Appendices
Appendix A Errata to the Final IS - ND
Final Initial Study - Negative Declaration
City of Santa Clarita
Housing Element Update
This page intentionally left blank.

Introduction
1 Introduction
Pursuant to the California Environmental Quality Act (CEQA), lead agencies are required to consult with public agencies having jurisdiction over a proposed project and to provide the general public with an opportunity to comment on the Draft Initial Study- Negative Declaration ( IS - ND). On December 16, 2021, the City circulated a Notice of Intent ( NOI) to Adopt for a 33- day comment period to help identify the types of impacts that could result from the proposed project, as well as potential areas of controversy.

Although not required by CEQA and the CEQA Guidelines, the City of Santa Clarita has evaluated the comments received on the Housing Element Update Draft IS - ND. The comments and the responses to those comments are included in this report. The Draft IS - ND and its appendices are incorporated by reference. The Draft IS -ND is available to view on the City' s website at: https:// www. santaclarita. com/ city- hall/ departments/ community- development/ planning/ environmental- impactreports- under- review. 1 These documents are for use by the City of Santa Clarita in its review and consideration of the Housing Element Update.

The City received five comment letters on the Draft IS - ND. A copy of the letters is included in Section 2 of this document. Based on the comments received, changes and revisions have been made to the text of the Draft IS - ND, included in Appendix A, the Errata to the Final IS - ND.

The Final IS - ND is organized into two sections:

Section 1: Introduction. This section discusses the purpose and organization of the Final IS -ND and summarizes the environmental review process for the project up until this point.

Section 2: Responses to Comments. This section contains reproductions of all comment letters received on the Draft IS - ND. A written response for each CEQA- related written comment received during the public review period is provided. If revisions were made to the IS -ND pursuant to those comments, those are reflected as redlines in the Errata to the Final IS -ND Appendix A).

Appendix A. This appendix contains the Errata to the Final IS - ND. 1 Upon adoption of the IS - ND the Draft and Final IS - ND will be available on the City' s website at: https:// www. santa- clarita. com/ cityhall/ departments/ community- development/ planning/ environmental- impact- reports- completed Final Initial Study — Negative Declaration
City of Santa Clarita
Housing Element Update
This page intentionally left blank.

Responses to Comments
2 Responses to Comments
This section includes comments received during the circulation of the IS -ND prepared for the City of Santa Clarita Housing Element Update Project.

The Draft IS - ND was circulated for a 33- day public review period that began on December 16, 2021 and ended on January 18, 2022. The City of Santa Clarita received five comment letters on the Draft IS -ND. The commenters and the page number on which each commenter' s letter appear are listed below.
1 Erinn Wilson- Olgin, Environmental Program Manager, California Department of Fish and Wildlife January 18, 2022 2 Mandy Huffman, Environmental Planner, Los Angeles County Sanitation Districts January 18, 2022 3 Tracey Jue, Director, Facilities Planning Bureau, Los Angeles County Sheriff' s Department January 18, 2022 4 Mitchell M. Tsai, Attorney, Southwest Regional Council of Carpenters January 18, 2022 5 Ronald M Durbin, Chief, Forestry Division, Prevention Services Bureau, County of Los Angeles January 24, 2022 Fire Department
The comment letters and responses follow. The comment letters have been numbered sequentially and each separate issue raised by the commenter, if more than one, has been assigned a number.

The responses to each comment identify first the number of the comment letter, and then the number assigned to each issue ( Response 1. 1, for example, indicates that the response is for the first issue raised in comment Letter 1).

Final Initial Study — Negative Declaration 3
DocuSign Envelope ID: 8469C61 E- F1 EC- 4E83- 13162- D398893156A0 State of California — Natural Resources Agency GAVINNEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTONH. BONHAM, Director South Coast Region -; i
3883 Ruffin Road
San Diego, CA 92123
858) 467- 4201
www. wildlife. ca. gov
BY EMAIL ONLY LETTER 1
January 18, 2022
James Chow
City of Santa Clarita
Community Development Department
23920 Valencia Boulevard, Suite 302
Santa Clarita, California 91355
JChow( a)santa- clarita. com
Subject: Negative Declaration for the City of Santa Clarita Housing Element Update Project, City of Santa Clarita, Los Angeles County
Dear Mr. Chow:

The California Department of Fish and Wildlife ( CDFW) has reviewed the Negative Declaration ND) from the City of Santa Clarita ( City) for the Housing Element Update ( Project). The ND' s supporting documents included an Initial Study -Negative Declaration and a Public Review Draft 2021- 2029 Housing Element. Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife. Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW' s Role
CDFW is California' s Trustee Agency for fish and wildlife resources, and holds those resources in trust by statute for all the people of the State [ Fish & Game Code, §§ 711. 7, subdivision ( a) & 1802; Public Resources Code, § 21070; California Environmental Quality Act (CEQA) Guidelines, § 15386, subdivision ( a)]. CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species ( Id., § 1802). Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect state fish and wildlife resources.

CDFW is also submitting comments as a Responsible Agency under CEQA (Public Resources Code, § 21069; CEQA Guidelines, § 15381). CDFW expects that it may need to exercise regulatory authority as provided by the Fish and Game Code, including lake and streambed alteration regulatory authority ( Fish & Game Code, § 1600 et seq.). Likewise, to the extent implementation of the Project as proposed may result in " take", as defined by state law, of any species protected under the California Endangered Species Act ( CESA) ( Fish & Game Code, § 2050 et seq.), or state -listed rare plant pursuant to the Native Plant Protection Act ( NPPA; Fish DocuSign Envelope ID: 8469C61 E- F1 EC- 4E83- 13162- D398893156A0 James Chow
City of Santa Clarita

January 18, 2022
Game Code, § 1900 et seq.) authorization as provided by the applicable Fish and Game Code will be required.

Project Description and Summary
Objective: The Project proposes a housing element update ( HEU) to amend the City of Santa Clarita General Plan. The HEU amends the current Housing Element with the proposed 2021- 2029 Housing Element and updates the Safety Element of the General Plan to reflect changes in State law. The City' s General Plan, One Valley One Vision, was last updated in June 2011 and the program Environmental Impact Report ( EIR) for the General Plan was completed in May 2011. The HEU sets goals, objectives, policies, and programs to achieve future housing needs for the City. The Regional Housing Needs Assessment ( RHNA) identified a final allocation of 10, 031 new housing units for this upcoming planning period.

Location: The Project will encompass the entire City of Santa Clarita, framed by three mountain ranges: the Sierra Pelona Mountains, Santa Susana Mountains, and San Gabriel Mountains.

Since incorporation, 40 areas positioned to the City have been annexed, adding a total of 31. 09 square miles to the City. The City is located within the Santa Clarita Valley, which includes incorporated and unincorporated areas of Los Angeles County. The General Plan for the Santa Clarita Valley planning area encompasses the entire Santa Clarita Valley. This area covers unincorporated communities of Stevenson Ranch, Castaic, Val Verde, Agua Dulce, Westridge, and Newhall Ranch. These unincorporated areas with the City of Santa Clarita form the Project area.

Comments and Recommendations
CDFW offers the comments and recommendations below to assist the City in adequately identifying, avoiding, and/or mitigating the Project' s significant, or potentially significant, direct and indirect impacts on fish and wildlife ( biological) resources. CDFW recommends the measures or revisions below be included in a science -based monitoring program that contains adaptive management strategies as part of the Project's CEQA mitigation, monitoring and reporting program ( Public Resources Code, § 21081. 6 and CEQA Guidelines, § 15097).

Comment # 1: Impacts on Existing Conservation Easement
Issue: Figure 12 and Figure 13 in the Public Review Draft Housing Element identifies 27 sites to be suitable for housing. Site 17 and Site 22 are adjacent to a CDFW- granted conservation easement ( CE) along the Santa Clara River as shown in the attached map ( Attachment A).

Specific impact: Future development of Sites 17 and 22 may result in direct and indirect impacts to conservation values within the CE.

Why impact would occur: Future development of Sites 17 and 22 may result in a need for increased bank protection along the Santa Clara River, which would encroach upon the CE. The installation of the bank protection may result in direct impacts to vegetation and hydrology within the CE. Future development of these two sites may also result in increased human densities, which may increase habitat degradation and edge effects within the CE. Habitat degradation would occur through anthropogenic impacts such as the creation of illegal trails, wildfire, noise, lighting, trash, fuel modification, and increased competition from invasive species.

1. 1,
cunt.

DocuSign Envelope ID: 8469C61 E- F1 EC- 4E83- 13162- D398893156A0 James Chow
City of Santa Clarita

January 18, 2022
Evidence impact would be significant: The CE was recorded to retain the natural condition of the property in perpetuity and to prevent any actions that will significantly impair or interfere with the conservation values of the property. Any future development facilitated by this Project will have a substantial adverse direct, indirect, and cumulative affect either directly or through habitat modifications on the CE.

Recommendation # 1: CDFW requests the City provide CDFW all notices for any subsequent projects on Sites 17 and 22 during the planning and permitting process to allow CDFW an opportunity to review and comment.

Recommendation #2: CDFW recommends the ND require subsequent development projects provide a complete assessment and impact analysis of the flora and fauna within and adjacent to the Project area ( including the adjacent CE), with emphasis upon identifying endangered, threatened, sensitive, regionally, and locally unique species, and sensitive habitats. Impact analysis will aid in determining any direct, indirect, and cumulative biological impacts, as well as specific mitigation or avoidance measures necessary to offset those impacts. CDFW recommends avoiding any sensitive natural communities found on or adjacent to the Project.

CDFW also considers impacts to SSC a significant direct and cumulative adverse effect without implementing appropriate avoid and/ or mitigation measures. The ND should include the following information:
a) Information on the regional setting that is critical to an assessment of environmental impacts, with special emphasis on resources that are rare or unique to the region [ CEQA Guidelines, § 15125( c)]. The ND should acknowledge that subsequent projects should include measures to fully avoid and otherwise protect Sensitive Natural Communities from Project -related impacts. Project implementation may result in impacts to rare or endangered plants or plant communities that have been recorded adjacent to the Project vicinity. CDFW considers these communities as threatened habitats having both regional and local significance. Plant communities, alliances, and associations with a State- wide ranking of S1, S2, S3 and S4 should be considered sensitive and declining at the local and regional level CDFWa];
b) A thorough, recent, floristic -based assessment of special status plants and natural communities, following CDFW' s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities [ CDFWb]; c) Floristic, alliance- and/ or association -based mapping and vegetation impact assessments conducted at the Project site and within the neighboring vicinity. The Manual of California Vegetation, second edition, should also be used to inform this mapping and assessment Sawyer et al., 2009). Adjoining habitat areas should be included in this assessment where site activities could lead to direct or indirect impacts off site. Habitat mapping at the alliance level will help establish baseline vegetation conditions; d) A complete, recent, assessment of the biological resources associated with each habitat type on site and within adjacent areas that could also be affected by the Project; e) A complete, recent, assessment of rare, threatened, and endangered, and other sensitive species on site and within the area of potential effect, including California Species of Special Concern and California Fully Protected Species ( Fish & Game Code, §§ 3511, 4700, 5050 and 5515). Species to be addressed should include all those which meet the CEQA 1- 2,
coat
DocuSign Envelope ID: 8469C61 E- F1 EC- 4E83- 13162- D398893156A0 James Chow
City of Santa Clarita

January 18, 2022
definition of endangered, rare or threatened species ( CEQA Guidelines, § 15380). Seasonal variations in use of the Project area should also be addressed. Focused species - specific surveys, conducted at the appropriate time of year and time of day when the sensitive species are active or otherwise identifiable, are required. Acceptable species - specific survey procedures should be developed in consultation with CDFW and the USFWS; and f) A recent, wildlife and rare plant survey. CDFW generally considers biological field assessments for wildlife to be valid for a one- year period, and assessments for rare plants may be considered valid for a period of up to three years. Some aspects of the proposed Project may warrant periodic updated surveys for certain sensitive taxa, particularly if build out could occur over a protracted time frame, or in phases.

Comment #2: Impacts on Biological Resources
Issue: Figure 12 and Figure 13 in the Public Review Draft Housing Element designates 27 sites as suitable for housing. Sites 3, 6, 8, and 24 may have protected biological resources.

Specific Impact: Future development of Sites 3, 6, 8, and 24 may result in direct and indirect impacts to biological resources. These activities all have the potential to impact and result in the loss of the following resources:

Site 3: California legless lizard ( Anniella spp.), a SSC; California glossy snake (Arizona e/egans occidentalis), a SSC; California gnatcatcher ( Polioptila californica californica), a federally listed species; Crotch' s bumble bee ( Bombus crotchii), a S1/ S2 State ranked species; Quino checkerspot ( Euphydryas editha quino), a federally listed species; slender horned spineflower Dodecahema leptoceras), a State -ranked 1 B plant; ridgelines; Site 6: Coast horned lizard ( Phrynosoma blainvillii), a SSC; California Orcutt grass ( Orcuttia californica), a state ranked 1 B plant; Palmer' s grapplinghook (Harpagonella palmeri), a state ranked 4. 2 plant; Oak Woodland Alliance ( Quercus spp.); wetlands; Site 8: Coast horned lizard; California gnatcatcher; California Orcutt grass; Palmer' s grapplinghook; Oak Woodland Alliance; ridgelines;
Site 24: Coast horned lizard; California Orcutt grass; Palmer' s grapplinghook 4. 2; and Oak Woodland Alliance.

Why impact would occur: Future housing development facilitated by the Project may result in vegetation removal, grading, ground disturbance, and permanent removal of habitat. Species listed above may rely on these sites for nesting and foraging habitat. Future work during the breeding season may lead to injury or mortality and nest abandonment in areas in and adjacent to the Project area. Grading, vegetation removal, and other ground disturbances could crush and bury listed or sensitive plants and animals, resulting in direct mortality and permanently impacting the habitat. The future development may also affect adjacent habitat by creating loud noises, lighting, fugitive dust, and spreading invasive weeds, resulting in stress, displacement, and mortality of these species.

Evidence impact would be significant: CEQA provides protection for special status species, including SSC. These SSC meet the CEQA definition of rare, threatened, or endangered DocuSign Envelope ID: 8469C61 E- F1 EC- 4E83- 13162- D398893156A0 James Chow
City of Santa Clarita

January 18, 2022
species ( CEQA Guidelines, § 15380). Therefore, take of SSC could require a mandatory finding of significance by the City ( CEQA Guidelines, § 15065). Inadequate avoidance, minimization, and mitigation measures for impacts to these listed species will result in the Project continuing to have a substantial adverse direct, indirect, and cumulative effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special -status species in local or regional plans, policies, or regulations, or by CDFW or United States Fish and Wildlife Service ( USFWS).

Future development of the proposed sites is inconsistent with the Santa Clarita Municipal Code SCMC) and specific policies identified in the Conservation and Open Space Element ( COSE), which are outlined in the One Valley One Vision General Plan. Protection and/ or conservation of wetlands are included in SCMC 17. 95. 050 and COSE Policy CO 3. 1. 2 and 3. 2. 1. Protection of oaks is provided under SCMC 17. 51. 040 and COSE Policy CO 3. 2. 2 and 3. 5. 3. Protection of ridgelines is provided under SCMC 17. 86. 040 and 17. 38. 070 and COSE Policy CO 2. 2. 3.

Recommendation # 3: CDFW recommends reconsider utilizing Sites 3, 6, 8, and 24 for other potential development types ( instead of housing). Other potential development types may minimize impacts on biological resources and maintain consistency with the policies outlined in the Conservation and Open Space Element. All subsequent development projects should provide information as outlined in Recommendation # 2.

Additional Recommendations
Data. CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database ( i. e., California Natural Diversity Database) which may be used to make subsequent or supplemental environmental determinations [ Pub.

Resources Code, § 21003, subd. ( e)]. Accordingly, please report any special status species detected by completing and submitting CNDDB Field Survey Forms [ CDFWc]. The City should ensure the data has been properly submitted, with all data fields applicable filled out, prior to finalizing/ adopting the environmental document. The City should provide CDFW with confirmation of data submittal.

Mitigation and Monitoring Reporting Plan. CDFW recommends the City update the Project's environmental document to include mitigation measures recommended in this letter. CDFW provides comments to assist the City in developing mitigation measures that are specific, detailed ( i. e., responsible party, timing, specific actions, location), and clear in order for a measure to be fully enforceable and implemented successfully via a mitigation monitoring and/ or reporting program ( CEQA Guidelines, § 15097; Pub. Resources Code, § 21081. 6). The City is welcome to coordinate with CDFW to further review and refine the Project' s mitigation measures. Per Public Resources Code section 21081. 6( a)( 1), CDFW has provided the City with a summary of our suggested mitigation measures and recommendations in the form of an attached Draft Mitigation and Monitoring Reporting Plan ( MMRP; Attachment B).

Filing Fees
The Project, as proposed, could have an impact on fish and/ or wildlife, and assessment of filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the City of Santa Clarita and serve to help defray the cost of environmental review by CDFW. Payment of

1. 3,
cone.

DocuSign Envelope ID: 8469C61 E- F1 EC- 4E83- 13162- D398893156A0 James Chow
City of Santa Clarita

January 18, 2022
the fee is required in order for the underlying Project approval to be operative, vested, and final Cal. Code Regs, tit. 14, § 753. 5; Fish & Game Code, § 711. 4; Pub. Resources Code, § 21089).

Conclusion
We appreciate the opportunity to comment on the Project to assist the City in adequately analyzing and minimizing/ mitigating impacts to biological resources. CDFW requests an opportunity to review and comment on any response that the City has to our comments and to receive notification of any forthcoming hearing date( s) for the Project. Questions regarding this letter and further coordination on these issues should be directed to Nicole Leatherman, Environmental Scientist, at Nicole. Leatherman( a)wildlife. ca. gov or ( 858) 761- 8020.

Sincerely,
DocuSigned by:
86E58CFE24724F5...

Erinn Wilson- Olgin
Environmental Program Manager I
South Coast Region
ec: CDFW
Erinn Wilson- Olgin, Los Alamitos — Erin n. Wilson- Olgin( c mildlife. ca. gov Victoria Tang, Los Alamitos — Victoria. Tang( o)wildlife. ca. gov Nicole Leatherman, Los Alamitos — Nicole. Leatherman ( a)_wildlife. ca. gov Julisa Portugal, Los Alamitos — Julisa. Portugal( o)wildlife. ca. gov Ruby Kwan- Davis, Los Alamitos — Ruby. Kwan- Davis( o-)wildlife. ca. gov Felicia Silva, Los Alamitos — Felicia. Silva( o-)-wildlife. ca. gov Cindy Hailey, San Diego — Cindy. Hailey( a) wildlife. ca. gov CEQA Program Coordinator, Sacramento — CEQACommentLetters( a wildlife. ca. gov State Clearinghouse, Office of Planning and Research — State. Clearing house( a) opr. ca. gov References:

CDFWa] California Department of Fish and Wildlife, 2022. Natural Communities. Accessed at:
https:// wiIdIife. ca. gov/ Data/ VegCAMP/ Natural- Communities CDFWb] California Department of Fish and Wildlife, 2018. Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Sensitive Natural Communities. Accessed at:
https:// nrm. dfq. ca. gov/ FileHandler. ashx? Document[ D= 18959& inline.

CDFWc] California Department of Fish and Wildlife. 2022. California Natural Diversity Database. Available from: https:// wildlife. ca. gov/ Data/ CNDDB Sawyer, J. O., Keeler - Wolf, T., and Evens J. M. 2009. A Manual of California Vegetation, 2nd ed.

ISBN 978- 0- 943460- 49- 9.

CALIFORNIA
1 DEP TAI ENT OF
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Site 17
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DocuSign Envelope ID: 8469C61 E- F1 EC- 4E83- 13162- D398893156A0 State of California — Natural Resources AgencV GAVINNEWSOM, Governor ' DEPARTMENT OF FISH AND WILDLIFE CHARLTONH. BONHAM, Director South Coast Region
3883 Ruffin Road '
San Diego, CA 92123
858) 467- 4201
www. wildlife. ca. eov
Attachment B: Draft Mitigation and Monitoring Reporting Plan Biological Resources ( 1310)
Mitigation Measure ( MM) or Recommendation ( REC) Timing Responsible Party REC- 1-
Impacts on CDFW requests the City provide CDFW all notices for any Prior to Existing subsequent projects on Sites 17 and 22 during the planning and finalizing/ City Conservation permitting process to allow CDFW an opportunity to review and adopting CEQA Easement
comment. document
CDFW recommends the ND require subsequent development
projects provide a complete assessment and impact analysis of the flora and fauna within and adjacent to the Project area ( including the adjacent CE), with emphasis upon identifying endangered, threatened, sensitive, regionally, and locally unique species, and REC- 2- sensitive habitats. Impact analysis will aid in determining any Impacts on
direct, indirect, and cumulative biological impacts, as well as Prior to Existing specific mitigation or avoidance measures necessary to offset finalizing/ City Conservation those impacts. CDFW recommends avoiding any sensitive natural adopting CEQA Easement
communities found on or adjacent to the Project. CDFW also document considers impacts to SSC a significant direct and cumulative adverse effect without implementing appropriate avoid and/ or mitigation measures. The ND should include the following information:
a) Information on the regional setting that is critical to an assessment of environmental impacts, with special
DocuSign Envelope ID: 8469C61 E- F1 EC- 4E83- 13162- D398893156A0 James Chow
City of Santa Clarita

January 18, 2022
emphasis on resources that are rare or unique to the region CEQA Guidelines, § 15125( c)]. The ND should
acknowledge that subsequent projects should include
measures to fully avoid and otherwise protect Sensitive Natural Communities from Project - related impacts. Project implementation may result in impacts to rare or endangered plants or plant communities that have been recorded
adjacent to the Project vicinity. CDFW considers these
communities as threatened habitats having both regional and local significance. Plant communities, alliances, and associations with a State- wide ranking of S1, S2, S3 and S4 should be considered sensitive and declining at the
local and regional level [ CDFWa];
b) A thorough, recent, floristic - based assessment of special status plants and natural communities, following CDFW' s Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities CDFWb];
c) Floristic, alliance- and/ or association -based mapping and vegetation impact assessments conducted at the Project
site and within the neighboring vicinity. The Manual of California Vegetation, second edition, should also be used to inform this mapping and assessment ( Sawyer et al.,
2009). Adjoining habitat areas should be included in this assessment where site activities could lead to direct or indirect impacts off site. Habitat mapping at the alliance level will help establish baseline vegetation conditions; d) A complete, recent, assessment of the biological resources associated with each habitat type on site and within
adjacent areas that could also be affected by the Project; e A complete, recent, assessment of rare, threatened, and DocuSign Envelope ID: 8469C61 E- F1 EC- 4E83- 13162- D398893156A0 James Chow
City of Santa Clarita

January 18, 2022
endangered, and other sensitive species on site and within the area of potential effect, including California Species of Special Concern and California Fully Protected Species
Fish & Game Code, §§ 3511, 4700, 5050 and 5515).

Species to be addressed should include all those which
meet the CEQA definition of endangered, rare or
threatened species ( CEQA Guidelines, § 15380). Seasonal variations in use of the Project area should also be
addressed. Focused species - specific surveys, conducted at the appropriate time of year and time of day when the
sensitive species are active or otherwise identifiable, are required. Acceptable species -specific survey procedures should be developed in consultation with CDFW and the
USFWS; and
f) A recent, wildlife and rare plant survey. CDFW generally considers biological field assessments for wildlife to be valid for a one-year period, and assessments for rare plants may be considered valid for a period of up to three years.

Some aspects of the proposed Project may warrant
periodic updated surveys for certain sensitive taxa,
particularly if build out could occur over a protracted time frame, or in phases.

CDFW recommends reconsider utilizing Sites 3, 6, 8, and 24 for REC- 3- other potential development types ( instead of housing). Other Prior to Impacts on potential development types may minimize impacts on biological finalizing/ City Biological resources and maintain consistency with the policies outlined in adopting CEQA Resources the Conservation and Open Space Element. All subsequent document development projects should provide information as outlined in REC- 2- Impacts on Existing Conservation Easements.

DocuSign Envelope ID: 8469C61 E- F1 EC- 4E83- 13162- D398893156A0 James Chow
City of Santa Clarita

January 18, 2022
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database i. e., California Natural Diversity Database) which may be used to make subsequent or supplemental environmental determinations Prior to
Pub. Resources Code, § 21003, subd. ( e)]. Accordingly, please finalizing/ REC- 4- Data report any special status species detected by completing and adopting CEQA City submitting CNDDB Field Survey Forms [ CDFWc]. The City should document ensure the data has been properly submitted, with all data fields applicable filled out, prior to finalizing/ adopting the environmental document. The City should provide CDFW with confirmation of data submittal.,
Responses to Comments

2. 1 Letter 1
COMMENTER: Erinn Wilson- Olgin, Environmental Program Manager, California Department of Fish and Wildlife ( CDFW)
DATE: January 18, 2022
Response 1. 1
The commenter introduces their role as California' s Trustee Agency for fish and wildlife resources and legal entity to provide biological expertise during the CEQA public review period. The commenter also reviews the project' s objective and location before introducing their comments and recommendations.

The City acknowledges CDFW as a Trustee Agency for future projects related to buildout of the Housing Element Update and adhere to CDFW' s direction in identifying, avoiding, and/ or mitigating potential impacts on biological resources. No additional revisions are necessary relative to this comment.

Response 1. 2
The commenter states that housing opportunity sites 17 and 22 are adjacent to CDFW-granted conservation easements ( CE) along the Santa Clara River. The commenter is concerned that future development on those sites may impact habitat resources and the conservation value of the CEs.

The commenter recommends that the City notify CDFW during planning and permitting for future development. Additionally, the commenter recommends that the IS -ND require subsequent development projects to provide a complete assessment and impact analysis of flora and fauna on housing opportunity sites 17 and 22. Further, the commenter recommends that the IS -ND be updated to include information on the regional setting, a thorough, recent, floristic -based assessment of special -status plants and natural communities, a floristic, alliance- and/ or association - based mapping and vegetation impact assessments conducted at housing opportunity sites or in the vicinity, and complete and recent surveys of biological resources, rare, threatened, and endangered species, and wildlife and rare plants on the housing opportunity sites.

The project is a comprehensive update to the City' s Housing Element and does not propose changes to zoning or land use designations. The Housing Element Update, in and of itself, does not propose specific projects but sets forth goals and policies that promulgate new housing development in Santa Clarita consistent with the current Regional Housing Needs Assessment ( RHNA) cycle.

Therefore, biological impacts to housing opportunity sites 17 and 22 were previously analyzed during any zoning or land use changes made to the sites. As a policy document, no impacts would occur at designated potential housing sites, including impacts to CEs adjacent to housing opportunity sites 17 and 22 because no development would occur. Future development projects accommodated by the Housing Element Update would be subject to development plan review to determine potential concerns related to biological resources enumerated throughout the IS - ND.

That development review would include consultation with CDFW, as warranted, and assessments of biological resources on the sites to ensure that the development would not have a substantial adverse effect on any special - status species, riparian habitat, or sensitive natural community.

Therefore, the commenter' s recommendations have not been included in the IS -ND considering that no development would occur under the project and future development would be subject to development plan review with consultation from CDFW.

Final Initial Study - Negative Declaration 15
City of Santa Clarita
Housing Element Update
No additional revisions are necessary relative to this comment.

Response 1. 3
The commenter states that housing opportunity sites 3, 6, 8, and 24 have the potential to contain biological resources, which may be impacted by future development under the Housing Element Update. The commenter notes that future development of those sites is inconsistent with Santa Clarita Municipal Code and General Plan policies in the City' s Conservation and Open Space Element. The commenter recommends utilizing these sites for other types of development that may minimize impacts on biological resources.

The project is a comprehensive update to the City' s Housing Element and does not propose changes to zoning or land use designations. The Housing Element Update, in and of itself, does not propose specific projects but sets forth goals and policies that promulgate new housing development in Santa Clarita consistent with the current RHNA cycle. Therefore, biological impacts to housing opportunity sites 3, 6, 8, and 24 were previously analyzed during any zoning or land use changes made to the sites. As a policy document, no impacts would occur at designated potential housing sites, including impacts to protected biological resources that may be found on housing opportunity sites 3, 6, 8, and 22. Further, the City is required to identify housing opportunity sites to meet the State' s requirement to meet housing needs. These sites were selected as suitable for housing due to their proximity to transit and existing residential, commercial/ retail, recreational, and institutional land uses. Future development projects accommodated by the Housing Element Update would be subject to development plan review to determine potential impacts to biological resources.

Development review would include preparation of a biological resources assessment, and if warranted based on the findings for the assessment consultation with CDFW to ensure that the development would not have a substantial adverse effect on any special -status species, riparian habitat, or sensitive natural community. Additionally, future development would be required to adhere to Santa Clarita Municipal Code and General Plan policies including codes and policies that protect wetlands, oaks, and ridgelines, such as those mentioned by the commenter.

Therefore, no additional revisions are necessary relative to this comment.

Response 1. 4
The commenters requests that all special - status species detected in preparation of the IS - ND be incorporated into CDFW' s California Natural Diversity Database.

A biological field survey was not conducted during preparation of the IS -ND because the document is a Citywide plan. Therefore, data reporting is not required nor are additional revisions necessary relative to this comment. Future biological resources site surveys conducted on individual sites would report special -status species to the California Natural Diversity Database, as requested by the commenter.

Response 1. 5
The commenter recommends that the IS - ND be updated to include mitigation measures recommended by the commenter in Responses 1. 1 and 1. 2. The commenter also requests that City prepare a subsequent Mitigation Monitoring Reporting Plan.

The project is a comprehensive update to the City' s Housing Element and does not propose changes to zoning or land use designations. The Housing Element Update, in and of itself, does not propose specific projects but sets forth goals and policies that promulgate new housing development in OR
Responses to Comments
Santa Clarita consistent with the current RHNA cycle. Therefore, as a policy document, no impacts would occur at designated potential housing sites. Because there are no impacts to biological resources mitigation is not required. Pursuant to the CEQA Guidelines mitigation can only be required for a project if there is a nexus linking the mitigation to an impact. Future development projects accommodated by the Housing Element Update would be subject to development plan review to determine potential impacts to biological resources on the housing opportunity sites.

Development review would include consultation with CDFW, as warranted, to ensure that the development would not have a substantial adverse effect on biological resources Therefore, no additional revisions are necessary relative to this comment.

Final Initial Study - Negative Declaration 17
ooms

LOS ANGELES COUNTY
Almo SANITATION DISTRICTS
Converting Waste Into Resources
Mr. James Chow, Senior Planner
City of Santa Clarita
Department of Community Development
23920 Valencia Boulevard, Suite 302
Santa Clarita, CA 91355
Dear Mr. Chow:

Robert C. Ferrante
Chief Engineer and General Manager
1955 Workman Mill Road, Whittier, CA 90601- 1400
Mailing Address: P. O. Box 4998, Whittier, CA 90607- 4998 562) 699- 7411 • www. lacsd. org
January 18, 2022 LETTER 2
Ref. DOC 6410000
NOI Response to Santa Clarita Housing Element Update
The Santa Clarita Valley Sanitation District ( District) received a Notice of Intent ( NOI) to Adopt a Negative Declaration (ND) for the subject project on December 20, 2021. The City of Santa Clarita (City) is located within the jurisdictional boundaries of the Santa Clarita Valley Sanitation District. We offer the following update and comments regarding sewerage service:

1. Section 19 Utilities and Service Systems, Wastewater Generation, page 96: the second paragraph in the Wastewater Generation subsection stated that " The planned Newhall WRP and Vista Canyon RWF have 2_1 expected capacities of 3. 75 mgd and 392,000 gpd." Please note that the current design flow for Newhall Ranch Water Reclamation Plant ( WRP) is 2 million gallons per day ( mgd).

2. The District owns, operates, and maintains 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. For 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.

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

4. The District operates two WRP' s, 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 2.4 known as the Santa Clarita Valley Joint Sewerage System ( SCVJSS). The SCVJSS has a capacity of 28. 1 mgd and currently processes an average flow of 19. 6 mgd.

5. 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 2. 5 the Table 1, Loadings for Each Class of Land Use link for a copy of the District' s average wastewater generation factors.

6. 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 2. 6 wastewater discharged from connected facilities. This connection fee is used by the District for its capital DOC 6433392. SCV
Mr. James Chow January 18, 2022
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 ofthe 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 connection fee application procedure and fees, the developer should contact the District' s Wastewater Fee Public Counter at ( 562) 908- 4288, extension 2727.

7. 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 ofthe 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 ofthe District' s treatment facilities will, therefore, be limited to levels associated with the approved growth identified by SLAG. 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 that 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 mandyhuffmanklacsd. org.

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

2. 61
cant.

2.7 DOC 6433392. SCV
City of Santa Clarita
Housing Element Update

2. 2 Letter 2
COMMENTER: Mandy Huffman, Environmental Planner, Los Angeles County Sanitation Districts District)
DATE: January 18, 2022
Response 2. 1
The Los Angeles County Sanitation District ( District) notes that the capacity for the Newhall Ranch Water Reclamation Plant is 2 million gallons per days ( mgd), as opposed to 3. 75 mgd included on page 96 of the Draft IS -ND.

In response to the capacity for the Newhall Ranch Water Reclamation Plan ( WRP), the capacity has been revised to 2 mgd as reflected in Appendix B, Errata.

Response 2.2
The District states that they cannot comment on deficiencies in the sewage system, outside of those maintained by the District.

No response or revisions are necessary, given that this comment is not relevant to CEQA analysis in the IS - ND. Therefore, no revisions are necessary relative to this comment.

Response 2. 3
The District states that individual development projects should be reviewed by the District to ensure sufficient trunk sewer capacity exists.

The project is a comprehensive update to the City' s Housing Element and does not propose changes to zoning or land use designations. The Housing Element Update, in and of itself, does not propose specific projects but sets forth goals and policies that promulgate new housing development in Santa Clarita consistent with the current RHNA cycle. Therefore, as a policy document, no impacts would occur at designated potential housing sites. Future development projects accommodated by the Housing Element Update would be subject to future development plan review to determine potential impacts related to sewage capacity.

Therefore, no revisions are necessary relative to this comment.

Response 2. 4
The District provides details on the wastewater treatment system in the Santa Clarita Valley, regarding the average flow of the wastewater treatment facilities.

In response to this information, new details were added to Section 19, Utilities and Service Systems, of the IS -ND. The City added that the Saugus WRP and Valencia WRP are interconnected to form a regional treatment system known as the Santa Clarita Valley Joint Sewerage System ( SCVJSS).

Second, the capacities of these two WRPs were added to the IS -ND, which shows that they operate at 30 percent below capacity, with an average flow of 19. 6 mgd.

These changes are reflected in Appendix B, Errata.
20 Responses to Comments
Response 2.5
The District provides information for their tool to estimate wastewater from individual projects.

The project is a comprehensive update to the City' s Housing Element and does not propose changes to zoning or land use designations. The Housing Element Update, in and of itself, does not propose specific projects but sets forth goals and policies that promulgate new housing development in Santa Clarita consistent with the current RHNA cycle. Therefore, as a policy document, no impacts would occur at designated potential housing sites. Future development projects accommodated by the Housing Element Update would be subject to development plan review. Development review would utilize the District' s wastewater generation factors or a comparable tool to estimate the volume of waste to ensure sufficient sewage capacity.

Therefore, no additional revisions are necessary relative to this comment.

Response 2. 6
The District notes their authority to collect a fee when connecting facilities to the District' s sewage system used to the District' s capital facilities.

No response or revisions are necessary. This comment is not relevant to CEQA analysis in the IS -ND because the project is a policy document that does not propose specific projects. Therefore, no revisions are necessary relative to this comment.

Response 2. 7
The District states that wastewater treatment capacities are based on regional growth forecast adopted by the Southern California Association of Governments ( SCAG), and the expansion of capacities are limited by the accuracy of those forecasts.

The project is a comprehensive update to the City' s Housing Element and does not propose changes to zoning or land use designations. The Housing Element Update, in and of itself, does not propose specific projects but sets forth goals and policies that promulgate new housing development in Santa Clarita consistent with the current RHNA cycle. Therefore, as a policy document, no impacts to regional growth and treatment capacity would occur at designated potential housing sites.

Further, the Housing Element Update is based upon SCAG' s existing forecasts. As noted in Section 14, Population and Housing, full buildout of the Housing Element Update would bring Santa Clarita' s 2030 population to 257,913, which is consistent with SCAG' s population growth projection.

Therefore, no revisions are necessary relative to this comment.

Final Initial Study - Negative Declaration 21
FFI : E ffF THE [ HERIFF
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COL-N TV OF Los A.NGELES
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ALEx VILLA?,'UEVA, SHERIFF
LETTER 3
January 18, 2022
Mr. James Chow, Senior Planner
City of Santa Clarita
Department of Community Development
23920 Valencia Boulevard, Suite 302,
Santa Clarita, California 91355
Dear Mr. Chow:

REVIEW COMMENTS

NOTICE OF INTENT TO ADOPT A

NEGATIVE DECLARATION

SANTA CLARITA HOUSING ELEMENT UPDATE
GENERAL PLAN AMENDMENT 21- 01; INITIAL STUDY 21- 009)
Thank you for inviting the Los Angeles County Sheriff' s Department Department) to review and comment on the December 2021 Initial Study/Negative Declaration ( IS/ND) 2021- 2029 Housing Element Update Project). The Project involves an update to the City of Santa Clarita ( City) Housing Element as part of the sixth -cycle planning period, which spans from 2021 through 2029. The Project also includes an update to the General Plan Safety Element, which is required by state law to be updated upon the next revision of the Housing Element. Areas of the Safety Element to be updated include fire hazards, stormwater management, and emergency response and preparedness, particularly as they relate to the City' s projected climate change exposure and vulnerability. The Safety Element would be updated to ensure alignment with the recently adopted 2021 Local Hazard Mitigation Plan.

Moreover, the IS/ ND identifies sites adequate to accommodate a variety of housing types for all income levels and needs of special population groups, analyzes governmental constraints to housing maintenance, improvement, and development addresses conservation and improvement of the condition of existing affordable housing stock, and outlines policies that promote housing 21 1 WEST TEMPLE STREET, Los ANGELES, CALII' ORNIA 90012 Jyaeliliall o1' 9'eivke
Vim, msr 4
Mr. Chow - 2 - January 18, 2021
opportunities for all persons. The Project must address the City' s ' fair share' of the Regional Housing Needs Assessment ( RHNA) and specific state statutory requirements and must reflect the vision and priorities of the local community. The Southern California Association of Governments ( SCAG) assigned the City a final RHNA allocation of 10, 031 units for the City, of which 5, 131 must be affordable to lower -income households.

The Department' s Santa Clarita Valley Sheriff' s Station ( Station) currently provides law enforcement services to the City. Although these changes do not reflect on a specific project at this time, the proposed Project may affect the level of service required by our Department when a proposed project is contemplated. For example, the proposed Project will increase resident, employees and daytime population of the Station' s service area which will generate an increased demand for law enforcement services at anticipated buildouts. The Station expects the future project environmental document to describe potential impacts to our resources and operations, and identify measures that will mitigate these impacts to a level of insignificance. If future development occurs within the City, the Department' s Contract Law Enforcement Bureau shall be informed during the planning phases so that potential impacts and its cost implications to our resources, operations, and law enforcement services contract may be properly re-evaluated and amended as necessary.

Also, for future reference, the Department provides the following updated address and contact information for all requests for reviews comments, law documents, and other related correspondence:

Tracey Jue, Director
Facilities Planning Bureau
Los Angeles County Sheriff' s Department
211 West Temple Street
Los Angeles, California 90012
Attention: Planning Section
Mr. Chow - 3 - January 18, 2021
Should you have any questions regarding this matter, please contact me at 323) 526- 5667, or your staff may contact Ms. Rochelle Campomanes of my staff, at ( 323) 526- 5614.

Sincerely,
ALEX VIL ANTJVA, SHERIFF Tracey
Jue, Director Facilities
Planning Bureau
Mr. Chow - 4 - January 18, 2021
TJ: RC: rclmm
Attachment
c: Justin R. Diez, Captain, Santa Clarita Valley Sheriff's Station ( SCV) Rodney Loughridge, Operations Lieutenant, SCV
Sergio V. Escobedo, Captain, Contract Law Enforcement Bureau ( CLEB) Bryan Aguilera, Lieutenant, CLEB
Julie Lowe, Sergeant, CLEB
Meghan Wang, Principal Facilities Project Manager, Facilities Planning Bureau ( FPB)
Rochelle Campomanes, Departmental Facilities Planner I, FPB Chrono
EIR- Santa Clarita Housing Element Update)
City of Santa Clarita
Housing Element Update

2. 3 Letter 3
COMMENTER: Tracey Jue, Director, Facilities Planning Bureau, Los Angeles County Sheriff' s Department
DATE: January 18, 2022
Response 3. 1
The commenter states that implementation of the proposed project would increase the demand for services within the Santa Clarita Valley Sheriff' s Station and may affect the level of service for the Department. The commenter states that they expect future environmental documents to describe the potential impacts to the Station' s resources and operations.

The project is a comprehensive update to the City' s Housing Element and does not propose changes to zoning or land use designations. The Housing Element Update, in and of itself, does not propose specific projects but sets forth goals and policies that promulgate new housing development in Santa Clarita consistent with the current RHNA cycle. Therefore, as a policy document, no impacts would occur at designated potential housing sites. Future development projects accommodated by the Housing Element Update would be subject to the City' s development plan review to determine potential concerns related to the Sheriff Department' s resource and operational capacity. If additional environmental review is required for future projects the CEQA documents would analyze impacts of those specific projects to police resources, as required by the CEQA Guidelines.

Therefore, no revisions are necessary relative to this comment.

Response 3. 2
The commenter notes that their address and contract information has changed.

The City acknowledges the commenter' s new address and contact information as:

Tracey Jue, Director
Facilities Planning Bureau
Los Angeles County Sheriff' s Department
211 West Temple Street
Los Angeles, California 90012
Attention: Planning Section
No revisions are necessary relative to this comment.
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VIA E-MAIL
January 18, 2022
Mary Cusick
City Clerk
City of Santa Clarita
23920 Valencia Blvd. Suite 120
Santa Clarita, CA 91355
Em: mcusick& santa-clarita.com
James Chow
Senior Planner
City of Santa Clarita
23920 Valencia Blvd, Suite 120
Santa Clarita, CA 91355
Em: jchow&e
santa- clarita. com
139 South Hudson Avenue
Suite 200
Pasadena, California 91101
LETTER 4
RE: City of Santa Clarita' s 6th Cycle Housing Element Update.

Dear Mary Cusick and James Chow,
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 City of Santa Clarita— 6th Cycle Housing Element Update January 18, 2022