City of Signal Hill– HCD Findings from 11/3/21 Letter
1 HCD Findings from 11/3/21 letter Edits/Response
A. Review and
Revision
The element must provide an evaluation of the cumulative effectiveness of past 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) and revise programs as appropriate.
The introduction portion of Appendix G: Progress report has been edited to address program effectiveness in meeting the housing needs of special needs populations.
B.1. AFFH -
Outreach
The element must describe outreach activities specific to affirmatively furthering fair housing (AFFH), summary of comments and how comments were considered and incorporated into the housing element.
The Introduction chapter has been updated to include a new section (J: Affirmatively Furthering Fair Housing (AFFH)). The section also discusses survey results and a discussion on AFFH and how comments were folded into the Element.
B.1. AFFH –
Integration
and
Segregation
While the element addresses integration and segregation related to race and ethnicity, disability, and familial status, it must also analyze patterns and trends related to income. Further, this analysis should compare Signal Hill to the surrounding region to better understand patterns of socio-economic concentrations and formulate goals and actions.
The integration/segregation section has been updated to:
• Add a section on income differences across the City.
• Added a regional comparison for households with a disabled member • Added a regional comparison for households with children Key findings in this section are that the City has a low level of racial/ethnic segregation, that there are no concentrations of families with children and households with disabled members, and that while compared to the region there is no concentrations of lower income households, there is a very wide income gap between renters and owners in the City.
B.1. AFFH –
RECAA
The element includes information relative to Racially and Ethnically Concentrated Areas of Poverty (R/ECAP) but should also address concentrated areas of affluence. 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 a regional level (e.g., city to region).
The section on Racially/Ethnically Concentrated Areas Of Poverty And Affluence has been updated. One tract has the highest median household income and the lowest proportion of minority residents (63.3%).
Nonetheless there are no racially or ethnically concentrated areas of affluence as the three census tracts have minority populations exceeding 64%. Between 2010 and 2018, the City’s level of diversity has remained unchanged in most areas and higher in a few areas of the City (using the U.S. Census Diversity Index in the HCD AFFH viewer). The surrounding South Bay region has also remained unchanged or become more diverse according to the same data source.
B.1. AFFH –
Disparities in
Access to
Opportunity
The element provides some general analysis of disparities in access to opportunity, mainly relative to the larger region.
However, this analysis should address patterns and trends within Signal Hill related to access to opportunities for education, employment, transportation and environmental quality.
Section G:4: Analysis of CBSA Regional Access to Opportunity/Los Angeles-Long Beach- Anaheim CA Region and Local Opportunity Access in Appendix B has been augmented with additional local information on:
• School quality and mobility
• Labor market information (industry, income, unemployment, and job access) • Transportation access
• Environmental quality
Die to the small size of the City, opportunity access varies very little across the City. While the City enjoys convenient access to transportation and jobs, they also live in an area with lower environmental quality.
B.1. AFFH –
Disproportion
ate Housing
Need
The element includes some City-wide statistics on cost burden and overcrowding, but it generally does not address this requirement. The housing element must include an analysis of disproportionate housing needs, including displacement risk. The analysis should address socio-economic patterns and trends of those patterns within Signal Hill and compared to the region. The analysis should include cost burden (renters and owners), overpayment, housing conditions, homelessness and displacement risks.
Section I.2: 2. Indicators of Disproportionate Housing Needs has been edited to add a discussion on overcrowding and substandard housing and augmented information related cost burden (renters and owners), housing conditions, homelessness and displacement risks.
B.1. AFFH –
Local Data
The element should incorporate local data and knowledge of the jurisdiction into the AFFH section. To assist in meeting this requirement, the element should provide local data not captured in regional, state, or federal data analysis. For A new section (Section 3. Local Knowledge And Other Relevant Factors) has been added to the AFFH chapter (Appendix C) and addresses results of the public outreach.
Attachment A
City of Signal Hill– HCD Findings from 11/3/21 Letter
2 HCD Findings from 11/3/21 letter Edits/Response
and
Knowledge
example, the element could utilize input from local service providers, neighborhood residents and advocates, local planning documents and City records.
B.1. AFFH –
Other
relevant
factors
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, zoning, governmental and nongovernmental spending including transportation investments, history of lending practices and demographic trends.
A new section (Section 3. Local Knowledge And Other Relevant Factors) has been added to the AFFH chapter (Appendix C) and addresses the City’s history of oil production, redlining, employment industry shifts.
B.1. AFFH –
Contributing
Factors
The element generally states the City does not have several fair housing issues (e.g., integration and segregation, disparities in access to opportunity and displacement risk). HCD encourages the City to revisit these findings based on a complete analysis. In addition, the element includes a few priorities and goals, but it should summarize the fair housing issues and identify and prioritize contributing factors to fair housing issues to better formulate the appropriate goals and action. Contributing factors create, contribute to, perpetuate, or increase the severity of fair housing issues and are fundamental to adequate goals and actions. Examples include community opposition to affordable housing, housing discrimination, land use and zoning laws, lack of regional cooperation, location and type or lack of affordable housing and lack of public or private investment in areas of opportunity or affordable housing choices. The analysis shall result in strategic approaches to inform and connect goals and actions to mitigate contributing factors to affordable housing.
Section 4: Summary of Findings have been added to the discussion and has been updated to identify potential issues. Section L:Fair Housing Issues And Contributing Factors has also been update to reflect this information. Section M: Fair Housing Priorities, Goals And Strategies in Appendix B is also updated to include a that that connects the fair housing issues with contributing factors and proposed actions. This table is also included in Program 5.3.
B.1. AFFH –
Sites
Inventory
The element indicates that all the sites identified to accommodate the lower income RHNA are in census tract 5734.02 which TCAC/HCD identified as a moderate resource neighborhood (p. C-14). However, the element must include analysis on the magnitude of the impact, any isolation of the regional housing need allocation (RHNA) by income group and address how the site locations (including sites intended for lower, moderate, and above moderate income households) improve conditions (or if sites exacerbate conditions, how a program can mitigate the impact) relative to segregation and integration, racially and ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs including displacement risk.
The AFFH sites discussion in Appendix B has been updated and expanded to include a list of findings from the analysis as well as identifying improved versus exacerbated conditions.
B.1. AFFH –
Goals and
Actions
The element must be revised to add or modify goals and actions based on the outcomes described above. Goals and actions must specifically respond to the analysis and identify and prioritize contributing factors to fair housing issues.
Actions must have metrics and milestones as appropriate and address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection.
Section M: Fair Housing Priorities, Goals And Strategies in Appendix B is also updated to include a that that connects the fair housing issues with contributing factors and proposed actions. This table is also included in Program 5.3.
B.2
Employment
Trends
The element provides some broad and brief information on employment trends, but it should include additional data and analysis to better formulate policies and programs. For example, the element could examine employment by industry, employment by occupation, local jobs and wages relative to affordability, major employers and relationship to housing, proximity to jobs, predominant modes of transportation and opportunities for improvement. The element could utilize data available through Local Housing Data prepared by the Southern California Association of Governments at https://scag.ca.gov/local-housing-data.
Section F.1.: 1. Population Trends and Projections has been updated to add information on employment by industry and median earnings to show the connection between employment and income which impacts housing choice and needs.
B.2 Ex Low
Income
Households
While the element identifies the projected number of extremely low-income (ELI) households, it must still analyze their existing housing needs. This is particularly important given the unique and disproportionate needs of ELI households.
For example, the element could analyze tenure, cost burden, overcrowding and other household characteristics then examine trends and the availability of resources to determine the magnitude of gaps in housing needs. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/housingneeds/extremely-low-income-housing-needs.shtml.
Section C.2.c. in Appendix A: Assessment of Housing Needs has been updated to include a description of the housing needs of ELI households and who the City is addressing those needs.
B.2 Housing
Cost
While the element includes costs data from the American Community Survey, it could also incorporate data from other sources such as the SCAG Local Housing Data for housing sales prices to better reflect current conditions and understand housing affordability issues.
Section G in Appendix E: Assessment of Housing Needs has been updated to include a section on Housing costs.
B.3 Parcel
Listing
Many sites listed in the sites inventory are comprised of multiple parcels (pp. C-5, C-8 and C-11). While the element may aggregate parcels, it must also list each parcel-by-parcel number or unique reference, parcel size, zoning, general plan designation, describe any existing uses for any nonvacant sites, and include a calculation of the realistic capacity of each Appendix C has been updated to include a parcel-specific listing. The section has also been updated to add more site details and fix the capacity calculation discrepancies. A summary site stable has been added prior to the site description for clarity.
City of Signal Hill– HCD Findings from 11/3/21 Letter
3 HCD Findings from 11/3/21 letter Edits/Response
parcel. In addition, the parcel listing should describe the existing use for each parcel. The description should be sufficiently detailed to facilitate an analysis that the use will likely discontinue in the planning period.
Most sites are undeveloped but are considered “non-vacant” because of the existence of oil wells on the sites. The section has been updated to clarify that existing uses will not impede residential development on the sites as those uses will be discontinued. The City and property owner have worked to ensure that this occurs with site plan creations, oil well remediation, environmental analysis, and site rezoning which will occur prior to Housing Element adoption.
Approved projects and ADU estimates have also been added to the sites inventory consistent with State law.
B.3
Environmenta
l Constraints
While the element indicates environmental review of identified sites and mitigation to allow development, it should also discuss impacts of oil wells on feasibility of development, including financial and should address whether there are any other known constraints or conditions that preclude development in the planning period.
Section H:Environmental Constraints in Appendix C has been updated to add information about geology and soils and hazardous materials information including oil wells. Information on site remediation is also added to this section.
The City has extensive experience in redevelopment of sites with oil well activity or abandoned/idle oil wells.
The City and the owners of the site will address all needed oil well remediation for the site and will make the site available “shovel-ready” to avoid development time delays and cost associated with these efforts. This approach is not new. In the 5th cycle, the City was able to meet its RHNA on sites owned by the City and SH Petroleum and that required oil production remediation. As the City has always relied on land with oil well production for new development, it has codified the requirements for those sites in its municipal code. Title 16: City of Signal Hill Oil and Gas Code regulates the drilling for production, processing, storage and transport by pipeline of petroleum and other hydrocarbon substances, timely and proper well abandonment and well site restoration and removal of oil and gas related facilities, reclamation and remediation of host sites and final disposition of pipelines in compliance with applicable laws and permits so that these activities may be conducted in conformance with federal, state, and local requirements, and to mitigate the impact of oilrelated activities on urban development.
B.3 Suitability
of Non Vacant
sites
The element must include an analysis demonstrating the potential for redevelopment of nonvacant sites. The analysis shall consider factors including the extent to which existing uses may constitute an impediment to additional residential development, the City’s past experience with converting existing uses to higher density residential development, the current market demand for the existing use, an analysis of any existing leases or other contracts that would perpetuate the existing use or prevent redevelopment of the site for additional residential development, development trends, market conditions, and regulatory or other incentives or standards to encourage additional residential development on these sites.
In addition, the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households (p. C-3). For your information, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).) Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the regional housing need allocation. The element indicates the City coordinated with the largest landowner, Signal Hill Petroleum, to identify sites that could be rezoned from nonresidential to residential for the purpose of accommodating the RHNA. The City should expand on Signal Hill Petroleum’s cooperation and demonstrate interest in residential development during the planning period.
Section B.5: Non-Vacant Sites in Appendix C is updated to address existing uses on the site and Signal Hill Petroleum’s cooperation.
Existing uses will not impede residential development on the identified sites as those uses will be discontinued and the City and property owner will lead that effort. The City and property owner have created conceptual site plans, oil well remediation plans, and environmental analysis. The City and the owners of the site will address all needed oil well remediation for the site and will make the site available “shovelready” to avoid development time delays and cost associated with these efforts. This approach is not new.
In the 5th cycle, the City was able to meet its RHNA with a similar approach on sites that required oil production remediation.
For the two sites used to meet the lower income and moderate income RHNA, Walnut Bluff and Orange Bluff, the site owners (the City of Signal Hill and Signal Hill Petroleum) will use a Request for Proposal process to identify a developer for the sites and achieve the indicated affordability levels. The City will waive the site plan review process for these sites and make the development process ministerial. The environmental analysis and oil well remediation process will have been completed for all sites (See Program 1.1).
As the City has always relied on land with oil well production for new development, it has codified the requirements for those sites in its municipal code. Title 16: City of Signal Hill Oil and Gas Code regulates the drilling for production, processing, storage and transport by pipeline of petroleum and other hydrocarbon substances, timely and proper well abandonment and well site restoration and removal of oil and gas related City of Signal Hill– HCD Findings from 11/3/21 Letter
4 HCD Findings from 11/3/21 letter Edits/Response
facilities, reclamation and remediation of host sites and final disposition of pipelines in compliance with applicable laws and permits so that these activities may be conducted in conformance with federal, state, and local requirements, and to mitigate the impact of oil-related activities on urban development.
The City will include findings in the adoption resolution that state that existing uses are not an impediment to additional residential development and will likely discontinue in the planning period.
B.3 Water and
sewer priority
Water and sewer service providers must establish specific procedures to grant priority water and sewer service to developments with units affordable to lower-income households. (Gov. Code, § 65589.7.) Local governments are required to immediately deliver the housing element to water and sewer service providers. The element should discuss compliance with these requirements and if necessary, add or modify programs to establish a written procedure by a date early in the planning period. For additional information and sample cover memo, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/other-requirements/priority-for-water-sewer.shtml.
Program 1.1 has been updated to address delivery of the housing element to water and sewer service providers and the establishment of priority procedures.
B.3 Map of
sites
The element includes potential site plans for identified sites. In addition, the element must include a general map of identified sites. This map may be utilized to facilitate analysis relative to AFFH. For additional information, see the sites inventory analysis section of the Building Blocks at http://www.hcd.ca.gov/community-development/buildingblocks/site-inventory-analysis/inventory-of-land-suitable.shtml.
A Site Inventory Map has been added in Section C.1 of Appendix C: Sites Inventory and Analysis B.3 Electronic
Sites
Inventory
For your information, pursuant to Government Code section 65583.3, the City must submit an electronic sites inventory with its adopted housing element. The City must utilize standards, forms, and definitions adopted by HCD. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-development/housingelement/index.shtml#element for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance.
Noted.
B.3 Zoning for
a Variety of
Housing Types
– Emergency
Shelters
The element indicates emergency shelters are permitted in the CG zone (Table D-1). In addition, the element must include analysis to demonstrate compliance with statutory requirements. The analysis must clarify emergency shelters are permitted without discretionary action and discuss available acreage in the CG zone, including typical parcel sizes and the presence of reuse opportunities. In addition, the analysis should address proximity to transportation and services, any conditions inappropriate for human habitability and development standards, including parking, compliance with statutory requirements. For example, parking, generally, should be limited to the number of spaces sufficient to accommodate staff working at the shelter. Based on the outcomes of the analysis, the element should add or modify programs as appropriate.
Section 7: Families and Persons in Need of Emergency Shelter in Appendix A has been updated to show the City’s development standards for emergency shelters, address parking requirements and give a description of the CG zone including access to services, transit, medical uses.
B.4 Land Use
Controls
The element must identify and analyze all relevant land use controls impacts as potential constraints on housing. The analysis should analyze land use controls independently and cumulatively with other land use controls. The analysis should specifically address requirements related to multifamily parking (garage and number of spaces) and heights.
This is particularly important given past programs to address these potential constraints. While the element includes some discussion of parking requirements and impacts on achievable densities, it must address all factors of a constraints analysis. 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 City regularly utilizes specific plan processes to set zoning and development standards on a project basis, including for identified sites. While yet to be determined, the element should discuss the potential zoning and development standards for identified sites, particularly for lower -income households and add or modify programs as appropriate to provide certainty for allowable development standards and ensure zoning does not act as a constraint.
The parking and height sections in Appendix D have been updated with more information and Program 3.3 has been updated to add an action item related to updating of the City’s parking standards and height limits.
To ensure that City parking standards and height limits are consistent yet take into consideration the differing needs for varying types of residential products and locations, the City will review the residential parking standards and height limits in the zoning code and make needed adjustments.
Table C-6 in Appendix C has been added to identify the expected development standards for the four sites.
This information is referenced in Program 1.1.
City of Signal Hill– HCD Findings from 11/3/21 Letter
5 HCD Findings from 11/3/21 letter Edits/Response
B.4 Processing
and Permit
Procedures
The element incudes some discussion of the site plan review process and the amount of time to reach a public hearing but should also address the amount of time for approvals. In addition, the analysis should address processing times for other entitlements such as specific plan processes, general plan amendments, rezoning, conditional use permits and variances.
In addition, the element should clarify whether the City has procedures consistent with streamlining procedures pursuant to Government Code section 65913.4 (SB 35) and include programs as appropriate.
Section I.2: Review and Approval Timelines in Appendix D has been updated to include two tables: Table D12 focuses more specifically on the individual entitlement approvals that may be required, providing estimated processing timelines for each as well as identifying the approving body. Table D-13 generally identifies the typical approvals required for single-family and multi-family projects, along with the estimated processing times of the planning and building departments. Information on the review process for the two affordable housing sites in the sites inventory is also included.
Program 3.4 has been added to address establishing procedures for development streamlining under SB 35.
B.4
Constraints
for persons
with
Disabilities
The element must include an analysis of potential constraints on housing for persons with disabilities. Specifically, • Group Homes for Six or Fewer Persons: Zoning appears to exclude unlicensed group homes for six or fewer persons.
The element should analyze this requirement and add or revise programs as appropriate • Group Homes for Seven or More Persons: The element requires a conditional use permit for group homes for seven or more persons in the single-family zones, unlike other similar uses (page D-21). The element should specifically analyze this constraint for impacts on housing supply and choices, approval certainty and objectivity for housing for persons with disabilities and include programs as appropriate.
Section J in Appendix D and Program 3.3 is updated to address issues related to developments standards for unlicensed group homes for Seven or More Persons Group Homes for Seven or More Persons.
B.4 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. The element includes some broad discussion but should analyze the actual standards applied for a typical development.
Section G: On-Site And Off-Site Improvement Requirements has been updated to address minimum street widths. This section also addresses the typical requirements. Also, to assist property owners and potential developers in identifying the type of improvements required for a specific type of projects, the City has created a Project Development Guide (2021) intended as a guide for developers of new buildings or large additions to existing buildings. It contains information on constraints to development in the City of Signal Hill such as oil wells, contaminated soils and seismic hazards, as well as cost considerations including developer impact fees, public works improvements, street widening dedication requirements and plan check and building permit fees. The Guide includes an overview of the planning process, leading to project entitlement and concludes with submittal requirements for Building, Grading and Street Improvement plan check and estimates on permit fees including developer impact fees for water, traffic, parks and schools.
B.4. Zoning,
Development
Standards and
Fees
The element must clarify whether the community complies with new transparency requirements for posting all zoning, development standards and fees or include programs as appropriate.
Section E in Appendix D: Governmental Constraints Analysis has been updated to address transparency and certainty in the development application process as required by Law. In addition to information on land use policies, zoning, and fees, the edit describes the City’s Project Development Guide (2021) for developers.
B.5. The element includes data and analysis for persons with special needs. However, to better formulate policies and programs, it should also identity and analyze persons with disabilities by type (e.g., ambulatory, cognitive, vision and hearing difficulty) and permanent and seasonal farmworkers at a county level (e.g., USDA Census of Agriculture). HCD will send data under separate cover.
Section E.2.a in Appendix A: Assessment of Housing Needs has been updated to include data on disabilities by type.
Section E.5.a in Appendix A: Assessment of Housing Needs has been updated to include farmworker data for Los Angeles County
City of Signal Hill– HCD Findings from 11/3/21 Letter
6 HCD Findings from 11/3/21 letter Edits/Response
B.6. The element does not analyze opportunities for energy conservation with respect to residential development. The element must include analysis of energy conservation opportunities in residential development. The analysis should facilitate the adoption of housing element policies and programs. For example, programs from the prior planning period (page G-7) could be added or programs could provide incentives to promote higher density housing along transit, encourage green building techniques and materials in new construction and remodels, promote energy audits and participation in utility conservation programs and facilitate energy conserving retrofits upon resale of homes. For additional information and sample analysis, see the Building Blocks at http://www.hcd.ca.gov/communitydevelopment/building-blocks/site-inventory-analysis/opportunities-for-energy-conservation.shtm and HCD’s Green Building and Sustainability Resources bibliography at http://www.hcd.ca.gov/hpd/green_build.pdf.
A new section (M: Energy Conservation Opportunities) has been added to Appendix D: Governmental Constraints Analysis to address opportunities for energy conservation with respect to residential development.
The Housing Plan has been edited to add an updated energy conservation program (Program 3.5) C.1 As noted in Finding B3, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types.
In addition, Program 1.1 (Adequate Sites Program) should commit to allowable development standards that will be considered. The program could specify a range of allowable development standards. Program 1.2 (Above Moderate- and Moderate-Income Rezoning Program) should commit to allowable densities and development standards to be considered.
Programs 1.1 and 1.2 are merged and updated to address the edits to the sites inventory. Table C-6 in Appendix C has been added to identify the expected development standards for the four sites. This information is referenced in Program 1.1.
Program 1.1 is also edited to reflect overall edits to the sites inventory analysis.
C.2. The element must include programs to assist in the development of very low-, low-, and moderate-income households, including ELI and all special needs households (e.g., elderly, homeless, farmworkers, persons with disabilities, femaleheaded households). Program actions could include proactive outreach (e.g., annually) and assistance to nonprofit service providers and developers, prioritizing some funding for housing developments affordable to lower, ELI and special needs households and offering financial incentives or regulatory concessions to encourage a variety of housing types.
Program 2.4: has been added to the Housing Plan to address special needs housing.
C.3 As noted in Finding B4, 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.
As a results of edits to the governmental and nongovernmental constraints analysis, several programs were edited or added:
• (edited) Program 3.1 ADU Ordinance and Incentives – edited to add an action item related to regional cooperation/funding, timeframes
• (edited) Program 3.3 Zoning Ordinance Amendments Program – edited to add action items related to development standards for: parking, height limits, and residential care facilities • (new) Program 3.4 SB 35 Development Streamlining
• (new) Program 3.5 Energy Conservation
C.4. As indicated in the review of past accomplishments (p. G-7), past efforts to implement a housing rehabilitation program do not appear effective. As a result, the program should be revised as appropriate and utilize a different approach in the current planning cycle. For example, the program could commit to pursue alternative funding sources on an annual basis or build partnerships with nonprofit developers to pursue funding options.
Program 4.2 has been updated to redirect the City’s effort toward identifying additional resources for housing rehabilitation activities.
C.5. As noted in Finding B1, the element must include a complete assessment of fair housing. Based on the outcomes of that analysis, the element must add or modify programs.
Section M: Fair Housing Priorities, Goals And Strategies in Appendix B is also updated to include a that that connects the fair housing issues with contributing factors and proposed actions. This table is also included in Program 5.3.
C.6. Program 3.1 (ADU Ordinance and Incentives) currently commits to adopt a plan for incentives in the planning period; however, it must also specifically commit to establishing incentives by a specified date early enough in the planning period.
Program 3.1 has been updated with more specific timeframes for the program actions. Specifically, the City’s updated ADU ordinance is currently being updated and will be completed by mid-year (July 2022).
D.1. While the element discusses how internal consistency will be maintained throughout the planning period, it should also discuss how internal consistency was achieved as part of the housing element update.
Section 1 under the “Housing Element Consistency with Other General Plan Elements” heading is updated to address continued consistency among elements. Also, the updated text addresses the new laws that require additional General Plan update requirements upon revision of the Housing Element.
City of Signal Hill– HCD Findings from 11/3/21 Letter
7 HCD Findings from 11/3/21 letter Edits/Response
E.1. While the City made efforts to include the public through workshops and a survey, moving forward, the City should employ additional methods for public outreach, particularly to include lower-income and special needs households and neighborhoods with higher concentrations of lower-income households. For example, the City could conduct targeted stakeholder interviews or establish a committee representative of lower-income households in future public outreach efforts. In addition, while the element includes a summary of the public participation process (pp. I-4 to I-8), it must also summarize the public comments and describe how they were considered and incorporated into the element. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community-development/buildingblocks/getting-started/public-participation.shtml.
In addition, HCD understands the City made the element available to the public concurrent with its submittal to HCD. By not providing an opportunity for the public to review and comment on a draft of the element in advance of submission, 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 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 revising 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.
The Public Participation And Consultation discussion in Section 1 has been updated to summarize the public comments and describe how they were considered and incorporated into the element.
The City will make the revised draft Element available to the public for at least one week prior to resubmittal to HCD and will note how public comment id incorporated into the Element.