SUBJECT: CITY OF HERMOSA BEACH 2000 HOUSING ELEMENT UPDATE

 

PURPOSE: RESPONSE TO THE COMMENTS OF THE State DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT (HCD) IN ORDER TO OBTAIN STATE CERTIFICATION OF THE 2000 HOUSING ELEMENT UPDATE

Recommended Alternatives:

That the City Council:

1. Approve the revisions to the 2000 Housing Element Update and direct staff to transmit the document to HCD.
2. Direct staff to transmit the Housing Element Update as originally approved December 12, 2000.

Background:

At the meeting of December 12, 2000, the City Council directed staff to transmit the Draft Housing Element Update to HCD as recommended by the Planning Commission, with revisions. The Draft Housing Element was submitted to HCD in early 2001 for review.

On July 2, 2001, the City received comments on the Draft Housing Element from HCD. Pursuant to State law, the City has until December 2001 to transmit revisions to the HCD for final review. The revisions are summarized as follows:

• Expand the program summary and evaluate the appropriateness of the previous Element goals, objectives and policies to determine where programs were successfully implemented and where they should be revised or replaced.

• Clarify the number of housing units constructed during the planning period and expand the land suitability inventory for residential development including sites available for redevelopment. Provide an analysis of relationship of zoning and public facilities and services to these sites. Expand this inventory to indicate how the City will facilitate development of vacant sites and redevelopment of non-residentially zoned sites.

• Describe housing programs for reuse/recycling of underutilized residential property based on realistic density ranges per zones.
• Describe how densities in the R-2, R-2B, R-3 and R-P zones facilitate development of affordable housing relative to the City’s RHNA projections and how City policies encourage higher density residential development when consistent with higher density zoning.
• Identify vacant or underutilized sites that have sufficient infrastructure available to accommodate higher density development and future residential development.
• Quantify the tenure characteristics of the elderly and large family households and existing and proposed emergency shelters and transitional housing.
• Quantify the maximum number of housing units by income category that can be constructed, rehabilitated, conserved or preserved over the planning period of the Element. Describe how the city’s plan approval process facilitates the construction objectives of the Element and describe programs to address governmental constraints to achieve housing objectives.
• Provide more definitive programs with implementation timelines which assist in the development of housing for low and moderate income households.

Analysis:

The City retained the firm of Blodgett, Baylosis Associates to prepare the 2000 Housing Element Update. The firm also prepared the City’s response to HCD’s comments which are attached. Beyond the provision of additional required data, the most substantive change recommended is to add the previously proposed program to allow mixed-use development along the City’s commercial corridors. With this program, the City can demonstrate to the State that some additional housing can be developed for varying income levels. Other recommended responses and changes are set forth in the attached draft document for response to HCD.

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Response to HCD

The purpose of this report is to outline the recommended changes that the State of California Department of Housing and Community Development (HCD) has indicated would bring Hermosa Beach’s housing element into compliance with Article 10.6 of the Government Code. Following each of HCD’s comments are the City’s specific response. In addition to responding to each of HCD’s concerns, the information that will be incorporated into the draft Housing Element is indicated using italics. The comments from HCD, and the City’s specific responses, correspond to the format of the original HCD review latter.

A. Review and Revision

HCD Comment A-1

• The previous element should be reviewed to evaluate the appropriateness of the element 's goals, objectives, policies, and provide a description of how the goals, objectives, policies, and programs of the updated element incorporate what has been learned from the results of the prior element (Section 65588(a) (1)).

Table 4-3 includes a general summary of the 40+ policies/objectives contained in the prior element (adopted 10/90). However, the element should be expanded to include a more detailed evaluation of the implementation of the policies/objectives during the past planning period to determine the success of the programs and, in turn, determine which programs should be continued, strengthened, or replaced. For additional guidance, please refer to HCD’s publication, "Housing Element Questions and Answers ", sent under a separate cover.

City Response A-1

Table 4-3 was expanded to provide more detailed information regarding the success in the implementation of the policies. A new column was added to elaborate on the activities that have been implemented since the adoption of the policies. The new information that will be included in the draft Housing Element includes the following:

• The City prepared a Policies Workbook that staff and decision-makers were asked to review. The workbook indicated those existing policies and objectives that were included in the previous Housing Element and reviewers were asked to make changes or comments in the space provided below each policy/objective. The purpose of this Policies Workbook was to assist in the review of the existing Housing Element programs and policies. This review, in turn, enabled the City staff to determine the appropriateness of the existing housing policy in meeting existing and projected housing needs. Finally, the Policies Workbook assisted in the development of new policies and programs in those instances it was determined that new policy direction was warranted.

• As required by Section 65583(c) of the Government Code, actions and policies included in the housing program were arranged so they addressed five key issue areas. As a result, the policies contained in the Housing Element are discussed according to the following five issue areas:

• + The conservation of the existing stock of affordable housing.

• + Assistance in the development of affordable housing.

• + The provision of adequate sites to achieve a variety and diversity of housing.

• + The removal of governmental constraints as necessary.

• + The promotion of equal housing opportunities.

• Table 4-3 indicates those original objectives and policies that were included in the previous Housing Element and the corresponding revisions. This Housing Element has been simplified to include only "policies." The previous Housing Element’s goals, policies, and objectives appeared to have a similar function that was largely indistinguishable.

Table 4-3 Previous Housing Element Objectives & Policies Matrix
Objective/Policy	Eliminated	Revised	Unchanged	Status of Objective/Policy in this Housing Element
To encourage the maintenance and improvement of the existing housing stock within the City.		p		The City will continue to encourage the maintenance and improvement of the existing housing stock within the local neighborhoods. (Rewording of Existing Objective No. 1)
To facilitate the preservation and enhancement of the housing supply for senior citizens.		p		The City will assist in the preservation and enhancement of the housing supply available to senior citizens. (Rewording of Existing Objective No. 2)
To prevent and abate the existence of illegal "bootleg" units, as they represent substandard and potentially unsafe housing or usage in conflict with zoning and/or general plan standards.	p			Policy was eliminated. New policy has been added indicating that any "bootleg" units must be brought up to code.
To protect from conversion the existing lower cost rental housing stock represented by apartments found in structures having three to nine units.		p		The City will strive to prevent the conversion of existing lower cost rental housing in multiple-family developments to condominiums. (Rewording of Existing Objective No. 4)
To promote and encourage the conservation of existing neighborhoods (where appropriate).		p		The City will promote and encourage the conservation and maintenance of the existing neighborhoods. (Rewording of Existing Objective No. 5)
To maintain and improve the existing stock of residences in sound condition through the use of available regulatory powers and financial incentives.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To maintain adequate levels of public services to existing neighborhoods and the maintenance of public property.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To establish actions which would result in the improvement of the maximum feasible number of units in need of major repairs.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To encourage the replacement of the maximum number of housing units that are in dilapidated condition.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To evaluate new development proposals in light of the community's environmental resources and values, and capacity of the public infrastructure within the scope of environmental constraints, housing demand, and projected share of regional bousing needs.		p		The City will evaluate new development proposals in light of the community's environmental resources and values, the capacity of the public infrastructure to accommodate the projected demand, and the presence of environmental constraints. (Rewording of Existing Objective No. 10)
To allow for innovative methods of construction and land use to conserve energy and enhance livability.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To promote the development of varied forms of family housing.		p		The City will continue to promote the development of a variety of housing types and styles to meet the existing and projected housing needs for all segments of the community. (Rewording of Existing Objective No. 12)
To ensure that new housing is provided with adequate open space, utility facilities, parking, and essential community services.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To promote energy efficient development of varied forms of housing.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To examine regulations promoting alternate heating and cooling systems.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To guide the development of the maximum feasible (and environmentally appropriate) number of housing units over the next five years consistent with the community's neighborhood conservation goals.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To replace housing lost from the community's inventory on at least a one-for-one basis.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To utilize, where appropriate, the existing housing stock as a means. of meeting the housing needs of all age groups and economic segments.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To encourage the development of adequate housing to meet the needs of all income groups.		p		The City will encourage the development of safe, sound, and decent housing to meet the needs of all income groups. (Rewording of Existing Objective No. 19)
To protect and enhance the supply of housing for senior citizens.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To encourage public support for private initiatives and efforts to administer and maintain housing units and funds acquired for senior citizen households.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To review General Plan and zoning to ensure residential development standards are adequate for the level of development projected.		p		The City will continue to evaluate the General Plan and zoning to ensure residential development standards are adequate to serve the future development. (Rewording of Existing Objective No. 22)
To continue to review zoning practices for consistency with the General Plan.		p		The City will continue to implement the land use policy of the General Plan, which provides for a wide range of housing types at varying development intensities. (Rewording of Existing Objective No. 23)
To encourage expansion in the number of owner-occupied dwellings in the City's housing stock.		p		The City will continue to support and promote home ownership in the community. (Rewording of Existing Objective No. 24)
To encourage the preservation of single-family dwelling units.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To encourage the preservation and expansion of family-oriented neighborhoods	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To investigate the use of property maintenance ordinances and programs to retain an aesthetic community appearance.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To conduct a historic preservation survey of the City's residential housing stock.	p			Policy was eliminated because its focus was unrelated to housing development policy.
Plan for and monitor the adequate delivery of public services such as parks, street maintenance, sewers, etc. to existing neighborhoods.		p		The City will continue to plan for, and monitor, the adequacy of public services such as parks, street maintenance, sewers, etc., to existing neighborhoods. ( Rewording of Existing Objective No. 29)
Provide a guide and other information services to assist in the preservation and renovation of older housing units.		p		The City will provide information to residents and property owners describing services designed to assist in the preservation and renovation of older housing units. (Rewording of Existing Objective No. 30)
Coordinate housing, community and economic development activities with private sector and citizen group involvement.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
To participate and coordinate, where appropriate, the activities of government agencies, citizen groups, and the private sector relative to the provision of adequate housing for all households		p		The City will continue to cooperate with other government agencies, citizen groups, and the private sector in order to provide adequate housing to accommodate existing and future demand. (Rewording of Existing Objective No.32)
Continue to conduct code compliance inspections for residents to make them aware of the safety hazards in their homes, or homes which they are considering purchasing.		p		The City will continue to utilize code enforcement as a means to reduce potential safety hazards in older, non-conforming residences. ( Rewording of Existing Objective No. 33)
Actively enforce zoning and buildings, codes to prevent the illegal conversion of existing structures to higher density use, and ensure that each resident lives in a safe and sanitary unit.		p		The City will continue to actively enforce zoning and buildings codes to prevent the illegal conversion of existing structures to non-permitted uses, and will strive to ensure that every City resident is provided a safe and sanitary unit. (Rewording of Existing Objective No. 34)
Continue to provide information and referral services to regional agencies that counsel people on fair housing and landlord-tenant issues.		p		The City will continue to provide information and referral services to regional agencies that counsel people on fair housing and landlord-tenant issues. (Existing Objective No. 35)
Continue to cooperate with the County Housing Authority with rental assistance to lower-income households.		p		The City will continue to cooperate with the County Housing Authority related to the provision of rental assistance to lower-income households. (Rewording of Existing Objective No. 36)
Cooperate with other cities and agencies in the area in investigating resources available for housing the area's homeless.		p		The City will continue to cooperate with other cities and agencies in the area in investigating resources available to provide housing for the area's homeless population. (Rewording of Existing Objective No. 37)
Encourage and expand shelter programs with adjacent cities and local private interests for the temporary accommodation of the homeless.		p		The City will continue to encourage and promote the expansion of shelter programs with adjacent cities and local private interests for the temporary accommodation of the homeless population. (Rewording of Existing Objective No. 38)
Senior citizen housing project on PCH should receive cooperation from the City, as a means of meeting our housing quantified objectives.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
Provide Affordable Rental and/or Sale of Housing for Low- and Moderate-Income Families.	p			Policy was eliminated. The City’s ability to directly implement this program as stated, is difficult.
Preserve the aesthetic value of neighborhoods by examining the height limitations in each residential zone.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.
Height of structures shall be restricted to limit view blockage when feasible and hardship does not result.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.
Floor area ratio should be retained as a means to reduce the bulk of family residences except where lot size would result in a dwelling of obsolete size.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.
Private open space to be provided on each lot, for each housing unit, by limiting maximum lot coverage.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.
Off-street parking spaces shall meet standards relating to size, access, and location.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.
Provision of required off-street parking spaces shall be based on typical use, household demand, total floor area for dwelling units, and number of units in developments.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.
Parking spaces, open or enclosed, shall be for that designation, and strict enforcement will be used to prevent conversion to storage or residential use such as bedrooms, "bootleg" units, dens, etc.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.
Density shall be imposed within the parameters stated in the General Plan.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.
Density bonuses for senior/low income housing projects may be awarded as required by the state.	p			Policy was eliminated. City is required to comply to the State’s requirements with respect to density bonuses for affordable housing.
Minimum unit size for senior citizen ownership bousing (condos) will be lowered for the purpose of providing affordable units.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.
Setback averaging for architectural variety and visual interest, provided that open space requirements are met, may be allowed.	p			Policy was eliminated due to its potential as a governmental constraint. City will use zoning standards to regulate residential development.
Open space shall be based an a percentage of the lot size. Ground level open space shall be adequate in size for passive and active recreational activity where lot size permits.	p			Policy was eliminated due to its potential as a governmental constraint. City will use zoning standards to regulate residential development.
Dwellings where the main pedestrian access is facing the side yard shall require a larger setback.	p			Policy was eliminated due to its potential as a governmental constraint. City will use zoning standards to regulate residential development.
Landscaping plans shall be required for all new development, including rental units; single- family dwellings shall be excluded.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.
Parking shall be designed to maximize its usefulness and availability, particularly guest spaces.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.
Conservation of legal non-conforming residential structures shall be directed through current procedures and programs.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
Increased density should be restricted in geologically and ecologically sensitive areas.	p			Policy was eliminated because it was a duplication of other policies included in the Housing Element.
A neighborhood approach of "string lining" and/or averaging shall be utilized wherever feasible in relation to any and all required standards.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.
Residential standards shall be more precisely examined for their relative effects on development and their individual impacts during the implementation of this element.	p			Policy was eliminated. Building standards are controlled through the General Plan and Zoning requirements.

 

B. Housing Needs, Resources and Constraints

HCD Comment – B1

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 (Section 65583(a) (1)). Include the locality’s share of regional housing need in accordance with Section 65584.

The element indicates 167 new residential units have been added to the City’s housing stock in the last three years (page 3-2). However, according to Table 3-5 (page 3-4), new construction has resulted in a net increase of only 56 units since July 1998. The element should clarify/reconcile the number of units actually constructed. The City may apply these units towards their Regional Housing Needs Allocation (RHNA) for the 2000-2005 planning period provided the element includes the basis for concluding that the newly-built units have been credited to the appropriate income group, based upon the unit’s affordability, in particular, the very low-, low-, and moderate-income categories. It is important to note that only those units constructed after January 1, 1998 can be counted.

City Response - B1

Units constructed have been recalculated, starting from January 1 1998, and extending until June 2001, based on building permit data, and tabulated it by calendar year. The number of units constructed in this period is 163. The data in table 3-5 are "fiscal year" permit data and thus do not precisely coincide with the calendar year data. The reason for the previous discrepancy between table 3-2 and table 3-5 was because the table 3-5 did not include the 80 unit senior housing project. It will now be adjusted to reflect the 80-unit senior housing project constructed in 1998.

(The text on page 3-2 following Table 3-1 will be revised to read as follows):

• As indicated previously, the number of housing units that have been added to the City’s housing inventory must be considered in the RHNA. The assumptions used in making the adjustments to the construction need for the City’s RHNA are identified below. These "assumptions" relied on building permit and demolition permit data provided by the Community Development Department.

• + In calendar year 1998, a total of 102 units were constructed and 78 units were demolished. In addition, the Sunrise Senior Housing development, consisting of 80 units, was constructed resulting in a net gain of 104 units in 1998.

• + In calendar year 1999, a total of 89 units were constructed and 76 units were demolished, resulting in a net gain of 13 units.

• --In calendar year 2000, a total of 112 units were constructed and 79 units were demolished, resulting in a net gain of 33 units. In addition, a hotel was constructed, consisting of 72 rooms, this year.
• --In the period between January and June 2001, 37 units were constructed and 24 demolished resulting in a net gain of 13 units.

• Based on the aforementioned information collected from the City’s Community Development Department, a total of 163 units have been added to the City’s housing inventory since January 1,1998. These additional units may be counted towards the City’s RHNA allocation. As a result, the total unmet construction need now stands at 170 units. Table 3-2 indicates the "adjusted" construction need when considering the net increase in housing units that have already been, or will be added, to the City’s housing inventory since January1998.

Table 3-2 Regional Housing Needs Assessment
Income Level	RHNA	Met 1998-2001	Unmet Need
Very Low-Income	55	0	55
Low-Income	42	42 1	0
Moderate-Income	61	38 1	23
Above Moderate-Income	175	83	92
Total Future Need	333	163	170
Source: City of Hermosa Beach 1 Assisted Housing Units for the Elderly

(In addition, the following text will be revised on page 3-4, following Table 3-4.)

Table 3-5 compares the residential development that has occurred since 1991 with the overall theoretical development capacity (9,842 housing units). As of July, 2000, the current zoning/ general plan land use designations provide for an additional 408 housing units, assuming that all of the underdeveloped residential lots in the City were developed to the maximum intensity.

Table 3-5 Development in the City of Hermosa Beach 1991 - 2000
Period 1	No. of Housing Units in Beginning of Period	Housing Units			No. of Housing Units at End of Period	Potential Additional Units
		New Units	Demos	Net Gain
December 1991	9,272	-	-	-	9,272	570
Dec. ‘91-‘92	9,272	14	7	7	9,279	563
1992-1993	9,279	17	6	11	9,290	552
1993-1994	9,290	8	6	2	9,292	550
1994-1995	9,292	8	2	6	9,298	544
1995-1996	9,298	20	4	16	9,314	528
1996-1997	9,314	40	21	19	9,333	509
1997-1998	9,333	179 2	72	107	9,360	482
1998-1999	9,360	92	53	39	9,399	443
1999-2000	9,399	92	97	(5)	9,394	448
2000-2001	9,394	102	62	40	9,434	408
Source: City of Hermosa Beach Community Development Department 1 Hermosa’s fiscal year begins in July and ends in the June. Dec. ’91 was beginning of data collection 2 Includes the 80-units constructed as assisted living units for the elderly, which did effect potential added units column

HCD Comment – 2a, 2b,2c, and 2d

Include an inventory of land suitable for residential development, including sites having the potential for redevelopment, and an analysis of the relationship of zoning and public facilities and services to these sites (Section 65583(a) (3))

The element indicates that Hermosa Beach is nearly built out and contains only 6.85 acres of scattered vacant residentially zoned sites, along with 3.2 acres of vacant commercial and industrial zoned land (page 3-5). Based on the programmatic efforts, land-use controls and constraints analysis, it is not clear that the City’s RHNA (55 very low; 42 low; 61 moderate; and 8 above moderate, for a total of 166), specifically for lower-income households, can be accommodated). The available sites and land inventory analysis should be expanded to include the following:

1. The element should describe the City’s role in facilitating development of the vacant residential and non-residentially zoned sites (page 3-5). For example, will the City provide fiscal or regulatory incentives, assist in the entitlement application and review processes for general plan amendments and/or rezones, or facilitate lot consolidation of the numerous substandard lots (page 3-5)?

2. Effective implementation of a reuse/recycling strategy is essential to the City in terms of its ability to meet the new construction need. Therefore, the element should include a description of the existing use(s) found on the identified underutilized sites and provide more information regarding the specifics of its proposed reuse/recycling strategy. Hermosa Beach should also provide realistic density ranges of the zones permitting residential uses (rather than theoretical or maximum yield), and an indication of the development viability for each site.

3. The element should demonstrate how permitted development densities in the R-2, R-2B, R-3, and R-P zones areas will facilitate the development of housing affordable to lower-income households commensurate with the City’s remaining regional share need. The element should also describe whether recent higher density developments have actually been built out at the densities shown in Table 3-4 (i.e., 25-33 du/per acre). Lastly, indicate if the City has policies in place that discourage single-family or lower density development in those area designated for higher density residential uses. The element should describe the affordability of recently approved multifamily and condominium projects.

4. Include an analysis of whether the identified vacant and underutilized sites have or could have sufficient infrastructure availability (e.g., water and sewer) to allow development to occur by the end of the current planning period. Also include information regarding the City’s public water and sewer treatment facilities (existing and planned), with respect to their ability/capacity, in the aggregate, to serve future residential development.

Response B2a

3.2.3 Land Availability - Vacant Land Inventory

• The majority of the City’s land area is designated for residential development, and virtually all of the parcels where such uses are permitted have been previously developed. To assess the availability of suitable development sites for residential uses, review of the City’s land use database was consulted to identify vacant parcels within the City. The results of this survey indicated the following:

• + A total of 2.24 acres of commercially zoned land Citywide is vacant consisting of 28 parcels ranging in size from 108 square feet (a remnant parcel) to more than 28,000 square feet. The majority of these parcels range in size from 1,500 to 2,500 square feet. The majority of these properties are zoned C-2, C-3, or SPA.

• + Approximately 0.8 acres of vacant land is designated for industrial uses. The eight parcels included in this category are located at 1514 Pacific Coast Highway.

• + A total of 6.85 acres of residentially zoned vacant land is distributed throughout the City among 101 parcels with 1,700 square feet to 3,500 square feet. The majority of these vacant parcels are substandard in that they do not meet the minimum lot size requirements for the applicable zoning designation.

• In order to facilitate the development of vacant lots, the City has and will continue to promote the density bonus program and the proposed mixed-use program. All vacant and underutilized sites are served by infrastructure that will permit their development, and the city is committed to maintain infrastructure capacity through its capital improvement program. The City contracts with L.A. County for sewer treatment, and California Water Service Co. for water supplies that can serve existing and future development.

• A detailed listing of vacant sites is provided herein in Appendix A. The parcel location, lot area, applicable zoning, and the development potential are also noted in Appendix A.

City Response - B2b

(In Section 3.2.2 the paragraph after table 3.5 will be revised to read as follows)

• Tables 3-4 and 3-5 clearly indicate that the City’s land use policy promotes a wide range of housing types at varying development intensities. Table 3-5 also provides an accurate description of the maximum as well as viable development available in the City. This inventory includes the development viability of each land use site showing that the capacity for new development is very limited. Based on the extent and location of land designated for residential land uses, and the permitted intensity of residential development corresponding to the land use designations, the City of Hermosa Beach General Plan is "non-exclusionary."

City Response - B2c

(In Section 3.2.2 add second paragraph after table 3.5)

• Currently there are 9,434 units located within the city and according to table 3-4 -- 9,842 units are possible under the City General Plan. Lot sizes, lot pattern, and the land values in the City dictate development of 2 and 3 unit projects that maximize development potential of the lots, and because of the market and beach location the units are still not affordable, and would not become affordable even if more density was permitted.

City Response - B2d

• Refer to City Response - B2a

Comment B-3

Analyze potential and actual governmental constraints upon the maintenance, improvement, and development of housing for all income levels, including land use controls 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 Section 65584 (Section 65583(a) (4))

• The element provides a good overview of the City’s residential development standards. However, Table 2-33 should be expanded to describe and analyze the parking requirement(s) for all zones permitting residential uses, and specifically the parking standard for multifamily uses (i.e., number per bedroom and covered vs. uncovered). The element should include an analysis of whether the parking standards pose a constraint to the development of affordable housing. Identified constraints should be removed or programs to mitigate the constraints should be included in the element.

The element should contain a description of the City’s entitlement processing procedures, including timelines (for general plan amendments, specific/community plans, rezones, maps, development plan review, and use permits), as they apply to residential uses. Additionally, the element should describe the City’s ministerial and/or discretionary review processes as they apply to the approval and development of multifamily housing and mobile homes.

According to the element, Hermosa Beach’s Local Coastal Plan (LCP) is in the final stages of review. The element further indicates that the LCP will include policies that could potentially impact future housing development "within the designated coastal zone of the City." The proposed policies will address the preservation of beach access, ensuring that adequate parking is available, restricting density, and regulating building size and height. As a result, the element should be expanded to include an analysis of whether the LCP’s proposed policies pose a constraint to the development of affordable housing.

City Response B-3

(Insert at the end of 2.8.1 Government Constraints-Land Use Controls)

Table 2-34 describes the parking requirements for residential uses.

Table 2-34 Parking Requirements for Residential Uses
Use	Required Parking
Single–Family Residence	Two off-street spaces plus one guest space per SFR.
Duplex or Two- Family Residential	Two off-street spaces and one guest space per unit, plus one additional space of on-site guest parking for each on-street space lost because of new curbcuts and/or driveways.
Multiple Dwellings (Three or more units)	Two off-street spaces for each dwelling unit plus one guest space for each two dwelling units. One additional space of on-site guest parking shall be provided for each on-street space lost because of new curbcuts and/or driveways.
Detached servants quarters or guesthouses	One Space.
Mixed Use	Parking spaces shall not be less than the sum total of the parking spaces required for each of the distinct uses. No off-street parking facility provided for one use shall be deemed to provide parking facilities for any other use except as otherwise specified within Chapter 17.44 of the Zoning Code.
Source: City of Hermosa Beach

2.8.2 Government Constraints- Permit Processing and Fees

• Permit fees and approval time frames do not pose a constraint to development, and the process applies to all residential development including multi-family and mobile homes. Plan check for the processing of building permits is generally four to six weeks, depending on the City’s workload. For discretionary permits, there is an initial internal review period of 30 days. Once the application is deemed complete, it is then forwarded for the prescribed public review and noticing period. This process can take either 2 month or 13 months depending on the permit. If the permit is a Conditional Use Permit or variance the process will take up to 2.5 months. If the project requires CEQA review the process is a little longer. A Negative Declaration (Neg. Dec.) may take 3 to 5 months to complete compared to an Environmental Impact Report (EIR) which can take up to 14 months, depending on the applicant. The processing time for the discretionary permits mentioned above include both the noticing and appeal time. Exhibit 2-1 and Exhibit 2-2 demonstrate the permit process and procedures for the Building and Planning Division.

• Building codes are applied to new construction, and are monitored and inspected under the building permit process. Where no permits have been obtained, inspections are made in response to requests and complaints. The City has adopted the 1997 Edition of the Uniform Building Code and other related construction codes. The ordinance details the revisions and amendments to the Building Code that exceed state standards. These amendments are all relatively inexpensive, and most of the revisions are related to fire alarms, smoke detectors, sprinkler systems, and other basic safety measures.

(Insert at the end of 3.2.2 Government Constraints-Land Use Controls)

• Land values are so high, that parking requirements have a relatively small effect on overall construction costs. As a result, the City’s parking requirements, as well as those governed by the Coastal Commission for that portion of the City within the coastal zone, are not a significant constraint or factor in housing affordability.

Comment B-4

• The element should contain an analysis of any special housing needs, such as the elderly and of large families, and families and persons in need of emergency shelter (Section 65583 (A) (6)).

The analysis of special housing needs should quantify the tenure characteristics of elderly and large family households. For your information, the 1990 Census determined that there were 672 elderly and 172 large family ownership households and 116 elderly and 60 large family renter households in Hermosa Beach (see enclosed CHAS data sheets). This information should be included in the housing element.

The element should also clarify the adequacy of the existing and planned facilities to accommodate the City’s identified need for emergency shelter and transitional housing and/or identify those zones where these uses are allowed as a permitted or conditional use. If no such zone exists, the element should include a program to provide for such opportunities.

City Response B-4

(Insert at the end of 2.5.1 Elderly)

• According to the 1990 Census there were 672 elderly ownership households and 116 elderly renter households. Of the 788 elderly households, 70 elderly ownership households and 17 elderly renter households make 0- 30% of the average household income, compared to 136 elderly ownership households and 33 elderly renter households that make between 50%-95% of the average household income. Of the 788 elderly households, 405 make more than 95% of the average household income, 62 renters and 343 homeowners.

(Insert at the end of 2.5.2 Large Families)

• According to the 1990 Census there were 172 large family ownership households and 60 large family renter households. Of the 232 large family households, 16 large family ownership households and no large family renter households that make 0- 30% of the average household income. There are 17 large family renter households and no large family ownership households that make between 50%-95% of the average household income. Of the 232 large family households, the majority of the large family households (192) make more than 95% of the average household income, 36 renters and 156 homeowners.

(Insert at the end of 2.5.5 Persons in Need of Emergency Shelter)

Emergency shelters and transitional housing facilities may be located in any area in the City. The infrastructure services for the City have been designed to accommodate build-out under the General Plan, and are adequate to handle these kinds of facilities. Public services and facilities are reviewed annually to determine if they are adequate for new development. An applicant desirous of providing or building an emergency shelter or transitional housing facility would obtain a conditional use permit, which would also study the adequacy and suitability of the site for its intended use, analyze traffic and other environmental impacts and, based on the anticipated impacts, set out conditions of development.

C. Quantified Objectives

Comment C-1

• The element should establish quantified objectives the maximum number of housing units by income category that can be constructed, rehabilitated, conserved, or preserved over the planning period of the element (Section 65583(b)).

The element should be expanded to include the number of new, rehabilitated, and conserved units by income category, as shown in the sample matrix. These objectives may include both private and City planned activities. For example, the construction objective might include streamlining the review and approval process for higher density and affordable residential developments.

Response C-1

3.3 New Housing Objectives

• As indicated in Section 3.1, the existing "unmet" need for housing units during this RHNA period is 166 units (a total of 163 units have been constructed since 1998, leaving an unmet balance of 170 units). Table 3-6 includes the revised new housing objectives the City will strive to meet during the balance of the RHNA period and distributes the units by income category that have been rehabilitated, conserved, constructed, and preserved since 1998.

Table 3-6 New Construction Objectives
Income Level	RHNA	Met 1998-2001	Unmet Need	New Construction	Rehabilitation 1	Conservation/ Preservation
Very Low-Income	55	--	55	--	210*	--
Low-Income	42	42	0	--	183*	--
Moderate-Income	61	38	23	--	82	--
Above Moderate-Income	175	83	92	139	310	--
Total Future Need	333	163	170	139	785	--
Source: City of Hermosa Beach 1 Distribution numbers based on HCD’s projections and SCAG. * Remodels, re-roof and additions to existing Multi-family units.

D. Housing Programs

Comment D-1

Include a program which sets forth a five-year schedule of actions 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, and provision of regulatory concessions and incentives. The housing element shall contain programs, which assist in the development of adequate housing to meet the needs of low- and moderate-income households (Section 65583(c)).

The draft element lists 9 programs to be implemented during the course of the 2000-2005 planning period. However, to address the program requirements of Sections 655 83(c), and in order for the City’s proposed housing development and assistance strategies to be more effective during the next planning period, each program should include definitive implementation timelines, describe the City’s role in implementation and identify the department or individual responsible for program implementation, as well as identifying specific funding sources where appropriate. For example, while it may be appropriate for Program 4.3.7 (Fair Housing) to be implemented over the course of the planning period, other actions should have detailed implementation actions with specific timelines early enough in the planning period to implement the desired change. Examples include, but are not limited to the following:

• + Development Bonus Program (4.3.1): The program should specify the bonuses and incentives (regulatory and fiscal) the City offers (or will offer), as well as describe the steps the City will take to ensure successful utilization of the program. For example, how will the City promote the program to those in the development community (i.e., brochures, etc)?

• + Housing Sites Identification (4.3.2): Provide specifics regarding the City’s role in implementation of this program including how it can be used as a tool to satisfy Hermosa Beach’s new construction need.

• + Second Unit Program (4.3.3): This program could aid in the City’s efforts to meet its new construction need. However, given the numerous requirements and restrictions (i.e., use permit, lot size minimum, age and deed restrictions) it appears, to date, that this program has been less than effective. To encourage more effective use of this program we suggest the City amend its second-unit ordinance to be less proscriptive.

• + Affordable Housing Outreach Program (4.3.9): Describe the specific steps the City will take to promote this program to lower-income households in the community.

City Response D-1

4.3.1 Mixed-use Program

• Mixed-use development is one potential strategy to provide both affordable housing and help revitalize commercial areas of the City. Housing affordability is established by the Department of Housing and Urban Development (HUD), and sets household income limit standards for very low, low, and moderate income.

• Mixed-use development can help increase housing affordability by decreasing both the cost of development and other household costs. For example, the land cost and construction associated with residential development may be reduced if commercial or office development included as part of a mixed-use project underwrites a portion of that cost. For future occupants, it can help minimize transportation costs because it can potentially reduce or eliminate work trips if one lives and works in the same space and helps reduce the amount of household income spent on transportation overhead and maintenance costs. Furthermore, it permits more efficient use of time because there is more time potentially available for work and less time allocated to work trip commutes. So mixed-use development can help occupants conserve that part of their income that is typically diverted to cover work-related transportation and commuting costs.

• Commercial land values in the City are approximately one-third the cost of residential land values. The reduced land cost can make housing projects more affordable in the City when coupled with density bonus provisions established under State law and shared parking arrangements with commercial portions of a mixed-use project. The price of land, cost for parking, and the cost per unit can be reduced under a mixed-use residential development program.

• A key element of the proposed program is envisioned as a vertical overlay zone for the commercial highway corridors utilizing existing zoning as the base zone designation with the potential to provide residential development pursuant to the R-3 zone requirements. The implementation involves the following:

1. A comprehensive inventory of potential mixed-use development sites;
2. The City will prepare mixed-use development standards and development guidelines incorporating R-3 residential density with the ability to utilize 25% density bonuses and relaxed parking requirements pursuant to State guidelines;
3. The City of Hermosa Beach Zoning Ordinance and Genreal Plan will be amended to permit mixed-use development;
4. The City will initiate an outreach program to publicize the program to project developers as required; and,
5. The City will undertake the implementation of the program to satisfy the City’s unmet affordable housing need over smaller scatter site residential projects with retail frontage, surface parking, and housing.

2. Development Bonus Program

• This program provides for bonuses and other incentives in the City=s Zoning Ordinance, as required under the California Government Code, to developers who construct projects containing affordable units. This program will also be useful in providing new market-rate and senior housing. According to the State guidelines, affordable units are defined as follows:

1. A "for-sale" unit is considered affordable to a lower-income household if the total monthly payment (rent or mortgage) does not exceed 35% of the monthly income of the household with a monthly income equal to 80% of the County median income. (The affordability thresholds are defined by the Department of Housing and Urban Development.)
2. A new rental unit is considered affordable to a lower-income family if the total housing cost (including rent and utilities) does not exceed 30% of 60% of the median monthly income for a family.
3. An existing rental unit is considered affordable if the total housing cost, including rent and utilities, does not exceed the prevailing fair-market rent published by the U.S. Department of Housing and Urban Development.

• New residential development meeting the above requirements may request that the City grant an incentive (with a value equivalent to a 25% density bonus) and/or regulatory concession or incentives. Within 90 days of receiving a request for such an incentive, the City Council is required to conduct a public hearing on the request. Following the hearing, the City Council may grant such incentives as long as the density bonus is appropriate and consistent with the General Plan and the Zoning Code.

• To help inform developers and contractors of the incentive program, the City will continue to provide brochures at the counter and provide information on the web about what the Housing Development Incentive Program has to offer.

4.3.3 Housing Sites Identification

• The purpose of this program is to comply with Government Code, Section 6558(c)(i), which requires local governments to identify sites that may be made available through appropriate zoning and development standards. The City will continue to maintain and update its comprehensive land use database as means to identify suitable sites for new residential development. This database provides zoning and other information for every parcel in the City, and includes information regarding underdeveloped and undeveloped parcels in the City.

• This effort also provides for a detailed examination of a site presently occupied by the Marineland Mobile Home Park, located at 531 Pier Avenue. In 1999, the City rejected a request by the property owner to reconfigure the mobile home park lines that would have resulted in the elimination of a number of existing units. The Applicant was seeking a Are-alignment of the trailer lots to accommodate the larger double-wide units. Through this review process, the City underscored its commitment in maintaining the existing configuration of the mobile home park, recognizing its value in providing more affordable housing units than what would otherwise be likely.

• In addition, there is land within the mobile home park that may be available for new residential development. The site would require some grading to make the site suitable for development. This program provides for City staff to consider and, if possible, work with, the current property owner to expand the mobile home leases within the park.

4.3.4 Second Unit Program

• Those portions of the City that are presently zoned R-2 and R-3 typically contain parcels too small to accommodate second units. As a result, the provisions for a second unit apply to the R-1 single-family zone. The current second-unit ordinance provides for a second unit on lots of at least 8,000 square feet, with a granting of a conditional use permit. The current code provides for the occupancy of a second unit to one or two adults who are 60 years of age or older. In addition, the maximum permitted floor area for the second unit is 640 square feet. Finally, the existing residence in which the second unit is to be located must conform to the City’s parking code. The City also requires that a deed restriction on the second unit, restricting its occupancy to one or two individuals who are 60 years of age or older. The City will prepare a brochure outlining the ordinance requirements and any requisite development standards.

4.3.10 Affordable Housing Outreach Program

• This proposed program will involve the investigation of potential funding sources to assist in the development and/or provision of affordable housing for those households in the City currently in need of such housing. The primary focus of the program will involve investigation into the feasibility of expanding Section 8 rental vouchers to qualifying households in the City.

• If the City is successful in finding a source for funds and/or expanding Section 8 rental vouchers for residents in the city, the City will post the information in the Community Center and notify those residents who qualify.

(Table 4-2 to be inserted at the End of 4.4 Housing Program Implementation Matrix)

Table 4-2

Program Implementation Matrix 2000-2005

Program	Funding Source	Implementation Schedule	Quantified Objectives	Responsible Department/Individual
Mixed-use Program	General Fund	Implemented 2002 and will continue to 2005	New Program to be implemented. It will provide for the construction of new affordable and market rate units.	Planning Department
Housing Bonus Program	General Fund	Implemented 2000 and will continue to 2005	Program will provide for the construction of new affordable and market rate units.	Planning Department
Housing Sites Identification Program	General Fund	Continue to 2005 and beyond	Database is being implemented.	Planning Department
Developer Consultation	General Fund	Continue to 2005 and beyond	Program will be on-going	Planning and Building Department
Code Enforcement Program	General Fund	Continue to 2005 and beyond	Program will continue at its current level.	Planning and Building Department
Environmental Review Program	General Fund Development Development	Continue to 2005 and beyond	Program is on-going pursuant to the requirements of CEQA.	Planning and Building Department
Fair Housing Program	General Fund	Continue to 2005 and beyond	New Program to be Implemented.
Second Unit Program	General Fund	Continue to 2005 and beyond	Program will continue to be implemented. Review of Ordinance will be initiated.	Planning Department
Affordable Housing Outreach Program	General Fund	Implement 2002 and continue to 2005	New Program to be Implemented.
Zoning Conformity Program	General Fund	Continue to 2005 and beyond	N/A	Planning Department

Comment D-2

Identify adequate sites which will be made available through appropriate zoning and development standards and with public services and facilities, including sewer collection and treatment, domestic water supply, and septic tanks and wells, needed to facilitate and encourage the development of a variety of types of housing for all income levels, including rental housing, factory-built housing, mobile homes, housing for emergency shelters and transitional housing (Section 65583(c) (1)).

• Absent a complete land inventory analysis as required in B.2, it is not possible to evaluate the adequacy of the City’s sites program. The City may need to develop programs and corresponding actions that will facilitate and encourage the development and/or recycling of the identified vacant and underutilized sites to accommodate its regional share for all income groups.

According to the element, the homeless population in the City is transient in nature and when encountered are referred to existing facilities in Long Beach and Redondo Beach. In spite of the small numbers, the element is still statutorily required to identify sites and/or zones where emergency shelters and transitional housing are permitted. If no site or zone exists, the element should include a description of the City’s role in encouraging and facilitating the development of emergency shelters and transitional housing and include a program to provide for such opportunities.

City Response D-2

(Land inventory will be included into the next draft to HCD)

(Refer to City Response B4)

Comment D-3

Include program actions to address and, where appropriate and legally possible, remove governmental constraints to the maintenance, improvement, and development of housing for all income levels (Section 65583(c) (3)).

As noted previously (B.3), Hermosa Beach’s element requires a more thorough description and analysis of the City’s identified governmental constraints. Depending upon the results of that analysis, the City may need to add programs to remove or mitigate, any identified constraints.

City Response D-3

Refer to City Response B3

E. Coastal Zone Localities

Comment E-1

Coastal Communities shall document the number of low-and moderate-income units converted or demolished, and the number of replacement units provided (Sections 65588(d)(1-3)).

• The element should identify the number of low- and moderate-income dwelling units that have been replaced, demolished, and/or converted, within the coastal zone, since January 1, 1982.

Response E-2

• The City of Hermosa Beach currently has 6.85 acres of vacant land Citywide available for residential use. The vacant land is distributed among 101 vacant parcels ranging from 1,700 to 3,500 square feet in area. Therefore failing to meet the minimum lot size requirements for the applicable zoning designation. Since the City does not have applicable land or the ability to construct or otherwise subsidize the construction of new housing through redevelopment, it must rely on its existing incentives to promote the development of affordable housing in the coastal zone.

• The Local Coastal Program (LCP) currently being finalized by the City of Hermosa Beach addresses three primary issue areas: access, locating and planning for new development, and the preservation of marine-related resources. The LCP will contain a number of policies that may impede the construction of new housing development within the designated coastal zone of the City. These include policies related to the preservation of beach access, the provision of adequate parking (including requiring adequate off-street parking to be provided in new residential development), and controlling the types and densities of residential development within the coastal zone. Those coastal policies related to residential development within the coastal zone include the following:

• + The maintenance of building mass in coastal zone residential neighborhoods consistent with overall coastal policies;

• + The maintenance of residential building bulk control through the implementation of development standards;

• + The maintenance of residential structure height limits within the coastal zone; and,

• + The beach areas must be preserved for public beach recreation, and no permanent structures, with the exception of bikeways, walkways, and restrooms, will be permitted on the beach.

• Article 10.7 of the State Government Code (Section 65590, et. al.) establishes special requirements for the replacement of low or moderate income dwelling units that are converted to non-residential uses or demolished, and provision of low and moderate income housing in conjunction with new development within the State Coastal Zone . The majority of Hermosa Beach located west of Valley Drive is located in the Coastal Zone.

State Code Section 65590 (b) requires that:

• "The conversion or demolition of existing residential units occupied by persons and families of low or moderate income, as defined in Section 50093 of the Health and Safety Code, shall not be authorized unless provision has been made for the replacement of those dwelling units with units for persons and families of low or moderate income. Replacement dwelling units shall be located within the same City or County as the dwelling units proposed to be converted or demolished." (Provisional language within this code Section specifies certain types of low or moderate-income residential demolitions/conversions that are exempt from this requirement.)

State Code Section 65590 (d) requires the following:

• "New housing developments constructed within the Coastal Zone shall, where feasible, provide housing units for persons and families of low or moderate income, as defined in Section 50093 of the Health and Safety Code. Where it is not feasible to provide these housing units in a proposed new housing development, the local government shall require the developer to provide such housing, if feasible to do so, at another location within the same City or County, either within the Coastal Zone or within three miles thereof. In order to assist in providing new housing units, each local government shall offer density bonuses or other incentives, including, but not limited to, modification of zoning and subdivision requirements, accelerated processing of required applications, and the waiver of appropriate fees."

• A third option to the preceding State requirements is to establish an affordable in-lieu housing fee, which is used to facilitate development of affordable housing in the City. An in-lieu housing fee is required if the developer demonstrates, to the satisfaction of the City, that affordable housing is not feasible either on or off site, after taking account economic, environmental social and technical factors, as stipulated in the State Code.

F. Public Participation

Comment F-1

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 (Section 65583(c)).

• We note that City’s public outreach included the solicitation of comments from thirteen public service agencies and housing providers. We also note that additional public hearings are scheduled subsequent to HCD’s review. We commend the City for its efforts.

However, the element should also describe how these or other groups represented all economic segments of the community, including lower-income households and how the process encouraged and incorporated the participation of these groups.

City Response F-1

1.5 Public Participation

• This Housing Element is an update of the City’s early Housing Element adopted in 1990. Throughout the course of the Element’s preparation, the City made a diligent effort to involve the public in the review of the existing Element and the proposed changes. A total of three noticed public hearings were held prior to the circulation of the Housing Element for public review. The efforts in informing and involving the public are described in the following:

• + The City conducted the noticed workshops/study sessions before the City of Hermosa Beach Planning Commission as part of the Housing Element update.

• + The first noticed workshop, City of Hermosa Beach Planning Commission reviewed the Draft Housing Element’s policies and programs. At the second noticed workshop, the Commission considered the version of the draft Housing Element containing the revised policies and programs. A notice was prepared and posted in the paper inviting all interested persons to attend the workshops.

• Prior to the first submittal to the State Department of Housing and Community Development (HCD), staff prepared a notice inviting the public and a number of housing and service providers, and others who requested CDBG funds this year, to attend the noticed public hearing before the City Council. To discuss issues germane to housing, including the provision of affordable housing in the City. These workshops and public hearings were not attended by interested parties.
• After receiving comments from HCD, staff prepared a mailing notice announcing the City will be hosting a workshop to gather comment information for the Housing Element update. The mailing notice was sent to a number of housing and service providers listed below.

• + At noticed public hearing before the City Council, the focus of the deliberations was the revised policies and new housing programs. At this City Council meeting, the Council did direct staff to make some revisions prior to the Element’s submittal to the State Department of Housing and Community Development (HCD). Public service agencies and housing providers were also contacted regarding the Housing Element update and the public meetings.

• The following public service agencies and housing providers were contacted to participate in the preparation of the draft Housing Element:
  • + Center for the Pacific-Asian Family, Los Angeles;
  • + Rainbow Services, San Pedro;
  • + South Bay Children’s Health Center, Torrance;
  • + Family Child Care Network - South Bay, Hermosa Beach;
  • + INFO Line of Los Angeles, El Monte;
  • + South Bay Center for Counseling, El Segundo;
  • + South Bay Senior Services, Torrance;
  • + South Bay Korean-American Senior Center, Gardena;
  • + California Water Service, Redondo Beach;
  • + Hermosa Beach Valley School, Hermosa Beach;
  • + Beach Cities Health District, Redondo Beach;
  • + Project Touch, Hermosa Beach; and,
  • + South Bay Association of Realtors, Torrance.

• Additional scheduled public hearings will be conducted following the receipt of HCD’s comments. These public hearings will provide the public additional opportunities to review the Element and the programs it contains.

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