HomeMy WebLinkAboutPublic Hearing - Code Amendment 93-2 - ND 91-32 - Affordable U30CITY OF HUNTINGTON BEACH
Lo" INTER DEPARTMENT COMMUNICATION
HUNTINGTON BEACH
TO Howard Zelefsky, Planning Director
FROM Connie Brockway, City Clerk (I'D
SUBJECT LEGAL NOTICE FOR PUBLIC HEARING ON ITEM D-1 (2-7-94
AGENDA) AFFORDABLE HOUSING
DATE February 8, 1994
Please provide the City Clerks office with a legal notice when your office decides on the
date to hold the public hearing on this item
Thank you for your cooperation
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Page 3 CounciYAgency Agenda 2/7/94
C-1 COUNCIL COMMITTEE/COUNCIL LIAISON REPORTS 5- 0
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D PUBLIC HEARINGS
Anyone wishing to speak on an OPEN public hearing item is requested to
complete the attached pink form and give it to the Sergeant at Arms who is
located near the Speakers Podium
PUBLIC HEARINGS SHALL BE CONSIDERED IN THE FOLLOWING ORDER
1 Closed public hearings with decision continued to this date
2 Public hearings continued open
3 New public hearings
-77WI t ./v -r,*Iee 11-3 ou* o OMQ -Afo+1oA catini-e o
D-1 (City Council) CLOSED PUBLIC HEARING - CODE AMENDMENT 93-2 - NEGATIVE
DECLARATION 91-32 - AFFORDABLE HOUSING - INTRODUCTION OF ORDINANCE
NO 3214 - DECISION CONTINUED FROM 11-15 93 (430 50)
Staff report prepared by Community Development
Public hearing closed on 10/4/93
APPLICATION NUMBER Code Amendment No 93 2/Negative Declaration
No 91-32
APPLICANT City of Huntington Beach Dept of Community Development
LOCATION City-wide
REQUEST To amend the City s Zoning code to include provisions for affordable
housing which require all projects of three (3) units or greater to address affordable
housing The ordinance also provides incentives for providing affordable housing
ENVIRONMENTAL STATUS, This request is covered by Negative Declaration
No 91-32 which will also be considered by Council
RECOMMENDED ACTION Continue Code Amendment No 93-2 and
Negative Declaration No 91-32 and re advertise prior to setting a new public
hearing
/��`co nyrn�-n�/�D �o� ,�}QvP�o v£I� /►
(3)
REQUEST FOR CITY COUNCIL ACTION
Date February 7, 1994
Submitted to Honorable Mayor and City Council Members
Submitted by Michael T Uberuaga, City Administrato f
Prepared by Howard Zelefsky, Planning Directo z
v�
Subject CODE AMENDMENT NO 93 2/NEGATIVE DECLARATION
NO 91-32 AFFORDABLE HOUSING ORDINANCE
` A) ;l q/GI y p6cowwl eodp-b 4c;�'ovi Woo uOb — -io Rtv—
Consistent with Council Policy [X] Yes [ ] New Policy or Exception M I VO&
Statement of Issue, Recommendation, Analysis, Funding Source, Alternative Actions, Attachments
4041
STATEMENT OF ISSUE
On November 15, 1993, the City Council continued action on the draft Affordable
Housing Ordinance for further study The staff is recommending that the City Council
continue the Affordable Housing Ordinance in order to allow staff additional time to refine
the data needed to respond to the City Council concerns The staff will re advertise this
item for public hearing prior to setting a specific date
RECOMMENDATION
Motion to
"Continue code Amendment No 93 2 and Negative Declaration No 91 32 and re-
advertise prior to setting a new public hearing "
MTU HZ kjl
(k1046)
REQUEST FOR CITY COUNCIL ACTION
Date November 15, 1993
Submitted to Honorable Mayor and City Council Members
Submitted by Michael T Uberuaga, City Admmis o
Prepared by Howard Zelefsky, Planning Director
Subject CODE AMENDMENT NO 93 2/NEGATIVE DECLARATION
NO 91 32 AFFORDABLE HOUSING ORDINANCE
Consistent with Council Policy) P4 Yes [ ] New Policy or Exception
Statement of Issue, Recommendation, Analysis, Funding Source, Alternative Actions, Attachments
STATEMENT OF ISSUE
On October 4, 1993, the City Council opened the public hearing on Code Amendment
No 93 2 and continued action until November 15, 1993, in order for staff to provide
additional information to the Council The staff is currently researching several issues and
will return with an updated report
w
RECOMMENDATION
Motion to f
"Continue Negative Declaration No 91 32 and Code Amendment No 93 2 to the
February 7, 1994, City Council meeting "
ANALYSIS
Not applicable
Vo
FUNDING SOURCE
Not applicable rn
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O r z c
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MTU HZ kll �-
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(k1024)
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Kirkland & Associates
Aik a real estate brokerage
Kirk Kirkland
Broker/Owner
November 10, 1993
Councilman Ralph Bauer
City of Huntington Beach
2000 Main St
Huntington Beach, CA 92648
Dear Councilman Bauer
On November 15 you will be asked to approve two items of affordable housing 313 11th
St , a proposed redevelopment project that is lender owned and in desperate need of
rehabilitation and 17372 Keelson Lane in the Oakview district as part of the H O M E pro-
gram I urge your support and approval of these two proposals
Both projects will ultimately be under the management and control of the Community
Housing Corporation, a non-profit provider of low income rental housing with an absolutely
outstanding track record as low income housing provider I have personally had a chance
to visit most of their properties and they would be an asset to any community They
successfully operate an eight unit apartment building across the street from Ensign High
School in Newport Beach that blends perfectly with its more affluent neighbors They have
been a major factor in the turn-around of the once infamous Buena Clinton neighborhood
in Garden Grove
Both properties have been "low income" housing--not by design but by usage 313 11th was
a "skin head" center with, as you might guess, the attendant societal and law enforcement
problems that type of tenant brings The units on Keelson Lane have been low income
because that is the nature of the area and affordability is achieved through overcrowding
with the resultant downgrading of the quality of life in the area The Community Housing
Corporation has demonstrated that they can successfully manage these types of properties
while providing clean and affordable housing It takes your help to make it happen
Thus far $4 7 million has been invested in the Oakview district to make it a more desirable
neighborhood Your support of the Keelson Lane project will further enhance the area and
buttress the city's efforts to upgrade this neighborhood
Sincerely yours,
Kirk Kirkland, GRI 9
\1 351 Beach Blvd Suite A Huntington Beach California 92648 ❑ (714) 536 6600 ❑ Auto(714) 745-0633 ❑ Fax(714)842 3530
PROOF OF PUBLICATION
STATE OF CALIFORNIA)
) ss
County of Orange )
am a Citizen of the United States and a
resident of the County aforesaid, I am
over the age of eighteen years, and not a
party to or interested in the below If PUBLIC NOTICE- 1
ENVIRONMENTAL STA
entitled matter I am aprincipal clerk of NOTICE OF TUS This request covered
by Negative Declaration
the HUNTINGTON BEACH INDEPENDENT a CODE ME DME T No 9132 which will also
NO 93 2 be considered by Council
newspaper of general circulation printed proposed
FILE A copy of the
b � NEGATIVE proposed request is on file
DECLARATION NO in the City Clerk s Office
and published in the City of Huntington 9132(To amend 2000 Main Street Hun
CityBeach, County of Orange, State of ode to includoninge
9264tington Beach California
by
Code to Include 92648 for inspection by
affordable housin the public A copy of the
California and that attached Notice is a NOTICE IS HEREBY staff report will be available
GIVEN that the Huntington to interested parties at City
true and complete copy as was printed g Hall or the Main cv
Beach City Council will brary (7111 Talbert Avenue
hold a public hearing in the after September 27 1993
and published in the Huntington Beach Council Chamber at the ALL INTERESTED PER
Huntington Beach Civic SONS are invited to attend
and Fountain Valle issues of said I Center 2000 Main Street said hearing and express
y Huntington Beach Califor opinions or submit evi
newspaper to wit the issue(s) of nia on the date and at the dence for or against the
time indicated below to re application as outlined
ceive and consider the above Written communica
statements of all persons tions may also be sent to
who wish to be heard rely the City Clerk If you chat
tive to the application de( lenge the City Councils ac
scribed below DATE/TIME Monday Oc lim Ilion in court you may bel
ited to raising only those
tober 4 1993 7 00 PM issues you or someone
APPLICATION NUMBER else raised at the public
September 23, 1993 Code Amendment No 93 hearing described in thisl
2/Negative Declaration No notice or in written cor
9132 respondence delivered to
APPLICANT City of Hun the City at or prior to the
tington Beach Department public hearing If there arei
Of Community Develop any further questions)
declare, under penalty of perjury, that ment please call Howard Zelef
LOCATION City wide sky Planning Director at
the foregoing is true and correct ZONE All Residential 536-5271
Zones REQUEST To amend the Connie Brockway
City s Zoning Code to in City Clerk Huntington,
clude provisions for afford Beach City Council
Executed on able housing which require 2000 Main Street Hun
September 23 199�— all projects of three (3)I tington Beach CA
units or greater to address 92648(714)536 5227
at Costa Mesa California affordable housing The Or Published Huntington
1 dinance also provides in Beach Fountain Valley In
centives for providing of fordable housing dependent September 23
— 1993
094 168
Signa ure
REQUEST FOR CITY COUNCIL ACTION
Date October 4 . 1993
Submitted to Honorable Mayor and City Council Members
Submitted by Michael T Uberuaga, City Administrat �,/Zlt,--
Prepared by Howard Zelefsky, Planning Director k
Subject CODE AMENDMENT NO 93-2/NEGATIVE DECLARATION NO 91-32
AFFORDABLE HOUSING ORDINANCE
io/V/9,f_ .4 00 tt3.2
Consistent with Council Policy? Yes [ ] New Policy or Exception
Statement of Issue Recommendation Analysis Fundinq Source Alternative Actions Attachments
STATEMENT OF ISSUE
Transmitted for City Council adoption is Code Amendment No 93-2 and
Negative Declaration No 91-32 , City' s Affordable Housing
Ordinance The Planning Commission approved the ordinance as
recommended by the Housing Task Force Ordinance on August 24 , 1993
RECOMMENDATION
Motion to
Approve Negative Declaration No 91-32 and Code Amendment No 93-2
as recommended by the Planning Commission
Planning Commission Recommendation
A MOTION WAS MADE BY GORMAN, SECOND BY RICHARDSON, TO APPROVE
NEGATIVE DECLARATION NO 92-31, BY THE FOLLOWING VOTE
AYES Cook, Bourguignon, Richardson, Dettloff, Gorman, Inglee
NOES None
ABSENT Biddle
ABSTAIN None
MOTION PASSED
A MOTION WAS MADE BY GORMAN, SECOND BY DETTLOFF,
AMENDMENT NO 93-2, AND FORWARD TO CITY COUNCIL Wi
RECOMMENDATION FOR ADOPTION, BY THE FOLLOWING VOTE
AYES Cook, Bourguignon, Richardson, Dettloff,
NOES None
ABSENT Biddle
ABSTAIN None
r h
MOTION PASSED
��
D —
No 5/85
ANALYSIS
On September 16, 1991, the City Council formed the Affordable
Housing Task Force The Task Force was comprised of a cross section
of the community which included City officials, the Board of
Realtors, Chamber of Commerce and housing advocates The Task Force
was given the charge of exploring the various aspects of affordable
housing and to recommend an affordable housing strategy to implement
the City' s adopted Housing Element
The Affordable Housing Task Force reached four (4) major conclusions
1 There is a city-wide need to provide affordable housing
2 There is a direct relationship between the City s long term
economic stability and the quality and affordability of its
housing stock
3 All future development has an obligation to address affordable
housing (residential, commercial and industrial)
4 The City and development community need to work cooperatively on
achieving a greater number of affordable units
The four (4) conclusions have been embodied in the Task Force s
recommended Affordable Housing Ordinance The Ordinance has several
key components which are highlighted below for the Council ' s
convenience
1 All residential projects of three (3) or more units need to
address affordable housing in one (1) of the following ways
a A minimum of ten (10) percent of all the units included in
the project shall be made available to very low, low and
moderate-income households based on the Orange County Median
Income as defined by the Department of Housing Urban
Development
b Developers of residential projects may elect to pay a fee of
$1 00 per square foot in lieu of providing the units on-site
to fulfill the requirement of the Section, unless they are
part of a specific plan project
c Developers of residential projects may elect to provide the
affordable units at an off-site location unless they are part
of a specific plan project
RCA - 10/4/93 -2- (7363d)
The Affordable Housing Task Force met to review the draft Ordinance
prior to its public distribution Prior to the last Planning
commission meeting on the matter, the Task Force met again to review
the Ordinance The Task Force agreed that with modifications the
Ordinance reflected their conclusions However, they did not reach
consensus on four (4) minor issues
1 Should the money collected through the in-lieu fee program only
be used for low and very low housing?
2 Should the payment of the in-lieu fee be paid prior to issuance
of building permit or certificate of occupancy?
3 Should the modified development standards proposed as incentives
for affordable housing be used for all developments?
4 Should the City establish a waiting list for affordable units?
Of these four (4) issues, the staff recommends that the Commission
accept the Ordinance as drafted The staff does, however, differ
with the Committee on one issue We believe that the in-lieu fee
should only be an option for pro3ects less than one (1) acre in size
or when a single family development is proposed The most efficient
means of providing affordable housing is to have the development
community build it The City s expertise in financing affordable
Housing pro]ects is limited
FUNDING SOURCE
Not applicable
ALTERNATIVE ACTION
The City Council may continue action on Code Amendment No 93-2 and
Negative Declaration No 91-32 until November 1, 1993
ATTACHMENTS
1 Draft Affordable Housing Ordinance
2 Negative Declaration No 91-32
MTU HZ k] l
RCA - 10/4/93 -3- (7363d)
ORDINANCE NO
AN ORDINANCE OF THE CITY COUNCIL OF THE
CITY OF HUNTINGTON BEACH
AMENDING THE HUNTINGTON BEACH ORDINANCE CODE
BY ADDING NEW ARTICLE 966 THERETO ENTITLED
"AFFORDABLE HOUSING"
WHEREAS, the City Council of the City of Huntington Beach does hereby ordain as
follows
SECTION 1 That the Huntington Beach Ordinance Code is hereby amended by adding
new Article 966 thereto, entitled "Affordable Housing," to read as follows
Article 966
Affordable Housing
Sections
9660 Purpose
9660 1 Applicability
9660 2 Fees in Lieu of Construction
9660 3 Off-site Construction of Affordable Units
9660 4 Incentives for Providing Affordable Housing
9660 5 Miscellaneous Provisions
9660 6 Sale of Affordable Units
9660 Purpose
(a) The purpose and intent of this Chapter is to implement the goals, objectives and policies
of the City's Housing Element It is intended to encourage low- and moderate-income
housing, and housing for older residents which is integrated, compatible with and
complements adjacent uses, and is located in close proximity to public and commercial
services
(b) The affordable housing program is one tool the City utilizes to meet its commitment to
provide housing affordable to all economic sectors and to meet its regional fair-share
requirements for construction and rehabilitation of housing affordable to low- and
moderate income households
9660 1 Applicability This chapter shall apply to all residential projects three (3) or more units
in size A developer shall have the option of addressing the affordable housing requirements in
one of the following ways
1
4\Ord\09/22/93
(a) A minimum of ten (10) percent of all the units included in the project shall be made
available to very low, low(rental projects) and moderate-income households based on the
Orange County Median Income as defined by the Department of Housing Urban
Development
(b) Developers of residential projects may elect to pay a fee in lieu of providing the units on-
site to fulfill the requirement of the Section, unless the affordable housing requirement is
called out as part of a specific plan project
(c) Developers of residential projects may elect to provide the affordable units at an off-site
location unless otherwise outlined as part of a specific plan project
9660 2 Fees in Lieu of Construction
(a) Fees paid to fulfill the requirements of this article shall be placed in the City's Affordable
Housing Trust Fund, the use of which is governed by Section 9660 5(f)
(b) The amount of the fees shall be calculated using the fee schedule established annually by
resolution of the City Council
(c) One hundred (100) percent of the fees required by this Section shall be paid prior to
issuance of a building permit
(d) Fees paid as a result of new residential projects shall be based upon the total number and
size of the residential units which are to be constructed
(e) Common interest developments created through the conversion of existing residential
housing shall either make available ten (10)percent of all the units in the project to low-
and moderate-income households, or pay an in-lieu fee as calculated in
Section 9660 2(b)
9660 3 Off-Site Construction of Affordable Units Developers of residential projects of three
(3) or more units may provide the required affordable housing off-site, at one or several sites
Application materials for the off-site project shall be filed concurrently with application materials
for the primary project The Commission shall review the off-site affordable units and
affirmatively find that
(a) The number of units provided off-site is equal to or greater than the number required on-
site
(b) Off-site projects may be new construction or rehabilitation of existing non-restricted units
conditioned upon being restricted to long-term affordability "At Risk" units identified in
the Housing Element or mobile homes may be used to satisfy this requirement
2
4\Ord\09/22/93
(c) All affordable off-site housing shall be constructed or rehabilitated prior to or
concurrently with the primary project and final approval of the project shall be contingent
on completion and final approval of the affordable units
9660 4 Incentives for Providing Affordable Housing The incentives contained in this section
are designed to encourage new affordable housing projects that are not subject to Huntington
Beach Ordinance Code Section 9637 et seq, relating density bonus and other incentives In order
to encourage the construction of housing affordable to low- and moderate-income households
and in order to encourage new construction of affordable housing, various density bonuses shall
be permitted They shall take into account the underlying zoning, the need for specialized types
of housing and the particular operating needs of non profit housing providers It is the intent of
these provisions to provide maximum design flexibility while still maintaining high quality
design standards in exchange for affordable housing
(a) No density bonus may be used in conjunction with a project paying a fee in lieu of
providing affordable units No density bonus may be used with or added to another
density bonus
1 The Planning Commission may grant, with appropriate findings, a density
increase of at least twenty-five (25) percent above the maximum density allowed
by the underlying zoning if the project complies with Section 9637 et seq of the
Huntington Beach Ordinance Code, relating to density bonus and other incentives
(b) The Planning Commission may grant a density bonus equal to fourteen (14) more units
per acre than that allowed by the underlying zoning, in R2 and R3 zoning districts,
provided the project complies with all of the following criteria
1 The project's exterior elevations are designed to be compatible with and
complement the scale and character of the adjoining lands uses,
2 The project is restricted to the maximum height allowed by the underlying zoning,
3 Any traffic impact directly attributable to the density bonus is mitigated, and
4 All of the bonus units are permanently dedicated to low- and moderate-income
persons and/or older residents as defined by the Government Code
(c) The Planning Commission may grant a density bonus equal to fifty (50) percent of the
maximum amount allowed density in R3 and R4 zoning districts if fifty (50) percent of
all of the units in the project are permanently dedicated to low- and moderate-income
persons or a bonus equal to 100 percent of all of the units in the R3 or R4 zoning districts
if 100 percent of all of the units in the project are permanently dedicated to low- and
moderate-income persons if the project complies with the following criteria
3
4\Ord\09/22/93
I The project's exterior elevations shall be designed to be compatible with and
complement the scale and character of the adjoining land uses
(d) Residential projects that offer 50% of the units to persons and households earning
between 80% - 100% of the Orange County Median Income as defined by HUD for a
period of 30 years may be eligible for a reduction in development standards as follows
1 Site coverage seventy-five (75) percent,
2 Common open space maximum seventy (70) percent reduction if replaced
by private open space (roof decks may be used to satisfy a portion of this
requirement)
3 Minimum unit size studio - 300 square feet
one (1) bedroom - 450 square feet
two (2) bedroom- 800 square feet
4 Density A floor area ratio of 1 0 may be substituted for units per acre
9660 5 Miscellaneous Provisions
(a) The conditions of approval for any project which requires affordable units shall specify
the following items
1 The density bonus being provided
2 The number of affordable units,
3 The number of units at each applicable sales price or rent level as related to
Orange County Median Income and
4 A list of any other incentives offered by the City
(b) An Atfordable Housing Agreement shall be executed between the applicant and the City
prior to issuance of building permits outlining all aspects of the affordable housing
provisions
1 Prior to issuance of building permits in a project requiring an in-lieu fee, the
applicant shall execute and record an Agreement to pay an Affordable Housing
In-Lieu Fee
4
4\Ord\09/2')/93
(c) All affordable on-site units in a project shall be constructed concurrently with or prior to
the construction of the market rate units unless otherwise approved by the Planning
Commission through a phasing plan
(d) All affordable units shall be reasonably dispersed throughout the project unless otherwise
designed through a master plan, shall contain on average the same number of bedrooms
as the market rate units in the project, and shall be comparable with the market rate units
in terms of exterior appearance, materials and finished quality
(e) In the event a phased project is approved by the City, required affordable units shall be
provided equally within each phasing
(f) Affordable Housing Trust Funds shall be used primarily for projects which have a
minimum of fifty (50)percent of the dwelling units affordable to low- and moderate-
income households with at least twenty (20)percent of the units available to low-income
households All units which obtain Affordable Housing Trust Funds shall maintain the
affordability of the units for a minimum of 30 years The funds may, at the discretion of
the City Council, be used for pre development costs, land or air rights acquisition,
rehabilitation, land write downs, administrative costs gap financing, or to lower the
interest rate of construction loans or permanent financing
(g) In a project which includes market rate units Affordable Housing Trust Fund monies
shall only be provided to assist in the acquisition and construction of those units
affordable to low- and moderate income households Units which have received City
financial subsidy or other incentive of equal financial value may not be used as credit to
satisfy other affordable housing obligations
(h) New affordable units shall be occupied in the following manner
1 If residential rental units are being demolished and the existing tenant(s) meets the
eligibility requirements, he/she shall be given the right of first refusal to occupy
the affordable unit(s) or
2 If there are no qualified tenants, or if the qualified tenant(s) chooses not to
exercise the right of first refusal, or if no demolition of residential rental units
occurs, then qualified households or buyers will be selected from the City's
affordable housing waiting list
9660 6 Sale of Affordable Units Affordable units shall be sold at prices affordable to low- or
moderate-income households at a price that will result in the total annual debt service (including
taxes, utilities association dues) shall not exceed the standard established by HUD for the
County of Orange Affordable units must first be offered to eligible buyers "Lower income"
affordable units shall be rented at a price that is affordable to a household whose income is sixty-
five (65) percent of median income
5
4\Ord\09/22/93
SECTION 2 That this ordinance shall become effective 30 days after its adoption
PASSED AND ADOPTED by the City Council of the City of Huntington
Beach at a regular meeting thereof held on the day of ,
1993
Mayor
ATTEST APPROVED AS TO FORM
City Clerk rty ttorney
REVIEWED AND APPROVED INITIATED AND APPROVED
Ir e2a.,2 aA4�
City Administrator Direct d{of Community
Development
J
6
4\Ord\09/22/93
AT &4 CITY OF HUNTINGTON 13EACH
INTER DEPARTMENT COMMUNICATION
HUNTINGTON BEACH
TO File
FROM Susan Pierce
Associate Plr n r
SUBJECT ENVIRONMENTAL ASSESSMENT FORM NO 91-32
DATE March 1, 1993
Applicant City of Huntington Beach
Request Adoption of the City of Huntington Beach Zoning and
Subdivision Ordinance Code Update and Revision
Location City-Wide
Background
The Environmental Assessment Committee reviewed the environmental
assessment form noted above on September 25, 1991 and determined
that a negative declaration may be filed for the pro]ect In view
of this , a draft negative declaration was prepared and was published
in the Daily Pilot for a thirty (30) day public review period
commencing October 1, 1991 and ending October 30 , 1991 All written
comments regarding the draft negative declaration are contained in
the EA 91-32 file
The Draft Negative Declaration was never acted on, as the revised
Zoning and Subdivision Ordinance Code continued to be reviewed and
amended by staff As a result, a revised draft negative declaration
was prepared and published in the Huntington Beach Independent for a
thirty (30) day public comment period commencing Thursday, March 4 ,
1993 and ending Monday, April 5 , 1993 Copies of the revised draft
negative declaration were directly distributed to all parties which
commented on the original document, as well as to the State
Clearinghouse
Recommendation
The Environmental Assessment Committee recommends that the Planning
Commission approve Negative Declaration No 91-32 finding that the
proposed pro]ect will not have a significant adverse effect on the
environment
SP JO 1p
( 6069d)
EA yi 3�-
ATTACHMENT NO
a
LEGAL ADVERTISEMENT
DEPARTMENT OF COMMUNITY DEVELOPMENT
PLANNING DIVISION
CITY OF HUNTINGTON BEACH
Notice is hereby given by the Department of Community Development,
Planning Division of the City of Huntington Beach that the following
Draft Negative Declaration request has been prepared and will be
submitted to the City of Huntington Beach Planning Commission for
their consideration The Draft Negative Declaration will be
available for public review and comment for thirty (30) days
commencing Thursday, March 4 , 1993
Draft Negative Declaration No 91-32 analyzes the potential
environmental impacts associated with adoption of the City of
Huntington Beach Zoning and Subdivision Ordinance Code Update and
Revision
A copy of the request is on file with the Department of Community
Development, City of Huntington Beach, 2000 Main Street, Huntington
Beach, California Any person wishing to comment on the request may
do so in writing within thirty (30) days of this notice by providing
written comments to the Department of Community Development,
Planning Division, P 0 Box 190, Huntington Beach, CA 92648
( 6009d)
l + i 3 l-
Z
ENVIRONMENTAL CHECKLIST FORM
CITY OF HUNTINGTON BEACH
PLANNING DIVISION
ENVIRONMENTAL ASSESSMENT NO 91-32
1 Name of Proponent City of Huntington Beach
Address 2000 Main Street
Huntington Beach CA 92648
Phone Number (714) 536-5271
2 Date Checklist Submitted for Review September 25 1991 Revised
and Recirculated February 19
1993
3 Concurrent Entitlement(s) N/A
4 Protect Location Citywide
5 Protect Description Adoption of the City of Huntington Beach
Zoning and Subdivision Ordinance Code Update and Revision For
description and background on the proposed update and revision see
Attachment #1
ENVIRONMENTAL IMPACTS
(Explanations of answers are included after each subsection )
Yes Maybe No
1 Earth Will the proposal result in
a Unstable earth conditions or changes in geologic substructures? _ _ X
Discussion Because no site development is involved adoption of the proposed zoning and subdivision
ordinance code will not result in or create unstable earth conditions or result in changes to geologic
substructures
b Disruptions displacements compaction or overcovering of the so,17 _ X
Discussion Because no site development is involved adoption of the proposed zoning and subdivision
ordinance code will not result in any disruptions displacements compaction of overcovering of soil
FA3�-
5
1
f
Yes Maybe No
c Change in topography or ground surface relief features'
Discussion The proposed zoning and subdivision ordinance code revisions do not consist of any
development Therefore adoption of the document will not result in changes to topography or ground surface
relief features
d The destruction covering or modification of any unique geologic or physical features' _ _ X
Discussion Because no site development is involved in the proposed project no destruction covering or
modification of any unique geologic or physical features will occur
e Any increase in wind or water erosion of soils either on or off the sites _ _ X
Discussion No site development is involved in the proposed project which would alter soils through wind or
water erosion
f Changes -in deposition or erosion of beach sands or changes in siltation deposition
or erosion which may modify the channel of a river or stream or the bed of the ocean
or any bay inlet or lake' — — X
Discussion No changes will occur which would result ,n the deposition or erosion of beach sands or
changes in siltation deposition or erosion which may modify the channel of a river or stream or the bed of
the ocean or any inlet or lake
9 Exposure of people or property to geologic hazards such as earthquakes landslides
mudslides ground failure or similar hazards? _ _ _X
Discussion Adoption of the proposed zoning and subdivision ordinance code will not result in the exposurt
of people or property to geologic hazards such as earthquakes landslides mudslides ground failure or
similar hazards
*Note (a-g) Subsequent development under the provisions of the proposed zoning and subdivision ordinance
code may result in some earth impacts However impacts will be project/site specific Subsequent
development projects will be subject to the provisions of the California Environmental Quality Act (CEQA)
As such projects which have a potential to result in significant adverse environmental impacts will be
subject to environmental review to determine the nature and extent of potential impacts and any mitigation
if necessary to ensure adequate environmental protection
2 Air Will the proposal result in
a Substantial air emissions or deterioration of ambient air quality? _ _ X
Discuss-ion Adoption of the proposed zoning and subdivision ordinance code will allow for a change in
density requirements in the existing residential zones which may impact air emissions Under the proposed
zoning designation of RM RMH and RH residential areas will be developed at a slightly lower density
Townlot and Oldtown areas redesignated as RMH-A may be developed at a slightly higher density based on lot
area rather than lot frontage as allowed by current code
However it should be noted that the TLSP and OTSP areas are predominantly developed (approximately 961) and
currently contain approximately 5 200 residential units (based upon unit counts conducted in the spring of
1989) Projected development under the proposed RMH-A zoning assuming 1007' recycling of the developed
areas and buildout of the existing 47' of vacant land would allow for development of a total of
Environmental Checklist -2- �J(1827D)
6,
Yes Maybe No
approximately 6 500 residential units Development of this degree would be a worse case scenario and would
necessitate a resubdivision of the entire area as well as demolition of all structures many which are
single family dwelling recently constructed Due to the large degree of single family development existing
in the area increases in density resulting from development of infill lots under the proposed zoning code
is anticipated to be negligible Therefore any additional air emissions generated by the additional
density permitted under the proposed zoning code are anticipated to be negligible
Furthermore although subsequent development under the provisions of the proposed zoning and subdivision
ordinance code may result in some air quality impacts impacts will be project/site specific and will be
— subject to the provisions of the California Environmental Quality Act (CEQA) As such projects which have
a potential to result in significant adverse environmental impacts will be subject to environmental review
to determine the nature and extent of potential impacts and any mitigation if necessary to adequate
environmental protection
b The creation of objectionable odors _ _ X_
Discussion No site development is proposed as part of the project therefore adoption of the proposed
zoning and subdivision ordinance code will not result in the creation of objectionable odors However ,t
is possible that future development under the provisions of the proposed ordinance code may result in the
generation of odor impacts Such odor generation impacts will be project/site specific Subsequent
development projects will be subject to the entitlement process and subsequent environmental review to
determine the nature and extent of potential impacts if any and mitigation measures if necessary to
ensure adequate environmental protection
c Alteration of air movement moisture or temperature or any change in climate either
locally or regionally — _ X
Discussion Air movements will not be altered in addition no changes in moisture temperature and climate
(either locally or regionally) will occur if the proposed zoning and subdivision ordinance code is adopted
as proposed
3 Water Will the proposal result in
a Changes in currents or the course of direction of water movements in either marine or
fresh waters' X
Discussion Changes in currents or the course or direction of water movements will not occur if the
proposed zoning and subdivision ordinance code is adopted as no physical development is proposed which will
alter such features
b Changes in absorption rates drainage patterns or the rate and amount of surface runoff? _ _ X
Discussion No change in absorption rates drainage patterns or runoff will occur if the proposed zoning
and subdivision ordinance code is adopted since no physical development has been included
c Alterations to the course or flow of flood waters' X
Discussion No changes to the course or flow of flood waters will occur as the result of the adoption of
the proposed zoning and subdivision ordinance code The proposed code has altered provisions for
development within floodplain areas Floodplain development will be subject to higher standards and
construction requirements identified by the Federal Flood Insurance Program established by the Federal
Emergency Management Agency (FEMA) and recommended by the California Department of Water Resources
Environmental Checklist —3— (1827D)
7
Yes Mavbg No
d Change in the amount of surface water in any water body _ X
Discussion As no site development is involved no changes will occur in the anjount of surface water in a
water body
e Discharge into surface waters or in any alteration of surface water quality including
but not limited to temperature dissolved oxygen or turb,dity7 _ — X
Discussion No direct impacts to surface waters or surface water quality are anticipated to result if
proposed zoning and subdivision ordinance code is adopted
f Alteration of the direction or rate of flow of ground waters' _ _ X
Discussion The direction or rate of flow of ground waters will not be affected if the proposed zoning and
subdivision ordinance code is adopted as no physical development is included
9 Change in the quantity of ground waters either through direct additions or withdrawals
or through interception of an aquifer by cuts or excavations' — _ X
Discussion Although project adoption will not result in changes to the quant ty or quality of ground
waters future facilities which are constructed under the proposed zoning and subdivision ordinance code
could result in physical changes to the environment Future development projects will be subject to future
env ronmental review to determine the nature and extent of any potential impact and appropriate mitigation
measures
h Substantial reduction in the amount of water otherwise available for public water
supplies'
Discussion Adoption of the proposed zoning and subdivision ordinance code will allow for a change in
density requirements in the existing residential areas which may increase water usage Under the proposed
zoning designation of RM RMH and RH will be developed at a slightly lower density and TLSP-B and OTSP-2
areas redesignated as RMH-A may be developed at a slightly higher density based on lot area rather than
lot frontage as allowed by current code
However it should be noted that the TLSP and OTSP areas are predominantly developed (approximately 96%) and
currently contain approximately 5 200 residential units (based upon unit counts conducted in the spring of
1989) Projected development under the proposed RMH-A zoning assuming 1007' recycling and buildout of the
area would allow for development of approximately 6 500 residential units Development of this degree
would be a worse case scenario and would necessitate a resubdivision of the entire area as well as
demolition of all structures many which are single family dwelling recently constructed Due to the large
degree of single family development existing in the area increases in density resulting from development of
,nfill lots under the proposed zoning code is anticipated to be negligible Therefore any additional air
emissions generated by the additional density permitted under the proposed zoning code are anticipated to be
negligible
Subsequent development under the provisions of the proposed zoning and subdivision ordinance code may result
in some water usage impacts However impacts will be project/site specific Subsequent development
projects will be subject to the provisions of the California Environmental Quality Act (CEQA) As such
projects which have a potential to result in significant adverse environmental impacts will be subject to
environmental review to determine the nature and extent of potential impacts and any mitigation if
necessary to adequate environmental protection
Environmental Checklist -4- (1827D)
J
Yes Maybe No
I Exposure of people or property to water related hazards such as flooding or tidal waves? _ _ X
Discussion Adoption of the proposed zoning and subdivision ordinance code will not result in the exposure
of people or property to water—related hazards (e g flooding or tidal waves) See 3c
*Note (a-0 Subsequent development under the provisions of the proposed zoning and subdivision ordinance
rode may result in some water impacts However impacts will be project/site specific Subsequent
development projects will be subject to the provisions of the California Environmental Quality Act (CEQA)
As such projects which have a potential to result in significant adverse environmental impacts will be
subject to environmental review to determine the nature and extent of potential impacts and any mitigation
if necessary to ensure adequate environmental protection
4 Plant Life Will the proposal result in
a Change in the diversity of species or number of any species of plants (including trees
shrubs grass crops and aquatic plants)? _ _ X
Discussion Because no site development is involved neither changes in the diversity of species nor
deterioration of vegetation will occur with the adoption of the proposed zoning and subdivision ordinance
code
b Reduction of the numbers of any mature unique rare or endangered species of plants? _ _ X
Discussion Because no site development is involved reduction of the numbers of any unique or rare or
endangered species of plants will not occur if the project is approved
c Introduction of new species of plants into an area or in a barrier to the normal
replenishment of existing species' _ _ X
Discussion Because no site development is involved no new species of plant or barriers to replenishment
of existing plant species will result with the adoption of the proposed zoning and subdivision ordinance
code
d Reduction in acreage of an agricultural crop? X
Discussion Because no site development is involved a reduction in acreage of any agricultural crop will
not result from the adoption of the proposed zoning and subdivision ordinance code
*Note (a—d) Subsequent development under the provisions of the proposed zoning and subdivision ordinance
code may result in some plant impacts However impacts will be project/site specific Subsequent
development projects will be subject to the provisions of the California Environmental Quality Act (CEQA)
As such projects which have a potential to result in significant adverse environmental impacts will be
subject to environmental review to determine the nature and extent of potential impacts and any mitigation
if necessary to ensure adequate environmental protection
5 Animal Life Will the proposal result in
a Change in the diversity of species or numbers of any species of animals (birds land
animals including reptiles fish and shellfish benthic organisms or insects)? _ _ X
Discussion Since no site development is proposed neither changes in the diversity of species nor number
of any species of animals will occur with the adoption of the proposed zoning and subdivision ordinance code
Environmental Checklist —5— Fy /� S (1827D)
Yes Maybe No
b Reduction of the numbers of any unique rare or endangered species of animals' _ _ X
Discussion Since no site development is proposed reduction of the numbers of any unique or rare or
endangered species of animals will not occur with the adoption of the proposed zoning and subdivision
ordinance code
c Introduction of new species of animals into an area or result in a barrier to the
migration or movement of animals° _ _ X
Discussion Since no site development is proposed no new species of animals or barriers to migration of
existing animal species will result with the adoption of the proposed zoning and subdivision ordinance code
d Deterioration to existing fish or wildlife habitats _ _ X
Discussion Since no site development is proposed no deterioration to existing fish or wildlife habitat
will result from the adoption of the proposed zoning and subdivision ordinance code
*Note (a-d) Subsequent development under the provisions of the proposed zoning and subdivision ordinance
code may result in some animal impacts However impacts will be project/site specific Subsequent
development projects will be subject to the provisions of the California Environmental Quality Act (CEQA)
As such projects which have a potential to result in significant adverse environmental impacts will be
subject to environmental review to determine the nature and extent of potential impacts and any mitigation
if necessary to ensure adequate environmental protection
6 Noise Will the proposal result in
a Increases in existing noise levels — _X
Discussion Adoption of the proposed zoning and subdivision ordinance code will allow for a change in
density requirements in the existing residential zones which may result in an increase in noise generation
and impact noise levels Under the proposed zoning designation of RMH-A TLSP and OTSP areas may be
developed at a slightly higher density based on lot area rather than lot frontage as currently permitted
residential areas with the proposed zoning designation of RM RMH and RH will be developed at a slightly
lower density
However it should be noted that the TLSP and OTSP areas are predominantly developed (approximately 967) and
currently contain approximately 5 200 residential units (based upon unit counts conducted in the spring of
1989) Projected development under the proposed RMH-A zoning assuming 1007' recycling and buildout of the
area would allow for development of approximately 6 500 residential units Development of this degree
would be a worse case scenario and would necessitate a resubdivision of the entire area as well as
demolition of all structures many which are single family dwelling recently constructed Due to the large
degree of single family development existing in the area increases in density resulting from development of
infill lots under the proposed zoning code is anticipated to be negligible Therefore any additional air
emissions generated by the additional density permitted under the proposed zoning code are anticipated to be
negligible
Subsequent development under the provisions of the proposed zoning and subdivision ordinance code may result
,n some noise impacts However impacts will be project/site specific Subsequent development projects
will be subject to the provisions of the California Environmental Quality Act (CEQA) As such projects
which have a potential to result in significant adverse environmental impacts will be subject to
environmental review to determine the nature and extent of potential impacts and any mitigation if
necessary to adequate environmental protection
Environmental Checklist -6- (1827D)
/G�
Yes Maybe No
b Exposure of people to severe noise levels' _ _ X
Discussion See 6a
7 Light and Glare Will the proposal produce new light or glare' _ _ X
Discussion Because no site development is involved adoption of the proposed zoning and subdivision
ordinance code will not result in the exposure of people to new light or glare Subsequent development
under the provisions of the proposed zoning and subdivision ordinance code may result in some light and
glare impacts However impacts will be project/site specific Subsequent development projects will be
subject to the provisions of the California Environmental Quality Act (CEQA) As such projects which have
a potential to result in significant adverse environmental impacts will be subject to environmental review
to determine the nature and extent of potential impacts and any mitigation if necessary to adequate
envirormental protection
8 Land Use Will the proposal result in a substantial alteration of the present or planned
land use of an areal _ _ X
Discussion Adoption of the proposed zoning and subdivision ordinance code does not propose any substantial
changes to land uses allowed in the city however the revised code will allow for a change in density
requirements in the existing residential areas which may impact air emmissions Under the proposed zoning
designations of RM RMH and RH will be developed at a slightly lower density and TLSP and OTSP areas
redesignated as RMH—A will be developed at a slightly higher density based on lot area rather than lot
frontage as permitted under the existing code
However it should be noted that the TLSP and OTSP areas are predominantly developed (approximately 967) and
currently contain approximately 5 200 residential units (based upon unit counts conducted in the spring of
1989) Projected development under the proposed RMH—A zoning assuming 1007' recycling and buildout of the
area would allow for development of approximately 6 500 residential units Development of this degree
would be a worse case scenario and would necessitate a resubdivision of the entire area as well as
demolition of all structures many which are single family dwelling recently constructed Due to the large
degree of single family development existing in the area increases in density resulting from development of
inf,ll lots under the proposed zoning code is anticipated to be negligible Therefore any additional air
emissions generated by the additional density permitted under the proposed zoning code are anticipated to be
negligible
9 Natural Resources Will the proposal result in
a Increase in the rate of use of any natural resources' - _ X
b Substantial depletion of any non—renewable natural resource' _ _ X
Discussion The proposed zoning and subdivision ordinance code does not propose any alteration to
development standards which will result in any noticeable change in the use of non—renewable or natural
resources Furthermore since no site development is included adoption of the proposed zoning and
subdivision ordinance code will not result in an increase in the use of natural resources such as energy
water and raw materials
Environmental Checklist —7— (1827D)
Yes Maybe No
10 Risk of Upset Will the proposal involve
a A risk of an explosion or the release of hazardous substances (including but not
limited to oil pesticides chemicals or radiation) in the event of an accident or
upset conditions' — _ X
Discussion Since no site development is included adoption of the proposed zoning and subdivision
ordinance code will not result in any risk of explosion or release of hazardous substances in the event of
an accident or upset condition
b Possible interference with an emergency response plan or an emergency evacuation plan' _ X
Discu lion Because no development is included adoption of the proposed zoning and subdivision ordinance
code will not interfere with an emergency response plan or evacuation plan
*Note (a-b) Subsequent development under the provisions of the proposed zoning and subdivision ordinance
code may result in some risk of upset impacts However impacts will be project/site specific Subsequent
development projects will be subject to the provisions of the California Environmental Quality Act (CEQA)
As such projects which have a potential to result in significant adverse environmental impacts will be
subject to environmental review to determine the nature and extent of potential impacts and any mitigation
if necessary to ensure adequate environmental protection
11 Population Will the proposal alter the location distribution density or growth rate of
the human population of an area' _ X
Discussion The proposed ordinance code will allow for minor increases in density in areas currently
designated as the Townlot and Oldtown Districts however since these areas are primarily built out
location distribution density and growth rate of the human population are anticipated to be negligible
12 Housing Will the proposal affect existing housing or create a demand for additional housing' _ X
Discussion The adoption of the proposed zoning and subdivision ordinance code will not have an impact upon
the existing housing and will not result in creating a demand for additional housing
13 Transportation/Circulation Will the proposal result in
a Generation of substantial additional vehicular movement' X
Discussion Adoption of the proposed zoning and subdivision ordinance code will allow for a change in
density requirements ,n the existing residential areas which may result in an -increase in traffic Under
the proposed zoning designation of RMH-A TLSP and OTSP areas may be developed at a slightly higher density
based on lot area rather than lot frontage as allowed under the current zoning code RM RMH and RH will be
deveoped at a slightly lower density
However it should be noted that the TLSP and OTSP areas are predominantly developed (approximately 96%) and
currently contain approximately 5 200 residential units (based upon unit counts conducted in the spring of
1989) Projected development under the proposed RMH-A zoning assuming 1007' recycling and buildout of the
area would allow for development of approximately 6 500 residential units Development of this degree
would be a worse case scenario and would necessitate a resubdivision of the entire area as well as
demolition of all structures many which are single family dwelling recently constructed Due to the large
degree of single family development existing in the area increases in density resulting from development of
infill lots under the proposed zoning code is anticipated to be negligible Therefore any additional air
emissions generated by the additional density permitted under the proposed zoning code are anticipated to
negligible
Environmental Checklist -8- (18270)
/ Z
Yes Maybe No
b Effects on existing parking facilities or demand for new off—site parking, _ _ X
Discussion The proposed zoning and ordinance code does not include any amendments to the existing parking
ratios or parking design requirements Therefore no impacts to parking are anticipated
c Substantial impact upon existing transportation systems' _ _ X
Discussion Because no site development is proposed no impacts to the existing transportation facilities
are anticipated to result from adoption of the proposed zoning and subdivision ordinance
d Alterations to present patterns of circulation or movement of people and/or goods' _ _ X
Discussion Since no site development is included neither present patterns of circulation nor the movement
of people and/or goods will be affected if the proposed zoning and subdivision ordinance code is adopted
e Alterations to waterborne rail or air traffic' _ _ X
Discussion Since no site development is included no waterborne rail or air traffic will be affected by
adoption of the proposed zoning and subdivision ordinance code
f Increase in traffic hazards to motor vehicles bicyclists or pedestrians' _ _ X
Discussion Since no site development is included no hazards to motor vehicles bicyclists or pedestrian
will not occur if the proposed zoning and subdivision ordinance code is adopted
*Note (a—f) Subsequent development under the provisions of the proposed zoning and subdivision ordinance
code may result in some traffic/circulation impacts However impacts will be project/site specific
Subsequent development projects will be subject to the provisions of the California Environmental Quality
Act (CEQA) As such projects which have a potential to result in significant adverse environmental impacts
will be subject to environmental review to determine the nature and extent of potential impacts and any
mitigation if necessary to ensure adequate environmental protection
14 Public Services Will the proposal have an effect upon or result in a need for new or
altered governmental services in any of the following areas
a Fire protection' i _ X
Discussion Adoption of the proposed zoning and subdivision ordinance code will have no effect upon or
result in the need for new or altered fire protection services
b Police protection' _ X
Discussion Adoption of the proposed zoning and subdivision ordinance code will have no effect upon or
result in the need for new or altered police protection services
c Schools' X
Discussion No new school facilities will be required if the proposed zoning and subdivision ordinance code
is adopted
Environmental Checklist —9— (1827D)
�3
Yes Maybe No
d Parks or other recreational facilities' X
Discussion No new parks and recreation facilities will be required if the proposed zoning and subdivis,
ordinance code is adopted
e Maintenance of public facilities including roads' _ _ X
Discussion No impacts are anticipated upon the maintenance of public facilities or roads as a result of
the adoption of the proposed zoning and subdivision ordinance code
f Other governmental services' _ _ X
Discussion No impacts to other governmental facilities are anticipated as the result of the adoption of
the proposed zoning and subdivision ordinance code
*Note (a-f) Subsequent development under the provisions of the proposed zoning and subdivision ordinance
code may result in some public service impacts However impacts will be project/site specific Subsecuent
development projects will be subject to the provisions of the California Environmental Quality Act (CEQA)
As such projects which have a potential to result in significant adverse environmental impacts will be
subject to environmental review to determine the nature and extent of potential impacts and any mitigation
if necessary to ensure adequate environmental protection
15 Energy Will the proposal result in
a Use of substantial amounts of fuel or energy' X
Discussion No substantial increases in demand upon existing sources of energy or requirements for the
development of new sources of energy are anticipated as a result of the adoption of the proposed zoning a
subdivision ordinance code
b Substantial increase in demand upon existing source of energy or require the
development of sources of energy? _ _ X
Discussion Adoption of the proposed zoning and subdivision ordinance code will not result in the use of
abnormally high amounts of fuel or energy
*Note (a-b) Subsequent development under the provisions of the proposed zoning and subdivision ordinance
code may result in some energy impacts However impacts will be project/site specific Subsequent
development projects will be subject to the provisions of the California Environmental Quality Act (CEQA)
As such projects which have a potential to result in significant adverse environmental impacts will be
subject to environmental review to determine the nature and extent of potential impacts and any mitigation
if necessary to ensure adequate environmental protection
16 Utilities Will the proposal result in a need for new systems or substantial alterations
to the following utilities
a Power or natural gasp _ X
Discussion The adoption of the proposed zoning and subdivision ordinance code will not create the demand
for additional power (i a electricity) or natural gas
Environmertal Checklist -10- (1827D)
Yes Maybe No
b Communication systems? _ _ _ X
Discussion No new demand for conwnunication systems will be created if the proposed zoning and subdivision
ordinance code is adopted
c Water? X
Discussion No new demands for domestic water will be created if the proposed zoning and subdivision
ordinance code is adopted
d Sewer or septic tanks' _ _ X
Discussion No new demands for sewer facilities or septic tanks will be created if the proposed zoning and
subdivision ordinance code is adopted
e Storm water drainage' _ _ X
Discussion Adoption of the proposed zoning and subdivision ordinance code will not necessitate new storm
water drainage improvements
f Solid waste and disposal's _ _ X
Discussion No new demands for solid waste disposal facilities will be created if the proposed zoning and
subdivision ordinance code is adopted
*Note (a-f) Subsequent development under the provisions of the proposed zoning and subdivision ordinance
code may result in some utility impacts However impacts will be project/site specific Subsequent
development projects will be subject to the provisions of the California Environmental Quality Act (CEQA)
As such projects which have a potential to result in significant adverse environmental impacts will be
subject to environmental review to determine the nature and extent of potential impacts and any mitigation
if necessary to ensure adequate environmental protection
17 Human Health Will the proposal result in
a Creation of any health hazard or potential health hazard (excluding mental health)? _ _ X
Discussion The creation of potential health hazards physical or mental will not result from the adoption
of the proposed zoning and subdivision ordinance code
b Exposure of people to potential health hazards? _ _ X
Discussion Adoption of the proposed zoning and subdivision ordinance code will not result in the exposure
of people to potential health hazards
Note (a-b) Subsequent development under the provisions of the proposed zoning and subdivision ordinance
code may result in some human health impacts However impacts will be project/site specific Subsequent
development projects will be subject to the provisions of the California Environmental Quality Act (CEQA)
As such projects which have a potential to result in significant adverse environmental impacts will be
subject to environmental review to determine the nature and extent of potential impacts and any mitigation
if necessary to ensure adequate environmental protection
Environmental Checklist -11- (1827D)
Yes Maybe No
18 Aesthetics Will the proposal result in the obstruction of any scenic vista or view open to
the public or will the proposal result in the creation of an aesthetically offensive site
open to public view?
Discussion Future development under the provisions of the proposed zoning and subdivision ordinance code
may be located on sites which result in potential impacts to the aesthetic environment However development
of such facilities will be subject to the entitlement process and additional environmental review
Subsequent environmental documentation will fully analyze the potential impacts and identify appropriate
mitigation measures prior to adoption of the projects No significant averse aesthetic impacts are
— anticipated
19 Recreation Will the proposal result in an impact upon the quality or quantity of existing
recreational opportunities' _ _ X
Discussion The proposed zoning and subdivision ordinance code will not create any impact upon the quality
or quantity o' existing recreational opportunities
20 Cultural Resources
a Will the proposal result in the alteration of or the destruction of a prehistoric or
historic archaeological site' _ _ X
Discussion Because no site development is included no alteration or destruction of archaeological
prehistoric or historic sites will occur as a result of the proposed zoning and subdivision ordinance code
adoption
b Will the proposal result in adverse physical or aesthetic effects to a prehistoric
or historic building structure or object'
Discussion Because no site development is included no effects physical or aesthetic are anticipated to
occur as a result of adoption of the proposed zoning and subdivision ordinance code
c Does the proposal have the potential to cause a physical change which would affect
unique ethnic cultural values? _ _ X
Discussion Because no physical development is included no unique ethnic cultural values are anticipated
to be affected as the result of adoption of the proposed zoning and subdivision ordinance code
d Will the proposal restrict existing religious or sacred uses within the potential
impact areas _ _ X
Discussion No known existing religious or sacred uses will be impacted as a result of adoption of the
proposed zoning and subdivision ordinance code
*Note (a—d) Subsequent development under the provisions of the proposed zoning and subdivision ordinance
code may result in some impacts to archeological or cultural resources However impacts will be
project/site specific Subsequent development projects will be subject to the provisions of the California
Environmental Quality Act (CEQA) As such projects which have a potential to result in significant adverse
environmental impacts will be subject to environmental review to determine the nature and extent of
potential impacts and any mitigation if necessary to ensure adequate environmental protection
knvrronmental Checklist —12— (1827D)
T fl it 3
Yes Maybe No
21 Mandatory Findings of Significance
a Does the project have the potential to degrade the quality of the environment sub—
stdntially reduce the habitat of a fish or wildlife species cause a fish or wildlife
population to drop below self sustaining levels threaten to eliminate a plant or animal
community reduce the number or restrict the range of a rare or endangered plant or
animal or eliminate important examples of the major periods of California history or
prehistory' _ _ X
Discussion As presented in the environmental analysis the proposed zoning and subdivision ordinance code
does not consist of any development and will not have any impact on plant or animal species
b Does the project have the potential to achieve short—term to the disadvantage of
long—term environmental goals' (A short—term impact on the environment is one which
occurs in a relatively brief definitive period of time while long—term impacts will
endure well into the future ) _ _ X
Discussion As presented in the environmental analysis adoption of the proposed zoning and subdivision
ordinance code will allow for minor alterations to density requirements in the existing TLSP—A & B and OTSP
1 & 2 zones However over the long—term the new zoning code will effectively reduce the number of units
in the area No significant adverse impacts are anticipated
c Does the project have impacts which are individually limited but cumulatively consid—
erable' (A project may impact on two or more separate resources where the impact on
each resource is relatively small but where the effect of the total of those impacts
on the environment is significant ) _ _ X
Discussion Cumulative impacts associated with the proposed zoning and subdivision ordinance code are not
significant
d Does the project have environmental effects which will cause substantial adverse effects
on human beings either directly or indirectly' _ _ X
Discussion Provisions of revised code do not alter development standards ,n any way which will impact
animal/plant species No significant adverse effects are anticipated to occur to human beings either
directly or indirectly if the proposed zoning and subdivision ordinance code is adopted
Environmental Checklist —13— (1827D)
/! 3
/
DETERMINATION
On the basis of this initial evaluation
I find that the proposed project COULD NOT have a significant effect on the environment and a
NEGATIVE DECLARATION will be prepared
I find that although the proposed project could have a significant effect on the environment there
will not be a significant effect ,n this case because the mitigation measures described on an attached
sheet have been added to the project A NEGATIVE DECLARATION WILL
BE PREPARED
I find the proposed project MAY have a significant effect on the environment and an ENVIRONMENTAL
IMPACT REPORT is required
1
Date Signature
For City of Huntington Beach
Community Development Department
s
Fnvironmental Checklist —14— C f1 // �J (1827D)
�n
ATTACHMENT #1
Project Description
Huntington Beach Zoning and Subdivision
Ordinance Code Update and Revision
Department of Community Development
City of Huntington Beach, California
The City of Huntington Beach is proposing a comprehensive update and
revision to its Zoning and Subdivision Ordinance Code Since 1946,
when the Zoning Ordinance Code was originally adopted, a myriad of
amendments and section rewrites have occurred in a patchwork fashion
to respond the changing City objectives, State laws and court
cases As a result, contradictory provisions have developed making
the Ordinance difficult to implement and enforce In order to
resolve previous interpretation, application and enforcement
problems , the City has commissioned a comprehensive update and
revision of the Zoning and Subdivision Ordinance Codes
The proposed code revision simplifies the content of the Zoning
Ordinance Code by identifying and eliminating inconsistencies and
ambiguities, adding charts and diagrams, and reformatting the
information by utilizing various print fonts and styles The
proposed code revisions fall into one of ( 6) six categories These
six categories include Reorganization of Regulations,
Reorganization of Use Classifications, Renaming and/or Consolidation
of Base Zoning Districts and Overlay Districts, Streamlining of
Administrative Procedures, Updates to Subdivision Provisions to
bring the code into conformance with State law Each of these
changes have been summarized below
Reorganization of Regulations
The proposed Zoning Ordinance has been reorganized into six sections
for incorporation into the City of Huntington Beach Municipal Code
A brief description of each section is contained below
Title 20 General Provisions - establishes the overall
organization and applicability of the regulations and
includes Definitions and Use Classifications
Title 21 Base District - specifies the land uses
permitted or conditionally permitted in each residential,
commercial , industrial, public, and open-space zoning
district, and includes special requirements, if any, that
are applicable to specific uses Base-district regulations
also include development standards to control the height,
bulk, location and appearance of structures on development
sites and requirements for landscaping and parking
r
Title 22 Overlay District - modifies base-district
provisions for specific purposes, such as oil production,
flood protection, high-rise buildings, neighborhood
conservation, planned block development or the coastal zone
Title 23 Provisions Applying in All Districts -
includes supplemental site-development standards, parking
and loading requirements, signs, mobile home park
conversions, condominium conversions and nonconforming uses
and structures
Title 24 Administration - contains detailed procedures
for the administration of the zoning ordinance, including
requirements for design review, conditional use permits and
variances , development agreements, amendments to the
ordinance and zoning map, appeals of zoning decisions, and
enforcement
Title 25 Subdivision - contains procedures for
implementation of the Subdivision Map Act, including parcel
maps and subdivision maps, vesting tentative maps,
dedication and improvements , and administrative
requirements
Reorganization of Use Classifications
The proposed Zoning Ordinance utilizes use classification titles to
describe groups of similar uses rather than attempt to specifically
list all uses that might be permitted as-of-right or with a
conditional use permit, as is done in the existing code The
classification titles provide for administrative determination for
the most appropriate category for unlisted uses
Renaming/Consolidation of Base Zoning and Overlay Districts
The proposed zoning ordinance renames and/or consolidates the
existing 22 base zoning districts into the 13 base districts
identified in the attachment A
Streamlining of Administrative Procedures
The proposed zoning ordinance includes revised provisions for
administrating the zoning regulations The revisions are intended
to simplify and consolidate procedures for environmental review,
conditional use permits, variances, design review, appeals,
amendments and enforcement and consist of the following changes
Conditional Exceptions Provisions for the conditional
exception in the current ordinance have been replaced with
provisions for Variances This term is more familiar to
the public and development community
-2- (1835D)
7��
Zoning Permit New regulations are proposed for zoning
permits and preliminary plan review The zoning permit
would serve as a "check" for compliance with the zoning
regulations This is done in practice prior to issuance of
building permits , but it may be useful to identify a
separate procedure to avoid any loopholes, such as a new or
expanded use that does not require a building permit The
zoning permit could be called a ' zoning certificate to
convey the fact that it is a ministerial permit, not a
discretionary permit
Public Notice Requirements Notice requirements for public
hearings are simplified by reference to state law
References to the appropriate Government Code sections are
declatory of existing law Additional notice may be given
at the direction of the hearing body Procedure for
notices, hearings, decisions and appeals are combined into
one chapter
Coastal Development Permits Proposed regulations for
Coastal Development Permit procedures primarily follow
existing requirements Exemptions and categorical
exclusions have been reorganized and streamlined Policies
have been eliminated from Definitions section
Subdivisions
Changes have been made to the subdivision provisions to make conform
to state law and to facilitate administration
Statutory Time Limits The Planning Commission or Zoning
Administrator has 50 days from the time of the acceptance
of the tentative map to act on the tentative map If an
EIR is prepared, the decision is to be made 45 days after
certification of the EIR If there is a negative
declaration adopted or a determination that the project is
exempt from the requirements of Division 13 of the Public
13 of the Public Resources Code, the decision shall be made
50 days after said action
Maps Procedures applicable to tentative tract maps and
tentative parcel maps have been combined The Zoning
Administrator may act on Tentative Parcel Maps and
Tentative (tract) Maps with 9 or less parcels The
Planning Commission will review and act on maps creating 10
or more parcels Final Map and Parcel Map procedures
likewise have been combined The City Engineer is
authorized to give final approval for Parcel Maps, City
Council action will be required only for Final Maps
-3- ( 1835D) Fi91/
Dedications and Reservations The requirements for
dedication have been detailed Current parkland dedication
and in-lieu fee formulas are included as well as provisions
addressing local transit facilities, solar easements,
supplemental improvements, and collection of development
fees
Improvement Standards Adopting standard engineering
specifications and standard drawings separately rather than
including all specifications within the subdivision
ordinance is proposed The chapter identifies when, where
and what improvements are required as a pre-requisite for
final or parcel map approval
Mergers . Correction and Amendments of Maps A distinct
section on parcel mergers and unmergers has been included
Procedures include lot line adjustments and the recordation
of a covenant to Hold-as-One-Parcel '
Appeals Appeals would be processed under the general
provisions established in Chapter 248
FN %i 3
-4- (1835D)
2l
ATTACHMENT A
Proposed Proposed Existing Existing Proposed Major Proposed
Base Zoning & Base Zoning & District District Changes in Changes
Overlay District Overlay District Designations Names Development in
Designations Names Standards Density
Base Zoning
Districts
1 RL Low Density Residential R1 Low Density Residential Delete open space requirement None
reduce garage setback to 20 feet
2 RM Medium Density Residential R2 Med Density Residential Replace building separation w/court Reduction in
all multi—family same standards see density to
RMH & RH for additional changes bring zoning
density based on net lot area into confo mance
with General
Plan 1 unit per
2 904 sq ft
3 RMH Med—High Density Residential R3 Med—High Density Res Upperstory setback, change in Reduction in
review body Open space based on 25% density to
of floor area and RM items bring zoning into
conformance with
General Plan l
unit per 1 742
sq ft
T
yti
Ca+
N
i
Proposed Proposed Existing Existing Proposed Major Proposed
Base Zoning & Base Zoning & District District Changes in Changes
Overlay District Overlay District Designations Names Development in
Designations Names Standards Density
6 —PBD Planned Block Development N/A Newly established to allow large sites N/A
flexibility in development standarads
7 —H High Rise —MS Multi—Story Changes setback requirements includes N/A
upperstory setback when adjacent to
R district
8 —MHP Mobilehome —MH Mobilehome Overlay None N/A
r�
(18181
.r•
1
Proposed Proposed Existing Existing Proposed Major Proposed
Base Zoning & Base Zoning & District District Changes in Changes
Overlay District Overlay District Designations Names Development in
Designations Names Stardards Density
Overlays
1 —0 01 Oil Production —0 01 Oil District None N/A
2 —CZ Coastal Zone —CZ Coastal Zone Condensed removes site specific N/A
requirements
3 —FP1 —FP2 —FP3 Floodplain —FP1 —FP2 Floodplain Incorporates higher standards required N/A
—FP3 and/or recommended by CA Water Resources
Dept elevate or floodproof 1 ft above
base flood elevation
4 —IS Interim Study LU Limited Use District Proposed as overlay rather than N/A
base district application of
base zone will comply with
General Plan expires in 2 years
5 —NC Neighborhood Conservation N/A Newly established to allow property N/A
owners to initiate programs to
revitalize and conserve their
neighborhoods
Z
Ln —7— (1818D
i
Proposed Proposed Existing Existing Proposed Major Proposed
Base Zoning & Base Zoning & District District Changes in Changes
Overlay District Overlay District Designations Names Development ,n
Designations Names Standards Density
13 SP Specific Plan PD Planned Development Deletes PD suffix None
Specific Plans Establishes procedures for
development of a specific
plan project
Ellis—Goldenwest SP None will remain as separate document None
Holly—Seacliff SP None will remain as separate document None
Downtown SP None will remain as separate document None
Meadowlark Specific Plan None will remain as separate document None
Seabridge Specific Plan None will remain as separate document None
Seacliff Specific Plan None will remain as separate document None
North Hunt Center SP Will be removed from ordinance None
code and retained as separate
document
Pacifica Community Plan Will be removed fron ordinance None
code and retained as separate
document
Magnolia Pacific Specific
Plan None will remain as separate document None
Z�
�^ —6—
Proposed Proposed Existing Existing Propc -d Major Proposed
Base Zoning & Base Zoning & District District Changes in Changes
Overlay District Overlay District Designations Names Development in
Designations Names Standards Density
12 PS Public—Semipublic CF—E Community Facility—Educ Designation applies to flood control N/A
channels Edison right—of—way schools
CF—C Community Facility—Civic churches etc PS required for 2 acres N/A
or more otherwise base and overlay
standards applicable to the site
1
_�_ (1818D)
Proposed Proposed Existing Existing Proposed Major Proposed
Base Zoning & Base Zoning & District District Changes in Changes
Overlay District Overlay District Designations Names Development in
Designations Names Standards Densil-y
10 IL Limited Industrial M1—A Restricted Manufacturing Adds FAR allows group residential Limited to
subject to Planning Commission approval housing for on—
site workers
11 OS Open Space With 4 subdistricts as follows
OS—WR Open Space—Water Rec WR Water Recreation None N/A
OS—C Open Space—Conservation CC Coastal Conservation Suf None N/A
OS—PR Open Space—Parks & Rec CF—R Community Facility—Rec Will require zone change if park N/A
no longer needed and declared
ROS Recreational Open Space surplus
OS—S Open Space—Shoreline S1 Shoreline None N/A
(1818 D)
u
Proposed Proposed Existing Existing Proposed Major Proposed
Base Zoning & Base Zoning & District District Changes in Changes
Overlay District Overlay District Designations Names Development in
Designations Names Standards Density
5 RMP Manufactured Home Park MH Mobile Home None None
MFH Manufactured Home Suffix Deleted existing section N/A
violates State law
6 CO Commercial Office OP Office Professional Adds floor area ratio upper story N/A
setback and building design standards
7 CG General Commercial Cl Neighborhood Commercial Eliminated None
C2 Community Business C2 & C4 Consolidated reduces and
changes setback requirements deletes
site angle requirements see CO
C4 Highway Commercial
8 CV Visitor Commercial VSC Visitor Serving Comm To encourage pedestrian access None
setback eliminated see CO and CG
9 IG General Industrial M1 Light Manufacturing Combined increased lot size Limited to
adds FAR allows group residential housing for on—
M2 Industrial subject to Planning Commission approval site workers
�1
,J
asp y_ (18180)
u.
Proposed Proposed Existing Existing Proposed Major Proposed
Base Zoning & Base Zoning & District Uistrict Changes in Changes
Overlay District Overlay District Designations Names Development in
Designations Names Standards Density
RMH—A Medium—High Density OTSP-1 & 2 Oldtown Specific Plan Combine into 1 d1c+n ct Density allowed
(Subdistrict) Residential—Small Lot Districts Land 2 no open space requirement for sfd on parcels 50
density based on net lot area rather feet or greater
TLSP—A B Townlot Spec Plan than site frontage reduce Oldtown currently exceeds
Sections A and B front yard to Townlot standard of General Plan and
12 feet should be medium
high density
will require GPA
to correct
density 1 unit
per 1 900 sq
ft
4 RH High Density Residential R4 High Density Residential Same as RM, RMH Reduction is
density to bring
zoning into
conformance with
General Plan 1
unit per 1 244
sq ft
W �
G (18180)
RESPONSE TO COMMENTS FOR DRAFT
NEGATIVE DECLARATION NO 91-32
I INTRODUCTION
This document serves as the Response to Comments on the Draft
Negative Declaration No 91-32 This document contains all
information available in the public record related to the Draft
Negative Declaration as of May 11, 1992 and responds to
comments in accordance with Section 15088 of the California
Environmental Quality Act (CEQA) Guidelines
This document contains five sections In addition to this
Introduction, these sections are Public Participation and
Review, Comments, Responses to Comments, and Appendix A
The Public Participation section outlines the methods the City
of Huntington Beach has used to provide public review and
solicit input on the Draft Mitigated Negative Declaration The
Comments section contains those written comments received from
agencies, groups, organizations, and individuals as of April 5,
1993 The Response to Comments section contains individual
responses to each comment
It is the intent of the City of Huntington Beach to include
this document in the official public record related to the
Draft Negative Declaration Based on the information contained
in the public record the decision makers will be provided with
an accurate and complete record of all information related to
the environmental consequences of the project
II PUBLIC PARTICIPATION AND REVIEW
The City of Huntington Beach notified all responsible and
interested agencies and interested groups, organizations, and
individuals that a Draft Negative Declaration had been prepared
for the proposed project The City also used several methods
to solicit input during the review period for the preparation
of the Draft Negative Declaration The following is a list of
actions taken during the preparation, distribution, and review
of the Draft Negative Declaration
1 A cover letter and copies of the Draft Negative
Declaration were filed with the State Clearinghouse on
September 27, 1991 The State Clearinghouse assigned
Clearinghouse Number 9109101 to the proposed project
A copy of the cover letter and the State Clearinghouse
distribution list is available for review and
inspection at the City of Huntington Beach, Planning
Department, 2000 Main Street, Huntington Beach,
California 92648
RT c r
2 An official thirty (30) day public review period for
the Draft Negative Declaration was established by the
State Clearinghouse It began on September 27, 1991
and ended on October 28, 1991 Public comment letters
were accepted by the City of Huntington Beach through
October 30, 1991
3 Notice of the Draft Negative Declaration was published
_ in the Daily Pilot on October 1, 1991 Upon request,
copies of the document were distributed to agencies,
groups, organizations, and individuals
4 The Draft Negative Declaration was never acted upon, as
the revised Zoning and Subdivision Ordinance Code
continued to be reviewed and amended by staff As a
result, a revised Draft Negative Declaration was
prepared and published in the Huntington Beach
Independent for a 30 day comment period commencing
March 4 , 1993 and ending April 5, 1993 Copies of the
revised Draft Negative Declaration were directly
distributed to those who commented on the original
document as well as the State Clearinghouse and local
school districts
5 An official thirty day (30) day public review period
for the revised Draft Negative Declaration was
established by the State Clearinghouse It began on
March 1, 1993 and ended on March 31, 1993 Public
comment letters were accepted by the City of Huntington
Beach through April 5, 1993
III COMMENTS
Copies of all written comments to the revised Draft Negative
Declaration received as of April 5, 1993 are contained in
Appendix A of this document Only those comments which raised
an environmental issue have been retyped verbatim in a
comment-response format for clarity All other comments are
hereby acknowledged
IV RESPONSE TO COMMENTS
The revised Draft Negative Declaration No 91-32 was
distributed to responsible agencies, interested groups,
organizations, and individuals The report was made available
for public review and comment for a period of thirty (30)
days The public review period for the revised Draft Negative
Declaration established by the State Clearinghouse commenced on
March 1, 1993 and expired on March 31, 1993 The City of
Huntington Beach accepted comment letters through April 5, 1993
Negative Declaration
No 91-32 -2- ( 1872D)
Copies of all documents received as of April 5, 1993 are
contained in Appendix A of this report Comments have been
numbered with responses correspondingly numbered Responses
are presented for each comment which raised a significant
environmental issue
Several comments do not address the completeness or adequacy of
the Draft Negative Declaration, do not raise significant
environmental issues, or request additional information A
substantive response to such comments is not appropriate within
the context of the California Environmental Quality Act
(CEQA) Such comments are responded to with a "comment noted"
reference This indicates that the comment will be forwarded
to all appropriate decision makers for their review and
consideration
Negative Declaration
No 91-32 -3- (1872D)
GOPR
Comment
The State Clearinghouse submitted the above named environmental
document to selected state agencies for review The review period
is closed and none of the state agencies have comments This letter
acknowledges that you have complied with the State Clearinghouse
review requirements for draft environmental documents, pursuant to
the California Environmental Quality Act
Please call Tom Loftus at (916) 445-0613 if you have any questions
regarding the environmental review process When contacting the
Clearinghouse in this matter, please use the eight-digit State
Clearinghouse number so that we may respond promptly
Response
Comment acknowledged
SCAG
Comment
We have reviewed the above referenced document and determined that
it is not regionally significant per Areawide Clearinghouse
criteria Therefore, the project does not warrant Clearinghouse
comments at this time Should there be a change in the scope of the
project, we would appreciate the opportunity to review and comment
at that time
A description of the project will be published in the March 15, 1993
Intergovernmental Review Report for public review and comment
The project title and SCAG number should be used in all
correspondence with SCAG concerning this project Correspondence
should be sent to the attention of the Clearinghouse Coordinator
If you have any questions , please contact Maureen Farley at (213)
236-1886
Response
Comment Acknowledged
Department of Transportation
Comment
Thank you for the opportunity to review and comment on the update
and revision of the City s Zoning and Subdivision Ordinance Code
Because the revision and update of the Zoning and Subdivision Code
does not state the specificity of a project, Caltrans is unable to
Negative Declaration _L
No 91-32 - ,Zr( U (1872D)
determine the impacts of any development upon State facilities
Therefore, District 12 reserves its rights to comment on individual
projects affected by this regulation We look forward to the
implementation of this element and improving regional partnership
Once again, thank you for the opportunity to review and comment on
the proposed project If clarification is needed, please
communicate with Nathaniel H Pickett, 714-724-2247 or Ms Aileen
Kennedy at 724-2239
Response
Comment Acknowledged
County of Orange - EMA
Comment
Thank you for the opportunity to respond to the above referenced
item The County of Orange has no comment at this time However,
we would appreciate being informed on any further developments
If you have any questions or need to contact us, please call KAri
Rigoni at (714) 834-2109
Response
Comment Acknowledged
DFG-1.
Comment .
The Department of Fish and Game (Department) has reviewed the
referenced document and has the following questions regarding
Attachment A" under the heading of 'Proposed Major Changes in
Development Standards '
1 "Base Zoning Districts, RL Delete open space
requirement, " page 1 How will this change affect the open
space requirement associated with any mitigation measures
designed to off-set adverse project-related impacts?
Response
On-site open space (private outdoor living area) for a single family
dwelling in the RL district will be satisfied by compliance with
site coverage and setback provisions Development of all
residential projects will continue to be subjected to parkland
dedication and/or payment of in-lieu fees Any mitigation measures
necessary to off-set adverse development specific impacts will be
generated through the project entitlement process in compliance with
CEQA
Negative Declaration tiTC
No 91-32 -5- (1872D)
DF -2
Comment
2 "RMH-S, no open space requirement for sfd, " page 2 Same
question posed above
Response
Response DFG-2 applicable to RMH-A district also
DFG-3
Comment
Pursuant to the Fish and Game Code Section 1802 which states that
the Department has jurisdiction over the conservation, protection,
and management of fish and wildlife resources, we are concerned that
future projects will not receive adequate mitigation measures
necessary to off-set adverse project-related impacts if open space
requirements are no longer required
Response
Open space (private outdoor living area) will be provided in all
single family developments by compliance with setbacks and site
coverage Both private and common outdoor living areas will be
required in all multiple family projects In addition, parkland
dedication and/or in lieu fees are required The proposed Zoning
Code revisions will not alter the City s environmental review
process Subsequent development under the proposed Zoning Code will
still be subject to the CEQA process which is the City' s present
means for identifying impacts and imposing adequate mitigation
measures to protect and conserve fish and wildlife resources
DFG-4
Comment
If our concerns are adequately addressed, we will have no opposition
to these updates and revisions to the City of Huntington Beach s
Zoning and Subdivision Ordinance Code
Response
Comment noted and will be forwarded to decision makers for
consideration prior to action on the proposed project
Negative Declaration
No 91-32 -6- (1872D)
DFG-5
Comment
Thank you for the opportunity to provide comments on this document
If you have any questions, please contact Ms Cheryl Heffley,
Wildlife Biologist, at (310) 694-3578
Response
Comment does pertain to any environmental issue No reply is
warranted
CSA-1
Comment
On behalf of the Huntington Beach City School District ( District") ,
Community Systems Associates, Inc ("CSA") has been requested to
provide comments on Negative Declaration No 91-32 prepared for the
Update and Revision of the Zoning and Subdivision Ordinance Code
( Amendment" ) for the City of Huntington Beach ("City")
Response
Comment noted Comment does not pertain to any environmental
issue No reply is warranted
CSA-2
Comment
The District received the Negative Declaration on March 3, 1993
Pursuant to the requirements of the California Environmental Quality
Act ( CEQA' ) , comments to the Negative Declaration may be provided
within 30 days of receipt of the Negative Declaration (i e , by
April 2, 1993) This letter provides the District ' s comments and is
intended to comply with the CEQA requirements on behalf of the
District
Response
Comment noted Comment does not pertain to any environmental
issue No reply is warranted
CSA-3
Comment
The District believes that the Amendment may have a significant
environmental impact on the District Additionally, the Negative
Declaration and Initial Study prepared to evaluate the environmental
impacts of the Amendment are inadequate and do not provide
Negative Declaration puL
No 91-32 -7- (1872D)
sufficient information to appropriately evaluate the impacts of the
Amendment More detailed environmental documentation, such as an
environmental impact report or revised negative declaration, should
be prepared to thoroughly evaluate the potential significant impacts
on the Amendment on the District The environmental documentation
prepared for the Amendment should also include measures to mitigate
all significant impacts on the Districts
Response
Comment noted and will be forwarded to decision makers for
consideration prior to action on the proposed project
CSA-4
Comment
All new residential development within the District will have a
direct impact on the District The capital facilities costs to the
District to accommodate students generated from new housing units is
much greater than the development fees received Additionally,
enrollment at all District schools is near or exceeds capacity The
District has demonstrated these facts to the City in numerous
previous letters Please see the attached letter sent to Mr
Michael T Uberuaga dated February 12, 1993 for further detail
Response
Comment noted and will be forwarded to decision makers for
consideration prior to action on the proposed project
CSA-5.
Comment
Question 14 (c) , Public Facilities Schools, claims that the
Amendment will not have an effect on the District "No new school
facilities will be required if the proposed zoning and subdivision
ordinance code is adopted ' [page 91 Apparently this conclusion is
based on the fact that some of the proposed zoning changes will
allow increased densities, while others will allow reduced
densities , thereby resulting in no net change For example, in the
discussion of land use impacts of the Amendment, the Negative
Declaration states
Under the proposed zoning designations of RM, RMH and RH will
be developed at a slightly lower density and TLSP and OTSP
areas , redesigned as RMH-A, will be developed at a slightly
higher density based on a lot area rather than lot frontage as
permitted under the existing code [page 71
Negative Declaration
No 91-32 -8- ( 1872D)
Response
The higher density proposed for the RMH-A areas will allow for
approximately 6, 500 residential units To achieve this density, the
entire area must be void of any structures prior to development at
the higher density Because the area is 96% built out, the City
does not anticipate a significant increase in student generation
Natural attrition of enrollment levels due to students graduating,
families relocating out of the area, etc open up space for new
students In addition, the school district has several closed
schools in the City which may be refurbished and reopened if
necessary Specific development projects will be subject to CEQA,
and any adverse project-related impacts on school facilities will be
identified and mitigation measures recommended
CSA-6
Comment
However, the District is approximately one half the size of the
City While the changes proposed may balance Citywide, it is
possible that the changes within the District will result in a net
increase in density The environmental documentation prepared for
the Amendment should include a map displaying changes in density so
it can be determined where the effects of the Amendment will occur
The table in Attachment A which lists the various zoning changes
should quantify the effects of each change, not simply include
qualitative notes such as "reduction in density"
Response
A map displaying changes in zoning districts has been prepared and
will be included Comment noted and will be forwarded to decision
makers for consideration prior to action on the proposed project
CSA-7
Comment .
Additionally, no mention is given in the Negative Declaration to the
potential impacts of allowing residential development in industrial
areas The Amendment would allow employee housing to be developed
in both General Industrial and Limited Industrial zones Besides
the typical impacts on the District of residential development,
housing in industrial areas may result in increased bussing and
exposure of students to health hazards District schools are
located in residential neighborhoods, so students living in
industrial areas would have to walk long distances or be bussed
Students living in industrial areas could be exposed to unsafe air
emissions, high noise levels, heavy truck traffic, and other
potential safety risks
Negative Declaration CTC
No 91-32 -9- (1872D)
Response
Development of employee residential in the industrial districts will
be subject to discretionary review Any adverse project-related
impacts will be generated through the entitlement process in
compliance with CEQA
CSA-8
Comment
However, Question 17, Human Health, summarily dismisses the
potential health hazards of the Amendment, claiming that further
environmental review will be done on a project specific basis
While project specific environmental review is certainly necessary,
it is not the correct level at which to evaluate the concept of
allowing residential development in industrial areas Rather, the
issue should be evaluated at the program level The Amendment and
its environmental documentation should contain guidelines and
mitigation measures for preventing the potential health hazards of
allowing residential development in industrial areas
Response
Comment noted and will be forwarded to the decision makers for
consideration prior to action on the proposed project
CSA-
Comment
The Amendment also proposes to change the zoning of schools from
Community Facility-Education to Public-Semipublic, but does not
discuss whether this is simply a name change of if it will actually
alter the zoning of District facilities If this change results in
additional restrictions on the use of District land, the District ' s
ability to provide educational services to the community could be
impacted The provisions of this zone change should be discussed in
greater detail
Response.
School district properties are designated Community Facilities
Overlay (CF-E) to identify use for publicly owned educational
purposes The underlying zoning is also in effect The proposed
base district Public-Semi public (PS) will continue to allow
publicly-owned educational facilities as well as other public-
semi-public uses
Negative Declaration T-C '
No 91-32 -10- ( 1872D)
CSA-10
Comment
The Huntington Beach City School District and Community Systems
Associates, Inc appreciate having the opportunity to provide these
comments concerning Negative Declaration No 91-32 to the City of
Huntington Beach If you have any questions or require additional
information, please contact Mr Jerry S Buchanan at (714) 964-8888,
or myself at (714) 838-9900
Response.
Comment does not pertain to any environmental issue No reply is
warranted
Negative Declaration
No 91-32 -11- (1872D)
STALE OF CALIFORNIA m r rrl ,1y o x /+ PETE WILSON Governor
GOVERNORS OFFICE OF PLANNING AND RESEARCH
1400 TENTH STREET
SACRAMENTO CA 95814 '
Mar 31, 1993
JULIE OSUGI
_ CTTY OF HUNTINGTON BEACH
2000 MAIN STREET
HUNTINGTON BEACH, CA 92648
Sub3ect NEGATIVE DECLARATION NO 91-32, HUNTINGTON BEACH
SCH # 91091091
Dear JULIE OSUGI
<-r
ti
The State Clearinghouse submitted the above named environmental S,
document to selected state agencies for review The review period is
GLosed and none of the state agencies have comments This letter
-Acknowledges that you have complied with the State Clearinghouse review
requirements for draft environmental documents, pursuant to the
California Environmental Quality Act
Please call Tom Loftus at (916) 445-0613 if you have
-tny questions regarding the environmental review process When
contacting the Clearinghouse in this matter, please use the eight-digit
State Clearinghouse number so that we may respond promptly J
Sincerely,
Christine Kinne
Acting Deputy Director, Permit Assistance
R r c A,'r'c.Al D,,
PTC /') r
Notice of Completion S NOTE t-I..
CLatr Clearinghousc 1-00 Tcnih Street.Sacran cnto CA 95814 916,1445 0613 SCH• e�/0 210 VI
tTltle Nay,1tt,.e Declaration No 91-32
„7 Ag ncy City of Huntington Beach Cc uctP rson Sawn Pierre
S Add 2000 Main Street phone 714-536-5250
I untington Beach ZP Cc my Orange
P olect Location
v Orange CIIY/N ar it Comm ry Huntington Beach
ci wide
L Stretu c a t y w l a Z p Cod Toul Acresy
A or s Pu I N N/A Section Twp Rang Bue
,hin2MI SureH-ya 1 ,anrl 19 Wterwys cantA Ana R ver Hiintingtnn Harhnur
A rporu Rulw s PERR Schools city wide
—— ———————————————————————————————————————
Occument Type
C GA ❑NOP ,LyS PPl m t/S bsei I NEPA ❑NO] Other ❑Joint Doeum nt
❑Early Cc s ❑EI R(Pn SCH No) ❑EA ❑F n I Docum i
ti g Dec [i Other ❑Dfafl EIS ❑Other
❑Dr EIR ❑FONSI
—————————————————————————————————————————
Lo al Action Type
G al Plan L)-d 1 ❑Spec r P an ❑R zo ❑Ann action
C al Plan Am d' t ❑hia_t Pla. ❑Prezon ❑R de lopm i
—C al Plan El m i ❑Plan d L i D I pm t ❑Us Pam I ❑C astal Perm t
Tn i Pan ❑Step n LudD uo (S bd is on jXO.h r7nninq
------ —J�� ItitPTrclMP ) subdivision update
— ————————— —————————————
De lopment Type N/A
d al t ❑µa F I T MGD
C 91r s F, 1 eu ❑T arispo t on T pe
❑M n g Af nc !
er ❑Power T p a arr
,i u 1 ❑Wut T tiara t T p
'a _ c 1 E)Hazardo sAw Tp
"T 'Oher -- -- -
p a ont.l
—— ———————————————————————————————————————
P o{ect I sue D cue ed in Doeum nt
A ,h i N 1 Flood PI 1'Flood g nl S h 1 R.n st s n K I Qual ty
J Agri 1w 1 Land Fo st Und'F re H zard ❑Sept c SVft ms g]w 21 r SUPpty/GIO ndw i r
AT Q I ry G 1 g CIS m S we C Pic ty $]Al tland/R pu an
Arch log c UH st al I]M als �j So 1 Er on/CompacuonlGradmg u ldl fe
4 C as al Zo \o s J]Sol d K use O CroMilt Ind ng
�,X D-L gc/Absorpt _LP P 1 10 14 g B lan a O T 'Hazwdo s ]Land se
r' m /lob P bl c S n c /F c l i s �j T frc/Cu 1 uon ]C mul ti e Eff u
F a. R o i or✓Pa.is 'I V geutwn .Q Other
—————————————————————————————————————————
P esent Land Use/Zoning,`Ceneral Plan Use
Pro ect is city wide and incorporates multiple land use designations
and zones
--———————————————- ———————————————————————
%)ect Desc Ipllon
- ` i d revisions to the City of Huntington Beaci Zoning and
Subdivi- on Ordinarce erode
TOE LOFTUS
(S 6 5 C6 3
HT SNT LILT SNT
3 (— Resources State/Consumer Svcs
a F I F A
F l A
7� �Ctactel Comm
A -3 jl&d Fish L Game
Parks6 Rec/OHP ty
— _ s
O Reg WQCB
&_DWR _—
1 ions
PLEASE NOTE SCH NUHBER ON AI.L COMMENTS
PLEASE FORWARD LATE COMENTS DIRECTLY _
TO THE LEAD AGENCY ONLY Caltrans 112,
— 0—Trans Planning _
P PP C c� ces _ Housing i Devel/ _
State Lands Comm
e
C r4 Z
i
, E C E 4 V IE D MICHAEL M RUANE
4 U NTY O F j 1! +� n u I� 13 DIRECTOR EMA
2 I G THOMAS B MAT S
Rom,+ �c^ - — '^` DIRECTOR OF PLA G
s 3 RANGE '
LOCATION
ENVIRONMENTAL MANAGEMENT AGENCY 300 N FLOWER ST
PLANNING THIRD FLOOR
SANTA ANA CA
MAR 1 9 1993 MAILING ADDRESS
P 0 BOX 4048
SANTA ANA CA 92702 4048
TELEPHONE
(714)834 464
Susan Pierce,Associate Planner FILE NCL 93-14 FAX# 83427/1
City of Huntington Beach DPC 834 4 7t
Department of Community Development
2000 Main Street
Huntington Beach, CA 92648
SUBJECT ND 91-32 - Update/Revision of the Zoning and Subdivision Ordinance Code
Dear Ms Pierce
Thank you for the opportunity to respond to the above referenced item The y
County of Orange has no comment at this time However, we would appreciate -�
being informed of any further developments
-r z
If you have any questions or need to contact us, please call Karl Rigoni at
(714) 834-2109
. J
1�
Very truly yours,
Kari A Rigoni, P nne
For Robert W White, Manager
Environmental Planning Division
CH crPL02-054
(3077)3031811450496
AM AM ftl&k
JOtlTHERO%CRLIFORRIARI/OCIRTIOO OF G
818 West Seventh Street,12th Floor • Los Angeles, California 90017 3435 E (213)236-1800 • FAX(213)236 1P
March 3, 1993
Ms Susan Pierce
Associate Planner
City of Huntington Beach
2000 Main Street
Huntington Beach, CA 92648
RE SCAG Clearinghouse # I9300139
Project Title Negative Declaration No 91-32
Update and Revision of the Zoning and Subdivision Ordinance Code
Dear Ms Pierce
We have reviewed the above referenced document and determined that it is not regionally
significant per Areawide Clearinghouse criteria Therefore, the project does not warrant
clearinghouse comments at this time Should there be a change in the scope of the project, we
would appreciate the opportunity to review and comment at that time
A description of the project will be published in the March 15, 1993 Intergovernmental Review
Report for public review and comment
The project title and SCAG number should be used in all correspondence with SCAG concerning +
this project Correspondence should be sent to the attention of the Clearinghouse Coordinator Z-
If you have any questions, please contact Maureen Farley at (213) 236-1886
0
f�
Sincerely,
b""
A a�k
ERIC H ROTH
Manager, Intergovernmental Review
J h I ni, 11 C t)of R alto Pre d nt Gaddi Vasquez Ora ge County First Vi a Pre ident Stella Alendoza City of Brawl y Se and Vice President John Flynn Ventura County Pa I
P d t s R cha d Alator e City of Lo Angeles Michael Antono ich Lo A gele County Robert Bartlett City of Monro to George Bass Cit of Bell Ronald Bales City of I o
al to t ( ri a Battey Jr C ty of Bu bank Frnam Bernardi City of Lo Angeles Hal Bernson C ty of Los Angele Walter Bowman City of Cypress Tom Bradley City of Los An}
I AI in Br ud City of Lo A gele Susan Brooks City of Rancho Palos Verdes Art Brown City of Buena Park Jim Busby Jr City of Victorville John Cox Cit of Newport B
D ne Dan 1 A gel County Flmer Digneo City of Loma Linda Richard Dixon City of Lake Forest Douglas Drummond C ty of Long Beach John Fe raro C ty of Lo A 1>
J n%l Ike Flur City of Lo Ang le Te ry Frizzel C ty of R ers de Ruth Galanter City of Los An eles Sandra Gems City of Costa Mesa Candace Haggard C ty of San Cie e
( I ind H dem n C ty of In flew) d Robert Hargra e C ty of Lom to Mike Hernandez City of Los Angeles Nate Holden City of Lo Ant,ele Robert Jamison C ty of Aries J m
Is,
If)( ty I S Ih I 1 M nt Ri h d Kelly City of Palm D ert Bob Kuhn City of Glendora Abbe Land C tv of West Hollywood Darlene hlcBane C ty of Agoura Hill John Melt m
( ty f S me P I Barbar Messina City of Alhambra Jon VLkels Sa i Bemardino Co my Judy hlikels City of Sim Valley Da id Myers City of Palmdale Kathryn Nack City of P d
B P rry C ty f B (wenn Norton Perry City of Ch H 11 Ronald Parks C ty of Teme ula Ir Pickler Cny of A ah in Jov Ihcus Cuy of Lo Ani,ele Beatrice Proo C Iy of
1 R r 1 rry Rhmeh rt C tv I M)n( la Mark Rill v 7 h)mas C ty of Lo Ang le Albert Robles City of South Gate Sam Sharp Impenal Count B ih Stone C ty of B Iltluwer
I h in tiyk s C I I w I iut J(1T 7 h imas C ty if Tu t n 1 auri Tully Payne City of H ghland J rel W achs C Iy of Lo Angel Rita Walters City of L( Ang I IFelvn N elk Cuv of
I y w d VI h I N� C Iy I I N g I Judy Wright C iv of(1 i ni Ze Yarosla sky City of I o Ani_ le Norton It ounglo a Ri rside Co ty 0
STATE OF CALIFORNI%—THE RESOURCES AGENCY PETE WILSON Go erno
DEPARTMENT OF FISH AND GAME f-�,
330 GOLDEN SHORE SUITE SO �
LONG BEACH CA 90802 '�,�l
k310) 590-5113
March 25, 1993
F .. �
uj)
Ms Susan Pierce
Associate Planner -f
City of Huntington Beach ask- -
2000 Main Street
Huntington Beach, California 92648
Dear Ms Pierce
Negative Declaration No 91-32 City of Huntington Beach
Zoning and Subdivision Ordinance Code
The Department of Fish and Game (Department) has reviewed
the referenced document and has the following questions regarding
"Attachment All under the heading of "Proposed Ma3or Changes in
Development Standards"
Dt C
1 "Base Zoning Districts, RL Delete open space
requirement, " page 1 How will this change affect the
open space requirement associated with any mitigation
measures designed to off-set adverse pro3ect-related
impacts'-)
2 "RMH-S, no open space requirement for sfd, " page 2 11)FL-, z
Same question posed above
Pursuant to the Fish and Game Code Section 1802 which states
that the Department has Jurisdiction over the conservation,
protection, and management of fish and wildlife resources, we are [' F6
concerned that future pro3ects will not receive adequate
mitigation measures necessary to off-set adverse pro3ect-related
impacts if open space requirements are no longer required
If our concerns are adequately addressed, we will have no '
opposition to these updates and revisions to the City of
Huntington Beach's Zoning and Subdivision Ordinance Code
k Tc A
Ms Susan Pierce
March 25 , 1993
Page Two
Thank you for the opportunity to provide comments on this IC)
document If you have any questions, please contact Ms Cheryl
Heffley, Wildlife Biologist, at (310) 694-3578
Sincerely,
Fred Worthley
Regional Manager
Region 5
cc C Heffley, DFG/WLM
K Lal, DFG/ES
ES Files
till
L --;D
Community Systems Assoc►ates Inc
April 2 1993
HAND DELIVERED
Ms Susan Pierce AICP G ' 11-0
Associate Planner
CITY OF HUNTINGTON BEACH + r
2000 Main Street
Huntington Beach California 92648
SUBJECT Negative Declaration No 91-32
Update and Revision of the Zoning and Subdivision Ordinance Code
for the City of Huntington Beach
Dear Ms Pierce
On behalf of the Huntington Beach City School District ("District"), Community Systems
Associates, Inc ("CSA") has been requested to provide comments on Negative C5/1
Declaration No 91-32 prepared for the Update and Revision of the Zoning and
Subdivision Ordinance Code ("Amendment") for the City of Huntington Beach ("City")
The District received the Negative Declaration on March 3 1993 Pursuant to the
requirements of the California Environmental Quality Act ("CEQA"), comments to the
Negative Declaration may be provided within 30 days of receipt of the Negative c,,A
Declaration (i e , by April 2 1993) This letter provides the District's comments and is
intended to comply with the CEQA requirements on behalf of the District
The District believes that the Amendment may have a significant environmental impact
on the District Additionally, the Negative Declaration and Initial Study prepared to
evaluate the environmental impacts of the Amendment are inadequate and do not provide
sufficient information to appropriately evaluate the impacts of the Amendment More
detailed environmental documentation, such as an environmental impact report or revised
negative declaration should be prepared to thoroughly evaluate the potential significant
impacts of the Amendment on the District The environmental documentation prepared
for the Amendment should also include measures to mitigate all significant impacts on
the District
1u L ( n 1 r)V11 _2uu TUSTIN CALI ORNIA 92b80 (714)835 +900 FAQ ( 1d)338 J099
Ir x _ I
Cc"m
Ms Susan Pierce
CITY OF HUNTINGTON BEACH
April 2 1993
Page 2
All new residential development within the District will have a direct impact on the District
The capital facilities costs to the District to accommodate students generated from new
housing units is much greater than the development fees received Additionally Syq �-
enrollment at all District schools is near or exceeds capacity The District has
demonstrated these facts to the City in numerous previous letters Please see the `
attached letter sent to Mr Michael T Uberuaga dated February 12, 1993 for further detail
Question 14(c), Public Facilities Schools claims that the Amendment will not have an '
i effect on the District "No new school facilities will be required if the proposed zoning and
subdivision ordinance code is adopted " [page 9] Apparently this conclusion is based on
the fact that some of the proposed zoning changes will allow increased densities, while
others will allow reduced densities thereby resulting in no net change For example in
the discussion of land use impacts of the Amendment the Negative Declaration states
i
Under the proposed zoning designations of RM, RMH and RH will be developed
at a slightly lower density and TLSP and OTSP areas, redesigned as RMH-A, will
be developed at a slightly higher density based on a lot area rather than lot C-`
frontage as permitted under the existing code [page 7]
However the District is approximately one half the size of the City While the changes
proposed may balance Citywide, it is possible that the changes within the District will
result in a net increase in density The environmental documentation prepared for the
I Amendment should include a map displaying changes in density so it can be determined �'"`
where the effects of the Amendment will occur The table in Attachment A which lists the E
various zoning changes should quantify the effects of each change, not simply include
qualitative notes such as "reduction in density"
Additionally, no mention is given in the Negative Declaration to the potential impacts of
allowing residential development in industrial areas The Amendment would allow
employee housing to be developed in both General Industrial and Limited Industrial i
zones Besides the typical impacts on the District of residential development housing in
industrial areas may result in increased bussing and exposure of students to health
hazards District schools are located in residential neighborhoods so students living in
industrial areas would have to walk long distances or be bussed Students living in
industrial areas could be exposed to unsafe air emissions high noise levels heavy truck i
traffic and other potential safety risks
t
However Question 17 Human Health summarily dismisses the potential health hazards
of the Amendment claiming that further environmental review will be done on a project
specific basis While project specific environmental review is certainly necessary it is not i
i
n r sr sA res 1
Ms Susan Pierce
CITY OF HUNTINGTON BEACH
April 2 1993
Page 3
the correct level at which to evaluate the concept of allowing residential development in
industrial areas Rather the issue should be evaluated at the program level The
Amendment and its environmental documentation should contain guidelines and
mitigation measures for preventing the potential health hazards of allowing residential
development in industrial areas
The Amendment also proposes to change the zoning of schools from Community Facility-
Education to Public-Semipublic, but does not discuss whether this is simply a name
change of if it will actually alter the zoning of District facilities If this change results in C /4
additional restrictions on the use of District land the District's ability to provide
educational services to the community could be impacted The provisions of this zone
change should be discussed in greater detail
The Huntington Beach City School District and Community Systems Associates, Inc
appreciate having the opportunity to provide these comments concerning Negative
Declaration No 91-32 to the City of Huntington Beach If you have any questions or
require additional information please contact Mr Jerry S Buchanan at (714) 964-8888,
or myself at (714) 838-9900
Sincerely,
I
I
+ COMMUNITY SYSTEMS ASSOCIATES, INC
�7 C
I
John C Hutt
Associate Vice President
attachment l
1120plercel ich
I
cc Mr Jerry S Buchanan
Assistant Superintendent Business Services
Huntington Beach City School District
i
I
I
_ J
h jc /�
U A--
0 ILtI
RECEIV77D FLB 1 3 1993
HUNTINGTON BEACH CITY SCHOOL DISTRICT
20451 Cratmer Lane P O Box 71 Huntington Beach California 92648 (714)964 8888
February 12 , 1993
80ARD OF TRUSTEES
Mr Michael T Uberuaga
Shirley Carey President City Administrator
City of Huntington Beach
Br an Garland 2000 Main Street
Clerk
Huntington Beach, California 92648
Robert Mann Ed D
Member Subject Mitigation of Development Impacts on the
Cather ne McGough Huntington Beach City School District
Member
Bran E Rechsteiner Dear Mr Uberuaga
Member
This letter is intended to update you and the rest of
ADMINISTRATION the City of Huntington Beach ("City") staff, as well as
the City Council and Planning Commission, of the
Duane Dshno Ed D current condition of the Huntington Beach City School
Superintendent District ("District") and recent legislation concerning
school impact mitigation
Alan Rasmussen Ed D
Ass stant Super ntendent
Personnel/Educational The District remains near capacity and unable to
Services adequately accommodate new students generated by
Jerry Buchanan development without mitigation in excess of statutory
Assistant Superintendent development fees On the bright side, the District is
Bus ness Services near completion of its Capital Facilities Strategic
Master Plan and Asset Management Program ("Master
Plan") The Master Plan will help the District
logically and efficiently plan and construct school
facilities required to accommodate increasing
enrollments Attached is a more detailed discussion of
the District ' s facilities and the impacts of
development Additionally, copies of the Master Plan
will be transmitted to the City after it is adopted by
the District ' s Board
As you know, for the past several months the District
has been challenging City approval of development
projects and land use actions in an attempt to ensure
adequate mitigation of the impacts of these items on
the District Over the course of these months, the City
and District have gained a better understanding of each
other Together, we have evolved standard condition of
approval language which ensures adequate mitigation of
school impacts, while allowing development to proceed
Similar language was made a condition of approval on
the Holly-Seacliff Specific Plan and NESI project
/6( A it
Mr Michael T Uberuaga February 12 , 1993 Page 2
and has been proposed by City Staff for the Coultrup
pro]ect
Unfortunately, Senate Bill No 1287 ("SB 128711) has
limited the methods the City and District can employ to
mitigate school impacts The District believes that
the basic concept of school mitigation that the City
and District have been pursuing is still sound, but the
condition of approval language may need to be modified
somewhat The District has drafted the following
modified mitigation language which it feels is legal
and in the same spirit as previous City-approved
condition of approval language
Prior to the issuance of any building permit, the
developer shall mitigate the impacts of the
pro3ect on school facilities, using any
combination of measures listed in Government Code
Section 65996 or other legal means, to a level
acceptable to the appropriate school district(s)
for K-12 This condition may be waived by the
appropriate school district(s)
The District therefore requests that the City impose
the proposed mitigation language as a condition of
approval for all development pro3ects and land use
actions Attached is a detailed discussion of the
ramifications of SB 1287
Thank you for your consideration and assistance If
you have any questions or desire additional
information, please don't hesitate to contact me
Sincerely,
Jerry S Buchanan
Assistant Superintendent, Business Services
Huntington Beach City School District
attachments
cc Mayor and Members of the City Council
Chairperson and Members of the Planning Commission
Ms Gail Hutton, City Attorney
Mr Mike Adams, Director of Community Development
Mr Howard Zelefski, Planning Director
Mr Hal Simmons, Planning Department
Mr Jack Bowland, Chairman of GPAC
City of Huntington Beach
Mr Michael T Uberuaga February 12 , 1993 Page 3
cc Gary A Burgner, Ed D , Assistant Superintendent
Huntington Beach Union High School District
Stanley Oswalt, Ed D , Assistant Superintendent
Ocean View School District
Mark Ecker, Ph D , Assistant Superintendent
Fountain Valley School District
Ms Barbara Winars, Assistant Superintendent
Westminister School District
President and Members of the Board of Education
Duane Dishno, Ed D , Superintendent
Huntington Beach City School District
Mr Marshall B Krupp, President
Community Systems Associates, Inc
Mr Woody Tescher, Consultant
Envicom Corporation
ATTACHMENT A"
TECHNICAL DOCUMENTATION
State of the District
The Huntington Beach City School District ( District") covers portions of the City of
Huntington Beach and portions of the unincorporated areas of Orange County The
District serves grades K-8 through the operation of eight (8) schools consisting of six (6)
K 5 elementary school and two (2) 6-8 middle schools Additionally Lhe District maintains
four (4) closed sites one of which is used as the District office Of these twelve (12)
schools seven (7) are twenty years old or older and two (2) are over thirty years old
The District has experienced a variety of enrollment changes over the last thirteen (13)
years From 1979 to 1987 student enrollments declined at a rate of 4 2% per year
However a new trend has begun starting in the 1988 school year of a gradual but
modest increase in student enrollment The Districts Developer Fee Report identifies an
enrollment of 5 303 students in 1987/88 This figure has increased to 5 675 students as
of October of 1991 representing an average annual increase of 1 71% between 1987 -
1991 For the 1992/93 school year enrollments have increased to 5 751 students or an
increase of approximately 1 34% from the previous year
The District prepared an Enrollment Projections Study in February of 1992 This study
predicted growth of about 2 00% per year throughout the 1990s based primarily on infill
development Additionally a number of large residential developments (i e Holly-
Seacliff Bolsa Chic@ Magnolia Pacific etc ) have been proposed or adopted which may
cause significant additional student enrollment increases within the District
The District s operating school facilities are currently facing severe capacity shortcomings
necessitating the addition of portable classrooms the construction of new permanent
school facilities and/or the reconstruction and expansion of existing school facilities As
of October 14 1992 the Districts capacity utilization and surplus/deficit capacity can be
seen as follows
A - 1
,�TTc A y
1992/93 School Year Capacity Utilization
Surplus/
School Capacity Enrollment Utilization (Deficit)
Eader 780 683 87 56% 97
Hawes 390 414 106 15% (24)
_ Kettler 720 705 97 92% 15
Moffett 690 682 98 84% 8
Perry 540 579 107 22% (39)
Smith 720 714 9917% 6
K 5 Total 3 840 3 777 98 36% 63
Dwyer 780 853 109 36% (73)
Sowers 1 110 1 121 100 99% (11)
6 8 Total 1 890 1 974 104 44% (84)
K 8 Total 5 730 5 751 100 37% (21)
In practice students are rarely divisible into uniform class sizes and individual class
enrollments tend to fluctuate over the course of the school year As such it is difficult to
achieve 100% capacity utilization It is a generally accepted practice to consider school
facilities to be impacted if utilization exceeds 85% Capacity utilization in excess of 100%
indicates actual overcrowding of school facilities resulting in the loading of classrooms
above State standards or the use of non-classrooms (i a libraries) for classroom
purposes As shown above the District's facilities are currently overcrowded All
subsequent enrollment increases will require expansion of District facilities
The District is developing a Capital Facilities Strategic Master Plan and Asset
Management Program ( Master Plan ) The preliminary draft of the Master Plan projects
increases in enrollment for the next ten years with a total K 8 enrollment of 8 204 by
school year 2002 03 The Master Plan projects a total K-8 enrollment of 8 636 at mid-
intensity buildout To accommodate the projected enrollment growth the District will need
to develop two to three additional elementary schools (Holly-Seacliff and one to two yet
to be located) on the west side of the District Middle school enrollment increases are
anticipated to be accommodated by reopening the Peterson School and by increasing the
capacity of the Dwyer School with new permanent construction
Impact of Development
The Districts Development Fee Report last updated February 18 1992 determined that
on average there are 0 1869 K-8 students per occupied housing unit within the District
The District has found however that this number is not a good estimator of student yield
from new development because it is based on the total housing stock within the District
A - 2
which includes a number of senior and non-child households In 1991 Mr Clyde Glasser
of the District conducted a survey of new development within the District and determined
a K-8 student generation factor ("SGF") of 0 2695 This includes a K-6 component of
0 2084 and a 7-8 component of 0 611 This survey included the Town Square Pier
Colony Huntington Place Seacliff Estates Ocean Point The Villas, The Huntington
Classics The Heritage at Huntington Shores and Central Park developments These
developments depict a representative range of housing types sizes and costs
Since originally conducting the survey Mr Glasser has monitored its results and analyzed
in greater detail the factors that determine student yield The results of his analyses
show there are a large number of variables which influence SGFs many of which cannot
be estimated before a development is planned or even built Because of this variability
the District believes it is best to use an average SGF rather than factors based on
different housing types sizes etc The District feels its survey determined SGF of 0 2695
is the best estimator of student generation for new development
To accommodate additional students generated by development the District will need to
add portable classrooms refurbish and redesign existing facilities construct additional
permanent classrooms at open schools reopen one or more schools and/or develop one
or more new schools The District also requires offsite support facilities such as a
maintenance and operations yard The full cost of accommodating an additional student
assuming land new classroom construction (70% permanent and 30% relocatable) and
offsite support facilities is $21 767 for K-6 and $33 808 for 7-8 These amounts are in
1992/93 dollars
Multiplying the SGF for each grade level by the District facilities cost per student for that
grade level results in the total impact on the District per housing unit This equates to
approximately $6 602 Based on the average size of housing units developed within the
District (1 600 square feet) the impact on the District per square foot of residential
development is estimated to be $4 13
However the District has certain facility and land assets which can be employed to
partially offset the full impact of development perhaps the most useful of which are the
Districts closed schools In order to house the projected increased student enrollments
the Master Plan contains a school facilities development program This program calls for
the rehabilitation of and expansion of existing schools reopening of two of the Districts
closed sites and the acquisition and development of three new schools (two schools in
addition to the Holly Seacliff school)
Unfortunately the Districts other closed schools cannot be used to house new students
because much of the new residential development will occur on the west side of the
District while all the closed schools are on the east side Sending students to schools far
away from their homes would violate the Districts commitment to neighborhood schools
and require prohibitively expensive bussing
A - 3
The total cost of this development program in 1992 dollars is estimated to be
$56 350 000 The resulting cost to the District per additional housing unit would be
approximately $4 612 (based upon 12 219 housing units projected to be developed within
the District by mid-intensity buildout) Based on an average housing unit size of 1 600
square feet the cost to the District per square foot of residential development is
estimated to be $2 88
Comparison of Impact Estimates
Full Impact Master Plan Impact
Impact per Housing Unit $6 601 91 $4 611 67
Impact per Square Foot 1 $4 13 $2 88
To offset the impacts described above the District is allowed under State law to levy fees
on development up to certain maximum levels Current California Law concerning school
development fees was established by Assembly Bill No 1600 ( AB 1600") and Assembly
Bill No 181 ( AB 181 ) and recently amended by Senate Bill No 1287 ( SB 1287 )
AB 1600 and AB 181 allow a total of $1 65 per square foot of residential development
and $0 27 per square foot on commercial/industrial development to be collected by school
districts These fees must be shared by non-unified school districts with overlapping
territory such as a high school district and its feeder elementary school districts Based
on a fee sharing agreement with the Huntington Beach Union High School District the
District's share of these fees is 61% or $1 0065 per square foot for residential
development This amount is clearly much less than the $4 13 full impact or $2 88
Master Plan impact derived above
Senate Bill No 1287 ( SB 1287 ) which became operative January 1 1993 authorizes
school districts to levy development fees higher than allowed pursuant to AB 1600 and
AB 181 Pursuant to SB 1287 an additional $1 00 per square foot may be assessed by
school districts on residential development The law is unclear as to whether non-unified
school districts must share this additional fee or if each district may assess a full $1 00
per square foot Within the next few months it is likely that either a court will render an
interpretation of SB 1287 or the State Legislature will clarify its intent
The District is currently assessing a full additional dollar for a total fee of $2 0065 per
square foot If through subsequent court ruling or legislation the District is only able to
assess a share of the additional $1 00 it will be able to collect a total fee of $1 6165 per
square foot Both fees are still less than the $4 13 full impact or $2 88 Master Plan
impact derived above
A - 4
Comparison of Impact and Fee Estimates
Per Housing Unit Per Square Foot
Full Impact $6 601 91 $4 13
Master Plan Impact $4 611 67 $2 88
AB 1600 & AB 181 Fees $1 61040 $1 0065
Shared SB 1287 Fees $2 586 40 $1 6165
Full SB 1287 Fees $3 210 40 $2 0065
However the increased fee level afforded by SB 1287 will become inoperative if the
California electorate rejects Assembly Constitutional Amendment No 6 ('ACA 6') which
will appear on the next Statewide election currently scheduled in June of 1994 Many
development projects and land use actions approved now or in the near future will not
result in the pulling of building permits (when school development fees are paid) until after
June 1994 Hence it is uncertain which of these fee structures will be in place when the
school development fees are actually paid
Never the less because all fee levels are lower than the impacts on the District it is clear
that some additional source of mitigation will be required to offset the impacts on the
District The District feels therefore that language requiring the complete mitigation of
impacts on the District should be made a condition of approval on all development
projects and land use actions
Ramifications of SB 1287 on School Impact Mitigation
SB 1287 was passed by the State Legislature and signed by the Governor as part of the
1992 budget deal It became effective January 1 1993 The intent of this bill was to
move a greater share of responsibility for school facilities funding to local school districts
In fact SB 1287 calls for the phase out of the Leroy F Greene State School Building
Lease-Purchase Program ( State Program ) by 1996
SB 1287 is tied to ACA 6 If passed by the voters in the next statewide election
(currently scheduled for June 1994) ACA 6 will allow school districts to pass general
obligation bonds by a simple majority vote rather than the current two thirds However
if the California electorate rejects ACA 6 SB 1287 will become inoperative and the State
Program will remain intact
As mentioned above SB 1287 allows school districts to levy an additional development
fee of $1 00 per square foot on residential development As a tradeoff for the increased
fee levels SB 1287 attempted to reduce the number of mitigation measures that can be
used to offset school impacts
A - 5
The measures available to mitigate impacts on schools of development projects are
limited by Government Code Section 65996 Prior to SB 1287 legislative actions (such
as general plan amendments specific plans and zone changes) where not considered
development projects so a wider array of mitigation options was available for such
actions SB 1287 attempted to place legislative actions under the requirements
Government Code Section 65996
Government Code Section 65996 lists the following seven mitigation measures
(1) Chapter 22 (commencing with Section 17700) of Part 10 of the Education
Code
This chapter sets forth the provisions of the State Program created by the Leroy
F Greene State School Building Lease-Purchase Law of 1976 The State
Program is funded through statewide general obligation bonds such as those
approved by Propositions 152 and 155 Because the demand for state money far
exceeds the supply of statewide bond funds only a small percentage of school
projects are funded through the State Program None the less the District is
applying for funding through the State Program to the fullest extent possible The
District has provisions in all its existing mitigation agreements with developers that
would lower developer contributions to the extent state funding is obtained
Additionally the State Program will be phased out by 1996 if the California voters
approve ACA 6
(2) Chapter 25 (commencing with Section 17785) of Part 10 of the Education
Code
This chapterwas enacted by the Emergency School Classroom Law of 1979 wnich
includes provisions for the lease of state portable facilities to address emergency
overcrowding conditions It does not provide funding for permanent facilities and
is useful only in emergency situations
(3) Chapter 28 (commencing with Section 17870) of Part 10 of the Education
Code
This chapter sets forth the provisions of the California School Finance Authority
This is a statewide financing vehicle that school districts can employ to gain the
benefits of statewide rather than local financing It does not provide additional
revenue but is only a financing tool
(4) Article 2 5 (commencing with Section 39327) of Chapter 3 Part 23 of the
Education Code
This article provides school districts with the authority to enter into a lease or other
agreement for school facilities with non profit corporations This allows for the
establishment of a non-profit corporation whose function is to sell bonds and build
A - 6
school facilities and in turn lease the facilities to the school district However it
does not solve the fundamental question of how the school facilities will be paid
for
(5) Section 53080 of the Government Code
This section sets forth the statutory development fees discussed above
(6) Chapter 2 5 (commencing with Section 53311) of Division 2 of Title 5 of the
Government Code
This chapter was established by the Mello-Roos Community Facilities Act of 1982
which allows for the creation of community facilities districts to fund public facilities
including schools The bonds issued to construct public facilities are repaid by
annual fees levied against parcels within a community facilities district
(7) Chapter 4 7 (commencing with Section 65970) of Division 1 of Title 7 of the
Government Code
This chapter was established by the School Facilities Act which allows a city or
county to levy development fees (known as ' SB 201 fees") on behalf of a school
district to fund interim classroom facilities Any fees levied pursuant to this chapter
reduce the ability of school districts to levy fees pursuant to Government Code
Section 53080 In practice these fees have been superseded by those set forth
in Government Code Section 53080
Additionally in Murrieta Valley Unified School District v County of Riverside the court
ruled that cities or counties can impose non-financial mitigation measures in addition to
the seven financial measures listed in Government Code Section 65996 Such non-
financial mitigation measures could include density reductions project phasing or senior-
only housing Nothing in SB 1287 prohibited the use of such non-financial mitigation
measures
Because SB 1287 was only recently adopted its legal interpretation remains uncertain
It appears that a city or county may not have the power to require financial mitigation
measures other than those specified in Government Code Section 65996 Most attorneys
agree however that a city or county can still deny a legislative action or require non-
financial mitigation measures Additionally Government Code Section 65996 allows the
use of Mello Roos Community Facilities Districts with charges in excess of State
mandated development fees Some attorneys believe that a city or county may have the
ability to require mitigation in excess of fees if the existing General Plan requires
adequate school facilities
However while SB 1287 may have limited the number of mitigation measures available
in no way did it preclude the requirement that development projects or land use actions
must comply with the California Environmental Quality Act ( CEQA ) The Legislative
A - 7
Counsel of California has issued an opinion that SIB 1287 "does not prohibit a city
county or city and county from considering the adequacy of school facilities in the course
of adopting or implementing a general plan zoning ordinance or other legislative land
use policy ' The impacts on the District of each project must be evaluated, and all
impl3cts must be mitigated to a IevPl of insignificance Hence the net effect of SIB 1287
is to limit the types of measures that may be used to mitigate school impacts but not the
total mitigation of impacts
In order to comply with the provisions of SIB 1287 while maintaining the spirit of school
facilities impact mitigation program that the City and District have evolved the District is
providing draft language for a condition of approval to be added to all development
projects and land use actions The City has applied the following or similar language
as a condition of approval to many development entitlements
Prior to the issuance of any building permit the developer shall enter into a school
facilities impact mitigation and reimbursement agreement with the appropriate
school district(s) for K-12 This condition maybe waived by the appropriate school
district
The District has modified this language as follows
Prior to the issuance of any building permit the developer shall mitigate the
impacts of the project on school facilities using any combination of measures
listed in Government Code Section 65996 or other legal means to a level
acceptable to the appropriate school district(s) for K-12 This condition may be
waived by the appropriate school district(s)
The District feels that this modified condition of approval language is legally acceptable
and roughly equivalent to though somewhat more restrictive than the previous condition
of approval language Its application will ensure adequate mitigation of school impacts
while allowing development to proceed The District therefore requests that the City
impose this language as a condition of approval for all development projects and land use
actions
A - 8
2-1
ATTACHMENT ' B'
SENATE BILL NO 1287
I
B - 1
STATUTES OF 1 1991--1992 REGULAR SESSION Ch 1354 `I
f
i
s outside the State of California SCHOOLS AND SCHOOL DISTRICTS—FACILITIES—FUNDING
i of time unrelated to the adop
be signed before a represents CHAPTER 1354
it of a birth parent in the state
tended period of time S B No 1287
to sign a consent for the adopts AN ACT to add and repeal Article 5(commencing with Section 17760)of Chapter 22 of Part to of
ct to revocation by reason of the Education Code to amend Sections 65995 and 65996 of and to add and repeal Sections
65995 65995 3 and 65996 of the Government Code and to repeal Section 34 of Chapter 1209
to read of the Statutes of 1989 relating to school facilities.
ed by the birth parent or paren [Approved by Governor September 30 1992]
nt or parents signer g the cons s Miled with Secret
ary of State September 30 1992
ns )
ency a written statement revo LEGISLATIVE COUNSELS DIGEST
to the birth parent or paten
form prescribed by the departmd SB 1287 School facilities
ent or delegated county adop (1) Under existing law the State Allocation Board is authorized to apportion fun(
rnia nor is physically present for school facilities projects for designated construction purposes on behalf of applii
a agency licensed or authorized school districts under the Leroy F Greene State School Building Lease-Purchase Lai
esides or is present for a p 1976
revoke consent may not be si This bill would repeal that program
rve P P grem pursuant to certain legislative findings a
.e Department of Social Se
January 1 1996
nt on the 121st day after si The bill would state that the changes specified above shall become operative only LL T
of the right to revoke consent ACA 6 is approved by a majority of the voters voting on that measure
the consent was signed which (2) Existing law authorizes local agencies to impose limited fees or other charges
4 against certain development projects to fund the construction or reconstruction of school
e to read facilities
has become permanent as pro This bill would authorize the levy of an additional fee for school facilities purposes on
ospective adoptive parents may certain residential construction of up to $1 per square foot of assessable space
becomes permanent as provid Existing law prohibits the legislative body of a local agency from levying development
fees or other requirements for the construction or reconstruction of schools other than
-tli parent or parents so reques ars nest return of the child puant to designated statutory authority
been placed have concerns that This bill would specify that this prohibition applies to both administrative and legisla
d are unfit or present a danger-ti'
trre action of the legislative body of a local agency
option is to report their concerns Under existing law development fees or other requirements to fund school construction
-sate child welfare agency Or reconstruction may be imposed against residential construction other than new con
ly return the child stracbon only where the resulting increase in assessable space as defined resulting from
s the construction exceeds 500 square feet Existing law also excludes designated school
1994 `-amity expenses from the construction or reconstruction purposes for which the
r independent adoption filed on "eloper fees or other consideration may be expended authorizes the expenditure of up
,ice shall be governed by the lad b 3%of the fees collected in any fiscal year for administrative costs incurred in collecting
t6 fees or other consideration defines the assessable space of residential development
Shall adopt emergency regal& sad the chargeable covered and enclosed space of commercial or industrial develop-
>kat,that are subject to a development fee or other requirement and specifies that the
Oar amount of the maximum developer fee or other requirement shall be increased for
government (ode if the Co kdkbon every 2 years
sins costs mandated by the fisting law also contains the legislative finding that the provisions of existing law
)0) for those costs shall 2 i�eribed in the preceding paragraph are declaratory of existing law
)0) of Division 4 of 'I5t1e 2 � Y
i for reimbursement does not ?his bill would repeal that legislative finding
be made from the State (� Existing law prescnbes the exclusive methods that may be required by local
Government
C onthe sa> des to mitigate environmental effects related to the adequacy of school facilities
bey
considering under the California Environmental Quality Act ( CEQA ) the approv
Constitution
eletlona by asterisks
Additions or changes y es Indicated b underline deletions by asterisks 5769
� r
t
a �J4
s
Ch 1354 STATUTES OF ly:
199
al or the establishment of conditions for the approval of a development project, which y
defined to mean a project undertaken for the purpose of development including a projeq shag
involving the issuance of a permit for construction or reconstruction Existing law alb perr
��.�er►r prohibits a public agency under CEQA or the Subdivision Map Act from denying stru
approval of a project on the basis of the adequacy of school facilities (2
This bill would prohibit a public agency in the exercise of its authority to adopt general per
plans zoning laws, and other land use legislation from either denying approval of a encl,
project on the basis of the adequacy of school facilities or imposing conditions, other than with
the requirement to pay the limited school facilities fees, on the approval of a project for area
the purpose of providing school facilities anen
The bill also would delete the definition of development project ds described above and co`ei
would specify that the restrictions described above upon the mitigation of environmentsl shall
effects under CEQA apply to both administrative and legislative action taken by a public Perm
agency under CEQA (3)
The bill would specify that these changes shall have prospective application only 19N
a the
(4) This bill would specify that the changes described in (2) and (3) are repealed on the 3aard
date that ACA 6 fails to receive the approval of a majority of the voters voting on thst meenr
measure ire
The people of the State of Californta do enact as follows .nder
(c) (
SECTION 1 It is the intent of the Legislature to enact a new program fo the atere
-- financing of school facilities in accordance with the following principles :Iou°t5
(a) Primary financial responsibility for school facilities should rest with school districts Ayme
(b) School districts should be authorized to raise a sufficient amount of revenue locill bnaiai
to finance a majority of their school facility needs
(c) The role of the state should be limited to (')
1 "` inei
(1) Usingstate funds to supplement the local revenues of those school districts ha x othe
PP � x othe
low assessed valuation i,.plical
(2) Using state funds to finance needed school facilities for those school districts the: id) Fc
have met or exceeded their debt capacity Li deveh
(3) Using state funds to provide interim school facilities for those school districts the a heret
are unable to supply the expected level of local revenues "clusiv,
SEC 2 krticle a (commencing with Section 17760) is added to Chapter 22 of Part J ode or
of the Education Code to read "local l
At limit
=arimur
Article 5 Repeal of Chapter '",denti
17760 This chapter shall remain in effect only until January 1 1996 and as of thg 't'th a
date is repealed unless a later enacted statute which is enacted before January 1 199t el TFe
deletes or extends that date �=.it:es
SEC 3 Section 6o995 of the Government Code is amended to read -'C3'acj
6a99a (a) Except for a fee charge dedication or other requirement authorized una` A_ lop—,
Section 53080 or pursuant to Chapter 4 7 (commencing with Section 6a970) ro r0' lures
charge dedication or other requirement shall be levied by the legislative bodv of a loa i \otr
agency against a development project as derined in Section 53080 tor the construction a zZur a is
reconstruction of school facilities ` "truc
(b) In no event shall the amount of any fees charges dedications or other req'2' I This
ments authorized under Section o3080 or pursuant to Chapter 4 7 (commencing 4. it
Section 65970) or both exceed the following '1j a
' (1) One dollar and fifty cents ($1 50) per square foot of assessable space in the csx� �as or
„ any residential development Assessable space for this purpose means all of* FC �
square footage within the penmeter of a residential structure not including any w r
-mill walkway garage overhang patio enclosed patio detached accessory structure or yr� a
I
area The amount of the square footage within the perimeter of a residential stlo ° �3f
.ate '� cep
5770 Additions or changes indfated by underline deletions by astensks
z
3
STATUTES OF
# 1991-1992 REGULAR SESSION Ch 1354
Y
of a development protect,which shall be calculated by the building department of the city or county issuing the budding
of development, including a p permit, in accordance with the standard practice of that city or county in calculating
reconstruction Existing law also Structural perimeters
Ddivision Map Act, from den (2) In the case of any commercial or industrial development twenty five cents ($0 25)
school facilities r per square foot of chargeable covered and enclosed space Chargeable covered and
se of its authority toadopt g enclosed space' for this purpose, means the covered and enclosed space determined to be
rom either denying approval t within the perimeter of a commercial or industrial structure not including any storage
or imposing conditions other areas incidental to the principal use of the development, garage parking structure
s on the approval of a protect fair imenclosed walkway or utility or disposal area The determination of the chargeable
covered and enclosed space within the perimeter of a commercial or industrial structure
nt protect, as described above, shall be made by the building department of the city or county issuing the building
on the mitigation of envi ronm porniit, in accordance with the budding standards of that city or county
legislative action taken by a public ,� (3) The amount of the limits set forth in paragraphs (1) and (2) shall be increased in
J 1990 and every two years thereafter according to the adjustment for inflation set forth
iave prospective application in the statewide cost index for class B construction as determined by the State Allocation
d in (2) and (3) are repealed on tb* Board at its January meeting which increase shall be effective as of the date of that
jonty of the voters voting on thath meeting The State Allocation Board shall not raise the amount of the distract matching
5 share calculated under Section 17705 5 of the Education Code as a result of the increase
adA under this paragraph until at least 90 days after the date of that increase
�011ow3 (c) (1) Notwithstanding any other provision of law during the term of any contract
to enact a new program for tlit entered into between a subdivider or builder and a school district, city county, or city and
lowing principles county whether general law or chartered on or before January 1 1987 that requires the
s should rest with school disU)c payment of a fee charge or dedication for the construction of school facilities as a
01, condition to the approval of residential development neither Section 53080 nor this
tficient amount of revenue,loc� chapter applies to that residential development.
(2) Any development protect for which a final map was approved and construction had
commenced on or before September 1 1986 is subject to only the fee charge dedication
es of those school districts ha or other e requirement the project
in any local ordinance in existence on that date and
spp1
fes for those school distnctar � (d) For purposes of Section 53080 and this chapter residential commercial or industri
til development does not include any facility used exclusively for religious purposes that
fes for those school districts` h thereby exempt from property taxation under the laws of this state any facility used
.r exclusively as a private full time day school as described in Section 48222 of the Education
es Code or any facility that is owned and occupied by one or more agencies of federal state
is added to Chapter 22 of PUtor local government. In addition commercial or industrial development includes but is
Wit limited to any hotel inn motel tourist home or other lodging for which the
mmmum term of occupancy for guests does not exceed 30 days but does not include any
' -: residential hotel, as defined in paragraph (1) of subdivision (b) of Section 50519 of the
oter Health and Safety Code
January 1 and as a� (e) The Legislature finds and declares that the subject of the financing of school
enacted before ore January 1� tA he hies with development fees is a matter of statewide concern For this reason the
t4 1APlature hereby occupies the subject matter of mandatory development fees and other
mended to read r S ti"elopment requirements for school facilities finance to the exclusion of all local
er requirement authorized tiD& Mutires on the subject
i�, with Section 65970)o
io a 1 0) Nothing in this section shall be interpreted to limit or prohibit the use of Chapter 2 5
the legislative body or �mencing with Section 53311) of Division 2 of Title a to finance the construction or
on o3080 for the construtb! 'instruction of school facilities
dedications or other > This section shall become inoperative on January 1, 1993 and shall remain inonera
Chapter 4 7 (commeDciiivv Until the date that AssemblyConstitutional Amendment 6 of the 1991-92 Regular
n fails to receive the approval of a majority of the voters voting on the measure
t assessable space in be� z that ate this section shall become operative
this purpose means 4 Section 65995 is added to the Government Code to read
icturt not including sn Z �w65995 (a) Fxcept for a fee charge dedication or other requirement authorized under
d accessory structure' on 53080 or pursuant to Chapter 4 7 (commencing with Section 65970) no fEe
nneter of a r(Yidenta�sii� �
v e dedication or other requirement shall be levied by the legislative body of a local
�
ons by asterisks Additions or changes Indicated by underline deletions by asterisks 5771
v
7)71 rt J
1Y
Ch 1354 STATUTES of 14}
a ••. 1t91-1992
13 agency against a development project, as defined m Section 53080 whether by adman
` tive or legislative action for the construction or reconstruction of school faeZibm (f) Nothu
(rouimencin
(b) In no event shall the amount of any fees charges dedications or other regS rKonstruct
ments authorized under Section 53080 or pursuant to Chapter 47 (commencing WA
Section 65970) o: both exceed the following-
e)ndmien
1 Sin
(1) One dollar and fifty cents ($1 50)per square foot of assessable space in the case a( d the vote
any residential development. Assessable space ' for this purpose means all of tw SEC 5
square footage within the perimeter of a residential structure not including any carpA 6o995 3
- walkway garage overhang patio enclosed patio detached accessory structure or simlill
-- area The amount of the square footage within the perimeter of a residential structunI Mnt of or
on
at
shall be calculated by the building department of the city or county issuing the buildias me of
permit, in accordance with the standard practice of that city or county in calcula* <overning 1
structural perimeters Rbparag w
JV Wnstructior
v (2) In the case of any commercial or industrial development twenty five cents ($oA (b) This s
+ per square foot of chargeable covered and enclosed space Chargeable covered and Amendment
�.. enclosed space for this purpose means the covered and enclosed space determined to be of the rote
within the perimeter of a commercial or industnal structure not including any storage
areas incidental to the principal use of the development, garage, parking structum SEC 6
unenclosed walkway or utility or disposal area The determination of the chargeable 6z)996
covered and enclosed space within the perimeter of a commercial or industrial structmt mvtronmen
shall be made by the building department of the city or county issuing the but7dmg approval or
permit in accordance with the building standards of that city or county defined in
(3) The amount of the limits set forth in paragraphs (1) and (2) shall be increased a Nblic Reso
1990 and every two years thereafter according to the adjustment for inflation set forth L) Chapt
v in the statewide cost index for class B construction as determined by the State Allocatioe 2 Chapt,
Board at its January meeting which increase shall be effective as of the date of that L Chapt�
meeting The State Allocation Board shall not raise the amount of the distract matchnig
share calculated under Section 17705 5 of the Education Code as a result of the mcreset �41 Artic1E
under this paragraph until at least 90 days after the date of that increase Education C
(c) (1) Notwithstanding any other provision of law during the term of any contrad 2 Sectia
entered into between a subdivider or builder and a school district city county or city and 2 Chapti
county whether general law or chartered on or before January 1 1987 that requires the Government
payment of a fee charge or dedication for the construction of school facilities as it (7) Chapu
condition to the approval of residential development neither Section 53080 nor this Government
chapter applies to that residential development. (b) No pu
(2) Any development project for which a final map was approved and construction bad 1 -e blic F
commenced on or before September 1 1986 is subject to only the fee charge dedicab= ieny approv
or other requirement prescribed in any local ordinance in existence on that date and t (cl This sF
applicable to the project :e until th
(d) For purposes of Section 53080 and this chapter residential commercial or industrt j xsaion fail
al development does not include any facility used exclusively for religious purposes that t Lm as o I a
is thereby exempt from property taxation under the laws of this state any facility axd "EC 7
exclusively as a private full time day school as described in Section 48222 of the Educabot 6,996 (a
Code or any facility that is owned and occupied by one or more agencies of federal stsil-
or local government In addition commercial or industrial development includes bat0`al or
ie �nmor
not limited to any hotel inn motel tourist home or other lodging for which the
maximum term of occupancy for f th
p y guests does not exceed 30 days but does not include si0 � )
residential hotel as defined in paragraph (1) of subdivision (b) of Section o0519 of 00 of th
Health and Safety Code (1) ChaotE
(e) The Legislature finds and declares that the subject of the financing of Scb00i (2) Chaotc-
facilities with development fees is a matter of statewide concern For this reason tW Q) Cnaptr
Legislature hereby occupies the subject matter of mandatory development fees and otho 1 (4) article
development requirements for school facilities finance to the exclusion of all cation C
Y measures on the subject
5) S-ctior
` 5772 Additions or changes Indicated by underilne deletions by asterisks
T-(-
L
r
4
STATUTES OF-1 1l91-
1992 REGULAR SESSION Ch 1354
action 53080 whether by ad Nothing to this section shall be interpreted to limit or prohibit the use of Chapter 2 5
reconstruction of school fa n
(commencing with Section 53311) of Division 2 of Title 5 to finance the construction or
irges dedications or other ownstruction of school facilities
to Chapter 4 7 (commencing (g) This section shall remain in effect only until the date that Assembly Constitutional
r Amendment 6 of the 1991-92 Regular Session fails to receive the approval of a majority
it of assessable space in the d the voters voting on the measure and as of that date this section is repealed
or this purpose means all o SEC 5 Section 65995 3 is added to the Government Code to read
tructure not including any "65995 3 (a) In addition to the fee charge dedication or other requirement specified in
iched accessory structure or a F subdivision (b) of Section 65995 an additional fee charge dedication or other require-
perimeter of a residential stru ment of one dollar ($1) per square foot of assessable space may be levied by the
city or county issuing the but governing board of a school district against that residential construction described in
that city or county in calcula subparagraphs (B) and (C) of ara p graph (1) of subdivision (a) of Section 53080 for the
wastructton or reconstruction of school facilities
elopment twenty five cents ( (b) This section shall remain in effect only until the date that Assembly Constitutional
d space Chargeable cove Amendment 6 of the 1991-92 Regular Session fails to receive the approval of a majority
ind enclosed space determined of the voters voting on the measure and as of that date this section is repealed
.ructue not including any sto
omens garage parking s
SEC 6 Section 65996 of the Government Code is amended to read
oment tru
e determination of the charg 65996 La) The following provisions shall be the exclusive methods of mitigating
commercial or industrial stru ovironmental effects related to the adequacy of school facilities when considering the
ity or county issuing the bnu7 q)proval or the establishment of conditions for the approval of a development project, as
that city or county 4 &fted in Section 53080 pursuant to Division 13 (commencing with Section 21000) of the
ns (1) and (2) shall be incr Public Resources Code
e adjustment for inflation setf Chapter 22 (commencing with Section 17700) of Part 10 of the Education Code
determined by the State All Chapter 25 (commencing with Section 17785) of Part 10 of the Education Code
)e effective as of the date,, Chapter 28 (commencing with Section 17870) of Part 10 of the Education Code
he amount of the district
)n Code as a result of the in
Article 2 5 (commencing with Section 39327) of Chapter 3 of Part 23 of the
date of that increase Mucation Code
during the term of any con @ Section 53080 of the Government Code
)ol district city county or city Government Code (commencing with Section 53311) of DivisiF,)n 2 of title 5 of the
January 1 1987 that req
struction of school facilittes fl Chapter 4 7 (commencing with Section 65970) of Division 1 of Title 7 of the
t neither Sect-ion 53080 nor Government Code
�b No public agency shall pursuant to Division 13 (commencing with Section 21000) of '
as approved and constructions 2* Public Resources Code or Division 2 (commencing with Section 66410) of this code
to only the fee charge d imy approval of a project on the basis of the adequacy of school facilities
ce in existence on that date tihis section shall become inoperative on January 1 1993, and shall remain inooera
we u� until the date that Assembly Constitutional Amendment 6 of the 1991-92 Regular
esidenbal commercial or in 'awn fails to receive the approval of a majority of the voters voting on the measure,
s�ively for religious piirposets !22 as of that date this section shall become operative
ws of this state any facilits/t SEC 7 Section 65996 is added to the Government Code to read
i in Section 48222 of the Edn "6 (a) The following provisions shall be the exclusive methods of mitigating
or more agencies of federal, Onlronmental effects related to the adequacy of school facilities when considering the
trial development includes 2Sroval or the establishment of conditions for the approval of a development project by
or other lodging for w trative or legislative action pursuant to Division 13 commencing with Section
i 30 days but does not uiclu UW)of the Public Resources Code
.,ision (b) of Section 50519f (1) Chapter 22 (commencing with Section 17700) of Part 10 of the Education Code
bji,-t of Of (2) Chapter 25 (commencing with Section 1778o) of Part 10 of the Education Code
id( concern For this greasod 0) Chapter 28 (commencing with Section 17870) of Part 10 of the Education Code
1awry devclopnif nt fees and (4) Article 2 ) (commencing with Section 39327) of Chapter 3 of Part 23 of the
r t tht exclusion of all ?A61Catlon Code
�) Section oJO80 of the Government Code
ions by asterisks Additions or changes Indicated by underiine deletions by asterisks 5773
t
s k TC y7
ti r
ag
Ch 1354 STATUTES OF I
lk191-1992 REGL
(6) Chapter 25 (commencing with Section 53311) of Division 2 of Title 5 of bill would si
Government Code at contain design
(7) Chapter 4 7 (commencing with Section 65970) of Division 1 of Title 7 ofThe bill would pr
Government Code 015ting resources
(b) No public agency shall pursuant to Division 13 (commencing with Section 21000)at ?nbhc Instruction
the Public Resources Code or Title 7 (commencing with Section 65000) deny approval of t This bill would
project on the basis of the adequacy of school facilities or impose conditions on t4 astncts when suff
approval of a project for the purpose of providing school facilities thal, exceed t6 (2) The California
amounts authorized pursuant to this chapter :istricts for certain
(c) This section shall have prospective application only and shall not affect any actft dares for making tl
taken by a local agency prior to the effective date of this section I lhnd to pay the co
(d) This section shall remain in effect only until the date that Assembly Constitubocd ;rocedures for ciair
A,mendment 6 of the 1991-92 Regular Session fails to receive the approval of a maj This bill would pr
of the voters voting on the measure and as of that date this section is repeal Clams Find for co
SEC 8 Section 34 of Chapter 1209 of the Statutes of 1989 is repealed ..at local agenc es
-eimbursement for
SEC 9 (a) The Legislature finds and declares that paragraph (2) of subdivision(4
of Section 53080 of the Go✓ernment Code and paragraph (1) of subdivision (b) of Seebot The people of the
6o995 of the Government Code as amended by Chapter 1209 of the Statutes of 1989 ut SECTION 1 Sec
declaratory of existing law
(b) This section shall become operative on the date that Assembly Constituboed �1'-20 0 (a) The
-lmendment 6 of the 199192 Regular Session fails to receive the approval of a majority of (1) The family is
the voter voting on the measure are for prepare ar
SEC 10 Sections 1 and 2 of this act shall become operative only upon the apprwil 12) Social resea-cl-
of Assembly Constitutional Amendment 6 of the 1991-92 Regular Session by a major# muse of increased A
of voters voting on the measure mininal activity
(3) The lack of kn
usu-ne parental res
iao contribute subst
COLLEGES AND UNIVERSITIES—COMMUNITY COLLEGES— (4) Because the st
PARENTING SKILLS AND EDUCATION COURSES usociated with the c
ind vital interest in
CHAPTER 1355 ib) The Legislature
L-d effective means t
S B No 1307 t -1 use the public e(
l gportunity to arquir
AN aCT to add Section a1220 5 to the Education Code relating to parenting education i c iwledge should ine
[kpproved by Governor September 30 1992] il) Child de,elopmE
[Filed with Secretary of State September 30 1992] i �l E,fective Darenr
3i PrF Pit on of c
LEGISLATIVE COUNSELS DIGEST 1) \utrton
SB 1307 Watson Parenting education housenold ,
(1) Existing law directs the State Department of Education to grant awards Pe onal and a
z,Decified to support the implementation in school districts of education programs regI4 M Method, to pron
ing family relationships and parenting
This bill would require commencing with the 1993-94 fiscal year that the adopt ) Eftecti�e dec sio
course of study for grade 7 or 8 in each school district include a one-semester course g 31 gamily and indi%
parenting skills and education as specified thereby imposing a state mandated low rl Commencing kit
program The bill would require that all pupils beginning grade 7 on or after July L 5 shall include the
1993 be offered that course in grade 7 or 8 or both The bill would require the Sta* " cation All puoil,
Department of Education to supply each school district that includes grade 7 or S wr�a ' 3e or ita equnaier,
sample curriculum for a course addressing parental skills as specified �� the State Deoarr
In addition commencing with the 1993-94 fiscal year the bill would authorize com-Mov i Mde i or b a ami
ty colleges to offer parenting skills and education classes to interested incuvid5sl� =r"-ies.er course o
5774 Additions or changes Indicated by underline deletions by asterisks Additions
R Tc 14 z
h
ATTACHMENT "C"
LEGISLATIVE COUNSEL OPINION
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Sacramento, California jW4�I rk ��
T�WInaw-"" December 4, 1992 G�"� +*aa°e1"ee
09MM saeelew
Honor-able Willie L. Brown, Jr.
219 State Capitol
School Facilities Fees - 430455
Dear Xr Brown.
QUESTION
Does Chapter 1354 of the Statutes of 1992 prohibit a
city, county, or city and county from considering the adequacy of
school facilities in the course of adopting or implementing a
general plan, zoning ordinance, or other legislative land use
policy?
OPINION NO 1
Chapter 1354 of the Statutes of 1992 does not prohibit a
city, county, or city and county from considering the adequacy of
school facilities in the course of adopting- or implementing a
general plan, zoning ordinance, or other legislative land use
Policy
ANALYSTS NO 1
Before assessing the effect of Chapter 1354 of the
Statutes of 1992' , we consider the existing law regarding the
relationship between the development of real property and school
facilities construction
1 This measure is the chaptered version of Senate Bill No
1287 of the 1991-92 Regular Session
Honorable Willie L. Brovn, Jr. - p. 3 - #30455
Section 65995 also contains two provisions expressing
the Legislatures intent to forbid any local legislation, except
as explicitly authorized under the state laws discussed above, _
that would condition the approval of development according to the -
impact upon school facilities. First, subdivision (a) of section=-
65995 prohibits the legislative body of any local agency,
including the governing board of a school district (see California
Rida. Zndustry kagni V. Governing J ,,, 206 Cal. App. 3d 212, 224) ,
from levying any tee or other requirement against a development
project to fund the eohstruetion or reconstruction of school
facilities except as authorized under Section 53080 or chapter 4.7
(subd. (a) ; See. 65995) .
Second, subdivision (a) of Section 65995 expressly
declares the intent of the Legislature to preempt local
legislation that would require fees or other consideration to be
paid as a condition of the approval of development. In this
regard, although Section 65995 does not specifically exclude a
local measure that authorizes the denial of a development project
on the basis of the adequacy of school facilities, we think that
the restriction placed by the Legislature upon local legislation
that would require that the impact of a development project on
school facilities be mitigated would be construed to apply equally
to a local standard that a development project be denied in the
absence of that mitigation. A statute is to be construed so as to
be given a reasonable result consistent with the legislative
purpose, in light of the context of the legislation and its
apparent objective (Cossack v Qjty = Los Angeles, 11 Cal 3d
7261 732-733 , see Clean = Constituency v California state &-r
Resources , 11 Cal 3d 801, 813)
in addition to the school-related conditions upon
development that may be established by local legislative action
pursuant to Section 53080 or Chapter 4 7 , a city or county
generally possesses the authority to impose conditions upon the
approval of a development project relative to the project's
potential burden upon public services or other environmental
impact concerns , this authority may be exercised under existing
state law pursuant to the California Environmental Quality Act, as
set forth in Division 13 (commencing with Section 21000) of the
Public Resources Code (hereafter "CEQA" , see Secs 21002 and
21002 Z, P R C ��, H- 1s HQ_ egyners sn v City Council,
83 Cal App 3d 515, 521) and the Subdivision Map Act (Div 2
(commencing with Sec 66410) , Title 7) However, Section 65996,
which also is contained in Chapter 4 9, identifies Section 53080
and other specific statutory provisions as the exclusive methods
of mitigating environmental effects under CEQA with regard to
conditioning the approval of a development project on the adequacy
of school facilities, and prohibits any public agency from denying
Honorable Willie L. Brown, Jr. - p• 2 - #30455
I. Existing LaW
Prior to January 1, 1987, development projects were
potentially subject to school facilities fees or other
requirements imposed by cities and counties either pursuant to
Chapter 4 .7 (commencing with Station 65970) of Division 1 of
Title 7 or the Governmant Code (hereafter "Chapter 4.7") or
pursuant to their police power generally (see Cad Entjrnri�ses.
inc, v Grossmont Union High gchool Dist , 39 Cal, 3d 878) Ahern
school overcrowding is demonstrated to exist, Chapter 4.7
generally prohibits a city or county from approving a residential =
development unless it first requires, except as specifiad, that
land be dedicated, fees be paid, or both, for classrooms and
related facilities, except as specified (sacs 65972 and 65974) .
Approval of a residantial development includes, for this purpose,
the approval of an ordinance rezoning property to a residential
use, the granting of a discretionary permit for residential use,
or the approval of a tentative subdivision map for residential
purposes (see Sec 65972)
As of January 1, 1987, however, the law governing school
facilities fees and other requirements was amended by Chapter 887
of the Statutes of 1986. Under that chapter, the Legislature
added Section 53080, granting to school districts the express
authority to levy developer fees and other requirements as "a
reasonable method of financing the expansion and construction of
school facilities resulting from new economic development within
the district" (subd (e) , Sec 7, Ch 887 , Stats 1986)
That authority is expressly made subject, however, to
the restrictions set forth in Chapter 4 9 (commencing with Section
65995) of Division 1 of Title 7 (hereafter "Chapter 4 9" , para.
(1) , subd (a) , Sec 53080) Included among those restrictions is
Section 65995 , which limits the total amount of the developer fees
and other requirements to fund the construction or reconstruction
of school facilities that may be levied by school districts under
Section 53080, by a city or county under Chapter 4 7 , or both, to
$1 50 per square foot of assessable space, in the case of
residential development, and $0 25 per square foot of chargeable
covered and enclosed space, in the case of commercial or
industrial development (subd (b) , Sec 65995) Those dollar
limits are increased periodically according to a designated
adjustment for inflation (para (3) , subd (b) , Sec 65995)
2 All section references are to the Government Code, unless
otrerwise indicated
k'7 c Iq j
Honorable Willie L. Brown, Jr. - P. 4 - #30455
approval of a development project on the basis of the adequacy of
school facilities pursuant to CEQA or the Subdivision Map Act.
The first decision of record in Which section 65996 vas
judicially construed is Mira Develogmant soT V. City = N=
cgs, 205 Cal. App. 3d 1201 (hereafter "JUra") , a casa in which a
city council denied a razoninq application that was prerequisite
to the Approval of a proposed residential development project. In
that case, the city council's decision was alleged by the
developer to have been based upon the inadequacy of school
facilities and, therefor&, to have violated the prohibition sat
forth in Section 65996 (fin, supra, p. 1217)
The court in Mira began its analysis by distinguishing
an application for a "development project, " to Which section 65996
expressly applies, from a request for a zoning amendment. The
court held that a governmental response to an application for the
approval of a development project is an adjudicative act, meaning
an act that requires the application of an existing rule to a
specific net of existing facts (==, supra, pp 1217-1218 ; see
Landi v County = Monterav, 139 Cal App. 3d 934, 936) In
contrast, the court characterized a governmental response to a
proposed zoning amendment as a legislative act, which involves the
formulation of a generally applicable rule or policy (Mira, supra,
p 1218 , �1, v County o& Monterey, supra, p 93 6)3
Pursuant to that distinction, the Mira court
characterized Section 65996 as a restriction upon only the
adjudicative authority of that agency. The court refused to
"broaden" the meaning of Section 65996 to include any restriction
upon a public agency 's authority over proposed zoning amendments
or over other matters involving the agency' s exercise of its
legislative powers (Mira, supra, p 1218)
In declining to overturn the city council ' s action on
the basis of Section 65996 , the Mira court did not discuss the
applicability to the city council ' s action of subdivision (e) of
Section 65995, or of any other aspect of the preemption doctrine
Thus , the Mira decision failed to address expressly whether
subdivision (e) of Section 65995, rather than Section 65996 , would
be construed to preempt the city council , in the exercise of its
legislative powers, from denying a rezoning application on the
basis of school facilities impact
3 As a legislative act, a zoning decision is afforded more
deference than a public agency' s adjudicative decisions (Mira
supra , p 1218 &gM-P.J pevelooment Co v City of Costa Mesa , 28
Cal 3d 511 , 522)
Honorable Willie L. Brown, Jr. - p 5 - #30455
Subsequent judicial decisions have elaborated, however,
upon the scope of Sections 65995 and 65996 in that regard.
}j1_111am ,&, Hart tini0II High 5shQ9l n1st, v. Regional planning Ccm. , _
226 Cal. App �d 1612 (hereafter "H=") , involved the refusal of -
a county to consider the school facilities impact of a proposed
zoning change. The court declared that subdivision (a) of Section
65995 preempts only "requirements for school finance that a local
- agency will impose on a development oroiect" (emphasis in
original) . The court explained that, because the local
legislative decision in Mira did not involve requirements to be
imposed on a development project, but, rather, the legislative
enactment of "land-use po icias" (emphasis in original) , that _
decision was not preempted by Section 65995 or any other provision
of Chapter 4 .9 (sea Murrieta valley Unified Sal gist, v. County
4l Riverside, 228 Cal App. 3d 1212, 1230; hereafter "Murrieta") .
Based upon that distinction, the court concluded that the county
was not restricted by state law from considering school facilities
impact with respect to its decision to grant or deny the proposed
zoning change (Id , pp. 1626-1627)
A similar analysis was employed in Murrieta, supra. In
that case, the county approved an amendment to its general plan to
permit additional development to occur as a matter of land use-
policy, without considering, pursuant to the requirements of CEQA,
the school facilities impact of that general plan amendment (Id.-,
pp 1218-1219) The court described a general plan as a "basic
land use charter governing the direction of future land use in the
local jurisdiction, " and held that the amendment of a general plan
is a legislative act that does not involve the approval of a
"development project" for purposes of section 65996 (Id , pp
1230-1231) Further, the preemption in subdivision (e) of Section
65995 was held by the court to relate only to the financing of
school facilities with development tees, "a far cry from stating
that a public agency cannot include in a general plan amendment
land use and development objectives and standards to mitigate the
amendment ' s potential negative effects on adequacy of school
facilities" (Id , p 1234 , fn 16)
The court concluded, consequently, that neither
subdivision (e) of Section 65995 nor section 65996 preempts a
county, when considering a general plan amendment that may
adversely affect the existing condition of inadequate school
facilities in a school district, from "considering and providing
feasible land use and development mitigating measures" as required
by CEQA The court suggested that these measures could include,
for example, the reduction of residential densities or the
controlled phasing of residential development within the
attendance areas of the school district having inadequate school
facilities (Murrieta, supra , p 1234)
Honorable Willi& L. Brown, Jr. - p. 6 - 00455
The restrictions established in Chapter 4.9 have been
construed by the courts, accordingly, to apply to the local
imposition of conditions on the approval of individual development
projects, but not to the local adoption or amendment of general
land use policies.
To summarise, Section 65995 precludes local agencies,
including cities and counties, from adopting any legislative
requirement, except to the axtent authorised by Section 53080 and
Chapter 4 71 that imposes fees as a condition to approval of a
development project in order to reduce the project's negative
impact on school facilities (see tea, supra, p. 1234, fn.
16) . Section 65996, in our view, r4Quires that, in the exercise
of local adjudicative authority to require under CEQA that the
school facilities impact of a development project be mitigated,
only the statutory remedies identified in that section may be
utilized, with the result that a local governmantal agency may not
employ CEQA to require individual development projects to
otherwise mitigate school facilities as a condition of receiving
approval
However, pursuant to the authority discussed above, we
conclude that Chapter 4 .9 does not prohibit a city, county, or
city and county from considering the adequacy of school facilities
in the course of adopting or implementing legislative land use
policy in the form, for example, of a general plan or zoning
ordinance
We next must determine the extent to which the changes
in Chapter 4 9 made by Chapter 1354 of the Statutes of 1992 will
alter the existing law described above
II 7ffect of Chapter 1354 of the Statutes _of 1992
Chapter 1354 of the Statutes of 1992 amends Sections
65995 and 65996 , and adds and repeals those sections, with the
effect that additional language is added to those sections,
effective January 1, 1993 , but it Assembly Constitutional
Amendnent No 6 of the 1991-92 Regular Session fails to receive
the approval of a majority of the voters voting on that measure,
Sections 65995 and 65996 will revert to the versions of those
sections in effect under existing law as described above This
analysis will address the changes made by Chapter 1354 of the
1,2 i( ��
Honorable Millie L. Brown, Jr. - p. 7 - #30455
Statutes of 1992 t? Sections 65995 and 65996 that will take effect
on January 1, 1993 .
We initially consider the provisions of Chapter 1354 of
the Statutes of 1292 that revise Section 65995.
Chapter 1354 of the Statutes of 1992 revises subdivision
ja) of Section 65995 to read as follows:
1165995. (a) Except for a fee, charge,
dedication, or other requirement authorized under
Section 53080, or pursuant to Chapter 4.7
(commencing with section 65970) , no fee, charge,
dedication, or other requirement shall be levied by
the legislative body of a local agency against a
development project, as defined in Section 53080,
whether = administrative = legislative Actign,
for the construction or reconstruction of school
facilities
* *" (New wording indicated
in underline )
Thus, while the current provisions of Section 65995
prohibit cities, counties, or other local agencies from levying
any fee or other requirement, except to the extent authorized by
Section 53080 and Chapter 4 7 , as a condition to approval of a
development project in order to fund the construction or
reconstruction of school facilities, Chapter 1354 of the Statutes
of 1992 Will revise that section to specify that this prohibition
applies to the levying of tees or other requirements "whether by
administrative or legislative action "
Generally speaking, a legislative act is described as a
governmental act that prescribes a new policy or plan, an
administrative act, by comparison, is an act undertaken to carry
out the legislative policies and purposes established by the
legislative body (Fishman v Cjy gJ Palo ltc, 86 Cal App. 3d
506 , 509) An act is administrative, rather than legislative, if
it involves, for example, the determination of specific rights
under existing law With regard to a specific tact situation
(Mountain pefe g Laaque v BAG D Supgrvisors, 65 Cal App 3d
723 , 728-729)
4 Chapter 1354 of the Statutes of 1992 also adds Section
65995 3 , which will be discussed in Analysis No 2
Ar� 14
Honorable Willi* L. Brown, Jr. j- p. 8 - #30455
Based upon that distinction, the approval of a
development project, including the issuance of any permit, the
granting of zoning variances and conditional use permits, and the
approval of tentative subdivision maps is considered an _
administrative act (Errt, supra, p. 1625 t Saindl v. County 21
Monterey, supra, p. 936) . By contrast, the approval of a zoning
amendment or the amendment of a general plan is riot limited in
scope to a specific attempt to develop, and is characterized,
therefore, as a legislative act (Hart, supra, p 1625; see
M rrieta, supra, pp 1230-1231) .
Thus, Section 65995, as revised by Chapter 1354 of the
Statutes of 19920 will expressly prohibit a city, county, city and
county, or other local agency from either establishinq legislative
standards, or applying any legislatively established standard, so
as to require, as a condition of the approval of any development
project, that a fee be paid or other requirement be met for the
purpose of funding school facilities construction or
reconstruction, other than as levied pursuant to section 53080 or
chapter 4 . 7 .
As discussed above, existing law already limits the
exercise of legislative authority to impose a school facilities
too or other requirement against a development project. Section
65995, in its current form, prohibits the legislative body of any
local agency from establishing any requirement that a development
project comply with a school facilities fee or other requirement,
other than pursuant to Section 53080 or chapter 4 7 , and preempts
the subject matter of the financing of school facilities from that
source as a matter of statewide concern (subds (a) and (e) , Sec
65995) Further, Section 65996 currently identities Section 53080
and other specific statutory provisions as the exclusive methods
of nitigating environmental effects under CEQA with regard to
conditioning the approval of a development project on the adequacy
of school facilities, and prohibits any public agency from denying
approval or a development project on the basis of the adequacy of
school facilities pursuant to CEQA or the Subdivision Map Act
Consequently , while existing law limits the authority of
a local agency to require that a development project provide
financial mitigation of its school facilities impact in the course
of the agency ' s administrative implementation of Section 53080 and
cEQA, the revision to Section 65995 made by Chapter 1354 of the
Statutes of 1992 further prohibits a local agency from requiring
that mitigation in its administrative implementation of any other
legislative authority
/'i C
' Nonorabls Willie L. Brown, Jr. - p. 9 - #30455 _
We turn next to the provisions of Chapter 1334 of thus;;
Statutes of 1992 that amend $action 65996. Section 659960-aS*,
revised by Chapter 1354 of the Statutes of 1992, reads as follow
065996. lal The following provisions shall
be the exclusive methods of i.itigating
environmental effects related to the adequacy of
school facilities when considering the approval or
the establishment of conditions for the approval of
a development project -- d_f r_d L
by administrative 2r 1Qislative Actign pursuant to -
Division 13 (commencing with section 21000) of the
Public Resources Code:
"fa} 1.11 Chaptar 22 (commencing with Section
17700) of Part 10 of the Education Code.
R{i�} Ial Chapter 25 (commencing with Section
17785) of Part 10 of the Education Code.
11 fe} J.,U Chapter 28 (commencing with Section
17870) of Part 10 of the Education Code.
"+* - 1-41 article 2.5 (commencing with Section
39327) of Chapter 3 of Part 23 of the Education
Code
n+e-} UL Section 53080 of the Government
Code
n{-f} I_U Chapter 2 5 (commencing with Section
53311) of Division 2 of Title 5 of the Government
Code.
Chapter 4 7 (commencing with Section
65970) of Division 1 of Title 7 of the Government
Code
" (b) No public agency shall , pursuant to
Division 13 (commencing with Section 21000) of the
Public Resources Code or
Title 7
(co me cing with Section 63000) , deny approval of a
project on the basis of the adequacy of school
facilities_, or impose conditions an the approval of
n project = =t purpose 21 trovidina school
facilities that exceed tht amounts authorized
pursuant _,t�o this chanter.
Honorable Willie L. Brown, Zr. - p. 10 - #30455
"I.QL Ala section shall have urosDectiye
acnl ication only, And pal I14At= A= action
taken by 3L local agency prior S4 = offictive dAtA
42 this section.
"jgl This section shall remain is stf s= gnlY
until = wag that A►sQeUly' Co stitutional
Amendment Qi =j 1991-92 R=lar Sgi2t1 fails 12
receive pproval j2.1 a majority of the voters
yot ing 2n th! measure. And A4 21 that I&&Q this
section I& revealed." (Changes in wording
indicated in strikeout and underline )
We begin with the first substantive revision mad* to
Section 65996 by Chapter 1354 of the Statutes of 1992 , to tha
affect that the limitations sot forth in that section expressly
apply to local mitigation "by administrative or legislative
action" of school facilities impact pursuant to CEQA.
Section 21082 of the Public Resources Code, a provision
of CEQA, expressly authorizes all public agencies to adopt local
legislative measures for the evaluation of projects and the
preparation of environmental impact reports and negative
declarations pursuant to CEQA Consequently, this first revision
to Section 65996 will specify that the restrictions set forth in
that section apply not only to local administrative action taken
under CEQA to require that a development project mitigate its
Impact on school facilities, but also to mitigation requirements
under CEQA that may be imposed under local legislative measures,
as may be adopted pursuant to Section 21082 of the Public
Resources Code
The second substantive revision to Section 65996 made by
Chapter 1354 of the Statutes of 1992 addresses the provision of
that section that currently prohibits a public agency from denying
approval of a pro3ect on the basis of the adequacy of school
facilities pursuant to CEQA or the Subdivision Map Act This
revision deletes the specific reference to the Subdivision Map
Act , as set forth in Division 2 (commencing with Section 66410) of
Title 7, instead applying that prohibition to the exercise of
local authority under Title 7 (commencing with Section 65000) in
its entirety (hereafter the "Planning and Zoning Law")
The Subdivision Map Act provides for the regulation and
control of the design and improvement of subdivisions and grants
power for that purpose to the iegislative bodies of local
agencies, including the authority to adopt ordinances to regulate
the design and improvement of subdivisions (Secs 66411 , 66418 ,
66419 , and 66421)
Honorable Willis L Brown, ZTr• - p. 11 - #30455
The Planning and Zoning Law, which include the
subdivision Map Act, also includes, for example, Chapter 3
(commencing with section 65100) of Division 1 of Title 7, which
contains various provisions governing the adoption or amendment of
a general plan. Every city or county, whether chartered or
general law, is required under that chapter to adopt a
comprehensive, long-term general plan, containing specific
mandatory elements for the physical development of the city or
county (Seca. 65300, 65302, and 65700) .
Also within the Planning and zoning Law is Chapter 4
(commencing with Section 65800) of Division 1 of Title 7, which
sets forth certain limitations upon local authority over zoninq.
The power of a city or county to zone is not granted by the
Legislature, but derives from the broad "police powers" conferred
on them by Section 7 of Article XT of the California Constitution
(Xaftnhnar, v city council , 31 Cal. App. 3d 48, 62 , disapproved on
other grounds, Associated Eame Builders etc. , Inc. v. cry 21
Livermore, 18 Cal 3d 582, 596, fn. 14) and, in the case of
charter cities , and cities and counties with authority over
municipal affairs, from the charter (Secs 5 and 6, Art XI, Cal
Const s !�,itX 21 jai An_ sles V. Department = Health, 63 Cal. App.
3d 473 , 479)
Thus, this revision to Section 65996 prohibits a public
agency from denying approval of a project on the basis of the
adequacy of school facilities, not only when acting pursuant to
the subdivision Map Act, but also when acting pursuant to other
provisions of the Planning and Zoning Law, including, but not
limited to, the adoption or amendment of a general plan or zoning
law Although the adoption or amendment of a general plan or
zoning law, as a legislative action, ordinarily involves the
establishment of categorical land use policy rather than the
approval of a development project (see Murrieta, supra, pp 1230-
1231 , Hart , supra, pp 1626-1627) , the apparent effect of this
revision will be to specifically prohibit the inclusion within a
general plan or coning law of any provision that would authorize
the denial of individual development projects on the basis of the
adequacy of school facilities
In addition to revising Section 65996 to prohibit a
public agency, pursuant to CEQA or the Planning and Zoning Law,
from denying approval of a project on the basis of the adequacy of
school facilities , Chapter 1354 of the Statutes or 1992 adds an
express prohibition upon the imposition of conditions on the
approval of a project for the purpose of providing school
facilities that exceed the amounts authorized pursuant to
/2 i c 4 y,
Honorable Willis L. Brown, Jr. - p. 12 - #30455
Chapter 4.9 . Thus, Section 65996 will specifically preclude a
public agency from exercising its authority under CEQA or the
Planning and Zoning Law, as discussed above, to require, that
school facilities fees or other requirements, in excess of the
amounts authorized under Chapter 4 9, be paid on behalf of any
development project as a condition of approval.
To summarize, while existing law limits the authority of
a local agency to require that a development project provide
financial mitigation of its school facilities impact in the course
of the agency's administrative implementation of Section 53080 and
CEQA, the revision to Section 65995 made by Chapter 1354 of the
Statutes of 1992 further prohibits a local agency from requiring
that mitigation in its administrative implementation of any other
legislative authority.
The revisions made to Section 65996 made by Chapter 1354
of the Statutes of 1992 specify that the restrictions set forth in
that section apply not only to local administrative action taken
under CEQA to require that a development project mitigate its
impact on school facilities, but also to mitigation requirements
under CEQA that may be imposed under local legislative measures,
as may be adopted pursuant to Section 21082 of the Public
Resources code to addition, those revisions specifically
prohibit the inclusion within a general plan or zoning law of any
provision that would authorize the denial of individual
development projects on the basis of the adequacy of school
facilities, and preclude a public agency from exercising its
administrative or legislative authority under CEQA or the Planning
and Zoning Law, as discussed above, to require that school
facilities fees or other requirements, in excess of the amounts
authorized under Chapter 4 91 be paid on behalf of any development
project as a condition of approval
The revisions made to Sections 65995 and 65996 by
Chapter 1354 of the Statutes of 1992 do not purport to address,
however, the authority of a local agency to consider the adequacy
of school facilities in any context other than the approval of
individual development proDects Consequently, based upon the
analysis set forth above, it is our conclusion that Chapter 1354
of the Statutes of 1992 does not prohibit a city, county, or city
and county from considering the adequacy of school facilities in
the course of adopting or implementing a general plan, zoning
ordinance or other legislative land use policy
i
12 Tc A yi
Honorable Willie L. Brown, Jr - p. 13 - #30455
111 lternative Construction of Chanter 1354 of the Statutes of
1992
You have asked that we consider an alternative
interpretation of the revisions made to Sections 65995 and 65996
by Chapter 1354 of the Statutes of 1992. This alternative
argument posits that tha legislative intent underlying those
revisions was to revise the meaninq of the term "development
project, " as used in Sections 65995 and 65996, to include the
legislative action of a local agency in adoptioq or amending a
general plan or zoning law to establish land use policy. _
According to this argument, the affect of this construction would
be that a local agency Mould be prohibited by those sections, as -
revised by Chapter 1354 of the Statutes of 1992, from takinq into
account the impact on school facilities in deciding on the
adoption or amendment of a general plan or zoning law
As quoted above, Chapter 1354 of the Statutes of 1992
revises Section 65995 to state that, except as authorized under
Section 53080 or Chapter 4 7 , "no fee, charge, dedication, or
other requirement shall be levied by the legislative body of a
local agency against a development project, as defined in Section
53060, whether by administrative = legislative action. for the
construction or reconstruction of school facilities" (emphasis
added to denote language inserted by Ch 1354 , Stats 1992)
To begin with, Section 65995, as revised by Chapter 1354
of the Statutes of 1992 , retains from existing law the phrase "a
development project, as defined in section 53080 11 This is
inconsistent with the contention that Chapter 1354 of the Statutes
of 1992 should be interpreted as a revision of the definition of
the term "development project "
More importantly, the only apparent reasonable
construction of the clause "whether by administrative or
legislative action" within the context of the provision of Section
65995 quoted above, in our opinion, is that the clause nodifies
the "levying" by a legislative body of a fee, charge, dedication,
or other requirement It is our view, as expressed in the
discussion above, that "whether by administrative or legislative
action" is clearly an adverbial clause in this context that
addresses the methods pursuant to which that levying of fees or
other requirements may occur
The alternative argument requires an interpretation that
the phrase "whether by administrative or legislative action" was
inserted in Section 65995 after "a development project, as defined
in Section 53080" to further define "development project" to mean
any administrative or legislative action In our opinion, it is
an unreasonable construction to suggest that the noun "development
/.>r� P �`
Honorable Willie L Brown, Jr. - p. 14 - #30455
Iwas modified by the clause "whether by administrative or
legislative action" to express the meaning that "development
project" is defined to include, for purposes of Section 65995, any
administrative or legislative action Had the Legislature
actually intended that result, we think it probable that the
definition of "development project" in Section 53080 would have
been amended or, alternatively, that a statement would have barn
-added to Chapter 4 .9 to the effect that "development project"
includes any "administrative or legislative action "
Furthermore, this alternative interpretation would
result in the simultaneous combination within Section 65995 of tiro
inconsistent definitions of the term "development project." As
noted above, Section 65995, as revised by Chapter 1354 of the
Statutes of 1992 , contains the express reference "a development
project, as defined in Section 53080. " Section 53080 defines
"development project" to mean "any project undertaken for the
purpose of development, and includes a project involving the
issuance of a permit for construction or reconstruction, but not a
permit to operate" (para. (2) , subd (a) , Sec. 53080) Although
"project" is not defined by Section 53080, that term is defined
elsewhere in the Planning and zoning Law to mean "any activity
involving the issuance to a person of a lease, permit, license,
certificate, or other entitlement for use by one or more public
agencies" (Sec 65931) A phrase or expression may be interpreted
in accordance with its use in other related statutes (Frediani v
Qom, 215 Cal App 2d 127 , 133)
Therefore, for purposes of Section 65995 , "development
project" means an activity undertaken for the purpose of
development that involves a public agency ' s issuance to a person
of a lease, permit, license, certificate, or other entitlement for
use As so defined, the term "development project" has been held
by the courts to exclude legislative action by a public agency
involving the adoption or amendment of general plans and zoning
laws (see mira , supra , p 1218 , Landi v County = o to ey,
supra, p 936) A construction to the effect that Section 65995
purports to define "development project" as specified in Section
53080 and, simultaneously, to mean any "administrative or
legislative action" of the legislative body of a local agency
would thus be internally inconsistent and , consequently,
unreasonable
Section 65996 is revised by Chapter 1354 of the Statutes
of 1992 to state that designated provisions "shall be the
exclusive methods of mitigating environmental effects related to
the adequacy of school facilities when considering the approval or
the establishment of conditions for the approval of a development
_�, . _ _ by administrative or
project, ir��c-z.rrrcc� iTr �-Tv av 53909
1Qgis�ative action pursuant to [CEQA) " (changes in wording
/Q-c �} �f
Honorable Willie L. Brown, Jr. - p. 15 - #30455
indicated in strikeout and underline) . The analysis set forth
above with regard to the inclusion in Section 65995 of the clause
"whether by administrative or legislative action" also applies in
this parallel context, to the effect that the clause "by
administrative or legislative action" in section 65996 may be
construed reasonably, in our view, to refer only to the methods of
_ mitigation utilized by local agencies when considering the
approva} of a development project (see Murrista, supra, p 1233,
fn 15) .
Finally, the legal impact of defininq "development
project" in sections 65995 and 65996 to include any
"administrative or legislative action" would not appear to have
the alliged result of prohibiting a city or county from taking
into account the impact on school facilities in deciding on the
adoption or amendment of a general plan or zoning law. in section
65995, defining "development project" to include any
administrative or legislative act would have the literal effect of
prohibiting the legislative body of a local agency from levying,
other than pursuant to Section 53080 or Chapter 4 7 , a school
facilities fee, charge, dedication, or other requirement against,
for example, the legislative act of adopting or amending a general
plan or zoning law Similarly, in Section 65996, defining
"development project" to include any administrative or legislative
act would have the literal effect of restricting the mitigation
requirements that may be imposed by a local agency under CEQA
against its adoption or amendment of a general plan or zoning law
5 The deletion by Chapter 1354 of the Statutes of 1992 of the
phrase " , as defined in Section 53080, " from Section 65996 could
be argued to reflect the legislative intent to revise the meaning
cf the term "development project, " as used in that section The
Legislature cannot be presumed to have indulged in idle acts
(Stafford v Realty Bond Service Corg . , 39 Cal 2d 797 , 805 ,
Peonle v Fo , 170 Cal App 3d 10391 1056)
However, Chapter 1354 of the Statutes of 1992 does not
purport to add language to Section 65996 that reasonably may be
construed to replace the definition of "development pro3ect" set
forth in Section 53080 Consequently, pursuant to the rule of
statutory construction that a phrase or expression may be
interpreted in accordance with its use in other related statutes
(Frediani v =, 215 Cal App 2d 127 , 133) , we conclude that
"development project" would have the same meaning in Section 65996
as it does in Section 65995 , which defines the term by express
reference to Section 53o80 and by use of the definition of the
tern "project' in a related section, namely Section 65931
I
Honorable Willie L. Brown, Jr - p 16 - #30455
It is well settled that, in construing a statute, a
court may use a vide variety of extrinsic aids, such as the
history of the statuta, committee reports, staff bill reports,
legislative debates, unpasced amendatory legislation, and avast
letters of legislative intent (see In ZI Marriace !21 Bouquet, 16
Cal. 3d 583 , 590-591; People V. Superior Court (Arthur j2,_I, 199
Sal App 3d 494 , 499-500) . In this case, for example, the Senate
Third Reading analysis of July 30, 1992, states that " [b]y setting
the fee cap as an exclusive method for mitigating school impacts
when considering ' legislative' actions, [S B. 12871 reverses the
effect of the Mira decision. "
It is equally true, however, that legislative intent may
be given effect only if it can reasonably be interred from the
language of the act (see Coulter. v Pool, 187 Cal, 181, 185-186 ;
g,.X 1�arte Goodrich, 160 Cal 410, 416-417 ; see also Andersen v.
Z .M. Z=eeon Corp . , 7 Cal 2d 60, 66-68) In this case, for the
reasons set forth above, it is our opinion that the legislative
intent suggested by the senate Third Reading analysis, and by the
alternative argument addressed in this discussion, cannot
reasonably be inferred from the language in Sections 65995 and
65996 as revised by Chapter 1354 of the Statutes of 1992 W6
conclude, accordingly, that this alternative construction of those
sections Would not be adopted by the courts
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