Housing Element Background and Process

Every eight years, the State of California requires local governments to update their housing elements to plan for the housing needs of everyone in the community. The HCD reviews every local government’s housing element to determine whether it complies with State law. Under HCD’s guidelines, the Housing Element process involves the following steps for jurisdictions to follow:

  1. Update previous housing element (Complete)

  2. Submit draft to HCD for review (Complete)

  3. Revise and adopt (Complete)

  4. Submit adopted housing element to HCD (Complete)

  5. Revise and resubmit (Complete)

Step 5 was completed on August 11, 2022 when the City formally submitted the revised and readopted Housing Element to HCD. Each step is detailed below.

Step 1. Update previous Housing Element (Complete)

After the Housing Element Update process kicked off at the May 12, 2021, Planning Commission meeting, the GPU team* began receiving input on and updating the Housing Element. After drafting an updated Housing Element, the City sought input on the plan from community members and the City’s Commissions, Boards, and Committees.

The City posted a First Draft of the Housing Element on the GPU project website for public review on July 19, 2021, and accepted comments through October 1, 2021. The public comments on the first draft are available to review in the Update Timeline section. During the public review period, the City also presented and discussed the Draft Housing Element with the General Plan Advisory Committee (GPAC) on July 22, 2021; the Housing Technical Advisory Committee (TAC) on July 28, 2021; the Planning Commission on July 28, 2021; and the Advisory Committee on Housing and Homelessness (ACOHH) on August 16, 2021.

Step 2. Submit draft to HCD for review (Complete)

After receiving preliminary feedback on the First Draft of the Housing Element from the public, GPAC, TAC, the Planning Commission, ACOHH, and the GPU team evaluated the comments and made corresponding changes, resulting in the Second Draft of the Housing Element, where feasible. Revisions included but are not limited to: the Housing Plan, Sites Inventory, Public Participation, and Fair Housing Assessment. View the Second Draft in the Update Timeline section.

The City submitted the Second Draft for HCD’s 60-day review on September 13, 2021. HCD assigned Analyst Shawn Danino to review Culver City’s Housing Element. The Second Draft was posted on the GPU project website for public review and comments while the City continued to accept comments on the First Draft. The public comments on the second draft are available to review in the Update Timeline section.

The GPU team provided an update on the City’s progress with the Housing Element to the City Council on September 27, 2021. After receiving the Planning Commission’s recommendation, the City Council directed the site inventory be revised to remove properties in the Culver Crest Residential Hillside Zone and a few added sites were removed based on project status and further feasibility review. The Culver Crest Residential Hillside zone prohibits accessory dwelling units (ADUs) due to findings related to fire hazard, slope, and emergency access.

Step 3. Revise and adopt (Complete)

On October 1, 2021, the public comment period for the Draft Housing Element ended, while HCD’s 60-day review period of the Second Draft ended on November 9, 2021. HCD's pre-submittal comment letter is available to review. The City presented and discussed the Draft Housing Element, HCD’s comment letter, the environmental documentation, and related public comments with the City Council on December 10, 2021, and the Planning Commission on November 30, 2021, and January 6, 2022. The Planning Commission recommended adoption of the Housing Element and environmental documentation at their January 6 meeting. The City reviewed public comments, HCD’s comment letter, City Council and Planning Commission’s comments, and revised the document, resulting in a Third Version of the 2021-2029 Housing Element that the City Council considered for adoption at their January 24, 2022 meeting.

Step 4. Submit adopted Housing Element to HCD (complete)

The adopted Housing Element is available to review in the Update Timeline section. It was submitted to HCD for certification on February 22nd, 2022 (“certification” means that HCD finds the Housing Element to be in substantial compliance with the State’s legal requirements). On April 21st, 2022, the City received HCD’s determination letter, which found that further revisions to the Housing Element are necessary for certification and to be compliant with State law.

STEP 5. REVISE (complete) 

The adopted Housing Element was revised to address comments issued by HCD from April 2022. City Council reviewed these minor updates at a hearing on August 8, 2022 and readopted the updated Housing Element. The City then resubmitted the revised Housing Element to HCD for a 60-day review period on August 11, 2022. During this review period, HCD requested that City staff make minor revisions, including strengthening language in some Affirmatively Furthering Fair Housing policies and clarifying the timelines for policy implementation. Two rounds of minor revisions were made, and these additional revisions were submitted to HCD on October 3, 2022 and October 6, 2022. On October 10, 2022, the California Department of Housing and Community Development (HCD) determined that the City’s adopted Housing Element is in full compliance with the State Housing Element Law. The full Housing Element Approval Letter and final Housing Element and appendices can be reviewed in the Update Timeline section below.

Notes

*The GPU team for the Housing Element includes Veronica Tam and Associates, the City’s housing consultant; Raimi + Associates, the City’s lead consultant; and City staff.

California Environmental Quality Act (CEQA)

Before the City can approve a plan, like a Housing Element, the CEQA requires that the City study the plan's potential impacts on the environment and find ways to avoid or reduce any expected environmental damage. The GPU’s environmental consultant, ESA, conducted an environmental review of the Housing Element through an Initial Study and Negative Declaration (IS/ND) and found the Housing Element would not result in significant environmental impacts since it is a policy document that will not result in changes in the land use designations or physical development at this time.

The City followed requirements under Assembly Bill 52 and Senate Bill 18 regarding tribal consultation and opened the public comment period for the IS/ND from October 7, 2021, through November 8, 2021. The City reviewed the comments received during the comment period and prepared responses. A full Environmental Impact Report (EIR) will be prepared for the entire GPU, including the updated Housing Element, to evaluate the environmental impacts the future development contemplated by the GPU will have on Culver City.

The proposed updates to the 2021-2029 Housing Element do not trigger the need for supplemental review under Section 15162 of the CEQA Guidelines. Therefore, an Addendum to the Negative Declaration has been added to the ND to account for the updates to the 2021-2029 Housing Element in compliance with CEQA Section 15164.

Engagement and Information to Date

The GPU Deliverables and Engagement Summary and Work Plan as of June 2021 outlines past engagement and deliverables, including the Housing Element. The Summary also shares in process, ongoing, and upcoming deliverables, and engagement. While most of the engagement activities and deliverables relate to and inform housing, deliverables and engagement most closely related to the Housing Element are outlined below. Items marked with an asterisk (*) are upcoming and will be linked as they become available.

General

Community Workshops

General Plan Advisory Committee Meetings  

Housing Technical Advisory Committee

Planning Commission

City Council

 

housing element update timeline

  • On October 10, 2022, the California Department of Housing and Community Development (HCD) determined that the City’s adopted Housing Element is in full compliance with the State Housing Element Law. Review the Housing Element Approval Letter and final Housing Element and appendices below.

  • In response to additional feedback from HCD, the City submitted a second round of minor edits to the Housing Element on October 6, 2022. The specific revisions are detailed below:

    • Page 89. Added reference language to revision for Measure 4B: “permit housing by right pursuant to Government Code sections 65583, subdivision (c)(1) and 65583.2, subdivisions (h) and (i).”

    • Page 89. Added statement that maximum densities will be achieved: “If current development standards prevent maximum densities (plus state density bonus law) from being achieved on any given site in the inventory, the City will revise those development standards to ensure that maximum densities can be achieved.”

  • In response to HCD feedback on the updated Housing Element (readopted August 8, 2022), the City submitted minor edits to the Housing Element on October 3, 2022. The specific revisions are detailed below:

    • Page 68. Explained how the General Plan Update will reduce impact fees to reduce this constraint on development. 

    • Page 86. Added specific actions for the shared housing program. Established process to provide relief of City fees for affordable housing projects. 

    • Page 88. Clarified the City’s by right permitting process for projects with 20 percent affordable low income units. Added timeline for updating the General Plan’s zoning implementation. 

    • Page 89. Established timeline for implementing SB 9. 

    • Page 90. Committed to establishing lower fees for accessory dwelling units (ADUs). 

    • Page 91. Expanded on the City’s current efforts to eliminate parking minimums. Committed to study removing the referendum on height limits. 

    • Page 93. Added program to study accessory commercial uses. 

    • Page 97. Committed to pursuing additional funding for Project Homekey. 

    • Page 100. Committed to establishing development standards to facilitate co-housing and other alternative housing arrangements. 

    • Page 109. Committed to petitioning Los Angeles Community Development Authority for city specific data. 

    • Appendix B.  

      • Clarified timing for housing development.

      • Updated the status and funding of City housing projects.

      • Provided justification for future mixed use development densities.

      • Explained development potential on sites with existing uses.

    • Appendix E. 

      • Added analysis regarding minority neighborhoods.

      • Highlighted the density increase across all land use categories, including affluent neighborhoods.

  • The updated Housing Element was readopted by City Council on August 8, 2022 and transmitted to HCD for certification on August 11, 2022. The readopted Housing Element and Adequate Sites Inventory are available to download below.

  • At the August 8, 2022 City Council public hearing, the City Council reviewed and considered minor updates made to the adopted Housing Element. To see what changes were made to the adopted Housing Element, review the redlined Housing Element and appendices below.

  • The adopted Housing Element was submitted to HCD for a 60-day review period on February 22, 2022. On April 21, 2022, the City received HCD’s determination letter, which found that further revisions to the Housing Element are necessary be compliant with State law.

  • At the January 24, 2022 City Council public hearing, the City Council reviewed the Planning Commission’s recommendations from the January 6, 2022 Planning Commission public hearing and adopted the 2021-2029 Housing Element Update for submittal to the HCD, by a vote of 3 to 2.

  • At the January 6, 2022 Planning Commission hearing, the Planning Commission considered the 2021-2029 Housing Element, environmental documentation, staff report, and public testimony, and recommended that the City Council adopt the 2021-2029 Housing Element and its Negative Declaration, with a few additional recommendations, by a vote of 4 to 1.

  • At the December 10, 2021 City Council meeting, the City Council received updates on the status of the Housing Element and directed staff to consider the setting a floor on the number of units that may be developed on multifamily lots, examining the Sites Inventory, additional sites that could be expected to be developed at existing under-performing shopping centers, streamlining permitting for mixed use development, and methods to promote the recycling of shopping centers and other commercial or industrial districts for new mixed- use development.

  • At the November 30, 2021 Planning Commission meeting, the Planning Commission received updates on the status of the Housing Element and directed staff to consider the implications of setting a floor on the number of units that may be developed on multifamily lots, examining the Sites Inventory, additional sites that could be expected to be developed at existing under-performing shopping centers, streamlining permitting for mixed use development, and methods to promote the recycling of shopping centers and other commercial or industrial districts for new mixed- use development.

  • On November 9, 2021, HCD’s 60-day review period on the draft submitted to them on September 13, 2021 ended and they sent the City a comment letter outlining their feedback. Review HCD’s comments below:

  • On September 27, 2021, City Council directed staff to revise the site inventory to remove properties in the Culver Crest Residential Hillside Zone where ADUs are prohibited, and a few other sites based on project status and further feasibility review. See below for the removed sites.

  • Comments received on the second public draft of materials, between September 14 and October 1, are available for download here:

  • The Housing and Community Development Submittal Draft (with appendices and the public participation summary) is available for download as one file (9/13/2021).

  • Comments received on the first public draft of materials between July 19 and September 13 are available for download here:

  • The First Draft Housing Element, without comments, is available for download (8/2/2021). The following updates were posted during the review period between July 19 and September 13:

    • The sites inventory was posted in a separate interactive document (7/23/2021).

    • Appendix E of the Draft Housing Element, the Fair Housing Assessment, was posted in a separate interactive document for review (7/22/2021).

    • Updates and clarifying comments from City staff on the Draft Housing Element were added via pinned comments by the site administrator. The site administrator was denoted with a star in the comment box (7/22/2021).