2022-05-23_CC_AgendaPacket1.CALL TO ORDER
2.ROLL CALL
3.PLEDGE OF ALLEGIANCE
4.PRESENTATIONS/PROCLAMATIONS/ANNOUNCEMENTS
5.BLUE FOLDER ITEMS (SUPPLEMENTAL)
Blue folder (supplemental) items are additional back up materials to administrative reports, changes to the posted
agenda packet, and/or public comments received after the printing and distribution of the agenda packet for receive and
file.
5.A.FOR BLUE FOLDER DOCUMENTS APPROVED AT THE CITY COUNCIL
MEETING
RECOMMENDATION: Approved
6.PUBLIC COMMENT ON NON-AGENDA ITEMS
This is the appropriate time for members of the public to make comments regarding items not listed on this agenda.
Pursuant to the Brown Act, no action will take place on any items not on the agenda.
7.CONSENT CALENDAR
Business items, except those formally noticed for public hearing, or those pulled for discussion are assigned to the
2 PORTUGUESE BEND ROAD
ROLLING HILLS, CA 90274
(310) 377-1521
AGENDA
Regular City Council Meeting
CITY COUNCIL
Monday, May 23, 2022
CITY OF ROLLING HILLS
7:00 PM
The meeting agenda is available on the City’s website. The City Council meeting will be live-streamed on the City’s
website. Both the agenda and the live-streamed video can be found here:
https://www.rolling-hills.org/government/agenda/index.php
Members of the public may submit written comments in real-time by emailing the City Clerk’s office at
cityclerk@cityofrh.net. Your comments will become part of the official meeting record. You must provide your full
name, but please do not provide any other personal information that you do not want to be published.
Recordings to City Council meetings can be found here: https://www.rolling-hills.org/government/agenda/index.php
Next Resolution No. 1300 Next Ordinance No. 376
CL_AGN_220523_CC_BlueFolderItem_7C.pdf
CL_AGN_220523_CC_BlueFolderItem_11A.pdf
CL_AGN_220523_CC_BlueFolderItem_12B.pdf
1
Consent Calendar. The Mayor or any Councilmember may request that any Consent Calendar item(s) be removed,
discussed, and acted upon separately. Items removed from the Consent Calendar will be taken up under the "Excluded
Consent Calendar" section below. Those items remaining on the Consent Calendar will be approved in one motion. The
Mayor will call on anyone wishing to address the City Council on any Consent Calendar item on the agenda, which has
not been pulled by Councilmembers for discussion.
7.A.APPROVE AFFIDAVIT OF POSTING FOR THE CITY COUNCIL REGULAR
MEETING OF MAY 23, 2022
RECOMMENDATION: Approve.
7.B.APPROVE MOTION TO READ BY TITLE ONLY AND WAIVE FURTHER
READING OF ALL ORDINANCES AND RESOLUTIONS LISTED ON THE
AGENDA
RECOMMENDATION: Approve.
7.C.APPROVE THE FOLLOWING CITY COUNCIL MINUTES: MAY 9, 2022
RECOMMENDATION: Approve as presented.
7.D.PAYMENT OF BILLS
RECOMMENDATION: Approve as presented.
7.E.REPUBLIC SERVICES RECYCLING TONNAGE REPORT FOR APRIL 2022.
RECOMMENDATION: Receive and file.
7.F.APPROVE COUNTY OF LOS ANGELES DEPARTMENT OF AGRICULTURAL
COMMISSIONER/WEIGHTS AND MEASURES FY 2022/2023 PEST CONTROL
AGREEMENT NO. 779 FOR PEST CONTROL SERVICES.
RECOMMENDATION: Approve as presented.
7.G.APPROVE AND AUTHORIZE THE CITY MANAGER TO EXECUTE A
PROFESSIONAL SERVICES AGREEMENT WITH BOLTON ENGINEERING
CORPORATION TO PERFORM A TOPOGRAPHIC SURVEY AT THE CITY HALL
CAMPUS TO SUPPORT THE IMPROVEMENTS REQUESTED BY THE NEEDS
OF SENIOR COMMITTEE
RECOMMENDATION: Approve as presented.
7.H.PENINSULA EMERGENCY WATERSHED MANAGEMENT PROJECT (EWMP)
RESPONSE TO REGIONAL BOARD COMMENTS
RECOMMENDATION: Receive and file.
7.I.APPROVE ROLLING HILLS COMMUNITY ASSOCIATION'S APPLICATION TO
LOS ANGELES COUNTY DEPARTMENT OF PUBLIC HEALTH FOR
CL_AGN_220523_CC_AffidavitofPosting.pdf
CL_MIN_220509_CC_F_A.pdf
CL_AGN_220523_PaymentOfBills.pdf
CL_AGN_220523_Rolling Hills YTD Tonnage Report.pdf
CL_AGN_220523_CC_LA_Co.PestControlAgreemtNo.779.pdf
CL_AGN_220509_Bolton_CHCampus_SurveyProposal.pdf
CA_AGR_220518_PSA_BoltonEng_TopographicSurvey.pdf
PVP EWMP Cover Letter (Mass-Based Approach) 22.05.13.pdf
PVP EWMP Response to RB Comments Table 22.05.13.pdf
PVP EWMP 22.05.13.pdf
2
REPLACEMENT OF SEPTIC TANK SERVING THE MAIN GATE AND
AUTHORIZE CITY MANAGER TO SIGN
RECOMMENDATION: Approve as presented.
7.J.ACCEPT EMERGENCY STORM DRAIN REPAIR AT 1 MIDDLERIDGE LANE
NORTH AS COMPLETE, FILE NOTICE OF COMPLETION, AND RELEASE
RETENTION AFTER 30 DAY LIEN PERIOD TO EC CONSTRUCTION
RECOMMENDATION: Approve as presented.
7.K.ADOPT RESOLUTION NO. 1299 ACCEPTING CALRECYCLE SB1383 GRANT
RECOMMENDATION: Approve as presented.
7.L.REPORT BY BUDGET/AUDIT/FINANCE COMMITTEE ON MEETING HELD ON
MAY 9, 2022
RECOMMENDATION: Receive and File
7.M.ADOPT RESOLUTION NO. 1298 MEMORIALIZING A REDUCTION IN THE SELF-
INSURANCE FUND RESERVES FROM $500,000 TO $250,000
RECOMMENDATION:
Approve as presented.
7.N.UPDATE ON RESTRICTED TRANSPORTATION FUND PROJECTS
RECOMMENDATION: Receive and file.
8.EXCLUDED CONSENT CALENDAR ITEMS
9.COMMISSION ITEMS
10.MATTERS FROM THE CITY COUNCIL
10.A.DISCUSS 2022 SCE RELIABILITY REPORT AND WILDFIRE DETECTION
CAMERAS ON THE PENINSULA (DIERINGER)
RECOMMENDATION: None.
10.B.DISCUSS EXISTING CELLULAR SERVICE ISSUES (BLACK)
RECOMMENDATION: None.
CL_AGN_220523_RHCA_LACoDPH_Application_Septic.pdf
CL_AGN_220523_RHCA_GeoTech_Septic.pdf
PW_STW_220303_SDRepair_1MiddleridgeLaneN.pdf
PW_STW_220418_MiddleridgeLaneN_INV 19092_revised.pdf
PW_STW_220430_MiddleridgeLaneN_Inv 19111_Retention.pdf
PW_STW_220418_MiddleridgeLaneN_CP_Release.pdf
Revised 1383 Award RFA 001.pdf
Exhibit A: 2022Jan3SB1383LocalAssistTermsConditions.pdf
Exibit B: 2022Apr25ProcsReqsAmended.pdf
ResolutionNo1288_SB1383_Grant_F_E.pdf
ResolutionNo1299_CalRecycle_SB1383_GrantAcceptance.pdf
ResolutionNo1298_AdministrativeFinancialPolicy.pdf
FN_POL_220518_AdminProcedures_BudgetDebtPolicies.pdf
3
11.BUDGET WORKSHOP
11.A.CITY COUNCIL FISCAL YEAR 2022-23 BUDGET WORKSHOP
RECOMMENDATION: Review the proposed Fiscal Year 2022/23 budget and
provide staff with comments and direction.
12.NEW BUSINESS
12.A.PRESENTATION OF EDUCATIONAL VIDEOS ON FIRE FUEL MANAGEMENT IN
THE CANYON; RECOGNIZE LEAD BLOCK CAPTAIN GENE HONBO, BLOCK
CAPTAIN DEBRA SHRADER, AND LOS ANGELES COUNTY FIRE
DEPARTMENT FORESTRY DIVISION TREVOR MOORE FOR THEIR
LEADERSHIP IN COMPLETING THE PROJECT; AND DIRECT STAFF TO
DISSEMINATE THE VIDEOS THROUGH THE BLOCK CAPTAIN PROGRAM.
RECOMMENDATION: Approve as presented.
12.B.APPROVE AMENDED PROFESSIONAL SERVICES AGREEMENT WITH
CHAMBERS GROUP TO PREPARE A CEQA DOCUMENT FOR THE 6TH CYCLE
HOUSING ELEMENT TO ADDRESS COMMENTS FROM THE DEPARTMENT OF
FISH AND WILDLIFE
R ECOM MENDATION : Authorize the preparation of a contract amendment
approved to form by the City Attorney in a not to exceed amount of $60,000;
and authorize the City Manager to execute such an agreement.
12.C.ADOPT RESOLUTIONS NOS. 1295 AND 1296 PERTAINING TO A GENERAL
MUNICIPAL ELECTION CONSOLIDATED WITH THE STATEWIDE GENERAL
ELECTION TO BE HELD ON TUESDAY, NOVEMBER 8, 2022
RECOMMENDATION:
Adopt Resolution Nos. 1295 and 1296 pertaining to the General Municipal
Election to be held on November 8, 2022 as presented.
13.PUBLIC HEARINGS
13.A.SUBMITTAL OF "ADOPTION DRAFT" 2021-2029 ROLLING HILLS HOUSING
ELEMENT TO HCD
REC OMMEN D AT ION: Authorize staff to submit the revised Draft Housing
Element to HCD for their second review, along with the responses to HCD’s
CL_AGN_220523_FY2023_Revenue Budget Recommendations.pdf
CL_AGN_220523_FY2023_Recommended Budget_General Fund Exp.pdf
CL_AGN_220523_FY2023 Summary of Sources and Uses of Funds_General Fund.pdf
CL_AGN_220523_Twelve Year History_ Rev Exp and Reserves.pdf
CL_AGN_FY22-23_OptionsToCloseBudgetDeficit_v2.pdf
CL_AGN_220523_FY2023 Recommended Budget - Other Funds.pdf
CL_AGN_220523_CC_BlueFolderItem_11A_01_Redacted.pdf
Agreement for Planning Services - Chambers-EXECUTED.pdf
CL_AGN_220523_CC_BlueFolderItem_12B_IS-MND_ChangeOrder.pdf
ResolutionNo1295_CallElection2022_CountyServices.pdf
ResolutionNo1296_EstablishRegulations_CandidateStatement.pdf
4
comments.
14.MATTERS FROM STAFF
15.RECESS TO CLOSED SESSION
16.RECONVENE TO OPEN SESSION
17.ADJOURNMENT
Next regular meeting: Monday, June 13, 2022 at 7:00 p.m. in the City Council Chamber,
Rolling Hills City Hall, 2 Portuguese Bend Road, Rolling Hills, California, 90274.
A. April 11, 2022 Comment letter from HCD
B. May 9, 2022 City Responses to HCD Comments
C. Tracked Change Adoption Draft Housing Element
Notice:
Public Comment is welcome on any item prior to City Council action on the item.
Documents pertaining to an agenda item received after the posting of the agenda are available for review in
the City Clerk's office or at the meeting at which the item will be considered.
In compliance with the Americans with Disabilities Act (ADA), if you need special assistance to participate in
this meeting due to your disability, please contact the City Clerk at (310) 377-1521 at least 48 hours prior to the
meeting to enable the City to make reasonable arrangements to ensure accessibility and accommodation for
your review of this agenda and attendance at this meeting.
5
Agenda Item No.: 5.A
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH, CITY CLERK / EXECUTIVE ASSISTANT TO
CITY MANAGER
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:FOR BLUE FOLDER DOCUMENTS APPROVED AT THE CITY COUNCIL
MEETING
DATE:May 23, 2022
BACKGROUND:
None.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approved.
ATTACHMENTS:
CL_AGN_220523_CC_BlueFolderItem_7C.pdf
CL_AGN_220523_CC_BlueFolderItem_11A.pdf
CL_AGN_220523_CC_BlueFolderItem_12B.pdf
6
BLUE FOLDER ITEM (SUPPLEMENTAL)
Blue folder (supplemental) items are additional back up materials to administrative reports, changes to the posted agenda packet,
and/or public comments received after the printing and distribution of the agenda packet for receive and file.
CITY COUNCIL MEETING
May 23, 2022
7.C APPROVE THE FOLLOWING CITY COUNCIL MINUTES: MAY 9, 2022
FROM: CHRISTIAN HORVATH, CITY CLERK/EXECUTIVE ASSISTANT TO THE CITY
MANAGER
CL_MIN_220509_CC_F_A.pdf
7
BLUE FOLDER ITEM (SUPPLEMENTAL)
Blue folder (supplemental) items are additional back up materials to administrative reports, changes to the posted agenda packet,
and/or public comments received after the printing and distribution of the agenda packet for receive and file.
CITY COUNCIL MEETING
May 23, 2022
11.A CITY COUNCIL FISCAL YEAR 2022-23 BUDGET WORKSHOP
FROM: CHRISTIAN HORVATH, CITY CLERK/EXECUTIVE ASSISTANT TO THE CITY
MANAGER
CL_AGN_220523_CC_BlueFolderItem_11A_01_Redacted.pdf
8
BLUE FOLDER ITEM (SUPPLEMENTAL)
Blue folder (supplemental) items are additional back up materials to administrative reports, changes to the posted agenda packet,
and/or public comments received after the printing and distribution of the agenda packet for receive and file.
CITY COUNCIL MEETING
May 23, 2022
12.B APPROVE AMENDED PROFESSIONAL SERVICES AGREEMENT WITH
CHAMBERS GROUP TO PREPARE A CEQA DOCUMENT FOR THE 6TH CYCLE
HOUSING ELEMENT TO ADDRESS COMMENTS FROM THE DEPARTMENT OF
FISH AND WILDLIFE
FROM: CHRISTIAN HORVATH, CITY CLERK/EXECUTIVE ASSISTANT TO THE CITY
MANAGER
CL_AGN_220523_CC_BlueFolderItem_12B_IS-MND_ChangeOrder.pdf
9
Agenda Item No.: 7.A
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH,
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:APPROVE AFFIDAVIT OF POSTING FOR THE CITY COUNCIL
REGULAR MEETING OF MAY 23, 2022
DATE:May 23, 2022
BACKGROUND:
None.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approve.
ATTACHMENTS:
CL_AGN_220523_CC_AffidavitofPosting.pdf
10
Administrative Report
7.A., File # 1206 Meeting Date: 05/23 /2022
To: MAYOR & CITY COUNCIL
From: Christian Horvath, City Clerk
TITLE
APPROVE AFFIDAVIT OF POSTING FOR THE CITY COUNCIL REGULAR MEETING OF MAY 23, 2022
EXECUTIVE SUMMARY
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) SS
CITY OF ROLLING HILLS )
AFFIDAVIT OF POSTING
In compliance with the Brown Act, the following materials have been posted at the locations below.
Legislative Body City Council
Posting Type Regular Meeting Agenda
Posting Location 2 Portuguese Bend Road, Rolling Hills, CA 90274
City Hall Window
Meeting Date & Time May 23, 2022 7:00pm Open Session
As City Clerk of the City of Rolling Hills, I declare under penalty of perjury, the document noted above was
posted at the date displayed below.
Christian Horvath, City Clerk
Date: May 19, 2022
11
Agenda Item No.: 7.B
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH,
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:APPROVE MOTION TO READ BY TITLE ONLY AND WAIVE FURTHER
READING OF ALL ORDINANCES AND RESOLUTIONS LISTED ON THE
AGENDA
DATE:May 23, 2022
BACKGROUND:
None.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approve.
ATTACHMENTS:
12
Agenda Item No.: 7.C
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH,
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:APPROVE THE FOLLOWING CITY COUNCIL MINUTES: MAY 9, 2022
DATE:May 23, 2022
BACKGROUND:
None.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
CL_MIN_220509_CC_F_A.pdf
13
MINUTES – CITY COUNCIL MEETING
Monday, May 9, 2022
Page 1
Minutes
Rolling Hills City Council
Monday, May 9, 2022
Regular Meeting 7:00 p.m.
1. CALL TO ORDER
The City Council of the City of Rolling Hills met in person on the above date at 7:00 p.m. Mayor James Black
presiding.
2. ROLL CALL
Councilmembers Present: Dieringer, Pieper, Mirsch, Mayor Pro Tem Wilson, Mayor Black
Councilmembers Absent: None
Staff Present: Elaine Jeng, City Manager
Jane Abzug, City Attorney
John Signo, Planning & Community Services Director
Christian Horvath, City Clerk / Executive Assistant to the City Manager
3. PLEDGE OF ALLEGIANCE – Councilmember Dieringer
4. PRESENTATIONS/PROCLAMATIONS/ANNOUNCEMENTS – NONE
5. BLUE FOLDER ITEMS (SUPPLEMENTAL)
Motion by Councilmember Pieper, seconded by Mayor Black to receive and file supplemental items for 9A
and 13A. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
6. PUBLIC COMMENT ON NON-AGENDA ITEMS – NONE
7. CONSENT CALENDAR
7.A. APPROVE AFFIDAVIT OF POSTING FOR THE CITY COUNCIL REGULAR MEETING OF MAY 9,
2022
7.B. APPROVE MOTION TO READ BY TITLE ONLY AND WAIVE FURTHER READING OF ALL
ORDINANCES AND RESOLUTIONS LISTED ON THE AGENDA
7.C. APPROVE THE FOLLOWING CITY COUNCIL MINUTES: APRIL 25, 2022
7.D. PAYMENT OF BILLS
7.E. RECEIVE AND FILE SOUTHERN CALIFORNIA EDISON'S 2022 CIRCUIT RELIABILITY REVIEW
7.F. PULLED BY COUNCILMEMBER DIERINGER
7.G. PULLED BY COUNCILMEMBER MIRSCH
14
MINUTES – CITY COUNCIL MEETING
Monday, May 9, 2022
Page 2
7.H. PULLED BY COUNCILMEMBER MIRSCH
7.I. PULLED BY COUNCILMEMBER MIRSCH
Motion by Councilmember Pieper, seconded by Councilmember Dieringer to approve Consent Calendar
excluding Items 7F, 7G, 7H and 7I. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
8. EXCLUDED CONSENT CALENDAR ITEMS
7.F. APPROVE THIRD AMENDMENT TO PROFESSIONAL SERVICES AGREEMENT WITH PACIFIC
ARCHITECTURE AND ENGINEERING INC. COVERING CONSTRUCTION DOCUMENTS FOR
CITY HALL ADA IMPROVEMENTS PROJECT
Motion by Councilmember Dieringer, seconded by Councilmember Mirsch to approve and direct staff to
provide Pacific Architecture and Engineering with hash-marks added to the existing Option 3 diagram to
denote and re-iterate the direction provided at the 4/25/22 Council meeting requesting a solution for the back
south wall of the council chambers allowing for access by overflow public meeting attendees.” Motion carried
unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
7.G. APPROVE BOLTON ENGINEERING CORPORATION TO PERFORM A TOPOGRAPHIC SURVEY
AT THE CITY HALL CAMPUS TO SUPPORT THE IMPROVEMENTS REQUESTED BY THE
NEEDS OF SENIOR COMMITTEE
Motion by Councilmember Mirsch, seconded by Councilmember Pieper to approve as presented and direct
staff to prepare a Professional Services Agreement with Bolton Engineering Corporation. Motion carried
unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
7.H. REPORT BY BUDGET/AUDIT/FINANCE COMMITTEE ON MEETING HELD ON APRIL 25, 2022
7.I. INVESTMENT POLICY, FINANCIAL, BUDGET AND DEBT POLICIES AND RESOLUTION NO.
953 - ASSET CAPITALIZATION POLICY
Motion by Councilmember Mirsch, seconded by Councilmember Dieringer to receive and file 7H; and review
and confirm the Investment Policy, the Financial, Budget and Debt Policies, with changes as recommended
and Resolution No. 953 – Asset Capitalization Policies, and direct staff to prepare a resolution memorializing
the reduction in the Self-Insurance Fund Reserves for 7I. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
15
MINUTES – CITY COUNCIL MEETING
Monday, May 9, 2022
Page 3
9. COMMISSION ITEMS
9.A. ZONING CASE NO. 21-10: REQUEST FOR APPROVAL FOR A MAJOR MODIFICATION TO A
SITE PLAN REVIEW FOR THE CONSTRUCTION OF A NEW 6,094-SQUARE-FOOT RESIDENCE,
4,491-SQUARE-FOOT BASEMENT, 987-SQUARE-FOOT ATTACHED GARAGE, COVERED
PORCHES, SWIMMING POOL AND SPA, 1,000-SQUARE-FOOT ACCESSORY DWELLING
UNIT, AND OTHER IMPROVEMENTS FOR A PROPERTY LOCATED AT 8 MIDDLERIDGE LANE
SOUTH (LOT 254-UR), ROLLING HILLS, CA 90274 (CIMMARUSTI)
Presentation by John Signo, Planning & Community Services Director
Public Comment: Chris Gunderson, Project Architect
Motion by Councilmember Pieper, seconded by Councilmember Dieringer to receive and file Resolution No.
2022-04 and Zoning Case No. 21-10 for a property located at 8 Middleridge Lane South. Motion carried
unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
10. PUBLIC HEARINGS – NONE
11. OLD BUSINESS – NONE
12. NEW BUSINESS
12.A. CONSIDER THE ROLLING HILLS COMMUNITY ASSOCIATION'S REQUEST TO ADOPT THE
VEHICLE CODE SECTION 25279
Presentation by Elaine Jeng, City Manager
Public Comment: Jim Aichele, Alfred Visco
Motion by Councilmember Pieper, seconded by Mayor Pro Tem Wilson to follow the City Attorney’s
suggested Option 2 authorizing the City Attorney to draft a resolution regulating RHCA’s use of a security
vehicle with amber lights and provide input on the posting of signs to make the rule effective. Motion carried
unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
12.B. CONSIDER ROLLING HILLS COMMUNITY ASSOCIATION'S REQUEST TO REPLACE SEPTIC
TANK SERVING THE MAIN GATE
Presentation by Elaine Jeng, City Manager
Mayor Black directed staff to communicate with the RHCA that the Council is in support and request they
provide a copy of the latest plans including the location of the new septic tank at the May 23, 2022 City
Council meeting. Without objection, so ordered.
16
MINUTES – CITY COUNCIL MEETING
Monday, May 9, 2022
Page 4
12.C. APPROVE RECLASSIFICATION OF THE CODE ENFORCEMENT OFFICER POSITION TO A
PLANNER POSITION
Presentation by John Signo, Planning & Community Services Director
Motion by Councilmember Dieringer to defer the item until the Council is provided more information about
the Budget and what monies are available for staff positions. Motion failed for lack of a second.
Motion by Mayor Black, seconded by Councilmember Mirsch to approve the reclassification of the Code
Enforcement officer position to a Planner position. Motion carried with the following vote:
AYES: Pieper, Mirsch, Wilson, Mayor Black
NOES: Dieringer
ABSENT: None
12.D. REVIEW FINANCE/AUDIT/BUDGET COMMITTEE'S RECOMMENDATION TO UPDATE THE
CONSOLIDATED TAX AND FEE SCHEDULE
Presentation by John Signo, Planning & Community Services Director
Motion by Mayor Black to decrease Committee on Trees and Views Processing fee to $1,000 for complaints
against one property and charge additional $1,000 per property for complaints against multiple properties.
Motion failed for lack of a second.
Motion by Councilmember Dieringer, seconded by Mayor Pro Tem Wilson to approve staff recommendation
of raising Committee on Trees and Views Processing fee to $6,000 for complaints against one property and
$10,000 for complaints against multiple properties. Motion carried with the following vote:
AYES: Dieringer, Mirsch, Wilson
NOES: Pieper, Mayor Black
ABSENT: None
12.E. APPROVE UPDATED CITY COUNCIL COMMITTEE ASSIGNMENTS FOR 2022-2023
Presentation by Christian Horvath, City Clerk / Executive Assistant to the City Manager
Motion by Mayor Black, seconded by Mayor Pro Tem Wilson to leave Councilmember Mirsch on the Fire
Fuel Committee. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
Motion by Councilmember Pieper, seconded by Mayor Pro Tem Wilson to approve the City Council
committee assignments as presented. Motion carried with the following vote:
AYES: Pieper, Mirsch, Wilson, Mayor Black
NOES: Dieringer
ABSENT: None
12.F. CONSIDER SUPPORT FOR FORMATION OF PROPOSED SOUTH BAY HOUSING TRUST; AND
INTEREST IN PARTICIPATING
17
MINUTES – CITY COUNCIL MEETING
Monday, May 9, 2022
Page 5
Presentation by Christian Horvath, City Clerk / Executive Assistant to the City Manager
Public Comment: Jim Aichele, Alfred Visco
Motion by Councilmember Pieper, seconded by Mayor Black to take no action until more information is
provided. Motion carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
13. MATTERS FROM THE CITY COUNCIL
13.A. RECEIVE AND FILE REPORT ON THE MARCH 30, 2022 FIRE FUEL COMMITTEE MEETING
Motion by Councilmember Pieper, seconded by Mayor Pro Tem Wilson to receive and file the report. Motion
carried unanimously with the following vote:
AYES: Dieringer, Pieper, Mirsch, Wilson, Mayor Black
NOES: None
ABSENT: None
14. MATTERS FROM STAFF
14.A. REVIEW OPTIONS FOR STATE OF THE CITY EVENT
Presentation by Christian Horvath, City Clerk / Executive Assistant to the City Manager
Mayor Black directed staff to work with the Mayor to write a letter to go out to the residents. Without objection,
so ordered.
City Manager Jeng reported that the Canyon Management Videos were finalized and will be presented at
the May 23, 2022 City Council meeting
Public Comment: Marcia Schoettle
15. RECESS TO CLOSED SESSION
Mayor Black recessed the City Council to Closed Session at 8:34 p.m.
15.A. CONFERENCE WITH LEGAL COUNSEL: ANTICIPATED LITIGATION GOVERNMENT CODE
SECTION 54956.9(d)(2)
16. RECONVENE TO OPEN SESSION
The City Council reconvened to Open Session at 9:46 p.m. and there was no reportable action.
17. ADJOURNMENT: 9:46 P.M.
The meeting was adjourned at 9:46 p.m on May 9, 2022 in the memory of Rolling Hills resident Dr. Elliott
Brunner who passed away. The next regular meeting of the City Council is scheduled to be held on Monday,
May 23, 2022 beginning at 7:00 p.m. in the City Council Chamber at City Hall, 2 Portuguese Bend Road,
18
MINUTES – CITY COUNCIL MEETING
Monday, May 9, 2022
Page 6
Rolling Hills, California. It will also be available via City’s website link at: https://www.rolling-
hills.org/government/agenda/index.php
All written comments submitted are included in the record and available for public review on the City website.
Respectfully submitted,
____________________________________
Christian Horvath, City Clerk
Approved,
____________________________________
James Black, M.D., Mayor
19
Agenda Item No.: 7.D
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH,
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:PAYMENT OF BILLS
DATE:May 23, 2022
BACKGROUND:
None.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
CL_AGN_220523_PaymentOfBills.pdf
20
21
Agenda Item No.: 7.E
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH,
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:REPUBLIC SERVICES RECYCLING TONNAGE REPORT FOR APRIL
2022.
DATE:May 23, 2022
BACKGROUND:
None.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Receive and file.
ATTACHMENTS:
CL_AGN_220523_Rolling Hills YTD Tonnage Report.pdf
22
Year 2022
Franchise Y/N Y
Month Commodity Tons Collected Tons Recovered Tons Disposed Diversion %
Jan Greenwaste 98.26 98.26 - 100.00%
Trash 156.54 - 156.54 0.00%
Jan Total 254.80 98.26 156.54 38.56%
Feb Greenwaste 93.00 93.00 - 100.00%
Trash 134.41 - 134.41 0.00%
Feb Total 227.41 93.00 134.41 40.90%
Mar Greenwaste 111.44 111.44 - 100.00%
Trash 183.40 - 183.40 0.00%
Mar Total 294.84 111.44 183.40 37.80%
Apr Greenwaste 100.44 100.44 - 100.00%
Trash 156.07 - 156.07 0.00%
Apr Total 256.51 100.44 156.07 39.16%
Grand Total 1,033.56 403.14 630.42 39.00%
111.44
CITY OF ROLLING HILLS RESIDENTIAL FRANCHISE
2022
Contract Requires 30% Household -
Page 1 of 2
23
Agenda Item No.: 7.F
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CONNIE VIRAMONTES , ADMINISTRATIVE ASSISTANT
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:APPROVE COUNTY OF LOS ANGELES DEPARTMENT OF
AGRICULTURAL COMMISSIONER/WEIGHTS AND MEASURES FY
2022/2023 PEST CONTROL AGREEMENT NO. 779 FOR PEST
CONTROL SERVICES.
DATE:May 23, 2022
BACKGROUND:
Historically, the City of Rolling Hills maintains an annual agreement with the Los Angeles
County Agricultural Commissioner/Weights & Measures Department for pest control services.
These services are provided on an daily and/or on an on-call basis at the rates listed in the
agreement and the city has used the agreement for services such as coyote trapping, as well
as pest control including rodents and weeds. The attached agreement for Fiscal Year 2022-
2023 is presented for City Council consideration. Of note, most of the hourly rates have
increased over last year's rates.
Labor Increase:
Agri/Weight & Measures Inspector III: 5.88%
Agricultural Chemical Sprayer: 5.54%
Pest Control Worker: 6.17%
Warehouse Worker I: 6.82%
Weed Haz & Pest Abatement Worker: 10.26%
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approve the agreement as presented and authorize the City Manager to execute the
agreement.
24
ATTACHMENTS:
CL_AGN_220523_CC_LA_Co.PestControlAgreemtNo.779.pdf
25
26
27
28
29
30
31
32
33
Agenda Item No.: 7.G
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH,
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:APPROVE AND AUTHORIZE THE CITY MANAGER TO EXECUTE A
PROFESSIONAL SERVICES AGREEMENT WITH BOLTON
ENGINEERING CORPORATION TO PERFORM A TOPOGRAPHIC
SURVEY AT THE CITY HALL CAMPUS TO SUPPORT THE
IMPROVEMENTS REQUESTED BY THE NEEDS OF SENIOR
COMMITTEE
DATE:May 23, 2022
BACKGROUND:
At the April 11, 2022 City Council meeting, Council received a presentation from the Rolling
Hills Community Association Needs of Seniors Committee on suggested improvements to the
City Hall Campus. Council directed staff to work with the city's landscape architect (hired
previously to inventory the existing City Hall campus irrigation system) on the suggested
improvements and report back at the May 23, 2022 City Council meeting.
At the May 9, 2022 City Council meeting, the Council directed staff to prepare a Professional
Services Agreement with Bolton Engineering Corporation.
DISCUSSION:
Staff held a kick off meeting with the landscape architect, Evan Smith and is awaiting his initial
report and findings on the irrigation system. Landscape architect Evan Smith expressed at the
kick-off meeting the need for a topographic survey of the City Hall campus to ensure the
inventoried irrigation system is properly recorded. One of the improvement suggested by the
Needs of the Seniors Committee is to level the grassy area between the Rolling Hills
Community Association office building and City Hall. To do so appropriate, a topographic
survey would be needed.
Previously, the city hired Bolton Engineering Corporation (Bolton) to survey the tennis courts,
and to provide civil engineering plans to bring the accessible paths of the tennis courts to
comply with the American with Disability Act (ADA). In light of the conversation with the
landscape architect Evan Smith, staff reached out to Bolton to find out if topographic survey
was available for the City Hall campus at the time the company was commissioned for
34
engineering work at the tennis courts. Bolton confirmed that they did not furnish a topographic
survey for the City Hall campus, only the tennis courts. Bolton was asked to provide a
proposal to for a topographic survey for the campus. With both sets of data provided by the
same company, there is an opportunity to merge the data to have topographic information for
the campus and tennis courts to approach the planning holistically.
Additionally, to offset potential General Fund expenditures, staff submitted a future project
request using Metro Measure R and M monies to re-imagine and refurbish the parking lot and
outer ring of the campus to include Active Transportation elements as well as resurface the
asphalt.
FISCAL IMPACT:
Bolton's proposal to provide a topographic survey for the City Hall campus is $5,000. If the
City Council should approve to engage for services, there is sufficient budget in the FY 2021-
2022 adopted budget in account 890 Consulting Fees to fund Bolton's professional services
fee.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
CL_AGN_220509_Bolton_CHCampus_SurveyProposal.pdf
CA_AGR_220518_PSA_BoltonEng_TopographicSurvey.pdf
35
Bolton Engineering Corporation
Page 1 of 2
25834 Narbonne Ave. Suite 210
Lomita, CA 90717
tel (310) 325-5580 fax (310) 325-5581
April 19, 2022
Client: City of Rolling Hills
2 Portuguese Bend Road
Rolling Hills, Ca
Ordered By: Christian Horvath
chorvath@cityofrh.net
Subject: Topographic Survey Proposal – 2 Portuguese Bend Rd.
I. Scope of Work
• Topographic Survey: Locate all structures, hardscape, fences, walls, observable above ground utilities,
trees greater than 6” in diameter and spot elevations.
• Prepare drawing showing property lines and topography with contours at 1 foot intervals.
Proposed Fee: $ 5,000.00
Required Retainer: $ 1,500.00
II. Deliverables
Pdf copy and stamped hard copy of topographic survey.
III. Exclusions:
• Fee estimates for surveying are based on the following assumptions . All parts of the property will be
reasonably free of visually obstructing vegetation or objects. The subject site will be open and readily
available for our entry without delay. The dimensions of the subject property, legal descriptions, and
surrounding surveys will close mathematically. The controlling survey monuments will be readily available
and in their proper locations.
• Project revisions, additions, and other services not included in the scope of work above are in addition.
Meetings and personal appearances are included only to the extent outlined above.
• All fees or levies required by government agencies will be assumed by the client and are not included in
the fee proposal. Reproduction and other incurred costs on the client’s behalf are additional.
• Easement plotting not included in proposed fee.
• Property line staking not included in proposed fee.
Hourly Rates are as follows:
Principal- $290.00 Reg. Land Surveyor - $160.00 Drafting - $ 100.00
Reg. Chief Engineer - $195.00 1 Person Survey Party - $150.00 Messenger - $ 75.00
Reg. Civil Engineer - $160.00 2 Person Survey Party - $245.00
Staff Engineer- $130.00 Surveyor Office - $120.00
Approximate cost, where indicated, is neither a maximum nor a fixed price unless so stated. Retainers are credited to final
billing. Interest rate shall be 12 percent. The undersigned client authorizes BOLTON ENGINEERING CORPORATION (BEC)
to perform the above described work. Reproduction costs and Government fees are not included in the fee and shall be paid
for by the client. The fee or balance of the fee is due and payable upon completion of the work. Work performed over an
extended period will be invoiced monthly and due and payable the 10th of the month following date of invoice. Client
acknowledges services are relating to improvement of real property. Accounts unpaid over 30 days will be charged a service
charge of one and one half percent per month (18% per annum), not to exceed 5 percent over the rate charged by the Federal
Reserve Bank of San Francisco to member banks on the 25th of the month preceding this contract.
36
Bolton Engineering Corporation
Page 2 of 2
If a suit or other legal action is instituted to collect fees, client agrees to pay, in addition, all costs of collection and reasonable
attorney's fees. Hourly rates will be adjusted annually. Work may be canceled before completion by written request by eithe r
party, and invoiced on an hourly basis to point of cancellation. Client acknowledges this as a "preliminary 20 day notice " and
understands that if bills are not paid in full for services furnished, the improved property may be subject to mechanics lien s.
Any controversy or claim arising out of or relating to this contract, or the breach thereof, shall be settled by arbitrat ion in
accordance with the Rules of the American Arbitration Association, and judgment upon the award rendered by the Arbitrator's
may be entered in any Court having jurisdiction thereof. In event that BEC is required to appear in any legal action relatin g to
any work performed under this agreement, client agrees to pay BEC prevailing hourly rates for such appearance, reasonable
attorney's fees and costs.
To authorize work under the outlined terms, please sign and initial one copy of this document and return to our offices. Tha nk
you for the opportunity to propose on this project.
Regards,
BOLTON ENGINEERING CORP.
Accepted By:
Signature Date
Title
37
65277.00001\40077817.2
PROFESSIONAL SERVICES AGREEMENT
This Agreement is made and entered into this 23rd day of May 2022 in the City of
Rolling Hills, County of Los Angeles, State of California, by and between the City of Rolling
Hills, a municipal corporation, (hereinafter, “City”) and Bolton Engineering Corporation, a
California corporation, (hereinafter, “Consultant”)
RECITALS.
A. The City desires to retain Consultant to perform a topographic survey and prepare
a drawing showing property lines and topography for 2 Portuguese Bend Rd. The scope of the
project is defined in Exhibit A, attached hereto and incorporated herein by reference.
B. Consultant is well-qualified by reason of education and experience to perform
such services; and
C. Consultant is willing to render such professional services as hereinafter defined.
NOW, THEREFORE, in consideration of the mutual covenants and conditions herein
contained, City hereby engages Consultant to perform the services set forth in this Agreement
and Consultant agrees to perform those services.
1. SCOPE OF WORK.
Consultant shall perform all work necessary to complete, in a manner satisfactory to the
City, the services set forth in the scope of work in Exhibit A, attached hereto and incorporated
into this Agreement by reference.
2. COST.
The City agrees to pay Consultant for all the work or any part of the work performed
under the Agreement at the rates and in the manner established in Exhibit A.
A. Compensation. Total expenditure made under this Agreement shall not exceed the
sum of $5,000. This fee includes all expenses, consisting of all incidental blueprinting,
photography, travel, attendance at meetings and miscellaneous costs, estimated to be accrued.
B. Written Approval Required. Any increase in the compensation or scope of work
shall be by express written amendment, approved by the City Manager and the Consultant.
3. METHOD OF PAYMENT.
Upon full execution of the Agreement, City shall issue payment to Consultant in the
amount of $1,500 as a retainer for Consultant’s services. The Consultant shall thereafter submit
to the City, by no later than the 10th day of each month, its bill for services describing the
services and the date services were performed and itemizing the fees and costs incurred during
the previous month. Such services shall initially be charged against the $1,500 retainer. The City
38
65277.00001\40077817.2
shall pay the Consultant all uncontested amounts set forth in the Consultant's bill within 30 days
after it is received. Consultant shall submit an invoice in duplicate addressed to the City at:
c/o Planning Department
2 Portuguese Bend Road
Rolling Hills, CA 90274
4. SUBCONTRACTING.
Consultant shall not be permitted to subcontract any portion of this Agreement without
the express written consent of the City.
5. COMMENCEMENT OF WORK.
Consultant shall commence the work described herein upon full execution of this
Agreement.
6. ACCOUNTING RECORDS.
Consultant must maintain accounting records and other evidence pertaining to costs
Consultant incurs in carrying out its obligations under this Agreement. The records and evidence
must be kept available in Consultant’s California office during the Term of Agreement (defined
in paragraph 8 of this Agreement) and thereafter for five years from the date of final payment. In
the event such records must be moved from that location, Consultant shall notify the City at the
address of the Planning Department provided in paragraph 4 of this Agreement.
7. OWNERSHIP OF DATA.
All data, maps, photographs, and other material collected or prepared under the
Agreement shall belong to the City and shall not be withheld from the City for any reason.
8. TERM OF AGREEMENT.
This Agreement shall be valid for one year from the date the Agreement is executed by
the parties. The City Manager may extend this contract with proof of a good cause. Such
extension shall be made in writing by the City Manager to the Consultant.
9. TERMINATION.
A. Breach. This Agreement may be terminated at any time for breach. A breach
occurs when Consultant fails to meet an obligation or condition required by this Agreement or
the scope of work set out in Exhibit A.
B. Unilateral Termination. The City may terminate unilaterally and without cause
upon seven (7) days written notice to the Consultant. All work satisfactorily performed pursuant
to this Agreement and prior to the date of termination may be claimed for reimbursement. To the
extent any portion of the retainer has not been expended on services provided by Consultant to
39
65277.00001\40077817.2
City, Consultant shall return any and all unexpended funds to City within 30 days of receipt of
City’s written notice to terminate.
10. ASSIGNABILITY.
Consultant shall not assign or transfer interest in this Agreement without the prior written
consent of the City.
11. AMENDMENT.
It is mutually understood and agreed that no alteration or variation of the terms of this
Agreement shall be valid unless made in writing, signed by the parties, and approved by all
parties.
12. NON-SOLICITATION CLAUSE.
The Consultant warrants that he or she has not employed or retained any company or
persons, other than a bona fide employee working solely for the Consultant, in exchange for any
fee, commission, percentage, brokerage fee, gifts, or any other consideration, contingent upon or
resulting from the award or making of this Agreement. For breach or violation of this warranty,
the City shall have the right to annul this Agreement without liability, or, in its discretion, to
deduct from the agreed price or consideration, or otherwise recover the full amount of such fee,
commission, percentage, brokerage fee, gift, or contingent fee.
13. INDEMNITY.
Consultant shall indemnify, defend with counsel approved by City, and hold harmless
City, its officers, officials, employees and volunteers from and against all liability, loss, damage,
expense, cost (including without limitation reasonable attorneys’ fees, expert fees and all other
costs and fees of litigation) of every nature arising out of or in connection with Consultant’s
performance of work hereunder or its failure to comply with any of its obligations contained in
this Agreement, regardless of City’s passive negligence, but excepting such loss or damage
which is caused by the sole active negligence or willful misconduct of the City. Should City in
its sole discretion find Consultant’s legal counsel unacceptable, then Consultant shall reimburse
the City its costs of defense, including without limitation reasonable attorneys’ fees, expert fees
and all other costs and fees of litigation. The Consultant shall promptly pay any final judgment
rendered against the City (and its officers, officials, employees and volunteers) covered by this
indemnity obligation. It is expressly understood and agreed that the foregoing provisions are
intended to be as broad and inclusive as is permitted by the law of the State of California and
will survive termination of this Agreement.
14. INSURANCE.
A. Insurance Required. Without limiting Consultant’s obligations arising under
paragraph 14 - Indemnity, Consultant shall not begin work under this Agreement
until it obtains policies of insurance required under this section. The insurance
40
65277.00001\40077817.2
shall cover Consultant, its agents, representatives and employees in connection
with the performance of work under this Agreement, and shall be maintained
throughout the term of this Agreement. Insurance coverage shall be as follows:
i. Automobile Liability Insurance, with minimum coverage of $300,000 for
property damage, $300,000 for injury to one person/single occurrence, and
$300,000 for injury to more than one person/single occurrence.
ii. General Liability Insurance insuring City of Rolling Hills, its elected and
appointed officers, agents, and employees from claims for damages for
personal injury, including death, as well as from claims for property
damage which may arise from Consultant’s actions under this Agreement,
whether or not done by Consultant or anyone directly or indirectly
employed by Consultant. Such insurance shall have a combined single
limit of not less than $1,000,000.
iii. Worker’s Compensation Insurance, for all Consultant’s employees to the
extent required by the State of California.
iv. Professional Liability Coverage for professional errors and omissions
liability insurance for protection against claims alleging negligent acts,
errors, or omissions which may arise from the Consultant’s operations
under this Agreement, whether such operations are by the Consultant or by
its employees, subcontractors, or subconsultants. The amount of this
insurance shall not be less than one million dollars ($1,000,000) on a
claims-made annual aggregate basis, or a combined single-limit-per-
occurrence basis. When coverage is provided on a “claims made basis,”
Consultant will continue to renew the insurance for a period of three (3)
years after this Agreement expires or is terminated. Such insurance will
have the same coverage and limits as the policy that was in effect during
the term of this Agreement, and will cover Consultant for all claims made
by City arising out of any errors or omissions of Consultant, or its officers,
employees, or agents during the time this Agreement was in effect.
B. Deductibility Limits for policies referred to in subparagraphs A (i) and (ii) shall
not exceed $5,000 per occurrence.
C. Additional Insured. City, its elected and appointed officers, agents, and employees
shall be named as additional insured on policies referred to in subparagraphs A (i)
and (ii).
D. Primary Insurance. The insurance required in paragraphs A (i) and (ii) shall be
primary and not excess coverage.
E. Evidence of Insurance. Consultant shall furnish City, prior to the execution of this
Agreement, satisfactory evidence of the insurance required, issued by an insurer
41
65277.00001\40077817.2
authorized to do business in California, and an endorsement to each such policy of
insurance evidencing that each carrier is required to give City at least 30 days
prior written notice of the cancellation of any policy during the effective period of
the Agreement. All required insurance policies are subject to approval of the City
Attorney. Failure on the part of Consultant to procure or maintain said insurance
in full force and effect shall constitute a material breach of this Agreement .
15. NOTICES.
Any notice required to be given hereunder shall be deemed to have been given by
depositing said notice in the United States mail, postage prepaid, and addressed as follows:
CITY: CONSULTANT:
Elaine Jeng, P.E., Dan Bolton
City Manager Bolton Engineering Corporation
2 Portuguese Bend Road 25834 Narbonne Ave., Suite 210
Rolling Hills, CA 90274 Lomita, CA 90717
TEL (310) 377-1521 TEL: (310) 325-5580
FAX (310) 377-2866 FAX: (310)325-5581
16. ENFORCEMENT OF AGREEMENT.
In the event that legal action is commenced to enforce or declare the rights created
under this Agreement, the prevailing party shall be entitled to an award of costs and reasonable
attorneys’ fees in the amount to be determined by the court.
17. CONFLICT OF INTEREST.
The Consultant represents that it presently has no interest and shall not acquire any
interest, direct or indirect, in any real property located in the City which may be affected by the
services to be performed by the Consultant under this Agreement. The Consultant further
represents that in performance of this Agreement, no person having any such interest shall be
employed by it.
A. The Consultant represents that no City employee or official has a material
financial interest in the Consultant’s business. During the term of this Agreement and as a result
of being awarded this contract, the Consultant shall not offer, encourage, or accept any financial
interest in the Consultant’s business by any City employee or official.
B. If a portion of the Consultant’s services called for under this Agreement shall
ultimately be paid for by reimbursement from and through an agreement with a developer of any
land within the City or with a City franchisee, the Consultant warrants that it has not performed
any work for such developer/franchisee within the last 12 months, and shall not negotiate, offer,
or accept any contract or request to perform services for that identified developer/franchisee
during the term of this Agreement.
42
65277.00001\40077817.2
18. INDEPENDENT CONSULTANT.
The Consultant is and shall at all times remain as to the City a wholly independent
contractor. Neither the City nor any of its agents shall have control over the conduct of the
Consultant or any of the Consultant’s employees, except as herein set forth. The Consultant
shall not at any time or in any manner represent that it or any of its agents or employees are in
any manner agents or employees of the City.
19. ENTIRE AGREEMENT OF THE PARTIES.
This Agreement supersedes any and all other agreements, either oral or in writing,
between the parties hereto with respect to the employment of Consultant by City and contains all
the covenants and agreements between the parties with respect to such employment in any
manner whatsoever. Each party to this Agreement acknowledges that no representations,
inducements, promises or agreements, orally or otherwise, have been made by any party, or
anyone acting on behalf of any party, which are not embodied herein, and that no other
agreement or amendment hereto shall be effective unless executed in writing and signed by both
City and Consultant.
20. GOVERNING LAW.
This Agreement shall be governed by and construed in accordance with the laws
of the State of California, and all applicable federal statutes and regulations as amended.
21. GENERAL TERMS AND CONDITIONS.
A. Non-Discrimination. The Consultant shall not discriminate as to race, creed,
gender, color, national origin or sexual orientation in the performance of its services and duties
pursuant to this Agreement, and will comply with all applicable laws, ordinances and codes of
the federal, state, county and city governments.
B. Compliance with Applicable Law. The Consultant and the City shall comply with
all applicable laws, ordinances and codes of the federal, state, county, and city governments.
C. Copyright. No reports, maps, or other documents produced in whole or in part
under this Agreement shall be the subject of an application for copyright by or on behalf of the
Consultant.
D. Legal Construction. This Agreement shall be construed without regard to the
identity of the persons who drafted its various provisions. Each and every provision of this
Agreement shall be construed as though each of the parties participated equally in the drafting of
same, and any rule of construction that a document is to be construed against the drafting party
shall not be applicable to this Agreement. The article and section, captions and headings herein
have been inserted for convenience only and shall not be considered or referred to in resolving
questions or interpretation or construction. Whenever in this Agreement the context may so
43
65277.00001\40077817.2
require, the masculine gender shall be deemed to refer to and include the feminine and neuter,
and the singular shall refer to and include the plural.
E. Counterparts. This Agreement may be executed in counterparts and as so
executed shall constitute an agreement which shall be binding upon all parties hereto.
F. Final Payment Acceptance Constitutes Release. The acceptance by the
Consultant of the final payment made under this Agreement shall operate as and be a release of
the City from all claims and liabilities for compensation to the Consultant for anything done,
furnished or relating to the Consultant’s work or services. Acceptance of payment shall be any
negotiation of the City’s check or the failure to make a written extra compensation claim within
ten (10) calendar days of the receipt of that check. However, approval or payment by the City
shall not constitute, nor be deemed, a release of the responsibility and liability of the Consultant,
its employees, sub-consultants, and agents for the accuracy and competency of the information
provided or work performed; nor shall such approval or payment be deemed to be an assumption
of such responsibility or liability by the City for any defect or error in the work prepared by the
Consultant, its employees, sub-consultants, and agents.
G. Corrections. In addition to the above indemnification obligations, the Consultant
shall correct, at its expense, all errors in the work which may be disclosed during the City’s
review of the Consultant’s report or plans. Should the Consultant fail to make such correction in
a reasonably timely manner, such correction shall be made by the City, and the cost thereof shall
be charged to the Consultant.
H. Waiver; Remedies Cumulative. Failure by a party to insist upon the performance
of any of the provisions of this Agreement by the other party, irrespective of the length of time
for which such failure continues, shall not constitute a waiver of such party's right to demand
compliance by such other party in the future. No waiver by a party of a default or breach of the
other party shall be effective or binding upon such party unless made in writing by such party,
and no such waiver shall be implied from any omissions by a party to take any action with
respect to such default or breach. No express written waiver of a specified default or breach shall
affect any other default or breach, or cover any other period of time, other than any default or
breach or period of time specified. All of the remedies permitted or available to a party under this
Agreement, or at law or in equity, shall be cumulative and alternative, and invocation of any
such right or remedy shall not constitute a waiver or election of remedies with respect to any
other permitted or available right of remedy.
I. Mitigation of Damages. In all such situations arising out of this Agreement, the
parties shall attempt to avoid and minimize the damages resulting from the conduct of the other
party.
J. Partial Invalidity. If any provision in this Agreement is held by a court of
competent jurisdiction to be invalid, void or unenforceable, the remaining provisions will
nevertheless continue in full force without being impaired or invalidated in any way.
44
65277.00001\40077817.2
K. Attorneys' Fees. The parties hereto acknowledge and agree that each will bear
his/her or its own costs, expenses, and attorneys' fees arising out of and/or connected with the
negotiation, drafting and execution of the Agreement, and all matters arising out of or connected
therewith except that, in the event any action is brought by any party hereto to enforce this
Agreement, the prevailing party in such action shall be entitled to reasonable attorneys' fees and
costs in addition to all other relief to which that party or those parties may be entitled.
L. Warranty of Authorized Signatories. Each of the signatories hereto warrants and
represents that he or she is competent and authorized to enter into this Agreement on behalf of
the party for whom he or she purports to sign.
IN WITNESS WHEREOF, the parties hereto have executed this Agreement on the date
and year first above written.
CITY OF ROLLING HILLS CONSULTANT
CITY MANAGER: BOLTON ENGINEERING CORP.
______ _____ ________
ELAINE JENG DAN BOLTON
ATTEST:
______ _____
CHRISTIAN HORVATH, CITY CLERK
APPROVED AS TO FORM:
______ _____
MICHAEL JENKINS, CITY ATTORNEY
45
65277.00001\40077817.2
Exhibit A
Scope of Work
I. Scope of Work
• Topographic Survey: Locate all structures, hardscape, fences, walls, observable above ground
utilities, trees greater than 6” in diameter and spot elevations.
• Prepare drawing showing property lines and topography with contours at 1 foot intervals.
II. Deliverables
Pdf copy and stamped hard copy of topographic survey.
III. Exclusions:
• Reproduction and other incurred costs on the client’s behalf are additional.
• Easement plotting not included in proposed fee.
• Property line staking not included in proposed fee.
Hourly Rates are as follows:
Principal- $290.00 Reg. Land Surveyor - $160.00 Drafting - $ 100.00
Reg. Chief Engineer - $195.00 1 Person Survey Party - $150.00 Messenger - $ 75.00
Reg. Civil Engineer - $160.00 2 Person Survey Party - $245.00 Staff Engineer- $130.00 Surveyor Office - $120.00
46
Agenda Item No.: 7.H
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:JOHN SIGNO, DIRECTOR OF PLANNING & COMMUNITY SERVICES
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:PENINSULA EMERGENCY WATERSHED MANAGEMENT PROJECT
(EWMP) RESPONSE TO REGIONAL BOARD COMMENTS
DATE:May 23, 2022
BACKGROUND:
On May 13, 2022, the Cities of Rancho Palos Verdes, Palos Verdes Estates, Rolling Hills
Estates, Rolling Hills, and the County of Los Angeles (Unincorporated County), along with the
Los Angeles County Flood Control District (LACFCD), collectively referred to as the Peninsula
WMG, submitted its updated Palos Verdes Peninsula Enhanced Watershed Management
Program (Peninsula EWMP) including an updated Reasonable Assurance Analysis (RAA), to
the California Regional Water Quality Control Board (Water Board). The updated Peninsula
EWMP and RAA have been prepared in accordance with the requirements of the 2021 LA
MS4 Permit1, the Los Angeles Regional Water Quality Control Board Guidelines for
Conducting RAA (March 2014), and the State Water Board Order WQ 2020-0038 (2020 State
Board Order).
The updated Peninsula EWMP and RAA includes the City of Rolling Hills and is consistent
with the 2020 State Board Order:
Explains how information considered in the source assessment was used (EWMP
Section 2 and Appendix 4.1 RAA Report).
Identifies unavailable, needed information and the assumptions made to substitute for
that information along with commitment to acquire the information through the Peninsula
CIMP for incorporation in the next adaptive management milestone (EWMP Appendix
4.1 RAA Report 7.1.3 Mercury and Arsenic).
Utilizes all relevant, available data2 to update the EWMP and RAA, including updates to
the water body pollutant combination (WBPC) prioritization and source assessment,
TMDL milestone achievement, and RAA calibration and validation. Data not used in the
RAA has been identified, with explanation as to why this data was disregarded.
Models each WBPC and therefore does not utilize or necessitate justification of a limiting
pollutant approach. Table 4-2 in Section 4 of the Updated EWMP provides the results of
this analysis for each WBPC supported by the detailed RAA Report in Appendix 4.1.
47
Includes 24-hour management volumes as a clear metric for demonstrating progress in
attaining load reduction targets – Table 5-1 in Section 5 of the Updated EWMP provides
the implementation schedule for demonstrating progress in attaining these volumetric
reductions by subwatershed and analysis region. Water body/pollutant milestones are
also included in this table.
Considers ongoing CIMP monitoring data which is sufficient to evaluate attainment of
milestones.
EWMP Addendum to include Rolling Hills
On January 31, 2022, an Addendum to the Palos Verdes Peninsula Enhanced Watershed
Management Program (EWMP Addendum) to include Rolling Hills as an 85th%, 24-hour
runoff retention area was submitted to the Water Board. On April 6, 2022, the Water Board
provided the City with comments on the EWMP Addendum that the City. On April 26, 2022,
the City responded to those comments and is currently awaiting the Water Board's response.
Although the City is not officially part of the Peninsula EWMP, if the Addendum is approved by
the Water Board, the updated Peninsula EWMP will apply to the City.
DISCUSSION:
The Water Board regulates discharges from municipal separate storm sewer systems (MS4s)
through the Municipal Separate Storm Sewer System Permit (MS4 Permit). The purpose of the
MS4 Permit is to protect the beneficial uses of the receiving waters in the Los Angeles County
region by regulating municipal stormwater and non-stormwater discharges from the
permittees’ MS4s. The overarching goal of these requirements is to reduce the discharge of
pollutants from MS4s to the maximum extent practicable. The Permit allows permittees the
flexibility of developing an Enhanced Watershed Management Program (EWMP) to implement
the requirements of the Permit.
The City of Rolling Hills has elected to join the Peninsula WMG and the status is currently
pending the Water Board's decision. In response the the Water Board's comments, Rolling
Hills has been incorporated into the revised EWMP and identified as a full 85th percentile, 24-
hour storm retention area as demonstrated through monitoring. Continuous flow monitoring
was conducted in Sepulveda Canyon in Rolling Hills for two complete wet-weather seasons,
from October 26, 2020 through April 2022. Stormwater run-off that is not contained on
properties is conveyed through Rolling Hills via natural, soft-bottom, vegetated drainage
courses/canyons providing disconnection of impervious developed areas and ample
opportunity for natural bio-retention and infiltration. The no-flow results observed during three
85th%, 24-hr rainfall events as well as the numerous smaller rainfall events that occurred
throughout the monitoring period provide evidence that the strategies, control measures and
BMPs implemented by Rolling Hills cumulatively retain stormwater runoff up to and including
runoff from the 85th percentile, 24-hour storm event, as well as any conditionally exempt non-
stormwater discharges.
FISCAL IMPACT:
Costs for McGowan Consulting to revise the EWMP to include Rolling Hills is $23,550 funded
by the Stormwater account in the Planning Department.
RECOMMENDATION:
Receive and file.
48
ATTACHMENTS:
PVP EWMP Cover Letter (Mass-Based Approach) 22.05.13.pdf
PVP EWMP Response to RB Comments Table 22.05.13.pdf
PVP EWMP 22.05.13.pdf
49
Palos Verdes Peninsula
Enhanced Watershed Management Group
June 30, 2021 (Revised May 13, 2022) Transmitted electronically via
FTP site link: https://ftp.watersboards.ca.gov
Renee Purdy, Executive Officer
Regional Water Quality Control Board, Los Angeles Region
Attention: Ivar Ridgeway
Subject: Submittal of the Updated Palos Verdes Peninsula Enhanced Watershed Management
Program
Dear Ms. Purdy,
The Cities of Rancho Palos Verdes, Palos Verdes Estates, Rolling Hills Estates, Rolling Hills, and the
County of Los Angeles (Unincorporated County), along with the Los Angeles County Flood Control
District (LACFCD), collectively referred to as the Peninsula WMG, are pleased to submit the
updated Palos Verdes Peninsula Enhanced Watershed Management Program (Peninsula EWMP)
including an updated Reasonable Assurance Analysis (RAA). The updated Peninsula EWMP and
RAA have been prepared in accordance with the requirements of the 2021 LA MS4 Permit 1, the
Los Angeles Regional Water Quality Control Board Guidelines for Conducting RAA (March 2014),
and consistent with State Water Board Order WQ 2020-0038 (2020 State Board Order).
The updated RAA was conducted using the newly released, LACFCD-developed Watershed
Management Modeling System 2.0 (WMMS 2.0), for general consistency with other RAA
modeling efforts across Los Angeles County. The default WMMS 2.0 LSPC model has been
calibrated by LACFCD on a regional basis using data through September 2018. The updated RAA
also incorporated Peninsula Coordinated Integrated Monitoring Program (Peninsula CIMP) water
quality and flow data collected through June 2020 (the latest complete Peninsula CIMP reporting
year data set subjected to QA/QC validation), and as appropriate, utilized this data to calibrate
and validate the revised RAA model to best reflect the baseline hydrology and water quality
conditions within the Palos Verdes Peninsula EWMP area. Detailed information on the model
calibration can be found in Section 5 of the Appendix 4.1 RAA Report.
Consistent with the 2020 State Board Order, the updated Peninsula EWMP and RAA:
1 Order No. R4-2012-0105, NPDES Permit No. CAS00400 Waste Discharge Requirements and National Pollutant
Discharge Elimination System (NPDES) Permit for Municipal Separate Storm Sewer System (MS4) Discharges within
the Coastal Watersheds of Los Angeles and Ventura Counties.
50
Explains how information considered in the source assessment was used (EWMP Section
2 and Appendix 4.1 RAA Report).
Identifies unavailable, needed information and the assumptions made to substitute for
that information along with commitment to acquire the information through the
Peninsula CIMP for incorporation in the next adaptive management milestone (EWMP
Appendix 4.1 RAA Report 7.1.3 Mercury and Arsenic).
Utilizes all relevant, available data 2 to update the EWMP and RAA, including updates to
the water body pollutant combination (WBPC) prioritization and source assessment,
TMDL milestone achievement, and RAA calibration and validation. Data not used in the
RAA has been identified, with explanation as to why this data was disregarded.
Models each WBPC and therefore does not utilize or necessitate justification of a limiting
pollutant approach. Table 4-2 in Section 4 of the Updated EWMP provides the results of
this analysis for each WBPC supported by the detailed RAA Report in Appendix 4.1.
Includes 24-hour management volumes as a clear metric for demonstrating progress in
attaining load reduction targets – Table 5-1 in Section 5 of the Updated EWMP provides
the implementation schedule for demonstrating progress in attaining these volumetric
reductions by subwatershed and analysis region. Water body/pollutant milestones are
also included in this table.
Considers ongoing CIMP monitoring data which is sufficient to evaluate attainment of
milestones.
Modifications to Peninsula EWMP including Special Study for Mass-Based Compliance for
Machado Lake Nutrient TMDL
The 2020 State Water Board Order (p. 29) recognizes that “Additional fine-tuning to develop
more tailored pollutant levels and control plans…will often require updates to regional water
quality control plans” and that “water body-specific special studies can provide adequate
protections for beneficial uses at reduced compliance costs to local jurisdictions”. Furthermore,
Part C.3.b of Attachment N to the 2012 LA MS4 Permit pertaining to the Machado Lake Nutrient
TMDL states, “Permittees may be deemed in compliance with water quality-based effluent
limitations by demonstrating reduction of total nitrogen and total phosphorous on an annual
mass basis measured at the storm drain outfall of the Permittee’s drainage area where approved
by the Regional Water Board Executive Officer based on the results of a special study by the
Permittee.”
The County of Los Angeles previously completed a special study to establish annual mass-based
WQBELs for total nitrogen and total phosphorus under the Machado Lake Nutrient TMDL for its
unincorporated areas, including those within the Peninsula EWMP area, which was developed
2 “Available data” includes all data collected through June 30, 2020 by the Peninsula WMG. This date marks the
end of the 2019-2020 reporting year of CIMP monitoring results, which includes data that has been analyzed and
verified according to the Peninsula CIMP QAPP standard for quality assurance and quality control (QA/QC).
Monitoring data collected after this time has not yet been verified for QA/QC in accordance with this protocol, and
so has not been used in the updated RAA and EWMP, but will be used in the next update.
51
following approval of the Special Study Workplan by the Los Angeles Water Quality Control
Regional Board 3. The updated Peninsula EWMP RAA establishes mass-based loading estimates
and WLAs for the entire Peninsula EWMP area, consistent with and following the same approach
established in the approved Los Angeles County Machado Lake Nutrient TMDL Special Study4.
The updated RAA utilizes a mass-based approach to assess the annual average loading estimates
and the waste load allocations (WLAs) for constituents of concern associated with the Machado
Lake Nutrient TMDL.5 The approach is based on and consistent with the Los Angeles County
Machado Lake Nutrient TMDL Special Study, which was previously approved by the Regional
Board. The implemented approach utilizes both monitoring data and modeling results to
estimate the dry and wet weather total nitrogen and total phosphorus loads to Machado Lake
during the average annual year. Consistent with the Los Angeles County Special Study, water year
2010 was used as the critical year.
A summary of the approach used to establish the mass-based WLAs for both pollutants of
concern is as follows:
1. The average water year was used as the critical year, consistent with the County Special
Study.
2. The allowable annual average pollutant load was calculated as the Water Quality Based
Effluent Limit (WQBEL) concentration multiplied by the annual average inflow to
Machado Lake (8.45 HM3/year) apportioned to the Peninsula EWMP area (directly or via
Wilmington Drain). The table below shows the resultant pollutant loads for the Peninsula
EWMP area. Allowable annual average pollutant loads applicable to Unincorporated Los
Angeles County (taken directly from the approved Special Study) are also included to
demonstrate consistency in the approach.
3 LARWQCB (Los Angeles Regional Water Quality Control Board). 2010. Machado Lake Nutrient TMDL – Conditional
Approval of the Special Study Work Plan for the Unincorporated Areas of Los Angeles County within the Machado
Lake Watershed. May.
4 LACDPW (Los Angeles County Department of Public Works). 2011. Machado Lake Nutrient TMDL Special Study:
Characterization of Water Quality Conditions in the Unincorporated Areas of Los Angeles County within the
Machado Lake Watershed Final Report. September.
5 The Machado Lake Nutrient TMDL allows permittees to assess compliance with TMDL WLAs on a mass basis for
total nitrogen and total phosphorous by submitting a special study to the LARWQCB.
52
Unincorporated
County
Peninsula
EWMP Area2
Calculation input
Machado Lake watershed (sq-mi) 22.5
Annual average flow condition approved in
the Special Study (hm3/day) 8.45
Interim Concentration
Based WQBELs (mg/L)
TP 1.25
TN 2.45
Final Concentration
Based WQBELs (mg/L)
TP 0.1
TN 1
Compute annual average flow apportioned to the permittees
Area tributary to
Machado Lake (Directly
or Via Wilmington Drain)
sq-mi 1.89 4.95
% of Machado
Lake Watershed 8.4% 22.0%
Flow apportioned to the permittees
(hm3/day) 0.71 1.86
Compute the annual WLAs as concentration WQBELs multiplied by apportioned
annual average flow
Interim WLA (kg/year) TP 8871 2,322
TN 1,7391 4,550
Final WLA (kg/year) TP 711 186
TN 7101 1,857
1All numbers presented for the Unincorporated County are consistent with the approved WLAs by
the LARWQCB.
2The Peninsula EWMP area includes unincorporated Los Angeles County within the EWMP area, but
does not include the City of Rolling Hills, which is a full 85th percentile, 24-hour storm retention area.
3. The baseline annual mass-based loads were computed as the summation of annual dry
weather and wet weather mass-based loads during the critical year. The dry weather
mass-based load was based on dry weather flow and water quality monitoring data
collected through the Peninsula CIMP from June 2016 to June 2020. The wet weather
mass-based load was obtained using the calibrated WMMS 2.0 model, including
Peninsula CIMP data collected through June 2020.
4. The difference between the annual baseline load (step 3) and the annual WLA (step 2)
resulted in the target load reduction required to meet the allowable TMDL limits.
53
Utilizing this approach, the RAA demonstrates that annual mass-based loading for total nitrogen
from the Peninsula EWMP Area is less than the WLA for the critical condition, while annual mass-
based loading for total phosphorus from the area is slightly higher than the WLA. Appendix 4.1
of the EWMP provides the details of these RAA results and Chapter 3 of the EWMP describes the
projects that have been identified to reduce pollutant loads to achieve the WLAs.
Prior and Current Milestones and Associated Work
The updated EWMP demonstrates achievement of past and current milestones, consistent with
the requirements of the 2020 State Board Order. For the Santa Monica Bay subwatershed areas
of the Peninsula EWMP, attainment of the final receiving water limitations (RWLs) was
established in the previously approved EWMP and no additional milestones were due on or
before June 30, 2021. Monitoring data evaluated in this revision of the EWMP/RAA continues to
show that TMDL RWLs and/or water quality based effluent limitations (WQBELs) are being met
for pollutants of concern in the Santa Monica Bay subwatershed of the Peninsula WMG.
For the Inner Harbor and Cabrillo Marina water bodies of the Los Angeles Harbor to which the
Peninsula EWMP areas are tributary, monitoring data demonstrates compliance with relevant
Greater Los Angeles Harbor Toxics TMDL interim WQBELs in the bed sediment over a three-year
averaging period consistent with TMDL provisions translated into Order No. R4-2012-0175
Attachment N, E.4.a.ii. This is addressed in Table 4-1 in Section 4 of the updated Peninsula EWMP
as well as Section 7.6 of the Appendix 4.1 RAA Report. Thus, applicable prior and current
milestones are being met within the Los Angeles Harbor subwatershed areas of the Peninsula
EWMP and no other work associated with prior or current milestones was due in the previously
approved Peninsula EWMP on or before June 30, 2021.
For the Machado Lake subwatershed areas of the Peninsula EWMP, the updated RAA
demonstrates that interim WQBELs for Total Nitrogen and Total Phosphorus are being met in all
the analysis regions of the Machado Lake subwatershed as discussed in Section 4 of the EWMP
and in Section 7.6 of the Appendix 4.1 RAA Report. Final WQBELs are also being met in all analysis
regions within the Machado Lake subwatershed of the Peninsula EWMP for Total Nitrogen, Total
PCBs, Dieldrin and DDT (all congeners) as demonstrated in the RAA and shown by zero final target
load reductions in Table 11 of the Appendix 4.1 RAA Report. The final WQBELs for Total
Chlordane, DDE congeners and DDD congeners have not yet been attained within all analysis
regions of the Machado Lake subwatershed and additional load reductions are also necessary for
indicator bacteria in the Wilmington Drain analysis regions of the Machado Lake Subwatershed
to address the 303(d) listing. The updated RAA quantifies the additional capture volume
(expressed as 24-hour management volume) needed in each analysis region to satisfy the unmet
final target load reductions.
Some of the prior and current action-based milestones have been completed in the Machado
Lake subwatershed, including completion of two regional projects identified in the previously
approved EWMP. The two remaining regional projects identified in the previously approved
Peninsula EWMP have not been completed as planned since feasibility studies were conducted
54
and these projects were determined to be technically or environmentally infeasible. Alternative
projects in various stages of implementation (feasibility study, planning or design) have been
identified in the updated EWMP and incorporated into the RAA to address the remaining target
load reductions. Completion of the additional projects identified in Table 5-1 in Section 5 of the
Peninsula EWMP within five years of approval of the updated Peninsula EWMP will provide the
needed capture volumes and attain the final WQBELs for the remaining unmet final WQBELs for
Machado Lake as well as the RWLs for bacteria in Wilmington Drain. Timely requests for Time
Schedule Orders have been submitted by the Peninsula WMG for the Machado Lake Nutrients
and Pesticides & PCBs TMDLs to allow time for completion of these additional projects.
Thank you for consideration of our updated Peninsula EWMP and RAA. Please don’t hesitate to
contact me should Regional Board staff have any questions or require additional information.
55
56
Palos Verdes Peninsula EWMP: Response to Comments received on March 24, 2022 and April 6, 2022
Comment # Comment Response
RAA Comments
1
In the revised RAA, a 39.1% reduction in the baseline copper loading to the Los Angeles Harbor sub-
watershed was calculated. This load reduction was calculated based on a 2013 Draft Study conducted by
TDC Environmental for CASQA that described the expected percent reduction of copper as a result of the
passage of SB 346. Was this load reduction used as an assumption in the watershed baseline conditions or
as a model input? If this is correct, staff have concluded the WMP did not provide a sufficiently robust
justification to support the specified pollutant load reduction. In addition, since the RAA was updated to
included outfall and receiving water monitoring data through June 2020, it’s likely any copper load
reductions would have been accounted for as part of the model calibration. For these reasons a 39.1%
baseline copper load reduction may not be appropriate and may require the RAA to be re-run.
The EWMP and RAA has been
updated accordingly. See Section 4
and Appendix 4.1.
2
Another concern with the model and/or RAA is the use of the wrong criteria for the Machado Lake Nutrients
TMDL. The cities of Palos Verdes Estates, Ranch Palos Verdes and Rolling Hills Estates were not approved for
annual mass-based effluent limitations for total nitrogen and total phosphorus discharges. The Machado
Lake Nutrients TMDL allows for annual mass-based loading, only after a Permittee has demonstrated total
nitrogen and total phosphorous load reductions will be achieved in accordance with a special study
workplan approved by the Executive Officer (EO). The County of Los Angeles submitted a special study
workplan for the unincorporated County areas within the Machado Lake watershed, which was approved by
the EO. The PVP WMG used the County’s approval and applied it to the entire PVP WMP area. While this
approach may be acceptable; the cities of Palos Verdes Estates, Rancho Palos Verdes, and Rolling Hills
Estates didn’t submit the required workplan to receive approval for this approach as outlined in the
Machado Lake Nutrients TMDL. It may be possible for these cities to use the RAA in order to receive
approval for the mass-based loads. Be advised, management has not provided clarification to staff at this
time, which is important as the deadline specified in the TMDL allowing a mass-based load option has past.
Additional justification for using the
annual mass-based effluent
limitations method of compliance
added to the cover letter. Also see
Appendix 4.1.
3
Additionally, the model and/or RAA may have used the wrong bacteria criteria for E. coli. The data analysis
of E. coli indicator bacteria densities discharged to Wilmington Drain used the LREC-1 single sample
maximum receiving water limitation of 576/100 mL. However, the new REC-1 bacteria objectives for the
geometric mean (100 cfu/100 mL) and the statistical threshold value (320 cfu/100 mL) for E. coli should
have been used to evaluate discharges to Wilmington Drain. What criteria was used in the modeling and
RAA?
The EWMP and RAA has been
updated accordingly. See Section 4,
Section 5, and Appendix 4.1.
EWMP Comments
1
Section 5.2.2, Table 5-1, page 5-5, lists the structural targeted control measures to be implemented.
However, not all the modeled projects listed in Table 3-1 are included in Table 5-1. The two distributed
projects, Rolling Hills Road Street Improvement, 0.06 ac-ft and Palos Verdes Drive East Street Improvement,
0.04 ac-ft are not listed in Table 5-1. These two distributed projects are included in Figures 5-1 and 5-2. If
The EWMP has been updated
accordingly. See Section 3 and 5.
57
Comment # Comment Response
these projects will be relied on to meet compliance, then these projects need to be included in Table 5-1
and an implementation schedule needs to be provided.
2
Section 5.2.2, Figures 5-1, 5-2, and 5-3, pages 5-6 to 5-8, presents the projects by WMG member. Do these
figures include all the responsible Permittees for each project or just the lead WMG member as listed in
Table 5-1? If these figures do not include all responsible Permittees then the WMP needs to include this
information.
The EWMP has been updated
accordingly. See Section 5. The
responsible Permittees are listed in
Figures 5-1, 5-2, and 5-3.
3
In Section 3.5.1.1.3 Proposed Regional BMPs, on page 3-25, the Palos Verdes Drive East Street Improvement
is listed as a proposed project in the Machado Lake Watershed. However, there is no description of this
project in this section. In Section 3.5.1.1.4 Potential Regional BMPs, there is a description of the Palos
Verdes Drive East Green Street project. Are these the same project? If so, then the WMP needs to specify
whether this is a “proposed” or “potential” project. If these are two different projects then provide a
description in Section 3.5.1.1.3. In addition, clarify which project was modeled as listed in Table 3-1 on page
3-11.4. Assess 1st year of CIMP data to verify existing load assumptions and assess the group's contribution
of coliform bacteria by July 1, 2016 (Wilmington Drain).
The EWMP has been updated
accordingly. See Section 3. The Palos
Verdes Drive East Street
Improvement is the same project as
the Palos Verdes Drive East Green
Street project. The project is
“potential”.
4
In Section 3.1.2.6, for the Public Information and Participation Program, include the metrics for measuring
the effectiveness in achieving each objective listed in Part VIII.D.2 of the Order, as required in Part VIII.D.4.a
of the Order.
The EWMP has been updated
accordingly. See Section 3.
5 Per Part IX.G.3.a of the Order, update the Peninsula WMP to be consistent with the requirements of the
Regional MS4 Permit and update all references to the previous permit.
The EWMP and RAA have been
updated accordingly.
6 Update the Peninsula WMP to include the Addendum from the City of Rolling Hills. The EWMP and RAA have been
updated accordingly.
7 Where necessary, update links and references to the 2018 303(d) list, which is the current 303(d) list (e.g.,
Sections 1.3.1 and 2.2 of the EWMP).
The EWMP has been updated
accordingly.
8 Table 2-11, page 2-21, the Sediment Target unit is incorrect it should be micrograms/kg not nanograms/kg. The units have been corrected.
9
Section 2.2.3, page 2-23, second paragraph, in the sentence “Thus, there appears to have been no
degradation in sediment quality in these three water bodies since adoption of the TMDL.” Besides Los
Angeles Harbor and Cabrillo Marina, what is the third water body this sentence is referencing?
The EWMP has been updated
accordingly. The Peninsula drains to
two waterbodies in the Los Angeles
Harbor Watershed: Inner Harbor
and Cabrillo Marina.
10
Section 2.3, page 2-26, tenth bullet, Figure 1-1 does not show the Peninsula agencies’ MS4s, major outfalls,
or major structural controls.
The EWMP has been updated
accordingly. Figure 1-1 shows the
Peninsula agencies’ MS4s and major
outfalls. Figure 3-1 shows the
structural controls modeled in the
RAA.
11 Section 2.3.1, page 2-28, Table 2-14 is not consistent with the narrative that follows. For example, sanitary
sewer, septic systems, and RV waste are sources of bacteria, and wildfires are sources of PAHs and increase
The EWMP has been updated
accordingly. Sources have been
58
Comment # Comment Response
TSS. Does Table 2-14 present only the MS4 sources of priority pollutants that the Peninsula WMP will be
addressing? If so, then this needs to be clarified in the WMP.
updated to be consistent with the
narrative.
12
Section 2.3.2, Table 2-17, page 2-42: According to the Addendum to the Palos Verdes Peninsula EWMP
submitted by the City of Rolling Hills, "The Portion of the Peninsula WMG with drainage tributary to Santa
Monica Bay consists of approximately 14.8 square miles, which is about 3.6% of the Santa Monica Bay
Watershed (414 sq. mi.)." Therefore, the calculation of the percentage of the Santa Monica Bay DDT and
PCBs TMDL annual mass-based wasteload allocation should be based on 3.6% not 3.8%. Update, the Santa
Monica Bay TMDL Annual Mass-Based WLA in Table 2-17, to 0.97 g/year and 5.05 g/year for DDT and PCBs,
respectively.
The EWMP has been updated
accordingly. The SMB TMDL Annual
Mass-Based WLA has been updated
in Table 2-17.
13
In the second column of Table 2-18, page 2-43 there is an asterisk on the units, is there a missing footnote? The EWMP has been updated
accordingly. A footnote has been
added in Table 2-18
14
Update Figure 2-12, on page 2-50, to use the E. coli STV of 320 cfu/100 mL as the receiving water criteria. The EWMP has been updated
accordingly. Figure 2-12 has been
removed. Narrative reflects the
change of receiving water criteria.
15
Footnote (c) of Table 3-1, page 3-11, states, “Does not include non-Peninsula EWMP drainage area.” Is this
statement still valid now that Rolling Hills is joining the WMP?
The EWMP and RAA has been
updated accordingly. Rolling Hills is
now a part of the Peninsula EWMP.
16
Section 3.5.1.1.1, San Ramon Canyon, page 3-14: Water Conservation/Supply is listed as one of the benefits
of the San Ramon Canyon project. Does this project retain stormwater onsite?
The EWMP has been updated
accordingly. Additional details about
project water supply benefit has
been added to Section 3.5.1.1.1.
17
In Table 4-3, page 4-6, the final target load reduction value of 1.5 ac-ft for analysis region LAH-CM has
footnote 1. Footnote 1 does not seem to apply, should this be a different footnote reference?
The EWMP and RAA have been
updated accordingly. Footnote has
been revised in Table 4-3.
18
In Table 5-1, page 5-5, the "Final TLR Equivalent 24-hour Management Volume” values for analysis regions
WD-Solano and LAH-IH do not match the values in Table 4-3 and Appendix 4.1 RAA, Section 7.6, Table 11.
The EWMP and RAA has been
updated accordingly. See consistent
values from Section 4, Section 5, and
Appendix 4.1.
19 In Section 10.1, page 10-1, the annual reporting period is from July 1st through June 30th of the following
year. Correct footnote 87 to reflect these dates not June 1st through July 30th.
The EWMP has been updated
accordingly. Footnote corrected.
20
Per Part IX.A.4.l of the Order, identify the lead agency for the Peninsula WMG. The EWMP has been updated
accordingly. See Section 1
identifying the City of RPV as the
lead agency for the Peninsula WMG.
21 Remove any statements intended to make implementation of actions contingent on funding or information-
gathering. While such issues may be cited in a separate request for a scheduling change to the Los Angeles
The EWMP has been updated
accordingly.
59
Comment # Comment Response
Water Board Executive Officer, they cannot be used to create a contingency. To the extent that any
contingency statements remain in the WMP, the Board gives them no effect.
60
PALOS VERDES
PENINSULA ENHANCED
WATERSHED
MANAGEMENT PROGRAM
Submitted By:
Palos Verdes Peninsula
Watershed Management Group
Revised: May 13, 2022
61
Palos Verdes Peninsula
Enhanced Watershed Management Program
i | Page
Table of Contents
1. Introduction and Background ............................................................................................................ 1-1
1.1. Introduction ............................................................................................................................... 1-1
1.2. Peninsula Watershed ................................................................................................................. 1-2
1.3. Water Quality Issues and the History of Water Quality Regulations ......................................... 1-4
1.3.1. Federal Law, State Law, and Regulatory Framework ......................................................... 1-4
1.3.2. California Environmental Quality Act ................................................................................. 1-5
1.4. Water Quality Requirements ..................................................................................................... 1-6
1.5. The Enhanced Watershed Management Program .................................................................... 1-7
1.5.1. Watershed Management Goals and Priorities ................................................................... 1-7
1.5.2. Water Quality Management Approach .............................................................................. 1-7
1.6. Reasonable Assurance Analysis and Watershed Control Measures ........................................ 1-10
1.7. Adaptive Management ............................................................................................................ 1-11
2. Identification of Water Quality Priorities ........................................................................................... 2-1
2.1. Water Quality Characterization and Prioritization .................................................................... 2-1
2.2. Receiving Water Characterization ............................................................................................. 2-3
2.2.1. Santa Monica Bay ............................................................................................................... 2-8
2.2.2. Machado Lake .................................................................................................................. 2-16
2.2.3. Greater Los Angeles Harbor ............................................................................................. 2-23
2.3. Source Assessment .................................................................................................................. 2-27
2.3.1. Watershed Sources of Priority Pollutants ........................................................................ 2-27
2.3.2. Characterization of Stormwater and Non-Stormwater Discharge Quality ...................... 2-42
3. Selection of Watershed Control Measures ........................................................................................ 3-1
3.1. Minimum Control Measures ...................................................................................................... 3-2
3.1.1. L.A. County Flood Control District Minimum Control Measures ....................................... 3-2
3.1.2. Assessment and Modification of Minimum Control Measures (Participating Agencies,
Excluding LACFCD).............................................................................................................................. 3-2
3.1.4 Fifth Term MS4 Permit Minimum Control Measures ............................................................ 3-4
3.2. Non-stormwater Discharge Measures ....................................................................................... 3-5
3.3 Targeted Control Measures ....................................................................................................... 3-6
3.3.1 Control Measures identified in TMDLs/Implementation Plans ......................................... 3-6
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3.4 Nonstructural Targeted Control Measures ................................................................................ 3-8
3.5 Structural Targeted Control Measures ...................................................................................... 3-9
3.5.1 Performance Evaluation of Structural Control Measures .................................................. 3-9
3.5.2 85th Percentile, 24-hour Runoff Retention Areas ............................................................ 3-32
Rolling Hills Nature-Based Runoff Retention Area .......................................................................... 3-34
4. Reasonable Assurance Analysis ......................................................................................................... 4-1
4.1. RAA Summary ............................................................................................................................ 4-1
4.2. Reasonable Assurance Analysis ................................................................................................. 4-2
5. Implementation Schedule .................................................................................................................. 5-1
5.1. Introduction ............................................................................................................................... 5-1
5.2. Schedules ................................................................................................................................... 5-2
5.2.1. Nonstructural Best Management Practices Schedule ....................................................... 5-3
5.2.2. Structural Best Management Practice Schedule ............................................................... 5-3
6. EWMP Implementation Costs and Financial Strategy ....................................................................... 6-1
6.1. EWMP Implementation Costs .................................................................................................... 6-1
6.1.1. Methodology ...................................................................................................................... 6-1
6.2. Summary of Costs ...................................................................................................................... 6-3
6.3. Financial Strategy ....................................................................................................................... 6-5
6.3.1. Summary ............................................................................................................................ 6-5
6.3.2. Other Potential Funding Options ....................................................................................... 6-8
6.3.3. Prioritization ..................................................................................................................... 6-10
7. Legal Authority ................................................................................................................................... 7-1
8. Coordinated Integrated Monitoring Program ................................................................................... 8-1
9. Adaptive Management Process ......................................................................................................... 9-1
9.1. Modifications ............................................................................................................................. 9-1
9.1.1. Reporting ............................................................................................................................ 9-1
9.1.2. Implementation ................................................................................................................. 9-2
9.2. Receiving Water Limitations ...................................................................................................... 9-3
10. Reporting Program & Assessment ............................................................................................... 10-1
10.1. Annual Report ...................................................................................................................... 10-1
10.2. Monitoring Report ............................................................................................................... 10-2
10.2.1. Data Reporting ................................................................................................................. 10-2
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10.2.2. Chronic Toxicity Reporting ............................................................................................... 10-2
10.2.3. TMDL Reporting ............................................................................................................... 10-2
List of Tables
Table 1-1: Jurisdictional Areas within Each Peninsula EWMP Watershed ................................................ 1-2
Table 2-1: Peninsula EWMP Priority Pollutants ......................................................................................... 2-2
Table 2-2: Peninsula EWMP Area Water Bodies and Beneficial Uses Designated in the Basin Plan ......... 2-4
Table 2-3: TMDLs Applicable to the Peninsula EWMP ............................................................................... 2-6
Table 2-4: 303(d) Listed Pollutants in Peninsula EWMP Watersheds ........................................................ 2-7
Table 2-5: SMBBB TMDL Bacteria Objectives ............................................................................................ 2-8
Table 2-6: Allowable Exceedance Day(s) by Period and Monitoring Location .......................................... 2-9
Table 2-7: Number of Exceedance Days Above Allowable Receiving Water Limitations ........................ 2-10
Table 2-8: Number of Year-Round Rolling Six-Week Geomean Exceedances of Receiving Water Limitations
................................................................................................................................................................. 2-11
Table 2-9: Nutrient TMDL Numeric Targets and Load Allocations for Machado Lake ............................ 2-19
Table 2-10: Monthly Average TN and TP Concentration in Machado Lake ............................................. 2-20
Table 2-11: Machado Lake Toxics TMDL In-Lake Numeric Targets.......................................................... 2-22
Table 2-12: Greater Harbor Toxics TMDL Marine Sediment Targets ....................................................... 2-24
Table 2-13: Water Quality Exceedances in Greater Los Angeles Harbor Waters to which Peninsula WMG is
Tributary ................................................................................................................................................... 2-25
Table 2-14: Potential Watershed Sources of Palos Verdes Peninsula Priority Pollutants ....................... 2-29
Table 2-15: Land Use Distribution within the Palos Verdes Peninsula Watersheds ................................ 2-30
Table 2-16: Automotive Sources of Metals in Stormwater ..................................................................... 2-35
Table 2-17: Santa Monica Bay DDT & PCBs 3-Year Rolling Average Outfall Data.................................... 2-43
Table 2-18: Machado Lake Pesticides & PCBs 3-Year Rolling Average Concentrations in Storm-Borne
Sediment .................................................................................................................................................. 2-44
Table 3-1: Summary of Modeled Regional BMPs .................................................................................... 3-11
Table 4-1: Interim Wet Weather Target Load Reduction Summary .......................................................... 4-3
Table 4-2: Final Wet Weather Target Load Reduction Summary .............................................................. 4-4
Table 4-3: Peninsula EWMP RAA Summary ............................................................................................... 4-6
Table 5-1: Structural TCM Implementation Schedule................................................................................ 5-5
Table 6-1: WMMS 2.0 Cost Function ......................................................................................................... 6-2
Table 6-2: Range of Soft Costs for Regional Projects ................................................................................. 6-3
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Table 6-3: Estimated Capital and O&M Costs for Regional BMPs ............................................................. 6-4
Table 6-4: Funding Option Priorities ........................................................................................................ 6-10
Table 7-1: Water Quality Ordinance Language .......................................................................................... 7-1
List of Figures
Figure 1-1: Peninsula EWMP Area and Existing Monitoring Locations ...................................................... 1-3
Figure 2-1: Santa Monica Bay Total Coliform Concentrations 2016-2020 .............................................. 2-12
Figure 2-2: Santa Monica Bay Fecal Coliform Concentrations 2016-2020 .............................................. 2-13
Figure 2-3: Santa Monica Bay Enterococci Concentrations 2016-2020 ................................................... 2-14
Figure 2-4: Storm Drains Entering Machado Lake ................................................................................... 2-18
Figure 2-5: Machado Lake Monitoring Stations ....................................................................................... 2-21
Figure 2-6: Greater LA Harbor Waters and Monitoring Stations ............................................................. 2-26
Figure 2-7: Total Nitrogen Concentrations in Peninsula Machado Lake Outfall flows from 2016-2020 . 2-46
Figure 2-8: Total Phosphorus Outfall Concentrations in Peninsula Machado Lake Outfall flows 2016-2020
................................................................................................................................................................. 2-47
Figure 2-9: Total Coliform Concentrations in Peninsula Stormwater Discharges from SD1 and SD2 (2016-
2020) ........................................................................................................................................................ 2-48
Figure 2-10: Fecal Coliform Concentrations in Peninsula Stormwater Discharges from SD1 and SD2 (2016-
2020) ........................................................................................................................................................ 2-49
Figure 2-11: Enterococci Concentrations in Peninsula Stormwater Discharges from SD1 and SD2 (2016-
2020) ........................................................................................................................................................ 2-50
Figure 3-1: Modeled Regional Projects .................................................................................................... 3-10
Figure 3-2: Casaba Estates (formerly Butcher Ranch) Post-Development Design Conditions. ............... 3-13
Figure 3-3: San Ramon Canyon Project .................................................................................................... 3-14
Figure 3-4: Chandler Quarry Project Drainage Area Map ........................................................................ 3-16
Figure 3-5: Chandler Quarry Project Drainage and Water Quality Concept Plan .................................... 3-17
Figure 3-6: Chandler Quarry Project Infiltration System Concept Design ............................................... 3-18
Figure 3-7: Torrance Airport Drainage Area ............................................................................................ 3-20
Figure 3-8: Conceptual Layout of Torrance Airport Basin ....................................................................... 3-21
Figure 3-9: Geologic Hazards in the Palos Verdes Peninsula Watershed ................................................ 3-24
Figure 3-10: Proposed PVP Multi-Benefit Flow Diversion Drainage Area ............................................... 3-26
Figure 3-11: Proposed Eastview Park Infiltration Project Drainage Area ................................................ 3-28
Figure 3-12 85th Percentile, 24-Hour Runoff Retention Areas Excluded from RAA ................................. 3-33
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Figure 3-13 Rolling Hills Nature-Based Stormwater Runoff Retention Area ........................................... 3-35
Figure 5-1: 24-Hour Management Volume Breakdown in Wilmington Drain WMA (WD-1 and WD-Solano)
................................................................................................................................................................... 5-6
Figure 5-2: 24-Hour Management Volume Breakdown in Machado Lake WMA (ML-1) .......................... 5-7
Figure 5-3: 24-Hour Management Volume Breakdown in Los Angeles Harbor WMA .............................. 5-8
List of Appendices
Appendix 1.0 LA County Flood Control District Summary
Appendix 3.1 Nonstructural Targeted Control Measures
Appendix 3.2 Structural Best Management Practices
Appendix 4.1 Reasonable Assurance Analysis Report
Appendix 4.2 Requirements for Achieving Receiving Water Limits
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1. INTRODUCTION AND BACKGROUND
1.1. INTRODUCTION
The Los Angeles Regional Water Quality Control Board (Regional Board) regulates discharges from
municipal separate storm sewer systems (MS4s) through the Municipal Separate Storm Sewer System
Permit (MS4 Permit). The purpose of the MS4 Permit is to protect the beneficial uses of the receiving
waters in the Los Angeles County region by regulating municipal stormwater and non-stormwater
discharges from the permittees’ MS4s. The overarching goal of these requirements is to reduce the
discharge of pollutants from MS4s to the maximum extent practicable.1 The Permit allows permittees the
flexibility of developing an Enhanced Watershed Management Program (EWMP) to implement the
requirements of the Permit. Implementation is to be achieved on a watershed basis through customized
strategies, control measures, and BMPs to ensure that discharges from the permittees’ MS4s:
i. Achieve applicable WQBELs,
ii. Do not cause or contribute to exceedances of receiving water limitations, and
iii. Do not include non-storm water discharges that are effectively prohibited.
Following the adoption of the 2012 MS4 Permit, the Cities of Palos Verdes Estates, Rancho Palos Verdes,
Rolling Hills Estates, along with the County of Los Angeles (Unincorporated County), and Los Angeles
County Flood Control District (LACFCD), collectively referred to as the Peninsula WMG, began to
collaborate on the initial development of an Enhanced Watershed Management Program (EWMP) to
implement the requirements of the MS4 Permit on a watershed scale and address the water quality
priorities for the Palos Verdes Peninsula watersheds. The Peninsula WMG coordinated with other
agencies and watershed management groups in the initial development of the 2016 EWMP, including the
City of Los Angeles, the Dominguez Channel EWMP Group, and the Beach Cities EWMP Group. The initial
Peninsula EWMP was approved by the Regional Board in April 2016. The City of Rolling Hills has elected
to join the Peninsula WMG and has been incorporated into this revised EWMP. The City of Rancho Palos
Verdes is the lead agency for the Peninsula WMG.
This revised EWMP reevaluates the Peninsula WMG’s water quality priorities identified during the initial
development of the 2016 EWMP in Section 2, presents an updated program of BMPs intended to achieve
these water quality priorities in Section 3The results of the revised EWMP are significantly different than
the initial EWMP due to availability of Coordinated Integrated Monitoring Program (CIMP) monitoring
data and continuous flow monitoring data within the Peninsula WMG area used to calibrate the updated
Reasonable Assurance Analysis (RAA) model. The updated Reasonable Assurance Analysis (RAA) results
are summarized in Section 4 and the BMP implementation schedule is summarized in Section 5. The
financial strategy incorporating new sources of funding for implementation is detailed in Section 6, Section
7 provides the Legal Authority language, Section 8 refers to the Coordinated Integrated Monitoring
Program, Section 9 summarizes the Adaptive Management process, and Section 10 summarizes the
Reporting Program.
1 Reference: http://www.swrcb.ca.gov/water_issues/programs/stormwater/municipal.shtml
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1.2. PENINSULA WATERSHED
The geographic scope of the Peninsula EWMP (as shown in Figure 1-1) is comprised of the incorporated
Cities of Rancho Palos Verdes, Palos Verdes Estates, Rolling Hills, Rolling Hills Estates, and unincorporated
areas of the County of Los Angeles and LACFCD facilities (See Appendix 1.0 for a description of the LACFCD
and its responsibilities within the Peninsula WMG).
The Palos Verdes Peninsula is situated in the southwestern portion of Los Angeles County atop the Palos
Verdes Hills, which are bounded to the north by the cities of Torrance and Lomita, to the east by the San
Pedro area of the City of Los Angeles, and to the south and west by the Pacific Ocean. The Peninsula WMG
area is divided into two HUC-12 equivalent watersheds: 1) Santa Monica Bay (SMB) Watershed and 2) the
Greater Dominguez Channel Watershed Management Area, which is subdivided into two subwatersheds,
the Los Angeles Harbor Subwatershed and the Machado Lake Subwatershed. A change in drainage divides
the Peninsula WMG from the northeast to the southwest with the westerly and southwesterly portion
draining into Santa Monica Bay and the northeasterly portion draining to Machado Lake and the Los
Angeles Harbor. The SMB Watershed accounts for 58% (14.8 square miles) of the total Peninsula WMG
area, and includes portions of the cities of Palos Verdes Estates, Rancho Palos Verdes, Rolling Hills, and
Rolling Hills Estates. The Los Angeles Harbor Subwatershed accounts for 18% (4.5 square miles) of the
total Peninsula WMG area and includes portions of the cities of Rancho Palos Verdes, Rolling Hills, and
Rolling Hills Estates. The Machado Lake Subwatershed accounts for 24% (6.2 square miles) of the total
Peninsula WMG area, and includes portions of the cities of Palos Verdes Estates, Rancho Palos Verdes,
Rolling Hills, Rolling Hills Estates, and the unincorporated areas of the County of Los Angeles. Drainage
from the Peninsula WMG agencies is conveyed via natural soft bottom canyons in conjunction with
structured storm drain systems. Table 1-1 provides the Peninsula EWMP area identified by watershed and
agency, and Figure 1-1 provides a map of the Peninsula EWMP watershed and jurisdictional boundaries,
including existing water quality monitoring sites in the Peninsula EWMP area.
Table 1-1: Jurisdictional Areas within Each Peninsula EWMP Watershed
Permittee Rancho
Palos
Verdes
Palos
Verdes
Estates
Rolling
Hills
Rolling
Hills
Estates
County of
Los Angeles
Total
Land Area within Santa
Monica Bay Watershed
(Square Miles)
9.35 4.35 0.64 0.46 0 14.8
Land Area within Machado
Lake Subwatershed
(Square Miles)
1.07 0.39 1.3 2.78 0.7 6.2
Land Area within Los
Angeles Los Angeles Harbor
Subwatershed
(Square Miles)
3.02 0 1.1 0.34 0 4.5
Total EWMP Area 13.5 4.8 3.0 3.6 0.7 25.6
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Figure 1-1: Peninsula EWMP Area and Existing Monitoring Locations
Peninsula-RW1
Peninsula-RW2
SMB 7-1
SMB 7-2
SMB 7-3 SMB 7-4 SMB 7-5
Receiving Water Site
Outfall Site
TMDL Site
City of Rolling Hills
(Full 85th Percentile
24-Hour Storm Retention Area)
Rolling Hills
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1.3. WATER QUALITY ISSUES AND THE HISTORY OF WATER QUALITY
REGULATIONS
1.3.1. FEDERAL LAW, STATE LAW, AND REGULATORY FRAMEWORK
The Clean Water Act (CWA) establishes the basic structure for regulating discharges of pollutants into the
waters of the United States and regulating quality standards for all inland surface waters, estuaries, and
coastal waters. The federal Environmental Protection Agency (EPA) is ultimately responsible for
implementation of the CWA and its associated regulations. In 1972 the National Pollution Discharge
Elimination System (NPDES) was created through Section 402 of the Federal Clean Water Act. The NPDES
prohibits discharges of pollutants from any point source, including the MS4 system, into the nation's
waters except as allowed under an NPDES permit. The MS4 system includes curbs and gutters, man-made
channels, catch basins and storm drains.
The CWA allowed the federal EPA to authorize the NPDES Permit Program to state governments, enabling
states to perform many of the permitting, administrative, and enforcement aspects of the NPDES
Program. California, like other states, implements the CWA by promulgating its own water quality
protection laws and regulations. As long as this authority provides equivalent protections as the federal
CWA, EPA can delegate CWA responsibilities to the state while retaining oversight responsibilities. In some
cases, California has established requirements that are more stringent than federal requirements.
The 1970, the Porter-Cologne Water Quality Control Act granted the California State Water Resources
Control Board (SWRCB) broad powers to protect water quality. The SWRCB chartered nine Regional Water
Quality Control Boards (Regional Boards) with regulatory responsibility for developing and enforcing
water quality objectives and implementation plans to best protect the beneficial uses of local
waterbodies. To protect clean water at the local level, municipalities in Los Angeles County and the County
of Los Angeles unincorporated areas are required to obtain a discharge permit from the Regional Board
to discharge stormwater through the MS4 into Waters of the United States, hence the MS4 Permit. The
Los Angeles Regional Water Quality Control Board (Regional Board) is the governing regulatory agency for
water quality within the Peninsula WMG area.
Section 303(d) of the CWA requires states to regularly identify waterbodies not meeting water quality
objectives. These waters are often referred to as "303(d) listed" or "impaired" waters. Development and
approval of the 303(d) list is a lengthy state and federal process. A list is not effective until the USEPA
approves the list. The current 303(d) list for California was approved by USEPA on April 6th, 2018. Changes
from the previous 303(d) list include removal of sediment toxicity for the Santa Monica Bay
Offshore/Nearshore, and revising the list of Category 2 Water Body Pollutant Combinations by adding
arsenic and mercury impairments for the Santa Monica Bay Offshore/Nearshore.
Waterbodies that are listed on the 303(d) list typically require development of a Total Maximum Daily
Load (TMDL) for the pollutant(s) impairing the use of water. A TMDL establishes the maximum amount of
a pollutant that a waterbody can receive and still meet water quality standards. Depending on the nature
of the pollutant, TMDL implementation requires limits on the contributions of pollutants from point
sources (waste load allocation), nonpoint sources (load allocation), or both.
Adoption of a TMDL requires an amendment to the Water Quality Control Plan (known as the Basin Plan)
for the Los Angeles Region. The Regional Board's Basin Plan is designed to preserve and enhance water
quality and protect the beneficial uses of regional waters. Specifically, the Basin Plan (i) designates
beneficial uses for surface and ground waters, (ii) sets narrative and numerical objectives that must be
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attained or maintained to protect the designated beneficial uses and conform to the state's
antidegradation policy, and (iii) describes implementation programs to protect all waters in the Region.
The Basin Plan is reviewed and updated as necessary (Regional Board 1994, as amended). Following
adoption by the Regional Board, the Basin Plan and subsequent amendments are subject to approval by
the State Board, the State Office of Administrative Law (OAL), and the Environmental Protection Agency
(EPA). The MS4 Permit includes effluent limitations, receiving water limitations, minimum control
measures (MCMs), and TMDL provisions, and outlines the process for developing watershed management
programs, including the EWMP. Development of an EWMP is one of the options outlined in the MS4
Permit to address effluent limitations, receiving water limitations, and TMDLs. The EWMP must also
incorporate MCMs, which are programs required to be implemented to address water quality issues.
1.3.2. CALIFORNIA ENVIRONMENTAL QUALITY ACT
The stormwater structural controls that will be implemented as a result the EWMP may require
discretionary approval subject to review under the California Environmental Quality Act (CEQA). The
LACFCD has prepared a Programmatic Environmental Impact report (PEIR) for all EWMP groups in which
they are a part. This PEIR covers CEQA requirements for the EWMPs as a whole. The Peninsula WMG
intends to comply with CEQA when implementing structural BMPs contained in this updated EWMP.
Public agencies responsible for carrying out or approving stormwater structural controls are identified as
the lead agency. The environmental review required imposes both procedural and substantive
requirements. At a minimum, the lead agency will adhere to the consultation and public notice
requirements set forth in the CEQA Guidelines, make determinations whether the proposed stormwater
structural control is a “project”, and if so, conduct an initial review of the project and its environmental
effects. The lead agency will identify and document the potential environmental impacts of the proposed
project in accordance with CEQA, (Public Resources Code Section 21000 et seq.), and the CEQA Guidelines
(Title 14 of the California Code of Regulations, Section 15000, et seq.).
Certain classes of projects have been determined not to have significant effect on the environment and
are exempt from the provisions of CEQA by statute or category. When a public agency decides that a
project is exempt from CEQA, and the public agency approves or determines to carry out the project, the
agency may file a Notice of Exemption. For projects deemed not exempt, the lead agency will prepare an
Initial Study and decide whether a Negative Declaration is applicable for the project, or depending on the
potential effects, a further, and more substantial review may be conducted in the form of an
Environmental Impact Report (EIR). A project may not be approved as submitted if feasible alternatives
or Mitigation Measures are not able to substantially lessen the significant environmental effects of the
project. Moreover, environmental review must include provisions for wide public involvement, formal
and informal, in order to receive and evaluate public reactions to environmental issues, and when deciding
the matter, the lead agency must consider all comments it receives (Cal. Pub. Res. Code § 21091(d)(1); 14
CCR § 15074(b)). The lead agency will use the EIR in determining the environmental effects of the
proposed storm water project, and whether or not to approve the proposed project. If the proposed
project is approved, all conditions and mitigations made in the adopted EIR will become part of any
subsequent actions taken by the lead agency. The CEQA process will also be used by permitting agencies,
funding agencies and the public to support proposed project decisions.
The National Environmental Policy Act (NEPA) comes into play less often than CEQA, but may be included
for storm water projects involving federal funding. A joint NEPA and CEQA review process is encouraged
to improve coordination and avoid redundancies. Like CEQA, the NEPA process provides opportunities to
address issues related to proposed projects early in the planning stages. NEPA was codified under Title 42
of the United States Code sections 4331 et seq. (42 U.S.C. 4331 et seq.).
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1.4. WATER QUALITY REQUIREMENTS
The Regional Board designates "beneficial uses" for waterbodies in the watersheds that it governs and
adopts water quality objectives to protect these uses through the Basin Planning process2. In some cases,
EPA may also promulgate objectives where it makes a finding that the state's objectives are not protective
enough to protect the beneficial use. The nature of the objectives is directly related to the type of
beneficial use. For example, the freshwater warm habitat beneficial use protects aquatic organisms
resident in warm-water streams. The associated water quality objectives are for those constituents known
to affect both the growth and reproduction of aquatic life. These objectives range from physical
characteristics such as temperature, dissolved oxygen, and pH to potential toxic constituents including
metals and organics. In California, the objectives for metals and a number of organic compounds have
been established by the federal EPA rather than the state (California Toxics Rule, 2000). The EPA
promulgated numeric water quality criteria for priority toxic pollutants and other water quality standards
provisions based on the determination that the numeric criteria were necessary (since the state had been
without numeric water quality criteria for many priority toxic pollutants as required by the CWA) to
protect human health and the environment. These Federal criteria are legally applicable in the state for
inland surface waters, enclosed bays and estuaries for all purposes and programs under the CWA. The
State Water Resources Control Board (State Water Board) adopted the Water Quality Control Plan for
Ocean Waters in California, California Ocean Plan in 1972 and adopted the most recent amended Ocean
Plan on February 4, 2019. The Ocean Plan also establishes water quality objectives and a program of
implementation to protect beneficial uses at all MS4 discharge points within Los Angeles County coastal
watersheds. See Chapter 2 for more details.
2 See Regional Board’s Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties, accessed May 07, 2021.
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1.5. THE ENHANCED WATERSHED MANAGEMENT PROGRAM
1.5.1. WATERSHED MANAGEMENT GOALS AND PRIORITIES
Addressing MS4 discharges on a watershed scale allows permittees to meet the requirements of the
Permit and address water quality priorities in an integrated and collaborative way. The conditions of the
receiving waters drive management actions, which in turn focus on the measures to address pollutant
contributions to and from the MS4.
The ultimate goals of the EWMP is to ensure that discharges from the MS4:
1. Achieve applicable Water Quality Based Effluent Limitations (WQBELs) that implement TMDLs,
2. Do not cause or contribute to exceedances of receiving water limitations,
3. Non-stormwater discharges from the MS4 are not a source of pollutants to receiving waters.
1.5.2. WATER QUALITY MANAGEMENT APPROACH
Development of an EWMP is one of the options outlined in the MS4 Permit held by Permittees to address
effluent limitations, receiving water limitations, and TMDLs. The EWMP includes an evaluation of existing
water quality conditions, including characterization of storm water and non-storm water discharges from
the MS4 and receiving water quality to support identification and prioritization/sequencing of
management actions. At a minimum, water quality priorities within each Watershed Management Area
must include achieving applicable water quality-based effluent limitations and/or established receiving
water limitations.
The MS4 permit requires that this EWMP identify strategies, control measures, and BMPs to implement
on a watershed scale, with the goal of creating an efficient program to focus collective resources on
meeting watershed priorities and effectively controlling the source of pollutants to and from the MS4.
See Chapter 2 of this EWMP for an evaluation of existing water quality conditions and classification of
waterbody pollutant combinations as Category 1 (Highest Priority), Category 2 (High Priority), and
Category 3 (Medium Priority).
This EWMP has incorporated State agency input from various sources on priority setting and
implementation issues. Specific priorities incorporated include, but are not limited to, the following:
• The EWMP is consistent with priorities listed in SB 985 and is in accordance with the Storm Water
Resource Plan Guidelines 3 for all categories with the exception of those which are more applicable to
the Peninsula Coordinated Integrated Monitoring Plan and the California Water Service Urban Water
Management Plan.
• The Peninsula WMG lies within the South Bay subregion of the LA IRWMP and will include its regional
projects in the LA IRWMP database.
• The Stormwater Strategic Initiative 4 identifies prioritization of projects to address issues facing the
storm water program. Efforts described within this EWMP have used the same priorities in mind,
3 Storm Water Resource Plan Guidelines. State Water Resources Control Board. December 15, 2015.
4 Stormwater Strategic Initiative. State Water Resources Control Board. June 25, 2015.
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including, but not limited to optimizing the use of stormwater as a resource and providing consistent
and widespread messaging to broaden the understanding of the value of stormwater.
• The Strategy to Optimize Resource Management of Storm Water5 identifies four main goals, all of
which the EWMP has incorporated: 1) Change the Perspective that Storm Water is a Waste or Hazard,
and Treat it as a Valuable Water Resource; 2) Manage Storm Water to Preserve Watershed Processes
and Achieve Desired Water Quality and Environmental Outcomes; 3) Implement Efficient and
Effective Regulatory Programs; and 4) Collaborate in order to Solve Water Quality and Pollutant
Problems with an Array of Regulatory and Non-Regulatory Approaches
• The California Water Action Plan6 describes several actions to address the drought in California. The
actions which this EWMP has incorporated include: making conservation a California way of life;
increasing regional self-reliance and integrated water management across all levels of government;
protecting and restoring important ecosystems; managing and preparing for dry periods; expanding
water storage capacity and improving groundwater management; and providing safe water for all
communities.
• The EWMP has incorporated goals in line with the California Stormwater Quality Association’s
2019Strategic Plan7 and 2020 Vision for Sustainable Stormwater Management 8, including:
Collaboration – Advance collaboration to address water quality problems in California;
Education/Outreach – Advance the knowledge of stormwater quality professionals and increase
the awareness and knowledge of policy-makers and regulators in California regarding stormwater
issues;
Implementation Guidance – Advance the quality of implementation guidance for
environmentally beneficial and cost-effective adaptive management approaches to improving
stormwater quality in California that emphasize true source control and operational source
control over treatment;
Regulatory Review – Advance the development of consistent, proactive, and flexible stormwater
policy and regulations consistent with the maximum extent practicable (MEP) standard of
pollutant reduction through the incorporation of the latest scientific and economic information
to promote the protection of water quality of beneficial uses; and
Scientific Assessment – Advance the understanding of pollutants of concern and their sources,
fate, and transport, and the effectiveness of best management practices (BMPs) to control them.
In order to achieve the goals of the MS4 Permit, the approach of the EWMP is to:
• Prioritize water quality issues resulting from stormwater and non-stormwater discharges from the
MS4 to receiving waters,
• Identify and implement strategies, control measures, and BMPs that:
o Achieve applicable water quality-based effluent limitations9
o Prevent exceedances of receiving water limitations10
5 Strategy to Optimize Resource Management of Storm Water. State Water Resources Control Board. December 11, 2015.
6 California Water Action Plan. California Natural Resources Agency, California Department of Food and Agriculture, and the
California Environmental Protection Agency (Cal/EPA). January 14, 2016.
7 CASQA Strategic Plan and Organizational Goals (April 2019) accessed May 26, 2021..
8 Vision for Sustainable Stormwater Management – October 2020. California Stormwater Quality Association (CASQA). October
2020.
9 Pursuant to Part VI.B and Attachments J through S of the Permit pursuant to corresponding compliance schedules
10 Pursuant to Parts V and X and Attachments J through S of the Permit
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o Cumulatively retain the runoff volume from the 85th%, 24-hour storm event for the drainage area
tributary to the applicable receiving water
o Prevent non-stormwater discharges that are effectively prohibited 11
o Reduce the discharge of pollutants to the maximum extent practicable 12
• Execute an integrated monitoring program and assessment program13 to determine progress towards
achieving applicable limitations and/or action levels.
• Modify strategies, control measures, and BMPs as necessary based on analysis of monitoring data
collected pursuant to the Monitoring and Reporting Program (MRP) to ensure that applicable water
quality-based effluent limitations and receiving water limitations and other milestones set forth in the
EWMP are achieved in the targeted timeframes.
The overall approach is adaptive, whereby BMPs will be implemented, their effectiveness monitored and
modifications to this EWMP will be made as needed. These modifications will maintain consistency with
the assumptions and requirements of applicable TMDL Waste Load Allocations.
11 Pursuant to Part III.A of the Permit
12 Pursuant to Part IV.A.1 of the Permit
13 Pursuant to Attachment E – MRP of the Permit
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1.6. REASONABLE ASSURANCE ANALYSIS AND WATERSHED CONTROL
MEASURES
As part of the initial EWMP development, a Reasonable Assurance Analysis (RAA) was conducted on a
watershed level, to determine through quantitative analysis or modeling, the target load reductions (TLRs)
necessary for each of the Peninsula EWMP priority pollutants in order to achieve water quality objectives
for areas of the EWMP not addressed through retention of the 85th%, 24-hr storm event. As a part of the
Peninsula EWMP’s adaptive management process, the Peninsula WMG is required to submit a revised
EWMP to the Regional Board, including an updated RAA, by June 30, 2021.
Building upon the original EWMP, the Revised RAA has been updated to include recent CIMP monitoring
data, project planning and implementation, and modeling advances over the past five years. The updated
wet weather RAA was conducted using the Watershed Management Modeling System 2.0 (WMMS 2.0),
the latest modeling tool developed by LACFCD, to determine a cost-effective implementation strategy to
meet applicable water quality priorities. For dry weather, a revised semi-quantitative approach was
implemented to update the dry weather portion of the revised RAA.
A suite of Watershed Control Measures (i.e. BMPs) to be implemented to achieve the necessary TLRs is
described in Chapter 3 of this revised EWMP. Watershed Control Measures are subdivided into 1)
Minimum Control Measures, 2) Non-Stormwater Discharge Measures 3) TMDL Control Measures and 4)
other control measures. A schedule has also been developed in Chapter 5 for the strategies, control
measures and BMPs to be implemented by each individual Permittee within its jurisdiction and for those
that will be implemented by multiple Permittees on a watershed scale. The schedules will measure
progress on a semi-regular basis during permit term(s) and incorporate:
1) Deadlines occurring within the permit term for all applicable interim and/or final water quality-based
effluent limitations and/or receiving water limitations to implement TMDLs,
2) Interim deadlines and numeric milestones within the permit term for any applicable final water quality-
based effluent limitation and/or receiving water limitation to implement TMDLs, where deadlines within
the permit term were not otherwise specified, and
3) Watershed priorities related to addressing exceedances of receiving water limitations.
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1.7. ADAPTIVE MANAGEMENT
An adaptive management process will continue to be implemented to further refine and adapt the EWMP
to become more effective, based on, but not limited to the following:
1. Progress toward achieving the outcome of improved water quality in MS4 discharges and receiving
waters through implementation of the watershed control measures,
2. Progress toward achieving interim and/or final water quality-based effluent limitations and/or
receiving water limitations, or other numeric milestones where specified, according to established
compliance schedules,
3. Achievement of interim milestones;
4. Reopening of TMDLs and new 303(d) listings;
5. Re-evaluation of the highest water quality priorities identified for the Watershed Management Area
based on more recent water quality data for discharges from the MS4 and the receiving water(s) and
a reassessment of sources of pollutants in MS4 discharges,
6. Availability of new information and data from sources other than the Permittees’ monitoring
program(s) within the Watershed Management Area that informs the effectiveness of the actions
implemented by the Permittees,
7. Regional Water Board recommendations; and
8. Recommendations for modifications to the EWMP solicited through a public participation process.
Based on the results of the adaptive management process, modifications necessary to improve the
effectiveness of the EWMP will be reported in the Annual Report, and as part of the Report of Waste
Discharge (ROWD). Any necessary modifications to the EWMP will be implemented upon acceptance by
the Regional Water Board Executive Officer within 60 days of submittal if the Regional Water Board
Executive Officer expresses no objections.
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2. IDENTIFICATION OF WATER QUALITY PRIORITIES
This updated Enhanced Watershed Management Program (EWMP) re-evaluates water quality priorities
identified for the Palos Verdes Peninsula Watershed Management Group (Peninsula WMG) during the
initial development of the EWMP. Water quality priorities have been revised based on updated
information and recent water quality data collected in the receiving water and re-assessment of sources
of pollutants in the watershed based on discharge water quality data collected from Peninsula WMG
outfalls since the initial development of the EWMP.
During the initial development of the EWMP, an evaluation of existing water quality conditions was
conducted in order to evaluate and prioritize water quality issues. Available data from applicable Total
Maximum Daily Loads (TMDLs), the State’s 303(d) list of impaired water bodies, and available monitoring
data collected between 2003-2015 were analyzed. For this update, recent information as well as four
years of receiving water and outfall water quality monitoring data collected between 2016 and 2020 under
the Palos Verdes Peninsula Coordinated Integrated Monitoring Program (Peninsula CIMP) have been
assessed as summarized below in Section 2.2 Receiving Water Characterization and Section 2.3 Source
Assessment.
2.1. WATER QUALITY CHARACTERIZATION AND PRIORITIZATION
The updated receiving water characterization in Section 2.2 has been used to identify pollutants of
concern for the Peninsula WMG and to classify them into the following three waterbody-pollutant
combination categories:
CATEGORY 1: Waterbody-pollutant combinations for which water quality-based effluent limitations
and/or receiving water limitations are established pursuant to a Total Maximum Daily Load (TMDL) as
identified in Part VI.B TMDL Provisions and Attachments J through S of the MS4 Permit.
CATEGORY 2: Pollutants for which data indicate water quality impairment in the receiving water
according to the State Board’s Water Quality Control Policy for Developing California’s Clean Water
Act Section 303(d) List (State Listing Policy) and for which MS4 discharges may be causing or
contributing to the impairment but for which a TMDL has not been established.
CATEGORY 3: Pollutants for which there are insufficient data to indicate water quality impairment in
the receiving water according to the State’s Listing Policy but for which data indicating exceedances
of applicable receiving water limitations may be occurring and for which MS4 discharges may be
causing or contributing to the exceedance.
This categorization forms the basis for prioritizing pollutants to be addressed by the EWMP. All of the
identified Peninsula WMG’s pollutants of concern fall into either Category 1 or 2 classification. There are
no Category 3 pollutants identified based on the receiving water characterization. Table 2-1 summarizes
the priority pollutant categorization for the Peninsula EWMP. As shown, Category 1 and Category 2
pollutants are considered with Highest and High Priority, respectively, in identifying control measures to
be implemented in each watershed. Highest priority pollutants include those with water quality-based
effluent limitations and/or receiving water limitations established pursuant to a TMDL. High priority
pollutants include those for which data indicate impairment of receiving water limitations and for which
the source assessment detailed in Section 2.3 has identified MS4 discharges as a potential source.
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Table 2-2: Peninsula EWMP Priority Pollutants
Category Priority Pollutant
Waterbody Santa Monica Bay Santa Monica Bay Beaches Machado Lake Wilmington Drain Inner Los Angeles Harbor Cabrillo Marina 1 Highest
Chlordane (water, sediment, fish tissue) x
Copper (water and sediment) x x
DDT (water, sediment, fish tissue) x x x x x
Dieldrin (water, sediment, fish tissue) x
Indicator Bacteria x
Lead (water and sediment) x x
Total Nitrogen x
Total PAHs x x
PCBs (water, sediment, fish tissue) x x x x x
Total Phosphorus x
Trash x x
Zinc (water and sediment) x x
2 High
Arsenic x
Indicator Bacteria x
Mercury x
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2.2. RECEIVING WATER CHARACTERIZATION
The Peninsula WMG area encompasses portions of the drainage area tributary to three receiving
waterbodies: the Santa Monica Bay, Machado Lake (which includes Wilmington Drain), and the Greater
Los Angeles Harbor. Existing water quality is characterized for each of these receiving waters using the
following information:
● Water Quality Control Plans
o Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties (Basin Plan)14
o California Ocean Plan15
● Applicable TMDLs
o Santa Monica Bay Bacteria Dry and Wet Weather TMDLs
o Santa Monica Bay Marine Debris TMDL
o Santa Monica Bay DDT and PCBs TMDL
o Machado Lake Trash TMDL
o Machado Lake Pesticides and PCBs TMDL
o Machado Lake Nutrient TMDL
o Long Beach and Greater Los Angeles Harbor Toxics TMDL 16
● California Water Quality Control Board Surface Water Quality Assessment Integrated Reports
o 2014/2016 303(d) List of Impaired Waterbodies
o 2018 303(d) List of Impaired Waterbodies
● Monitoring Data and Reports
o PVP CIMP Water Quality Data
o Machado Lake Water Quality Monitoring Data collected by City of Los Angeles
o Greater Los Angeles Harbor Waters Coordinated Compliance Monitoring and Reporting
Water Quality Monitoring Data collected by the Greater Harbor Waters Regional
Monitoring Coalition
The sections below provide more details on the updated information utilized to evaluate existing water
quality for the Peninsula WMG’s three receiving waters: Santa Monica Bay, Machado Lake and Greater
Los Angeles Harbor waters.
WATER QUALITY CONTROL PLANS
The Peninsula WMG watersheds are subject to both the Basin Plan and California Ocean Plan, which set
water quality objectives and implementation provisions to protect the quality of surface and marine
14 Los Angeles Regional Water Quality Control Board. Basin Plan for the Coastal Watersheds of Los Angeles and Ventura
Counties. Last accessed online on March 26, 2021.
https://www.waterboards.ca.gov/losangeles/water_issues/programs/basin_plan/basin_plan_documentation.html
15 State Water Resources Control Board, 2019. Water Quality Control Plan for Ocean Waters in California, California Ocean Plan
effective February 4, 2019.
16 As recognized by the footnote in Attachment K-4 of the 2012 LA MS4 Permit, the Peninsula WMG members have entered into
an Amended Consent Decree with the United States and the State of California, including the Regional Board, pursuant to which
the Regional Board has released the Peninsula WMG members from responsibility for Toxic pollutants in the Dominguez Channel
and the Greater Los Angeles and Long Beach Harbors. Accordingly, no inference should be drawn from the submission of this
EWMP or from any action or implementation taken pursuant to it that the Peninsula WMG has waived any rights under the
Amended Consent Decree.
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waters, respectively, and to ensure that the beneficial uses of these waters are maintained. For this EWMP
update, the most recent versions of the Basin Plan and Ocean Plan available as of the preparation of this
document were consulted to determine beneficial uses and water quality objectives applicable to the
Peninsula WMG. The beneficial uses of the Peninsula WMG’s receiving waters as designated in the Basin
Plan are summarized in Table 2-2, and the beneficial use acronyms used in the table are defined as follows:
MUN – Municipal and Domestic Supply
IND – Industrial Service Supply
GWR – Groundwater Recharge
NAV – Navigation
COMM – Commercial and Sport Fishing
REC1 – Water Contact Recreation
REC2 – Non-Contact Water Recreation
WARM – Warm Freshwater Habitat
MAR – Marine Habitat
WILD – Wildlife Habitat
BIOL – Preservation of Biological Habitats
RARE – Rare, Threatened, or Endangered Species
aquatic habitat
MIGR – Migration of Aquatic Organisms
SPWN – Spawning, Reproduction, and/or Early
Development
SHELL – Shellfish Harvesting
WET – Wetland Habitat
Table 2-3: Peninsula EWMP Area Water Bodies and Beneficial Uses Designated in the Basin Plan
Water Body MUN IND GWR NAV COMM REC1 REC2 WARM MAR WILD BIOL RARE MIGR SPWN SHELL WETb Los Angeles County Coastal Nearshore Zone^ E E E E E E E E Ee Ef Ef Ear
Los Angeles County Coastal Offshore Zone E E E E E E E Ee Ef Ef E
Machado Lake P* E E E E E E
Coastal Streams of Palos Verdes P* I I I I E E
Canyon Streams of Palos Verdes P* I I I I E E
Point Vicente Beach E E E E E E P E
Los Angeles Harbor – Other Inner Areas E E E P E E Ee P
Los Angeles Harbor – Marinas (Cabrillo) E E E E E E E P
E: Existing beneficial use; P: Potential beneficial use; I: Intermittent beneficial use
* Asterisked MUN designations are designated under SB 88-63 and RB 89-03. Some designations may be considered for
exemption at a later date.
b Water bodies designated as WET may have wetlands habitat associated with only a portion of the water body. Any regulatory
action would require a detailed analysis of the area.
^ Nearshore is defined as the zone bounded by the shoreline and a line 1000 feet from the shoreline or the 30-foot depth
contours, whichever is further from the shoreline. Longshore extent is from Rincon Creek to the San Gabriel River Estuary.
e One or more rare species utilizes all ocean, bays, estuaries, and coastal wetlands for foraging and/or nesting.
f Aquatic organisms utilize all bays, estuaries, lagoons, and coastal wetlands, to a certain extent, for spawning and early
development. This may include migration into areas which are heavily influenced by freshwater inputs.
arAreas exhibiting large shellfish populations include Malibu, Point Dume, Point Fermin, White Point and Zuma Beach.
TOTAL MAXIMUM DAILY LOADS (TMDLS) AND 303(D) LISTINGS
Waterbodies or waterbody segments that do not meet water quality standards consistent with beneficial
uses are considered impaired and placed on the State Water Resources Control Board’s 303(d) list of
impaired waters which includes identification of the specific pollutant(s) causing the impairment, i.e.,
waterbody/pollutant combinations. TMDLs are required to be developed for pollutants that are causing
impairment for each listed waterbody or waterbody segment. Where appropriate, TMDLs assign waste
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load allocations (WLAs) to MS4 dischargers to ensure that the total amount of a particular pollutant
entering a receiving waterbody from the MS4 will not cause the water quality objectives in that water
body to be exceeded and thereby impair its beneficial uses. Table 2-3 shows existing TMDLs applicable to
the Peninsula WMG that were evaluated to identify Category 1 water body pollutant combinations.
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Table 2-4: TMDLs Applicable to the Peninsula EWMP
TMDL Water Body Segments
Addressed by TMDL
Pollutants
Addressed by
TMDL
Regional Board Resolution Number Effective Date
Santa Monica Bay Beaches Bacteria Wet
and Dry Weather TMDLs
Santa Monica Bay
Beaches
Indicator Bacteria
(Total Coliform
Fecal Coliform
Enterococcus)
2002-022 (Wet TMDL) &
2002-004 (Dry TMDL);
Amended by R12-007
July 15, 2003;
R12-007 effective July 2,
2014
Santa Monica Bay Nearshore and
Offshore Debris TMDL Santa Monica Bay Trash R10-010
Amended by R19-004
March 20, 2012
R19-004 effective date
pending
Santa Monica Bay DDT and PCBs TMDL
Santa Monica Bay
Santa Monica Bay
Beaches
DDT
PCBs Established by USEPA March 26, 2012
Machado Lake Trash Machado Lake Trash 2007-006
Amended by R19-14
March 6, 2008
R19-14 effective date
pending
Machado Lake Pesticides and PCBs
(Toxics) TMDL Machado Lake
Chlordane
Dieldrin
PCBs
DDT
R10-008 March 20, 2012
Machado Lake Nutrient TMDL Machado Lake
Algae
Total Nitrogen
Total Phosphorus
Ammonia
Chlorophyll a
Dissolved Oxygen
Odor
2008-006 March 11, 2009
Dominguez Channel and Greater Los
Angeles and Long Beach Harbor Waters
Toxic Pollutants TMDL
Inner Harbor
Cabrillo Marina
DDT
PCBs
Copper
Lead
Zinc
PAHs
R11-008 March 23, 2012
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The State’s 2014/2016 and 2018 303(d) lists have been reviewed to identify waterbody impairments
applicable to the Peninsula WMG that are not yet being addressed by a TMDL. Table 2-4 below
summarizes the waterbody pollutant combinations identified on these 303(d) lists that are the basis for
Peninsula EWMP Category 2 water body pollutant combinations.
Table 2-5: 303(d) Listed Pollutants in Peninsula EWMP Watersheds
Impaired Waterbody Segment Pollutant Causing Impairment
Santa Monica Bay Arsenic
Santa Monica Bay Mercury
Wilmington Drain Coliform Bacteria
WATER QUALITY MONITORING DATA
The Peninsula WMG, implements the Palos Verdes Peninsula Coordinated Integrated Monitoring Program
(CIMP). The data collected by the CIMP are used to assess water quality priorities and effectiveness of
EWMP projects and programs. The CIMP established two (2) new near-shore monitoring locations in the
Santa Monica Bay (approximately 1000 feet offshore) for collection of receiving water monitoring data
during three (3) wet weather events and two (2) dry weather events per year. The CIMP also includes
weekly indicator bacteria monitoring conducted in accordance with the Santa Monica Bay Beaches
Bacteria TMDL at five (5) historical Santa Monica Bay shoreline locations.
In addition, some CIMP receiving water data evaluated in this water quality prioritization has been
collected by other agencies or groups including:
● Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters Toxic Pollutants TMDL
data collected under the Coordinated Compliance Monitoring and Reporting Plan (CCMRP)
implemented by the Regional Monitoring Coalition (RMC) for the Greater Harbor Waters, and
● Machado Lake in-lake water quality, sediment and fish tissue data collected by the City of Los Angeles
under the Machado Nutrient and Pesticides and PCBs TMDLs.
The following sections are organized by watershed and include a characterization of each receiving water
body based on applicable TMDLs, 303(d) listings and recently collected water quality data.
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2.2.1. SANTA MONICA BAY
The Palos Verdes Peninsula is known for its steep cliffs and rocky intertidal coastal habitat and tidepools.
Sandy beaches on the Peninsula are few and small, most with difficult access. The portion of the Peninsula
WMG with drainage tributary to Santa Monica Bay consists of approximately 14.8 square miles, which is
about 3.6% of the Santa Monica Bay Watershed (414 sq. mi.).
INDICATOR BACTERIA
The Santa Monica Bay Beaches (SMB Beaches) were first designated as impaired due to fecal indicator
bacteria on the State’s 1998 303(d) list of impaired waters. The Regional Board subsequently issued the
SMB Beaches Bacteria TMDLs (SMBBB TMDLs) for wet and dry weather conditions, which became
effective on July 15, 2003 and were subsequently amended on July 2, 2014. All of the Peninsula shoreline
monitoring sites have been delisted from the 2014/16 and 2018 303(d) lists in accordance with the State
Water Resources Control Board’s delisting criteria, however the SMBBB TMDLs continue to remain in
effect.
The SMBBB TMDLs include single-sample and six-week rolling geometric mean numeric objectives for
total coliform, fecal coliform and enterococcus densities measured in most probable number per 100
milliliters (MPN/100mL). The TMDLs set waste load allocations (WLAs) based on the single sample
objectives as an allowable number of days on which the single sample bacteria objectives could be
exceeded at shoreline monitoring sites along the Santa Monica Bay (allowable exceedance days). The
TMDLs divide the calendar year into three separate periods, each with specified numbers of allowable
single-sample exceedance days:
● Summer dry-weather (April 1 – October 31),
● Winter dry weather (November 1 – March 31), and
● Wet weather (Year-round)
The six-week rolling geometric mean applies year-round during all weather conditions.
Table 2-5 shows the single sample and geometric mean bacteria objectives for the three types of indicator
bacteria and Table 2-6 presents the allowable number of exceedance days at each monitoring location
along the Peninsula WMG’s shoreline.
Table 2-6: SMBBB TMDL Bacteria Objectives
Constituent Six-Week Rolling Geometric Mean Single Sample
Total Coliform* 1,000 MPN/100 mL 10,000 MPN/100 mL
Fecal Coliform 200 MPN/100 mL 400 MPN/100 mL
Enterococcus 35 MPN/100 mL 104 MPN/100 mL
*Total Coliform density shall not exceed a daily maximum of 1,000/100 mL if the ratio of total to fecal
coliform exceeds 0.1
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Table 2-7: Allowable Exceedance Day(s) by Period and Monitoring Location
Shoreline Monitoring Location Period
Winter Dry Weather (b) Summer Dry Weather (c) Wet Weather (d)
(e)
SMB 7-1 (Malaga Cove) 1 0 2
SMB 7-2 (Bluff Cove) 1 0 0
SMB 7-3 (Long Point) 1 0 1
SMB 7-4 (Abalone Cove) 0 0 1
SMB 7-5 (Portuguese Bend Cove) 1 0 1
(a) Allowable Exceedance days based on weekly sampling;
(b) Final period beginning July 15, 2009;
(c) Final period beginning July 15, 2006;
(d) Wet weather days include days with rain events of ≥ 0.1 inches of precipitation and the three days following the end of
the rain event;
(e) Final period beginning July 15, 2021
To meet the monitoring requirements of these TMDLs, a SMB Beaches Bacteria TMDLs Coordinated
Shoreline Monitoring Plan was developed by a committee of responsible agencies including
representatives from the Peninsula WMG. The five shoreline monitoring sites established for the
Peninsula WMG area (SMB 7-1 through 7-5) are shown on Figure 1-1. These five shoreline monitoring
sites historically demonstrated fewer exceedance days than the reference beach (Leo Carrillo) used in the
TMDL and were therefore considered anti-degradation sites which were required to maintain their
existing high quality. The five Peninsula shoreline monitoring sites have historically and continue to be
sampled for indicator bacteria along the Palos Verdes Peninsula shoreline on a weekly basis. The data
summarized in Table 2-7 and Table 2-8 indicate that exceedances of the single sample and rolling six-week
geometric mean receiving water limitations are infrequent at these shoreline monitoring sites and even
during the 2016-17 rainy season, which exceeded the number of wet days for the critical 90th percentile
wet year, there were very few exceedances.
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Table 2-8: Number of Exceedance Days Above Allowable Receiving Water Limitations
Station ID SMB 7-1 SMB 7-2 SMB 7-3 SMB 7-4 SMB 7-5
Season* Dry
Summer
Dry
Winter
Wet
Weather
Dry
Summer
Dry
Winter
Wet
Weather
Dry
Summer
Dry
Winter
Wet
Weather
Dry
Summer
Dry
Winter
Wet
Weather
Dry
Summer
Dry
Winter
Wet
Weather
Reporting
Year
Number of Exceedances of Annual Allowable Exceedance Days
2019-20 0 0 1 0 0 0 0 0 0 1 0 0 1 0 0
2018-19+ 0 0 0 0 0 1 0 0 1 0 1 0 1 0 0
2017-18 0 0 0 0 0 0 0 2 0 0 0 0 0 0 0
2016-17* 0 0 2 0 0 0 0 0 2 0 0 2 0 0 0
+ From 11/19/18 through 1/14/19 enterococcus samples were run with 0:0 dilution rather than standard 1:10 dilution in an attempt to lower the detection limits for enterococcus following
changeover in laboratories and method of analysis from EPA 1600 membrane filtration to IDEXX Enterolert® which may have resulted in increase in false positive exceedances.
* The number of wet days during the 2016-17 rainy season exceeded the number of wet days during the critical 90th percentile rain year
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Table 2-9: Number of Year-Round Rolling Six-Week Geomean Exceedances of Receiving Water Limitations
Station ID SMB 7-1 SMB 7-2 SMB 7-3 SMB 7-4 SMB 7-5
Reporting
Year
Number of Rolling Six-Week Geomean Exceedances
2019-20 1 0 0 0 0
2018-19 + 2 0 0 0 1
2017-18 0 0 0 0 0
2016-17* 2 0 0 1 0
+ From 11/19/18 through 1/14/19 enterococcus samples were run with 0:0 dilution rather than standard 1:10 dilution in an attempt to lower the detection limits for
enterococcus using IDEXX Enterolert® analytical method which may have resulted in an increase in false positive results and geomean exceedances
* The number of wet days during the 2016-17 rainy season exceeded the number of wet days during the critical 90th percentile rain year
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In addition, two nearshore receiving water monitoring stations located approximately 1,000 feet offshore
in the Santa Monica Bay are being used to assess the effects of stormwater discharges on Santa Monica
Bay receiving water quality. Each of these stations is situated directly in line with one of the two (2) CIMP
outfall monitoring locations and wet weather nearshore receiving water sampling occurs in the Santa
Monica Bay as soon as safety allows following outfall sampling. Four complete years of wet and dry-
weather data from these receiving water sites have been collected beginning with reporting year 2016-
17. Out of the forty (40) samples collected offshore in the Santa Monica Bay during this four-year period,
only three (3) samples, or 7.5% of samples, exhibited elevated indicator bacteria results above Ocean Plan
objectives. Figure 2-1, Figure 2-2, Figure 2-3 show fecal indicator bacteria concentrations observed in
receiving water samples collected under the PVP CIMP between 2016 and 2020. The horizontal line in
each graph represents the Ocean Plan target for each respective species. As can be seen in these graphs,
indicator bacteria concentrations in the Santa Monica Bay receiving water are consistently well below the
2012 Ocean Plan targets17.
17 While these graphs compare data to the 2012 Ocean Plan, bacteria targets in the most recent (2019) Ocean Plan are consistent
with the 2012 Ocean Plan.
Figure 2-2: Santa Monica Bay Total Coliform Concentrations 2016-2020
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Figure 2-3: Santa Monica Bay Fecal Coliform Concentrations 2016-2020
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PCBS AND DDTS
The Palos Verdes Shelf portion of Santa Monica Bay is an active EPA Superfund site that is subject to
Superfund Remedial Action Objectives which include institutional controls, natural recovery, capping, and
monitored attenuation, and are expected to result in improved water quality. 18 From 1947 to 1971 large
quantities of DDT were discharged from the Montrose Chemical plant in Los Angeles to the Los Angeles
County Joint Water Pollution Control Plant (JWPCP) which discharges to the Palos Verdes Shelf. PCBs also
entered the JWPCP from several industrial sources in the Los Angeles area. These DDT and PCBs discharges
passed through the JWPCP and were deposited on the Palos Verdes Shelf. There have also been reports
of recently discovered illegal offshore dumping of waste barrels containing DDT acid sludge between
Catalina Island and the Palos Verdes coast19. There is also concern that the rate of erosion on the
southwest portion of the Palos Verdes Shelf could bring previously buried deposits to the surface.
18 USEPA: Santa Monica Bay DDT and PCBs TMDL
19https://www.latimes.com/projects/la-coast-ddt-dumping-ground/#nt=1col-7030col1-mainnt=00000173-4a29-
dafc-a977-dabb7b330001-liA9promoSmall-1col-7030col1-main
Figure 2-4: Santa Monica Bay Enterococci Concentrations 2016-2020
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Concentrations of DDT and PCBs deposited in the surface sediments of the Santa Monica Bay have
decreased substantially since the early 1970s and during this time period the benthic communities in the
Palos Verdes shelf and Santa Monica Bay have improved substantially to the point where impairments to
benthic communities are not seen; however, DDT and PCBs are still present at levels of concern for
bioaccumulation and human health 20. This contamination of DDT and PCBs in the sediments of Santa
Monica Bay, largely centered on the Palos Verdes shelf, has led to a large number of fish advisories for
much of Santa Monica Bay and a commercial fishing ban in the area around the Palos Verdes Shelf. As a
result, the US EPA issued the Santa Monica Bay DDT and PCBs TMDL in 2012 and the TMDL objectives
were established to meet fish concentrations for human consumption.
Four complete years of nearshore receiving water quality data have been collected under the PVP CIMP
in the Santa Monica Bay and analyzed for total DDT and PCBs. Of these dry and wet-weather samples
collected over the past four years, only one (1) out of forty (40) samples or 2.5% resulted in detection of
4,4’- DDT at a concentration between the method detection limit and the reporting limit. This sample was
collected during a summer dry weather sampling event in the fourth year of CIMP monitoring. None of
the forty (40) receiving water samples collected over the past four years have resulted in detections of
Total PCBs above the Ocean Plan objective for total PCBs.
TRASH
The Santa Monica Bay nearshore beneficial uses are impaired by the accumulation of suspended and
settleable debris. In 2008 and 2009, Regional Board staff conducted site visits along beaches in the
southern and northern parts of the Santa Monica Bay to document the trash problem, though no beaches
along the Peninsula WMG area were included in these site visits. Common items found on every beach
evaluated included: plastic bags, candy wrappers, cigarette butts, styrofoam, beverage containers, straws,
and paper. To address this impairment, the Regional Board issued the Santa Monica Bay Nearshore and
Offshore Marine Debris TMDL (SMB Marine Debris TMDL), which went into effect on Mar 20, 2012. The
SMB Marine Debris TMDL established a numeric target of zero trash and zero plastic pellets in the Santa
Monica Bay based on the narrative water quality objectives in both the Basin Plan and the Ocean Plan.
ARSENIC & MERCURY
The Santa Monica Bay is listed on the State’s 2014/16 and 2018 303(d) Lists as being impaired by arsenic
and mercury based on sediment and fish tissue data collected under the Hyperion Treatment Plant NPDES
Permit no. CA0109991 between January 2006 and June 2010. Nineteen (19) of 19 fish tissue samples
collected in the Santa Monica Bay exceeded the USEPA Guidance for Assessing Chemical Contaminant
Data for Use in Fish Advisories Volume 1: Fish Sampling and Analysis21 for arsenic in fish tissue of 0.0034
ppm. Two (2) of thirty-two (32) sediment samples exceeded the Basin Plan narrative objective for mercury
based on the effects range median for saline waters (predictive of sediment toxicity) for mercury of 0.71
20 USEPA: Santa Monica Bay DDT and PCBs TMDL
21 USEPA. Office of Science and Technology Office of Water. Guidance for Assessing Chemical Contaminant Data for Use In Fish
Advisories Volume 1: Fish Sampling and Analysis. EPA 823-B-00-007 (November 2000).
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mg/Kg dry weight 22. In addition, two (2) of nineteen (19) fish tissue samples exceeded the OEHHA fish
contaminant goal of 0.22ppm 23.
TOXICITY
The Santa Monica Bay Offshore/Nearshore water body was removed from the 2014/16 and 2018 303(d)
lists for sediment toxicity at the recommendation of USEPA, indicating that Peninsula shoreline waters
are no longer considered to be impaired for sediment toxicity.
Some intermittent water column toxicity has been observed in the nearshore receiving water quality
monitoring data collected under the PVP CIMP. One (1) out of twenty-four (24) wet weather nearshore
receiving water samples collected under the PVP CIMP over the past four years has indicated toxicity,
however the toxic effect was not sufficiently elevated to require the performance of a toxicity
identification evaluation (TIE) and subsequent follow up wet-weather sampling showed no further toxic
effects during wet weather.
During the third and fourth years of PVP CIMP dry weather monitoring, three (3) of four (4) dry weather
receiving water samples collected in the Santa Monica Bay at receiving water site RW-1 off Malaga Cove
in Palos Verdes Estates indicated low-level persistent toxicity. A TIE was performed on the initial receiving
water sample showing toxicity collected at RW-1. The result of this TIE was inconclusive, though divalent
cationic metals were suggested as the potential constituents causing the observed effects during that dry
weather receiving water monitoring event. Follow up sampling at an ‘upstream’ shoreline monitoring
found no toxicity present closer to the shoreline nor were metals observed above Ocean Plan limits in
either the nearshore or shoreline receiving water sites. Based on monitoring data collected to date, there
is no evidence that MS4 discharges have caused or contributed to these intermittent nearshore toxicity
results nor has a cause of the toxicity been identified.
2.2.2. MACHADO LAKE
Machado Lake is located in the Ken Malloy Harbor Regional Park, which is a 231-acre Los Angeles City Park
serving the Wilmington and Harbor City communities. Machado Lake was created by damming one of the
last wetland systems in Los Angeles in 1971. The lake was intended for boating and fishing but over the
years water quality generally declined, boating was stopped, and signs were posted warning of the risk of
eating fish from the lake.
The Peninsula WMG areas do not drain directly into Machado Lake. The portion of the Peninsula WMG
which contributes runoff to Machado Lake consists of approximately 6.2 square miles, which is about 27%
of the Machado Lake watershed drainage area (approximately 22.6 sq. mi. in total). Drainage from the
Peninsula WMG areas exits the Palos Verdes Peninsula in an easterly or northeasterly direction where it
22 Long, E.R., D.D. MacDonald, S.L. Smith, and F.D. Calder. Incidence of adverse biological effects within ranges of
chemical concentrations in marine and estuary sediments. Environmental Management. 19, (1): 81-97
(1995).
23 Klasing, S. and Brodberg, R. Development of Fish Contaminant Goals and Advisory Tissue Levels for Common Contaminants in
California Sport Fish: Chlordane, DDTs, Dieldrin, Methylmercury, PCBs, Selenium, and Toxaphene. Pesticide and Environmental
Toxicology Branch Office of Environmental Health Hazard Assessment California Environmental Protection Agency. (June 2008).
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is comingled with drainage from the cities of Torrance and Lomita prior to flowing into three of the four
major drainage systems entering Machado Lake: Wilmington Drain, Project 77 and Project 510 (Figure 2-
4). As shown in Table 2-3, Machado Lake is impaired for organochlorine pesticides, PCBs, nutrients, and
trash. Over 80% of the Peninsula WMG’s Machado Lake watershed drains to Machado Lake through
Wilmington Drain. Wilmington Drain is listed on the State’s 303(d) List for indicator bacteria.
Machado Lake underwent renovations as part of the City of Los Angeles’s Machado Lake Ecosystem
Rehabilitation Project funded by Prop O which was completed in 2017. The primary goal of the
Rehabilitation Project was to improve water quality in Machado Lake while also enhancing natural habitat
and recreational features of the park. The project consisted of in-lake improvements that included
dredging approximately 239,000 cubic yards of lake sediment and capping the lake bottom with an
AquaBlok bio-layer cap, constructing an oxygenation system, and rehabilitating the dam structure at the
south end of the lake. Storm drain facility improvements included installing five (5) Continuous Deflection
Separation (CDS) systems at the major storm drain inlets to treat storm water before it enters the lake.
The vegetation, habitat, and park improvements included invasive plant removal, replanting of native
species, and installation of fencing and walkways. The project has been undergoing an optimization
period since the project was completed, and the City of Los Angeles began conducting receiving water
monitoring in Machado Lake on September 11, 2017. The Machado Lake Ecosystem and Rehabilitation
Project optimization period is expected to last between three to five years to allow for control measures
such as vegetation for water quality treatment to be fully established. As part of the City of Los Angeles’
Machado Lake Ecosystem and Rehabilitation Project, planning efforts are underway to pump treated
water from Terminal Island’s Advanced Water Purification Plant to Machado Lake to offset impacts of
evapotranspiration. This is expected to lower pollutant concentrations to below the required levels for
Machado Lake TMDLs.
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Figure 2-5: Storm Drains Entering Machado Lake
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N UTRIENTS
Machado Lake is identified on the State’s 303(d) list of impaired water bodies due to eutrophic conditions,
algae, ammonia, and odors. Eutrophication is defined by increased nutrient loading to a waterbody and
the resulting increased growth of biota, phytoplankton and other aquatic plants. To address these
impairments, the Regional Board issued the Machado Lake Eutrophic, Algae, Ammonia, and Odors
(Nutrient) TMDL, which became effective March 11, 2009. The chemical pollutants that most stimulate
excessive aquatic vegetative growth and stimulate eutrophication are nitrogen and phosphorus, thus
numeric receiving water limitations were set for these constituents in the Machado Lake Nutrient TMDL.
Table 2-9 presents numeric targets and interim and final load and waste load allocations for Machado
Lake.
Table 2-10: Nutrient TMDL Numeric Targets and Load Allocations for Machado Lake
Date Numeric Target WLAs and LAs
(Monthly Average Concentration)
March 11, 2009
(1st Interim)
- Total Phosphorus
1.25 mg/L
Total Nitrogen
3.5 mg/L
March 11, 2014
(2nd Interim)
- Total Phosphorus
1.25 mg/L
Total Nitrogen
2.45 mg/L
September 11, 2018
(Final)
Total Phosphorus
0.1 mg/L (monthly average)
Total Nitrogen
1.0 mg/L (monthly average)
Ammonia
5.95 mg/L (hourly average)
2.15 mg/L (30-day average)
Dissolved Oxygen*
5 mg/L (single sample minimum)
*Measured at 0.3-m above the sediment)
Chlorophyll-a
20 μg/L (monthly average)
Total Phosphorus
0.1 mg/L
Total Nitrogen
1.0 mg/L
Just over two years of in-lake water quality data have been collected by City of Los Angeles following
completion of the Machado Lake Ecosystem Rehabilitation Project24. Nutrient data is collected via grab
sampling from two in-lake monitoring stations: ML-1 and ML-2 (Figure 2-5), and a thirty-day rolling
average in-lake concentration is calculated on a monthly basis for Total Nitrogen and Total Phosphorus.
24 Water quality monitoring data collection began September 2017, following completion of the Machado Lake Ecosystem
Rehabilitation Project, and was available through June 2020 at the time of this update.
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Table 2-10 below shows monthly average Total Nitrogen and Total Phosphorus concentrations calculated
for Machado Lake. With the exception of Total Nitrogen monthly average concentration in January and
April 2020, all in-lake monthly average concentrations of Total Nitrogen and Total Phosphorous have been
higher than applicable receiving water limitations established in the TMDL.
Table 2-11: Monthly Average TN and TP Concentration in Machado Lake
Month/Year
Total Nitrogen Monthly
Average (mg/L,
calculated)
Total Phosphorus
Monthly Average (mg/L,
calculated)
September 2017 - 0.2
October 2017 - 0.18
November 2017 1.70 0.17
December 2017 1.35 0.14
January 2018 1.24 0.27
February 2018 - 0.28
March 2018 1.14 0.42
April 2018 1.98 0.29
May 2018 3.65 0.38
June 2018 2.70 0.27
July 2018 2.88 0.38
August 2018 4.43 0.54
September 2018 2.30 0.27
October 2018 2.78 0.32
November 2018 3.10 0.33
December 2018 1.58 0.32
January 2019 1.56 0.38
February 2019 1.14 0.28
March 2019 - 0.28
April 2019 - 0.30
May 2019 1.45 0.31
June 2019 1.38 0.33
July 2019 1.8 0.3
August 2019 2.2 0.3
September 2019 2.2 0.3
October 2019 2.3 0.3
November 2019 2 0.2
December 2019 1.4 0.4
January 2020 0.8 0.28
February 2020 1.3 0.28
March 2020 1.2 0.21
April 2020 1 0.19
May 2020 1.5 0.21
June 2020 1.6 0.26
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Figure 2-6: Machado Lake Monitoring Stations
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ORGANOCHLORINE PESTICIDES AND PCBS
Machado Lake is identified on the State’s 303(d) List of impaired water bodies as impaired due to
Chlordane, Dieldrin, Chem A, DDT and PCBs in fish tissue 25. The Machado Lake Pesticides and PCBs TMDL
(Machado Lake Toxics TMDL) was issued by the Regional Board to address these impairments and became
effective March 20, 2012. Polychlorinated Biphenyls (PCBs) and organochlorine pesticides belong to a
broad group of synthetic chlorinated hydrocarbons. PCBs include up to 209 different chlorinated chemical
compounds which are called congeners. Chlordane, Dieldrin and DDT are organochlorine pesticides that
were widely used until the late 1970s and 1980s. Organochlorine pesticides and PCBs are highly lipophilic
and will accumulate in the fatty tissues of exposed wildlife and bioaccumulate as they move through the
food chain. Chem A (abbreviation for chemical group A) is a suite of bio-accumulative pesticides that
includes chlordane and dieldrin. The 1998 303(d) listing (and subsequent listings) for Chem A was
predominately based on fish tissue concentrations of chlordane and dieldrin while the other Chem A
pollutants have not been detected in tissue in over 25 years. Therefore, the Machado Lake Toxics TMDL
addresses the Chem A listing by establishing water quality, sediment and fish tissue targets for chlordane
and dieldrin.
The Machado Lake Pesticide and PCBs TMDLs established numeric targets for pesticides and PCBs in
water, sediment, and fish tissue to protect aquatic life, fishing, and other recreational uses in the lake.
The California Toxics Rule (CTR) criteria for human health (including protection for consumption of
organisms) are the numeric targets for the water column, while the sediment numeric targets are based
on the freshwater Threshold Effect Concentration guidelines compiled by NOAA, and the fish tissue
targets are based on OEHHA Fish Contaminant Goals. Table 2-11 presents these water column, sediment,
and fish tissue numeric targets for the Machado Lake organochlorine pesticides and PCBs.
Table 2-12: Machado Lake Toxics TMDL In-Lake Numeric Targets
Pollutant Water Column Target
(ng/L)
Sediment Target
(μg/kg dry weight)
Fish Tissue Target
(ng/g wet weight)
Total PCBs 0.17 59.8 3.6
DDT (all congeners) 0.59* 4.16 No target
DDE (all congeners) 0.59* 3.16 No target
DDD (all congeners) 0.84 4.88 No target
Total DDT -- 5.28 21.0
Chlordane 0.59 3.24 5.6
Dieldrin 0.14 1.9 0.46
*Water column targets for 4,4’ DDT, 4,4’ DDE and 4,4’ DDD only
Since September 2017, following completion of the Machado Lake Ecosystem Rehabilitation Project,
water quality, sediment and fish tissue samples have been collected by City of Los Angeles in Machado
Lake. Sediment grab samples collected in October 2017 showed non-detects for all constituents listed in
Table 2-11. Results of in-lake water column monitoring conducted via grab sampling in March 2018
showed one exceedance of the CTR criteria for protection of human health for Total Chlordane (the
calculated for Total Chlordane of 2ng/L was the result of the gamma-Chlordane analysis). Fish tissue grab
and composite samples collected in May 2019 showed multiple exceedances of the OEHHA fish tissue
targets for Total Chlordane and Total PCBs.
25 Machado Lake Pesticides and PCBs TMDL
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TRASH
Machado Lake is identified on the State’s 303(d) List of impaired water bodies due to trash 26.
Consequently, the Regional Board issued the Machado Lake Trash TMDL, which became effective March
6, 2008. Existing beneficial uses impaired by trash in Machado Lake are Water Contact Recreation (REC-
1), Non-contact Water Recreation (REC-2), Warm Freshwater Habitat (WARM), Wildlife Habitat (WILD),
Rare, Threatened, or Endangered Species (RARE), and Wetland Habitat (WET). Common items that have
been observed in Machado Lake include styrofoam cups, styrofoam food containers, glass and plastic
bottles, paper cartons, packaging materials, plastic bags, and cans. Heavier debris can be transported
during storms as well. The numeric target for this TMDL is zero trash in Machado Lake and on the
shoreline. The TMDL assigns limits on point sources of trash, such as discharges from the MS4, and
nonpoint sources of trash, such as direct discharges from areas of Ken Malloy Harbor Regional Park
adjacent to the lake such as parking lots, recreational, and picnic areas. Dischargers can comply with
WLAs through structural trash capture devices installed in the storm drain system or through
nonstructural source control BMPs.
2.2.3. GREATER LOS ANGELES HARBOR
The Peninsula WMG areas do not drain directly into the Greater Los Angeles Harbor. Drainage from the
Peninsula EWMP area exits the cities of Rancho Palos Verdes and Rolling Hills Estates in an easterly or
southeasterly direction via storm drains and becomes comingled with MS4 discharges from the City of LA.
The portion of the Peninsula EWMP area which contributes runoff to Greater Los Angeles Harbor consists
of approximately 4.5 square miles, which is about 4.1% of the Dominguez Channel Watershed
Management Area (approximately 109.4 sq. mi. total) that drains to the Los Angeles Harbor 27. Specific Los
Angeles Harbor water segments to which the Peninsula WMG contributes runoff include the Inner Harbor
and Cabrillo Marina (Figure 2-6). These segments are listed on the State’s 303(d) list as impaired by
copper, lead, zinc, Polycyclic Aromatic Hydrocarbons (PAH) compounds, DDT and PCBs. These
impairments exist in the water, sediments and fish tissue within the Los Angeles Harbor waters. Fish
consumption advisories also currently exist for DDT and PCBs in certain fish species in all of the Los Angeles
Harbor waters.
The Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters Toxic Pollutants TMDL
(Harbor Toxics TMDL) was issued by the Regional Board to address the constituents causing water quality
impairment and became effective on March 23, 2012. The applicable water quality objectives for this
TMDL are narrative objectives for Chemical Constituents, Bioaccumulation, Pesticides, and Toxicity in the
Basin Plan and the numeric water quality criteria promulgated in 40 CFR section 131.38 (the California
Toxics Rule (CTR)). In addition, marine sediment targets were determined for the Dominguez Channel and
Greater Los Angeles and Long Beach Harbor waters using the narrative standards of the Basin Plan, State
Water Quality Control Plan for Enclosed Bays and Estuaries – Part 1 Sediment Quality (SQO Part 1) and
the sediment quality guidelines recommended by the State Listing Policy 28.
The following Table 2-12 provides the marine sediment targets for the Dominguez Channel and Greater
Los Angeles and Long Beach Harbor waters applicable to the Peninsula WMG priority pollutants.
26 Machado Lake Trash TMDL
27 Dominguez Channel and Greater Los Angeles and Long Beach Harbor Waters Toxic Pollutants TMDL
28 Long, ER, LJ Field and DD MacDonald. 1998. Predicting Toxicity in Marine Sediments with Numerical Sediment Quality
Guidelines, Environ. Toxicol. Chem. 17:4, 714-727. MacDonald, DD, CG Ingersoll and TA Berger. 2000. Development and
evaluation of consensus-based sediment quality guidelines for freshwater ecosystems. Arch. Environ. Contam. Toxicol. 39:20-31.
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Table 2-13: Greater Harbor Toxics TMDL Marine Sediment Targets
Pollutant Marine Sediment Target
Copper 34 mg/kg
Lead 46.7 mg/kg
Zinc 150 mg/kg
Total PCBs 22.7 ug/kg
Total PAHs 4,022 ug/kg
Total DDT 1.58 ug/kg
The Harbor Toxics TMDL requires monitoring by the responsible parties under the Coordinated
Compliance Monitoring and Reporting Plan29. The Coordinated Compliance Monitoring and Reporting
program includes sampling for both water quality and sediment quality within 12 distinct water quality
groups, each water quality group representing a water body within the greater harbor waters, as well as
fish tissue sampling at four different locations (Figure 2-6).
In 2019, an assessment of bed sediment quality over a three-year averaging period in comparison with
interim TMDL objectives provided in Attachment N Part E.2.a. of the 2012 LA MS4 Permit was performed
under the Coordinated Compliance Monitoring Program. Most water bodies within the Greater Los
Angeles Harbor were found to have met the interim three-year average concentration-based sediment
objectives including the two water bodies to which stormwater from the Peninsula WMG is tributary:
Inner Los Angeles Harbor and Cabrillo Marina. Thus, there appears to have been no degradation in
sediment quality in these two water bodies since adoption of the TMDL. In evaluating progress toward
attainment of the final objectives, sediment quality in the Los Angeles Harbor was assessed using
California’s Sediment Quality Objectives (SQO) for aquatic life benthic community based on multiple lines
of evidence: sediment chemistry, sediment toxicity, and benthic community condition. Per this
methodology, the qualitative sediment conditions of Unimpacted or Likely Unimpacted are protective of
the benthic community. Based on the analysis incorporating monitoring events in 2013, 2016, and 2018,
the Inner Los Angeles Harbor, including Cabrillo Marina, was determined to be Not Protective.
As shown in Table 2-13 receiving water data collected over the past four years in the two Greater Los
Angeles Harbor water bodies to which the Peninsula WMG is tributary indicates that the CTR criteria for
the protection of aquatic life is consistently exceeded for dissolved copper in the Cabrillo Marina while
there have been some exceedances of the CTR criteria for dissolved copper as well total DDx in the Los
Angeles Outer Harbor.
29 Anchor QEA. Coordinated Compliance Monitoring and Reporting Plan for the Greater Harbor Waters Regional Monitoring
Coalition. August 2019.
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Table 2-14: Water Quality Exceedances in Greater Los Angeles Harbor Waters to which Peninsula WMG is
Tributary
Total Water Quality Exceedances of CTR Aquatic Life Criteria/Total Samples Collected Between 2016 and 2020
Constituent Los Angeles Inner Harbor Cabrillo Marina
Copper (Dissolved) 8/51 8/10
Lead (Dissolved) 0/51 0
Zinc (Dissolved) 0/51 0
4.4’ - DDT 0/51 0
Total DDx 7/51 1/10
Total PCBs 3/51 0
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Figure 2-7: Greater LA Harbor Waters and Monitoring Stations
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2.3. SOURCE ASSESSMENT
The focus of this Source Assessment is on watershed sources contributing to the presence of pollutants
in stormwater discharges conveyed through the MS4.
A source assessment was conducted with the initial development of the EWMP to identify potential
sources in discharges to the MS4 and from the MS4 to receiving waters and other potential stressors
related to MS4 discharges causing or contributing to the WBPCs classified as Category 1, 2, or 3. Per the
MS4 Permit, the following available data and documents were considered in the identification of known
and suspected sources of the Peninsula WMG’s priority pollutants:
● Findings from the Peninsula WMG’s Illicit Connections and Illicit Discharges Elimination Programs
● Findings from the Peninsula WMG’s Industrial/Commercial Facilities Control Programs
● Findings from the Peninsula WMG’s Development Construction Programs
● Findings from the Peninsula WMG’s Public Agency Activities Programs
● TMDL Implementation Plans
● TMDL Source Investigations
● Findings from MS4 Permittees’ monitoring programs
● Watershed model results
● Other pertinent data, information, or studies related to pollutant sources and conditions that
contribute to the highest water quality priorities
● Locations of the Peninsula Agencies’ MS4s including, at a minimum, all major outfalls and major
structural controls for stormwater and non-stormwater that discharge to receiving waters
● Other known and suspected sources of pollutants in non-stormwater or stormwater discharges
from the MS4 to receiving waters within the EWMP area
This source assessment has been updated based on outfall monitoring data collected via the Coordinated
Integrated Monitoring Program (CIMP) as well as updated information on potential watershed sources of
priority pollutants.
2.3.1. WATERSHED SOURCES OF PRIORITY POLLUTANTS
There are two general categories of stormwater pollutant sources, point sources and non-point sources.
Non-point sources, by definition, include pollutants that reach receiving waters via routes other than a
defined conveyance/point source and are not regulated by the MS4 Permit nor included in the reasonable
assurance analysis. An example of such a non-point source could be trash deposited on the beach by
recreational use which is then transported into the receiving water by wind or tide action. Point source
discharges are regulated through NPDES permits and include stormwater and urban runoff (also referred
to as non-stormwater discharges) through the MS4. Stormwater runoff in the watershed is regulated
through one of several types of National Pollutant Discharge Elimination System (NPDES) permits,
including MS4 permits, a statewide MS4 permit for Caltrans; a statewide Construction General Permit
(CGP) for construction sites disturbing 1 acre or more of land; and a statewide Industrial General Permit
(IGP).
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This section will first consider historical and current land uses in the Peninsula WMG watersheds, identify
key pollutant fate and transport mechanisms characteristic of the watersheds, and then consider relevant
point and non-point sources of priority pollutants that may be present in the watersheds based on land
uses. This source assessment will help to shape appropriate pollutant control measures in subsequent
chapters of this EWMP.
Potential sources of the priority pollutants in the watershed and potential fate and transport mechanisms
that could cause these pollutants to reach the MS4 are summarized in Table 2-14.
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Table 2-15: Potential Watershed Sources of Palos Verdes Peninsula Priority Pollutants
Potential Source Pollutants OC Pesticides PAHs Bacteria Nutrients Metals TSS/Turbidity Trash WATERSHED SOURCES
Residential land areas ● ● ● ● ● ●
Agricultural activities (e.g., animal husbandry) ● ● ●
Construction activities ● ● ●
Landscaping, gardening ● ●
Pet waste ● ●
Wildlife ●
Native geology ● ●
Land surface erosion ● ● ●
Commercial activity ● ● ● ● ●
Car washing ● ●
Transportation sources (e.g., brake and tire wear) ● ● ●
Pavement erosion ● ● ●
Sanitary sewer ● ●
FATE AND TRANSPORT MECHANISMS
Atmospheric Deposition ● ● ●
Wildfires ● ● ● ●
Resuspension in soil particles ● ● ●
Land surface erosion ● ● ● ● ●
Sanitary sewer overflows ● ● ●
● ●
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Watershed Land Uses
Understanding historical and current land uses in the watershed helps to identify potential sources of
priority pollutants in stormwater runoff. Following the arrival of Europeans to the Los Angeles Basin, the
lands of the Palos Verdes Peninsula were first used for cattle ranching and then later for dry farming of
barley, hay, grain and garbanzo beans.30 Residential development on the Palos Verdes Peninsula began
in 1913 when J.P. Morgan purchased 16,000 acres of ranch land, however major development was
delayed until after World War I and thereafter growth of residential development proceeded at a modest
pace until the 1950s when growth accelerated and then grew explosively during the 1960s. 31
Today the Palos Verdes Peninsula is effectively built-out and is dominated by single-family residential
(55.6%) and open space (32.8%) land uses, limited multi-family residential (2.8%) and commercial areas
(2.2%), and does not include any industrial land uses. There are also locations where horse uses exist in
designated semi-rural residential areas of the Peninsula. There are no IGP facilities within the PVP EWMP
area. Construction sites are by nature transitory pollutant sources and are subject to oversight by MS4
agencies through their issuance of building permits – the impact of construction sources of pollutants are
indirectly incorporated into the CIMP monitoring data and therefore captured in the reasonable assurance
modeling. Caltrans’ MS4 permit incorporates TMDL WLAs and as such it is assumed that Caltrans land uses
will meet their WLAs individually and such areas have been excluded from the reasonable assurance
modeling exercise.
A breakdown of land uses by watershed is shown in Table 2-15. Drainage within the Peninsula WMG area
is conveyed via natural, soft-bottom canyons and engineered storm drain networks.
Table 2-16: Land Use Distribution within the Palos Verdes Peninsula Watersheds
Watershed COM EDU OS OTHER OTHER (R) PUB MFR SFR
Dominguez Channel: Machado
Lake & Harbor Watersheds
3.10% 5.00% 18.40% 3.90% 1.40% 0.40% 2.90% 64.80%
Santa Monica Bay 1.60% 3.30% 41.20% 0.30% 0.00% 0.50% 2.70% 50.20%
Total 2.20% 3.90% 32.80% 1.60% 0.50% 0.40% 2.80% 55.60%
COM: Commercial
EDU: Educational facility
OS: Open space (i.e., park, recreational facility (i.e., stable, golf course), preserved land, and vacant)
Other: Churches, cemetery
Other (R): Covered Reservoir
PUB: Public facility (i.e., fire, police, city hall)
MFR: Multi-family residential
SFR: Single-family residential
Note: A total of 0.2% are zoned as roads and are not included in this table.
30 Gales, Donald M. 1988. Handbook of Wildflowers, Weeds, Wildlife, and Weather of the South Bay and Palos Verdes Peninsula.
Third Edition.
31 Gales 1988.
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POLLUTANT FATE AND TRANSPORT MECHANISMS WITHIN THE WATERSHED
Pollutant fate and transport mechanisms should also be considered in source characterization to the
extent they contribute or reduce pollutant loading to receiving waters.
ROAD INFRASTRUCTURE
Roadways with curb and gutter are considered part of the MS4 system and as such serve to transport
pollutants from the watershed to receiving waters. However, transportation activities on the roadways
also generate pollutant. Pollutants originate from cars, roadway degradation, and landscaping along the
roadways. Typical contaminants associated with these include sediment, heavy metals, oils and grease,
debris, fertilizers, and pesticides, among others 32. The use and wear of cars is one of the most prevalent
sources of roadway pollutants. Vehicle brake pads constitute the single largest source of copper 33. Tires
and engine parts are also a source of metals pollutants—tire wear accounts for over 50 percent of the
total cadmium and zinc loads in urban runoff 34. Roadways can also be a source of nutrients from
atmospheric deposition of nitrogen and from fertilizers and pesticides used during parkway landscaping
activities.
ATMOSPHERIC DEPOSITION
Atmospheric (or air) deposition is the transfer of pollutants from air to land. Pollutants in the atmosphere
deposit onto solid surfaces and are then washed off by rain, becoming entrained in the stormwater runoff
that reaches receiving waters. Atmospheric deposition of pollutants to developed and undeveloped
surfaces in the watershed can be a major source of pollutants, especially in major metropolitan areas.
Typical pollutants associated with atmospheric deposition are metals, PAHs, PCBs, and nitrogen. These
pollutants enter the atmosphere from point sources (i.e., an industrial facility emitting metals and PAHs
into the air) and mobile sources such as trucks and automobiles.
WILDFIRES
The Palos Verdes Peninsula is in a very high fire hazard severity zone and, when they occur, wildfires can
mobilize pollutants and thereby increase stormwater pollutant loading due to several factors including:
increased runoff associated with soil hydrophobicity which results from fire, increased mobility of
contaminants from soil, release of previously bound contaminants in vegetation, and higher erosion rates.
Total suspended solids (TSS) concentrations in stormwater runoff often increase by orders of magnitude
in post-fire systems thereby increasing the transport of particulate bound pollutants. Combustion of
plants and natural materials has also been reported to release metals which are then mobilized by
storms.35
Southern California Coastal Water Research Project (SCCWRP) conducted a study comparing post-fire
stormwater runoff data from five wildfires in natural open space between 2003 and 2009 in comparison
32 Caltrans (California Department of Transportation). 2003. Discharge characterization study report. California Department of
Transportation, Sacramento, CA.
33 TDC Environmental 2004, Copper Sources in Urban and Shoreline Activities. San Francisco, CA.
34 Davis A.P., M. Shokouhian, and S. Ni. 2001. Loading estimates of lead, copper, cadmium, and zinc in urban runoff from
specific sources. Chemosphere.
35 Burke, M.P., T.S. Hogue, A. Kinoshita, J. Barco, C. Wessel, E.D. Stein 2013. Environmental Monitoring and Assessment
185:10131–10145. Pre- and post-fire pollutant loads in an urban fringe watershed in Southern California.
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with stormwater runoff data from sixteen unburned natural areas and six developed areas. The study
found average copper, lead and zinc fluxes were hundreds of times higher from burned areas than
unburned areas.36 Even more striking, the flux of PAHs from natural burned areas was four times greater
than from adjacent unburned urban areas. Ash fallout on unburned watersheds produced three times
greater flux of PAHs and metals. Prior to the wildfires, most of the burned areas were dominated by sage
scrub [similar to natural plant communities on the Palos Verdes Peninsula], or chaparral plant
communities. It is also notable that the study did not address potential toxic effects from flame retardants
commonly used in combatting wildfires.37
SCCWRP conducted a more recent study of the 2009 Station Fire which consumed 660 square kilometers
of the Angeles National Forest. Much of the area had not burned in over 60 years which meant there was
a potentially large store of anthropogenic lead contamination resident in vegetation and soil due to air
deposition during the time that lead additives were still used in gasoline. Stormwater quality sampling
was conducted from four storm events post-fire at two-hour intervals for a total of 54 grab samples. These
results were compared with 131 grab samples from four storm events during the storm year preceding
the Station Fire. Post-fire peak stormwater flows during two of the storm events post-fire were 15 and 17
times the largest storm during the preceding pre-fire year and yet these post-fire peak flows were
produced with only 80% and 65% of the pre-fire storm precipitation depth. The sediment volume
delivered during the post-fire storm year was ten times the total volume deposited in the preceding fifteen
years at Devil’s Gate Reservoir. Mean seasonal total suspended solids concentration in stormwater
increased 100-fold following the fire. Median concentrations of lead increased by more than 100 times
the magnitude post-fire, while median concentrations of zinc increased by 10 times, and copper by 9
times. Although the burned watershed monitored in this study was largely undeveloped, the
concentrations of metals measured were in the range of concentrations typically measured from highway
drainage, industrial areas and mining operations.38
NATURAL CANYON DRAINAGE SYSTEMS
On the Palos Verdes Peninsula the improved MS4 is interconnected with natural canyon drainage courses
that naturally detain and retain runoff, effectively serving as nature-based stormwater retention systems.
Intense rain events can cause erosion in the natural canyons and increase transport of sediments and
mobilize storm-borne sediment pollutants; for this reason, it is important to protect these canyons from
hydromodification. Overall, these natural canyon drainage courses serve to attenuate pollutants and
reduce stormwater pollutant loading to receiving waters. The reasonable assurance model has been
calibrated against storm flow data from the CIMP monitoring to more accurately reflect the storm runoff
reduction provided by these natural canyon systems.
ORGANOCHLORINE PESTICIDES
Organochlorine pesticides (OC pesticides) are a large group of legacy pesticides, including chlordane,
dieldrin, and DDT, that were previously used widely throughout the United States. Even though they have
been banned from use for many years, they are slow to degrade and continue to persist in the
36 SCCWRP 2012. ED Stein, JS Brown, TS Hogue, MP Burke, A Kinoshita. pp. 11-28 in: Stephen Weisberg and Karlene Miller (eds.),
Southern California Coastal Water Research Project 2012 Annual Report. Southern California Coastal Water Research Project.
Costa Mesa, CA.
37 SCCWRP 2012.
38 Burke et al. 2013.
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environment. Because of their chemical and physical properties these pollutants tend to partition and
bind preferentially to the surfaces of soil particles. When transported in stormwater-borne sediment to
local receiving waters, OC pesticides have been shown to accumulate in the fatty tissue of fish and wildlife
and bio-magnify in the food-web. Soils historically treated with DDT and chlordane continue to be a source
of pollutants in the storm-borne sediment discharges from the MS4 on the Palos Verdes Peninsula as
evidenced by the recent CIMP monitoring results discussed in the next section.
DDT
The history of DDT use was summarized in the staff report to the Machado Lake Toxics TMDL as follows:
“DDT first became widely used as a pesticide in 1939; the use was focused on controlling
insects that transmit diseases such as malaria and typhus during World War II. DDT for
agricultural and commercial uses became widespread in the United States after 1945.
1959 was the peak of DDT use in the United States when approximately 80 million pounds
were applied. In California, DDT was used for the control of both agricultural and urban
pests like mosquitoes and cockroaches. In 1963, the California Department of Food and
Agriculture declared DDT a restricted material. The last year that substantial amounts of
DDT were applied in California was 1970 when 1.2 million pounds of DDT were applied
primarily to agricultural areas.”39
Considering the ubiquitous use of DDT from 1939 through 1970 and understanding the history of land use
and development on the Palos Verdes Peninsula, it is reasonable to expect that DDT was used in
residential applications and that DDT and its breakdown products, DDE and DDD may remain in soils within
the Palos Verdes Peninsula.
CHLORDANE
The history of chlordane use was summarized in the staff report to the Machado Lake Toxics TMDL as
follows:
“Chlordane was first registered and approved for both agricultural and non-agricultural
uses in the United States in 1948. Non-agricultural uses of chlordane included treating
pests in residential lawns and gardens as well as structural pests such as termites.
Chlordane was used on a variety of agricultural crops including corn, citrus, deciduous
fruits and nuts, and vegetables. In 1978, the U.S. EPA cancelled the use of chlordane on all
food crops and for applications to lawns and gardens, although it was still registered for
use in termite control. In 1988, the U.S. EPA cancelled all uses for chlordane.”40
Due to the widespread use of chlordane on residential lawns and gardens, it is reasonable to expect that
chlordane may remain in soils within the watershed.
DIELDRIN
The history of dieldrin use was summarized in the staff report to the Machado Lake Toxics TMDL as
follows:
39 Machado Lake Pesticides and PCBs TMDL. Staff Report - September 2, 2010, page 13.
40 Machado Lake Pesticides and PCBs TMDL. Staff Report - September 2, 2010, page 15
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Dieldrin was widely used from 1950 – 1970 as a structural pesticide for the control of
termites and as an agricultural pesticide for cotton, corn, and citrus crops. The agricultural
use of dieldrin was banned by the US Department of Agriculture in 1970 and in 1987 all
uses of dieldrin were cancelled.41
Historical agricultural land uses on the Palos Verdes Peninsula are not known to include cotton, corn or
citrus crops. Since the use of dieldrin in residential areas was mainly as a structural termiticide and was
not widely applied in lawns and gardens, it is less likely that dieldrin will be present in soils. If present,
dieldrin would exhibit similar fate and transport properties as chlordane and DDT, i.e., it would partition
on storm-borne sediment. As discussed in the next section, to-date dieldrin has not been detected in
storm borne sediment of the CIMP outfall monitoring.
POLYCHLORINATED BIPHENYLS (PCBS)
Polychlorinated biphenyls (PCBs) are mixtures of synthetic organic chemicals that were commonly used
for various applications from approximately 1929 until 1979 when the U.S. banned PCB manufacturing,
processing, distribution, and use. PCBs may be present in products that were made before 1977 but are
still in use today, such as transformers, fluorescent lighting fixtures, household caulking, paints and
waxes42.
U.S. EPA identifies the following list of products and materials that if produced and installed prior to the
1979 ban may still contain PCBs:43
● Transformers and capacitors
● Electrical equipment including voltage regulators, switches, re-closers, bushings, and
electromagnets
● Oil used in motors and hydraulic systems
● Old electrical devices or appliances containing PCB capacitors
● Fluorescent light ballasts
● Cable insulation
● Thermal insulation material including fiberglass, felt, foam and cork
● Adhesives and tapes
● Oil-based paint
● Caulking
● Plastics
● Carbonless copy paper
● Floor finish
Considering the predominantly residential nature of development on the Palos Verdes Peninsula and the
limited industrial sources, either current or in the past, presence of PCBs in exposure to stormwater is
most likely limited to external building materials such as caulk or paint or in utility transformers or
residuals in soils associated with spills from ruptured utility transformers.
POLYCYCLIC AROMATIC HYDROCARBONS (PAHS)
41 Machado Lake Pesticides and PCBs TMDL. Staff Report - September 2, 2010, page 15
42 USEPA: Santa Monica Bay DDT and PCBs TMDL
43 https://www.epa.gov/pcbs/learn-about-polychlorinated-biphenyls-pcbs#commercial
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Polycyclic aromatic hydrocarbons (PAHs) are a group of organic contaminants that are associated with the
release of petroleum products (petrogenic sources) or form from the incomplete combustion of
hydrocarbons (pyrogenic sources). PAHs are an environmental concern because they are toxic to aquatic
life and because several of the individual PAH compounds are suspected human carcinogens. Research
has shown that the dominant source of origin is pyrogenic (combustion of organic matter) in the Los
Angeles Region, and PAHs are often deposited through atmospheric deposition and delivered to
waterbodies in stormwater runoff 44. Other non-point sources may include leaking motor oil, tire wear and
vehicular exhaust.
METALS
General wear and tear of automotive parts can be a source of metals. For example, brake wear and tire
wear can release copper, lead, and zinc into the environment and contribute concentrations of metals to
roads and in turn stormwater runoff. Motor oil and automotive coolant spills are another potential source
of metals. One study found that cars are the leading source of metal loads in stormwater, producing over
50 percent of copper, cadmium, and zinc loads 45.
Table 2-17: Automotive Sources of Metals in Stormwater 46
Source Cadmium Chromium Copper Iron Nickel Lead Zinc
Gasoline ● ● ● ●
Exhaust ● ●
Motor oil and grease ● ● ● ●
Antifreeze ● ● ● ● ● ●
Undercoating ● ●
Brake Linings ● ● ● ● ●
Tires ● ● ● ●
Asphalt ● ● ● ●
Concrete ● ● ●
Diesel Oil ● ● ● ●
Engine wear ● ● ● ●
Fertilizers, herbicides, and pesticides used for lawn and landscape maintenance can contain metals such
as cadmium, copper, mercury, zinc, lead, iron, and manganese47. Algaecides, wood preservatives,
galvanized metals, and paints when used in exposure to stormwater can also be a source of these metals.
ARSENIC
44 Sabin, L.D., K.A. Maruya, W. Lao, D. Diehl, D. Tsukada, K.D. Stolzenbach, and K.C. Schiff 2009. Exchange of Polycyclic Aromatic
Hydrocarbons among the Atmosphere, Water, and Sediment in Coastal Embayments of Southern California, U.S.A. Environmental
Toxicology and Chemistry, Vol. 29, No. 2, pp. 265-274.
45 Schueler, T., and H.K. Holland. 2000. The Practice of Watershed Protection. Center for Watershed Protection, Ellicott City.
46 Nixon, H., and J.D. Saphores. 2007. Impacts of motor vehicle operation on water quality: Clean-up costs
and policies. Transportation Research Part D. Transport and Environment.
47 County of Los Angeles. 2010. Multi-pollutant TMDL Implementation Plan for the Unincorporated County Area of Los Angeles
River Watershed. County of Los Angeles, Los Angeles, CA
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Arsenic is a natural component of the Earth's crust and low levels of the element are found in all
environmental media. Anthropogenic sources of arsenic include nonferrous metal mining and smelting,
pesticide application, coal and oil combustion, wood combustion, and waste incineration. Most
anthropogenic arsenic is emitted to the atmosphere through high temperature processes (e.g., coal and
oil combustion, smelting operations, and waste incineration) and occurs as fine particles which are
transported by wind and air currents until they are returned to earth by wet or dry deposition.48
Arsenic found in soil, either naturally occurring or from anthropogenic releases, forms insoluble
complexes with iron, aluminum, and magnesium oxides found in soil surfaces, and is relatively immobile.
However, under reducing conditions, arsenic can be released from the solid phase, resulting in soluble
mobile forms of arsenic, which may potentially leach into groundwater or result in runoff of arsenic into
surface waters. Arsenic is largely immobile in agricultural soils; therefore, it tends to concentrate and
remain in upper soil layers indefinitely. Terrestrial plants may accumulate arsenic by root uptake from the
soil or by absorption of airborne arsenic deposited on the leaves.49 Arsenic can also leach from wood
treated with chromated copper arsenate (CCA). Ammoniacal copper zinc arsenate (ACZA) is another
arsenic-containing waterborne preservative, though not as widely used as CCA.
Based on current and historical land use, potential sources of arsenic within the Palos Verdes Peninsula
watersheds may include air deposition and residuals in soils from pesticide application, with very minor
contributions from leaching of wood used in landscaping or exterior building materials exposed to
stormwater that have been treated with arsenate-type wood preservatives. Arsenic present in
stormwater discharges would be expected to be associated primarily with storm-borne sediments.
COPPER
Research beginning in the 1990s to address copper impairment of lower South San Francisco Bay has
provided a wealth of information on sources of copper releases to stormwater from urban and suburban
areas. A study prepared by TDC Environmental in 2004 of copper sources in urban and stormwater runoff
to San Francisco Bay identified vehicle brake pads, followed by atmospheric deposition, architectural
copper, industrial use, potable water discharged to storm drains, soil erosion and copper algaecides, in
order of significance.50 Other studies from other parts of the U.S. and internationally have also contributed
to the body of evidence for the importance of these sources in stormwater runoff from developed areas.
The relative importance of copper sources depends on land use within a watershed as well as proximity
to nearby air pollution sources.
Sources of copper in deposits from air pollution can be a result of combustion of vehicle or stationary
source fuels, including wood burning. TDC Environmental estimated comparable emission rates of copper
from industrial air emissions and emissions from fires (both residential wood burning and forest fires). Air
pollution may convey copper from local sources or air emission sources outside the immediate area that
are then deposited in a watershed, either via dry air deposition or wet air deposition during rainfall. In
2006 a study of atmospheric dry deposition of metals was conducted at six urban sites and one nonurban
site within the coastal region of the Los Angeles air basin. Mean flux of copper at the urban sites ranged
from 11 to 34 micrograms per square meter per day whereas the flux of copper at the non-urban Malibu
48 https://www.atsdr.cdc.gov/toxprofiles/tp2-c6.pdf
49 https://www.atsdr.cdc.gov/toxprofiles/tp2-c6.pdf
50 TDC Environmental, 2004. Copper Sources in Urban Runoff and Shoreline Activities – Information Update. Prepared for the
Clean Estuary Partnership. November 2004.
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Creek Watershed site was 3.7 micrograms per square meter per day—the Malibu Creek watershed is
generally upwind of the Los Angeles metropolitan area which further removes it from urban influence. 51
Architectural copper if left uncoated will develop a patina of copper oxides which are water soluble. The
amount of copper washed off architectural features is proportional to the surface area, so copper roofs
provide the greatest surface area, with gutters and flashing providing a lesser surface area.52
Trace levels of copper may occur naturally in soils or be present because of application of copper-
containing pesticides. The TDC Environmental study estimated an average value of 38.57 mg Cu/kg soil
based on data from the State Water Resources Control Board’s construction stormwater database for the
San Francisco Bay area. Copper-containing pesticides are widely used to control fungi, mildew, algae and
roots. Common applications include control of roots in sewers, controlling algae in swimming pools and
ponds, and preventing rot and mildew on wood, roofing and other outdoor surfaces. Copper is also used
in lawn and garden fungicides.53
Copper in the potable water supply may arise from the raw water supply, from algaecides used to control
algae in reservoirs, or by dissolution from copper pipes.54 Potable water may flow into the storm drain
system due to runoff from outdoor irrigation, hydrant flushing, and other sources of outdoor water use
such as car washing or patio cleaning.
Antifouling hull paints or coatings are applied to marine vessels to prevent the attachment and growth of
“fouling organisms” such as barnacles, oysters, mussels, shipworms, or algae that attach to boat hulls.
Copper has been a standard biocide in anti-fouling hull paints for many decades, and copper- based
antifouling hull paints are currently the most commonly used antifouling coating. Copper in hull paint can
slowly leach into the water column and be released from the hull as particles that fall to the bed
sediments, causing impairment 55. There are no marinas or boat maintenance facilities within the
Peninsula WMG watersheds, however it is noteworthy that Cabrillo Marina in Los Angeles Harbor exhibits
ongoing elevated dissolved copper concentrations as discussed in Section 2.2.3.
Based on the preceding discussion of major sources of copper and understanding of current and past land
uses on the Palos Verdes Peninsula, potential sources of copper in stormwater discharges from the
watershed may include releases from vehicle brake pads, use of algaecides in pools or fountains, pesticide
application in landscapes, and air deposition.
LEAD SOURCES
Potential sources of lead to the watershed may include historical and current air deposition of lead from
leaded gasoline used historically in automobiles and currently in general aviation fuel, lead wheel weights
on vehicles, and lead in paint on buildings constructed prior to 1977. Beginning in November 1973 U.S.
EPA began requiring the phase out of lead in all grades of gasoline—at the time the average lead content
in gasoline was 2-3 grams per gallon amounting to 200,000 tons of lead emissions per year in the U.S. By
1995 leaded fuel accounted for only 0.6 percent of total gasoline sales and less than 2,000 tons of lead
51 Sabin, L.D., J.H. Lim, K.D. Stolzenbach and K.C. Schiff, 2006. Atmospheric Dry Deposition of Trace Metals in the Coastal Region
of Los Angeles, California, U.S.A. Environ Toxicol Chem. 2006 Sep;25(9)2334-41.
52 TDC Environmental 2004.
53 TDC Environmental 2004.
54 TDC Environmental 2004.
55 Metz, V. and Gregg, J. Boat Hull Coating Selection and Hull Cleaning for Water Pollution Prevention: Water Quality Factsheet
for Marina Operators and Boaters. Water Quality Program, California Coastal Commission. (2017).
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emissions per year. Effective January 1, 1996, the Clean Air Act banned the sale of leaded fuel in on-road
vehicles.56 The nearby Torrance Airport located just north of the Palos Verdes Peninsula is a general
aviation airfield and a potential source of air deposition of lead within the Palos Verdes Peninsula
watershed due to the use of leaded avgas fuel in piston engine aircraft.
A 2009 study by Sabin found that the mean flux of lead due to air deposition at urban sites in the Los
Angeles basin ranged from 8.3 to 29 micrograms per square meter per day, whereas the flux at the non-
urban site in Malibu Creek Watershed was 1.4 micrograms per square meter per day. A significant drop in
concentration of lead was observed in the study by Sabin when compared with the study done 15 years
earlier in 1987—this was attributed to the elimination of lead from gasoline in the late 1980s.57 Aviation
gasoline for piston airplanes, known as avgas, still includes lead additives and is widely used for general
aviation aircraft thus continuing to be a source of lead in air deposition. Jet aircraft and turbine-powered
propeller aircraft do not use avgas. Efforts to develop an operationally safe and suitable replacement for
the leaded additive in avgas have been underway for over a decade. 58
According to the California Department of Toxic Substances Control (DTSC), prior to 2010 approximately
1.6 million pounds of lead wheel weights fell from vehicles each year onto roadways. Roadway traffic
pulverizes lead wheel weights into dust which then contaminates the air and washes into storm drains.
As of January 1, 2010, California law prohibits the manufacture, sale or installation of wheel weights
containing more than 0.1% lead.59
In 1977 the U.S. Consumer Product Safety Commission effectively banned lead in paint in residential
properties and buildings by limiting the allowable concentration to 0.06 percent.60 Deteriorating or
improperly abated lead paint in older buildings can endanger human health, especially that of children,
and may cause release of lead to the environment, including stormwater.
MERCURY
According to USEPA, on a global level, gold mining is the largest source of anthropogenic mercury
emissions, followed by stationary combustion of coal, non-ferrous metals production and cement
production.61 No gold mining or non-ferrous metals industrial sources are known to have existed on the
Palos Verdes Peninsula with the exception of a former cement mixing facility located on the site of the
former Chandler sand and gravel quarry. Thus, the predominant sources of mercury that might be
encountered on the Palos Verdes Peninsula are mercury deposited as a result of air deposition or
improper disposal of mercury-containing consumer products. USEPA maintains a website with
information on products that contain mercury.62
ZINC
A study was commissioned by the California Stormwater Quality Association (CASQA) to identify major
and minor sources of zinc as a water pollutant and to assist MS4 Permittees in focusing source control
measures in a cost-effective manner. The two major sources of zinc in urban runoff identified by the study
56 https://archive.epa.gov/epa/aboutepa/epa-takes-final-step-phaseout-leaded-gasoline.html
57 Sabin et al. 2006.
58 Federal Aviation Administration 2013. Fact Sheet – Leaded Aviation Fuel and the Environment. June 19, 2013.
59 http://www.dtsc.ca.gov/PollutionPrevention/ToxicsInProducts/leadwheelweights.cfm
60 https://www.cpsc.gov/Recalls/1977/cpsc-announces-final-ban-on-lead-containing-paint
61 https://www.epa.gov/international-cooperation/mercury-emissions-global-context#types
62 https://www.epa.gov/mercury/resources-mercury-science-and-research
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were outdoor surfaces treated with zinc (especially galvanized steel surfaces) and tire wear debris. Other
local sources depending on land use may include zinc-containing paint, recycled tire shred and crumb
products, industrial air emissions, zinc-rich soils, and mining. Minor sources of zinc in urban runoff include
vehicle brake pads, wheel weights, vehicle exhaust, zinc-preserved wood, and certain types of roofing and
siding materials. 63
Galvanized steel has long been used as a cost-effective material for outdoor applications such as: roofing,
gutters, flashing, drainage pipe, and chain-link fencing. Zinc sheet has drawn recent interest in the design
community for its appearance and longevity as a building roofing material and use as siding for
commercial and institutional buildings. A body of literature since the late 1980s has documented relatively
high concentrations of zinc in runoff from outdoor zinc surfaces, and consistent with this occurrence, zinc
concentrations are typically highest in urban runoff from industrial land uses. The amount of zinc washed
off outdoor surfaces is directly proportional to the exposed surface area. Other factors include the quality
of zinc material and the presence of temporary or permanent coatings over the zinc surface. Galvanized
wire fencing has surprisingly large surface area, for example a 6-foot-high industrial gauge (6-gauge) chain
link fence has a surface area of 2.2 square meters per meter of length.64 The presence of coatings over
the zinc surface reduces or substantially eliminates exposure to weather depending on the permanence
of the coating—temporary passivation coatings reduce zinc losses for several years but eventually wash
away, whereas painted zinc surfaces nearly eliminate zinc in runoff. Location is also important because
when large zinc surfaces like galvanized chain-link fencing are sited over permeable surfaces in the
landscaped buffers between properties, infiltration of runoff into a soil drip zone substantially reduces
zinc levels in runoff.65
Nearly all rubber products, including tires, contain zinc oxide which is used to accelerate the vulcanization
process. “According to the International Zinc Association, zinc oxide improves tire wear abrasion
performance, protects against ultraviolet radiation, reduces thermal effects caused by internal friction,
helps bond rubber to metal (such as the steel cord of tires), reduces rubber shrinkage during curing, and
helps keep product molds clean.”66 In the U.S., the main outdoor use for rubber is in vehicle tires.
Tires also comprise the majority of California’s rubber waste and through strong efforts by CalRecycle,
about half of waste tire material is reused within the state. Reuse applications for waste tires that have
the potential to disperse zinc into the environment include combustion as tire-derived fuel, tire retreads,
and tire shred and crumb products such as those used in artificial turf infill and rubberized asphalt.67 There
are no facilities permitted to use tire-derived fuel for combustion within the Los Angeles area.68
Tire wear from on-road vehicles is expected to be the predominant source of zinc within the watershed.
To the extent that rubberized asphalt paving is used for road resurfacing within the watershed, there may
be contributions of zinc from this use as well. There is limited information currently available on the
significance of rubberized asphalt as a source of zinc in stormwater runoff.
63 TDC Environmental, 2015. Zinc Sources in California Urban Runoff prepared for California Stormwater Quality Association. April
2015.
64 Golding 2006. A Survey of Zinc Concentrations in Industrial Stormwater Runoff. Washington State Department of Ecology,
Environmental Assessment Program. Publication No. 06-03-009.
65 Blok 2005. Blok, J. (2005). "Environmental Exposure of Road Borders to Zinc." The Science of the Total Environment 348(1-3):
173-190.
66 TDC Environmental, 2015.
67 TDC Environmental, 2015.
68 California Air Resources Board, 2015. 2015 Report on Air Emissions from Facilities Burning Waste Tires in California. June 2015.
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Air deposition of zinc can also be important. The 2006 study by Sabin found that the mean flux of zinc due
to air deposition at urban sites in the Los Angeles basin ranged from 69 to 228 micrograms per square
meter per day whereas zinc flux at the non-urban Malibu Creek Watershed site was 15 micrograms per
square meter per day.69
Typical California soils have a mean zinc concentration of 149 mg/kg, with few soil types exceeding 200
mg/kg. However, a few soil formations (e.g., the Bedford Canyon formation and fresh carbon-rich portions
of the Monterey formation) have much higher zinc levels in excess of 300 mg/kg. High-zinc soils may
increase zinc levels in urban runoff and creeks where these soils are exposed.70 Since the marine sediment
target for zinc in the Harbor Toxics TMDL is set at 150 mg/kg in sediment, discharge of suspended
sediment associated with soils exhibiting zinc concentrations only slightly above the mean soil
concentration in California could cause exceedance of the target even without loading from additional
sources.
BACTERIA
Sources of indicator bacteria potentially present in the Peninsula WMG’s watersheds based on land uses
include both anthropogenic and non-anthropogenic sources such as:
● Animal wastes – horses, dogs, cats, etc.
● Gardening activities - application of animal manure that has not been fully composted to gardens
and landscapes are a source of bacteria
● Organic food waste from commercial activities when dumpsters are left uncovered in exposure
to stormwater, or subject to scattering by vectors such as seagulls, pigeons, rats, and racoons
● Illegal dumping from recreational vehicle/vessel holding tanks among others, can be a source of
elevated levels of total coliform bacteria
● Sanitary sewer overflows, leaks and/or illicit connections of sanitary lines to the storm drain
system
● Illegal connections and discharges are also possible sources of bacteria in stormwater discharge
● Open defecation associated with recreational activities or people without housing
● Non-anthropogenic sources of indicator bacteria include – soils, decaying vegetation, wildlife such
as birds, opossums, raccoons, etc.
Sanitary sewer systems and septic systems are potential sources of contaminants. Cracks in aging sewer
laterals and mainlines, root intrusion and fats/oils/grease clogs can contribute to sanitary sewer leaks and
overflows. When sanitary sewers overflow or leak, they can release raw sewage into the environment.
Raw sewage contains high concentrations of indicator bacteria and nutrients and may also contain other
pollutants such as suspended solids, pathogenic organisms, toxic pollutants, oil and grease.
N UTRIENTS
69 Sabin et al. 2006.
70 TDC Environmental, 2015.
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Possible sources of nutrients include runoff from residential and commercial areas associated with
landscaping activities and use of fertilizer for lawns and gardens, including organic fertilizer such as
compost or manure. Maintenance activities such as washing cars, parking lots and driveways can
contribute nutrients to the watershed since some detergents contain phosphorus. Other sources of
nutrients include food wastes and domestic animal wastes in exposure to stormwater, or occasional sewer
overflows. Key sources of nutrients identified in the Palos Verdes Peninsula Nutrient Implementation
Plan 71 were fertilizer applied to turf and landscapes, horse manure, and dry air deposition of nitrogen:
● Manure - Within the portion of the Palos Verdes Peninsula that drains to Machado Lake
equestrian activities and horse keeping are common. Horse manure can be a source of nutrients
in runoff. The average 1,000-pound animal produces over 102 pounds of total nitrogen and 18.8
pounds of total phosphorous per year 72. Information from the Model Equestrian Center Project
provides support for the understanding that equestrian centers are a source of nutrients in
stormwater runoff.
● Numerous reports document the linkages between excess nutrients in local water bodies and the
augmentation of naturally occurring soil nutrients with nitrogen and phosphorus applied in
commercial fertilizers, whether organic or synthetic. The desire for green turf and the use of
tropical or exotic plants may lead to the overuse or the misapplication of nitrogen and phosphorus
fertilizers. Because single-family residences are the predominant land use within the Palos Verdes
Peninsula, the application of fertilizer to residential landscapes and to a lesser extent commercial
landscapes, ball fields and parks are potential sources of nutrients. The excess nutrients
accumulated in the soils can be transported to waterways through excessive irrigation or
stormwater runoff.
● Air deposition of nitrogen due to air pollution, particularly onto impervious surfaces where it can
be readily washed into storm drains is a known source of nitrogen, the predominate species being
NHO3 (nitric acid), NO2 (nitrogen dioxide) and NH3 (ammonia)73.
TRASH
Statewide and local studies have documented the presence of trash in state waters and the accumulation
of land-based trash in the ocean. Trash discarded on land may be transported through storm drains to
waterways, shorelines, and the ocean. Street and storm drain trash studies conducted in regions across
California have provided insight into the composition and quantity of trash that flows from urban streets
into the storm drain system and out to adjacent waters.74 The major source of trash results from litter that
is intentionally or accidentally released/deposited onto roadways or other land uses in the watershed by
human activity or animal vectors. Transport mechanisms which cause the litter to reach the storm drain
system include wind action, dispersion by vectors and movement with surface runoff during storm events.
The Statewide Trash Amendments identify certain priority land uses that have been shown in multiple
studies to have high trash generation rates, specifically these include high-density residential land uses
71 Palos Verdes Peninsula Subwatershed Coordinated Implementation Plan in Compliance with the Machado Lake Eutrophic,
Algae, Ammonia and Odors (Nutrient) TMDL, March 11, 2011.
72 Wheeler and Zajaczkowski. Horse Stable Manure Management, Publication G-97. Penn State College of Agricultural Sciences
Cooperative Extension, Agricultural and Biological Engineering
73 Palos Verdes Peninsula Subwatershed Coordinated Implementation Plan. 2011.
74 SWRCB Resolution 2015-0019. Amendment to the Water quality Control Plan for Ocean Waters of California to Control Trash
and Part 1 Trash Provisions of the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays and Estuaries of California.
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with at least ten developed dwelling units per acre, industrial land uses, commercial land uses, mixed
urban land uses, and public transportation stations.75
2.3.2. CHARACTERIZATION OF STORMWATER AND NON-STORMWATER
DISCHARGE QUALITY
The Peninsula WMG began conducting outfall monitoring consistent with the CIMP beginning in 2016.
The outfall monitoring program includes:
Outfall Monitoring: Stormwater outfall water quality and flow monitoring is conducted at six (6)
locations during three (3) wet weather events per year. Two (2) of these outfall monitoring
locations (SD-1 and SD-2) are used to evaluate stormwater discharges from the Palos Verdes
Peninsula to the Santa Monica Bay. Four (4) outfall monitoring locations (Rolling Hills Estates
(RHE) City Hall, Lariat, Solano, and Valmonte) are used to evaluate stormwater discharges from
the Palos Verdes Peninsula to the Dominguez Channel Watershed, including the Wilmington
Drain, Machado Lake and the Greater Los Angeles Harbor surface waterbodies. The CIMP outfall
data also includes continuous flow monitoring and monthly grab samples for Total Nitrogen and
Total Phosphorus in two (2) of the afore mentioned outfall locations with baseline flows to
quantify discharges of nutrients from the Palos Verdes Peninsula to Machado Lake and assess
attainment of the Machado Lake Nutrient TMDL targets.
Non-stormwater Outfall Monitoring: Periodic storm drain screening and monitoring is also
conducted to assess whether there are significant dry weather discharges from the storm drains
on the Palos Verdes Peninsula that need to be added to the monitoring program.
Since the initial development of the EWMP, four complete years of outfall monitoring data have been
collected and validated and are available for use in this characterization and, importantly, for calibration
of the model supporting the reasonable assurance analysis.
Trends in this data are summarized in the following subsection for purposes of updating the source
assessment for the following Peninsula WMG Category 1 and 2 priority pollutants: organochlorine
pesticides (chlordane, DDT and its breakdown products DDE and DDD, dieldrin), PCBs, polycyclic aromatic
hydrocarbons (PAHs), metals (arsenic, copper, lead, mercury, zinc), nutrients (nitrogen, phosphorus), fecal
indicator bacteria, and trash.
The following summarizes findings and trends in this stormwater discharge quality from the four
completed monitoring years between July 2016 and June 2020.
ORGANOCHLORINE PESTICIDES AND POLYCHLORINATED BIPHENYLS (PCBS)
Stormwater outfall monitoring for bioaccumulative organochlorine pesticides and PCBs is conducted by
filtering the sediment fraction from stormwater samples at each of the outfall monitoring sites (two
outfalls tributary to Santa Monica Bay and four outfalls tributary to Machado Lake). Sediment samples
filtered from each storm event are archived and composited by site for the entire storm year (at least
75 SWRCB Final Staff Report for Amendment to the Water Quality Control Plan for Ocean Waters of California to Control Trash
and Part 1 Trash Provisions for Inland Surface Waters, Enclosed Bays, and Estuaries of California.
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three sample events) to accumulate sufficient sample to analyze all the required organochlorine pesticides
as well as PCBs.
For the Santa Monica Bay DDT and PCBs TMDL, waste load allocations (WLAs) set by the USEPA to attain
fish tissue concentration limits for human consumption are based on the calculated three-year average
mass of DDT and PCBs discharged from the Santa Monica Bay watershed area of the Peninsula assigned
as a percentage of the total mass based WLA for the entire Santa Monica Bay Watershed. In order to
estimate stormwater loading of DDT and PCBs to the Santa Monica Bay during TMDL development, a study
by Curren et al. (2011) was used along with data collected by the City of Los Angeles between 2007 and
2010. Estimated stormwater loads from Santa Monica Bay watersheds were found to be lower than
TMDL calculated allowable waste loads necessary to achieve sediment targets; therefore, the WLAs in the
TMDL for DDT and PCBs are based on existing MS4 loading estimates, and MS4 dischargers are essentially
in an anti-degradation condition76. Table 2-17 demonstrates that the rolling three-year average Santa
Monica Bay outfall monitoring results meet the assigned WLAs for both DDT and PCBs, consequently RAA
modeling is not necessary for this water body pollutant combination.
Table 2-18: Santa Monica Bay DDT & PCBs 3-Year Rolling Average Outfall Data
3-Year Period Monitoring Station DDT (g/year) PCBs (g/year)
Santa Monica Bay TMDL Annual Mass-Based WLA* 0.97 5.05
3-Year Averages
2016-17 thru 2018-19
Peninsula-SD1 0.0582 0.0677
Peninsula-SD2 0.0795 0.0634
2017-18 thru 2019-20
Peninsula-SD1 0.0570 0.0014
Peninsula-SD2 0.8836 0.2267
*The WLAs indicated in the TMDL are assigned to the entire Santa Monica Bay Watershed. The WLAs shown
here are calculated as a percentage of the TMDL WLAs based on the Peninsula EWMP area.
Note: Flow data for stormwater outfall event 1/19/17 is not available for SD-2 due to personnel error in
deploying equipment during the monitoring event and is therefore not included in this calculation
The Machado Lake Pesticides and PCBs WLAs are set differently than for the Santa Monica Bay in that for
Machado Lake the WLAs are expressed as three-year average concentrations in the sediment fraction of
the discharge, rather than as total pollutant mass discharged. The organochlorine pesticide 4,4’-
dichlorodiphenyltrichloroethane (DDT) and its breakdown products 4,4’-
dichlorodiphenyldichloroethylene (DDE) and 4,4’dichlorodiphenyldichloroethane (DDD) are assigned
WLAs individually and grouped as Total DDT in the Machado Lake Toxics TMDL. Outfall monitoring data
from the Palos Verdes Peninsula generally supports the underlying assumption in the Machado Lake
Toxics TMDL that a three-year averaging period would provide a means to meet concentration-based
sediment targets for Dieldrin and PCBs since Dieldrin has not been observed to occur in sediment samples
76 USEPA: Santa Monica Bay DDT and PCBs TMDL
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above detection limits, and PCBs have only exceeded the 3-year average concentration in sediment at one
site for one 3-year period. By contrast, as shown in Table 2-18, the data for the DDT breakdown product
DDE and for Chlordane show that sediment discharges from all four monitored outfalls tributary to
Machado Lake exceed the rolling three-year WLA consistently for those constituents and yet for DDT itself,
the WLAs are met. This is evidence that DDT is degrading in the environment. This data also demonstrates
that residuals present in sediments on the Palos Verdes Peninsula from legacy use of DDT and Chlordane
are ubiquitous. The results vary widely from storm year to storm year, and it is unclear whether the
variability is related to timing of sample collection during the storm hydrograph, the intensity of particular
storm events, or a combination of these and other variables. Despite the variability in the data, DDE and
Total Chlordane concentrations in sediment discharges are consistently above the WLAs across all four
sites. This data has been combined with data collected for total suspended solids (TSS) in these samples
and incorporated into the reasonable assurance modeling for Machado Lake.
Table 2-19: Machado Lake Pesticides & PCBs 3-Year Rolling Average Concentrations in Storm-Borne Sediment
Constituent
Final
Machado
Lake
Pesticides
and PCBs
TMDL WLA
(µg/kg) *
3-Year Period
Average Rolling 3-year Monitoring Results by Outfall Location (µg/kg)
RHE City Hall RHE City Hall
Duplicate Valmonte Solano Lariat
Sum DDD 4.88
2016-17 thru 2018-19 21.77 8.5 1.99 3.26 1.73
2017-18 thru 2019-20 22.2 8.87 2.73 279.8 3.37
Sum DDE 3.16
2016-17 thru 2018-19 14.9 13.93 6.6 27.43 30.33
2017-18 thru 2019-20 17.23 16.93 10.00 100.4 36.3
Sum DDT 4.16
2016-17 thru 2018-19 0.98 1 0.58 1.33 0.2
2017-18 thru 2019-20 1.42 1.74 1.02 2.03 1.33
Total
Chlordane 3.24
2016-17 thru 2018-19 15.47 8.27 28.96 48.07 9.7
2017-18 thru 2019-20 16.81 9.47 30.46 110.41 14.93
Total PCB
Congeners 59.8
2016-17 thru 2018-19 7 12.53 0.97 81.68 1.29
2017-18 thru 2019-20 1.37 7.2 0.83 1.35 1.13
*Applied as a 3-year average
METALS
Total and dissolved metals have been monitored in stormwater discharges from the RHE City Hall outfall
site, which is representative of discharges to the Los Angeles Harbor since all of the typical land uses found
on the Palos Verdes Peninsula are included in the catchment tributary to the RHE City Hall MS4 Outfall
site. This data has been utilized in the reasonable assurance modeling for the Los Angeles Harbor to assess
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the necessary load reductions for copper and zinc to meet the waste load allocations for the Los Angeles
Harbor water segments to which the Peninsula WMG is tributary.
Arsenic and mercury have been added to the outfall monitoring sites for the Santa Monica Bay in response
to recent 303(d) listings, however sufficient data are not yet available to support the reasonable assurance
modeling.
POLYCYCLIC AROMATIC HYDROCARBONS (PAHS)
Total PAHs in discharges from the RHE City Hall outfall site representative of discharges to the Los Angeles
Harbor have been analyzed as the sum of acenaphthylene, anthracene, benzo(a)anthracene,
benzo(a)pyrene, benzo(b)fluoranthene, benzo(g,h,i)perylene, benzo(k)fluoranthene, chrysene,
dibenzo(a,h)anthracene, fluorene, indeno(1,2,3-c,d)pyrene, phenanthrene, and pyrene. Results for Total
PAHs measured in stormwater samples from this site have been used in the RAA modeling to assess load
reductions needed to meet the waste load allocations for the Los Angeles Harbor.
N UTRIENTS – DRY WEATHER
Monthly dry weather monitoring for Total Nitrogen and Total Phosphorus has been conducted in storm
drain outfalls tributary to Machado Lake with presence of significant year-round baseline flows associated
with rising groundwater. In Figure 2-7 Total Nitrogen concentrations in these monthly year-round baseline
dry weather flows are compared with the water quality objective for Machado Lake of 1.0 mg/L over the
course of four complete reporting years. These results show periods when the Total Nitrogen results
remain near or below the water quality objective interspersed by periods when the Total Nitrogen results
are consistently above the water quality objective.
In Figure 2-8 Total Phosphorus concentrations in these monthly year-round baseline dry weather flows
are compared with the water quality objective for Machado Lake of 0.1 mg/L over the course of four
complete reporting years. These results show periods when the Total Phosphorus results at the RHE City
Hall site remain near or below the water quality objective interspersed with short-term excursions above
the water quality objective. By contrast, at the Valmonte monitoring site the Total Phosphorus results are
consistently above the water quality objective.
Total Nitrogen and Total Phosphorus monitoring also have been conducted at four storm drain outfalls
tributary to Machado Lake during wet weather along with wet weather flow monitoring. This stormwater
monitoring data along with the monthly dry weather data has been incorporated into the reasonable
assurance modeling to assess necessary load reductions needed to meet the overall nutrient WLAs for
Machado Lake.
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Figure 2-8: Total Nitrogen Concentrations in Peninsula Machado Lake Outfall flows from 2016-2020
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TRASH
Trash is not a pollutant amenable to reasonable assurance modeling. The Peninsula WMG agencies are
individually responsible for meeting WLAs for trash TMDLs and/or complying with the Statewide Trash
Provisions as appropriate, and for monitoring and reporting consistent with their approved plans.
FECAL INDICATOR BACTERIA
As shown in Figure 2-9, Figure 2-10, and Figure 2-11 fecal indicator bacteria densities of Total Coliforms,
Fecal Coliforms and Enterococci in stormwater discharged from the Peninsula MS4 outfalls to Santa
Monica Bay (SD-1 and SD-2 ) do exceed the single-sample water quality based effluent limitations
(WQBELs) during wet weather and these results are typical of MS4 discharges. There does not appear to
be an increasing or decreasing trend in these wet weather indicator bacteria densities over the four years
of CIMP monitoring nor has there been degradation of recreational water quality of the Santa Monica Bay
shoreline or nearshore waters off the Palos Verdes Peninsula, as discussed in Section 2.2.1. Given that the
Figure 2-9: Total Phosphorus Outfall Concentrations in Peninsula Machado Lake Outfall flows 2016-2020
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Palos Verdes Peninsula beaches for which monitoring data exists have been removed from the 303(d) list
for indicator bacteria impairments and the fact that there is no apparent degradation of recreational
water quality, reasonable assurance modeling is not necessary for indicator bacteria in the Santa Monica
Bay.
E. Coli indicator bacteria densities in stormwater discharged from the RHE City Hall MS4 outfall to
Wilmington Drain consistently exceed the STV of 320 cfu /100 mL for fresh waters designated for limited
water contact recreation. These indicator bacteria densities have remained relatively consistent during
the four years of CIMP monitoring. This stormwater outfall monitoring data has been incorporated into
the reasonable assurance modeling to assess necessary load reductions to address the 303(d) listing for
Wilmington Drain.
Figure 2-10: Total Coliform Concentrations in Peninsula Stormwater Discharges from SD1 and SD2 (2016-2020)
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Figure 2-11: Fecal Coliform Concentrations in Peninsula Stormwater Discharges from SD1 and SD2 (2016-2020)
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Figure 2-12: Enterococci Concentrations in Peninsula Stormwater Discharges from SD1 and SD2 (2016-2020)
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3. SELECTION OF WATERSHED CONTROL MEASURES
This chapter identifies Watershed Control Measures (WCMs) to be implemented through the Participating
Agencies’ jurisdictional stormwater management programs, and collectively on a watershed scale. The
WCMs are structural and/or nonstructural controls designed with the following objectives:
● Prevent or eliminate non-stormwater discharges to the MS4 that are a source of pollutants from the
MS4 to receiving waters.
● Implement pollutant controls necessary to achieve all applicable interim and final water quality-based
effluent limitations and/or receiving water limitations pursuant to corresponding compliance
schedules.
● Ensure that discharges from the MS4 do not cause or contribute to exceedances of receiving water
limitations.
● Retain the runoff volume of the 85th%, 24-hour storm event, where feasible.
The goal is to create an efficient program that focuses individual and collective agency resources on water
quality priorities (WQPs). The WCMs are categorized as:
● Minimum Control Measures (MCMs),
● Non-stormwater Discharge (NSWD) Measures, and
● Targeted Control Measures (TCMs), which are designed to achieve applicable water quality-based
effluent limitations and receiving water limitations.
Each WCM category may be further categorized through type: structural or nonstructural, and structural
WCM may be categorized by status as well: existing, planned, proposed, or potential. Combined with
Chapter 4 (RAA) and Chapter 5 (Compliance Schedules), the EWMP addresses the nature, scope, and
timing of implementation for each WCM and provides interim milestones for the WCMs to achieve TMDL
compliance. Also discussed are the responsibilities of each Permittee.
Since the Machado Lake TMDLs and the Los Angeles Harbor Toxics TMDL WLAs were calculated based on
the average annual water year, the revised RAA used the average water year (Water Year 2010) as the
critical condition to establish wet weather nutrient and organic pollutant target load reductions (TLRs) in
the Peninsula Machado Lake watershed management area (WMA)77, including the Wilmington Drain
WMA1 tributary to Machado Lake, and the Los Angeles Harbor WMA. Consistent with all existing Los
Angeles region freshwater bacteria TMDLs, the RAA used the 90th percentile water year (Water Year 2011)
as the critical condition to establish wet weather bacteria TLRs in the Wilmington Drain WMA to address
the 303(d) listing. Based on these critical conditions, the RAA estimated the following 24-hour stormwater
runoff management volumes needed to meet all the non-zero TLRs: 1.3 acre-ft for the Machado Lake
WMA, 0.5 for the Wilmington Drain – Solano WMA, 7.4 acre-ft for the Wilmington Drain WMA, 5.4 acre-
ft for Los Angeles Harbor – Inner Harbor WMA, and 1.5 acre-ft for the Los Angeles Harbor – Cabrillo Marina
WMA. These 24-hour management volumes are intended to be addressed through LID implementation,
existing/planned BMPs, and proposed green streets and regional BMPs as described in this chapter.
Please note that this estimate does not reflect an estimate of recharged groundwater but is simply an
estimate of the reduced amount of stormwater runoff leaving the Peninsula EWMP Area as a result of
BMP implementation as discussed herein.
77 Both Machado Lake and Wilmington Drain WMAs are subwatersheds to the HUC-12 Dominguez Channel Watershed.
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3.1. MINIMUM CONTROL MEASURES
The Minimum Control Measures (MCMs) are baseline WCMs required for all Permittees. The MCMs are
defined in the MS4 Permit (excluding modifications set forth in an approved EWMP) and are implemented
individually by each Permittee. The objectives of the MCMs are to 1) result in a significant reduction in
pollutants discharged into receiving waters and 2) satisfy the requirements of 40 CFR §122.26(d)(2)(iv).
The MCMs are separate from Targeted Control Measures, which are included in the EWMP to specifically
address WQPs.
The MS4 Permit allows the modification of certain MCMs programs, so long as the modified actions are
set forth in the approved EWMP and are consistent with 40 CFR §122.26(d)(2)(iv). The modifications are
based on an assessment to identify opportunities for focusing resources on WQPs. The term
“modifications” refers only to instances where language from the MS4 Permit MCM provisions is removed
and/or replaced. The Permittees in the Peninsula EWMP have implemented the MCMs (Development
Construction Program, Industrial/Commercial Facilities Program, Illicit Connection and Illicit Discharges
Elimination Program, Planning and Land Development Program, Public Agency Activities Program, Public
Information and Participation Program, and Progressive Enforcement and Interagency Coordination
Program) as applicable and will continue to do so as required. Any control measures that are
enhancements of the existing programs (i.e. do not conflict with the MS4 Permit MCM provisions) are
included in the separate category of Targeted WCMs.
A summary of the assessment of each MCM program as well as a determination as to whether each
Participating Agency will implement the MCM provisions either 1) as stated in the corresponding section
of the MS4 Permit or 2) with modifications to focus resources on WQPs can be found in Section 3.1.2. The
implementation of the MCMs are annually reported in the NPDES Individual Annual Reports.
3.1.1. L.A. COUNTY FLOOD CONTROL DISTRICT MINIMUM CONTROL
MEASURES
The LACFCD will implement the MCMs as defined in the MS4 Permit. See Appendix 1 for additional
information.
3.1.2. ASSESSMENT AND MODIFICATION OF MINIMUM CONTROL MEASURES
(PARTICIPATING AGENCIES, EXCLUDING LACFCD)
The following section is an assessment of the MS4 Permit MCMs, intended to identify opportunities for
modifying MCMs to focus resources on WQPs. This section applies to all participating agencies where
applicable, excluding the LACFCD.
3.1.2.1 DEVELOPMENT CONSTRUCTION PROGRAM
The purpose of the MS4 Permit Development Construction Program is to track, inspect and enforce
implementation of BMPs on construction sites and to ensure that construction projects of one acre or
more have coverage under the Construction General Permit. The Permittees are not modifying this
Program and will implement it as defined in the MS4 Permit.
3.1.2.2 INDUSTRIAL/COMMERCIAL FACILITIES PROGRAM
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The purpose of the MS4 Permit Industrial/Commercial Facility Program is to track, inspect, and enforce
implementation of BMPs at industrial and commercial facilities and to ensure coverage under the
Industrial General Permit where appropriate. There are currently no sites subject to the Industrial General
Permit within the jurisdictional authority of the Peninsula WMG nor any commercial sites within the City
of Rolling Hills. The Permittees are not modifying this Program and will implement it as defined in the MS4
Permit.
3.1.2.3 ILLICIT CONNECTION AND ILLICIT DISCHARGES ELIMINATION PROGRAM
The purpose of the MS4 Permit Illicit Connection and Illicit Discharge (IC/ID) Elimination Program is to
detect, investigate and eliminate IC/IDs to the MS4. The Permittees are not modifying this Program and
will implement it as defined in the MS4 Permit.
3.1.2.4 PLANNING AND LAND DEVELOPMENT PROGRAM
Following MS4 Permit provisions, Permittees cannot modify the Planning and Land Development Program
to be less strict than requirements in the MS4 Permit. The Permittees will implement the Program as
defined in the MS4 Permit.
3.1.2.5 PUBLIC AGENCY ACTIVITIES PROGRAM
The Public Agency Activities Program consists of several sub-programs. Many of the MS4 Permit provisions
within the sub-programs consist of baseline operation and maintenance (O&M) control measures that do
not appear to offer clear benefits from modification. The sub-programs that do suggest a prioritized
approach – such as street sweeping and catch basin cleaning frequencies – already provide this
opportunity (frequencies are based on an agency’s assessment of trash and debris generation). As such
the Cities are not modifying this Program and will implement it as defined in the MS4 Permit.
3.1.2.6 PUBLIC INFORMATION AND PARTICIPATION PROGRAM
The MS4 Permit allows an agency to implement the requirements of the Public Information and
Participation Program (PIPP) 1) by participating in a County-wide effort, 2) by participating in a Watershed
Group effort, 3) individually within its jurisdiction or 4) through a combination of these approaches. The
Agencies will implement the PIPP following a combination of approaches.
In terms of Program modifications, the MS4 Permit provisions provide flexibility to focus efforts on WQPs
through the development of the Program. As such, the Cities will implement it as defined in the MS4
Permit. Modifications to elements of the PIPP MCM Program were made to address the Peninsula WMG
watershed priorities through activity-specific outreach programs targeted at the following residential
activities:
a) DIY auto activities
b) DIY home improvement activities
c) DIY landscaping and gardening activities
d) Pet owner activities
e) Rainwater Harvesting and Downspout Disconnection
Each Permittee will implement the Residential Outreach Program through a combination of individual,
watershed, and Countywide program efforts to implement Residential Outreach Program elements.
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The Peninsula WMG implement a customized PIPP strategy, developed collaboratively with the Beach
Cities WMG, to better address watershed priorities, including; hosting Sustainable Gardening and
Landscaping and Integrated Pest Management (IPM) webpages with the South Bay Environmental
Services Center (SBESC) providing information regarding alternative pest controls and best management
practices for fertilizer use, developing a BMP tip card targeting mobile businesses that generate waste
water to mitigate non-stormwater discharges, developing a Small Site Construction brochure focused on
illicit discharge mitigation measures, developing a comprehensive Homeowner’s Guide to Rainwater
Harvesting to encourage the interception and collection of stormwater on residential properties,
maintaining pet waste collection and clean-up stations in municipal parks, developing horse keeping and
manure outreach material, facilitating the management of landscape for brush and fire control by
providing unlimited green waste collection to residents which minimizes potential leaching of phosphorus
from accumulated vegetation and helps to prevent brush fires which mitigates the release of toxic
pollutants, and promoting water conservation and stormwater pollution and prevention messages via
email blasts and the SBESC website.
Outreach metrics may include impressions, educational materials distributed, website views/interactions,
or individuals signed up to receive information. Agencies will annually report outreach metrics in the
Individual Annual Report.
3.1.2.7 PROGRESSIVE ENFORCEMENT AND INTERAGENCY C OORDINATION
Following MS4 Permit provisions, Permittees cannot modify the Progressive Enforcement and Interagency
Coordination Program. The Permittees will implement the Program as defined in the MS4 Permit.
3.1.4 FIFTH TERM MS4 PERMIT MINIMUM CONTROL MEASURES
Previous iterations of the WMP included a review of the substantive enhancements and additions to the
MCMs. The purpose of the review was to highlight new provisions that would address WQPs. The MCM
Provisions of the Fifth Term MS4 Permit do not include significant changes. As such, a review of expected
Fifth Term MS4 Permit MCM provisions is not included in the WMP. The implementation of the Enhanced
MCMs is annually reported in the NPDES Individual Annual Reports and Permittees will continue to report
the implementation of Enhanced MCMs. .
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3.2. NON-STORMWATER DISCHARGE MEASURES
The Participating Agencies will require dischargers that drain to their respective MS4s to implement the
Non-stormwater Discharge (NSWD) Measures. If the Participating Agencies identify non-stormwater
discharges from the MS4 as a source of pollutants that cause or contribute to exceedances of receiving
water limitations, the WCMs will be modified and implemented – subject to the adaptive management
process – to effectively eliminate the source of pollutants consistent with the MS4 Permit. In these
instances, potential WCMs may include prohibiting the non-stormwater discharge to the MS4, requiring
the responsible party to 1) incorporate additional BMPs to reduce pollutants in the non-stormwater
discharge or conveyed by the non-stormwater discharge or 2) divert to a sanitary sewer for treatment, or
strategies to require the non-stormwater discharge to be separately regulated under a general NPDES
permit.
The Permittees in the Peninsula WMP have implemented the NSWD Measures as applicable and will
continue to do so as required by the MS4 Permit. The implementation status of the NSWD Measures have
not changed since the August 2019 Peninsula EWMP. See Appendix 3.1 for enhanced dry weather runoff
reduction control measures.
The implementation of NSWD Measures have been annually reported in the NPDES Individual Annual
Reports and the Watershed Progress Report. The results of the most recent joint NSW Screening and
Monitoring were provided in the 2017-18 Peninsula Watershed Report Volume II IMCR in Section 6.3c and
Table 6f which summarized the work completed to investigate the sources of any significant non-
stormwater discharges at outfalls within the Peninsula WMG. The WMG regularly assesses dry weather
water quality monitoring data and other information to confirm the results of the NSW Screening and
Monitoring.
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3.3 TARGETED CONTROL MEASURES
Targeted Control Measures (TCMs) are additional control measures beyond the baseline MCMs and
NSWD measures of the MS4 Permit that are intended to target the Peninsula WMG’s WQPs based on
potential pollutant sources identified in the updated source assessment in Section 2.3. TCMs may be
divided into two categories: nonstructural and structural. The selection of structural and nonstructural
control measures to address WQPs within the Peninsula WMG is a vital component of the EWMP planning
process.
The Participating Agencies continue to implement structural and nonstructural control measures in the
watershed. There are many different types of structural and nonstructural control measures that provide
varying benefits from their implementation. The following sections and corresponding appendices
describe TCMs that may be implemented (where implementation is conditional upon factors such as site
constraints, governing body approval, etc.), as well types of structural BMPs available to the Peninsula
WMG.
3.3.1 CONTROL MEASURES IDENTIFIED IN TMDLS/IMPLEMENTATION PLANS
This section describes the nonstructural control measures that have been previously identified in TMDLs
and corresponding implementation plans and the status of their implementation. For those TMDLs that
do not sufficiently identify control measures, control measures are identified in the planned Targeted
Control Measures as described in the following sections in this chapter. For more information on the
TMDLs refer to Section 2: Water Quality Priorities.
3.3.1.1 SANTA MONICA BAY BEACHES BACTERIA TMDL
To meet the requirements of Santa Monica Bay Beaches Bacteria (SMBBB) TMDL, a Coordinated Shoreline
Monitoring Plan (CSMP) was developed by a committee of responsible agencies, including representatives
from the Peninsula WMG. The Peninsula WMG monitoring sites historically experience fewer exceedance
days than the reference beach used in the TMDL and are therefore in an anti-degradation condition 78.
Furthermore, as discussed in Section 2.2.1, all of the Peninsula shorelines monitoring sites have been
delisted from the 303(d) list in accordance with the State Water Resources Control Board’s delisting
criteria. As a result, control measures in the approved Implementation Plan include continued
implementation of MCMs to protect or enhance existing water quality, and as-needed investigation if an
excessive number of exceedances occurs at a monitoring site. As discussed in Section 2.2.1, monitoring
results consistently demonstrate attainment of the dry and wet weather SMBBB TMDL receiving water
limitations, therefore a RAA modeling effort is not required for this water body pollutant combination.
Summer-dry and winter-dry weather data at the SMBBB TMDL compliance monitoring locations (CMLs)
collected up to TMDL Year 2015 were evaluated in the initial RAA to conclude that the dry weather water
quality was better than that of the referenced beach based on long-term average exceedance rates. For
the revised RAA, the summer-dry and winter dry- weather monitoring data collected between Year 2015
and 2019 have been evaluated to verify that the dry weather exceedance rates have not degraded from
historical levels and continue to meet their receiving water limitations.
3.3.1.2 SANTA MONICA BAY NEARSHORE AND O FFSHORE DEBRIS TMDL
78 The antidegradation policy applies to waters that are determined to have high water quality and requires that existing high
quality be maintained.
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Compliance with the Santa Monica Bay Debris TMDL is based on installation of structural best
management practices such as full capture or partial capture systems, institutional controls, or any best
management practices, to attain a reduction in the amount of trash in the Santa Monica Bay. Through a
joint project among the PVP Agencies 1,112 catch basins have been retrofit with certified full capture
Connector Pipe Screens within the Santa Monica Bay watershed areas of the Peninsula WMG, funded in
part through a $600,000 Prop 84 Santa Monica Bay Restoration Commission Grant. See Permittee’s
individual Annual Reports for status and information on compliance with the Santa Monica Bay Nearshore
and Offshore Debris TMDL.
3.3.1.3 SANTA MONICA BAY DDT &PCBS TMDL
Data summarized in Section 2.3.1 demonstrates that the rolling three-year average Santa Monica Bay
outfall monitoring results meet the assigned WLAs for both DDT and PCBs, consequently RAA modeling is
not necessary for this water body pollutant combination.
3.3.1.4 MACHADO LAKE T RASH TMDL
Compliance with the Machado Lake TMDL is based on installation of structural best management practices
such as full capture or partial capture systems, institutional controls, implementation of a Minimum
Frequency of Assessment and Collection (MFAC) program, or any best management practices, to attain a
reduction in the amount of trash in the Machado Lake Watershed. To date, over 2,000 full capture trash
devices have been installed in Peninsula WMG catch basins tributary to Machado Lake, partially funded
by Proposition 84 Stormwater Grant funding. These devices were installed in accordance with the
compliance schedule outlined in the TMDL. See Permittee’s individual Annual Report for status and
information on compliance with the Machado Lake Trash TMDL.
3.3.1.5 MACHADO LAKE N UTRIENTS TMDL AND MACHADO LAKE PESTICIDES & PCBS TMDL
To meet the requirements of the Machado Lake Nutrients TMDL, the Peninsula WMG monitors the
Machado Lake outfalls on a monthly basis. To meet the requirements of the Machado Lake Pesticides &
PCBs TMDL, the Peninsula WMG collects sediment samples from the Machado Lake outfalls during every
wet weather event and compiles the samples for analysis. See data summarized in Chapter 2. The
Peninsula WMG developed a plan for achievement of compliance with the Machado Lake Nutrients TMDL
in the Palos Verdes Peninsula Subwatershed Coordinated Implementation Plan (2011), which served as
guidelines for an adaptive implementation of source control programs and development of structural best
management practices.
Infiltration projects reducing nutrients, pesticides, and PCBs flow to Machado Lake, such as the Chandler
Ranch Project, have been constructed and the Peninsula WMG continues to pursue structural projects to
within the Peninsula Watershed and support project opportunities outside of the Peninsula Watershed
such as the Torrance Airport Stormwater Project.
For nutrients, pesticides, and PCBs source control programs, the Peninsula WMG in a collaborative effort
with the Beach Cities, developed Sustainable Gardening and Landscaping and Integrated Pest
Management (IPM) webpages, provided information regarding alternative pest controls and best
management practices for fertilizer use, a BMP tip card targeting mobile businesses that generate waste
water to mitigate non-stormwater discharges, developed a Small Site Construction brochure focused on
illicit discharge mitigation measures, developed a comprehensive Homeowner’s Guide to Rainwater
Harvesting to encourage the interception and collection of stormwater on residential properties, maintain
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pet waste collection and clean-up stations in municipal parks, and developed horse keeping and manure
outreach material.
3.4 NONSTRUCTURAL TARGETED CONTROL MEASURES
Following MS4 Permit provisions, the Peninsula WMG has developed customized strategies, control
measures and O&M control measures to implement the EWMP. Addressing WQPs will be based on a
multi-faceted strategy initially focused on source control. If pollutants are not generated or released, they
will not be available for transport to the receiving waters. In addition, if soils can be stabilized, sediment
controlled, and dry-weather runoff and initial flushes of stormwater runoff eliminated or greatly reduced,
the major transportation mechanisms will be eliminated or greatly reduced, and fewer pollutants will
reach the receiving waters. Since there is a substantial body of research demonstrating that wildfires can
be a significant source of toxic pollutants in stormwater, prevention of wildfires is also an important
source control measure for preventing pollutant mobilization and transport of the Peninsula WMG, which
is identified as a very high fire hazard severity zone. See detailed discussion in Section 2.3.1.
Many of the highest WQPs, such as copper, lead, and zinc, are released into the atmosphere, resulting in
widespread aerial deposition onto impervious surfaces in the Watershed. In addition, these pollutants are
discharged directly onto streets, highways, parking lots, and driveways from motor vehicle components
such as brakes, wheel weights, and tires. The Participating Agencies have concluded that the most cost-
effective and long-lasting way to address WQPs is to develop and support state-wide or regional measures
that will encourage or require, if necessary, product or material substitution at the manufacturing stage.
This can be a complex and time-consuming process, but the payoff in water quality improvement can be
tremendous.
The nonstructural TCMs supplement the MCM efforts with targeted source control measures such as
incentives for irrigation control and upgraded street sweeping equipment, designed with the objective of
achieving interim and final water quality-based effluent limitations and/or receiving water limitations.
Planned and potential nonstructural TCMs for each participating agency can be found in the Appendix 3.1.
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3.5 STRUCTURAL TARGETED CONTROL MEASURES
Structural TCMs are Structural BMPs that, in combination with MCMs, are designed with the objective to
achieve interim and final water quality-based effluent limitations and/or receiving water limitations and
where feasible to achieve retention of runoff from the 85th percentile, 24-hour storm event. Structural
TCMs are an important component of the Peninsula WMG’s load reduction strategy. These BMPs are
constructed to capture runoff and filter, infiltrate, or treat stormwater. If properly maintained, these
BMPs can have high pollutant removal efficiencies); however, they tend to be more expensive than
nonstructural BMPs. The two prevailing approaches for implementing Structural BMPs are regional and
distributed approaches. Both serve important purposes and should be considered in combination to
determine the best possible implementation strategy to meet the Peninsula WMG’s water quality goals.
Appendix 3.2 provides a description of each of the major structural BMP subcategories.
DISTRIBUTED BMPS
Distributed Structural BMPs are generally built at the site-scale. They are intended to treat stormwater
runoff at the source and usually capture runoff from a single parcel or a small area consisting of multiple
parcels and public rights of way. They may also include nature-based solutions such as natural habitat
restoration, and in particular on the Palos Verdes Peninsula natural canyon habitat and riparian canyon
restoration.
REGIONAL BMPS
Regional BMPs refer to large structural BMPs that receive flows from neighborhoods or large areas and
may provide multiple benefits such as: improved water quality, increased water supply, improved flood
management, enhanced park space, restored habitat, improved public access to waterways, creation of
new recreational opportunities, enhanced green spaces at school, reduced heat local island effect,
increased number of trees or other vegetation, or implementation of nature-based solutions79.
3.5.1 PERFORMANCE EVALUATION OF STRUCTURAL CONTROL MEASURES
Except for areas where runoff from the 85th percentile, 24-hour is retained, the performance of existing
and planned BMPs in the Peninsula EWMP area is evaluated through the RAA following provisions of the
MS4 Permit, both in terms of volume capture (based on BMP design criteria) and predicted effluent
quality. An analysis of BMP Performance data has been summarized in Appendix 4.1 and a summary of
modeled BMPs is included in Figure 3-1 and Table 3-1 below. Refer to Section 4 (Reasonable Assurance
Analysis) for more detail on the RAA.
3.5.1.1 REGIONAL BMPS
This chapter contains a summary of existing, planned, proposed, and potential Regional BMPs within the
Peninsula EWMP area
. These project categories are defined as follows:
• Existing – constructed and on-line Regional BMPs.
79 Los Angeles County, California – Code of Ordinances. Flood Control District Code. Chapter 16 - The Los Angeles
Region Safe, Clean Water Program. Accessed May 2021.
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• Planned – some planning for the Regional BMP has been conducted (i.e. preliminary design report,
feasibility study).
• Proposed – initial planning for the Regional BMP has begun, but feasibility studies and preliminary
design reports have not yet been completed.
• Potential – alternative locations where conditions may be suitable for a Regional BMP
It is important to note that the EWMP is subject to adaptive management during the implementation
phase (see Section 9 of this EWMP). The Participating Agencies may notify the Regional Board that
alternative, equivalent actions are proposed in place of the actions described herein. It is important for
the Participating Agencies to have flexibility during the implementation phase if proposed Regional BMPs
are found to be infeasible or less desirable than alternatives. Regional BMPs will be subject to feasibility
studies and/or alternatives analyses. In some cases, the actions proposed herein may be determined to
be less preferred compared to other alternatives. If a preferred alternative action is identified and
selected, the responsible agency will notify the Regional Board of the newly selected alternative(s) and
demonstrate its equivalency.
Figure 3-1: Modeled Regional Projects
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Table 3-20: Summary of Modeled Regional BMPs
Watershed
Management
Area
Project Name Lead WMG
Member
Completed,
Planned, or
Proposed
BMP Type
Drainage
Area
(ac)
Impervious
Drainage
Area (ac)
BMP
Volume
(ac-ft)
Infiltration
/Treatment
Capacity
Wilmington Drain (WD-1)
Torrance Airport Stormwater Basin Project Phase II Rolling Hills Estate Torrance[a] Planned Subsurface Detention & Diversion to Sewer
74 (PVE) 15 (PVE)
21[b] 2.2 cfs 678 (RPV) 263 (RPV) 1,113 (RHE) 539 (RHE) 441 (LAC) 112 (LAC) Rolling Hills Road Green Street Improvement Rolling Hills Estate Proposed Pervious Pavement 0.4 (RHE) 0.4 (RHE) 0.04 1 in/hr
Machado Lake (ML-1)
Casaba Estates LID Rolling Hills Estate Completed Surface Retention Basin 28 (RHE) 7 (RHE) 0.4 0.9 in/hr Rolling Hills Country Club Regional LID Project – West Rolling Hills Estate Completed Surface Retention & Infiltration Basin 358 (RHE) [c] 60 (RHE) 3.8 482 in/hr Rolling Hills Country Club Regional LID Project – East Rolling Hills Estate Completed Surface Retention & Infiltration Basin 51 (RHE) 2.0 (RHE) 0.7 1.3 in/hr Palos Verdes Drive East Green Street Improvement Rolling Hills Estate Potential Green Infrastructure - TBD 2.6 (RHE) 0.5 (RHE) 0.3 1 in/hr Los Angeles Harbor – Inner Harbor (LAH-IH) Eastview Park Regional Project Rancho Palos Verdes Proposed Subsurface Retention, Treatment and Diversion 345 (RPV) 123 (RPV) 1.2 0.6 cfs
Notes:
RPV-Rancho Palos Verdes; PVE-Palos Verdes Estates; RHE-Rolling Hills Estates; RH-Rolling Hills; LAC – Los Angeles County Unincorporated; TOR-Torrance
(a) The Peninsula WMG has agreed to collaborate with City of Torrance to utilize this project to receive and manage stormwater runoff from the Peninsula EWMP area.
(b) The Torrance Airport Stormwater Basin Project total estimated BMP volume is 21 ac-ft. The Peninsula WMG RAA June 2021 model that did not include Rolling Hills demonstrates
that for the Wilmington Drain (WD-1) Watershed Management Area (WMA), 8 ac-ft of 24-hour management volume is needed to meet the final target load reductions. See Section
4 and Section 5 of the EWMP and Appendix 4.1 RAA Report.
(c) Does not include Rolling Hills 85%, 24-hr stormwater runoff retention area.
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3.5.1.1.1 COMPLETED REGIONAL BMPS
CASABA ESTATES (FORMERLY BUTCHER RANCH)80
The Casabas Estates regional BMP project was completed in 2013. The project is approximately 8.55 acres
located in Rolling Hills Estates. It is bounded on the south by Palos Verdes Drive North, easterly by
Monticello Drive, and westerly by Palos Verdes Drive East. The project consists of residential lots, one new
Commercial Recreational lot, parking lots, private roads, and allows for keeping of horses on the
residential lots.
The project involved re-grading a portion of the pre-existing ravine to remove standing water conditions.
This ravine area was rehabilitated into a vegetated bioretention system to retain and infiltrate runoff from
the site. The project receives runoff from offsite (through an existing 24” diameter culvert under Palos
Verdes Drive East) from onsite and offsite areas (a total of 28.62 acres). The new bioretention system was
designed to retain and infiltrate onsite and offsite runoff in a volume greater than the 85th percentile, 24-
hr storm event; therefore, the project was modeled in the RAA as a Regional EWMP Project. See Figure 3-
2 for post-development design conditions.
The Casaba Estates project includes multiple benefits in addition to the stormwater quality benefits that
will be observed. These additional benefits may include, but are not limited to, the following:
● Beneficial Use Protection. This project will result in higher water quality which will help to protect
recreational beneficial uses and support public health (and wellness) in Machado Lake and the Greater
LA Harbor.
● Neighborhood Greening and Public Recreation. This project includes green space within this
development which can positively impact the aesthetics, as well as property values, of urbanized
areas. Property value tends to increase when an urban neighborhood has green space or trees in sight
(CNT, 2010). Green infrastructure and green space can also alleviate urban heat-island effects by
reducing temperatures by about 5oF through shade and evaporation (CNT, 2010).
● Water Conservation/Supply. The stormwater retained onsite recharges groundwater which is being
used for potable or non-potable purposes by the adjacent golf course, thus offsetting reliance on
imported water supply.
80 Bolton Engineering Corp. Hydrology and Hydraulic Calculations. September 13, 2010.
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Figure 3-2: Casaba Estates (formerly Butcher Ranch) Post-Development Design Conditions (Bolton Engineering Corp. Hydrology and Hydraulic Calculations.
September 13, 2010).
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SAN RAMON CANYON
The San Ramon Canyon project is located in the City of Rancho Palos Verdes. The project was completed
in October 2014. The project consists of a mid-canyon inlet structure connected to a 3,900-foot long and
a 54-inch pipe that outlets below the oceanfront bluff, bypassing a highly erodible section of the canyon
(see Figure 3-3). The project inlet is located slightly upstream of the upper switchback along Palos Verdes
Drive East and substantially reduces the amount of flow being delivered to an existing, and overwhelmed,
storm drain at Palos Verdes Drive South/25th Street. This project improves water quality by substantially
reducing erosion and minimizing debris and sediment transport to this drain by diverting all stormwater
runoff from a greater than ¼ inch rain event to the underground pipe, diverting it from the erosive canyon.
Two tunnels (over 2,300 feet in total) were dug, about 4,000 linear feet of 54-inch steel pipe was laid, an
aesthetically-pleasing sculpted concrete outlet structure was built at the beach, a well-anchored concrete
inlet structure was installed in the canyon bottom (acts as a detention basin), the canyon streambed was
restored to historic elevations, new native habitat landscaping was installed, affected portions of the Palos
Verdes Drive East roadway and storm drain system were repaired and improved, and hiking trail access
points were created. Due to the nature of this project its benefits could not be quantified in the RAA
model. However, as mentioned above, this project significantly improves the quality of the downstream
receiving water and addresses PCBs, DDT, and Sediment Toxicity.
The San Ramon Canyon project includes multiple benefits in addition to the stormwater quality benefits
that have been accrued. These additional benefits include, but are not limited to, the following:
● Beneficial Use Protection. This project protects recreational beneficial uses and supports public
health (and wellness) in Santa Monica Bay
● Habitat. This project restores and protects the existing streambed and the surrounding ecosystem to
encourage infiltration and biologic uptake.
● Flood Management. This project decreases flood risk by reducing runoff rate and volume.
● Water Conservation/Supply. The stormwater retained onsite recharges the groundwater which is
being used for potable or non-potable purposes by the golf course, thus offsetting reliance on
imported water supply.
Figure 3-3: San Ramon Canyon Project
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CHANDLER RANCH/ROLLING HILLS COUNTRY C LUB PROJECT 81
Redevelopment of the former Chandler Quarry in the City of Rolling Hills Estates was completed in 2018
through private funding to construct a 114-home subdivision (Chandler Ranch) and reconfigure the Rolling
Hills Country Club golf course and clubhouse. The golf course portion of the project was constructed on
the site of the former quarry, with the golf course and subsurface infiltration gallery designed to provide
the same hydraulic retention and infiltration capacity as the former quarry, an exception to the
Peninsula’s typical geological constraints. The new homes that are part of this redevelopment are still
under construction, however the stormwater infiltration systems have been fully operational since
January 2018 and the golf course is also completed. The project site lies within the Machado Lake sub-
watershed of the Dominguez Watershed Management Area (DWMA). The 226-acre project site is now
comprised of the Chandler Ranch homes under development the Rolling Hills Country Club, and golf
course.
The regional project consists of three (3) infiltration galleries along with a pretreatment system for each
gallery that consists of a suite of catch basin inserts, drainage swales, barrancas and, for the largest gallery,
a biofiltration basin. The largest subsurface infiltration gallery has been designed as a regional BMP system
to capture the 50-year storm runoff event from its 705.2-acre tributary area. This regional project well
exceeds the standard for retention of the 85th percentile, 24-hour storm.
See Figure 3-4, Figure 3-5, and Figure 3-6.
The Chandler Ranch/Rolling Hills Country Club project has multiple benefits in addition to the stormwater
quality benefits. These additional benefits include, but are not limited to, the following:
● Beneficial Use Protection. This project protects the multiple beneficial uses of Machado Lake and
supports public health (and wellness) through protection of this public recreational asset.
● Neighborhood Greening and Public Recreation. This project increases green space within this
neighborhood which positively impacts the aesthetics, as well as property values, of adjacent areas.
Property value tends to increase when an urban neighborhood has green space or trees in sight (CNT,
2010). Green infrastructure and green space can also alleviate urban heat-island effects by reducing
temperatures by about 5oF through shade and evaporation (CNT, 2010). Replacement of the
landfilling and concrete plant uses of the former quarry site with green space has decreased the
associated air pollutants including dust from the concrete and inert landfill activity, as well as diesel
truck trips along local roadways.
● Water Conservation/Supply. The stormwater retained onsite recharges groundwater and is used by
the golf course for non-potable purposes, thus offsetting reliance on imported water supply.
● Public Education/Awareness. This project incorporates stormwater infrastructure within a
recreational facility, creating an awareness of stormwater quality and its importance.
81 Hunsaker and Associates. Water Quality Mitigation Plan. June 16, 2010.
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Figure 3-4: Chandler Quarry Project Drainage Area Map
Source: Hunsaker and Associates. Water Quality Mitigation Plan. June 16, 2010.
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Figure 3-5: Chandler Quarry Project Drainage and Water Quality Concept Plan
Source: Hunsaker and Associates. Water Quality Mitigation Plan. January 29, 2016
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Figure 3-6: Chandler Quarry Project Infiltration System Concept Design
Source: Hunsaker and Associates. Water Quality Mitigation Plan. January 29, 2016
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3.5.1.1.2 PLANNED REGIONAL BMPS
The Peninsula WMG has planned regional BMPs which are at levels varying from a concept plan to a final
design. The anticipated pollutant removals associated with these BMPs were modeled in the RAA prior to
determining additional BMPs necessary for each drainage area. A summary of Planned Regional BMPs
within the Peninsula EWMP area is included below.
TORRANCE AIRPORT BASIN
A planned regional BMP located within the City of Torrance adjacent to the Torrance Airport will capture
and divert urban stormwater flows into the sanitary sewer. This project is located within the Machado
Lake Watershed, outside the Peninsula WMG watershed (see Figure 3-7). The agencies with tributary area
to this planned regional BMP include the cities of Torrance, Rolling Hills, Rolling Hills Estates, Rancho Palos
Verdes, Palos Verdes Estates, and unincorporated Los Angeles County.
The purpose of the project is to divert stormwater flows from the storm drain to be pre-treated and then
stored in subsurface reservoirs for controlled release to the sanitary sewer system and ultimately to the
Joint Water Pollution Control Plant (JWPCP) in the City of Carson where the Metropolitan Water District
(MWD) has constructed the Regional Recycled Water Advanced Purification Center demonstration plant
to treat storm water for regional groundwater infiltration. See Figure 3-8. The project was modeled in the
RAA and is predicted to achieve the TLRs for the entire Wilmington Drain WMA, while also capturing
stormwater from the 24-hour, 85th percentile event .
The Torrance Airport project will have multiple benefits in addition to the stormwater quality benefits
which may include, but are not limited to, the following:
● Beneficial Use Protection. This project will prevent stormwater runoff from reaching the Machado
Lake, and instead divert these flows to the sanitary sewer and ultimately to the JWPCP, thus resulting
in improved water quality, protection of beneficial uses, and support of public health and wellness in
Machado Lake.
● Flood Management. This project will decrease flood risk by reducing runoff rate and volume.
● Water Conservation/Supply. The stormwater diverted to sanitary sewer system and ultimately to the
JWPCP will provide a source of urban stormwater flow for recycled water and potential regional
groundwater infiltration.
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Figure 3-7: Torrance Airport Drainage Area
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Figure 3-8: Conceptual Layout of Torrance Airport Basin
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3.5.1.1.3 PROPOSED REGIONAL BMPS
The Peninsula WMG has proposed regional BMPs, in addition to those already existing and planned, in
order to achieve the TLRs. Appendix 4.1 provides greater detail on the current land use designation,
location, and potential design capture volume of each site. The proposed BMP sites were scored and
ultimately ranked by the sum score from these characteristics:
- Drainage area
- Site area
- Completion status
- Land use
- Estimated infiltration rate
- Estimated depth to groundwater
- Geotechnical hazards
- Sensitive environmental area
- Liquefaction potential.
The sites with the largest drainage area were scored the highest. The land use with the highest
accessibility is listed first. Within each land use designation, the sites have been scored from largest
to smallest. Ultimately, these locations can serve as a starting point for the continued implementation
of the EWMP. Note that with Regional BMPs there are opportunities for multiple agencies to benefit
from the same site. The land uses are ranked as follows:
OPEN SPACE AND RECREATION: Sites designated for open space, parks, and recreational activities were
ranked with the highest potential for future regional BMPs. This ranking is based on the fact that these
types of areas have a high likelihood of being publicly owned eliminating or reducing any high land
acquisition costs, they generally have a high percentage of landscaped area available, and they have
a greater opportunity for multiple benefits.
MUNICIPAL INSTITUTION: Sites owned by a municipality and designated for government use were
ranked with the second highest potential for future Regional BMPs. This ranking is based on the
institution being municipally-owned and presenting a higher likelihood of collaboration than a
privately-owned facility. Although this may be the case, many Municipal Institutions may not be
willing to take on maintenance responsibilities which could result in the necessity of land acquisition
or maintenance agreements.
GOLF COURSES/COUNTRY CLUBS: Sites designated as golf courses or country clubs were ranked with the
third highest potential for future Regional BMPs. This ranking is based on the fact that these types of
areas generally have a high percentage of landscaped area available and have a greater opportunity
for multiple benefits. Although this may be the case, land acquisition for these sites is expected to be
a difficult and costly process.
EDUCATIONAL USE: Sites designated for educational use were ranked with the fourth highest potential
for future Regional BMPs. These sites generally have a high percentage of landscaped area available
and have a greater opportunity for multiple benefits; however, gaining cooperation is expected to be
difficult.
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COMMERCIAL USE: Sites designated as commercial areas were ranked with the fifth highest potential
for future regional BMPs. This ranking is based on the fact that these types of areas generally have a
high percentage of parking available which could potentially be retrofitted for infiltration
opportunities. Although this may be the case, land acquisition for these sites is expected to be a
difficult and costly process.
The available sites were then further assessed by the Peninsula WMG to determine locations for Regional
BMPs. Note that the sites presented do not represent the only sites available for the Peninsula WMG. The
site selection process took into account the following characteristics:
LOCATION IN RELATION TO RAA RESULTS: The RAA provides an estimation of runoff reduction to be
provided in each area in order to meet the water quality objectives. The sites should be selected to
take this into consideration.
GIS DATA: GIS data was further analyzed to screen projects based on criteria such as land use,
topography, hydrologic features, streets and roads, existing storm drain infrastructure, and storm
drain invert depth.
PROJECT BENEFITS: Projects with potential multiple benefits were prioritized due to the increase in the
overall benefit and support for these projects. Benefits to take into consideration included, but were
not limited to, the following:
Water quality benefits
Water supply benefits
Recreational use
Multi-agency benefits
Publicly owned
Storage availability
Funding available
Project readiness
Flood control benefits
Proximity to pollutant sources or impaired waters
Adjacent to existing storm drain
PROJECT CONSTRAINTS: Potential project constraints were a key component in site selection and
elimination. It is important to take into consideration any constraints that may result in project
infeasibility prior to the design phase. Constraints that were taken into consideration include:
High groundwater
Potential for deleterious geotechnical impacts (land movement)
Low infiltration rates
Existing soil contamination/proximity to existing soil contamination
Brownfields82
Existing groundwater contamination/proximity to existing groundwater contamination
Potential for soil instability (liquefaction zones, hillside areas)
82 With certain legal exclusions and additions, the term "brownfield site" means real property, the expansion, redevelopment,
or reuse of which may be complicated by the presence or potential presence of a hazardous substance, pollutant, or
contaminant (Environmental Protection Agency).
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Existing private ownership (requires land acquisition)
Cost Effectiveness (determined through RAA)
Historical landmarks
The participating agencies of the Peninsula Watershed Management Group has encountered geotechnical
and geological constraints in the process of developing projects. Due to the unique geological nature of
the Palos Verdes Peninsula, infiltration is often infeasible. Frequent geologic movement is prevalent
throughout the Palos Verdes Peninsula and extensive research has documented areas where geotechnical
hazards exist and are a concern. See Figure 3-9. These geologic conditions coupled with additional areas
where rising groundwater is a known concern have limited the feasibility of infiltration projects in many
areas within the Palos Verdes Peninsula.
Figure 3-9: Geologic Hazards in the Palos Verdes Peninsula Watershed
These locations served as a starting point for the RAA, which was the final step to determine where BMPs
were needed and the pollutant removal that could be observed through implementation of a BMP.
BMPs were identified in a prioritized manner. Prioritization was based on cost (low cost BMPs were
prioritized); BMP effectiveness for the pollutants of concern (BMPs that had greater treatment efficiency
for the pollutant of concern in a particular analysis region were prioritized over other BMPs); and
implementation feasibility as determined by desktop screening. In general, structural BMPs were
identified that would result in the greatest load reduction per dollar. This was accomplished by targeting
land uses with the greatest drainage area with imperviousness, and BMPs with the greatest performance,
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particularly for the controlling pollutant. The Proposed BMPs resulting from the selection process are
described below.
MACHADO LAKE WATERSHED BMPS
The Machado Lake Watershed has limited areas capable of implementing infiltration projects due to
limited areas with storm drains, available right-of-way, geotechnical hazards, specifically land subsidence,
and lack of available space. Despite these limitations, construction of a large infiltration system was
completed at the former Chandler Quarry (Chandler Ranch/Rolling Hills Country Club Project) in 2018.
Alternatives to regional infiltration-type projects have also been proposed: the Palos Verdes Peninsula
Multi-Benefit Flow Diversion Project and the Rolling Hills Road Green Street Improvement. The Peninsula
WMG will continue efforts to identify projects within and outside of the geotechnically challenged
Machado Lake Watershed. In previous iterations of the Peninsula EWMP (2016, 2019), projects in the
Machado Lake Watershed were considered “proposed regional BMPs.” After further investigation and
communication with potential project collaborators or land owners, the projects as they were initially
conceived were found to be infeasible (South Coast Botanic Garden Regional BMP, Palos Verdes Landfill
Regional BMP, and the Valmonte Regional BMP). The South Coast Botanic Garden Regional BMP was
removed because at this time, a regional-scale project is not feasible. The County is prioritizing planning
of alternate regional projects (Palos Verdes Peninsula Multi-Benefit Flow Diversion Project and Torrance
Airport Project) with the Peninsula agencies. Feasibility investigations have shown that site conditions are
not conducive for stormwater capture.
P ALOS VERDES PENINSULA MULTI-BENEFIT FLOW DIVERSION PROJECT
The EWMP initially conceived the closed Palos Verdes Landfill (PVLF) as a potential location for diversion
of a major storm drain into a flow-through regional stormwater treatment facility. Due to impaired
groundwater and subsurface contamination at this inactive landfill, which is under the oversight of DTSC,
the scale of the original proposed project, which was sized to manage large storm flows, was subsequently
determined to be infeasible due to constraints associated with the proposed project site on the PVLF Main
Site. A smaller scale project is currently proposed to divert baseline flows for beneficial use for irrigation.
The proposed project would address significant year-round baseline flow from rising groundwater in a
major storm drain system tributary to Machado Lake within the WD-1 Analysis Region, i.e., the Machado
Lake Wilmington Drain subwatershed. See Figure 3-10.
The Palos Verdes Peninsula Multi-Benefit Flow Diversion project would have multiple benefits in addition
to the stormwater quality benefits that will be accrued. These additional benefits may include, but are not
limited to, the following:
● Beneficial Use Protection. This project will result in higher water quality which will help to protect
recreational beneficial uses and support public health (and wellness) in Machado Lake. Furthermore,
beneficially using the baseline flows emerging from the Palos Verdes Hills within the Palos Verdes
Peninsula for enhancing parks and open space is a sustainable use for capture flows that reduces the
demand of imported water.
● Neighborhood Greening and Public Recreation. The primary uses proposed for the captured flows
will be to replace potable water used for irrigation of nearby parks and public landscaping. The use
of native and climate-appropriate plants in landscaping would maximizes the use of nature-based
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solutions by limiting use of turf grass only for playing fields. Green infrastructure and green space can
also alleviate urban heat-island effects by reducing temperatures by about 5oF through shade and
evaporation (CNT, 2010).
● Water Conservation/Supply. The primary water supply benefits to accrue from the captured flows
are to offset current potable water use for irrigation, thus offsetting reliance on imported water
supply.
● Public Education/Awareness. This project will beneficially use captured runoff to enhance
recreational benefits, creating an awareness of stormwater and its value as a resource. This project
will provide public education opportunities in the form of on-site educational materials, such as
placards and interpretive signage.
Legend
Storm Drain Diversion
Tributary Area
Flow Direction
Figure 3-10: Proposed PVP Multi-Benefit Flow Diversion Drainage Area
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ROLLING HILLS ROAD GREEN STREET IMPROVEMENT
Redevelopment of Rolling Hills Road from Palos Verdes Drive North to the northern boundary of Rolling
Hills Estates with Torrance has been proposed to the conceptual design level. The project concept has
received significant community engagement through the City of Rolling Hills Estates’ Traffic and Safety
Committee. The preferred project conceptual design received City Council approval on December 8,
2020. This section of roadway will be significantly improved to include bike lanes and
pedestrian/equestrian multi-use pathways on both sides of Rolling Hills Road and will incorporate green
infrastructure features consistent with the City of Rolling Hills Estates’ Green Street Policy. Due to
grade/elevation change along the length of the roadway and current unimproved soft shoulders, during
storm conditions the current drainage conditions along the roadway result in erosion and transport of
sediment into downstream MS4s. Roadway realignment is likely to be associated with this project and will
include the installation of rolled curbs and gutters and related drainage improvements. Project
construction will be scheduled after the neighboring City of Rolling Hills completes installation of a new
sanitary sewer line along this same stretch of roadway. Benefits of the project include but are not limited
to improved pedestrian, equestrian and bicycle safety; connectivity to local bicycle routes in the adjacent
City of Torrance; stormwater quality improvements through reduced sediment and associated pollutant
transport; and enhanced multi-modal transportation and recreational opportunities. Potential green
street elements could include porous paving, biofiltration, bioswales or dry wells.
LOS ANGELES HARBOR WATERSHED BMPS
EASTVIEW PARK INFILTRATION PROJECT
Eastview Park is a large park space near the southeast corner of the intersection of Western Avenue and
Westmont Drive in Rancho Palos Verdes (see Figure 3-11). A large storm drain main runs adjacent to the
park, draining approximately 350 acres. There are two sanitary sewer outfall tunnels running through
Eastview Park at depths ranging from 145-208 ft. If feasible, treatment at this location could consist of a
subsurface infiltration BMP capable of capturing the 1-inch design storm 83 is proposed. Assuming a depth
of 6 feet, the project footprint would be approximately 3.5 acres. Multiple benefits include pollutant load
reduction and groundwater recharge. Significantly more work is needed to investigate the feasibility, cost-
effectiveness, and design details of such a BMP. In the case that infiltration is not a feasible option or
unforeseen constraints affect the project, alternative BMPs could be proposed in the Los Angeles Harbor
Watershed.
The Eastview Park Infiltration project would have multiple benefits in addition to the stormwater quality
benefits that will be observed. These additional benefits may include, but are not limited to, the
following:
● Beneficial Use Protection. This project will result in higher water quality which will help to protect
recreational beneficial uses and support public health (and wellness) at the Greater LA Harbor.
● Neighborhood Greening and Public Recreation. This project will increase the green space within this
development which can positively impact the aesthetics, as well as property values, of urbanized
areas. Property value tends to increase when an urban neighborhood has green space or trees in sight
(CNT, 2010). Green infrastructure and green space can also alleviate urban heat-island effects by
83 The 1.00 -inch storm was selected for load reduction purposes and is larger than the 85th percentile storm
(approximately 0.85-inch).
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reducing temperatures by about 5oF through shade and evaporation (CNT, 2010). Recreation
opportunities also can be increased by increased green space which may decrease the amount of cars
on the road, subsequently decreasing the associated pollutants.
● Water Conservation/Supply. The stormwater retained onsite will recharge the groundwater which
could potentially be used for potable or non-potable purposes in the future, thus offsetting reliance
on imported water supply.
● Public Education/Awareness. This project will incorporate stormwater infrastructure within an area
which is highly used by the public creating an awareness of stormwater quality and its importance.
The onsite BMP may serve as public education opportunities in the form of on-site educational
materials, such as placards and interpretive signage.
Figure 3-11: Proposed Eastview Park Infiltration Project Drainage Area
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3.5.1.1.4 POTENTIAL REGIONAL BMPS
In addition to the existing, planned, and proposed BMPs, several opportunities will be considered for
implementation. In many cases, significantly more work is needed to investigate the feasibility, cost-
effectiveness, and design details of these BMPs; however, they will be considered during the
implementation phase of the EWMP. As further information is gathered, the Participating Agencies may
be inclined to select the below opportunities as alternative or supplemental to the proposed BMPs listed
above. The revised RAA model projected that to meet the TLRs, the Peninsula Watershed Management
Group needs to develop additional projects to manage stormwater besides projects that are existing,
planned, or proposed. This includes projects that would manage additional stormwater for Rancho Palos
Verdes and Rolling Hills Estates in the ML-1 WMA, for Rancho Palos Verdes and Rolling Hills Estates in the
LAH-IH WMA, and for Rancho Palos Verdes in the LAH-CM WMA. See Section 4 and Section 5.
The EWMP is subject to adaptive management during the implementation phase (see Section 9 of this
EWMP) and it is important for the Participating Agencies to have flexibility during the implementation
phase if proposed Regional BMPs are found to be infeasible or less desirable than alternatives.
POTENTIAL MACHADO LAKE WATERSHED BMPS
HARBOR CITY PARK
A stormwater capture project at Harbor City Park would provide water quality improvements to Machado
Lake. An earlier project concept, included in the EWMP developed by the Dominguez Channel Watershed
Management Group, assumed an infiltration project with 2,230 acres diverted to the project from Cities
of Los Angeles, Lomita, and unincorporated Los Angeles County. On behalf of the Peninsula WMG, the
County of Los Angeles initiated discussion with City of Los Angeles and Los Angeles County Sanitation
Districts to evaluate feasibility of expanding the project to include tributary area from the Palos Verdes
Peninsula, diverting stormwater and dry weather runoff from a total capture area of 4,783 acres to be
infiltrated or diverted to the Joint Water Pollution Control Plant in Carson for treatment.
WALTERIA DETENTION BASIN
The Walteria Detention Basin was constructed for flood protection in 1962 by the LACFCD. The basin has a
perimeter of approximately one mile and extends to an approximate depth of 100 feet and has a total capacity
of approximately 1,005 acre-feet. The primary function of the Walteria Detention Basin is to provide flood
protection and as such it is operated to detain flows that enter the basin during storm events. During storm
conditions the basin receives runoff from a tributary area of approximately 2,287 acres with 7.6% of that area
(174 acres) contributed by the Peninsula WMG, with the balance of the area contributed by the City of
Torrance. The facility is operated as a detention basin and when a major storm is forecast or following a
significant storm event, the level in the basin is pumped down to maintain sufficient flood protection capacity
for adjacent communities and to sustain capacity of downstream flood conveyance infrastructure. When such
discharge is necessary, the discharge is pumped into a 54-inch diameter storm drain, i.e., through the Project
No. 584 storm drain, and comingles with flows from other MS4 agencies before eventually discharging to
Wilmington Drain and on to Machado Lake. The Peninsula WMG also understands that it is also necessary to
periodically pump the level in the basin down for maintenance purposes.
The Walteria Detention Basin was identified as a potential location for a regional BMP in the Peninsula
EWMP, pending the results of a Special Study Monitoring Program. The City of Torrance and the LACFCD
collaborated and completed the two-year Special Study Monitoring program to characterize water quality
of the stormwater flowing into and out of the basin. Results of the monitoring effort can be found in the
2017-18 Watershed Annual Report.
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Although it is not feasible to use Walteria Basin as an in-situ water quality treatment system (such as
through application of aluminum sulfate or other flocculants) since such approaches could diminish the
flood protection capacity of the basin, the Peninsula WMG is interested in further analysis to assess how
the basin could be utilized as part of a regional system of stormwater capture projects in conjunction with
the Torrance Airport Regional Project, the Harbor City Park Regional Project, and the Palos Verdes Multi-
Benefit Flow Diversion Project to meet Machado Lake TMDL WLAs on a mass basis for the tributary area
to the basin.
FERN CREEK & VALMONTE CANYON CROSSING RESTORATION PROJECT (FERN CREEK MULTI-BENEFIT
WETLAND RESTORATION PROJECT)
Fern Creek Canyon and Valmonte Canyons are natural drainage courses that converge at the western
corner of Ernie Howlett Park in Rolling Hills Estates where stormwater flows from the two canyons are
directed into an improved culvert and cross under Ernie Howlett Park via a subsurface storm drain that
connects into the MS4 leading to Wilmington Drain and Machado Lake. As observed through years of dry
weather monitoring, Valmonte Canyon does not exhibit flow during dry weather, however Fern Creek
Canyon receives groundwater discharges and exhibits low or intermittent flows throughout the year along
its lower reach. The mouth of Fern Creek Canyon as it enters the culvert has been adversely impacted by
periodic storm debris flows from upper reaches of the canyon which accumulate at the mouth below the
culvert entrance. Restoring the creek bed at the mouth of the canyon and management of debris flows
could reduce nutrient loading to Machado Lake associated with these year-round low flows. The land at
this location is currently privately held and is used for horse keeping, but is not suitable for residential
development, thereby making land acquisition for public open space and recreation potentially feasible
in the future by the City of Rolling Hills Estates. This project would have multiple benefits in addition to
year-round water quality benefits for Machado Lake including, but not limited to, improvement of riparian
habitat, permanent trail access and connectivity of the multi-use trail system at the crossing of Fern Creek
and Valmonte Canyon Trails (currently trail access is conditional by permission of the property owner),
restoration and protection of stream habitat, and enhanced passive and active recreational opportunities.
ACADEMY CANYON AND TRAIL RESTORATION PROJECT
This project would restore and preserve a one-mile section of natural canyon drainage course and hiking
trail that has been adversely impacted by hydromodification. Erosion of the canyon invert has eroded
portions of the trail and exposed sections of a 2,000 linear foot section of subterranean sewer line.
Restoration work would involve canyon, trail and sewer line stabilization, trail enhancement, stormwater
management to protect from future hydromodification and improvement of stormwater quality through
erosion remediation and control, enhancement of wildlife habitat, and enhancement of recreational and
educational opportunities. The trail crest is located adjacent to an independent K-12 day school—the
school has listed the canyon as a certified wildlife habitat with the National Wildlife Federation and
includes the canyon in its environmental education programs. At its terminus near Palos Verdes Drive
North, Academy Canyon drainage is directed into a box culvert and flows via the subsurface MS4 to
Wilmington Drain and Machado Lake. Reversing the impacts of hydromodification will enhance the
nature-based retentive function of this natural canyon thereby reducing storm flow and associated
pollutant loading to Machado Lake.
P ALOS VERDES D RIVE EAST GREEN STREET
The City of Rolling Hills Estates is considering redevelopment of Palos Verdes Drive East roadway from
Palos Verdes Drive North to the northern boundary of Rolling Hills Estates with the City of Lomita. Due to
grade/elevation change along the length of the roadway, roadway curvature and unimproved soft
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shoulders, during storm conditions the current drainage conditions along the roadway result in erosion
and transport of sediment into downstream MS4s and cause stormwater to flow across the roadway at
several locations. Conceptual planning for the project has not yet begun but would incorporate the City’s
Green Street Policy and include/consider the following improvements and benefits: pedestrian,
equestrian and vehicular safety; drainage improvements; stormwater quality improvements through
reduced sediment and associated pollutant transport; and enhanced multi-modal transportation and
recreational opportunities.
REOPENER FOR THE MACHADO LAKE NUTRIENT AND PESTICIDES AND PCBS TMDL
A reconsideration of the Machado Lake Nutrient TMDL was scheduled for September 11. 2016, and the
Peninsula WMG submitted a request for reconsideration on September 7, 2016. At the time Regional
Board TMDL staff indicated that a sufficient body of in-lake monitoring data collected by the City of Los
Angeles following completion of the lake rehabilitation project would be needed prior to a
reconsideration. The Peninsula WMG subsequently requested the Machado Lake Nutrient and Pesticides
& PCBs TMDL implementation schedules be extended as part of the Regional Board’s Consideration of
Extension of Final TMDL Implementation deadlines for Certain TMDLs in the Los Angeles Region in
November 2020; however, the Machado Lake TMDLs were ultimately not considered for extension in that
action. A TMDL reopener to allow reevaluation of the TMDL schedules for final compliance is an avenue
which the Peninsula WMG continues to support.
POTENTIAL SANTA MONICA BAY WATERSHED BMPS
MALAGA COVE WATER REUSE 84
The City of Palos Verdes Estates has implemented dewatering measures to prevent nuisance rising
groundwater from damaging homes and businesses in Malaga Cove. The nuisance groundwater removed
from these dewatering sites is currently discharged into the local storm drain system and/or to the nearby
Pacific Ocean. This potential project could divert this water to a nearby school site or a nearby parkway
in Palos Verdes Estates for irrigation use. This project would serve as a dry weather/low flow diversion
rather than as stormwater capture or treatment project.
In 2019, the City of Palos Verdes Estates completed a source tracking study of dry weather storm drain
flows in this area for presence of HF183 human markers and found no persistent human sources in the
City’s MS4 system upstream of Malaga Cove Beach. Although this potential project has not been included
in the load reductions modeled in the RAA, if needed in the future, it has the potential to contribute to
additional pollutant removal by reducing or eliminating non-stormwater discharges and low flow wet
weather flows from the drainage area.
More work would be required to investigate the feasibility, cost-effectiveness, and design details of such
a BMP. The Malaga Cove Water Reuse project could have additional benefits besides water quality
benefits including offsetting current use of potable water in landscaping of nearby areas.
P ORTUGUESE BEND LANDSLIDE COMPLEX M ITIGATION PROJECT 85 (ABALONE COVE WATER REUSE)
The City of Ranchos Palos Verdes has implemented dewatering measures to prevent nuisance
groundwater and runoff from damaging homes and businesses. In the City of Rancho Palos Verdes,
continuous-withdrawal dewatering wells have been installed to slow the progression of the Abalone Cove
Landslide and the Portuguese Bend Landslide. The nuisance groundwater removed from these dewatering
84 RMC. “Abalone Cove Project and Malaga Cove Plaza Project Conceptual Evaluation.” August 06, 2009.
85 Information gathered from a feasibility study which is currently being conducted for this project.
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sites is currently discharged into the local storm drain system and/or to the nearby Pacific Ocean. The
City of Rancho Palos Verdes conducted and completed a feasibility study of the Portuguese Bend Landslide
Complex (PBLC) to investigate additional mitigation measures to reduce landslide movement and protect
Santa Monica Bay coastal water quality. Although this potential project has not been included in the load
reductions modeled in the RAA, it has the potential to contribute to additional pollutant removal by
reducing or eliminating non-stormwater discharges and low flow wet weather flows from the drainage
area. Additionally, the PBLC Mitigation project will serve to protect the restored rocky reef from excessive
sediment deposition from stormwater discharges through drainage improvements, flow detention basins,
bioswales, and coastal sage scrub habitat restoration.
More work is needed to investigate the cost-effectiveness and design details of such a BMP.
3.5.1.1.5 STAKEHOLDER INCORPORATION
STAKEHOLDER MEETINGS
The Peninsula WMG initially solicited stakeholder input on the Peninsula EWMP development. These
stakeholders included: City Staff, City Council Members and Water Quality and Flood Protection Oversight
Committee, Governmental Organizations Staff, Non-Governmental Environmental Organizations Staff,
Non-Governmental Organizations Staff, and residents. Several public workshops were held and ultimately
stakeholder feedback was incorporated. The Participating Agencies have and will continue to conduct
project-specific stakeholder and community engagement through public workshops, meetings, and
project presentations at the Safe, Clean Water Program South Santa Monica Bay Watershed Area Steering
Committee meetings.
3.5.2 85TH PERCENTILE, 24-HOUR RUNOFF RETENTION AREAS
As provided in Order R4-2021-0105 Part IX.A.4.k., Watershed Management Programs may demonstrate
that strategies, control measures, and BMPs cumulatively retain the runoff volume from the 85th
percentile, 24-hour storm event for the drainage area tributary to the applicable receiving water and for
such areas an RAA is not required. Furthermore, as provided in Order R4-2021-0105 Part X.B.2.b.iii., a
Permittee is deemed in compliance with final WQBELs and receiving water limitations if it has retained all
conditionally exempt, non-essential non-stormwater and all stormwater runoff up to and including the
volume equivalent to the 85th percentile, 24-hour event for the drainage area tributary to the applicable
receiving water provided the Permittee is implementing all actions and schedules in an approved
Watershed Management Program. Watershed areas that fully retain the 85th percentile, 24-hour runoff
volume and were excluded from the RAA analysis are shown in Figure 3-12 and described in the
subsequent narrative.
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Figure 3-12 85th Percentile, 24-Hour Runoff Retention Areas Excluded from RAA
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ROLLING HILLS NATURE-BASED RUNOFF RETENTION AREA
The City of Rolling Hills (Rolling Hills) is a small, entirely residential semi-rural community of single-family
homes with fewer than 2,000 residents in three square miles. By design, it is a model of low-impact
development utilizing nature-based solutions for management of stormwater. Its zoning code includes
strict standards for development ratios on each property and limits disturbed area during development.
A substantial area of land in Rolling Hills is constrained from development due to steep hillsides and
canyons; the use of these areas as wildlife habitat and for native vegetation is emphasized. Rolling Hills’
zoning code further promotes the preservation and appreciation of open space by requiring easements
for equestrian/hiking trails on all lots. There are approximately 30 miles of unpaved equestrian/hiking
trails throughout the city.86
Under Rolling Hills municipal code 87, only 40% of the net area of a residential lot may be disturbed during
construction and the remaining area of the lot must remain in its natural, pre-development state. Only
35% of the net lot area may be developed with impervious surfaces, including structures, patios, and other
paved areas. Given that the minimum lot size in Rolling Hills is 1 acre, with many substantially larger lots,
the limitation on lot coverage preserves significant permeable area throughout the city. Additionally,
driveways may not cover more than 20% of the area of the yard in which they are located, and uncovered
motor courts/parking pads may not cover more than 10% of the yard in which they are located.
Roads within the City have many green street features. They are designed as narrow, two-lane undivided
winding roads 20 to 25 feet wide with rolling to steep grades lined with significant naturalized landscaping.
There are no sidewalks or curb-and-gutter systems, and roads are not designed to be stormwater
conveyance systems.88
Stormwater run-off that is not contained on properties is conveyed through Rolling Hills via natural, soft
bottom, vegetated drainage courses/canyons (see Figure 3-13), providing disconnection of impervious
developed areas and ample opportunity for natural bioretention and infiltration as described in Section
2.3.1: Pollutant Fate and Transport Mechanisms within the Watershed. There is limited public
infrastructure and no city-owned or maintained storm drains, roads, sidewalks, or curb-and-gutter,
though there are some limited, discontinuous drainage improvements owned/operated by the Los
Angeles County Flood Control District (LACFCD).
86 City of Rolling Hills 1990. General Plan – Land Use Element. June 25, 1990.
87 Rolling Hills Municipal Code, Title 17
https://library.municode.com/ca/rolling_hills/codes/code_of_ordinances?nodeId=TIT17ZO
88 City of Rolling Hills 1990. General Plan – Circulation Element. June 25, 1990.
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Figure 3-13 Rolling Hills Nature-Based Stormwater Runoff Retention Area
The net effect of Rolling Hills’ planning and land development standards along with its extensive network
of natural canyon drainage systems is to promote retention and infiltration, creating a system of nature-
based solutions for stormwater management. Along with the Minimum Control Measures, Non-
Stormwater Discharge Measures, and Targeted Non-Structural Control Measures described in Sections
3.1, 3.2 and 3.3, this system of nature-based runoff retention measures effectively retains runoff from the
85%, 24-hr rain event within Rolling Hills as demonstrated through monitoring.
Continuous flow monitoring was conducted in Sepulveda Canyon in Rolling Hills for two complete wet-
weather seasons, from October 26, 2020 through April 2022. Sepulveda Canyon is the largest canyon
system within the Machado Lake tributary area of City, and the second largest in the City as a whole. It
extends from the top of the Palos Verdes Peninsula at the drainage divide between the Machado Lake
and Santa Monica Bay watersheds, running northward to the City’s northern boundary. Sepulveda Canyon
consists of approximately 280 acres lying entirely within Rolling Hills with tributary land use representative
of the City as a whole.
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The continuous flow monitoring was conducted using an ultra-sonic sensor and data logger within a
culvert at the Middleridge Road crossing (33.773522, -118.348538), which is an accessible location near
the bottom of the canyon suitable for flow monitoring. No flow was recorded by the Sepulveda Canyon
monitoring equipment during two complete wet seasons except for during one intense rain event that
occurred from December 29 - 30, 2021. Monthly visual field inspections conducted between November
2020 and June 2021 confirmed the absence of flows and documented the site conditions during storm
events. In Rolling Hills the 85th %, 24-hr rain event ranges from 1.0 - 1.1 inches, depending on location.
From October 26, 2020, through April 30, 2022, there were four (4) rainfall events greater than or equal
to (≧) the 85th%, 24-hr event with numerous lesser rainfall events occurring. No flow was measured at
the Sepulveda Canyon monitoring station during three of the ≧85th%, 24-hr rain events which ranged
from 1.13 to 1.38 inches of rainfall, nor was any flow measured during the smaller rain events. The fourth
large rain event, which occurred from December 29-30, 2021, was more intense and more than twice the
85th% 24-hour storm depth; the LA County rain gauge at the Rolling Hills Fire Station recorded 2.36 inches
in the 24-hour period from 10am on December 29th through 10am on December 30th, 2021, which was in
excess of the 95%, 24-hour storm depth. In total, the Rolling Hills Fire Station rain gauge recorded more
than 3 inches for that entire rain event which spanned 31 hours and produced flow at the Sepulveda
Canyon monitoring station beginning approximately 14 hours after the rain event began. That rainfall
event provides an estimate of the upper bound on the retentive capacity of runoff retention in Rolling
Hills. The no-flow results observed during the three other ≧85th%, 24-hr rainfall events as well as the
numerous smaller rainfall events that occurred throughout the monitoring period provide evidence that
the strategies, control measures and BMPs implemented by Rolling Hills cumulatively retain stormwater
runoff up to and including runoff from the 85th percentile, 24-hour storm event, as well as any
conditionally exempt non-stormwater discharges.
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4. REASONABLE ASSURANCE ANALYSIS
4.1. RAA SUMMARY
The MS4 Permit requires that a Reasonable Assurance Analysis (RAA) be conducted for the waterbody-
pollutant combinations addressed by this EWMP for areas not addressed through retention of the 85%,
24-hr storm event. The RAA involves the identification and evaluation of potential BMP implementation
scenarios with respect to the MS4 Permit-specified effluent and receiving water limits (RWLs) for the
priority pollutants of concern for the Peninsula WMG. The RAA demonstrates achievement of these
effluent and receiving water limits for each waterbody-pollutant combination addressed in this EWMP.
As part of the Adaptive Management process as prescribed by the MS4 Permit, the RAA must be updated
by June 30, 2021, and submitted for review and approval by the Regional Water Board Executive Officer.
Further refining the original RAA (2015), the revised RAA continues to conform to Permit requirements
and the (2014) guidelines developed by the Regional Board. Per MS4 Permit provisions, the revised RAA
incorporates recent monitoring data, project planning and implementation, and modeling advances.
Additionally, the revised RAA addresses issues and comments raised by the State Water Resources Control
Board (SWRCB, 2020), such as inclusion of relevant data for model calibration, non-structural Best
Management Practices (BMP) credit, and application of the limiting pollutant approach.
The updated wet weather RAA was conducted using the Watershed Management Modeling System 2.0
(WMMS 2.0), the latest modeling tool developed by Los Angeles County Flood Control (LACFCD), to
determine a cost-effective implementation strategy to meet applicable water quality standards (i.e. TMDL
waste load allocations [WLA] and Basin Plan Objectives) and targets. For dry weather, a revised semi-
quantitative approach was implemented to update the dry weather portion of the revised RAA.
The RAA process:
1. Applied an acceptable model tailored to the Peninsula WMG based on available outfall and
receiving water data collected through June 2020.
2. Calculated target load reductions (TLRs) necessary to achieve applicable water quality targets.
3. Demonstrated that the existing and proposed suite of projects will attain the TLRs. Where this
was not demonstrated, volumetric management needs have been documented to show what
needs to be achieved in order to demonstrate compliance.
The final MS4 WLAs for total nitrogen and total phosphorus are expressed in the following two ways in
the Machado Lake Nutrients TMDL:
• Monthly average WQBEL concentration.
• Annual average pollutant load calculated as the WQBEL concentration multiplied by the annual
average inflow to the Machado Lake (8.45 HM3/year) apportioned to each WMA tributary to
Machado Lake (directly or via Wilmington Drain). This method was initially established in the Los
Angeles County Machado Lake Nutrient TMDL Special Study (LACDPW, 2011) following
conditional approval of the work plan by LARWQCB (LARWQCB, 2010).
Of the two acceptable pathways to meet targets, the annual average pollutant load method was selected
to determine the allowable load in subsequent TLR calculations.
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The revised and updated Peninsula RAA therefore meets the objectives and requirements of the MS4
Permit and RAA Guidance Document, demonstrating that a reasonable assurance of compliance will be
achieved in each analysis region if the TLRs are fully and appropriately managed.
Refer to the Reasonable Assurance Analyses provided in Appendix 4.1 for the rationale of the Model
Selection and Overview and the RAA Approach. Refer to Appendix 4.2 for requirements for achieving RWLs
for each pollutant category.
4.2. REASONABLE ASSURANCE ANALYSIS
The Reasonable Assurance Analysis for the Peninsula WMG is included in Appendix 4.1.
Table 4-1 summarizes the interim target load reductions (TLRs) established by the RAA, which yielded
interim TLRs of zero for all analysis regions in the Machado Lake and Wilmington Drain WMAs. For the
Santa Monica Bay and Los Angeles Harbor WMAs, no RAA is required to demonstrate compliance with
the interim MS4 WLAs because receiving water monitoring demonstrates the pollutants are below the
interim RWLs.
See Table 4-2 for the final TLR summary. For the Santa Monica Bay WMA, no RAA is required to
demonstrate compliance with the final MS4 WLA because receiving water monitoring shows the
pollutants are meeting the RWLs.
For the non-zero TLRs in the Machado Lake WMA, all the TLR-equivalent 24-hour management volumes
are less than the 85th percentile, 24-hour design storm runoff volume. As a result, the recommended
approach is to meet the final TLRs rather than trying to meet the full 85th percentile, 24-hour design storm
runoff capture alternative. For the Machado Lake analysis region, the largest 24-hour management
volume was selected as the target compliance metric, since management of the largest volume will result
in management of all others. For the Wilmington Drain WMA, since bacteria was not modeled and 85th
percentile 24-hour design storm capture projects are planned for both tributary analysis regions, the full
85th percentile, 24-hour runoff volume is shown as the compliance volume.
For analysis regions in the Los Angeles Harbor WMA, the 85th percentile 24-hour design storm runoff
volume of each analysis region is less than the maximum TLR-equivalent 24-hour runoff management
volumes in that analysis region. Therefore, the recommended approach is to meet the full 85th percentile
24-hour runoff capture alternative.
Table 4-3 summarizes the results of the Peninsula EWMP RAA for all analysis regions and shows that the
TLRs will be met through a combination of LID, Regional and Distributed BMPs. More details on the
completed, planned, proposed and potential BMPs to be implemented to meet these TLRs is provided in
Section 3.
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Table 4-21: Interim Wet Weather Target Load Reduction Summary WMA Analysis Region Pollutant Critical Condition Baseline Load Allowable Interim
Load
Interim Target Load
Reduction
TLR
Equivalent 24-
Hour
Management
Volume (ac-ft) Absolute
% of
Baseline
Load Machado Lake ML-1 Total Nitrogen Average Runoff Year Final TLR = 0%, hence RAA achieved
Total Phosphorus Average Runoff Year 38.4 lb/yr 475 lb/yr 0 lb/yr 0% 0.0 Machado Lake - Wilmington Drain WD-1 Total Nitrogen Average Runoff Year Final TLR = 0%, hence RAA achieved
Total Phosphorus Average Runoff Year 346 lb/yr 3,731 lb/yr 0 lb/yr 0% 0.0 WD -Solano Total Nitrogen Average Runoff Year Final TLR = 0%, hence RAA achieved
Total Phosphorus Average Runoff Year Final TLR = 0%, hence RAA achieved Los Angeles Harbor LAH - IH Total Copper
Total Lead
Total Zinc
DDx (Total)
Total PCBs
Total PAHs
Receiving water monitoring shows all interim RWLs have been met. Hence no RAA needed. LAH-CM Total Copper
Total Lead
Total Zinc
DDx (Total)
Total PCBs
Total PAHs
Receiving water monitoring shows all interim RWLs have been met. Hence no RAA needed. Santa Monica Bay SMB DDx (Total)
Total PCBs Receiving water monitoring shows all RWLs have been met. Hence no RAA needed. SMBBB Total Coliform
Fecal Coliform
Enterococci
Receiving water monitoring shows all RWLs have been met. Hence no RAA needed.
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Table 4-22: Final Wet Weather Target Load Reduction Summary Subwatershed Analysis Region Pollutant Critical Condition Baseline Load
Final Target Load Reduction
Absolute % of Baseline
Load
TLR Equivalent 24-
Hour Management
Volume
(ac-ft) Machado Lake ML-1 Total PCBs Average Water Year 7.5E-04 lb/yr 0 lb/yr 0% 0.0
DDx (Total) Average Water Year 1.0E-03 lb/yr 9.0E-04 lb/yr 88% 1.3
DDT (All congeners) Average Water Year 1.2E-05 lb/yr 0 lb/yr 0% 0.0
DDE (All congeners) Average Water Year 6.4E-04 lb/yr 5.7E-04 lb/yr 89% 1.3[1]
DDD (All congeners) Average Water Year 6.3E-04 lb/yr 5.2E-04 lb/yr 82% 1.1
Total Chlordane Average Water Year 2.1E-04 lb/yr 1.3E-04 lb/yr 64% 0.7
Dieldrin Average Water Year 1.2E-05 lb/yr 0 lb/yr 0% 0.0
Total Nitrogen Average Water Year 119 lb/yr 0 lb/yr 0% 0.0
Total Phosphorus Average Water Year 38.4 lb/yr 0.4 lb/yr 1% 0.1
n/a 85th Percentile 24-Hour
Storm 1.6 ac-ft 1.6 ac-ft 100% 1.6 Machado Lake - Wilmington Drain WD-1 Total PCBs Average Water Year 3.6E-03 lb/yr 0 lb/yr 0% 0.0
DDx (Total) Average Water Year 4.9E-03 lb/yr 4.3E-03 lb/yr 88% 7.4
DDT (All congeners) Average Water Year 6.0E-05 lb/yr 0.0E+00 lb/yr 0% 0.0
DDE (All congeners) Average Water Year 3.1E-03 lb/yr 2.7E-03 lb/yr 89% 7.4
DDD (All congeners) Average Water Year 3.1E-03 lb/yr 2.5E-03 lb/yr 82% 6.2
Total Chlordane Average Water Year 9.9E-04 lb/yr 6.3E-04 lb/yr 64% 4.2
Dieldrin Average Water Year 5.6E-05 lb/yr 0 lb/yr 0% 0.0
Total Nitrogen Average Water Year 1510 lb/yr 0 lb/yr 0% 0.0
Total Phosphorus Average Water Year 346 lb/yr 47.2 lb/yr 14% 0.6
Bacteria (E. coli) 90th Percentile Wet
Year 8.3 1012 MPN/yr 4.2 1012 MPN/yr 51% 6.0
n/a 85th Percentile 24-Hour
Storm 8.01 ac-ft 8.01 ac-ft 100% 8.0[1] WD-Solano Total PCBs Average Water Year 2.07E-04 lb/yr 0 lb/yr 0% 0.0
DDx (Total) Average Water Year 2.84E-04 lb/yr 2.5E-04 lb/yr 88% 0.5
DDT (All congeners) Average Water Year 3.47E-06 lb/yr 0 lb/yr 0% 0.0
DDE (all congeners) Average Water Year 1.77E-04 lb/yr 1.6E-04 lb/yr 89% 0.5
DDD (All congeners) Average Water Year 1.76E-04 lb/yr 1.4E-04 lb/yr 82% 0.4
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Final Target Load Reduction
Absolute % of Baseline
Load
TLR Equivalent 24-
Hour Management
Volume
(ac-ft)
Total Chlordane Average Water Year 5.72E-05 lb/yr 3.6E-05 lb/yr 64% 0.3
Dieldrin Average Water Year 3.21E-06 lb/yr 0 lb/yr 0% 0.0
Total Nitrogen Average Water Year 42 lb/yr 0 lb/yr 0% 0.0
Total Phosphorus Average Water Year 9 lb/yr 0 lb/yr 0% 0.0
Bacteria (E. coli) 90th Percentile Water
Year 0.46 1012 MPN/yr 0.23 1012 MPN/yr 50% 0.5
n/a 85th Percentile 24-Hour
Storm 0.57 ac-ft 0.57 ac-ft 100% 0.6[1] Los Angeles Harbor LAH - IH Total Copper Average Water Year 8.1 lb/yr 4.5 lb/yr 55% 2.2[2]
Total Lead Average Water Year 1.7 lb/yr 0 lb/yr 0% 0.0
Total Zinc Average Water Year 33.5 lb/yr 17.4 lb/yr 52% 2.0
4,4'-DDT Average Water Year 1.3E-05 lb/yr 0 lb/yr 0% 0.0
DDx (Total) Average Water Year 4.7E-03 lb/yr 4.6E-03 lb/yr 96% 10.4
Total PCBs Average Water Year 3.5E-03 lb/yr 1.0E-03 lb/yr 30% 0.9
Total PAHs Average Water Year 4.4E-01 lb/yr 9.8E-03 lb/yr 2% 0.1
n/a 85th Percentile 24-Hour
Storm 5.4 ac-ft 5.4 ac-ft 100% 5.4[1] LAH-CM Total Copper Average Water Year 1.8 lb/yr 0.87 lb/yr 49% 0.5[2]
Total Lead Average Water Year 0.4 lb/yr 0 lb/yr 0% 0.0
Total Zinc Average Water Year 8.2 lb/yr 4.1 lb/yr 50% 0.5
4,4'-DDT Average Water Year 3.3E-06 lb/yr 0 lb/yr 0% 0.0
DDx (Total) Average Water Year 1.2E-03 lb/yr 1.2E-03 lb/yr 96% 2.8
Total PCBs Average Water Year 8.8E-04 lb/yr 2.6E-04 lb/yr 30% 0.3
Total PAHs Average Water Year 1.1E-01 lb/yr 2.5E-03 lb/yr 2% 0.1
n/a 85th Percentile 24-Hour
Storm 1.5 ac-ft 1.5 ac-ft 100% 1.5[1]
[1] Bold value is the representative 24-hour management runoff volume for each analysis region. For WD-1 and WD-Solano, the 85th percentile, 24-hour storm volume is selected
since bacteria was not modeled.
[2] TLR for Total Copper does not account for expected reductions over time due to copper brake pad phase-outs in California. See Appendix 4.1 RAA Section 8.2.1.
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Table 4-23: Peninsula EWMP RAA Summary Analysis Region Management Volume
Final Target Load
Reduction
BMP Load Reduction Summary
LID Redevelopment Regional Projects[2] Distributed Projects Total Load Reduction Assurance Achieved? Absolute % Absolute % Absolute % Absolute % Absolute %
ML-1 24-Hour[1] 1.3[3] ac-ft 100 0.003 ac-ft 0.2 1.25 ac-ft 96 0.04 ac-ft 0.4 1.3 ac-ft 100 Yes
WD-1 85%, 24-Hour 8.0[3] ac-ft 100 0.02 ac-ft 0.6 8.0 ac-ft 100 0 ac-ft 0 8.0 ac-ft 100 Yes
WD-Solano 85%, 24-Hour 0.6[3] ac-ft 100 <0.01 ac-ft 0.5 0.6[4] ac-ft 100 0 ac-ft 0 0.6 ac-ft 100 Yes
LAH-IH 85%, 24-Hour 5.4[3] ac-ft 100 0.03 ac-ft 0.6 5.4 ac-ft 100 0 ac-ft 0 5.4 ac-ft 100 Yes
LAH-CM 85%, 24-Hour 1.5[3] ac-ft 100 <0.01 ac-ft 0.5 1.5 ac-ft 100 0 ac-ft 0 1.5 ac-ft 100 Yes
[1] The 24-hour management volume is the equivalent runoff management volume that will achieve all TLRs. It does not necessarily equate to BMP capacity. A project located at
analysis region outlet may have more 24-hour management capacity than a project with same BMP capacity but is located further upstream in the analysis region. The 24-hour
management volume of a project needs to be computed via a continuous modeling simulation using the calibrated Peninsula EWMP WMMS 2 model.
[2] Regional projects include existing and proposed projects discussed in Section 3 of the EWMP and modeled in the RAA.
[3] Please see the Appendix 4.1 RAA Section 7.6 and Table 11 on how the representative 24-hour management volume was selected for each analysis region.
[4] Includes the Walteria Basin Special Study for analysis region WD-Solano. It is assumed that the Peninsula WMG will continue working with LACFCD and City of Torrance to assess
how the Walteria Basin can be utilized as part of a regional stormwater capture project in conjunction with other regional projects in the Wilmington subwatershed to meet TLRs
in the WD-Solano analysis region.
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5. IMPLEMENTATION SCHEDULE
This Chapter provides the implementation schedule for the Peninsula EWMP. The implementation
schedule will be used to measure progress toward addressing the highest water quality priorities (WQPs)
and achieving final water quality-based effluent limitations (WQBELs) and receiving water limitations
(RWLs). As noted in Chapter 4 and Appendix 4.1 Reasonable Assurance Analysis (RAA), interim WQBELs
have been met for all water body pollutant combinations (WBPCs).
5.1. INTRODUCTION
Provisions of the MS4 Permit describe how receiving water limits (RWLs) goals are to be attained for
various WBPCs identified through adaptive management of the EWMP. Specifically, the following
categories of WBPCs are to be addressed by the EWMP:
• WBPCs addressed through a TMDL (Category 1 pollutants)
• 303(d)-listed WBPCs (Category 2 Pollutants)
o Pollutants in the same class as those identified in a TMDL and for which the waterbody is 303(d)-
listed
o Pollutants not in the same class as those identified in a TMDL, but for which the waterbody is
303(d)-listed
• Non 303(d)-listed WBPCs (Category 3 pollutants)
o Pollutants for which there are exceedances of RWLs, but for which the waterbody is not 303(d)-
listed
Refer to Section 2 for the priority pollutant categorization for the Peninsula EWMP.
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5.2. SCHEDULES
Per Permit provisions, TMDL schedules must be incorporated into the EWMP to demonstrate that
watershed control measures (WCMs) selected during EWMP development will adequately address these
WBPCs in a timely manner so that MS4 discharges of the pollutants will not cause or contribute to
exceedances of RWLs.
This updated EWMP incorporates TMDL schedules outlined in the Permit and, where necessary, interim
milestones and dates for their achievement during the next five-year Permit term. These schedules will
be used to measure progress towards addressing the highest water quality priorities and achieving
applicable WQBELS and/or RWLs.
These schedules will meet the following criteria:
• Schedules must be adequate for measuring progress on a watershed or subwatershed scale.
• Schedules must be developed for all WCMs that will be implemented individually and on a watershed
scale.
Schedules must also incorporate the following:
• Applicable interim and/or final TMDL deadlines occurring within the Permit term identified in Permit.
• Interim milestones and dates for their achievement within the Permit term must be developed for
any applicable TMDL(s) where deadlines within the next 5-year Permit term are not otherwise
specified.
• Interim milestones and dates for their achievement within the Permit term must be developed for
Water Quality Priorities not addressed through a TMDL (Category 2 and 3 WBPCs) based on the
following criteria:
o Milestones must be based on measurable criteria or indicators, to be achieved in the receiving
waters and/or MS4 discharges,
o A schedule with dates for achieving the milestones must be developed, and
o A final date for achieving the receiving water limitations as soon as possible must be determined.
The Peninsula WMG has identified Category 1 and 2 WBPCs as summarized in Table 2-1.
Table 5-1 below outlines the dates and corresponding water quality objectives to be achieved by the
Peninsula EWMP.
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5.2.1. NONSTRUCTURAL BEST MANAGEMENT PRACTICES SCHEDULE
The RAA does not assume or separately quantify a load reduction for the implementation of nonstructural
BMPs. Rather, because recent monitoring data was used during calibration, it was assumed that the
calibrated baseline model effectively accounted for the load reduction accomplished by existing non-
structural BMPs already being implemented in the Peninsula EWMP area. These nonstructural BMPs
consist of Minimum Control Measures (MCMs), Nonstormwater Discharge (NSWD) Measures and
Nonstructural Targeted Control Measures (TCMs) as described in Chapter 3 and Appendix 3.1.
In accordance with the State Board Order (SWRCB, 2020), all non-structural BMP credits are required to
be adequately justified. As such, the RAA has calculated load reductions associated with quantifiable non-
structural BMPs (for copper reductions resulting from phase out of copper in brake pads).
In 2010, California Senate Bill 346 (SB 346) was enacted to eliminate nearly all use of copper in brake pad
manufacturing. In 2013, TDC Environmental prepared a draft detailed study for the California Stormwater
Quality Association (CASQA) describing the expected percent reduction for copper as a result of the
passage of SB 346 (TDC Environmental, 2013). The TDC study identified three possible implementation
scenarios, the least aggressive of which estimated that a 52% load reduction in copper will be achieved
by 2032 due to the brake pad phase-out.
Although there is an expectation that copper loads in urban runoff will decrease over time as a result of
SB 346, the updated RAA did not attempt to take credit for this load reduction at this time. Following the
collection of additional watershed-specific water quality data in the future, adaptive management may
be utilized by the Peninsula WMG to update the TLR for copper and/or the load reductions expected to
be achieved by this source control program.
5.2.2. STRUCTURAL BEST MANAGEMENT PRACTICE SCHEDULE
STRUCTURAL MINIMUM CONTROL MEASURE SCHEDULE
Pollutant load reductions are anticipated through each Participating Agency’s effective implementation
of the structural LID BMP requirements of the Planning and Land Development Program.
STRUCTURAL TARGETED CONTROL MEASURE SCHEDULE
The RAA (Chapter 4) and Appendix 4 RAA Report demonstrates the cumulative effectiveness of BMPs to
be implemented, supports BMP selection, and provides target load reduction (TLR) goals optimized across
the entire watershed.
The plan depicted in the RAA is considered a potential scenario. Through the adaptive management
process, the Participating Agencies may select different types and/or locations of BMPs as described in
Chapter 3. The proposed implementation schedule for the projects needed to meet the 24-hour
management volumes identified in the RAA can be found in Table 5-1. In addition to the projects listed in
Table 5-1 and shown in Figure 5-1, Figure 5-2, and Figure 5-3, the Peninsula WMG is also collaboratively
identifying and seeking funding for other regional projects. The Peninsula WMG agencies draining to
modeled projects are listed in Figure 5-1, Figure 5-2, and Figure 5-3. These agencies would be responsible
for the development of the modeled projects.
In the WD-1 analysis region, the Torrance Airport Project as proposed will meet the 85%, 24-
hour management volume required to meet final target load reductions. The Rolling Hills Road
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Street Improvement/Green Street project is a proposed project that will only be relied upon if
the Torrance Airport Stormwater Basin Project does not proceed as planned.
In the Machado Lake ML-1 analysis region, the City of Rolling Hills Estates intends to meet its
24-hour management volume via the ML-1 RHE Project, and the Palos Verdes Drive East Street
Improvement/Green Street will only be relied upon if it is integrated into the ML-1 RHE Project.
These projects listed below were not modeled in the RAA due to uncertainty of their feasibility, future
design, and performance:
• Walteria Basin Special Study: Walteria Basin is a flood control basin that receives runoff from 174
acres of drainage area (which includes 55 acres of impervious area) from Palos Verdes Estates in
analysis region WD-Solano. The Peninsula WMG will continue working with LACFCD and the City
of Torrance to assess how the Walteria Basin can be utilized as part of a regional system of
stormwater capture project in the Machado Lake watershed to meet TLRs in the WD-Solano
analysis region.
• Palos Verdes Multi-Benefit Flow Diversion Project. This project is currently proposed as a dry
weather flow management project within analysis region WD-1. The Peninsula WMG submitted
this project for FY 21-22 SCW Technical Resources Program funding and it has been approved by
the South Santa Monica Bay Watershed Area for inclusion in its FY 21-22 Stormwater Investment
Plan being forwarded to the Regional Oversight Committee and Los Angeles County Board of
Supervisors for final technical resources funding approval. A wet weather flow management
component will be further evaluated if additional wet weather projects are required to meet the
final TLR through the Peninsula EWMP adaptive management process.
• Harbor City Park Stormwater Capture Project. This project is a signature regional project
proposed by the Dominguez Channel WMG. It is hydrologically connected to the Torrance Airport
Stormwater Capture Project and can potentially capture and treat excess stormwater runoff from
analysis region WD-1. The project was approved for SCW Technical Resources Program FY 20-21
funding. The Peninsula WMG is interested in collaborating with the Dominguez Channel WMG to
share in the benefits of reduced load if additional wet weather projects are required to meet the
final TLR through the Peninsula EWMP adaptive management process.
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Table 5-24: Structural TCM Implementation Schedule
[a] The Torrance Airport Stormwater Basin Project is a collaborative effort with the City of Torrance. Subwatershed Analysis Region Project Name Responsible
WMG Member
Estimated Schedule Modeled
24-Hour
Management
Volume
(ac-ft)
Final TLR
Equivalent
24-Hour
Management
Volume
(ac-ft)
Targeted
Milestone Site Investigation and
Feasibility Study Design and Permitting Construction/
Implementation Machado Lake - Wilmington WD-1 Torrance Airport
Stormwater Basin
Project Phase II
RPV, RHE, PVE,
LA County, and
TOR[a] Completed in 2019 Completed in 2019 Completion Date: 2027 7.4 8.0
• Machado Lake
Nutrient TMDL
Final Deadline
Date:
(September 11,
2018)
• Machado Lake
Pesticides and
PCBs TMDL
Final Deadline
Date:
(September 30,
2019) WD-Solano WD-Solano PVE
Project/Study PVE, LACFCD Completion Date: 2024 TBD Completion Date: 2027 0.57 0.6 Machado Lake ML-1 Casaba Estates LID RHE Project completed in 2013 0.06
1.3
Rolling Hills Country
Club Regional LID
Project – West
RHE Project completed in 2018 0.82
Rolling Hills Country
Club Regional LID
Project – East
RHE Project completed in 2018 0.02
ML-1 RHE Project
(may replace PVDE
Green Street
Improvement)
RHE Completion Date: 2024 Completion Date: 2025 Completion Date: 2027 0.35
ML-1 RPV Project RPV Completion Date: 2024 Completion Date: 2025 Completion Date: 2027 0.04 LA Harbor LAH -IH Eastview Park
Regional Project RPV Completion Date: 2022 Completion Date: 2025 Completion Date: 2030 1.16
5.38 Long Beach and
Greater LA
Harbor Toxics
TMDL Final
Deadline Date:
(March 23, 2032) LAH-IH (cont.) LAH-IH RPV Project RPV Completion Date: 2024 Completion Date: 2027 Completion Date: 2032 3.42
LAH-IH RHE Project RHE Completion Date: 2025 Completion Date: 2028 Completion Date: 2030 0.80 LAH-CM LAH-CM RPV Project RPV Completion Date: 2024 Completion Date: 2026 Completion Date: 2032 1.51 1.51
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Note:
PVE = Palos Verdes Estates; RPV =Rancho Palos Verdes; RHE = Rolling Hills Estates. LAC = Unincorporated Los Angeles County
Due to comparatively low volumes, LID redevelopment distributed projects are not shown in the figure
Figure 5-14: 24-Hour Management Volume Breakdown in Wilmington Drain WMA (WD-1 and WD-Solano)
LACFCD
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Note:
RPV = Rancho Palos Verdes; RHE = Rolling Hill Estates
Due to comparatively low volumes, LID redevelopment is not shown in the figure
Figure 5-15: 24-Hour Management Volume Breakdown in Machado Lake WMA (ML-1)
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Note: RPV = Rancho Palos Verdes; RHE = Rolling Hill Estates
Due to comparatively low volumes, LID redevelopment is not shown in the figure
Figure 5-16: 24-Hour Management Volume Breakdown in Los Angeles Harbor WMA
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6. EWMP IMPLEMENTATION COSTS AND FINANCIAL
STRATEGY
The purpose of this section is to present the financial strategy and to represent the strategic options available to the
permittees for financing the program costs associated with this updated EWMP. This section provides an order-of-
magnitude estimate of the financial resources and an outline for the financial strategy associated with those costs that
may be required to attain the goals of the EWMP. The financial strategy is defined as the options available to the Peninsula
WMG to finance the EWMP implementation, including a prioritization of these options.
6.1. EWMP IMPLEMENTATION COSTS
Planning-level estimates of costs associated with implementation of the proposed structural BMPs within the Peninsula
WMG area are provided herein based on results from the RAA (Section 4). This section includes an evaluation of the overall
economic impacts the proposed projects and programs may have on the community. The cost estimates are preliminary
and are based on the best available information to date. The estimated costs will be refined as EWMP implementation
progresses with the use of actual BMP implementation costs. Costs associated with implementation of non-structural
programs are not provided herein.
Cost opinions are presented as an aid for decision makers, and contain considerable uncertainties. Given the iterative and
adaptive nature of the EWMP and the many variables associated with the projects, the budget forecasts are order-of
magnitude estimates, and are subject to change based on BMP effectiveness assessments, results of outfall and receiving
water monitoring, and additional studies such as site specific objectives which could modify water quality objectives for a
specific water body-pollutant combination.
6.1.1. METHODOLOGY
Costs estimated for structural BMPs include capital as well as “soft” costs, which include considerations such as
contingency and permitting.
The capital, operation and maintenance (O&M) and 20-year life-cycle costs of the proposed projects were estimated using
the following information and cost functions:
• For the Torrance Airport Stormwater Capture Project, the presented costs were extracted from the Safe Clean
Water Program Feasibility Study submitted in October 2020 (City of Torrance, 2020).
• The cost of the remaining projects was estimated based on key modeling parameters using the cost functions
presented in the WMMS 2.0 Phase II Report (LACFCD, 2020c). The cost functions are summarized in Table 6-1.
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Table 6-25: WMMS 2.0 Cost Function
BMP Type BMP Component Capital Cost[1] Annual O&M
Cost[1] Life Cycle Cost[1]
Pervious Pavement $253(A) $5.1 (A) $253(A) + $5.1(A) (Yr)
Subsurface
Retention +
Infiltration
Diversion $7,000(In) $320(In) [$7000 + $12,000](A) +
$12.6(Vf) + $6,000(Yr) + $320
(In)(Yr)
Pretreatment $12,000(In)
Storage $12.6(V) $6,000
Subsurface
Retention +
Filtration
Diversion $7,000(In) $320(In) [$7000 + $12,000](A) +
$12.6(Vf) + $6,000(Yr) + $320
(In)(Yr) + [$177,000
+$70,000](Eff) + [$1,000 +
$3,000](Eff)*(Yr)
Pretreatment $12,000(In)
Storage $12.6(V) $6,000
Pump $177,000(Eff) $3,000(Eff)
Filtration $70,000(Eff) $1.000(Eff)
Subsurface
Retention +
Diversion to
Sewer
Diversion $7,000(In) $320(In) [$7000 + $12,000](In) +
$12.6(Vf) + $6,000(Yr) + $320
(In)(Yr) + $177,000(Ps) +
$3,000(Ps)(Yr)
Pretreatment $12,000(In)
Storage $12.6(V) $6,000
Pump $177,000(Ps) $3,000(Ps)
Sewer Diversion $67,000
[1] A – BMP footprint in ft2; Eff – Treatment rate in cfs ; In – Inflow rate in cfs; Ps – Sewer diversion rate in cfs; Vf –
BMP storage capacity in ft3;
Soft costs are project costs that cannot be calculated on a unit cost basis. For conceptual cost estimating,
these costs are generally calculated as a percentage of total capital costs.
The soft costs considered for each BMP were:
• Contingency – Costs intended to compensate for any estimating inaccuracy based on assumptions or
measured values, unanticipated market conditions, scheduling delays and acceleration issues, lack of
bidding competition, and subcontractor defaults.
• Construction Management – The costs associated with management and oversight of the
construction of the BMP, from project initiation until completion of the contract.
• Mobilization and Demobilization – The costs associated with activation/deactivation of equipment
and manpower resources for transfer to/from a construction site until completion of the contract.
• Permitting – Cost, including permit fees and personnel hours, of obtaining required permits for BMP
installation. Examples of permits needed may include erosion and sediment control, stormwater,
construction, and public space permits.
• Engineering and Planning – Costs associated with BMP and site design, as well as access for
maintenance, environmental mitigation, buried objects, safety/security, traffic control, limited space,
and site restoration.
The expected costs for each of these soft costs as percent of total project capital costs are presented in
Table 6-2. These percentages were based on literature, best professional judgment, and data from past
projects.
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Table 6-26: Range of Soft Costs for Regional Projects
Cost Item Low Cost Assumption
(% of Capital Cost)
High Cost Assumption
(% of Capital Cost)
Contingency 10% 20%
Construction Management 8% 15%
Mobilization and Demobilization 3% 5%
Permitting 3% 5%
Engineering and Planning 10% 20%
Total 38% 50%
6.2. SUMMARY OF COSTS
The Reasonable Assurance Analysis (RAA) for the Peninsula EWMP indicates that the 24-hour
management volume of runoff and stormwater required to be captured within the Watershed to comply
with RWLs and WQBELs is: 1.3 acre-ft for the Machado Lake WMA, 0.5 for the Wilmington Drain – Solano
WMA, 7.4 acre-ft for the Wilmington Drain WMA, 5.4 acre-ft for Los Angeles Harbor – Inner Harbor WMA,
and 1.5 acre-ft for the Los Angeles Harbor – Cabrillo Marina WMA.
Table 6-3 presents the estimated capital cost to construct or implement each modeled structural BMP
and the associated annual O&M costs. The cost summary does not include already-completed regional
projects (Casaba Estates LID and Rolling Hills Country Club LID) or projects that are not included in the
RAA (Harbor City Park Stormwater Capture Project). The cost of the Palos Verdes Peninsula Multi-benefit
Flow Diversion Project will be determined as part of the Project’s Safe, Clean Water Program Feasibility
Study.
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Table 6-27: Estimated Capital and O&M Costs for Regional BMPs
Analysis
Region Lead Agency Project Capital Annual
O&M Cost
20-Year Life
Cycle Cost
ML-1 Rolling Hills
Estates
Palos Verdes Drive East Street
Improvement $2,859,000 $58,000 $4,012,000
ML-1 Rolling Hills
Estates ML-1 RHE Regional Project $254,000 $40,000 $1,060,000
ML-1 Rancho Palos
Verdes ML-1 RPV Regional Project $30,000 $40,000 $821,000
WD-1
Rancho Palos
Verdes and
Torrance
Torrance Airport Stormwater
Basin Project Phase 2 $12,000,000 $118,000 $13,700,000
WD-1 Rolling Hills
Estates
Rolling Hills Road Street
Improvement $481,000 $10,000 $675,000
LAH-IH Rancho Palos
Verdes Eastview Park $781,000 $42,000 $1,619,000
LAH-IH Rolling Hills
Estates LAH-IH RHE Regional Project $2,308,000 $47,000 $3,241,000
LAH-IH Rancho Palos
Verdes LAH-IH RPV Regional Project $540,000 $41,000 $1,363,000
LAH-CM Rancho Palos
Verdes LAH-CM RPV Regional Project $913,000 $9,000 $968,000
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6.3. FINANCIAL STRATEGY
6.3.1. SUMMARY
Financing the implementation of the Peninsula EWMP has historically been the greatest challenge
confronting the Peninsula WMG. In the absence of stormwater utility fees (aside from those specified for
maintenance), the Peninsula WMG had no dedicated revenue stream to pay for implementation of the
EWMP. The absence of a stable stormwater funding mechanism not tied to municipal General Funds
became ever more critical with the approval of the fourth term MS4 Permit, which greatly magnified the
cost challenges associated with managing stormwater. This prompted the City Manager Committees of
the California Contract Cities Association and the League of California Cities, Los Angeles Division, to form
a City Managers’ Working Group (Working Group) to review stormwater funding options after the Clean
Water, Clean Beaches funding initiative that was proposed by LA County failed to move forward. The result
was a Stormwater Funding Report that noted, “the Los Angeles region faces critical, very costly, and
seriously underfunded stormwater and urban runoff water quality challenges.” The Report found that
funding stormwater programs is so complex and dynamic, and that the water quality improvement
measures are so costly, that Permittees could not depend on a single funding option at the time. The
Report also included a variety of recommendations, including organizational recommendations;
education and outreach program recommendations; recommendations for legislation; Clean Water, Clean
Beaches recommendations; local funding options; and recommendations for the Regional Water Board89.
The Watershed Group carefully considered the recommendations of the Report during the development
of the original financial strategy for the EWMP, and placed focus on the local funding options presented
in the Report to secure the needed funding for initial implementation of the EWMP.
The challenges associated with financing the implementation of the EWMP have since been partially
addressed and ameliorated with the passage of Measure W, which was approved by voters in Los Angeles
County with 69.45% of the vote in the general election held on November 6, 2018. Measure W successfully
proposed the implementation of a special parcel tax of 2.5 cents per square foot of impermeable area to
be included on property tax bills in Los Angeles County beginning in October 2019. As presented on the
ballot, funds generated through Measure W are to be utilized for “improving/protecting water quality;
capturing rain/stormwater to increase safe drinking water supplies and prepare for future drought;
protecting public health and marine life by reducing pollution, trash, toxins/plastics entering Los Angeles
County waterways/bays/beaches.” The special parcel tax is initially anticipated to amount to an annual,
county-wide commitment of up to $285 million, though this could decrease slightly over time as
exemptions and credits are processed.
The passage of Measure W also created the Safe Clean Water Program (SCWP), which is administered by
the County of Los Angeles and is designed to provide local, dedicated funding for stormwater and urban
runoff management programs and projects. Total revenue will be distributed per the following
breakdown: 10% will be allocated to the District Program (for the Los Angeles County Flood Control
District to distribute funds, provide staff support, and oversee capacity building programs), 40% to the
Municipal Program, and 50% to the Regional Program.
The Municipal Program will provide cities with direct funding proportional to the revenues generated
within their boundaries. The Peninsula WMG may utilize these funds to finance the implementation of
the EWMP, including public LID projects and many of the other WCMs outlined in Section 3.
89 League of California Cities. (2014). Providing Sustainable Water Quality Funding in Los Angeles County. Prepared By City
Managers Working Group. Los Angeles County Division May 21, 2014.
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The Regional Program will allocate funds through nine Watershed Area Steering Committees (WASCs) into
the competitive Infrastructure, Technical Resources, and Scientific Studies Programs. Respectively, the
Infrastructure Program will provide funding for multi-benefit regional projects including design, permits,
CEQA compliance, grant-writing, right-of-way and land acquisition, construction, and long-term
operations and maintenance of projects; the Technical Resources Program will provide funding for the
development of project feasibility studies; and the Scientific Studies Program will provide funding for
scientific studies, technical studies, monitoring, modeling, and other similar activities. The Peninsula WMG
falls under the jurisdiction of the South Santa Monica Bay WASC.
With the implementation of the SCWP underway, the Peninsula WMG now have a reasonably dependable
revenue stream to offset, albeit only partially, the high costs of the multi-faceted strategy for the selection
and implementation of WCMs outlined in Section 3. The Peninsula WMG has coordinated the proposed
implementation schedule (outlined in Section 5) with the financial strategy outlined in this chapter.
However, uncertainties associated with future risks persist. For instance, there are multiple TMDLs in
multiple watersheds that must be addressed despite limited resources.
The Peninsula Agencies will set priorities to construct these facilities strategically, and in accordance with
the administrative and financial limitations and requirements of the SCWP framework, and seek
alternative outside funding in order to close funding gaps.
To address the Water Quality Priorities (WQPs), the Peninsula WMG is going to pursue a multi-faceted
financial strategy. In addition, the Peninsula WMG has coordinated the proposed implementation
schedule (see Section 5) with the financial strategy. The participating agencies are committed to
developing projects through the design phase so that they are shelf ready to take advantage of grants and
federal infrastructure funding that may become available. In collaboration with City of Torrance, the
Participating Agencies secured Prop 1 Stormwater Planning grant funding for the preliminary design and
feasibility study for the Torrance Airport Project and supported the subsequent application for SCW
Regional Program Infrastructure funding for design, which was approved and included in the South Santa
Monica Bay (SSMB) Watershed Area Steering Committee (WASC) FY 20-21 Stormwater Investment Plan
(SIP). The Torrance Airport Project has the potential to address the highest water quality priorities of the
Machado Lake Nutrient and Pesticides and PCBs TMDLs within the WD-1 WMA. The Peninsula WMG is
planning to submit the Torrance Airport Project to the SSMB WASC for construction funding by the FY2122
Call for Projects deadline. The participating agencies also received SCW Regional Program Technical
Resources funding to complete feasibility studies during FY2122 for the Palos Verdes Peninsula Multi-
Benefit Flow Diversion and during FY2021 for the Harbor City Park Regional projects for the WD-1 WMA.
The participating agencies also succeeded in securing SCW Technical Resources Program funding for the
Eastview Park Infiltration Project feasibility study as part of the SSMB WASC FY 20-21 SIP. The Eastview
Park Project will address priority pollutants under the Long Beach and Greater LA Harbor Toxics TMDLs
in the LAH-IH WMA.
The continued exploration and leveraging of additional sources of funding will be necessary to finance the
implementation of the WCMs. Notably, these may include Municipal Safe Clean Water Program funds and
other existing funding measures (such as Measures H, A, and M), various grant programs administered by
local, state and federal agencies, local fees such as inspection fees, and Clean Water State Revolving Fund
program financing agreements to the extent feasible.
Additionally, the Peninsula WMG will also support programs to increase water conservation, reduce dry
weather discharges to the storm drain system, and reduce TSS during wet weather. Successfully
accomplishing these efforts could reduce the money needed in the long term to capture and/or treat
stormwater discharges to comply with TMDLs and address other WQPs.
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In the long term, the challenge of financing the WCMs for the Peninsula WMG has partially been alleviated
with the passage of Measure W and the ongoing implementation of the SCWP, which have established a
reasonably dependable revenue stream for local water quality programs. Nonetheless, implementation
of the WMP will require the cooperation of many entities, including business, environmental
organizations, and the Regional Board.
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6.3.2. OTHER POTENTIAL FUNDING OPTIONS
The financial strategy to fund the EWMP requires the utilization of multiple funding options. The Peninsula
WMG will work together to maximize cost-effectiveness and each individual agency will be responsible
for seeking funding for its share in EWMP implementation. The sections below outline multiple
approaches to funding and allow each jurisdiction to consider and select the funding options that best fit
the specific preferences of their agency. For each funding option, a brief description is included that
includes benefits and challenges associated.
EDUCATION AND OUTREACH
The Peninsula WMG implements public outreach and engagement on a watershed-based level and at the
individual participating agency level. Projects proposed for SCW funding are reviewed by various
stakeholders: government, non-profit, and business and available for public review and comment at the
Watershed Advisory Steering Committee (WASC) level.
LEGISLATION
Legislative action has changed the face of contemporary stormwater management. This includes passage
of laws, adoption of regulations, and interpretation of laws and enforcement of regulations by the courts
at local, state and federal levels. These legislative activities impact all aspects of stormwater management
by local governments, as well as the private sector, such as developers who provide basic infrastructure
as a part of their developments, industrial facilities that discharge stormwater from their properties, and
those conducting ground disturbing construction activities. The Peninsula WMG will continue
participation in stormwater legislation advocacy efforts led by the League of California Cities and California
Contract Cities and California Stormwater Quality Association (CASQA). The challenges associated with
legislation include time and resources. Incorporating new legislation requires a significant amount of time
and political influence. Although these options have great potential, they will likely not be available in the
short term.
FEDERAL AND STATE GRANTS
Federal and State Grant programs are made available for agencies to receive funding for projects which
fall under the guidelines of the grant.
Factors considered in the financial strategy include the following:
• Matching Funds. Almost all grants include matching requirements, which can be up to 50% of the
total project costs. Additionally, grant development and administration can take up significant
resources, particularly from the small agencies associated with the Peninsula WMG.
• Shovel ready projects are typically preferred. Grant programs are generally structured to favor
projects that are “shovel ready”, while projects without substantially complete design plans are less
likely to be selected.
• Grants are competitive. Each grant program has a set allocation of funds that are available within a
defined region (i.e. statewide). As regulatory pressures are increased throughout California and the
United States, the competition for securing this type of funding will significantly increase.
• Project eligibility. Project eligibility is dependent on the grant program which may not support the
project type as needed.
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• Long-term O&M funding. In general, grants are structured to help fund project construction costs.
Separate funding streams for the operations and maintenance costs would be needed.
The Peninsula agencies are committed to pursuing and leveraging these opportunities with their SCW
Regional and Municipal funding as well as other local funding sources as they become available.
LOCAL FUNDING OPTIONS
The agencies may consider local funding options to address stormwater funding. Local funding options
would typically be pursued within individual agencies. Local funding options include:
• Safe Clean Water Municipal Program funds allocated as local return proportional to the revenues
generated within the municipality for activities such as project development, design, construction,
monitoring, and O&M;
• Revising street sweeping contracts to provide NPDES trash control programs;
• Adoption of water conservation fees to provide funding for reducing irrigated runoff to conserve
water and reduce dry weather discharges;
• Local, statewide, or regional fees on car rentals to contribute to copper and zinc clean-up costs and
incorporate stormwater quality features into street and highway projects funded by bonds and other
street funds;
• Increase in commercial facility inspection fees.
Local funding options may be considered in the financial strategy for short-term funding.
CLEAN WATER STATE REVOLVING FUND
The Clean Water State Revolving Fund (CWSRF) program is a federal-state partnership that provides low-
cost financing (at half of the most recent General Obligation Bond Rate at the time of funding approval –
1.6% in March 2015) with terms up to 30 years for a wide range of water quality infrastructure projects.
This fund is likely to be the vehicle for delivery of federal infrastructure funding to local projects once it
becomes available to states. The Peninsula WMG could use CWSRF for individual projects or groups of
projects as there is no maximum funding limit. The CWSRF can be used for a variety of projects including
stormwater measures to manage, reduce, treat, or recapture stormwater or subsurface drainage water;
water conservation, efficiency, and reuse; and watershed pilot projects meeting criteria in CWA §122.
TRANSPORTATION BONDS
Another consideration is future transportation bonds. This can be pursued by encouraging the
Metropolitan Transportation Authority (MTA) to include funding stormwater quality features, such as
Green Streets, in future bonds and encourage Council of Governments to develop strategic transportation
plans that include mitigations designed to address water quality issues from transportation projects.
RECOMMENDATIONS FOR THE REGIONAL WATER QUALITY CONTROL BOARD
The Regional Board should request funding for a staff position that would be responsible to identify and
distribute information on the available federal, state, non-profit, corporate and other sources of funds;
and establish an on-line resource center to assist the cities in complying with the stormwater permit
requirements.
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6.3.3. PRIORITIZATION
The Group continues to support programs to increase water conservation, reduce dry-weather discharges
to the storm drain system, and reduce TSS during wet weather. Successfully accomplishing these efforts
could reduce the funds needed in the long term to capture and/or treat stormwater discharges to comply
with TMDLs and address other WQPs.
The Peninsula WMG and/or the Participating Agencies will also pursue state grants (i.e. IRWMP,
Proposition 1, Proposition 84, etc.) and potential federal infrastructure funding to implement stormwater
BMPs.
In the long term, financing the WCMs for the Peninsula Watershed will require establishing dependable
revenue streams for local water quality programs with the cooperation of many entities, including
business and environmental organizations. Participating Agencies will begin utilizing existing funds to
implement the EWMP as well as pursue additional funding in accordance with Table 6-4 below.
Table 6-28: Funding Option Priorities
Agency Funding Priorities Integration with Existing
Infrastructure Improvement Plans
County
1. Federal and State Grants
2. Local Funding Options & Stormwater Fees (Measure W Safe
Clean Water Program)
3. Seek allocation in the General Fund; investigate bond and loan
opportunities (i.e. CWSRF)
4. Continued participation in stormwater funding advocacy efforts
led by the League of California Cities and California Contract
Cities and CASQA
• Incorporation of stormwater
improvements in capital improvement
plan for public facilities
• Design guidelines updated and
included green street standard plans
which include elements such as bio-
retention planters, porous pavement,
tree wells, etc.
LACFCD
1. Federal and State Grants
2. Local Funding Options & Stormwater Fees (Measure W Safe
Clean Water Program)
3. Seek allocation in the Flood Fund
• Incorporation of stormwater
improvements in capital improvement
plan for public facilities
•
RPV
PVE
RHE
RH
1. Federal and State Grants
2. Local Funding Options & Stormwater Fees (Measure W Safe
Clean Water Program)
3. Continued participation in stormwater funding advocacy efforts
led by the League of California Cities and California Contract
Cities and CASQA
• Incorporation of stormwater
improvements in capital improvement
plan for public facilities
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7. LEGAL AUTHORITY
This section covers information such as documentation and references/links to water quality ordinances
for each participating agency. These documents demonstrate adequate legal authority to implement and
enforce Watershed Control Measures (WCMs) identified in this plan and as required in the MS4 Permit.
The goal of these WCMs is to create an efficient program that focuses on the watershed priorities by
meeting the following objectives:
• Prevent or mitigate non-storm water discharges to the MS4 that are a source of pollutants from
the MS4 to receiving waters.
• Implement pollutant controls necessary to achieve all applicable interim and final water quality-
based effluent limitations and/or receiving water limitations pursuant to corresponding
compliance schedules.
• Ensure that discharges from the MS4 do not cause or contribute to exceedances of receiving water
limitations.
The WCMs include the minimum control measures, non-stormwater discharge measures and targeted
control measures (i.e. controls to address TMDL and 303(d) listings). As the requirement to incorporate
these WCMs is an element of the MS4 Permit, the legal authority to implement them results from each
agency’s legal authority to implement the NPDES MS4 Permit.
Table 7-1 includes the water quality ordinance for each agency with a reference link. Additionally, the
participating agencies have developed and adopted LID ordinances and Green Street Policies which
provides legal authority to enforce the Planning and Land Development Program.
Table 7-1: Water Quality Ordinance Language
City Water Quality Ordinance Reference
Rancho Palos
Verdes
Chapter 13.10 - STORM WATER AND URBAN RUNOFF
POLLUTION CONTROL
https://www.municode.com/library/ca/rancho_p
alos_verdes/codes/code_of_ordinances?nodeId=
TIT13PUSE_CH13.10STWAURRUPOCO
13.10.020 Purpose – This chapter is also intended to provide the city with the legal authority necessary to control discharges to and
from those portions of the municipal storm water system over which it has jurisdiction as required by the municipal NPDES permit.
Palos Verdes
Estates
Chapter 13.08 – STORM DRAINS AND STORM WATER
MANAGEMENT AND POLLUTION CONTROL
http://www.codepublishing.com/ca/palosverdes
estates/
13.08.Purpose and Intent– The purpose of this chapter is to protect and enhance the quality of surface waters and surface water
bodies, including the Santa Monica Bay and Machado Lake, in a manner consistent with the Federal Clean Water Act (33 U.S.C.
Sections 1251 et seq.), the California Porter-Cologne Water Quality Control Act (Cal. Water Code Sections 13000 et seq.), and the
municipal National Pollutant Discharge Elimination System (NPDES) permit.
Rolling Hills Chapter 8.32 - Storm Water Management and Pollution
Control
https://library.municode.com/ca/rolling_hills/cod
es/code_of_ordinances?nodeId=TIT8HESA_CH8.3
2STWAMAPOCO
8.32.030 - Purpose and intent.
A. The purpose of this chapter is to comply with the Federal Clean Water Act, the California Porter-Cologne Water Quality
Control Act, and the Municipal NPDES Permit by:
1. Reducing pollutants in storm water discharge to the maximum extent practicable;
2. Regulating illicit connections and illicit discharges and thereby reducing the level of contamination of storm water and
dry weather runoff into receiving waters; and
3. Regulating non-storm water discharges to the storm sewer system.
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Rolling Hills
Estates
Chapter 8.38 - STORMWATER AND URBAN RUNOFF
POLLUTION CONTROL
https://library.municode.com/ca/rolling_hills_est
ates/codes/code_of_ordinances?nodeId=TIT8HES
A_CH8.38STURRUPOCO
8.38.030 Construction and Application – This chapter will be construed to assure consistency with the requirements of the Clean Water
Act and the Porter-Cologne Water Quality Control Act, and their implementing regulations, and the municipal NPDES permit.
LACFCD Flood Control District Code, Chapter 21 - Stormwater and
Runoff Pollution Control
https://library.municode.com/HTML/16274/level
2/FLCODICO_CH21STRUPOCO.html#FLCODICO_C
H21STRUPOCO_21.01PUIN
21.01 - Purpose and Intent - The purpose and intent of this chapter is to regulate the stormwater and non-stormwater discharges to
the facilities of the Los Angeles County Flood Control District for the protection of those facilities, the water quality of the waters in and
downstream of those facilities, and the quality of the water that is being stored in water-bearing zones underground.
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8. COORDINATED INTEGRATED MONITORING PROGRAM
The Participating Agencies implement a customized Coordinated Integrated Monitoring Program (CIMP)
based on the provisions set forth in Attachment E of the MS4 Permit. The data collected by the CIMP are
used to assess the effectiveness of the EWMP projects and programs in addressing water quality priorities,
specifically in achieving water quality-based effluent limitations (WQBELs) and receiving water limitations
(RWLs) per compliance schedules. The customized CIMP includes the following program elements:
• Receiving Water Monitoring
• Storm Water Outfall Monitoring
• Non-Storm Water Outfall Monitoring
• Regional Studies
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9. ADAPTIVE MANAGEMENT PROCESS
Adaptive management is the process by which new information about the state of the watershed is
incorporated into the EWMP.
Following the previous 2018 and 2020 Adaptive Management processes, the Peninsula WMG is required
to submit an updated EWMP and Reasonable Assurance Analysis (RAA) by June 30, 2021 for review and
approval by the Regional Board. The updated RAA detailed in Appendix 4.1, utilizes all relevant, available
data, including updates to the water body pollutant combination prioritization, source assessment, TMDL
milestone achievements, and control measure performance data. As further elaborated in the updated
EWMP (Section 2, Section 3, RAA Report in Appendix 4.1, etc.), the EWMP is adaptively managed following
the process described in the MS4 Permit.
The process is implemented by the participating agencies and submitted to the Regional Water Board for
review and approval as required by the MS4 Permit and as deemed appropriate. The purpose of the
adaptive management process is to improve the effectiveness of the EWMP based on – but not limited to
– consideration of the following:
1. Progress toward achieving interim and/or final water quality-based effluent limitations and/or
receiving water limitations in §VI.E and Attachments L through R of the MS4 Permit, according to
established schedules;
2. Progress toward achieving improved water quality in MS4 discharges and achieving receiving
water limitations through implementation of the watershed control measures based on an
evaluation of outfall-based monitoring data and receiving water monitoring data;
3. Achievement of interim milestones;
4. Reopening of TMDLs;
5. Re-evaluation of the water quality priorities identified for the Watershed Management Area
(WMA) based on more recent water quality data for discharges from the MS4 and the receiving
water(s) and a reassessment of sources of pollutants in MS4 discharges;
6. Availability of new information and data from sources other than the MS4 Permittees’ monitoring
program(s) within the WMA that informs the effectiveness of the actions implemented by the
Permittees;
7. Regional Water Board recommendations; and
8. Recommendations for modifications to the Enhanced Watershed Management Program solicited
through a public participation process.
9.1. MODIFICATIONS
Based on the results of the adaptive management process, the participating agencies may find that
modifications of the EWMP are necessary to improve effectiveness. Modifications may include new
deadlines and interim milestones, with the exception of those deadlines established in a TMDL.
9.1.1. REPORTING
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Modifications are reported in the Annual Report and as part of the Report of Waste Discharge (ROWD)
required pursuant to the MS4 Permit. The background and rational for these modifications are included
by addressing the following points:
• Identify the most effective control measures and describe why the measures were effective and
how other control measures will be optimized based on past experiences.
• Identify the least effective control measures and describe why the measures were deemed
ineffective and how the control measures will be modified or terminated.
• Identify significant changes to control measures during the prior year and the rationale for the
changes.
• Describe all significant changes to control measures anticipated to be made in the next year and
the rationale for the changes. Those changes requiring approval of the Regional Water Board or
its Executive Officer shall be clearly identified at the beginning of the Annual Report.
• Include a detailed description of control measures to be applied to New Development or Re-
development projects disturbing more than 50 acres.
• Provide the status of all multi-year efforts that were not completed in the current year and will
continue into the subsequent year(s).
• Provide the status of multi-year/future regional BMPs, both planned and proposed.
• Provide the status of efforts to secure funding for structural TCMs both for capital investments
and O&M.
9.1.2. IMPLEMENTATION
Modifications are implemented upon approval by the Regional Water Board Executive Officer or within
60 days of submittal if the Regional Water Board Executive Officer expresses no objections.
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9.2. RECEIVING WATER LIMITATIONS
The adaptive management process fulfills the requirements in MS4 Permit to address continuing
exceedances of receiving water limitations.
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10. REPORTING PROGRAM & ASSESSMENT
The reporting information provided below is based on the requirements of the MS4 Permit. These
implementation reports and monitoring reports allow the Regional Board to assess implementation
progress and program effectiveness.
10.1. ANNUAL REPORT
Each year as directed by the MS4 Permit, all Permittees are required to submit an Individual Annual
Report. Each year the participating agencies in the Peninsula EWMP will also submit a joint Watershed
Annual Report to the Regional Water Board Executive Officer. The Watershed Annual Report will present
a summary of information that will allow the Regional Board to assess implementation progress and
effectiveness of the watershed management program 90.
The reporting process is intended to meet the following objectives to assess:
• Each agency's participation in the Enhanced Watershed Management Program and Coordinated
Integrated Monitoring Program.
• The impact of each agency's storm water and non-storm water discharges on the receiving
water.
• Monitoring results in comparison to receiving water limitations, numeric water quality-based
effluent limitations, and non-storm water action levels.
• The effectiveness of control measures in reducing discharges of pollutants from the MS4 to
receiving waters.
• Whether the quality of MS4 discharges and the health of receiving waters is improving, staying
the same, or declining as a result watershed management program efforts, and/or TMDL
implementation measures, or other Minimum Control Measures.
• Whether changes in water quality can be attributed to pollutant controls imposed on new
development, re-development, or retrofit projects.
The Annual Report will identify data collected and strategies, control measures and assessments
implemented for each watershed within the participating agency's jurisdiction. The participating agencies
will submit annual reports as required by the MS4 Permit.
90 Annual reports will cover summary from previous fiscal year beginning July 1st through June 30th of the following year.
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10.2. MONITORING REPORT
10.2.1. DATA REPORTING
Analytical data reports will be submitted on a semi-annual basis, or as directed by the MS4 Permit. CEDEN-
formatted data will be sent electronically to the Regional Water Board's Storm Water site at
MS4stormwaterRB4@waterboards.ca.gov. These data reports will summarize:
• Exceedances of applicable WQBELs, receiving water limitations, or any available interim action
levels or other aquatic toxicity thresholds.
• Basic information regarding sampling dates, locations, or other pertinent documentation.
• The annual watershed monitoring report will summarize efforts to address water quality
exceedances.
10.2.2. CHRONIC TOXICITY REPORTING
Aquatic toxicity monitoring results will be submitted to the Regional Board on an annual basis as part of
the watershed and monitoring report as well as in the semi-annual basis data report submittal.
10.2.3. TMDL REPORTING
The participating agencies will also report on progress of TMDL implementation on an annual basis as part
of the watershed and monitoring report and submit to the Regional Water Board Executive Officer.
195
Appendix 1.0
LA County Flood Control District Summary
196
HOA.1069965.1
In 1915, the Los Angeles County Flood Control Act established the LACFCD and
empowered it to manage flood risk and conserve stormwater for groundwater recharge. In
coordination with the United States Army Corps of Engineers the LACFCD developed and
constructed a comprehensive system that provides for the regulation and control of flood
waters through the use of reservoirs and flood channels. The system also controls debris,
collects surface storm water from streets, and replenishes groundwater with storm water and
imported and recycled waters. The LACFCD covers the 2,753 square-mile portion of Los
Angeles County south of the east-west projection of Avenue S, excluding Catalina Island. It
is a special district governed by the County of Los Angeles Board of Supervisors, and its
functions are carried out by the Los Angeles County Department of Public Works. The
LACFCD service area is shown in Figure 1.A -1.
Unlike cities and counties, the LACFCD does not own or operate any municipal sanitary
sewer systems, public streets, roads, or highways. The LACFCD operates and maintains
storm drains and other appurtenant drainage infrastructure within its service area. The
LACFCD has no planning, zoning, development permitting, or other land use authority
within its service area. The permittees that have such land use authority are responsible
under the Permit for inspecting and controlling pollutants from industrial and commercial
facilities, development projects, and development construction sites. (Permit, Part II.E, p.
17.)
The MS4 Permit language clarifies the unique role of the LACFCD in storm water
management programs: “[g]iven the LACFCD’s limited land use authority, it is appropriate
for the LACFCD to have a separate and uniquely-tailored storm water management
program. Accordingly, the storm water management program minimum control measures
imposed on the LACFCD in Part VI.D of this Order differ in some ways from the minimum
control measures imposed on other Permittees. Namely, aside from its own properties and
facilities, the LACFCD is not subject to the Industrial/Commercial Facilities Program, the
Planning and Land Development Program, and the Development Construction Program.
However, as a discharger of storm and non-storm water, the LACFCD remains subject to the
Public Information and Participation Program and the Illicit Connections and Illicit
Discharges Elimination Program. Further, as the owner and operator of certain properties,
facilities and infrastructure, the LACFCD remains subject to requirements of a Public
Agency Activities Program.”
(Permit, Part II.F, p. 18.)
Consistent with the role and responsibilities of the LACFCD under the Permit, the EWMPs
and CIMPs reflect the opportunities that are available for the LACFCD to collaborate with
permittees having land use authority over the subject watershed area. In some instances, the
opportunities are minimal, however the LACFCD remains responsible for compliance with
certain aspects of the MS4 permit as discussed above.
In some instances, in recognition of the increased efficiency of implementing certain programs
regionally, the LACFCD has committed to responsibilities above and beyond its obligations
under the 2012 Permit. For example, although under the 2012 Permit the Public Info rmation and
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HOA.1069965.1
Participation Program is a responsibility of each Permittee, the LACFCD is committed to
implementing certain regional elements of the PIPP on behalf of all Permittees at no cost to the
Permittees. These regional elements include:
Maintaining a countywide hotline (888-CLEAN-LA) and website (www.888cleanla.com)
for public reporting and general stormwater management information at an estimated
annual cost of $250,000. Each Permittee can utilize this hotline and website for public
reporting within its jurisdiction.
Broadcasting public service announcements and conducting regional advertising
campaigns at an estimated annual cost of $750000.
Facilitating the dissemination of public education and activity specific stormwater
pollution prevention materials at an estimated annual cost of $100,000.
Maintaining a stormwater website at an estimated annual cost of $10,000.
The LACFCD will implement these elements on behalf of all Permittees starting July 2015 and
through the Permit term. With the LACFCD handling these elements regionally, Permittees can
better focus on implementing local or watershed-specific programs, including student education
and community events, to fully satisfy the PIPP requirements of the 2012 Permit.
Similarly, although water quality monitoring is a responsibility of each Permittee under the 2012
Permit, the LACFCD is committed to implement certain regional elements of the monitoring
program. Specifically, the LACFCD will continue to conduct monitoring at the seven existing
mass emissions stations required under the previous Permit. The LACFCD will also participate
in the Southern California Stormwater Monitoring Coalition’s Regional Bioassessment Program
on behalf of all Permittees. By taking on these additional responsibilities, the LACFCD wishes
to increase the efficiency and effectiveness of these programs.
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HOA.1069965.1
Figure 1.A-1 Los Angeles County Flood Control District Service Area
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HOA.1069965.1
Figure 1.A-2 Los Angeles County Flood Control District Areas in Peninsula WMG
200
Appendix 3.1
Nonstructural Targeted Control Measures
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3.1 NONSTRUCTURAL TARGETED CONTROL MEASURES
Table 3.1-1 lists implemented enhanced nonstructural TCMs for each participating agency. The BMP
effectiveness from 4 is based on similar BMPs listed in Tetra Tech’s CLRP for Chollas Creek Watershed in
San Diego County, 2012.
The responses for each agency under Table 3-3 are defined as follows:
R Regulatory TCM. The TCM is to be implemented through legislative measures that have the
support of the Peninsula WMG.
C Completed TCM. The TCM is preexisting (has been in effect for several years or more).
Table 3.1-2 lists the anticipated pollutants to be addressed through each Nonstructural TCM. The pages
following Table 3-4 describe each of the listed controls. It is important to note that the LACFCD are
operating regional stormwater programs and consequently incorporating localized institutional TCMs
may not be feasible. As such their exclusion from such TCMs is justified.
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Table 3.1-1: Enhanced Nonstructural Targeted Control Measures (TCMs)
Targeted Control Measure
BMP effectiveness with respect to
WQPs 1
Agency
Priority
Pollutant
Reduction
Sediment
reduction
Volume or
flow
reduction
LACFCD County
Unincorporated
Palos
Verdes
Estates
Rancho
Palos
Verdes
Rolling
Hills
Rolling
Hills
Estates
Planning and Land Development
LID and Green Streets Staff Training ❑ ❑ ❑ N/A C C C C C
Industrial/Commercial Facilities
Restaurant Certification Program ◆ ◇ ❑ N/A C C NA C
Dry weather runoff reduction
Irrigation Reduction Incentives Program ◆ ◆ ◆ N/A C C C C C
Public Information and Participation
Downspout Disconnect Program ❑ ❑ ◆ N/A C C C C C
Targeted Outreach ◆ ◆ ◆ C C C C C C
Horse Manure Management ◆ ◇ ◇ N/A C N/A C C C
Public Agency Activities
Enhanced Street Sweeping ◆ ◆ ◇ N/A C C C NA C
Adopt Sewer System Management Plan (SSMP) ◆ ◇ ◇ N/A C C C NA C
Increased Street Sweeping Frequency or Routes ◆ ◆ ◇ N/A C NA C
Jurisdictional SW Management
Prepare guidance documents to aid in implementation
of MS4 Permit MCMs ❑ ❑ ❑ C C C C C
Regulatory Initiatives
Brake Pad Replacement Program ◆ ◆ ◇ R R R R R R
Lead Reduction Program ◆ ◆ ◇ R R R R R R
Zinc Reduction Program ◆ ◆ ◇ Watershed Group
Apply for grant funding for stormwater projects
(Measure W Safe Clean Water Program) ◆ ◆ ◆ C C C C NA C
Ordinances
Water Efficient Landscaping ◆ ◇ ◆ N/A C C C C C
Green Building Ordinance ◆ ❑ ❑ N/A C
Enhanced Irrigation Runoff Reduction Program ◆ ❑ ◆ N/A C C C C C
Adoption of LA County Fire Code ◆ ◆ ◆ C C C C C C
✗– Planned TCM P – Potential TCM C – Completed/Implemented TCM R - Regulatory TCM
◆ Primary pollutant reduction ❑ Secondary pollutant reduction ◇ Pollutant not addressed
1 BMP effectiveness ratings based on similar BMPs listed in Tetra Tech’s CLRP for Chollas Creek Watershed in San Diego County, 2012.
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Table 3.1-2: Anticipated Pollutants to be addressed through Enhanced Nonstructural TCMs
Targeted Control Measure
Category 1 Category 2
SMB
Trash
SMB DDT
& PCBs ML Trash
ML Pesticides &
PCBs
(Chlordane, DDT,
Dieldrin, and
PCBs)
ML Nutrients
(Total Nitrogen
and Total
Phosphorus)
Harbor Toxics
(Copper, DDT,
Lead, PAHs,
PCBs, and Zinc)
SMB
Beaches
Indicator
Bacteria
SMB
Arsenic
SMB
Mercury
Wilmington
Drain
E. coli
Restaurant Certification
Program √ √ √ √ √ √ √
Rainwater Harvesting
Program √ √ √ √ √ √ √
Irrigation Reduction
Incentives Program √ √ √ √ √ √ √ √
Targeted Outreach √ √ √ √ √ √ √ √ √ √
Horse Manure Management √ √ √
Enhanced Street Sweeping √ √ √ √ √ √ √ √ √
Adopt Sewer System
Management Plan √ √ √ √ √
Increased Street Sweeping
Frequency or Routes √ √ √ √ √ √ √ √ √ √
Wildfire Prevention
Program √ √ √ √ √ √
Prepare Guidance
Documents √ √ √ √ √ √ √ √ √ √
Brake Pad Replacement
Program √
Lead Reduction Program √
Zinc Reduction Program √
Apply for Grant Funding
(SCW Regional and
Municipal Program)
√ √ √ √ √ √
√
√ √ √
Water Efficient Landscaping √ √ √ √ √ √ √ √
Green Building Ordinance √ √ √ √ √ √ √ √ √ √
Enhanced Irrigation Runoff
Reduction Program √ √ √ √ √ √ √ √
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INDUSTRIAL/COMMERCIAL FACILITIES
RESTAURANT CERTIFICATION PROGRAM
The Restaurant Certification Program educates restaurants on restaurant best management practices,
including proper disposal of wastes and spill prevention. This program enhances the Commercial MCMs
by implementing an annual program of restaurant inspections. Additionally, through promotion of green
business or ocean-friendly certification programs, agencies encourage restaurants to go above and
beyond local stormwater regulations to help prevent pollution.
The program is currently being implemented by the City of Rancho Palos Verdes, Palos Verdes Estates,
and Rolling Hills Estates.
DRY WEATHER RUNOFF REDUCTION
IRRIGATION REDUCTION INCENTIVES PROGRAM
This measure will provide incentives such as rebates for irrigation reduction (i.e. runoff reduction)
practices such as xeriscaping and turf conversion. All agencies are currently involved in this effort through
the West Basin Municipal Water District rebate incentives program and promotion by the South Bay Cities
Council of Governments Environmental Services Center.
ENHANCED IRRIGATION RUNOFF REDUCTION PROGRAM
Reductions to irrigation runoff help to achieve runoff volume reduction and associated pollutant load
reductions. This BMP, which doubles as a water conservation initiative, incorporates good landscaping
practices to limit irrigation runoff. Measures to reduce irrigation runoff can be implemented wherever
landscapes are irrigated. Residential, commercial, recreational, and industrial land uses can be targeted
by incentive policies and programs. The Peninsula WMG agencies already implement Water Efficient
Landscaping ordinances. Additional implementation methods being implemented include:
• Municipal Landscape Retrofits converting municipal landscaping to drought tolerant, low
irrigation landscaping
• Landscape Irrigation Efficiency Program for large landscape residential water users
• Weather-based irrigation controller exchange events through West Basin Municipal Water
District
• Turf Conversion Programs implemented through West Basin Municipal Water District to
encourage the conversion of lawns and gardens to drought tolerant, low irrigation landscaping
• California Friendly Landscape Workshops through West Basin Municipal Water district and South
Bay Environmental Services Center
• Rain barrel distribution through South Bay Environmental Services Center
The County of LA and the cities of Palos Verdes Estates, Rancho Palos Verdes, Rolling Hills, and Rolling Hills
Estates are currently implementing this program.
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PUBLIC INFORMATION AND PARTICIPATION
DOWNSPOUT DISCONNECT PROGRAM
This Program encourages homeowners to redirect their downspouts to a rain garden or rain barrel
program. This program is currently being implemented for the Peninsula WMG through the West Basin
Municipal Water District and through the South Bay Cities Council of Governments website and direct
outreach by individual agencies.
TARGETED OUTREACH
Within the Public Information and Education Program, targeted activity-specific residential outreach is
conducted to address watershed priorities. This targeted outreach effort is focused on residential do-it-
yourself (DIY) auto, home improvement, and gardening activities and pet owner activities and is
implemented through the promotion of successful existing workshops and programs and the
development and dissemination of dual print/electronic outreach pieces targeted at residential activities
for which City staff have identified a clear need. The Permittees will adapt the PIPP over time to address
new information, water quality priorities and stormwater management program priorities – activities
listed below provide examples of how the PIPP is currently being enhanced. The targeted residential
outreach includes:
• Promotion of the CalRecycle Used Oil Collection and Filter Recycling Program
• Promotion of sustainable landscaping, gardening and water efficiency programs offered through
West Basin Municipal Water District
• Waste management and recycling outreach
• Promotion/hosting of household hazardous waste collection events
• Development and distribution of outreach pieces including a dual print/digital mobile business tip
card, small site construction brochure, and a print brochure showcasing Native and Drought
Tolerant Plant Gardens and Landscapes on the Palos Verdes Peninsula
• Maintenance and promotion of Environmentally Friendly Landscaping, Gardening and Integrated
Pest Management outreach webpages
• Maintenance of California-friendly demonstration gardens throughout the Peninsula
• Maintenance of pet waste stations in municipal parks
• Development and distribution of South Bay Homeowners Guide to Rainwater Harvesting
• Dissemination of Wildfire Prevention materials from CalFire
HORSE MANURE MANAGEMENT
Where residential horse keeping is allowed, the Peninsula WMG agencies implement and enforce Horse
Manure Management ordinances requiring the proper handling and disposal of horse manure to prevent
its accumulation, runoff, or leaching. Peninsula WMG agencies that allow residential horse keeping also
provide manure collection services through the solid waste contract. Additionally, public outreach
materials describing stormwater BMPs for horse keeping are targeted to horse owners and equestrian
businesses throughout the Peninsula. These efforts work to address pollutants generated from existing
equestrian facilities which are a recognized source of nutrients. In Rolling Hills Estates, the completed
Model Equestrian Center Project at the Peter Weber Equestrian Center (PWEC) serves an educational
function in addition to the water quality improvements realized through retrofits to the facility.
Interpretive signage throughout the PWEC identifies horse keeping BMPs for owners of horses boarded
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at the facility, horse trainers, and children who attend pony camps at the facility (as well as their parents).
Pony camp materials used at the facility include worksheets on environmentally friendly horse keeping
practices.
PUBLIC AGENCY ACTIVITIES
ENHANCED STREET SWEEPING
Improved street and median sweeping technology enhances the potential for wet weather pollutant load
reductions for bacteria, metals, non-metal toxics, and nutrients. Increasing the sweeping frequency,
increasing the area of impervious cover swept, or upgrading the sweeping equipment can result in an
increase in pollutant load removal2. Most of the Peninsula Agencies contract street sweeping to private
companies. These companies have already phased in regenerative sweepers.
Regenerative air sweepers have the ability to clean a larger path than vacuum sweepers, can remove
smaller debris more efficiently and release less exhaust and particulates back into the environment.
Generally speaking, regenerative air systems are more environmentally friendly than are vacuum
sweepers. Regenerative air sweepers are similar to vacuum sweepers in that there is a suction tube
located on one side of the sweeping head. However, the key difference between regenerative and vacuum
sweepers is that, unlike vacuum sweepers which exhaust the particulate-laden used air back into the
atmosphere, regenerative air sweepers work on a closed loop system. In most applications, they also are
a better choice than are vacuum sweepers. As the regenerative air sweepers circulate the air on a
continuous basis. 3
The cities of Palos Verdes Estates and Rancho Palos Verdes implement this Program. Additionally, the
County of Los Angeles has incorporated regenerative sweepers in its street cleaning program.
ADOPT SEWER SYSTEM MANAGEMENT PLAN (SSMP)
All agencies are enrolled in the statewide Waste Discharge Requirements for Sanitary Sewer Systems,
which required the development and implementation of a SSMP in mid-2009. The goal of the SSMP is to
reduce and prevent sanitary sewer overflows (SSOs), as well as mitigate any SSOs that do occur. This goal
also addresses WQPs. Elements of the SSMP include:
• Sanitary sewer system operation and maintenance program
• Design and performance provisions
• Overflow emergency response plan
• FOG Control Program
• System Evaluation and Capacity Assurance Plan
INCREASED STREET SWEEPING FREQUENCY OR ROUTES
This measure works to increase the street sweeping frequency, jurisdiction-wide or in high trash-
generating areas and/or include additional routes (e.g. center medians and intersections).
2 City of San Diego: San Diego River Watershed Comprehensive Load Reduction Plan – Appendix A: BMP Representation Summary
(2012)
3 An Overview of Power Sweeping Equipment Technology (www.worldsweeper.com)
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REGULATORY INITIATIVES
BRAKE PAD REPLACEMENT PROGRAM
Efforts of the California Stormwater Quality Association (CASQA) and Sustainable Conservation led to the
passage of the SB 346 legislation in 2010 and signed by the Governor on September 25, 2010. This
legislation is a milestone that will significantly reduce the level of copper in metropolitan area waters
throughout the state. SB 346 requires incremental reduction in the amount of copper in vehicle brake
pads, which constitute the single largest source of copper in metropolitan environments 4. Already in
effect, new codes required on brake pads sold in California will provide information on copper content
and a notice that on and after January 1, 2014 any motor vehicle brake friction materials sold in California
must contain no more than 0.1 percent by weight of the following materials: cadmium and its compounds,
chromium (VI) salts, lead and its compounds, mercury and its compounds, and asbestiform fibers.
According to industry data on brake pad copper content, “SB 346 should reduce annual statewide copper
emissions by more than 1.2 million pounds per year and should reduce brake pad copper levels by about
95%”5. Additionally, based on available information, which was largely developed through a lengthy
collaboration among brake pad manufacturers, government agencies, and environmental groups in the
Brake Pad Partnership, a preliminary estimate of copper runoff reduction due to this piece of legislation
was developed.
In 2013, TDC Environmental prepared a draft detailed study for the California Stormwater Quality
Association (CASQA) describing the expected percent reduction for copper as a result of the passage of
SB 346 (TDC Environmental, 2013). The TDC study identified three possible implementation scenarios, the
least aggressive of which estimated that a 52% load reduction in copper will be achieved by 2032 due to
the brake pad phase-out.
Although there is an expectation that copper loads in urban runoff will decrease over time as a result of
SB 346, the updated RAA did not attempt to take credit for this load reduction at this time. Following the
collection of additional watershed-specific water quality data in the future, adaptive management may
be utilized by the Peninsula WMG to update the TLR for copper and/or the load reductions expected to
be achieved by this source control program.
LEAD REDUCTION PROGRAM
The SB 346 legislation was passed by the Senate, approved by the Governor, and filed with the Secretary
of State on October 11, 2010. This bill prohibits the manufacture, sale, or installation in California of a
wheel weight that contains more than 0.1% lead. Additionally, this bill requires that if the department
identifies an alternative to lead contained in wheel weights as a chemical of concern, then the lead
alternative would remain subject to the evaluation process, as prescribed, to determine how best to
limit exposure or to reduce the level of hazard posed by the lead alternative.
Through the implementation of SB 757, a reduction in lead will be observed for the Peninsula WMG.
ZINC REDUCTION PROGRAM
The Department of Toxic Substances Control (DTSC) adopted new Safer Consumer Product Regulations
that became effective October 1, 2013. These regulations contain a process for identifying and prioritizing
Chemicals of Concern in Priority Products containing these constituents, as well as a process for
eliminating or reducing the adverse impacts of Chemicals of Concern in Priority Products. It will apply to
4 Moran, Kelly. 2011. Brake Pad Copper Reduction – MRP Section C.13.c. Report 2011
5 Ibid.
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most consumer products placed into the stream of commerce in California. It specifically applies to
adverse environmental impacts, including adverse water quality impacts, and it contains a petition
process for identification and prioritization of chemicals and projects. CASQA, supported by Peninsula
WMG, has started the process of conducting research and building a file of critical information to support
the designation of zinc in tires as a future priority product/constituent combination.
Measures:
• As a watershed group, plan to work with others to use the Department of Toxic Substances
Control’s Safer Consumer Product Regulations to reduce the zinc in tires, which is one of the
greatest sources of zinc in urban areas.
ORDINANCES
WATER EFFICIENT LANDSCAPING ORDINANCE
The Peninsula WMG agencies implement and enforce water efficient landscaping ordinances to promote
the design, installation, and maintenance of landscaping in a manner that conserves water resource and
minimizes irrigation water runoff.
Additionally, the Peninsula Agencies jointly developed and have been distributing a tri-fold color brochure
promoting Native & Drought Tolerant Plant Gardens and Landscapes on the Palos Verdes Peninsula. This
brochure was developed with input from the Palos Verdes Peninsula Land Conservancy, Los Angeles
County Fire Department and South Coast Botanic Garden staff.
GREEN BUILDING ORDINANCE
The City of Rancho Palos Verdes, the largest of the Peninsula WMG agencies, implements a Green Building
Construction ordinance, effective January 1, 2014, that establishes incentives such as expedited plan
review and fee reductions, and outlines procedures for participation in the agency’s voluntary green
building program. This program encourages the design and development of single-family, multifamily
residential, commercial, institutional and mixed-use projects that are sited, designed, constructed and
operated to enhance the well-being of occupants, and to minimize negative impacts on the community
and natural environment. In addition, all of the Peninsula WMG agencies have adopted or customized the
2010 California Green Building Standards Code.
The Green Building Ordnance is based on a point system in which a developer earns points for
incorporating certain aspects of the program into their design. Some of the specific stormwater quality
aspects of this program are identified below in Table 3.1-3
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Table 3.1-3: Green Building Ordinance Program Stormwater Quality Aspects
Category Stormwater Benefit
Stormwater Control:
• Permeable Paving Material
• Filtration and/or Bio-Retention Features
• Non-Leaching Roofing Materials
• Smart Stormwater Street Design
• Rainwater Harvesting System
• Vegetated Roof
Encourages incorporation of stormwater BMPs which
directly benefits stormwater quality
Irrigation Control:
• Plants Grouped by Water Needs
• Resource Efficient Landscapes
• High-Efficiency Irrigation System
Reduces irrigation demand which subsequently
reduces dry weather flows
Impervious Area Reduction:
• Construction Footprint
• Minimal Turf in Landscape
• Trees
Reduces impervious areas which subsequently
reduces stormwater runoff
Non-toxic Materials Reduces exposed toxic materials during and after
construction
Vandalism Deterrence Practices and
Vandalism Management Plan
Reduces the potential for vandalism which
subsequently reduces the potential for exposed
contaminants associated with vandalism (i.e. spray
paint, trash, etc.)
Pedestrian, bicycle, and public transit access
Reduces vehicle use which subsequently reduces
pollutants associated with vehicles (i.e. organics, oil,
grease, metals, etc.)
Structural Pest Controls
Reduces likeliness of needing pest-control which
subsequently reduces potential for related
contaminants to be exposed to stormwater
Green Building Education Increases environmental awareness including
stormwater quality
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WILDFIRE PREVENTION PROGRAM
There is a substantial body of research demonstrating that wildfires can be a significant source of
pollutants in stormwater while also increasing stormwater runoff from burned areas. Consequently, the
prevention of wildfires is an important control measure for preventing mobilization and increased
discharge of pollutants in stormwater. The agencies have adopted the most recent fire standards in Title
32 of the Los Angeles County Code (Fire Code). These include more restrictive building standards relating
to fire and public safety than those adopted by the State Fire Marshal in the California Building Code.
Because the Palos Verdes Peninsula is a very high fire hazard severity zone, CalFire encourages risk
reduction through reduction of fire fuel, especially on properties adjacent to natural open space. The
agencies offer green waste collection to residents through their solid waste franchise contracts to
encourage the prompt removal of accumulated leaves and landscape debris to prevent brush fires which
also minimizes the potential for leaching of nutrients from accumulated dead vegetation. The agencies
disseminate information to residents on the management of landscapes for brush and fire control.
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Appendix 3.2
Structural Best Management Practices (BMPs)
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3.2 STRUCTURAL BMP SUBCATEGORIES
Structural BMPs fall under a variety of subcategories that correspond to their function and water quality
benefit. Some of the most common of these subcategories are described below. These subcategories will
be used throughout the EWMP to describe existing, planned, and potential regional and distributed BMPs.
INFILTRATION BMPS
Infiltration BMPs allow for stormwater to percolate through the native soils and recharge the underlying
groundwater table, subsequently decreasing the volume of water discharged to the downstream
waterbodies. These BMPs must be constructed in areas where the native soils have percolation rates and
groundwater levels appropriate for infiltration.
INFILTRATION BASIN
An infiltration basin consists of an earthen basin with a flat bottom. An infiltration basin retains
stormwater runoff in the basin and allows the retained runoff to percolate into the underlying soils.
The bottom of an infiltration basin is typically vegetated with dryland grasses or irrigated turf grass.
INFILTRATION TRENCH
An infiltration trench is a long, narrow, rock-filled trench with no outlet other than for overflow.
Runoff is stored in the void space between stones and infiltrates through the bottom and sides of the
trench. Infiltration trenches provide the majority of their pollutant removal benefits through volume
reduction. Pretreatment is important for limiting amounts of coarse sediment entering the trench
which can clog and render the trench ineffective.
INFILTRATION GALLERY
An infiltration gallery may consist of a modular, multi-chamber pre-cast concrete arch system usually
installed below grade. An infiltration gallery retains stormwater runoff in the basin and allows the
retained runoff to percolate into the underlying soils.
BIORETENTION WITH NO UNDERDRAIN
Bioretention facilities with no underdrain are landscaped shallow depressions that capture and
infiltrate stormwater runoff. These facilities function as a soil and plant-based filtration device that
removes pollutants through a variety of physical, biological, and chemical treatment processes. The
facilities normally consist of a ponding area, mulch layer, engineered media, and vegetation. As
stormwater passes down through the media, pollutants are filtered, adsorbed, and biodegraded by
the soil and vegetation.
DRYWELL
Drywells are similar to infiltration trenches in their design and function; however, drywells generally
have a greater depth to footprint area ratio and can be installed at relatively deep depths. A drywell
is a subsurface storage facility designed to temporarily store and infiltrate runoff. A drywell may be
either a small excavated pit filled with aggregate or a prefabricated storage chamber or pipe segment.
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P OROUS PAVEMENT
Porous pavements (concrete, asphalt, and pavers) contain small voids that allow water to pass
through to a gravel base. They come in a variety of forms; they may be a modular paving system
(concrete pavers, grass-pave, or gravel-pave) or poured in place pavement (porous concrete,
permeable asphalt). Porous pavements treat stormwater and remove sediments and metals within
the pavement pore space and gravel base. While conventional pavement results in increased rates
and volumes of surface runoff, properly constructed and maintained porous pavements allow
stormwater to percolate through the pavement and enter the soil below. This facilitates groundwater
recharge while providing the structural and functional features needed for the roadway, parking lot,
or sidewalk. The paving surface, subgrade, and installation requirements of porous pavements are
more complex than those for conventional asphalt or concrete surfaces.
BIOTREATMENT BMPS
Biotreatment BMPs treat stormwater through a variety of physical, chemical, and biological processes
prior to being discharged to the MS4 system. These BMPs should be considered where Infiltration BMPs
are infeasible.
BIORETENTION WITH UNDERDRAINS
Bioretention stormwater treatment facilities are landscaped shallow depressions that capture and
filter stormwater runoff. These facilities function as a soil and plant-based filtration device that
removes pollutants through a variety of physical, biological, and chemical treatment processes. The
facilities normally consist of a ponding area, mulch layer, engineered media, and vegetation. As
stormwater passes down through the media, pollutants are filtered, adsorbed, biodegraded, and
sequestered by the soil and vegetation. Bioretention with underdrain systems are utilized for areas
containing native soils with low permeability or steep slopes, where the underdrain system routes the
treated runoff to the storm drain system.
VEGETATED SWALES
Vegetated swales are open, shallow channels with low-lying vegetation covering the side slopes and
bottom that collect and slowly convey runoff flow to downstream discharge points. Vegetated swales
provide pollutant removal through settling and filtration in the vegetation (usually grasses) lining the
channels. In addition, although it is not their primary purpose, vegetated swales also provide the
opportunity for volume reduction through subsequent infiltration and evapotranspiration and reduce
the flow velocity. Where soil conditions allow, volume reduction in vegetated swales can be enhanced
by adding a gravel drainage layer underneath the swale allowing additional flows to be retained and
infiltrated. Where slopes are shallow and soil conditions limit or prohibit infiltration, an underdrain
system or low flow channel for dry weather flows may be required to minimize ponding and convey
treated and/or dry weather flows to an acceptable discharge point. An effective vegetated swale
achieves uniform sheet flow through a densely vegetated area for a period of several minutes
(depending on design standard used).
WET DETENTION BASIN
Wet detention basins are constructed, naturalistic ponds with a permanent or seasonal pool of water
(also called a “wet pool” or “dead storage”). Aquascape facilities, such as artificial lakes, are a special
form of wet pool facility that can incorporate innovative design elements to allow them to function
as a stormwater treatment facility in addition to an aesthetic water feature. Wet ponds require base
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Appendix 3.2 - 3 | Page
flows to exceed or match losses through evaporation and/or infiltration, and they must be designed
with the outlet positioned and/or operated in such a way as to maintain a permanent pool. Wet ponds
can be designed to provide extended detention of incoming flows using the volume above the
permanent pool surface.
DRY EXTENDED DETENTION BASIN
Dry extended detention basins are basins whose outlets have been designed to detain the stormwater
runoff to allow particulates and associated pollutants to settle out. Dry extended detention basins do
not have a permanent pool; they are designed to drain completely between storm events. They can
also be used to provide hydromodification and/or flood control by modifying the outlet control
structure and providing additional detention storage. The slopes, bottom, and forebay of Dry
extended detention basins are typically vegetated.
PRE TREATMENT BMPS
Pre-treatment BMPs are typically not used as primary treatment; however, they are highly recommended
for preliminary treatment in order to prolong the life and prevent clogging of the downstream system in
a treatment train.
MEDIA FILTERS
Media filters are usually designed as multi-chambered stormwater practices; the first is a settling
chamber, and the second is a filter bed filled with sand or another filtering media. As stormwater
flows into the first chamber, large particles settle out, and then finer particles and other pollutants
are removed as stormwater flows through the filtering medium. They can also be used as pre-
treatment, with their location prior to any infiltration or biotreatment BMP.
CATCH BASIN INSERTS
Catch basins inserts typically include a grate or curb inlet and a sump to capture sediment, debris, and
pollutants. Filter fabric can also be included to provide additional filtering of particles. The
effectiveness of catch basin inserts, their ability to remove sediments and other pollutants, depends
on its design and maintenance. Some inserts are designed to drop directly into existing catch basins,
while others may require retrofit construction. Similar to media filters, catch basin filters can also be
used as a pre-treatment BMP for infiltration and biotreatment BMPs.
HYDRODYNAMIC SEPARATORS
Hydrodynamic separators are typically vertically oriented cylinders or rectangular vaults with baffles,
weirs, and screens to direct flow to settle, separate and remove oil, sediment and floatables through
the force of gravity. The effectiveness of hydrodynamic separators depends on its design and
maintenance. Hydrodynamic separators are typically used in combination with other pre-treatment
BMPs.
SEDIMENT CHAMBERS
Sediment chambers are typically wet detention basins allowing preliminary settling areas for large debris
and sediment. As water reaches a predetermined level, it flows over a weir into bed of filter medium,
usually composed of sand, soil, gravel, or a combination. The medium filters out small sediment and other
pollutants.
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RAINFALL HARVEST
Rainfall Harvest BMPs capture rainwater to be reused in lieu of discharging directly to the MS4.
ABOVE GROUND CISTERNS
Cisterns are large above ground tanks that store stormwater collected from impervious surfaces for
non-potable domestic consumption. Above ground cisterns are used to capture runoff. Mesh screens
are typically used to filter large debris before the stormwater enters the cistern. The collected
stormwater could potentially be used for landscape irrigation and some interior uses, such as toilets
and washing machines. The collection and consumption of the stormwater results in pollution control,
volume reduction, and peak flow reduction from the site.
UNDERGROUND RETENTION
Underground retention systems function similarly to above ground cisterns in that they collect and
use stormwater from impervious surfaces. These systems are concealed underground and can allow
for larger stormwater storage and capture additional impervious surfaces not easily captured in an
above ground system (e.g. parking lots and sidewalks). Water is then infiltrated into the ground via
medium, usually composed of sand, soil, gravel, or a combination.
DIVERSION SYSTEMS
Flow diversion systems collect and divert runoff, flow diversion structures can primarily be sued in two
ways.
LOW F LOW DIVERSION
Low flow diversion structures may be used to direct dry weather or small wet weather flows to a
treatment facility via the sanitary sewer system or to a infiltration system, preventing the low flows
from reaching a receiving water body. This is typically done with low flow runoff, which occurs during
periods of dry weather or for small rain events at the beginning and end of the wet season.
STORMWATER DIVERSION
Stormwater diversion structures can also be used to direct storm flows from the MS4 into other
structural BMPs. For example, diverted flow can be fed into a regional BMP, which may include
underground detention.
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Appendix 4.1
Reasonable Assurance Analysis Report
217
Prepared for
Palos Verdes Peninsula Watershed Management Group
Reasonable Assurance Analysis
Revised Palos Verdes Peninsula EWMP 2021
Prepared by
Geosyntec Consultants, Inc.
6167 Bristol Parkway Ste 390
Culver City, CA. 90230
Project Number CWR0644
May 2022
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean i May 2022
TABLE OF CONTENTS
1. Introduction ........................................................................................................... 1
2. Water Body Pollutant Combinations .................................................................... 2
3. Model Selection and Overview ............................................................................ 4
3.1. WMMS 2.0 LSPC........................................................................................ 4
3.1.1. Updating Weather Data .................................................................. 7
3.1.2. Adding Indicator Bacteria as a Modeled Constituent .................... 7
3.1.3. Use of Surrogate Pollutants ............................................................ 8
3.1.4. Model Calibration and Validation .................................................. 8
3.1.5. Revising LSPC Sub-Basin Boundaries .......................................... 8
3.2. WMMS 2.0 SUSTAIN ................................................................................ 9
4. RAA Approach ................................................................................................... 10
4.1. Wet Weather RAA Approach .................................................................... 11
4.2. Dry Weather RAA Approach .................................................................... 12
5. Model Calibration and Validation ...................................................................... 13
5.1. Hydrologic Calibration .............................................................................. 14
5.2. Water Quality Calibration ......................................................................... 17
6. Critical Condition Definition .............................................................................. 21
6.1. Machado Lake ........................................................................................... 21
6.2. Wilmington Drain ...................................................................................... 21
6.3. Los Angeles Harbor ................................................................................... 21
7. Target Load Reductions ...................................................................................... 22
7.1. Santa Monica Bay WMA .......................................................................... 22
7.1.1. Indicator Bacteria ......................................................................... 22
7.1.2. PCBs and DDT ............................................................................. 22
7.1.3. Mercury and Arsenic .................................................................... 23
7.1.4. Trash and Marine Debris .............................................................. 23
7.2. Machado Lake WMA ................................................................................ 23
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7.2.1. Nutrients ....................................................................................... 24
7.2.2. Pesticides and PCBs ..................................................................... 25
7.3. Wilmington Drain WMA........................................................................... 26
7.3.1. Nutrients ....................................................................................... 26
7.3.2. Pesticides and PCBs ..................................................................... 26
7.3.3. Bacteria (E. coli) ........................................................................... 27
7.4. Los Angeles Harbor WMA ........................................................................ 27
7.4.1. Metals ........................................................................................... 27
7.4.2. Pesticides and PCBs. .................................................................... 28
7.5. 85th Percentile, 24-Hour Design Storm Simulation ................................... 28
7.6. Interim and Final Wet Weather TLR Summary ........................................ 28
8. Stormwater Control Overview ............................................................................ 34
8.1. Methods to Select and Prioritize BMPs ..................................................... 34
8.2. Quantified Non-Structural BMPs .............................................................. 34
8.2.1. Copper Brake Pad Reduction ....................................................... 35
8.3. Representing Structural BMPs .................................................................. 35
8.3.1. Regional and Distributed Structural Projects ............................... 36
8.3.2. LID Redevelopment ..................................................................... 39
9. Wet Weather RAA Results ................................................................................. 41
9.1. Machado Lake WMA ................................................................................ 41
9.2. Wilmington Drain WMA........................................................................... 45
9.3. Los Angeles Harbor WMA ........................................................................ 49
10. Dry Weather RAA Result ................................................................................... 53
10.1. Santa Monica Bay WMA .......................................................................... 53
10.2. Machado Lake WMA ................................................................................ 54
10.3. Wilmington Drain WMA........................................................................... 55
10.4. Los Angeles Harbor WMA ........................................................................ 55
11. BMP Cost Opinion ............................................................................................. 55
12. Conclusions......................................................................................................... 57
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13. References ........................................................................................................... 58
LIST OF TABLES
Table 1. Updated Waterbody Pollutant Combinations ..................................................... 3
Table 2. Default BMPs Modeled in SUSTAIN ................................................................ 9
Table 3. Calibration Metrics ........................................................................................... 14
Table 4. Summary Calibrated Hydrology Modeling Parameters ................................... 15
Table 5. Model Performance Summary - Hydrology ..................................................... 15
Table 6. Summary of Calibrated FIB Modeling Parameters .......................................... 17
Table 7. Summary of Calibrated Total Nitrogen Loading Parameters ........................... 18
Table 8. Summary of Calibrated Sediment Loading Parameters ................................... 18
Table 9. Summary of Calibrated Sediment-Associated Pollutant Parameters ............... 19
Table 10. Water Quality Model Calibration Summary .................................................. 19
Table 11. Final Wet Weather Target Load Reduction Summary ................................... 30
Table 12. Interim Wet Weather Target Load Reduction Summary ................................ 33
Table 13. Summary of Modeled Project ......................................................................... 38
Table 14. Redevelopment LID BMP Modeling Parameters ........................................... 40
Table 15. Peninsula Machado Lake WMA (ML-1) RAA Summary .............................. 42
Table 16. Peninsula Wilmington Drain WMA RAA Summary ..................................... 46
Table 17. Peninsula Los Angeles Harbor WMA RAA Summary .................................. 50
Table 18. Dry Weather RAA Summary ......................................................................... 53
Table 19. WMMS 2.0 Cost Function .............................................................................. 55
Table 20. Project Cost Opinion Summary ...................................................................... 56
LIST OF FIGURES
Figure 1. HRU Overview for Peninsula EWMP Area ...................................................... 5
Figure 2. Hydraulic Network, Subwatershed, and Weather Station Overview ................ 6
Figure 3. Analysis Region Overview .............................................................................. 10
Figure 4. Dry Weather RAA Process ............................................................................. 12
Figure 5. Locations of CIMP Monitoring Stations Utilized for Calibration .................. 13
Figure 6. Comparison of Modeled and Monitored Flows at RHECH ............................ 16
Figure 7. Total Nitrogen Concentration Comparison. .................................................... 20
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Figure 8. Modeled Regional and Distributed Projects .................................................... 37
Figure 9. 24-Hour Management Volume Breakdown in Machado Lake WMA (ML-1) 43
Figure 10. 24-Hour Management Volume Status in Machado Lake WMA (ML-1). ..... 44
Figure 11. 24-Hour Management Volume Breakdown in Wilmington Drain WMA (WD-
1 and WD-Solano) .......................................................................................................... 47
Figure 12. 24-Hour Management Volume Mapping in Wilmington Drain WMA (WD-1
and WD-Solano) ............................................................................................................. 48
Figure 13. 24-Hour Management Volume Breakdown in Los Angeles Harbor WMA. 51
Figure 14. 24-Hour Management Volume in Peninsula LA Harbor WMA ................... 52
LIST OF ATTACHEMTNS
Attachment A Supplementary Calibration Exhibits
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1. INTRODUCTION
As specified in the 2012 Los Angeles Municipal Separate Storm Sewer System (MS4)
National Pollutant Discharge Elimination System (NPDES) Permit 1 (Permit), the Cities
of Palos Verdes Estates, Rancho Palos Verdes, and Rolling Hills Estates, together with
the County of Los Angeles and the Los Angeles County Flood Control District
(LACFCD), collectively referred to as the Palos Verdes Peninsula (Peninsula) Watershed
Management Group (WMG), developed an Enhanced Watershed Management Program
(EWMP) for their drainage areas within the Santa Monica Bay, Machado Lake (including
Wilmington Drain) and Los Angeles Harbor watersheds. As a part of demonstrating
progress and adaptive management, the Peninsula WMG is required to submit a revised
EWMP to the Los Angeles Regional Water Quality Control Board (LARWQCB),
including an updated Reasonable Assurance Analysis (RAA), by June 30, 2021.
This report has been prepared to summarize the approach and results of the revised RAA.
Building upon the original and revised updated plans in 2015 and 2018, the revised RAA
has been conducted to conform to the original RAA guidelines developed by the
LARWQCB (LARWQCB, 2014a). The revised RAA also provides updates to include
recent monitoring data, project planning and implementation, and modeling advances
over the past five years. Where appropriate, it also addresses issues and comments raised
by the State Water Resources Control Board (SWRCB, 2020), such as inclusion of
relevant data for model calibration, non-structural Best Management Practices (BMP)
credit, and application of the limiting pollutant approach.
The updated wet weather RAA was conducted using the Watershed Management
Modeling System 2.0 (WMMS 2.0), the latest modeling tool developed by LACFCD, to
determine a cost-effective implementation strategy to meet applicable water quality
standards (i.e., TMDL waste load allocations [WLA] and Basin Plan Objectives) and
targets. This modeling platform was approved and endorsed by the LARWQCB as an
acceptable regulatory approach for developing the RAA. WMMS 2.0 has the capability
of representing wet and dry weather flow discharges, although based on a variety of
factors, dry weather flows were not modeled using WMMS 2.0 as part of this effort. For
dry weather, a revised semi-quantitative approach was implemented to update the dry
weather portion of the revised RAA.
1 Order No. R4-2012-0175 NPDES Permit No. CAS004001 Waste Discharge Requirements for Municipal
Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles County,
except those Discharges Originating from the City of Long Beach MS4.
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The RAA was completed for the full geographic domain of the Peninsula EWMP area.
Unless otherwise noted, all Water Body Pollutant Combinations (WBPCs) identified in
the Peninsula EWMP have been addressed as part of this revised RAA.
2. WATER BODY POLLUTANT COMBINATIONS
The WBPCs defined in the original Peninsula EWMP were revised based on the most
recent updates to applicable TMDLs and 303(d) listings, as well as the available
Coordinated Integrated Monitoring Program (CIMP) monitoring data. The updated
WBPC list is summarized in Table 1.
As with the original Peninsula EWMP, this RAA was done to address all Category 1
WBPCs by meeting the interim and final MS4 waste load allocations (WLAs), and all
Category 2 and 3 WBPCs where the Peninsula WMG may have caused or contributed to
historical exceedances.
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 3 May 2022
Table 1. Updated Waterbody Pollutant Combinations
Category Pollutant
Waterbody
SMB(a) SMB
Beaches ML(b) WD(c) IH(d) CM(e)
1
Chlordane
(water, sediment, fish tissue) [1] Wet
Dry
Copper
(water and sediment) [2] Wet
Dry
Wet
Dry
DDT
(water, sediment, fish tissue) [2]
Wet
Dry
Wet
Dry
Wet
Dry Wet
Dry
Wet
Dry
Dieldrin
(water, sediment, fish tissue) [1] Wet
Dry
Indicator Bacteria Wet
Dry
Lead
(water and sediment) [2] Wet
Dry
Wet
Dry
Total Nitrogen[3] Wet
Dry
Total PAHs[2] Wet
Dry
Wet
Dry
PCBs
(water, sediment, fish tissue) [2]
Wet
Dry
Wet
Dry
Wet
Dry Wet
Dry
Wet
Dry
Total Phosphorus[3] Wet
Dry
Trash Wet Wet
Zinc
(water and sediment) [2] Wet
Dry
Wet
Dry
2
Arsenic Wet
Dry
Indicator Bacteria Wet
Mercury Wet
Dry
3 Analysis of monitoring data from outfalls and receiving waters do not currently result in the
identification of any Category 3 WBPCs
Abbreviations:
a = Santa Monica Bay, b = Machado Lake, c = Wilmington Drain, d = Inner Harbor, e = Cabrillo Marina
Notes:
1. Machado Lake Pesticides and PCBs TMDL Water Quality Based Effluent Limits (WQBELs) for Chlordane and Dieldrin address the
associated 303(d) listing for ChemA, therefore this listing is not shown in the table. Please refer to revised Peninsula EWMP Chapter 2
for additional descriptions.
2. The Dominguez Channel and Greater Los Angeles and Long Beach Harbor Toxics TMDL WQBELs for Total PAHs, Copper, DDT,
Lead, PCBs and Zinc address associated 303(d) listings in harbor waterbodies for Toxicity, Benthic Community Effects,
Benzo(a)pyrene, Chrysene, Dibenz[a,h]anthracene, Phenanthrene, and Pyrene, therefore these listings are not shown in the table. Please
refer to revised Peninsula EWMP Chapter 2 for additional description.
3. Machado Lake Nutrient TMDL WQBELs for TN and TP address associated 303(d) listings for Algae, Ammonia, Eutrophic Conditions,
and Odor, therefore these listings are not shown in the table. Please refer to revised Peninsula EWMP Chapter 2 for additional description.
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3. MODEL SELECTION AND OVERVIEW
While the original RAA leveraged the strengths of the Structural BMP Prioritization and
Analysis Tool (SBPAT) to perform the wet weather modeling analysis, the revised RAA
used the newly released WMMS 2.0 modeling platform to maintain consistency with the
majority of RAAs across Los Angeles County. Developed by LACFCD and publicly
released in May 2020, WMMS 2.0 utilizes remote sensing, water quality, and hydrology
data collected through 2018 to simulate contaminant loading, runoff volume, and flow
rate. WMMS 2.0 contains two major components: the Loading Simulation Program in
C++ (LSPC) to determine hydrology and pollutant loading; and the System for Urban
Stormwater Treatment and Analysis Integration (SUSTAIN) to assist in BMP selection
and performance. Detailed descriptions of each model component are provided below).
An advantage of using the WMMS 2.0 model is the extensive regional calibration effort
that has gone into the recent update of the model.
3.1. WMMS 2.0 LSPC
WMMS 2.0 LSPC (version 6.0) is capable of simulating watershed hydrology, sediment
erosion and transport, and water quality processes from both upland contributing areas
and receiving streams. Long-term, hourly rainfall data and average monthly
evapotranspiration values are used along with land use-linked catchment imperviousness,
soil properties, and land use-specific pollutant buildup/wash off rates to estimate wet
weather runoff volumes and pollutant loading. WMMS 2.0 LSPC utilizes the following
spatial and temporal data to conduct the simulation:
• Hydrologic response unit (HRU), which is a combination of:
o Soils
o Land cover
o Groundwater recharge potential
o Topography
o Land use
• Hydraulic network (dams, debris basins, spreading grounds, water reclamation
plants, storm drains, open channels)
• Subwatershed/subbasin
• Hourly and spatially interpolated precipitation and evapotranspiration data.
Figure 1 illustrates the HRUs and the hydraulic network, and the subwatershed boundary
of the Peninsula EWMP area. Figure 2 illustrates the weather station coverage for the
Peninsula LSPC model.
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Figure 1. HRU Overview for Peninsula EWMP Area
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Figure 2. Hydraulic Network, Subwatershed, and Weather Station Overview
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The default 2 WMMS 2.0 LSPC model has been configured, calibrated, and validated
through a regional approach against flow and water quality monitoring data collected at
all Mass Emission Stations (MES) in Los Angeles County. The following pollutants are
included in the downloaded version of the WMMS 2.0 platform:
• Total Nitrogen
• Total Phosphorus
• Total Zinc
• Total Lead
• Total Copper
• Total Cadmium, and
• Total Suspended Solids (TSS)
The application of this model provides an estimate of the target load reduction (TLR), a
numerical expression of the Permit compliance metrics (e.g., allowed mass per day for
metals for wet weather and allowable exceedance days per year for bacteria), that serves
as a basis for confirming, with reasonable assurance, that implementation of the proposed
stormwater runoff or dry weather best management practices (BMPs) will result in
attainment of the applicable TMDL WLA based WQBELs in the Permit for Category 1
pollutants, or the Water Quality Objectives for Category 2 pollutants.
The subsections below summarize the modifications to the default WMMS 2.0 LSPC
model that were used to conduct the revised RAA.
3.1.1. Updating Weather Data
The default WMMS 2.0 LSPC model database includes precipitation data up to
September 2018. Additional hourly rainfall data collected up to June 2020 from Los
Angeles County Automatic Local Evaluation in Real Time (ALERT) rain gauges were
requested and amended to the model database in accordance with the default WMMS 2.0
rain gauge coverage assignment.
3.1.2. Indicator Bacteria as a Modeled Constituent
Because none of the default constituents in WMMS 2.0 LSPC model can be used as a
surrogate pollutant for fecal indicator bacteria (FIB), a representative FIB had to be added
to the model. HRU-specific event mean concentration (EMCs) for FIB were established
using monitoring data collected via the Peninsula CIMP through June 2020.
2 The term “default” refers to the “as-downloaded” model released by LACFCD in May 2020.
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However, no bacteria modeling was necessary for the updated Peninsula RAA for the
following reasons:
• While indicator bacteria is a Category 1 WBPC for the Santa Monica Bay and
Santa Monica Bay Beaches, no modeling was required to demonstrate reasonable
assurance of compliance in the Santa Monica Bay watershed since water quality
data demonstrates compliance is already being achieved. See Section 7.1 for
further details on the Santa Monica Bay watershed.
• While indicator bacteria is a Category 2 WBPC for Wilmington Drain, the
Peninsula subwatersheds tributary to Wilmington Drain will be managed with 85th
percentile regional projects. Therefore, bacteria modeling was not required for
these subwatersheds. See Section 7.3 for further details on the Wilmington Drain
watershed.
3.1.3. Use of Surrogate Pollutants
Pollutant load rate and concentration for WBPCs involving the seven default WMMS 2.0
LSPC model pollutants and the added indicator bacteria were obtained from the WMMS
2.0 LSPC output files directly. A subset of the directly modeled pollutants was used as
surrogate pollutants to establish pollutant loading and concentration of pollutants not
directly modeled in the WMMS 2.0 LSPC model. Details on surrogate pollutant selection
and assignment are presented in Section 7.
3.1.4. Model Calibration and Validation
The default WMMS 2.0 LSPC model has been calibrated by LACFCD on a regional basis
using data through September 2018. Geosyntec further calibrated and validated the
WMMS 2.0 LSPC model using Peninsula CIMP monitoring data collected up to June
2020 to best reflect the baseline hydrology and water quality conditions within the
Peninsula EWMP area. This date was selected as it marks the most recently complete
CIMP annual reporting year, and therefore is inclusive of the latest available data that has
been properly QC’d by the Peninsula WMG. Detailed information on the model
calibration can be found in Section 5.
3.1.5. Revising LSPC Sub-Basin Boundaries
Since the default LSPC subwatershed boundaries were developed at a regional scale and
cover the entire Los Angeles Basin, they were found to contain some minor inaccuracies
at the finer spatial resolution used for the revised RAA. As part of the revised RAA
process, the subwatershed boundaries were refined to more accurately reflect the drainage
boundaries within the Peninsula EWMP area.
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3.2. WMMS 2.0 SUSTAIN
Utilizing hourly hydrograph and pollutograph outputs from LSPC, WMMS 2.0
SUSTAIN (version 2.1) provided estimates of water balance such as volumes
evapotranspired, diverted, captured, treated, and/or released by various BMPs, as well as
a conceptually optimal spatial distribution of BMPs based on cost-effectiveness to
achieve TLR goals. WMMS 2.0 SUSTAIN also has a batch-processing framework to
inform selection, configuration, and placement of BMPs throughout a watershed-based
on defined evaluation criteria, such as cost and TLR. The default WMMS 2.0 SUSTAIN
model was used to determine the estimated performance of BMPs summarized in Table
2.
Table 2. Default BMPs Modeled in SUSTAIN
BMP Type Performance Type
Distributed BMP
Bioretention/biofiltration (with
optional underdrain) Volume reduction and flow-through treatment
Pervious pavement Volume reduction and flow-through treatment
Cistern/Rain barrel Volume reduction
Drywell Volume reduction
Proprietary treatment unit Flow-through treatment
Regional BMP
Infiltration gallery Volume reduction
Retention/detention basin Volume reduction and flow-through treatment
Constructed wetland Volume reduction and flow-through treatment
Sewer diversion Volume reduction
Regional treatment facility Flow-through treatment
For the revised RAA, WMMS 2.0 SUSTAIN was used to estimate the performance of
existing and proposed distributed and regional BMPs, thereby assuring that an effective
and suitable suite of stormwater management BMPs is implemented to meet applicable
interim and final TLR goals. This approach is therefore used to demonstrate a reasonable
assurance of compliance for all modeled WBPCs. Details on modeled BMPs can be found
in Section 8.
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4. RAA APPROACH
Consistent with the original Peninsula EWMP RAA, the revised RAA was completed for
the Peninsula EWMP analysis regions. An analysis region is defined by one of the
following conditions:
1. A subwatershed that drains to a compliance monitoring location (CML) (e.g. WD-
1)
2. Area tributary to the open beach between two CMLs (SMB-7-03_7-04)
3. Area tributary to an existing waterbody (e.g. LAH-IH)
As shown in Figure 3, there are 16 analysis regions in the Peninsula EWMP area. Among
the analysis regions in the Dominguez Channel – Los Angeles Harbor HUC-12
watershed, analysis regions WD-Solano and WD-1 are tributary to Machado Lake via
Wilmington Drain. Analysis region ML-1 is tributary to Machado Lake directly. Analysis
regions LAH-IH and LAH-CM are tributary to Los Angeles Inner Harbor and Cabrillo
Marina respectively.
Figure 3. Analysis Region Overview
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4.1. Wet Weather RAA Approach
The approach for representing wet weather flows and pollutant management for the RAA,
including model determination and calibration, data inputs, critical condition selection
calibration performance criteria, and output types, were selected for consistency with the
RAA Guidance Document (LARWQCB, 2014b), as well as the functionality of WMMS
2.0. The process for determining the wet weather RAA included the following sequential
steps for the Peninsula EWMP area:
1. Identify current WBPC list, including all quantifiable parameters requiring model
simulation.
2. Revise, as needed, the contributing MS4 service areas to represent the Peninsula
EWMP (e.g. remove lands or areas not required to be analyzed and adjust
boundaries to match at a more detailed scale). This includes land owned and
operated by Caltrans and the 85th-percentile 24-hour storm runoff retention area
in City of Rolling Hills.
3. For analysis regions draining to a CML, review the Peninsula CIMP and SMBBB
TMDL monitoring data and assess if the analysis region is already in compliance.
Remove analysis regions that area in compliance based on monitoring data.
4. Perform hydrologic and water quality calibration on the WMMS 2.0 LSPC model
using Peninsula CIMP outfall monitoring data.
5. Identify WBPC-specific critical conditions.
6. Develop TLRs for identified WBPCs during the respective critical condition.
7. Identify the following with respect to structural and non-structural BMPs:
a. Significant variations to BMPs accounted for in the original Peninsula
EWMP (e.g., differences in LID implementation levels);
b. Exclude original Peninsula EWMP projects that were found to be
technically infeasible at the scale originally proposed, such as the
Valmonte Regional BMP and Palos Verdes Landfill Regional BMP;
c. Identify new BMPs that have been implemented since 2014 and were not
accounted for in the original EWMP; and
d. Identify new BMPs that are planned for implementation and were not
accounted for in the original EWMP.
8. Evaluate the pollutant load reductions of existing and proposed BMPs.
9. Compare these estimates with the final TLRs.
10. Revise the BMP implementation scenarios until all final TLRs are met, thereby
reasonably assuring compliance with wet weather permit goals.
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4.2. Dry Weather RAA Approach
Consistent with the original EWMP RAA, a semi-quantitative approach was implemented
as summarized in Figure 4 to perform dry weather RAA and to demonstrate reasonable
assurance of meeting applicable permit goals.
Figure 4. Dry Weather RAA Process
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5. MODEL CALIBRATION AND VALIDATION
The default WMMS 2.0 LSPC watershed model was configured, calibrated, and validated
by LACFCD through a regional approach against flow and water quality monitoring data
collected at all Los Angeles County Mass Emission Stations (MES) between water years
2008 and 2018 (LACFCD, 2020a). Geosyntec further calibrated the model using
Peninsula CIMP wet weather outfall flow and water quality data collected through June
2020. The calibrated Peninsula LSPC model was used as the foundation for performing
the wet weather RAA. Figure 5 shows the CIMP monitoring locations used in model
calibration and validation.
Figure 5. Locations of CIMP Monitoring Stations Utilized for Calibration
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Calibrations were performed to meet the specifications of the RAA Guidelines Document
(LARWQCB, 2014b), which are summarized in Table 3. Consistent with the regional
WMMS 2.0 calibration process, percent bias (PBIAS) is the primary statistic used to
evaluate the agreement between modeled-predicted and observed data. PBIAS quantifies
systematic over- or under-prediction. Low values of PBIAS indicate a better fit. The
lower bound of the “Fair” threshold is the minimum acceptable criteria for the model
calibration. If a “Fair” threshold is not met during the model validation process, additional
model adjustments are made to attain the threshold at the validation site. If such effort is
not successful, additional investigations such as site monitoring investigations or further
data collection would be completed to examine potential issues in the modeled and
monitored data.
Table 3. Calibration Metrics
Category Percent Difference Between Model-Predicated and Observed Data (PBIAS)
Very Good Good Fair
Hydrology /
Flow ±0 – 10% >±10% - 15% >±15% - 25%
Sediment ±0 – 20% >±20% - 30% >±30% - 40%
Water Quality ±0 – 15% >±15% - 25% >±25% - 35%
Pesticides /
Toxics ±0 – 20% >±20% - 30% >±30% - 40%
Details of the calibration and validation approach and results are presented in the
following subsections.
5.1. Hydrologic Calibration
The objective of hydrologic calibration is to compare observed and model-predicted wet
weather flow rates at monitoring sites and achieve a “Fair” agreement or better for the
computed PBIAS metric.
As part of the Peninsula CIMP, continuous year-round flow data is collected at the
Rolling Hills Estates City Hall (RHECH) and Valmonte outfall monitoring sites. For the
remaining outfall monitoring sites, flow monitoring data is collected only during wet
weather events, which is also when water quality samples are collected. With the
exception of RHECH, the available wet weather flow rates were either too sporadic or
too low, with no more than 15% of recorded wet weather flow above 0.1 cubic feet per
second (cfs). As a result, and to avoid overly reducing runoff generation parameters, the
hydrologic calibration only utilized continuous wet weather flow data collected at the
RHECH monitoring site.
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The hydrologic calibration required the evaluation of subsurface storage, infiltration, and
groundwater recession modeling parameters. The calibration was performed by
iteratively applying multipliers to HRU-specific modeling parameters. It should be noted
that the majority of the Peninsula EWMP area first drains to vegetated natural canyons,
where a significant portion of the runoff is detained and infiltrated prior to reaching
downstream monitoring locations. This finding is consistent with the observation of the
low flow rates at monitoring locations during the majority of the wet weather events. To
account for the natural canyons throughout the Peninsula EWMP area, it is assumed that
a fraction of the surface runoff is infiltrated in the natural canyons. The numeric value of
the fraction was iteratively determined along with other HRU-specific modeling
parameters until satisfactory calibration criteria were met. The resulting hydrology
parameter ranges are presented in Table 4.
Table 4. Summary Calibrated Hydrology Modeling Parameters
Parameter Description Unit Peninsula Model
Range of Values
INFILT Index to Infiltration Capacity in/hr 0.4-8
AGWRC Base groundwater recession none 0.99
INTFW Interflow inflow parameter - 0.05-0.1
IRC Interflow inflow recession
parameter - 0.03
ROUTE_SURO Fraction of surface runoff
routed to the stream - 0.15
Notes: For hydrologic parameters not listed in the table, the default WMMS 2.0 model values were used without
modification.
Table 5 presents a summary of the statistical results of the hydrologic calibration.
Calculations of R2, NSE, and PBIAS were based on a comparison of modeled and
observed daily flow. For the PBIAS metric, all modeled flows were within or better than
the “Fair” percent difference range, achieving the minimum acceptable criteria for the
Regional Board RAA Guidance. R2 and NSE are supplementary hydrological calibration
metrics and show an acceptable correlation between modeled and observed flow data.
Table 5. Model Performance Summary - Hydrology
Calibration
Metrics
Comparison Locations
RHECH
PBIAS +19.2
To further evaluate the temporal trends of the hydrology calibration, comparisons
between model and observed monthly flows were evaluated by examining the time series
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plots and the average monthly flows between November 2016 and June 2020. See Figure
6.
Figure 6. Comparison of Modeled and Monitored Flows at RHECH
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5.2. Water Quality Calibration
The RAA Guideline requires water quality calibration based on available monitoring data
from each analysis region over the most recent 10 years. The default WMMS 2.0 LSPC
watershed model has been regionally calibrated and validated using data collected at Los
Angeles County MES and CIMP receiving water monitoring stations throughout the Los
Angeles County between water years 2008 and 2018. Building upon such effort,
Geosyntec further calibrated the LSPC model using water quality data collected at
Peninsula CIMP outfall monitoring locations shown in Figure 5. Modeling was
completed for the following constituents:
• E. coli
• Total Suspended Solids (TSS)
• Nutrients – Total nitrogen and total phosphorus
• Metals – Total copper, total lead, and total zinc.
As discussed in Section 3.1.2, FIB representation was added to the WMMS 2.0 LSPC
model to demonstrate compliance to water quality objectives that are expressed in
exceedance days. HRU-specific land use bacteria EMCs from WMMS 1.0 were adopted
as the starting point of the calibration. The next step in the calibration process was an
iterative application of multipliers to EMCs across all HRUs. Specifically, the FIB
modeling parameters were calibrated against E. Coli monitoring data collected at outfall
site RHECH. The calibrated parameters are summarized in Table 6.
Table 6. Summary of Calibrated FIB Modeling Parameters
Parameter Description Units Peninsula Model
Range of Values
SOQC
Concentration of
constituent in surface
outflow
MPN/
100mL 500 – 45,500
IOQC
Concentration of
constituent in interflow
outflow
MPN
/100mL 500 – 45,500
Note: For parameters not listed in the table, the default WMMS 2.0 model values were used.
Total nitrogen was modeled as a non-sediment-associated pollutant in WMMS 2.0 LSPC.
The total nitrogen build-up/wash-off parameter values are summarized in Table 7.
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Table 7. Summary of Calibrated Total Nitrogen Loading Parameters
Parameter
Name Description Units Peninsula
Model Values
ACQOP Accumulation rate of
total nitrogen on surface lb/acre/day 0 - 3
SQOLIM Maximum storage of
total nitrogen on surface lb/acre 0 - 12
Although TSS is not a pollutant of concern for the Peninsula EWMP area, it is a
representative pollutant for sediment-associated pollutant simulation in LSPC. TSS load
can be used as a surrogate for organic pollutants of concern that are not modeled directly
in LSPC (i.e. PAHs, DDT, and PCBs). TSS calibration was performed by iteratively
applying multipliers to HRU-specific parameter associated with sediment load buildup
on the land surface. The range of values for TSS build-up/wash-off parameters are
summarized in Table 8.
Table 8. Summary of Calibrated Sediment Loading Parameters
Parameter
Name Description Units
Peninsula
Model Range
of Values
ACCSDP
Rate at which solids
accumulate on the land
surface
lb/acre/day 0 – 0.016
KSER
Coefficient in the
detached sediment wash
off equation
- 0 - 2
Note: TSS associated parameters that are not listed in the table, the default WMMS 2.0 model values were used
without modification.
Metals and total phosphorous were modeled in WMMS 2.0 LSPC as sediment-associated
pollutants. Calibration for metals was performed by iteratively applying HRU specific
multipliers to LSPC model parameters associated with metal potency factors in order to
maintain the same relative ratios among HRUs determined in the regionally calibrated
WMMS 2.0 LSPC model. The model values associated with metal potency factors are
summarized in Table 9.
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Table 9. Summary of Calibrated Sediment-Associated Pollutant Parameters
Pollutant Parameter
Name Description Units
Peninsula
Model
Range of
Values
Total Copper POTFW Pollutant wash-off potency factor
per mass of sediment
lb/ton 0 – 0.4
POTFS Pollutant scour potency factor per
mass of sediment
lb/ton 0 – 0.4
Total Lead POTFW Pollutant wash-off potency factor
per mass of sediment
lb/ton 0 – 0.09
POTFS Pollutant scour potency factor per
mass of sediment
lb/ton 0 – 0.09
Total Zinc POTFW Pollutant wash-off potency factor
per mass of sediment
lb/ton 0 – 2.1
POTFS Pollutant scour potency factor per
mass of sediment
lb/ton 0 – 2.1
Total
Phosphorus
POTFW Pollutant wash-off potency factor
per mass of sediment
lb/ton 0 – 6.4
POTFS Pollutant scour potency factor per
mass of sediment
lb/ton 0 – 6.4
Note: For parameters not listed in the table, the default WMMS 2.0 model values were used without modification.
Table 10 presents a summary of results for water quality calibration. Calculations of
PBIAS are based on a comparison of modeled and observed daily average concentration
at each outfall monitoring site. In reference to the RAA Guideline calibration metrics
summarized in Table 3, all modeled pollutant concentrations were within the range for
“Very Good” agreement with observed data.
Table 10. Water Quality Model Calibration Summary
Calibration
Metric
Pollutants RHECH
PBIAS
E. coli -2.9
TSS 14
Total Copper 1.4
Total Lead 7.1
Total Zinc 4.9
Total Nitrogen -2.0
Total Phosphorus 6.7
To further evaluate the temporal trends of the water quality calibration, comparisons
between modeled and observed monthly flows were assessed using the time series plots
of flows between November 2016 and June 2020. Please see Attachment A for the
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resultant comparison plots. The time series plots for total zinc concentration is shown in
Figure 7 as an example. The remaining time series plots are included in Attachment A.
Figure 7. Total Nitrogen Concentration Comparison.
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6. CRITICAL CONDITION DEFINITION
Consistent with RAA Guideline Document (LARWQCB, 2014b), the RAA was
performed on the critical conditions defined in the applicable TMDLs. Determination of
the critical conditions is summarized in the subsections below.
6.1. Machado Lake
The final MS4 WLAs in Machado Lake Nutrient TMDL and Machado Lake Pesticides
and PCBs TMDL were both calculated based on the average water year, which is used as
the critical condition for the wet weather RAA. LACFCD performed a hydrologic
analysis to define the “average” water year during the WMMS 2.0 model development.
Water Year 2010 was identified as the representative average water year in the
Dominguez Channel watershed 3 based on analysis of the most recent 10-years of rainfall
data (LACFCD, 2020c). As such, Water Year 2010 was used as the critical condition to
establish wet weather nutrient and organic pollutant TLRs in the Peninsula Machado Lake
watershed management area (WMA)
6.2. Wilmington Drain
Wilmington Drain WMA is a subwatershed tributary to Machado Lake. As explained in
Section 6.1, Water Year 2010 represents the average water year and was used as the
critical condition to establish wet weather nutrient and organic pollutants in the Peninsula
Wilmington Drain WMA.
6.3. Los Angeles Harbor
According to the Dominguez Channel and Greater Los Angeles and Long Beach Harbor
Toxics TMDL (herein referred as the “Los Angeles Harbor Toxics TMDL”), the MS4
WLAs to Los Angeles Harbor waterbodies were calculated based on average annual
condition. As such, the average water year was used as the critical condition to establish
wet weather TLRs for metals and toxics pollutants. Again, Water Year 2010 was used as
the critical wet weather condition.
3 Both Machado Lake and Wilmington Drain WMAs are subwatershed to the HUC-12 Dominguez Channel
Watershed.
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7. TARGET LOAD REDUCTIONS
The following subsection documents the development of wet weather and year-round 4
TLRs for each of the Peninsula EWMP WMAs for all modeled WBPCs. A justification
for WBPCs that did not require modeling to demonstrate compliance to applicable water
quality standard are also provided. The dry weather RAA process, as described in Section
4.2 using the decision tree, do not require development of dry-weather specific TLRs.
Section 10 summarizes the dry weather RAA results.
7.1. Santa Monica Bay WMA
Wet weather WBPCs in the Santa Monica Bay WMA include bacteria, trash and marine
debris, PCBs, DDT, mercury, and arsenic. No modeling was conducted within the Santa
Monica Bay WMA for the updated RAA, as reasonable assurance of compliance is
already demonstrated via monitoring data.
7.1.1. Indicator Bacteria
The five SMBBB shoreline CMLs established for the Peninsula EWMP area (SMB 7-1
through 7-5) historically demonstrated fewer exceedance days than the reference beach
(Leo Carrillo) used in TMDL development and were therefore considered anti-
degradation sites when the TMDL was developed. The five Peninsula shoreline
monitoring sites were sampled for indicator bacteria along the Palos Verdes Peninsula
shoreline on a weekly basis. Data collected up through June 2020 indicate that exceedance
of wet weather single sample limits are infrequent. All five sites generally averaged less
than one exceedance day above the annual wet weather allowable exceedance days over
the past 10 years, except during the 2016-17 rainy season which was wetter than the
critical year. Given these findings, zero TLR were determined for analysis regions
tributary to SMB-7-1 through 7-5. This is consistent with the TMDL’s approach that
acknowledges that historic bacteria exceedance rates for each of these subwatersheds are,
on average, lower than that of the reference beach.
7.1.2. PCBs and DDT
For PCBs and DDT, the WLAs for the entire Santa Monica Bay watershed were
determined as equal to the existing estimates of annual loads for DDTs and PCBs.
Therefore, consistent with the TMDL, it is assumed that there is a required load reduction
of zero for PCBs and DDT, and no RAA is required. Additionally, four complete years
of nearshore receiving water quality data have been collected under the Peninsula CIMP
4 Year-round TLRs that account for both wet and dry weather TLRs were only developed for area with
observed non-exempt dry weather flow.
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in the Santa Monica Bay and analyzed for total DDT and PCBs. Of these dry and wet-
weather samples collected, only one (1) out of forty (40) samples or 2.5% resulted in
detection of 4,4’- DDT at a concentration between the method detection limit and the
reporting limit. This sample was collected during a summer dry weather sampling event
in the fourth year of CIMP monitoring. None of the forty (40) receiving water samples
collected over the past four years have resulted in detections of Total PCBs above the
Ocean Plan objective for total PCBs. This data further validates the conclusion that the
Peninsula WMG is in compliance with the TMDL MS4 WLA for total DDTs and total
PCBs, and no RAA is needed for these WBPCs.
7.1.3. Mercury and Arsenic
Mercury and arsenic were recently added to the 303(d) list for Santa Monica Bay based
on sediment and fish tissue data collected under the Hyperion Treatment Plant NPDES
Permit no. CA0109991 between January 2006 and June 2010. There’s no existing data or
evidence tying either of these pollutants to stormwater MS4 discharges. Arsenic and
mercury have been added to the outfall monitoring sites for the Santa Monica Bay in
response to recent 303(d) listings, however insufficient data are available to support the
need for RAA.
7.1.4. Trash and Marine Debris
Compliance with the Santa Monica Bay Debris TMDL will be met through a phased
retrofit of catch basins throughout the Peninsula Santa Monica Bay WMAs. Trash
exclusion devices, along with trash source controls to meet each interim compliance
deadline and the final compliance deadline are the management controls planned to
achieve compliance. Hence, these constituents do not require a TLR to be calculated and
were not modeled as part of the revised RAA.
7.2. Machado Lake WMA
Wet weather and year-round pollutants of concern in the Machado Lake watershed
include trash, PCBs, DDT, total chlordane, dieldrin, total nitrogen, and total phosphorus.
Compliance with the Machado Lake Trash TMDL has been met through retrofit and
ongoing maintenance of catch basins throughout the Machado Lake WMAs with trash
exclusion devices. Hence, trash does not require a TLR and was not modeled as part of
the revised RAA. TLRs for the remaining WBPCs were established using the calibrated
WMMS 2.0 LSPC model. While the model is only capable of representing a subset of the
WBPCs directly, justifications were provided to establish TLRs for the other WBPCs to
comply with the State Board’s requirement to demonstrate attainment of water quality
standards for all compliance targets (SWRCB, 2020).
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7.2.1. Nutrients
The final MS4 WLAs for total nitrogen and total phosphorus are expressed in the
following two ways in the Machado Lake Nutrients TMDL:
• Monthly average WQBEL concentration.
• Annual average pollutant load calculated as the WQBEL concentration multiplied
by the annual average inflow to the Machado Lake (8.45 HM3/year) apportioned
to each WMA tributary to Machado Lake (directly or via Wilmington Drain). This
method was initially established in the Los Angeles County Machado Lake
Nutrient TMDL Special Study (LACDPW, 2011) following conditional approval
of the work plan by LARWQCB (LARWQCB, 2010).
Of the two acceptable compliance pathways, the annual average pollutant load method
was selected to determine the allowable load in subsequent TLR calculations.
The following approach was implemented to calculate a TLR for total nitrogen and total
phosphorus in Peninsula Machado Lake WMA:
1. The analysis region was modeled in LSPC for water year 2010 in order to obtain
the baseline wet weather pollutant load. The number of wet days during the
modeled year were also defined based on the precipitation data.
2. For analysis regions with observed dry weather flow, the baseline dry weather
pollutant load was estimated by multiplying the average measured daily dry
weather flow from water year 2010 by the average dry weather pollutant
concentrations.
3. For analysis regions without observed dry weather flow as determined through
the non-stormwater outfall screening and source investigation report (Peninsula
WMG, 2018), the dry weather pollutant load was assumed to be zero.
4. The total baseline load was computed by summing the dry weather and wet
weather pollutant load computed in Step 1 and 2.
5. The allowable load was calculated as the WQBEL concentration multiplied by the
annual average inflow to the Machado Lake (8.45 HM3/year) apportioned to the
analysis region tributary to the Machado Lake.
6. The difference between the annual baseline load (step 4) and the annual allowable
load (step 5) resulted in a TLR for the average water year, which was the load
reduction required to meet the allowable TMDL concentration.
7. A TLR equivalent 24-hour runoff management volume was estimated as the
following:
a. First, estimate the annually managed runoff volume by dividing the TLR by
the annual baseline runoff volume.
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b. Next, add an in-stream diversion to a hypothetical retention BMP with a 24-
hour drawdown time at the outlet of analysis region and iteratively size until
the diverted (and hence managed) runoff volume is equal to or greater than
the annually managed runoff volume. The retention volume of this
hypothetical retention BMP was determined to be the 24-hour runoff
management volume. Both load-based TLRs and the equivalent 24-hour
runoff management volumes are considered acceptable Peninsula EWMP
compliance metrics
7.2.2. Pesticides and PCBs
PCBs, DDT, total chlordane, and dieldrin are Category 1 WBPCs in the Machado Lake
WMA due to inclusion in the Machado Lake Pesticides and PCBs TMDL. The final MS4
WLA in the TMDL is expressed as the annual loading of pollutants calculated as the
sediment-based WQBEL multiplied by the annual TSS load.
These pollutants cannot be modeled directly in WMMS 2.0 LSPC. Instead, TSS was
modeled and used as a surrogate to compute the TLR based on data demonstrating the
amount of pollutant associated with TSS particulates.
The following approach was implemented to calculate a TLR for each organic pollutant
in the Peninsula Machado Lake WMA.
1. The analysis region was modeled in LSPC to obtain TSS load during water year
2010.
2. Particulate strength (organic-to-TSS ratio) for PCBs, DDT, total chlordane, and
dieldrin were calculated using paired wet weather monitoring data collected at
outfall monitoring within the Machado Lake and Wilmington Drain WMAs.
3. The baseline pollutant load was computed by multiplying the baseline TSS load
and the organic pollutant particulate strength.
4. An average baseline pollutant concentration was computed as the annual baseline
5. The allowable load was calculated as the sediment-based WQBEL multiplied by
the annual TSS load.
6. The difference between the baseline load and the allowable load resulted in a TLR
for water year 2010 was the load reduction required to meet the applicable water
quality standard.
7. A TLR equivalent 24-hour (daily) runoff management volume was estimated as
the following:
a. First, estimate the annually managed TSS load by dividing the TLR by the
particulate strength.
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b. Next, an in-stream diversion to a large hypothetical retention BMP with a
24-hour drawdown time at the outlet of analysis region was iteratively
sized until the diverted (and hence managed) TSS load equal to or greater
than the annually managed TSS load. The retention volume of this
hypothetical retention BMP was deemed as the 24-hour runoff
management volume. Both load-based TLR and the equivalent 24-hour
runoff management volume are considered eligible Peninsula EWMP
compliance metrics.
7.3. Wilmington Drain WMA
Wilmington Drain is an impaired waterbody that drains to Machado Lake. Hence,
WBPCs applicable to the Machado Lake WMA (trash, PCBs, DDT, total chlordane,
dieldrin, total nitrogen, and total phosphorus) are also applicable to the Wilmington Drain
WMA. In addition, Wilmington Drain is a 303(d) listed receiving water for bacteria (E.
coli), making this a Category 2 WBPC for the Wilmington Drain WMA.
Compliance with the Machado Lake Trash TMDL has been met through a phased retrofit
of catch basins throughout the Wilmington Drain WMA. Therefore, trash does not require
a TLR and was not modeled as part of the revised RAA. TLRs for the remaining
pollutants of concern were established using the calibrated WMMS 2.0 LSPC model.
While the model is only capable of modeling a subset of WBPCs directly, a justification
was provided to how the TLRs were developed for the other WBPCs in order to
demonstrate the attainment of water quality standards for all compliance targets
(SWRCB, 2020).
7.3.1. Nutrients
Due to inclusion in the Machado Lake Nutrients TMDL, total nitrogen and total
phosphorous are Category 1 WBPCs in Wilmington Drain. The same approach described
in Section 7.2.1 was used to establish TLRs and TLR-equivalent 24-hour runoff
management volumes for total nitrogen and total phosphorus.
7.3.2. Pesticides and PCBs
Due to inclusion in the Machado Lake Toxic TMDL, PCBs, DDT, total chlordane, and
dieldrin are Category 1 WBPCs in the Machado Lake WMA. The same calculation
approach described in Section 7.2.2 was used to determine TLRs and TLR-equivalent 24-
hour management volumes for PCBs, DDT, total chlordane, and dieldrin TLRs.
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7.3.3. Bacteria (E. coli)
Although Wilmington Drain is a 303(d)-listed waterbody for bacteria, modeling was not
conducted as part of the updated RAA due to the fact that the Wilmington Drain
watershed area will be fully captured and managed via 85th percentile regional projects.
If future bacteria modeling is conducted, it will account for the latest State Board
guidance regarding the statistical threshold value (STV) as well as local applications of
this standard.
7.4. Los Angeles Harbor WMA
Wet weather pollutants of concern in the Los Angeles Harbor watershed include PCBs,
DDT, total copper, total lead, total zinc, and PAHs. TLRs were established using the
calibrated Los Angeles Harbor LSPC model. While the model is only capable of
representing a subset of WBPCs directly, justification was provided to establish TLRs for
the other WBPCs in order to comply with the State Board’s requirement to demonstrate
the attainment of water quality standards for all compliance targets (SWRCB, 2020).
7.4.1. Metals
Due to inclusion in the Dominguez Channel and Greater Los Angeles Harbor Toxics and
Metals TMDL, total copper, total lead, and total zinc are considered Category 1 WBPCs
for the two Los Angeles Harbor waterbodies the Peninsula EWMP area drains to (Inner
Harbor and Cabrillo Marina). The final MS4 WLA in the TMDL are expressed in the
following three ways:
1. Annual loading of pollutants calculated as the California Toxics Rule (CTR)
saltwater chronic criteria-based water-column WQBEL concentration multiplied
by the average annual flow volume.
2. Annual loading of pollutants calculated as the sediment-based WQBELs
multiplied by the annual average TSS loading. The WQBEL is based on the Los
Angeles Region Water Quality Control Plan to address the TMDL. It is adopted
from the sediment numeric targets developed in the Screening Quick Reference
Tables (SQuiRTs) developed by National Oceanic and Atmospheric
Administration (NOAA).
3. Annual mass-based MS4 WLA apportioned to Peninsula WMG’s tributary areas
to the Los Angeles Harbor.
According to the MS4 Permit Attachment N, all three approaches are acceptable to
demonstrate TMDL compliance. Method 2 was used as the allowable load in subsequent
TLR calculations. The same calculation approach described in Section 7.2.2 was used to
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establish TLRs and TLR-equivalent 24-hour management volumes for total copper, total
lead, and total zinc, with one modification to Step 3. This modification did not require
development of particulate strengths as the metal loads can be directly represented in
WMMS 2.0 LSPC model.
7.4.2. Pesticides and PCBs.
Because of the Dominguez Channel and Greater Los Angeles Harbor Toxics and Metals
TMDL, PCBs, DDT, total chlordane, and dieldrin are defined as Category 1 WBPCs for
the two Los Angeles Harbor waterbodies draining the Peninsula EWMP area (Inner
Harbor and Cabrillo Marina). The same calculation approach described in Section 7.2.2
was used to establish TLRs and TLR-equivalent 24-hour management volumes for PCBs,
DDT, total chlordane, and dieldrin.
7.5. 85th Percentile, 24-Hour Design Storm Simulation
As an alternative path of demonstrating compliance with the MS4 Permit, the Peninsula
WMG evaluated the option of fully capturing the 85th percentile, 24-hour design storm
runoff from each WMA. The hydrology simulation was performed using the calibrated
Peninsula WMMS 2.0 LSPC model. LACFCD has included the 85th percentile design
storm hyetograph as part of the WMMS 2.0 database. The design storm depth for the
Peninsula WMG varies from 0.8 to 1.1 inches (LACDPW, 2006).
7.6. Interim and Final Wet Weather TLR Summary
Final TLRs were developed for each modeled pollutant using the established numeric
targets. TLRs are listed by analysis region for each modeled WBPC in Table 11. WBPCs
for both Machado Lake and Wilmington Drain are applicable to analysis regions in the
Wilmington Drain WMA (WD-1 and WD-Solano). WBPCs for the Machado Lake are
applicable to analysis regions in the Machado Lake WMA (ML-1). WBPCs for the Los
Angeles Harbor are applicable to the analysis regions of the Los Angele Harbor WMAs
and. Specifically, WBPCs are apportioned to the Inner Harbor (LAH-IH) and to Cabrillo
Marina (LAH-CM).
For the Machado Lake and Wilmington Drain WMAs, the calculation yielded zero total
PCBs TLRs in all analysis regions. This is consistent with the recent CIMP monitoring,
which showed no exceedance of total PCBs in the past five years. The calculation also
yielded zero total nitrogen TLRs for all analysis regions and yielded zero total phosphorus
TLRs for WD-Solano. A 1% total phosphorous TLR was calculated for ML-1 and a 14%
total phosphorus TLR was calculated for WD-1. The primary reason of the resultant zero
or little total nitrogen and total phosphors TLRs is the that the calibrated model, which
reflected Peninsula WMG’s watershed management over the past decade, significantly
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showed reduction in wet weather runoff and associated less total nitrogen and total
phosphorus load in comparison to the baseline condition used in the development of total
nitrogen and total phosphorus MS4 WLAs in the TMDL. For the non-zero TLRs in the
Machado Lake WMA, all the TLR-equivalent 24-hour management volumes are less than
the 85th percentile, 24-hour design storm runoff volume. As a result, the recommended
approach is to meet the final TLRs rather than trying to meet the full 85th percentile, 24-
hour design storm runoff capture alternative. For the Machado Lake analysis region, the
largest 24-hour management volume was selected as the target compliance metric, since
management of the largest volume will result in management of all others. For the
Wilmington Drain WMA, since bacteria was not modeled, and 85th percentile 24-hour
design storm capture projects are planned for both tributary analysis regions the full 85th
percentile, 24-hour runoff volume is shown as the compliance volume.
For analysis regions in the Los Angeles Harbor WMA, the 85th percentile, 24-hour design
storm runoff volume of each analysis region is less than the maximum TLR-equivalent
24-hour runoff management volumes in that analysis region. Therefore, the
recommended approach is to meet the full 85th percentile, 24-hour runoff capture
alternative.
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Table 11. Final Wet Weather Target Load Reduction Summary Subwatershed Analysis Region Pollutant Critical Condition Baseline Load
Final Target Load Reduction
Absolute
% of
Baseline
Load
TLR Equivalent
24-Hour
Management
Volume
(ac-ft) Machado Lake ML-1 Total PCBs Average Water Year 7.5E-04 lb/yr 0 lb/yr 0% 0.0
DDx (Total) Average Water Year 1.0E-03 lb/yr 9.0E-04 lb/yr 88% 1.3
DDT (All congeners) Average Water Year 1.2E-05 lb/yr 0 lb/yr 0% 0.0
DDE (All congeners) Average Water Year 6.4E-04 lb/yr 5.7E-04 lb/yr 89% 1.3[1]
DDD (All congeners) Average Water Year 6.3E-04 lb/yr 5.2E-04 lb/yr 82% 1.1
Total Chlordane Average Water Year 2.1E-04 lb/yr 1.3E-04 lb/yr 64% 0.7
Dieldrin Average Water Year 1.2E-05 lb/yr 0 lb/yr 0% 0.0
Total Nitrogen Average Water Year 119 lb/yr 0 lb/yr 0% 0.0
Total Phosphorus Average Water Year 38.4 lb/yr 0.4 lb/yr 1% 0.1
n/a 85th Percentile 24-Hour Storm 1.6 ac-ft 1.6 ac-ft 100% 1.6 Machado Lake - Wilmington Drain WD-1 Total PCBs Average Water Year 3.6E-03 lb/yr 0 lb/yr 0% 0.0
DDx (Total) Average Water Year 4.9E-03 lb/yr 4.3E-03 lb/yr 88% 7.4
DDT (All congeners) Average Water Year 6.0E-05 lb/yr 0.0E+00 lb/yr 0% 0.0
DDE (All congeners) Average Water Year 3.1E-03 lb/yr 2.7E-03 lb/yr 89% 7.4
DDD (All congeners) Average Water Year 3.1E-03 lb/yr 2.5E-03 lb/yr 82% 6.2
Total Chlordane Average Water Year 9.9E-04 lb/yr 6.3E-04 lb/yr 64% 4.2
Dieldrin Average Water Year 5.6E-05 lb/yr 0 lb/yr 0% 0.0
Total Nitrogen Average Water Year 1510 lb/yr 0 lb/yr 0% 0.0
Total Phosphorus Average Water Year 346 lb/yr 47.2 lb/yr 14% 0.6
n/a 85th Percentile 24-Hour Storm 8.01 ac-ft 8.01 ac-ft 100% 8.0[1] WD-Solano Total PCBs Average Water Year 2.07E-04 lb/yr 0 lb/yr 0% 0.0
DDx (Total) Average Water Year 2.84E-04 lb/yr 2.5E-04 lb/yr 88% 0.5
DDT (All congeners) Average Water Year 3.47E-06 lb/yr 0 lb/yr 0% 0.0
DDE (all congeners) Average Water Year 1.77E-04 lb/yr 1.6E-04 lb/yr 89% 0.5
DDD (All congeners) Average Water Year 1.76E-04 lb/yr 1.4E-04 lb/yr 82% 0.4
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Final Target Load Reduction
Absolute
% of
Baseline
Load
TLR Equivalent
24-Hour
Management
Volume
(ac-ft)
Total Chlordane Average Water Year 5.72E-05 lb/yr 3.6E-05 lb/yr 64% 0.3
Dieldrin Average Water Year 3.21E-06 lb/yr 0 lb/yr 0% 0.0
Total Nitrogen Average Water Year 42 lb/yr 0 lb/yr 0% 0.0
Total Phosphorus Average Water Year 9 lb/yr 0 lb/yr 0% 0.0
n/a 85th Percentile 24-Hour Storm 0.57 ac-ft 0.57 ac-ft 100% 0.6[1] Los Angeles Harbor LAH - IH Total Copper Average Water Year 8.1 lb/yr 4.5 lb/yr 55% 2.2[2]
Total Lead Average Water Year 1.7 lb/yr 0 lb/yr 0% 0.0
Total Zinc Average Water Year 33.5 lb/yr 17.4 lb/yr 52% 2.0
4,4'-DDT Average Water Year 1.3E-05 lb/yr 0 lb/yr 0% 0.0
DDx (Total) Average Water Year 4.7E-03 lb/yr 4.6E-03 lb/yr 96% 10.4
Total PCBs Average Water Year 3.5E-03 lb/yr 1.0E-03 lb/yr 30% 0.9
Total PAHs Average Water Year 4.4E-01 lb/yr 9.8E-03 lb/yr 2% 0.1
n/a 85th Percentile 24-Hour Storm 5.4 ac-ft 5.4 ac-ft 100% 5.4[1] LAH-CM Total Copper Average Water Year 1.8 lb/yr 0.87 lb/yr 49% 0.5[2]
Total Lead Average Water Year 0.4 lb/yr 0 lb/yr 0% 0.0
Total Zinc Average Water Year 8.2 lb/yr 4.1 lb/yr 50% 0.5
4,4'-DDT Average Water Year 3.3E-06 lb/yr 0 lb/yr 0% 0.0
DDx (Total) Average Water Year 1.2E-03 lb/yr 1.2E-03 lb/yr 96% 2.8
Total PCBs Average Water Year 8.8E-04 lb/yr 2.6E-04 lb/yr 30% 0.3
Total PAHs Average Water Year 1.1E-01 lb/yr 2.5E-03 lb/yr 2% 0.1
n/a 85th Percentile 24-Hour Storm 1.5 ac-ft 1.5 ac-ft 100% 1.5[1]
[1] Bold value is the representative 24-hour management runoff volume for each analysis region. For WD-1 and WD-Solano, the 85th percentile, 24-hour storm volume is
selected since bacteria was not modeled.
[2] TLR for Total Copper does not account for expected reductions over time due to copper brake pad phase-outs in California. See Section 8.2.1.
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To demonstrate compliance with interim TMDL WLAs, interim TLRs were developed
for Category 1 pollutants that have non-zero TLRs as shown in as summarized in Table
11. No interim TLRs were developed for pollutants without an interim TMDL numeric
target. The resultant interim TLRs are summarized in Table 12.
As shown in the table, the calculation yielded zero interim TLRs for all analysis regions
in the Machado Lake and Wilmington Drain WMA. For analysis regions in the Los
Angele Harbor WMA, no RAA is required to demonstrate compliance with the interim
MS4 WLA because receiving water monitoring shows the 3-year average pollutants are
below the RWLs at Inner Harbor and Cabrillo Marina for all pollutants of concern
(Anchor QEA, 2019).
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Table 12. Interim Wet Weather Target Load Reduction Summary WMA Analysis Region Pollutant Critical Condition Baseline Load Allowable
Interim Load
Interim Target Load
Reduction
TLR
Equivalent
24-Hour
Management
Volume (ac-
ft)
Absolute
% of
Baseline
Load Machado Lake ML-1 Total Nitrogen Average Runoff Year Final TLR = 0%, hence RAA achieved
Total Phosphorus Average Runoff Year 38.4 lb/yr 475 lb/yr 0 lb/yr 0% 0.0 Machado Lake - Wilmington Drain WD-1 Total Nitrogen Average Runoff Year Final TLR = 0%, hence RAA achieved
Total Phosphorus Average Runoff Year 346 lb/yr 3,731 lb/yr 0 lb/yr 0% 0.0 WD -Solano Total Nitrogen Average Runoff Year Final TLR = 0%, hence RAA achieved
Total Phosphorus Average Runoff Year Final TLR = 0%, hence RAA achieved Los Angeles Harbor LAH - IH Total Copper
Receiving water monitoring shows compliance with all interim RWLs. Hence no RAA needed.
Total Lead
Total Zinc
DDx (Total)
Total PCBs
Total PAHs LAH-CM Total Copper
Receiving water monitoring shows compliance with all interim RWLs. Hence no RAA needed
Total Lead
Total Zinc
DDx (Total)
Total PCBs
Total PAHs
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8. STORMWATER CONTROL OVERVIEW
8.1. Methods to Select and Prioritize BMPs
To demonstrate reasonable assurance, dry weather and stormwater runoff BMPs were
identified in a prioritized manner to meet the TLRs. Prioritization was based on cost (low-
cost BMPs were prioritized first); BMP effectiveness for the pollutants of concern (BMPs
that had greater treatment efficiency for the pollutant of concern in a particular analysis
region were prioritized over other BMPs); and implementation feasibility as determined
by the Peninsula WMG.
Because recent monitoring data was used during calibration, it was assumed that the
calibrated baseline model effectively accounted for existing BMPs that were already
present in the Peninsula EWMP area (e.g., implementation of street sweeping, catch basin
and storm drain cleaning, and low impact development projects completed prior to June
2020, etc.). Since drainage area to the monitoring location utilized for hydrology and
water quality calibration does not contain any existing regional stormwater BMPs or
green streets, the effects of regional or green street BMPs were not used for calibration.
The performance of existing, location specific regional BMPs has been quantified in this
revised RAA.
The RAA was performed according to the following steps:
1. Calculate load reductions associated with existing structural regional and
distributed BMPs;
2. Calculate load reductions for proposed regional and distributed BMPs that were
identified in existing plans; and
3. If necessary, identify additional BMP capacity needed to meet any remaining TLR
for each analysis region.
8.2. Quantified Non-Structural BMPs
In accordance with the State Board Order (SWRCB, 2020), all non-structural BMP
credits are required to be adequately justified. Since data is limited with respect to load
reductions achieved by most non-structural BMPs, this revised RAA incorporated the
assumption that non-structural BMPs implemented prior to June 2020 (including
enhanced minimal control measures [MCMs]) have been accounted for as part of the data
used in the calibrated baseline condition. As a result, no “blanket” non-structural BMP
load reduction credit has been incorporated into the revised RAA.
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Source controls implemented by the Peninsula WMG included a combination of BMPs
such as new or enhanced pet waste controls (ordinance, signage, education/outreach, mutt
mitts, etc.), enhanced street sweeping (e.g., 100% vacuum sweepers, increased frequency,
posting of ‘No Parking’ signs for street sweeping, etc.), increased catch basin and storm
drain cleaning, and other new or enhanced non-structural BMPs that target the pollutants
addressed in the EWMP. Although no separate pollutant load reduction was calculated in
the RAA for the implementation of these BMPs, the RAA assumes that the Peninsula
WMG will continue to implement a variety of these targeted non-structural BMPs.
One specific non-structural regulatory BMP program was accounted for in this revised
RAA for which a load reduction could be quantified and forecasted based on phased
implementation – the elimination of copper in brake pads.
8.2.1. Copper Brake Pad Reduction
In 2010, California Senate Bill 346 (SB 346) was enacted to eliminate nearly all use of
copper in brake pad manufacturing. In 2013, TDC Environmental prepared a draft
detailed study for the California Stormwater Quality Association (CASQA) describing
the expected percent reduction for copper as a result of the passage of SB 346 (TDC
Environmental, 2013). The TDC study identified three possible implementation
scenarios, the least aggressive of which estimated that a 52% load reduction in copper
will be achieved by 2032 due to the brake pad phase-out.
Although there is an expectation that copper loads in urban runoff will decrease over time
as a result of SB 346, the updated RAA did not attempt to take credit for this load
reduction at this time. Following the collection of additional watershed-specific water
quality data in the future, adaptive management may be utilized by the Peninsula WMG
to update the TLR for copper and/or the load reductions expected to be achieved by this
source control program.
8.3. Representing Structural BMPs
To represent structural BMPs, WMMS 2.0 SUSTAIN was used to account for BMP
storage, infiltration, inflow, and outflow capacities using available BMP as-built
drawings or conceptual drawings provided by the Peninsula WMG. For structural BMPs
that provide flow-through treatment, the treatment efficacy was represented as either
fixed effluent concentration or as a percentage of influent concentration reduction
extracted from the following data sources:
• WMMS 2.0 Phase II Report: BMP Model and Optimization Framework
(LACFCD, 2020b), which includes effluent concentrations of BMPs included in
the default WMMS 2.0 SUSTAIN model.
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• The International Stormwater Database (IBMPDB; www.bmpdatabase.org),
which is a comprehensive source of BMP performance information, comprised of
data from a peer-reviewed collection of studies that have monitored the
effectiveness of a variety of BMPs in treating water quality pollutants for multiple
land use types.
8.3.1. Regional and Distributed Structural Projects
Through the project screening and evaluation process, a total of four regional projects and
four distributed projects were modeled in the RAA, Table 13 summarizes project types
and key modeling parameters. Project locations and tributary areas to these projects are
shown in Figure 8.
The following regional structural projects are planned to receive Peninsula WMG runoff
but were not modeled due to uncertainty of their future design and performance:
• Walteria Basin Special Study: Walteria Basin is a flood control basin that
receives runoff from 174 acres of drainage area (which includes 55 acres of
impervious area) from Palos Verdes Estates in analysis region WD-Solano. The
Peninsula WMG will continue working with LACFCD and the City of Torrance
to assess how the Walteria Basin can be utilized as part of a regional stormwater
capture project in conjunction with other regional projects in the Machado Lake
watershed to meet TLRs in the WD-Solano analysis region.
• Palos Verdes Multi-Benefit Flow Diversion Project. This project is currently
proposed as a dry weather flow management project within analysis region WD-
1. A wet weather flow management component will be further evaluated if
additional wet weather projects are required to meet the final TLR through the
Peninsula EWMP adaptive management process.
• Harbor City Park Stormwater Capture Project. This project is a signature
regional project proposed by the Dominguez Channel WMG. It is hydrologically
connected to the Torrance Airport Stormwater Capture Project and can potentially
capture and treat excess stormwater runoff from analysis region WD-1. The
Peninsula WMG is interested in collaborating with the Dominguez Channel
WMG to share in the benefits of reduced load if additional wet weather projects
are required to meet the final TLR through the Peninsula EWMP adaptive
management process.
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Figure 8. Modeled Regional and Distributed Projects
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Table 13. Summary of Modeled Project
Analysis
Region Project Lead WMG
Member BMP Type Drainage Area
(ac)
Impervious
Drainage
Area (ac)
BMP
Volume
(ac-ft)
Infiltration
/Treatment
Capacity
WD-1
Torrance Airport
Stormwater Basin
Project Phase II
Rancho Palos
Verdes and
Torrance[1]
Subsurface Detention &
Diversion to Sewer
74 (PVE) 15 (PVE)
21 2.2 cfs
678 (RPV) 263 (RPV)
1,113 (RHE) 539 (RHE)
441 (LAC) 112 (LAC)
Rolling Hills Road
Street Improvement
Rolling Hills
Estate Pervious Pavement 0.4 (RHE) 0.4 (RHE) 0.04 1 in/hr
ML-1
Casaba Estates LID Rolling Hills
Estate Surface Retention Basin 28 (RHE) 7 (RHE) 0.4 0.9 in/hr
Rolling Hills Country
Club Regional LID
Project – West
Rolling Hills
Estate
Surface Retention &
Infiltration Basin 358 (RHE) [2] 60 (RHE) 3.8 482 in/hr
Rolling Hills Country
Club Regional LID
Project – East
Rolling Hills
Estate
Surface Retention &
Infiltration Basin 51 (RHE) 2.0 (RHE) 0.7 1.3 in/hr
Palos Verdes Drive
East Street
Improvement
Rolling Hills
Estate Pervious Pavement 2.6 (RHE) 0.5 (RHE) 0.3 1 in/hr
LAH-IH Eastview Park
Regional Project
Rancho Palos
Verdes
Subsurface Retention,
Treatment and Diversion 345 (RPV) 123 (RPV) 1.2 0.6 cfs
[1]The Peninsula WMG has agreed to collaborate with City of Torrance to utilize this project to receive and manage stormwater runoff form Peninsula EWMP area.
[2]Does not include non-Peninsula EWMP drainage area.
PVE = Palos Verdes Estates; RPV = Rancho Palos Verdes; RHE = Rolling Hills Estates: LAC = Unincorporated Los Angeles County
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8.3.2. LID Redevelopment
The 2012 MS4 Permit established new criteria for redevelopment projects, requiring
certain sized projects to capture, retain, or infiltrate the 85th percentile, 24-hr design storm
or the 0.75-inch design storm, whichever is greater, or treat 150% of the peak stormwater
runoff rate resulting from a 1-year, 1-hour design storm, via the implementation of low
impact development (LID) BMPs. All LID BMPs constructed through June 2020 were
assumed to be accounted for in the model via the monitoring and calibration process.
Moving forward, LID was assumed to be implemented at the annual redevelopment rate
of 0.038% per year. In accordance with this redevelopment rate, which was summarized
in the 2019-20 Peninsula WMG Annual Watershed Report (Peninsula WMG, 2020),
redevelopment that is subject to an LID ordinance was modeled assuming an annual
redevelopment of 0.038% per year across all Peninsula WMG agency jurisdictions for
residential, commercial, industrial, institutional, and transportation land uses. To estimate
load reductions associated with these redevelopment BMPs, the land use percentages
were multiplied by the respective land use areas in each analysis region. This resulted in
a calculated area that would be treated by LID BMPs each year. This area was multiplied
by the applicable number of years until the TMDL final deadlines, as LID BMPs will be
implemented each year at the assumed rate. The total land use area assumed to be
redeveloped for each analysis region was then modeled as being treated by assumed
BMPs and the total load reduction was quantified.
To maintain consistency with the BMP types observed in redevelopment activities to-
date in the Peninsula EWMP area, 52% of the redeveloped land is projected to implement
bioretention or similarly functioning systems that fully capture the on-site 85th percentile,
24-hour storm runoff. The remaining 48% of the redeveloped area will implement
biofiltration systems that treat 1.5 times on-site 85th percentile 24-hour storm runoff.
Modeling parameters of the bioretention and biofiltration units are summarized in Table
14.
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Table 14. Redevelopment LID BMP Modeling Parameters
Bioretention Biofiltration
Max Years of
Redevelopment
Modeled
5 years[1] (Machado Lake and Wilmington Drain)
12 years[2] (Los Angeles Harbor)
Pond Depth 12 inches
Infiltration Rate 5 in/hr n/a
Soil Depth (in) 24
Effluent Concentration
Total Copper n/a 5.7 ug/L[3]
Total Lead n/a 0.32 ug/L[3]
Total Zinc n/a 12 ug/L[3]
TSS n/a 10 mg/L[3]
E. coli n/a See footnote 4
1 5 years was assumed based on the expected coverage length of the MS4 Permit.
2 Based on the effect year of the final Dominguez Channel and Los Angeles Harbor Toxic
TMDL (2032).
3 Default WMMS 2.0 SUSTAIN Parameter for Biofiltration BMP (LACFCD, 2020b)
4 It is assumed that biofiltration BMP does not provide significant E. coli treatment.
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9. WET WEATHER RAA RESULTS
9.1. Machado Lake WMA
Load reduction calculations for the Machado Lake WMA (analysis region ML-1) are
summarized in Table 15. Through the RAA, the collective load reductions achieved by
all existing and proposed BMPs were equal to or greater than all the TLRs within the
analysis region. Hence, reasonable assurance was demonstrated.
As discussed in Section 7, a TLR-equivalent 24-hour stormwater management volume
was computed for each non-zero TLR. Through the RAA, the 24-hour management
volume achieved by a project was computed as the representative volume apportioned to
the load reduction that was or would be achieved by the project. The resultant 24-hour
management volume of a project may or may not be equal to its static detention capacity
shown in Table 13. The approach of tying the 24-hour management volume metric to
TLR result in prioritizing more efficient BMPs that provide more load reduction per BMP
capacity. The 24-hour management volume of each project, and the cumulative 24-hour
management volume achieved by all projects, are shown in Figure 9. As shown in the
figure, for each analysis region, the cumulative 24-hour management volume achieved
by all projects exceed the maximum 24-hour management need in each analysis region.
Hence, reasonable assurance was also demonstrated throughout the Machado Lake WMA
using the 24-hour runoff volume as the compliance metric.
To spatially represent the RAA output, the 24-hour management volume is illustrated in
Figure 10. The 24-hour management volume of a regional project was reflected to its
drainage area. In addition to the existing and proposed projects discussed in Section 8.3.1,
two additional projects (ML-1 RHE Project and ML-1 RPV Project) were necessary to
meet the 24-hour management volume requirement. Although these two projects were
not explicitly modeled in the RAA, they are intended to manage drainage areas that do
not drain to modeled projects (i.e. non-horizontally shaded area) in Figure 10 and provide
the 24-hour management volume specified in Figure 9.
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Table 15. Peninsula Machado Lake WMA (ML-1) RAA Summary Analysis Region Pollutant
Final Target Load
Reduction
BMP Load Reduction Summary
LID Redevelopment Regional Projects[2] Distributed Projects Total Load Reduction Assurance Achieved? Absolute % Absolute % Absolute % Absolute % Absolute % ML-1a Total PCBs 0 lb/yr 0% TLR = 0%, hence no RAA needed to demonstrate compliance n/a
DDx (Total) 9.0E-04 lb/yr 88% 2.3E-06 lb/yr 0.2% 8.8E-04 lb/yr 85% 3.1E-05 lb/yr 3.0% 9.0E-04 lb/yr 88% Yes
DDT (All
congeners) 0 lb/yr 0% TLR = 0%, hence no RAA needed to demonstrate compliance n/a
DDE (all
congeners) 5.7E-04 lb/yr 89% 1.4E-06 lb/yr 0.2% 5.5E-04 lb/yr 85% 1.9E-05 lb/yr 3.0% 5.7E-04 lb/yr 89% Yes
DDD (All
congeners) 5.2E-04 lb/yr 82% 1.4E-06 lb/yr 0.2% 5.1E-04 lb/yr 79% 1.9E-05 lb/yr 3.0% 5.2E-04 lb/yr 82% Yes
Total
Chlordane 1.3E-04 lb/yr 64% 4.6E-07 lb/yr 0.2% 1.3E-04 lb/yr 63% 6.2E-06 lb/yr 3.0% 1.4E-04 lb/yr 66% Yes
Dieldrin 0 lb/yr 0% TLR = 0%, hence no RAA needed to demonstrate compliance n/a
Total
Nitrogen 0 lb/yr 0% TLR = 0%, hence no RAA needed to demonstrate compliance n/a
Total
Phosphorus 0.4 lb/yr 1% 0.1 lb/yr 0.2% 24.4 lb/yr 63% 1.1 lb/yr 2.9% 25.6 lb/yr 67% Yes
24-Hour
Management
Volume[1]
1.3[3] ac-ft 100% 0.003 ac-ft 0.2% 1.25 ac-ft 96% 0.04 ac-ft 0.4% 1.3 ac-ft 100% Yes
[1] The 24-hour management volume is the equivalent runoff management volume that will achieve all TLRs. It does not necessarily equate to BMP capacity. A project
located at analysis region outlet may have more 24-hour management capacity than a project with same BMP capacity but is located further upstream in the analysis
region. The 24-hour management volume of a project needs to be computed via a continuous modeling simulation using the calibrated Peninsula EWMP WMMS 2
model
[2] Regional projects include existing and proposed projects discussed in Section 8.3.1 and the estimated benefit of the additional project (ML-1 RHE Project and ML-
1 RPV Project)
[3] Please see Section 7.6 and Table 11 on how the representative 24-hour management volume was selected for each analysis region.
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Note:
RPV = Rancho Palos Verdes; RHE = Rolling Hill Estates
Due to comparatively low volumes, LID redevelopment is not shown in the figure
Figure 9. 24-Hour Management Volume Breakdown in Machado Lake WMA
(ML-1)
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Figure 10. 24-Hour Management Volume Status in Machado Lake WMA (ML-1).
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9.2. Wilmington Drain WMA
As discussed in Section 7.6, the 85th percentile, 24-hour storm runoff volume was
determined as the compliance metric for the Peninsula Wilmington Drain subwatershed
(analysis regions WD-1 and WD-Solano). To demonstrate reasonable assurance, the
cumulative 24-hour management capacity of planned stormwater control measures shall
be equal to or greater than the 85th percentile, 24-hour storm runoff volume for each
analysis region.
The 24-hour management capacity of the existing and planned stormwater control
measures are summarized in Table 16. The 24-hour management volume breakdown by
project category and Peninsula WMG agency is shown in Figure 11. To spatially
represent the RAA output, the 24-hour management volume is also illustrated in Figure
12 where the 24-hour management volume of a regional project was reflected to its
drainage area. For analysis region WD-Solano, the Peninsula WMG will continue to work
with LACFCD and the City of Torrance to assess how the Walteria Basin can be utilized
as a part of a regional stormwater capture project. The combination of these controls will
be designed to achieve the TLRs in the WD-Solano analysis region in the areas without
existing projects as shown in Figure 12.
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Table 16. Peninsula Wilmington Drain WMA RAA Summary Analysis Region 85th Percentile
24-Hour Runoff
Volume
BMP Load Reduction Summary
LID Redevelopment Regional Project Distributed Project Total Load Reduction RAA Achieved? Absolute % Absolute % Absolute % Absolute %
WD-1 8.0 [1] ac-ft 100% 0.02 ac-ft 0.6% 8.0 ac-ft 100% <0.01 ac-ft 0% 8.0 ac-ft 100% Yes
WD-
Solano 0.6[1] ac-ft 100% <0.01 ac-ft 0.5% 0.6[2] ac-ft 100% 0 ac-ft 0% 0.6 ac-ft 100% Yes
[1]Please see Section 7.6 and Table 11 on how the representative 24-hour management volume was selected for each analysis region.
[2] Includes the Walteria Basin Special Study for analysis region WD-Solano. It is assumed that the Peninsula WMG will continue working with LACFCD
and City of Torrance to assess how the Walteria Basin can be utilized as part of a regional stormwater capture project in conjunction with other regional
projects in the Wilmington subwatershed to meet TLRs in the WD-Solano analysis region.
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Note:
PVE = Palos Verdes Estates; RPV =Rancho Palos Verdes; RHE = Rolling Hills Estates. LAC = Unincorporated Los
Angeles County
Due to comparatively low volumes, LID redevelopment distributed projects are not shown in the figure
Figure 11. 24-Hour Management Volume Breakdown in Wilmington Drain WMA
(WD-1 and WD-Solano)
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Figure 12. 24-Hour Management Volume Mapping in Wilmington Drain WMA
(WD-1 and WD-Solano)
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9.3. Los Angeles Harbor WMA
As discussed in Section 7.6, the 85th percentile, 24-hour storm runoff volume was
determined as the compliance metric for the Peninsula Los Angeles Harbor WMA
(analysis regions LAH-IH and LAH-CM). To demonstrate reasonable assurance, the
cumulative 24-hour management capacity of planned stormwater control measures shall
be equal to or greater than the 85th percentile, 24-hour storm runoff volume for each
analysis region.
The 24-hour management capacity of the existing and planned stormwater control
measures are summarized in Table 17. The 24-hour management volume breakdown by
project category and Peninsula WMG agency is shown in Figure 13. To spatially
represent the RAA output, the 24-hour management volume is also illustrated in Figure
14, where the 24-hour management volume of a regional project was reflected to its
drainage area.
As shown Figure 13 and Figure 14, three additional projects (LAH-IH RPV Project,
LAH-IH RHE Project and LAH-CM RPV Project) were necessary to fully capture the
85th percentile, 24-hour runoff from the non-horizontal shaded area shown in the figure.
The 24-hour management volume need of each of the additional projects is quantitatively
shown in Figure 13. As shown in Table 17, the cumulative management capacity of the
Eastview Park Regional Project, LID redevelopment and the three additional regional
projects are sufficient to fully capture the 85th percentile, 24-hour storm from both
analysis regions in the Los Angeles Harbor WMA. Hence, reasonable assurance is
demonstrated.
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Table 17. Peninsula Los Angeles Harbor WMA RAA Summary Analysis Region 85th Percentile
24-Hour Runoff
Volume
BMP Load Reduction Summary
LID Redevelopment Regional Project Distributed Project Total Load Reduction RAA Achieved? Absolute % Absolute % Absolute % Absolute %
LAH-
IH 5.4 [1] ac-ft 100% 0.03 ac-ft 0.6% 5.4 ac-ft 100% 0 ac-ft 0% 5.4 ac-ft 100% Yes
LAH-
CM 1.5[1] ac-ft 100% <0.01 ac-ft 0.5% 1.5 ac-ft 100% 0 ac-ft 0% 1.5 ac-ft 100% Yes
[1]Please see Section 7.6 and Table 11 on how the representative 24-hour management volume was selected for each analysis region.
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Note: RPV = Rancho Palos Verdes; RHE = Rolling Hill Estates
Due to comparatively low volumes, LID redevelopment is not shown in the figure
Figure 13. 24-Hour Management Volume Breakdown in Los Angeles Harbor
WMA.
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 52 May 2022
Figure 14. 24-Hour Management Volume in Peninsula LA Harbor WMA
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10. DRY WEATHER RAA RESULT
The dry weather RAA was completed in accordance with the approach outlined in Section
4.2. The Peninsula WMG has attempted to eliminate non-exempt dry weather MS4
discharges using a suite of structural BMPs and non-structural source controls (e.g., water
conservation incentives, enhanced IDDE efforts, enhanced education/outreach, and
inspection/enforcement to prevent sources of non-stormwater flow). To date, monitoring
has shown that the WMG has been successful in this endeavor, and successfully
eliminated most of the non-exempt dry weather flows. The Peninsula WMG plans to
capture and intercept the remaining dry weather flow with regional dry weather capture
projects, such as the Palos Verdes Peninsula Multi-Benefit Flow Diversion Project and
the Torrance Airport Stormwater Project. The analysis summary of dry weather flows is
shown in Table 18. A WMA-specific discussion of the dry weather RAA is presented in
the following subsections.
Table 18. Dry Weather RAA Summary
Watershed
Management
Area
Analysis
Region
Is non-exempt dry
weather flow
currently non-
existent and/or
sufficiently treated or
diverted?
Are sufficient
structural BMP
proposed to intercept,
treat or divert 100%
of dry weather
runoff?
Is dry weather
reasonable
assurance
demonstrated
through
monitoring?
Santa Monica
Bay All Yes n/a Yes
Machado Lake ML-1 Yes n/a Yes
Wilmington
Drain
WD-1 No Proposed Yes[1]
WD-Solano Yes n/a Yes
Los Angeles
Harbor LAH-IH Yes n/a Yes
LAH-CM Yes n/a Yes
[1] Assuming completion of the Palos Verdes Peninsula Multi-benefit Flow Diversion Project and/or the Torrance
Airport Stormwater Capture Project will sufficiently manage all dry weather flows.
10.1. Santa Monica Bay WMA
As shown in Section 2, dry weather pollutants of concern in the Santa Monica Bay WMA
include bacteria, trash and marine debris, PCBs, DDT, arsenic, and mercury.
For dry weather indicator bacteria in Santa Monica Bay, final compliance deadlines for
dry weather have passed. Therefore, a RAA is not required. However, the following
discussion is provided for informational purposes. Historic summer-dry and winter-dry
weather monitoring data at all Peninsula SMBBB compliance monitoring locations show
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 54 May 2022
water quality to be better than that of the reference beach based on long-term average
exceedance rates. Dry weather exceedance rates at these beaches have historically ranged
from 0 – 3% across both seasons. In addition, compliance monitoring locations SMB-7-
1 through SMB-7-5 are open beach sites located on segments of shoreline that have all
been removed from the States 303(d) list of impaired waterbodies, with no observed dry
weather discharges affecting water quality. Therefore, reasonable assurance of
compliance has successfully been demonstrated for this WBPC.
For DDT and PCBs, the annual TMDL based WLA accounts for both dry and wet
weather. As summarized in Section 7.1.2 Four complete years of nearshore receiving
water quality data have been collected under the Peninsula CIMP in the Santa Monica
Bay and analyzed for total DDT and PCBs. Only one (1) out of forty (40) samples or
2.5% resulted in detection of 4,4’- DDT at a concentration between the method detection
limit and the reporting limit. This sample was collected during a summer dry weather
sampling event in the fourth year of CIMP monitoring. None of the forty (40) receiving
water samples collected over the past four years have resulted in detections of Total PCBs
above the Ocean Plan objective for total PCBs. Therefore, dry weather reasonable
assurance is demonstrated.
As discussed in Section 7.1.3, there’s no existing data or evidence tying arsenic and
mercury pollutants to MS4 discharges. Both pollutants have been added to the outfall
monitoring sites for the Santa Monica Bay in response to recent 303(d) listings, however
sufficient data are not yet available to support the dry weather RAA.
For trash and marine debris, compliance with the Santa Monica Bay Debris TMDL is
being met through a phased retrofit of catch basins throughout the Peninsula Santa
Monica Bay WMA along with source controls to meet the final compliance deadline.
In summary, reasonable assurance of compliance during dry weather is demonstrated for
the Peninsula Santa Monica Bay WMA.
10.2. Machado Lake WMA
As part of the Peninsula CIMP, the Peninsula WMG completed a non-stormwater runoff
source investigation study (Peninsula WMG, 2018). According to the study findings, no
dry weather flow is observed through Machado Lake WMA. Therefore, reasonable
assurance of compliance during dry weather is demonstrated for the Peninsula Machado
Lake WMA.
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10.3. Wilmington Drain WMA
According to non-stormwater runoff source investigation study findings, dry weather
flow is only observed in the WD-1 analysis region and has been determined to be
associated with natural flows, i.e., rising groundwater or springs entering the MS4. The
dry weather runoff and pollutants have been accounted for as part of the wet weather
RAA summarized in Section 9.2. In addition, Peninsula WMG has planned to intercept
and divert 100% of dry weather runoff draining to the WD-1 analysis region with the
Palos Verdes Peninsula Multi-benefit Flow Diversion Project and the Torrance Airport
Stormwater Capture project.
In summary, reasonable assurance of compliance during dry weather is demonstrated for
the Peninsula Wilmington Drain WMA.
10.4. Los Angeles Harbor WMA
The Peninsula WMG is addressing dry weather pollutants of concern in the Los Angeles
Harbor WMA via 100% non-exempt dry weather flow capture. As part of the Peninsula
CIMP, the Peninsula WMG have performed a non-stormwater runoff source investigation
study. According to the study findings, dry weather flow is not observed in both LAH-IH
and LAH-CM analysis regions. Therefore, reasonable assurance of compliance during
dry weather is demonstrated for Peninsula Los Angeles Harbor WMA.
11. BMP COST OPINION
The capital, operation and maintenance (O&M) and 20-year life-cycle costs of the
proposed projects were estimated for EWMP planning purposes. For the Torrance Airport
Stormwater Capture Project, the presented costs were extracted from the Safe Clean
Water Program Feasibility Study submitted in October 2020 (City of Torrance, 2020).
The cost of the remaining projects was estimated based on key modeling parameters using
the cost functions presented in the WMMS 2.0 Phase II Report (LACFCD, 2020c). The
cost functions are summarized in Table 19.
Table 19. WMMS 2.0 Cost Function
BMP Type BMP
Component
Capital
Cost[1]
Annual O&M
Cost[1] Life Cycle Cost[1]
Pervious Pavement $253(A) $5.1 (A) $253(A) + $5.1(A) (Yr)
Subsurface
Retention +
Infiltration
Diversion $7,000(In) $320(In) [$7000 + $12,000](A) +
$12.6(Vf) + $6,000(Yr) +
$320 (In)(Yr)
Pretreatment $12,000(In)
Storage $12.6(V) $6,000
Diversion $7,000(In) $320(In)
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 56 May 2022
BMP Type BMP
Component
Capital
Cost[1]
Annual O&M
Cost[1] Life Cycle Cost[1]
Subsurface
Retention +
Filtration
Pretreatment $12,000(In) [$7000 + $12,000](A) +
$12.6(Vf) + $6,000(Yr) +
$320 (In)(Yr) + [$177,000
+$70,000](Eff) + [$1,000 +
$3,000](Eff)*(Yr)
Storage $12.6(V) $6,000
Pump $177,000(Eff) $3,000(Eff)
Filtration $70,000(Eff) $1.000(Eff)
Subsurface
Retention +
Diversion to
Sewer
Diversion $7,000(In) $320(In) [$7000 + $12,000](In) +
$12.6(Vf) + $6,000(Yr) +
$320 (In)(Yr) + $177,000(Ps)
+ $3,000(Ps)(Yr)
Pretreatment $12,000(In)
Storage $12.6(V) $6,000
Pump $177,000(Ps) $3,000(Ps)
Sewer
Diversion $67,000
[1] A – BMP footprint in ft2; Eff – Treatment rate in cfs ; In – Inflow rate in cfs; Ps – Sewer diversion rate
in cfs; Vf – BMP storage capacity in ft3;
The resultant project costs are summarized in Table 20. The cost summary does not
include already-completed projects (Casaba Estates LID and Rolling Hills Country Club
LID) or projects that are not included in the RAA (Harbor City Stormwater Capture
Project). The cost of the Palos Verdes Peninsula Multi-benefit Flow Diversion Project
will be determined as part of the Project’s Safe, Clean Water Program Feasibility Study.
Table 20. Project Cost Opinion Summary
Analysis
Region Lead Agency Project Capital
Annual
O&M
Cost
20-Year Life
Cycle Cost
ML-1 Rolling Hills
Estates
Palos Verdes Drive East Street
Improvement $2,859,000 $58,000 $4,012,000
ML-1 Rolling Hills
Estates ML-1 RHE Regional Project $254,000 $40,000 $1,060,000
ML-1 Rancho Palos
Verdes ML-1 RPV Regional Project $30,000 $40,000 $821,000
WD-1
Rancho Palos
Verdes and
Torrance
Torrance Airport Stormwater
Basin Project Phase 2 $12,000,000 $118,000 $13,700,000
WD-1 Rolling Hills
Estates
Rolling Hills Road Street
Improvement $481,000 $10,000 $675,000
LAH-IH Rancho Palos
Verdes Eastview Park $781,000 $42,000 $1,619,000
LAH-IH Rolling Hills
Estates LAH-IH RHE Regional Project $2,308,000 $47,000 $3,241,000
LAH-IH Rancho Palos
Verdes LAH-IH RPV Regional Project $540,000 $41,000 $1,363,000
LAH-CM Rancho Palos
Verdes LAH-CM RPV Regional Project $913,000 $9,000 $968,000
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 57 May 2022
12. CONCLUSIONS
To update the RAA for the revised Peninsula EWMP, a modeling approach that utilizes
WMMS 2.0 has been applied using the rationale, analytical basis, and process described
in this RAA report. The RAA process:
1. Applied an acceptable model tailored to the Peninsula WMG based on available
outfall and receiving water data collected through June 2020.
2. Calculated target load reductions (TLRs) necessary to achieve applicable
compliance targets.
3. Demonstrated that the existing and proposed suite of projects will attain the TLRs.
Where this was not demonstrated, volumetric management needs have been
documented to show what needs to be achieved in order to demonstrate
compliance.
The revised and updated Peninsula RAA therefore meets the objectives and requirements
of the LA MS4 Permit and RAA Guidance Document, demonstrating that a reasonable
assurance of compliance will be achieved in each analysis region if the TLRs are fully
and appropriately managed.
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Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 58 May 2022
13. REFERENCES
LACDPW (Los Angeles County Department of Public Works). 2011. Machado Lake
Nutrient TMDL Special Study: Characterization of Water Quality Conditions in the
Unincorporated Areas of Los Angeles County within the Machado Lake Watershed Final
Report. September.
LACDPW. 2006. Los Angeles County Hydrology Map. Accessed January 2021 from
<link>
LACFCD (Los Angeles County Flood Control District). 2020a. WMMS 2.0 Average and
90th Percentile Water Year Simulation. Accessed December 2020 from <link>
LACFCD. 2020b. WMMS 2.0 Phase II Report: BMP Model and Optimization
Framework. Accessed December 2020 from <link>
LACFCD. 2020c. WMMS 2.0 Average & 90th Percentile Water Year. Accessed January
2021 from <link>
LARWQCB (Los Angeles Regional Water Quality Control Board). 2010. Machado Lake
Nutrient TMDL – Conditional Approval of the Special Study Work Plan for the
Unincorporated Areas of Los Angeles County within the Machado Lake Watershed. May.
LARWQCB (Los Angeles Regional Water Quality Control Board). 2012. Attachment A
to Resolution No. R12-009. Amendment to the water quality control plan for the Los
Angeles Region to revise the TMDL for bacteria in the Malibu Creek Watershed. Adopted
June 7.
LARWQCB (Los Angeles Regional Water Quality Control Board). 2014a. Guidelines
for Conducting Reasonable Assurance Analysis in a Watershed Management Program,
Including an Enhanced Watershed Management Program. Los Angeles, CA.
LARWQCB (Los Angeles Regional Water Quality Control Board). 2014b. Water Quality
Control Plan: Los Angeles Region Basin Plan for the Coastal Watersheds of Los Angeles
and Ventura Counties. Accessed January 2021 from <link>.
Peninsula WMG (Watershed Management Group). 2020. Annual Watershed Report –
Reporting Year 2019 – 20. December.
Peninsula WMG (Watershed Management Group). 2018. Non-Stormwater Outfall
Screening and Source Investigation Report. November.
280
Peninsula_Appendix 4.1 Reasonable Assurance Analysis_clean 59 May 2022
SWRCB (State Water Resources Control Board). 2020. In the Matter of Review of
Approval of Watershed Management Programs and an Enhanced Watershed
Management Program Submitted Pursuant to Los Angeles Regional Water Quality
Control Board Order R4-2012-0175. SWRCB/OCC FILES A-2386, A-2477 & A-2508.
Sacramento, CA.
TDC Environmental, 2013. Estimate of Urban Runoff Copper Reduction in Los Angeles
County from the Brake Pad Copper Reductions Mandated by SB 346. Prepared for
Richard Watson & Associates, Inc.
281
Attachment A
Supplementary Calibration Exhibits
282
E. Coli
Total Suspended Solids
283
Total Copper
Total Lead
284
Total Zinc
Total Phosphorus
285
Total Nitrogen
286
Appendix 4.2
Requirements for Achieving Receiving Water
Limits
287
Palos Verdes Peninsula
Enhanced Watershed Management Program
Appendix 4.2-1 | Page
APPENDIX 4.2 REQUIREMENTS FOR ACHIEVING RECEIVING WATER
LIMITS FOR POLLUTANT CATEGORIES
Provisions of the MS4 Permit describe how compliance with receiving water limits (RWLs) are to be
attained for various water body-pollutant combinations (WBPC) identified through adaptive management
of the EWMP. Requirements for achieving RWLs for each priority pollutant category is described in the
following sections.
WBPCS ADDRESSED BY A TMDL (CATEGORY 1 POLLUTANTS)
For WBPCs addressed by a TMDL, adherence to all requirements and compliance dates set forth in the
approved EWMP will constitute compliance with applicable interim TMDL-based water quality-based
effluent limits and interim receiving water limits outlined in the Permit. Most of the WBPCs addressed
through a TMDL have corresponding interim and/or final compliance milestones that fall within the term
of the Permit. However, there are a few WBPCs being addressed by a TMDL for which interim compliance
milestones need to be developed within the term of the Permit. Table 5-2 summarizes the applicable
TMDL compliance dates and those that have been developed for the EWMP.
During the adaptive management process, if a WBPC within the Peninsula WMG is added to the State’s
303(d) list that falls within the same class as those being addressed by a TMDL, the WBPC will be added
to the list of Water Quality Priorities and the following actions will be completed following Permit
provisions:
• It will be demonstrated that Watershed Control Measures (WCMs) selected to achieve the applicable
TMDL provisions will also adequately address MS4 contributions of the pollutant(s) within the same
class. Assumptions and requirements of the corresponding TMDL provisions must be applied to the
additional pollutant(s), including interim and final requirements and deadlines for their achievement,
such that the MS4 discharges of the pollutant(s) will not cause or contribute to exceedances of
receiving water limitations.
• The WBPC will be included in the revised Reasonable Assurance Analysis (RAA).
• Dates for their achievement will be developed consistent with those in the applicable TMDL.1
303(D) LISTED WATER BODY POLLUTANT COMBINATIONS (CATEGORY 2 POLLUTANTS)
Currently, indicator bacteria (E. coli) in the Wilmington Drain Subwatershed, in addition to Arsenic and
Mercury in Santa Monica Bay Subwatershed, are the only 303(d)-listed pollutants within the Peninsula
WMG that are not being addressed by a TMDL. These WBPCs are not in the same class as any existing
TMDL within the Dominguez Channel or Santa Monica Bay Watershed Management Area portions of the
Peninsula EWMP Area. Although a definitive linkage between indicator bacteria in Wilmington Drain and
MS4 discharges from the Peninsula WMG has not been demonstrated, the MS4 system may cause or
contribute to this impairment. Mercury and arsenic were recently added to the 303(d) list for Santa
Monica Bay based on sediment and fish tissue data collected under the Hyperion Treatment Plant NPDES
Permit no. CA0109991 between January 2006 and June 2010. There’s no existing data or evidence tying
1 The Peninsula WMG has requested modification of the Machado Lake Nutrient TMDL deadline. That request is
pending.
288
Palos Verdes Peninsula
Enhanced Watershed Management Program
Appendix 4.2-2 | Page
either of these pollutants to stormwater MS4 discharges. No modeling was conducted within the Santa
Monica Bay WMA for the updated RAA, as reasonable assurance of compliance is already demonstrated
via monitoring data. Therefore, the following actions have been completed as part of the EWMP to
address indicator bacteria in Wilmington Drain, in addition to Arsenic and Mercury in Santa Monica Bay:
• WBPC (indicator bacteria) was included in the RAA.
• WCMs were selected to address contributions of indicator bacteria from MS4 discharges coming from
the Peninsula WMG, such that these MS4 discharges will not cause or contribute to the exceedance
of the receiving water limits coliform bacteria.
• Milestones and dates for BMP implementation have been identified to control MS4 discharges such
that they do not cause or contribute to exceedances of receiving water limitations within a timeframe
that is as short as practicable, taking into account the technological, operational, and economic factors
that affect the design, development, and implementation of the WCMs that are necessary.
• Milestones relate to a specific water quality endpoint (e.g., percent load reduction) and dates relate
either to taking a specific action or meeting a numeric water quality endpoint.
• If the identified dates are beyond the term of the Permit, the following will apply per Permit
provisions:
o In drainage areas where retention of all nonstormwater runoff and all stormwater runoff from
the 85th percentile, 24-hour storm event will be achieved, efforts will continue to target
implementation of WCMs identified in the EWMP, including WCMs to eliminate nonstormwater
discharges that are a source of pollutants to receiving waters.
o For areas where retention of the volume described above is technically infeasible and where the
Regional Board determines that MS4 discharges cause or contribute to the water quality
impairment, development of a stakeholder-proposed TMDL may be initiated upon approval of the
EWMP. For MS4 discharges from these drainage areas to the receiving waters, any extension of
this compliance mechanism beyond the term of the Permit will be consistent with the
implementation schedule in a TMDL for the WBPC(s) adopted by the Regional Board.
N ON 303(D)-LISTED WATER BODY POLLUTANT C OMBINATIONS (CATEGORY 3 POLLUTANTS)
There have been no Category 3 Pollutants identified within the Peninsula WMG.
289
Agenda Item No.: 7.I
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH, CITY CLERK / EXECUTIVE ASSISTANT TO
CITY MANAGER
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:APPROVE ROLLING HILLS COMMUNITY ASSOCIATION'S
APPLICATION TO LOS ANGELES COUNTY DEPARTMENT OF PUBLIC
HEALTH FOR REPLACEMENT OF SEPTIC TANK SERVING THE MAIN
GATE AND AUTHORIZE CITY MANAGER TO SIGN
DATE:May 23, 2022
BACKGROUND:
In a letter dated April 11, 2022, the Rolling Hills Community Association (RHCA) requested to
install a new septic tank to service the Main Gate. The referenced letter noted that the
replaced septic tank would also serve the new kitchen and restroom proposed for the tennis
courts common area.
The RHCA leases the tennis courts, and the City Hall campus from the City. Per the lease
agreement, the RHCA maintain and operates the tennis courts. To replace the referenced
septic tank, located in the area adjacent to the guest lane approaching the Main Gate, a permit
is required from the Los Angeles County Department of Public Health. As the owner of the
property, RHCA is requesting that the City submit the required forms to the Los Angeles
County Department of Public Works to commence the permitting process. RHCA has a
contractor, Peninsula Septic Service on standby to implement the tank replacement upon
permit issuance.
The City and the RHCA planned separate projects at the tennis courts. The RHCA plans to
improve the common areas of the tennis courts to add amenities like a restroom, kitchen, and
a gazebo. To comply with the American with Disability Act (ADA), the City plans to bring the
walkways of the tennis courts to ADA standards. Over the last three years, these
improvements have been placed on hold.
The proposed amenities would add effluent to the existing septic tank and would trigger tank
replacement by the Los Angeles Department of Public Health. In light of the City's 8" sewer
main project, the RHCA decided to hold off on the septic tank replacement in the event that
that the City constructs the 8" line, the effluent from the proposed amenities could be
290
discharged to the sewer main instead of the septic tank.
The 8" sewer main has been in the design phase for the past 12 months and at the January
2022 City Council Strategic Planning Session, the City Council decided not to dedicate
General Fund to construct the 8" sewer main line. Instead, the City Council discussed pursing
grant funds for the project. In consideration of the City Council's actions, the RHCA decided to
revisit the septic tank replacement project.
At the May 9, 2022 City Council meeting, staff was directed to communicate with the RHCA
that the Council was in support and requested a copy of the latest plans including the location
of the new septic tank.
DISCUSSION:
The RHCA has provided their application including plans as requested. It is attached for
Council's review.
FISCAL IMPACT:
There is no fiscal impact to complete the permitting forms requested by the RHCA.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
CL_AGN_220523_RHCA_LACoDPH_Application_Septic.pdf
CL_AGN_220523_RHCA_GeoTech_Septic.pdf
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
312
313
314
315
316
317
318
319
320
321
322
Agenda Item No.: 7.J
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH,
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:ACCEPT EMERGENCY STORM DRAIN REPAIR AT 1 MIDDLERIDGE
LANE NORTH AS COMPLETE, FILE NOTICE OF COMPLETION, AND
RELEASE RETENTION AFTER 30 DAY LIEN PERIOD TO EC
CONSTRUCTION
DATE:May 23, 2022
BACKGROUND:
On December 30, 2021, the easement adjacent to Middleridge Lane South developed multiple
sinkholes during a storm event. As a result the RHCA contacted LA County Department of
Public Works (LACDPW) on January 3, 2022 to request assistance and repair. On January 6,
2022, LACDPW informed the RHCA and City that they had found documentation confirming
that the City of Rolling Hills was responsible for maintenance of the subject drain via a 1972
signed agreement between the Los Angeles County Flood Control District and the City. On
January 9, 2022 the City Manager sent an email update to the Council and adjacent neighbors
updating them on the above and the steps being taken to address the issues. While the city
initially tried to engage LA County through our General Services agreement, they were unable
to commit time and resources due to extenuating circumstances including lack of manpower
due to COVID-19 and other emergency projects.
Staff contacted private contractors who visited the site and provided feedback on repair scope
of work, schedule, and cost. In the meantime, the RHCA, in anticipation of projected rain
directed staff to place sandbags and tarp over the sink holes. Staff also received a phone call
from the resident at 1 Middleridge Lane North regarding potentially related concerns.
On Tuesday, January 18, 2022, EC Construction (ECC) was on site to investigate as to
whether the broken drainpipe was the cause of the upper sinkhole and determine a more clear
scope of work. The coupling (pipe connector) was the issue at the upper and lower sinkholes.
During this visit ECC also visited 1 Middleridge Lane North at staff request due to assess
potential stormwater drain issues in the canyon. At that time, it was challenging for them to
ascertain what exactly might be happening in the canyon and so direction was focused on the
more imminent sinkhole issues at 1 Middleridge Lane South.
323
On Monday, January 24, 2022, the City Council unanimously adopted Resolution No. 1287,
directed the City Attorney to draft a construction contract with ECC and authorized the City
Manager to execute. On Monday, February 7, 2022, the final executed contract was received
and work commenced thereafter. On Tuesday February 8, 2022, ECC took a second look at 1
Middleridge Lane North and reported that there was a sinkhole in the resident's yard coming
from a stand pipe with a metal cover. The 24" Corrugate Metal Pipe (CMP) empties in the
aforementioned canyon. ECC advised the resident, that if the resident's grounds crews could
hand dig around the sinkhole and expose the CMP- they could return in few days to provide
some insight into what might be required to address. On February 9, 2022, the resident at 1
Middleridge Lane North contacted staff to follow-up on their concerns.
Work at 1 Middleridge Lane South was completed on Friday, February 11, 2022. At this time
ECC was able to gain further insight into the potential issues and found the bottom of the CMP
was gone and water was eroding the dirt under the CMP, causing it to collapse and create the
sink hole. The catch basin in the street at the intersection of Middleridge Lane North & South
was determined to be the source of water flowing through the CMP on the property. The exit
point is down the canyon between 1 Middleridge North and the property to the North. ECC
pointed out that this was a much more difficult repair because of the terrains as well as the
trees / vegetation requiring removal in order to replace the CMP.
ON March 14, 2022, the City Council passed Resolution 1293 directing the City Attorney to
draft a construction contract and authorizing the City manager to execute, approve the
resolution for emergency work, and appropriate $48,645 from the General Fund Reserves to
Fund 40 for the repair.
DISCUSSION:
The work completed and originally described ECC's estimate to repair the issue was as
follows:
1. Remove existing vegetation as required to access damaged pipe.
2. Excavate dirt and remove approx 100 LF of existing 24” CMP.
3. Install 100 LF of new 24” CMP.
4. Backfill pipe with 1 sack slurry, 1’ over new pipe, backfill the remaining with dirt to finish
grade.
FISCAL IMPACT:
The repair to the storm drain line was an unexpected expense and not budgeted in the FY
2021-2022 adopted budget.
The final cost was $47,028.56 which includes an additional $4728.56 for the breaking and
removal of four concrete encasements surrounding the old CMP Pipe that were found during
the work and not included as part of the original estimate.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
PW_STW_220303_SDRepair_1MiddleridgeLaneN.pdf
PW_STW_220418_MiddleridgeLaneN_INV 19092_revised.pdf
PW_STW_220430_MiddleridgeLaneN_Inv 19111_Retention.pdf
324
PW_STW_220418_MiddleridgeLaneN_CP_Release.pdf
325
BID PROPOSAL AND CONTRACT
2213 CHICO AVE./SO. EL MONTE, CA 91733
Phone: (626) 444-9596 Fax: (626) 444-3077
California Contractors License #366814
DATE: 3/3/2022
TO City of Rolling Hills JOB ADDRESS
2 Portuguese Bend Rd
Rolling Hills, CA 90274 1 Middleridge Lane N
We agree to furnish all labor, materials, equipment and supervision necessary to complete the f ollowing:
STORM DRAIN REPAIR
1. Remove existing vegetation as required to access damaged pipe.
2. Excavate dirt and remove approx 100 LF of existing 24” CMP.
3. Install 100 LF of new 24” CMP.
4. Backfill pipe with 1 sack slurry, 1’ over new pipe, backfill the remaining with dirt to finish grade.
COST……..$42,300.00
Note: The homeowner at 1 Middleridge Lane N had a photo of a concrete culvert that appeared to be in the
canyon between properties. This proposal does not include removing that structure or constructing a new
culvert.
Exclusions: permits, inspection fees, SWPPP plan, engineering, survey, relocation of underground utilities,
night or weekend work, concrete, slurry, and striping.
The above described work will be performed in a workman like manner and in accordance with standard practices.
TERMS: Unless credit arrangements have been made, in writing, in advance, the invoice for the work described herein is due and payable on
presentation. 1 ½ % per month will be charged on a daily basis on all accounts or portions thereof not paid within 10 days of the date of the invoice.
Customer agrees to pay reasonable attorney fees and collection costs incurred by E.C. Construction Co. for the collection of both principal and interest
due to customer’s failure to pay per this agreement.
Unless otherwise specified, if this proposal is not accepted within______30___________days from bid date, we reserve the right of cancellation.
APPROVE AND ACCEPTED Respectfully Submitted,
___________________________ E.C. CONSTRUCTION CO.
Date__________________20___ By_________________________
326
2213 CHICO AV ENUE
SOUTH EL MONTE, CA 91733
(626) 444-3077Fax:
E. C. CONSTRUCTION CO.
(626) 444-9596Phone:
Attn: Christian Horvath
2 PORTUGUESE BEND ROAD
ROLLING HILLS, CA 90274
CITY OF ROLLING HILLS
Contract3-21-22 5/18/2022
4/18/2022
19092
1 MIDDLERIDGE LANE N
ROLLING HILLS, CA 90274
STORM DRAIN REPAIR
220309
Our Job No Payment Terms Due Date
Description Price
Re:
Invoice
Invoice Number
Invoice Date
Bill To:
Contrs Lic # 366814
Customer Job No Customer PO
Net 30 Days
42,300.00STORM DRAIN REPAIR- BASE CONTRACT AMOUNT $42,300.00
4,728.56CO#1 BREAK & REMOVE 4 CONCRETE ENCASEMENTS SURROUNDING OLD CMP PIPE
$4,728.56
-4,702.8610% RETENTION -4,702.86
AMOUNT DUE THIS INVOICE $42,325.70
42,325.70Total Due $
42,325.70Subtotal $
All Sales Taxes Paid
Thank you for your business!
0.00Sales Tax (if applicable) $
327
2213 CHICO AV ENUE
SOUTH EL MONTE, CA 91733
(626) 444-3077Fax:
E. C. CONSTRUCTION CO.
(626) 444-9596Phone:
Attn: Christian Horvath
2 PORTUGUESE BEND ROAD
ROLLING HILLS, CA 90274
CITY OF ROLLING HILLS
5/30/2022
4/30/2022
19111
1 MIDDLERIDGE LANE N
ROLLING HILLS, CA 90274
STORM DRAIN REPAIR
220309
Our Job No Payment Terms Due Date
Description Price
Re:
Invoice
Invoice Number
Invoice Date
Bill To:
Contrs Lic # 366814
Customer Job No Customer PO
Net 30 Days
4,702.86REQUEST FOR RELEASE OF RETENTION
4,702.86Total Due $
4,702.86Subtotal $
All Sales Taxes Paid
Thank you for your business!
0.00Sales Tax (if applicable) $
328
329
330
Agenda Item No.: 7.K
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:JOHN SIGNO, DIRECTOR OF PLANNING & COMMUNITY SERVICES
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:ADOPT RESOLUTION NO. 1299 ACCEPTING CALRECYCLE SB1383
GRANT
DATE:May 23, 2022
BACKGROUND:
On January 24, 2022, the City Council directed staff to file an application for the SB 1383
Local Assistance Grant Program and prepare a resolution in support of the application. On
February 1, 2022, staff submitted an application to the Department of Resources Recycling
and Recovery (CalRecycle) for a one-time grant program meant to provide aid in the
implementation of regulations adopted by CalRecycle. This non-competitive grant program
provides $57,000,000 of funding to local jurisdictions to assist with the implementation of
regulation requirements associated with SB 1383.
On February 14, 2022, the City Council adopted Resolution No. 1288, attached, authorizing
the submittal of the CalRecycle Local Assistance Grant Program application and related
authorizations. Although the City had already submitted its application to meet the deadline,
the resolution is still required by CalRecycle.
On March 14, 2022, the City Council adopted Ordinance No. 374 adding Chapter 8.10 to the
Rolling Hills Municipal Code relating to edible food recovery in compliance with SB 1383. The
Ordinance was sent to CalRecycle as a supplement to the grant application.
On April 24, 2022, CalRecycle awarded the City of Rolling Hills in the first round of the SB
1383 Local Assistance Grant Program. The City initially requested $20,000 but was awarded
$20,183.
DISCUSSION:
The program provides funding to assist local jurisdictions with meeting the requirements
below:
Provide organics collection services to all residents and businesses
Conduct education and outreach to the community
331
Secure access to recycling and edible food recovery capacity
Establish edible food recovery program
Procure recyclable and recovered organic products
Monitor compliance and conduct enforcement
Staff will be working with CalRecycle in the next few weeks on further steps, including possibly
revising the grant budget and activities. Grant funds will be used to implement the
requirements in Chapter 8.10 regarding food recovery. The grant term ends on April 2, 2024
for first round recipients.
FISCAL IMPACT:
The City is awarded a grant amount of $20,183.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
Revised 1383 Award RFA 001.pdf
Exhibit A: 2022Jan3SB1383LocalAssistTermsConditions.pdf
Exibit B: 2022Apr25ProcsReqsAmended.pdf
ResolutionNo1288_SB1383_Grant_F_E.pdf
ResolutionNo1299_CalRecycle_SB1383_GrantAcceptance.pdf
332
Request for Approval
To:
Michelle Martin
Branch Chief, Financial Resources Management Branch
Decision Subject: Awards for the SB '1383 Local Assistance Grant Program, (Greenhouse
Gas Reduction Fund, Fiscal Year2021-22)
Action By:April 25, 2022 (Revised Mav 6, 2022)
Summary of Request
Staff requests approval of grant awards for the SB 1383 Local Assistance Grant Program
(Program) for fiscal year (FY) 2021-22. Staff received 475 eligible applications totaling
$54,929,783 for this grant program.
Funding
The FY 2021-22 Budget Act allocates $60,000,000 to be used to provide grants to local
jurisdictions to assist in the implementation of regulations adopted by the Department of
Resources Recycling and Recovery pursuant to Chapter 395 of the Statutes of 2016;
$3,000,000 (5 percent) has been allocated for administrative costs.
Fund Source Amount
Available
$57.000,000Greenhouse Gas
Reduction Fund
(FY 2021-22\
Total $57,000,000 $41,782.906 $15,217,094
$42p3+7€ $14863,724
Background and Findings
Statutory Authority
Senate Bill (SB) 1383 Lara, Chapter 395, Statutes of 2016, set methane emissions reduction
targets for California in a statewide effort to reduce emissions of short-lived climate pollutants.
SB '170 Budget Act of 2021 authorizes CalRecycle to award grants to local jurisdictions to assist
in the implementation of programs to meet these statutory requirements.
Program Background
The SB 1383 Local Assistance Grant Program provides funding to assist local jurisdictions
Amount to
Fund ltem
$41,782.906
$12;936;276
Amount
Remaining
$15.217.094
$/.4s63J%
Line ltem
Local
Assistance/Grants
Page 1 of 't3
Zoe Heller
Acting Deputy Director, Materials Management and Local Assistance
Division
From:
Request Date: April 14,2022
Table 1. Funding
333
with meeting the requirements below:. Provide organics collection services to all residents and businesses
. Conduct education and outreach to the community
o Secure access to recycling and edible food recovery capacity
o Establish edible food recovery program
r Procure recyclable and recovered organic products
e Monitor compliance and conduct enforcement
Criteria and Process
The Eligibility Criteria and Evaluation Process was approved by the Deputy Director on
December 28,2021, and presented at the January 2022 CalRecycle Monthly Public Meeting.
The Notice of Funds Available was placed on the CalRecycle website on January 4, 2022, wilh
an appropriate notice sent to stakeholders.
Applicationsweredue February 1,2022, with asecondaryduedateof Marci 1,2022,for
Resolution submission. CalRecycle received 476 applications requesting $54,947,783. Staff
reviewed the applications in accordance with the approved evaluation criteria; 399 applications
met the application requirements and adopted their enforceable ordinance, or similarly
enforceable mechanism, by April 1, 2022, and are therefore eligible for first round funding.
Subsequently, one application is ineligible. ln addition, first round awardees will receive
additional remaining funds from entities who did not apply. The remaining 82 76 applications
will be moved to the second funding round, tentatively scheduled for award in September 2022.
please note that if a participant in a Regional or Joint Powers Authority application did not meet
the application requirements, the entire application was moved to the second funding round.
The types of projects recommended for funding include: green, blue, and brown bins, education
and ouheach materials, record keeping subscriptions, refrigerators for food rescue, side loaders
for collection, and personnel and administrative costs.
Recommendation
staff recommends approval of 393 399 grant awards as listed below for $41,782.906
$42,936*76.
Table 2. Recommended Awards
APPlicant
Alameda County
Almonte Sanitary District
Alto Sanitary District
Bolinas Community Public Utility District
Cs+te4€snty
Calaveras County
Cambria Community Services District
Castro Valley Sanitary District
City of Agoura Hills
City of Alameda
Award Amount
Page 2 of 13
$208,136
$20,143
$20,1 18
$20,106
$84.;76+
$58,808
$20,558
$77,526
$29,860
$115,019
334
Applicant Award Amount
City of Albany
City of Alhambra
City of Aliso Viejo
City of American Canyon
City of Anaheim
City of Antioch
City of Arcadia
City of Artesia
City of Atwater
City of Auburn
City of Avalon
City of Avenal
City of Azusa
City of Bakersfield
City of Baldwin Park
City of Banning
City of Barstow
City of Beaumont
City of Bell Gardens
City of Bellflower
City of Belmont
City of Benicia
City of Berkeley
City of Beverly Hills
City of Blythe
City of Bradbury
City of Brawley
City of Brea
City of Brentwood
City of Brisbane
City of Buellton
City of Buena Park
City of Burbank
City of Burlingame
City of Calabasas
City of Calexico
City of California City
City of Calimesa
City o1_Calip-al!?
City of Camarillo
City of Canyon Lake
City of Capitola
City of Carlsbad
City of Carmel-bythe-Sea
City of Carpinteria
$25,065
$122,592
$71,231
$30,346
$499,168
$160,065
$82,290
$24,261
$45,859
$21,419
$20,391
$21,214
$70,912
$561,069
$108,044
$46,456
$35,142
$75,280
$60,548
$'110,191
$38,334
$39,237
$165,580
$48,099
$27,181
$20,103
$39,540
$64,641
$94,'180
$20,450
$20,534
$116,064
$147,552
$42,951
$35,333
$58,085
$21,388
$21,006
$20,640
$99,269
$21,084
$20,992
$163,804
$20,395
$21,297
Page 3 of 13 335
Applicant Award Amount
City of Carson
City of Cathedral City
City of Ceres
City of Cerritos
City of Chico
City of Chino
City of Chino Hills
City of Chowchilla
City of Citrus Heights
City of Claremont
City of Clovis
City of Coachella
Citv of oalinqa
City of Colfax
City of Colton
City of Commerce
City of Concord
City of Corcoran
City of Corona
City of Coronado
City of Costa lvlesa
$130,217
$77,093
$69,946
$71,562
$158,151
$125,307
$117,523
$25,453
$124,781
$s1,351
$172,729
$68,429
$24.633
$20,214
$77,411
$21,257
$183,213
$29,887
$239,839
$32,537
$159,969
$69,850
$34,501
$57,127
$83,693
$69,424
$154,077
$47,803
$98,687
$20,419
$20,164
$73,002
$80,961
$38,400
$29,493
$158,060
$31,269
$92,204
$43,802
$96,334
$146,529
$64,444
$36,045
$165,163
$24,509
City of Covina
City of Cudahy
City of Culver City
City of Cupertino
City of Cypress
City of Daly City
City of Dana Point
City of Davis
City of Del Mar
Page 4 of 13
City of Del Rey Oaks
City of Delano
Cig of Diamond Bar
City of Dinuba
City of Dixon
City of Downey
City of Duarte
City of Dublin
City of East Palo Alto
City of Eastvale
City of El Cajon
City of El Centro
City of El Cerrito
City of El Monte
City of El Segundo
336
Applicant Award Amount
City of G lendale
City of Glendora
City of Goleta
City of Gonzales
City of Grand Terrace
City of Grass Valley
City of Greenfield
City of Guadalupe
City of Half Moon Bay
City of Hawaiian Gardens
$252,058
$21,237
$88,813
$214,802
$21,081
$167,333
$23,307
$20,799
$117,019
$302,539
$2H2€
$47,314
$78,475
$20,649
$331 ,140
$771,586
$197,528
$37,835
$244,098
$86,072
$288,291
$73,665
$46,605
$20,835
$21,219.
$21,254
$26,964
$20,820
$21,210
$21,422
$123,637
$223,823
$120,150
$37,480
$28,442
$136,396
$20,188
$78,625
$20,613
$20,718
$278,482
$84,089
$29,623
$20,534
$20,042
City of Elk Grove
City of Emeryville
City of Encinitas
City of Escondido
City of Exeter
City of Fairfield
City of Fillmore
City of Firebaugh
City of Folsom
City of Fontana
erty-e++e*S+agg
City of Foster City
City of Fountain Valley
City of Fowler
City of Fremont
City of F-resno
City of Fullerton
City of Galt
City of Garden Grove
City of Gardena
City of HaMhorne
City of Hayward
City of Hemet
City of Hercules
City of Hermosa Beach
City of Hesperia
City of Hidden Hills
City of Highland
City of Holtuille
City of Hughson
City of Huntington Beach
City of Huntington Park
City of lmperial
City of lndian Wells
City of lndustry
Page 5 of 13 337
Applicant Award Amount
City of lrvine
City of lrwindale
City of Jurupa Valley
City of Kerman
City of King City
City of Kingsburg
City of La Canada Flintridge
City of La Habra
City of La Mesa
City of La Mirada
City of La Palma
City of La Puente
City of La Quinta
City of La Verne
City of Lafayette
City of Laguna Hills
City of Laguna Niguel
City of Laguna Woods
City of Lake Elsinore
City of Lake Forest .
City of Lakevood
City of Lancaster
City of Larkspur
City of Lawndale
City of Lemon Grove
City of Lemoore
City of Lindsay
City of Livermore
City of Lomita
City of Lompoc
City of Long Beach
City of Los Alamitos
City of Los Altos
City of Los Banos
City of Lynwood
City of Malibu
City of Manhattan Beach
City of Manteca
City of Marina
City of Martinez
City of Maywood
City of Mendota
City of Menifee
City of Menlo Park
City of Merced
$383,742
$20,142
$153,370
$23,745
$22,137
$21,286
$29,489
$89,545
$84,993
$69,565
$22,792
$57,524
$59,159
$47,655
$36,767
$44,821
$e2,870
$23,629
$92,298
$120,168
$114,080
$228,449
$21,199
$47,128
$38,1 58
$38,812
$21,287
$129,580
$29,823
$60,915
$660,1 96
$21,134
$44,027
$61,445
$99,511
$21,134
$50,437
$124,088
$31,922
$52,930
$40,025
$21,224
$141,516
$50,108
$129,234
Page 6 of 13 338
Applicant Award Amount
City of Mill Valley
City of Millbrae
City of Milpitas
City of Mission Viejo
City of Modesto
City of Monrovia
City of Montebello
City of Monterey
City of Monterey Park
City of Moorpark
City of Moreno Valley
City of Mountain View
City of Murrieta
City of Napa
City of National City
City of Needles
City of Newark
City of Newport Beach
City of Norco
City of Norwalk
City of Novato
City of Oakdale
City of Oakland
City of Oakley
City of Oceanside
City of Ojai
City of Ontario
City of Orange
City of Orinda
City of Oroville
City of Oxnard
City of Pacific Grove
City of Pacifica
City of Palm Desert
City of Palm Springs
City of Palo Alto
City of Paramount
City of Parlier
City of Pasadena
City of Patterson
City of Perris
City of Pico Rivera
City of Piedmont
City of Pinole
City of Pittsburg
$21,535
$32,752
$107,661
$133,671
$310,078
$55,258
$89,694
$41,028
$86,123
$51,738
$296,171
$1 17,739
$163,340
$112,923
$89,461
$20,526
$69,886
$122,038
$37,822
$149,559
$76,407
$33,778
$614,794
$61,481
$250,127
$20,731
$257.526
$194,618
$27,916
$26,204
$289,476
$22,925
$54,428
$76,979
$68,329
$96,378
$78,823
$23,336
$205,808
$33,872
$1'12,331
$90,036
$21 ,1 10
$28,327
$106,019
Page 7 of 13 339
Applicant Award Amount
City of Placentia
City of Placerville
City of Pleasant Hill
City of Pleasanton
City of Point Arena
City of Pomona
City of Porterville
City of Poway
City of Rancho Cordova
City of Rancho Cucamonga
City of Rancho Mirage
City of Rancho Palos Verdes
City of Rancho Santa Margarita
City of Redondo Beach
City of Redwood City
City of Reedley
City of Richmond
City of Ridgecrest
City of Rio Vista
City of Riverside
City of Rocklin
City of Rolling Hills
City of Rolling Hills Estates
City of Rosemead
City of Sacramento
City of Salinas
City of San Bernardino
City of San Bruno
City of San Buenaventura
City of San Carlos
e+tfefSaneemente
City of San Dimas
City of San Fernando
City of San Gabriel
City of San Jacinto
City of San Jose
City of San Juan Capistrano
City of San Leandro
City of San Marcos
City of San Marino
City of San Mateo
City of San Pablo
City of San Rafael
City of San Ramon
City of Sand City
$73,147
$21,070
$49,133
$111,477
$20,043
$214,282
$84,983
$69,995
$1 13,297
$247,840
$27,523
$59,573
$68,934
$94,725
$121 ,076
$37,794
$156,235
$42,732
$20,991
$458,065
$100,341
$20,183
$20,796
$77,454
$727,761
$226,806
$305,846
$64,358
$149,590
$43,047
$9+31€
$48,950
$35,916
$57,324
$73,283
$1,452,288
$51,484
$124,045
$136,747
$21,274
$146,250
$44,776
$84,201
$119,217
$20,038
Page 8 of 13 340
Applicant Award Amount
City
City
City
City
City
City
City
City
City
City
City
City
City
City
City
City
City of Sanger
City of Santa Barbara
City of Santa Clara
City of Santa Cruz
$39,578
$132,171
$185,289
$80,170
$152,451
$132,049
$44,282
$81,078
$20,723
$21 ,1 56
$46,298
$29,847
$21,047
$21,142
$176,441
$21,359
$35,493
$20,542
$31,042
$1 37,101
$34,005
$37,204
$95,643
$56,800
$41,733
$217,816
$20,702
$21,180
$159,957
$52,081
$177,791
$205,140
$139,987
$1 13,786
$43,262
$103,597
$111,677
$139,1 98
$167,109
$20,029
$20,566
$146,564
$43,076
$101,536
$38,820
of Santa Maria
of Santa Monica
of Santa Paula
of Santee
of Sausalito
of Scotts Valley
of Seaside
of Shafter
of Sierra Madre
of Signal Hill
of Simi Valley
of Solana Beach
of Soledad
of Solvang
of South El Monte
of South Gate
ity
ity
Ity
ity
ity
ity
ity
ity
ity
ity
ity
ityC
c
C
C
c
C
C
c
C
C
c
City of South Lake Tahoe
City of South Pasadena
City of South San Francisco
City of Stanton
City of Suisun City
City of Sunnyvale
of Taft
of Tehachapi
of Temecula
of Temple City
of Thousand Oaks
of Torrance
of Tracy
of Tustin
of Twentynine Palms
of Union City
of Upland
of Vacaville
City of Vallejo
City of Vernon
City of Villa Park
City of Vista
City of Walnut
City of Walnut Cr,eek
City of Wasco
Page 9 of 13 341
City of Waterford
City of West Covina
City of West Hollywood
City of West Sacramento
City of Westlake Village
City of Westmorland
City of Whittier
City of Wildomar
City of Winters
City of Woodlake
City of Woodland
City of Yorba Linda
City of Yucaipa
Contra Costa County
Costa Mesa Sanitary District
Del Norte Solid Waste Management Authority
o City of Crescent City
o Del Norte County
E+D€mdo€oun$
f+esneeeun$
Heber Public Utility District
Homestead Valley Sanitary District
Kern County
Las Gallinas Valley Sanitary District
Los Angeles County
Madera County
Marin County
[qenC€€ine€o$nry
Merced County
Midway City Sanitary District
Mono County
Monterey County
Mountain House Community Service District
Nevada County
Novato Sanitary District
Orange County
Oro Loma Sanitary District
Pebble Beach Community Services District
Placer County
Regional Waste Management Authority
. City of Live Oak. City of Marysvilleo City of Wheatland. City of Yuba Cityo Sutter County
Award Amount
w&e32
$24OJe3
$20,649
$20,231
$449,757
$43,309
$1,444,427
$106,687
$95,294
$s3J34
$131,133
$141,153
$20,538
$151,474
$35,556
$93,217
$75,890
$181 ,1 1 9
$191 ,284
$20,442
$162,553
$284,735
Applicant
$20,879
$'149,841
$51,941
$77,085
$20,804
$20,227
$122,505
$53,192
$20,749
$20,792
$86,966
$96,645
$79,434
$246,842
$168,262
$50,774
Page 10 of 1 3 342
Applicant
o Yuba County
Riverside County
Rodeo Sanitary District
Rubidoux Community Services District
Sacramento County
San Benito County lntegrated Waste Management Regional
Agency. City of Hollistero City of San Juan Bautistao San Benito County
Sa+Ce+na+dm€€oufiV
San Diego County
3:l lxi: 3ii:3: 3:xlil rntegrated waste Management
Authority. California Valley Community Service District
. Cayucos Sanitary Districto City of Arroyo Grandeo City of Atascaderoo City of El Paso de Robleso City of Grover Beach. City of Morro Bayo City of Pismo Beach. City of San Luis Obispoo Heritage Ranch Community Service Dishict. Nipomo Community Service District. Oceano Community Service District
. Templeton Community Service District
San Mateo County
Santa Barbara County
Santa Clara County (CEPA)
Santa Cruz County
Solano County
Sonoma County Waste Management Agency d.b.a. Zero
Waste Sonomao City of Cloverdalec City of Cotatio City of Healdsburgo City of Petaluma. City of Rohnert Park. City of Santa Rosa. City of Sebastopolo City of Sonomao Sonoma Countyo Town of Windsor
Award Amount
$550,518
$20,886
$53,174
$833,204
$108,766
$42932s
$703,210
$163,811
$371,025
$92,465
$188,960
$121 ,7',t3
$186,699
$26,912
$725,996
Page 11 of 13 343
Applicant Award Amount
Strawberry Recreation District
Tamalpais Community Services District
Tehama County Solid Waste Management Agency
. City of Corning. City of Red Bluffo City of Tehamao Tehama County
Town of Apple Valley
Town of Atherton
Town of Colma
Town of Danville
Town of Fairfax
Town of Hillsborough
Town of Loomis
Town of Los Altos Hills
Town of Moraga
Town of Ross
Town of San Anselmo
Town of Tiburon
Town of Truckee
Town of Woodside
Tulare County
Upper Valley Waste Management Agency
o City of Calistoga. City of St. Helenao Napa Countyr Town of Yountville
Ventura County
West Valley Solid Waste Management Authority
. City of Campbello City of Monte Serenoo City of Saratoga. Town of Los Gatos
Yolo County
$20,s90
$20,688
$123,787
$131 ,025
$168,481
$105,81 1
$20,678
$20,163
$62,906
$20,737
$21,120
$20,669
$20,825
$24,734
$20,250
$21,247
$20,930
$23,879
$20,553
$203,512
$95,370
Total Award $41,
$37,167
782.906
$42p36+75
Revisions were made to the RFA becau se one iurisdiction qualified for round one fundino that
was inadve rtentlv olaced in round two fun dinq. Seven iurisdictions did not
fundinq and are subseouentlv moved
Page 12 ot 13
qualifu fo r round one
for consideration to round two
344
Zoe HeIIer5!li:',*,**
Digilally signed by Zoe
13:05122 -07'00'
Zoe Heller
Acting Deputy Director
Dated
Page 13 of 13
Deputy Director Action
On the basis of the information and analysis in this Request for Approval and the findings set
out herein, I hereby conditionally approve the grant awards for the SB 1383 Local Assistance
Grant Program as listed in Table 2. Each proposed grantee's award is subject to the following
condition:
. The recommended grantee must pay all outstanding debts due to CalRecycle, or bring
current any outstanding payments owed to CalRecycle, within 60 days of the date of the
award email.
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CalRecycle’s Non-Competitive Grant Terms and Conditions – Revised 3/30/21 1
Exhibit A
Terms and Conditions
SB 1383 Local Assistance Grant Program
Fiscal Year 2021–22
The following terms used in this Grant Agreement (Agreement) have the meanings
given to them below, unless the context clearly indicates otherwise:
• "CalRecycle" means the Department of Resources Recycling and Recovery.
• "Director" means the Director of CalRecycle or his or her designee.
• "Grant Agreement" and "Agreement" means all documents comprising the
agreement between CalRecycle and the grantee for this grant.
• "Grant Manager" means CalRecycle staff person responsible for monitoring the
grant.
• "Grantee" means the recipient of funds pursuant to this Agreement.
• "Program" means the SB 1383 Local Assistance Grant Program.
• "State" means the State of California, including, but not limited to, CalRecycle and/or
its designated officer.
Air or Water Pollution Violation
The grantee shall not be:
(a) In violation of any order or resolution not subject to review promulgated by the State
Air Resources Board or an air pollution control district.
(b) Out of compliance with any final cease and desist order issued pursuant to Water
Code Section 13301 for violation of waste discharge requirements or discharge
prohibitions.
(c) Finally determined to be in violation of provisions of federal law relating to air or
water pollution.
Amendment
No amendment or variation of the terms of this Agreement shall be valid unless made in
writing, signed by the parties, and approved as required. No oral understanding or
agreement not incorporated into this Agreement is binding on any of the parties. This
Agreement may be amended, modified or augmented by mutual consent of the parties,
subject to the requirements and restrictions of this paragraph.
Americans with Disabilities Act
The grantee assures the state that it complies with the Americans with Disabilities Act of
1990 (ADA) (42 U.S.C.§ 12101 et seq.), which prohibits discrimination on the basis of
disability, as well as all applicable regulations and guidelines issued pursuant to the
ADA.
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CalRecycle’s Non-Competitive Grant Terms and Conditions – Revised 3/30/21 2
Assignment, Successors, and Assigns
(a) This Agreement may not be assigned by the grantee, either in whole or in part,
without CalRecycle’s prior written consent.
(b) The provisions of this Agreement shall be binding upon and inure to the benefit of
CalRecycle, the grantee, and their respective successors and assigns.
Audit/Records Access
The grantee agrees that CalRecycle, the Department of Finance, the Bureau of State
Audits, or their designated representative(s) shall have the right to review and to copy
any records and supporting documentation pertaining to the performance of this
Agreement. The grantee agrees to maintain such records for possible audit for a
minimum of three (3) years after final payment date or grant term end date, whichever is
later, unless a longer period of records retention is stipulated, or until completion of any
action and resolution of all issues which may arise as a result of any litigation, dispute,
or audit, whichever is later. The grantee agrees to allow the designated
representative(s) access to such records during normal business hours and to allow
interviews of any employees who might reasonably have information related to such
records. Further, the grantee agrees to include a similar right of the State to audit
records and interview staff in any contract or subcontract related to performance of this
Agreement.
[It may be helpful to share the Terms and Conditions (Exhibit A) and Procedures and
Requirements (Exhibit B) with your finance department, contractors and subcontractors.
Examples of audit documentation include, but are not limited to: expenditure ledger,
payroll register entries and time sheets, personnel expenditure summary form, travel
expense log, paid warrants, contracts, change orders, invoices, and/or cancelled
checks.]
Authorized Representative
The grantee shall continuously maintain a representative vested with signature authority
authorized to work with CalRecycle on all grant-related issues. The grantee shall, at all
times, keep the Grant Manager informed as to the identity and contact information of the
authorized representative.
Availability of Funds
CalRecycle's obligations under this Agreement are contingent upon and subject to the
availability of funds appropriated for this grant.
Bankruptcy/Declaration of Fiscal Emergency Notification
If the grantee files for protection under Chapter 9 of the U.S. Bankruptcy Code
(11 U.S.C. §901 et seq.) or declares a fiscal emergency at any time during the Grant
Term, the grantee shall notify CalRecycle within 15 days of such filing or declaration,
pursuant to the procedures set forth in the section entitled “Communications” herein.
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CalRecycle’s Non-Competitive Grant Terms and Conditions – Revised 3/30/21 3
Charter Cities
If the grantee is a charter city, a joint powers authority that includes one or more charter
cities, or the regional lead for a regional program containing one or more charter cities,
the grantee shall not receive any grant funding if such funding is prohibited by Labor
Code section 1782. If it is determined that Labor Code section 1782 prohibits funding
for the grant project, this Agreement will be terminated and any disbursed grant funds
shall be returned to CalRecycle.
Child Support Compliance Act
For any agreement in excess of $100,000, the grantee acknowledges that:
(a) The grantee recognizes the importance of child and family support obligations and
shall fully comply with all applicable state and federal laws relating to child and
family support enforcement, including, but not limited to, disclosure of information
and compliance with earnings assignment orders, as provided in Family Code
Section 5200 et seq.
(b) The grantee, to the best of its knowledge, is fully complying with the earnings
assignment orders of all employees, and is providing the names of all new
employees to the New Hire Registry maintained by the California Employment
Development Department.
Communications
All communications from the grantee to CalRecycle shall be directed to the Grant
Manager. All notices, including reports and payment requests, required by this
Agreement shall be given in writing by email, letter, or fax to the Grant Manager as
identified in the Procedures and Requirements (Exhibit B). If an original document is
required, prepaid mail or personal delivery to the Grant Manager is required following
the email or fax.
Compliance
The grantee shall comply fully with all applicable federal, state, and local laws,
ordinances, regulations, and permits. The grantee shall provide evidence, upon
request, that all local, state, and/or federal permits, licenses, registrations, and
approvals have been secured for the purposes for which grant funds are to be
expended. The grantee shall maintain compliance with such requirements throughout
the Grant Term. The grantee shall ensure that the requirements of the California
Environmental Quality Act are met for any approvals or other requirements necessary to
carry out the terms of this Agreement. The grantee shall ensure that all of grantee’s
contractors and subcontractors have all local, state, and/or federal permits, licenses,
registrations, certifications, and approvals required to perform the work for which they
are hired. Any deviation from the requirements of this section shall result in non-
payment of grant funds.
Conflict of Interest
The grantee needs to be aware of the following provisions regarding current or former
state employees. If the grantee has any questions on the status of any person
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CalRecycle’s Non-Competitive Grant Terms and Conditions – Revised 3/30/21 4
rendering services or involved with this Agreement, CalRecycle must be contacted
immediately for clarification.
Current State Employees (Pub. Contract Code, § 10410):
(a) No officer or employee shall engage in any employment, activity, or enterprise from
which the officer or employee receives compensation or has a financial interest and
which is sponsored or funded by any state agency, unless the employment, activity,
or enterprise is required as a condition of regular state employment.
(b) No officer or employee shall contract on his or her own behalf as an independent
contractor with any state agency to provide goods or services.
Former State Employees (Pub. Contract Code, § 10411):
(a) For the two-year period from the date he or she left state employment, no former
state officer or employee may enter into a contract in which he or she engaged in
any of the negotiations, transactions, planning, arrangements or any part of the
decision-making process relevant to the contract while employed in any capacity by
any state agency.
(b) For the twelve-month period from the date he or she left state employment, no
former state officer or employee may enter into a contract with any state agency if he
or she was employed by that state agency in a policy-making position in the same
general subject area as the proposed contract within the twelve month period prior to
his or her leaving state service.
If the grantee violates any provisions of above paragraphs, such action by the grantee
shall render this Agreement void. (Pub. Contract Code, § 10420).
Contractors/Subcontractors
The grantee will be entitled to make use of its own staff and such contractors and
subcontractors as are mutually acceptable to the grantee and CalRecycle. Any change
in contractors or subcontractors must be mutually acceptable to the parties.
Immediately upon termination of any such contract or subcontract, the grantee shall
notify the Grant Manager.
Nothing contained in this Agreement or otherwise, shall create any contractual relation
between CalRecycle and any contractors or subcontractors of grantee, and no
agreement with contractors or subcontractors shall relieve the grantee of its
responsibilities and obligations hereunder. The grantee agrees to be as fully
responsible to CalRecycle for the acts and omissions of its contractors and
subcontractors and of persons either directly or indirectly employed by any of them as it
is for the acts and omissions of persons directly employed by the grantee. The
grantee's obligation to pay its contractors and subcontractors is an independent
obligation from CalRecycle’s obligation to make payments to the grantee. As a result,
CalRecycle shall have no obligation to pay or to enforce the payment of any moneys to
any contractor or subcontractor.
Copyrights
Grantee retains title to any copyrights or copyrightable material produced pursuant to
this Agreement. grantee hereby grants to CalRecycle a royalty-free, nonexclusive,
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CalRecycle’s Non-Competitive Grant Terms and Conditions – Revised 3/30/21 5
transferable, world-wide license to reproduce, translate, and distribute copies of any and
all copyrightable materials produced pursuant this Agreement, for nonprofit, non-
commercial purposes, and to have or permit others to do so on CalRecycle’s behalf.
Grantee is responsible for obtaining any necessary licenses, permissions, releases or
authorizations to use text, images, or other materials owned, copyrighted, or
trademarked by third parties and for extending such licenses, permissions, releases, or
authorizations to CalRecycle pursuant to this section.
Corporation Qualified to do Business in California
When work under this Agreement is to be performed in California by a corporation, the
corporation shall be in good standing and currently qualified to do business in the State.
"Doing business" is defined in Revenue and Taxation Code Section 23101 as actively
engaging in any transaction for the purpose of financial or pecuniary gain or profit.
Discharge of Grant Obligations
The grantee's obligations under this Agreement shall be deemed discharged only upon
acceptance of the final report by CalRecycle. If the grantee is a non-profit entity, the
grantee’s Board of Directors shall accept and certify as accurate the final report prior to
its submission to CalRecycle.
Disclaimer of Warranty
CalRecycle makes no warranties, express or implied, including without limitation, the
implied warranties of merchantability and fitness for a particular purpose, regarding the
materials, equipment, services or products purchased, used, obtained and/or produced
with funds awarded under this Agreement, whether such materials, equipment, services
or products are purchased, used, obtained and/or produced alone or in combination
with other materials, equipment, services or products. No CalRecycle employees or
agents have any right or authority to make any other representation, warranty or
promise with respect to any materials, equipment, services or products, purchased,
used, obtained, or produced with grant funds. In no event shall CalRecycle be liable for
special, incidental or consequential damages arising from the use, sale or distribution of
any materials, equipment, services or products purchased or produced with grant funds
awarded under this Agreement.
Discretionary Termination
The Director shall have the right to terminate this Agreement at his or her sole discretion
at any time upon 30 days written notice to the grantee. Within 45 days of receipt of
written notice, grantee is required to:
(a) Submit a final written report describing all work performed by the grantee.
(b) Submit an accounting of all grant funds expended up to and including the date of
termination.
(c) Reimburse CalRecycle for any unspent funds.
Disputes
In the event of a dispute regarding performance under this Agreement or interpretation
of requirements contained therein, the grantee may, in addition to any other remedies
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CalRecycle’s Non-Competitive Grant Terms and Conditions – Revised 3/30/21 6
that may be available, provide written notice of the particulars of such dispute to the
Branch Chief of Financial Resources Management Branch, Department of Resources
Recycling and Recovery, PO Box 4025, Sacramento, CA 95812-4025. Such written
notice must contain the grant number.
Unless otherwise instructed by the Grant Manager, the grantee shall continue with its
responsibilities under this Agreement during any dispute.
Drug-Free Workplace Certification
The person signing this Agreement on behalf of the grantee certifies under penalty of
perjury under the laws of California, that the grantee will comply with the requirements
of the Drug-Free Workplace Act of 1990 (Gov. Code, § 8350 et seq.) and will provide a
drug-free workplace by taking the following actions:
(a) Publish a statement notifying employees that unlawful manufacture, distribution,
dispensation, possession or use of a controlled substance is prohibited and
specifying actions that will be taken against employees for violations.
(b) Establish a drug-free awareness program to inform employees about all of the
following:
(1) The dangers of drug abuse in the workplace.
(2) The grantee's policy of maintaining a drug-free workplace.
(3) Any available counseling, rehabilitation, and employee assistance programs.
(4) Penalties that may be imposed upon employees for drug abuse violations.
(c) Require that each employee who works on the grant:
(1) Receive a copy of the drug-free policy statement of the grantee.
(2) Agrees to abide by the terms of such statement as a condition of employment on
the grant.
Failure to comply with these requirements may result in suspension of payments under
the Agreement or termination of the Agreement or both and grantee may be ineligible
for award of any future State agreements if CalRecycle determines that the grantee has
made a false certification, or violated the certification by failing to carry out the
requirements as noted above.
Effectiveness of Agreement
This Agreement is of no force or effect until signed by both parties.
Entire Agreement
This Agreement supersedes all prior agreements, oral or written, made with respect to
the subject hereof and, together with all attachments hereto, contains the entire
agreement of the parties.
Environmental Justice
In the performance of this Agreement, the grantee shall conduct its programs, policies,
and activities that substantially affect human health or the environment in a manner that
ensures the fair treatment of people of all races, cultures, and income levels, including
minority populations and low-income populations of the state.
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CalRecycle’s Non-Competitive Grant Terms and Conditions – Revised 3/30/21 7
Failure to Perform as Required by this Agreement
CalRecycle will benefit from the grantee's full compliance with the terms of this
Agreement only by the grantee's:
(a) Investigation and/or application of technologies, processes, and devices which
support reduction, reuse, and/or recycling of wastes.
(b) Cleanup of the environment.
(c) Enforcement of solid waste statutes and regulations, as applicable.
Therefore, the grantee shall be in compliance with this Agreement only if the work it
performs results in:
(a) Application of information, a process, usable data or a product which can be used to
aid in reduction, reuse, and/or recycling of waste.
(b) The cleanup of the environment.
(c) The enforcement of solid waste statutes and regulations, as applicable.
If the Grant Manager determines that the grantee has not complied with the Grant
Agreement, the grantee may forfeit the right to reimbursement of any grant funds not
already paid by CalRecycle, including, but not limited to, the 10 percent withhold.
Force Majeure
Neither CalRecycle nor the grantee, its contractors, vendors, or subcontractors, if any,
shall be responsible hereunder for any delay, default, or nonperformance of this
Agreement, to the extent that such delay, default, or nonperformance is caused by an
act of God, weather, accident, labor strike, fire, explosion, riot, war, rebellion, sabotage,
flood, or other contingencies unforeseen by CalRecycle or the grantee, its contractors,
vendors, or subcontractors, and beyond the reasonable control of such party.
Forfeit of Grant Funds/Repayment of Funds Improperly
Expended
If grant funds are not expended, or have not been expended, in accordance with this
Agreement, or if real or personal property acquired with grant funds is not being used,
or has not been used, for grant purposes in accordance with this Agreement, the
Director, at his or her sole discretion, may take appropriate action under this
Agreement, at law or in equity, including requiring the grantee to forfeit the unexpended
portion of the grant funds, including, but not limited to, the 10 percent withhold, and/or to
repay to CalRecycle any funds improperly expended.
Generally Accepted Accounting Principles
The grantee is required to use Generally Accepted Accounting Principles in
documenting all grant expenditures.
Grant Manager
The Grant Manager’s responsibilities include monitoring grant progress, and reviewing
and approving Grant Payment Requests and other documents delivered to CalRecycle
pursuant to this Agreement. The Grant Manager may monitor grantee performance to
ensure that the grantee expends grant funds appropriately and in a manner consistent
with the terms and conditions contained herein. The Grant Manager does not have the
authority to approve any deviation from or revision to the Terms and Conditions
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CalRecycle’s Non-Competitive Grant Terms and Conditions – Revised 3/30/21 8
(Exhibit A) or the Procedures and Requirements (Exhibit B), unless such authority is
expressly stated in the Procedures and Requirements (Exhibit B).
Grantee Accountability
The grantee is ultimately responsible and accountable for the manner in which the grant
funds are utilized and accounted for and the way the grant is administered, even if the
grantee has contracted with another organization, public or private, to administer or
operate its grant program. In the event an audit should determine that grant funds are
owed to CalRecycle, the grantee is responsible for repayment of the funds to
CalRecycle.
Grantee's Indemnification and Defense of the State
The grantee agrees to indemnify, defend and save harmless the state and CalRecycle,
and their officers, agents and employees from any and all claims and losses accruing or
resulting to any and all contractors, subcontractors, suppliers, laborers, and any other
person, firm or corporation furnishing or supplying work services, materials, or supplies
in connection with the performance of this Agreement, and from any and all claims and
losses accruing or resulting to any person, firm or corporation who may be injured or
damaged by the grantee as a result of the performance of this Agreement.
Grantee's Name Change
A written amendment is required to change the grantee's name as listed on this
Agreement. Upon receipt of legal documentation of the name change, CalRecycle will
process the amendment. Payment of Payment Requests presented with a new name
cannot be paid prior to approval of the amendment.
In Case of Emergency
In the event of an emergency, or where there is an imminent threat to public health and
safety or the environment, the grantee may choose, at its own risk, to incur grant-
eligible expenses not previously included in the approved Budget, subject to
subsequent approval by the Grant Manager of both the Budget change and the need to
implement the Budget change on an emergency basis. The grantee shall notify the
Grant Manager of the emergency and the Budget change at the earliest possible
opportunity. CalRecycle reserves the right to accept or reject the grantee’s
determination that the circumstances constituted an emergency or a threat to public
health and safety or the environment. If the Grant Manager determines that the
circumstances did not constitute an emergency or a threat to public health or safety, the
Budget change will be disallowed.
No Agency Relationship Created/Independent Capacity
The grantee and the agents and employees of grantee, in the performance of this
Agreement, shall act in an independent capacity and not as officers or employees or
agents of CalRecycle.
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CalRecycle’s Non-Competitive Grant Terms and Conditions – Revised 3/30/21 9
No Waiver of Rights
CalRecycle shall not be deemed to have waived any rights under this Agreement unless
such waiver is given in writing and signed by CalRecycle. No delay or omission on the
part of CalRecycle in exercising any rights shall operate as a waiver of such right or any
other right. A waiver by CalRecycle of a provision of this Agreement shall not prejudice
or constitute a waiver of CalRecycle’s right otherwise to demand strict compliance with
that provision or any other provision of this Agreement. No prior waiver by CalRecycle,
nor any course of dealing between CalRecycle and grantee, shall constitute a waiver of
any of CalRecycle’s rights or of any of grantee’s obligations as to any future
transactions. Whenever the consent of CalRecycle is required under this Agreement,
the granting of such consent by CalRecycle in any instance shall not constitute
continuing consent to subsequent instances where such consent is required and in all
cases such consent may be granted or withheld in the sole discretion of CalRecycle.
Non-Discrimination Clause
(a) During the performance of this Agreement, grantee and its contractors shall not
unlawfully discriminate, harass, or allow harassment against any employee or
applicant for employment on the bases enumerated in Government Code Section
12900 et seq.
(b) The person signing this Agreement on behalf of the grantee certifies under penalty
of perjury under the laws of California that the grantee has, unless exempted,
complied with the nondiscrimination program requirements (Gov. Code, § 12990,
subd. (a-f) and California Code of Regulations, Title 2, Section 8103). (Not
applicable to public entities.)
Order of Precedence
The performance of this grant shall be conducted in accordance with the Terms and
Conditions (Exhibit A), Procedures and Requirements (Exhibit B), Project
Summary/Statement of Use, Work Plan, and Budget of this Agreement, or other
combination of Exhibits specified on the Grant Agreement Coversheet attached hereto
(collectively referred to as “Terms”). Grantee’s CalRecycle-approved Application
(Grantee’s Application) is hereby incorporated herein by this reference. In the event of
conflict or inconsistency between the articles, exhibits, attachments, specifications or
provisions that constitute this Agreement, the following order of precedence shall apply:
(a) Grant Agreement Coversheet and any Amendments thereto
(b) Terms and Conditions
(c) Procedures and Requirements
(d) Project Summary/Statement of Use
(e) Budget
(f) Work Plan
(g) Grantee’s Application
(h) All other attachments hereto, including any that are incorporated by reference.
Ownership of Drawings, Plans and Specifications
The grantee shall, at the request of CalRecycle or as specifically directed in the
Procedures and Requirements (Exhibit B), provide CalRecycle with copies of any data,
drawings, design plans, specifications, photographs, negatives, audio and video
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CalRecycle’s Non-Competitive Grant Terms and Conditions – Revised 3/30/21 10
productions, films, recordings, reports, findings, recommendations, and memoranda of
every description or any part thereof, prepared under this Agreement. Grantee hereby
grants to CalRecycle a royalty-free, nonexclusive, transferable, world-wide license to
reproduce, translate, and distribute copies of any and all such materials produced
pursuant to this Agreement, for nonprofit, non-commercial purposes, and to have or
permit others to do so on CalRecycle’s behalf.
Payment
(a) The approved Budget, if applicable, is attached hereto and incorporated herein by
this reference and states the maximum amount of allowable costs for each of the
tasks identified in the Work Plan, if applicable, which is attached hereto and
incorporated herein by this reference. CalRecycle shall reimburse the grantee for
only the work and tasks specified in the Work Plan or the Grantee’s Application at
only those costs specified in the Budget and incurred in the term of the Agreement.
(b) The grantee shall carry out the work described in the Work Plan or in the Grantee’s
Application in accordance with the approved Budget, and shall obtain the Grant
Manager’s written approval of any changes or modifications to the Work Plan,
approved project as described in the Grantee’s Application or the approved Budget
prior to performing the changed work or incurring the changed cost. If the grantee
fails to obtain such prior written approval, the Director, at his or her sole discretion,
may refuse to provide funds to pay for such work or costs.
(c) The grantee shall request reimbursement in accordance with the procedures
described in the Procedures and Requirements (Exhibit B).
(d) Ten percent will be withheld from each Payment Request and paid at the end of the
grant term, when all reports and conditions stipulated in this Agreement have been
satisfactorily completed. Failure by the grantee to satisfactorily complete all reports
and conditions stipulated in this Agreement may result in forfeiture of any such funds
withheld pursuant to CalRecycle’s 10 percent) retention policy.
(e) Lodgings, Meals and Incidentals: Grantee’s Per Diem eligible costs are limited to the
amounts authorized in the California State Administrative Manual (contact the Grant
Manager for more information).
(f) Payment will be made only to the grantee.
(g) Reimbursable expenses shall not be incurred unless and until the grantee receives a
Notice to Proceed as described in the Procedures and Requirements (Exhibit B).
Personnel Costs
If there are eligible costs pursuant to Exhibit B, Procedures and Requirements, any
personnel expenditures to be reimbursed with grant funds must be computed based on
actual time spent on grant-related activities and on the actual salary or equivalent hourly
wage the employee is paid for his or her regular job duties, including a proportionate
share of any benefits to which the employee is entitled, unless otherwise specified in the
Procedures and Requirements (Exhibit B).
Real and Personal Property Acquired w ith Grant Funds
(a) All real and personal property, including equipment and supplies, acquired with grant
funds shall be used by the grantee only for the purposes for which CalRecycle
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CalRecycle’s Non-Competitive Grant Terms and Conditions – Revised 3/30/21 11
approved their acquisition for so long as such property is needed for such purposes,
regardless of whether the grantee continues to receive grant funds from CalRecycle
for such purposes. In no event shall the length of time during which such property,
including equipment and supplies, acquired with grant funds, is used for the purpose
for which CalRecycle approved its acquisition be less than five (5) years after the
end of the grant term, during which time the property, including equipment and
supplies, must remain in the State of California.
(b) Subject to the obligations and conditions set forth in this section, title to all real and
personal property acquired with grant funds, including all equipment and supplies,
shall vest upon acquisition in the grantee. The grantee may be required to execute
all documents required to provide CalRecycle with a security interest in any real or
personal property, including equipment and supplies, and it shall be a condition of
receiving this grant that CalRecycle shall be in first priority position with respect to
the security interest on any such property acquired with the grant funds, unless pre-
approved in writing by the Grant Manager that CalRecycle will accept a lower priority
position with respect to the security interest on the property. Grantee shall inform
any lender(s) from whom it is acquiring additional funding to complete the property
purchase of this grant condition.
(c) The grantee may not transfer Title to any real or personal property, including
equipment and supplies, acquired with grant funds to any other entity without the
express authorization of CalRecycle.
(d) CalRecycle will not reimburse the grantee for the acquisition of equipment that was
previously purchased with CalRecycle grant funds, unless the acquisition of such
equipment with grant funds is pre-approved in writing by the Grant Manager. In the
event of a question concerning the eligibility of equipment for grant funding, the
burden will be on the grantee to establish the pedigree of the equipment.
Reasonable Costs
A cost is reasonable if, in its nature or amount, it does not exceed that which would be
incurred by a prudent person under the circumstances prevailing at the time the
decision was made to incur the cost. Consideration will be given to:
(a) Whether the cost is of a type generally recognized as ordinary and necessary for the
performance of the grant.
(b) The restraints or requirements imposed by such factors as generally accepted sound
business practices, arms-length bargaining, federal and state laws and regulations,
and the terms and conditions of this Agreement.
(c) Whether the individuals concerned acted with prudence in the circumstances,
considering their responsibilities to the organization, its members, employees,
clients, and the public at large.
(d) Significant deviations from the established practices of the organization which may
unjustifiably increase the grant costs.
Recycled-Content Paper
All documents submitted by the grantee must be printed double-sided on recycled-
content paper containing 100 percent post-consumer fiber. Specific pages containing
full color photographs or other ink-intensive graphics may be printed on photographic
paper.
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CalRecycle’s Non-Competitive Grant Terms and Conditions – Revised 3/30/21 12
Reduction of Waste
In the performance of this Agreement, grantee shall take all reasonable steps to ensure
that materials purchased or utilized in the course of the project are not wasted. Steps
should include, but not be limited to: the use of used, reusable, or recyclable products;
discretion in the amount of materials used; alternatives to disposal of materials
consumed; and the practice of other waste reduction measures where feasible and
appropriate.
Reduction of Waste Tires
Unless otherwise provided for in this Agreement, in the performance of this Agreement,
for all purchases made with grant funds, including, but not limited to equipment and tire-
derived feedstock, the grantee shall purchase and/or process only California waste tires
and California waste tire-derived products. As a condition of final payment under this
Agreement, the grantee must provide documentation substantiating the source of the
tire materials used during the performance of this Agreement to the Grant Manager.
Reimbursement Limitations
Under no circumstances shall the grantee seek reimbursement pursuant to this
Agreement for a cost or activity that has been or will be paid for through another funding
source. The grantee shall not seek reimbursement for any costs used to meet cost
sharing or matching requirements of any other CalRecycle funded program.
All costs charged against the Agreement shall be net of all applicable credits. The term
“applicable credits” refers to those receipts or reductions of expenditures that operate to
offset or reduce expense items that are reimbursable under this Agreement. Applicable
credits may include, but are not necessarily limited to, rebates or allowances, discounts,
credits toward subsequent purchases, and refunds. Grantee shall, where possible,
deduct the amount of the credit from the amount billed as reimbursement for the cost, or
shall deduct the amount of the credit from the total billed under a future invoice.
Reliable Contractor Declaration
Prior to authorizing any contractor or subcontractor to commence work under this Grant,
the grantee shall submit to CalRecycle a Reliable Contractor Declaration (CalRecycle
168) from the contractor or subcontractor, signed under penalty of perjury, disclosing
whether of any of the events listed in Section 17050 of Title 14, California Code of
Regulations, Natural Resources (https://www.calrecycle.ca.gov/laws/regulations/title14),
Division 7, has occurred with respect to the contractor or subcontractor within the
preceding three (3) years. If a contractor is placed on CalRecycle’s Unreliable List after
award of this Grant, the grantee may be required to terminate that contract.
Remedies
Unless otherwise expressly provided herein, the rights and remedies hereunder are in
addition to, and not in limitation of, other rights and remedies under this Agreement, at
law or in equity, and exercise of one right or remedy shall not be deemed a waiver of
any other right or remedy.
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Self-Dealing and Arm’s Length Transactions
All expenditures for which reimbursement pursuant to this Agreement is sought shall be
the result of arm’s-length transactions and not the result of, or motivated by, self-dealing
on the part of the grantee or any employee or agent of the grantee. For purposes of this
provision, “arm’s-length transactions” are those in which both parties are on equal
footing and fair market forces are at play, such as when multiple vendors are invited to
compete for an entity’s business and the entity chooses the lowest of the resulting bids.
“Self-dealing” is involved where an individual or entity is obligated to act as a trustee or
fiduciary, as when handling public funds, and chooses to act in a manner that will
benefit the individual or entity, directly or indirectly, to the detriment of, and in conflict
with, the public purpose for which all grant monies are to be expended.
Severability
If any provisions of this Agreement are found to be unlawful or unenforceable, such
provisions will be voided and severed from this Agreement without affecting any other
provision of this Agreement. To the full extent, however, that the provisions of such
applicable law may be waived, they are hereby waived to the end that this Agreement
be deemed to be a valid and binding agreement enforceable in accordance with its
terms.
Site Access
The grantee shall allow the state to access sites at which grant funds are expended and
related work being performed at any time during the performance of the work and for
ninety (90) days after completion of the work, or until all issues related to the grant
project have been resolved.
Stop Work Notice
Immediately upon receipt of a written notice from the Grant Manager to stop work, the
grantee shall cease all work under this Agreement.
Termination for Cause
CalRecycle may terminate this Agreement and be relieved of any payments should the
grantee fail to perform the requirements of this Agreement at the time and in the manner
herein provided. In the event of such termination, CalRecycle may proceed with the
work in any manner deemed proper by CalRecycle. All costs to CalRecycle shall be
deducted from any sum due the grantee under this Agreement. Termination pursuant to
this section may result in forfeiture by the grantee of any funds retained pursuant to
CalRecycle’s 10 percent retention policy.
Time is of the Essence
Time is of the essence to this Agreement.
Tolling of Statute of Limitations
The statute of limitations for bringing any action, administrative or civil, to enforce the
terms of this Agreement or to recover any amounts determined to be owing to
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CalRecycle as the result of any audit of the grant covered by this Agreement shall be
tolled during the period of any audit resolution, including any appeals by the grantee to
the Director.
Union Organizing
By signing this Agreement, the grantee hereby acknowledges the applicability of
Government Code Sections 16645, 16645.2, 16645.8, 16646, 16647, and 16648 to this
Agreement and hereby certifies that:
(a) No grant funds disbursed by this grant will be used to assist, promote, or deter union
organizing by employees performing work under this Agreement.
(B) If the grantee makes expenditures to assist, promote, or deter union organizing, the
grantee will maintain records sufficient to show that no state funds were used for
those expenditures, and that grantee shall provide those records to the Attorney
General upon request.
Venue/Choice of Law
(a) All proceedings concerning the validity and operation of this Agreement and the
performance of the obligations imposed upon the parties hereunder shall be held in
Sacramento County, California. The parties hereby waive any right to any other
venue. The place where the Agreement is entered into and place where the
obligation is incurred is Sacramento County, California.
(b) The laws of the State of California shall govern all proceedings concerning the
validity and operation of this Agreement and the performance of the obligations
imposed upon the parties hereunder.
Waiver of Claims and Recourse against the State
The grantee agrees to waive all claims and recourse against the state, its officials,
officers, agents, employees, and servants, including, but not limited to, the right to
contribution for loss or damage to persons or property arising out of, resulting from, or in
any way connected with or incident to this Agreement. This waiver extends to any loss
incurred attributable to any activity undertaken or omitted pursuant to this Agreement or
any product, structure, or condition created pursuant to, or as a result of, this
Agreement.
Work Products
Grantee shall provide CalRecycle with copies of all final products identified in the Work
Plan. Grantee shall also provide CalRecycle with copies of all public education and
advertising material produced pursuant to this Agreement.
Workers’ Compensation/Labor Code
The grantee is aware of Labor Code Section 3700, which requires every employer to be
insured against liability for Workers’ Compensation or to undertake self-insurance in
accordance with the Labor Code, and the grantee agrees to comply with such
provisions before commencing the performance of the work of this Agreement.
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January 2022
Amended April 2022
Department of Resources Recycling and Recovery
Exhibit B
Procedures and Requirements
SB 1383 Local Assistance Grant
Program
First Round Funding
Fiscal Year 2021–22
Copies of these Procedures and Requirements must be shared with
both the Grantee’s Finance Department and the staff responsible for
implementing the grant activities.
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Table of Contents
Introduction ................................................................................................................... 3
Milestones ...................................................................................................................... 3
Grants Management System (GMS) ............................................................................. 3
Accessing the Grant .................................................................................................... 4
Contact Updates .......................................................................................................... 4
Prior to Commencing Work .......................................................................................... 5
Reliable Contractor Declaration ................................................................................... 5
Grant Term ..................................................................................................................... 6
Eligible Costs ............................................................................................................... 6
Ineligible Costs ............................................................................................................ 7
Modifications ................................................................................................................ 8
Acknowledgements ...................................................................................................... 8
Reporting Requirements .............................................................................................. 9
Electronic and Original Signatures............................................................................... 9
Progress Report......................................................................................................... 10
Final Report ............................................................................................................... 10
Grant Payment Information ........................................................................................ 10
Expenditure Itemization Summary and Documentation ......................................... 11
Unspent Funds ....................................................................................................... 12
Audit Considerations .................................................................................................. 12
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Introduction
The Department of Resources Recycling and Recovery (CalRecycle) administers the
SB 1383 Local Assistance Grant Program. These Procedures and Requirements
describe project and reporting requirements, report due dates, report contents, grant
payment conditions, eligible and ineligible project costs, project completion and closeout
procedures, and records and audit requirements.
This document is attached to, and incorporated by reference, into the Grant Agreement.
Milestones
April 1, 2022: Grant Term Begins: Date CalRecycle sends the award email
October November 3, 2022: Expenditure Itemization Summary 1 Due
Covering expenses from April 1, 2022, the Grant Term Start Date through
October November 2, 2022
April May 3, 2023: Expenditure Itemization Summary 2 Due
Covering expenses from October November 3, 2022, through April
May 2, 2023
October November 2, 2023: Expenditure Itemization Summary 3 Due
Covering expenses from April May 3, 2023, through October
November 1, 2023
April May 2, 2024: Expenditure Itemization Summary 4 Due
Covering expenses from October November 2, 2023, through May 2, 2024
April May 2, 2024: Final Report Due
Covering activities from April 1, 2022 the Grant Term Start Date through April
May 2, 2024
April May 2, 2024: Grant Term End
Note: These dates are subject to change. If they change, Grant Managers will notify the
Awardees immediately.
Grants Management System (GMS)
GMS is CalRecycle’s web-based grant application and Grants Management System.
Access to GMS is secure; grantees must log in using a WebPass. WebPass accounts
are tied to a specific email address. If an email address changes, or if it becomes
inactive, the grantee must create a new WebPass account to continue accessing GMS.
Establish or manage a WebPass at CalRecycle’s WebPass page
(https://secure.calrecycle.ca.gov/WebPass/).
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Accessing the Grant
Grantees must log in to GMS (https://secure.calrecycle.ca.gov/Grants) using their web
pass. After logging in, locate the grant in the My Awarded/Open Grants table and
select the Grant Management link. The Grant Management Module includes the
following sections:
Summary tab: Shows approved budget, paid and remaining amounts. (This
section is available to the grantee in read-only mode.)
Payment Request tab: Grantee uploads expenditure documentation.
Reports tab: Grantee uploads required reports.
Documents tab: Grantee uploads all other grant documents that are not
supporting documents for an expenditure or a report. This section also provides
access to documents that were uploaded within other sections of GMS.
Follow the instructions in GMS to work in the system. The following sections describe
the reports, transactions, and supporting documents CalRecycle requires.
Contact Updates
Access to the grant is limited to those listed in the Contacts tab of the Application
Module with the “Allow Access” check box marked. A contact may be listed but not
granted access by not checking the box. Please note, if a contact is granted access to
a grant, they will be able to edit contacts, submit payment requests, upload reports, and
view all documents. Those with access may update contact information for all contact
types except Signature Authority. Email the assigned Grant Manager regarding any
changes to Signature Authority information.
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Prior to Commencing Work
Prior to commencing work under this grant, the grantee’s Grant Manager or primary
contact and authorized grant Signature Authority should review the Terms and
Conditions (Exhibit A) and the Procedures and Requirements (Exhibit B) to identify key
grant administrative requirements. Evaluation of the grantee’s compliance with these
requirements is a major focus of grant audits.
Reliable Contractor Declaration
Prior to authorizing a contractor or subcontractor to commence work under this grant,
the grantee shall submit to the Grant Manager a declaration from the contractor or
subcontractor, signed under penalty of perjury, stating that within the preceding three
(3) years, none of the events listed in section 17050 of Title 14
(https://www.calrecycle.ca.gov/Laws/Regulations/Title14/), California Code of
Regulations, Natural Resources, Division 7, has occurred with respect to the contractor
or subcontractor. The grantee must submit this form for each contractor and
subcontractor working under the grant.
If a contractor or subcontractor is placed on the CalRecycle Unreliable Contractor List
(https://www.calrecycle.ca.gov/Funding/Unreliability/) after award of this grant, the
grantee may be required to terminate the contract. Obtain the Reliable Contractor
Declaration form (CalRecycle 168) from CalRecycle's Grant Forms web page
(https://www.calrecycle.ca.gov/Funding/Forms/).
The grantee must upload a scanned copy of each signed Reliable Contractor
Declaration form in GMS. To upload the form:
1. Go to the Reports tab.
2. Click on Reliable Contractor Declaration under Report Type.
3. Click the Add Document button.
4. Select Reliable Contractor Declaration in the Document Type drop down box,
enter a document title, click the Browse button to search and upload the
document, and then Save.
5. Click on the Submit Report button.
For further instructions regarding GMS, including login directions, see the “Grants
Management System” section (above).
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Grant Term
The Grant Term begins on the date CalRecycle sends the award email April 1, 2022
and ends on April May 2, 2024. The grantee must make all grant-eligible program
expenditures and incur all grant-eligible costs within this period. Expenditures made or
costs incurred prior to April 1, 2022 the grant term start date or after the grant term end
date will be considered ineligible.
The Final Report, final Expenditure Itemization Summary, and Certification Document
are due on April May 2, 2024.
Eligible Costs
Grantees may incur eligible costs only during the Grant Term, which starts on
the date CalRecycle sends the award email and ends on May 2, 2024 April 1, 2022 and
ends April 2, 2024. All grant expenditures must be for activities, products, and costs
specifically included in the approved Budget. Costs must be incurred after the term
start date. All services must be provided and goods received during this period in order
to be eligible costs.
Eligible costs include:
Personnel
Consultants
Safety Equipment
Vehicles/Trucks
o For compost procurement activities - Vehicles/tractors, turf tires, forklifts or
compost slingers
Note: The Grantee needs to own and control the vehicle, however they may
allow participants to use the vehicle for grant implementation purposes only.
Education and Outreach materials
o Print Media
o Television, radio, video, and social media
o Materials offered in other languages
Door-to-Door Outreach
Signage
Recordkeeping or tracking software
o Software to match donor with food bank
o Recordkeeping/reporting software
o Procurement tracking software
o Apps for food recovery
Inspections and Enforcement
Training
Tablet/Electronic Devices (seven inches or more measured diagonally) used for
the purposed of organic tracking and Education and Outreach
o Maximum price of $500 (excluding sales tax) and limit to one (exceptions
may be approved on a case-by-case basis)
o Accessories used for security, protection, and charging
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Equipment
o For larger items, The Grantee needs to own and control the equipment,
however, they may allow participants use of said equipment for grant
implementation purposes.
Bins (green and blue only) and lids
o Includes, but is not limited to, curbside, small household food waste pail,
labeling, and liners
Procurement of recovered/recycled organic products
Equipment
o Food distribution - included refrigeration, coolers, and packing materials
Ineligible Costs
Any costs not specifically included in the approved Budget and not directly related to
grant implementation will be considered ineligible. The grantee should contact the
Grant Manager if clarification is needed.
Ineligible costs include, but are not limited to:
Costs incurred prior to April 1, 2022 the Term Start Date or after April May 2,
2024
Development, purchase, or distribution of strictly promotional give -away items
Stuff We All Get, (SWAG) (https://www.calrecycle.ca.gov/Funding/SWAG/)
Purchase or lease of land or buildings
Equipment or services not directly related to grant implementation
Food dehydrators or liquefiers
Disposal costs
Costs currently covered by or incurred under any other CalRecycle loan, grant, or
contract
Cell phones
Purchase of data plans and/or mobile service plans/hotspots
Costs related to website host and web page domain
Audit expenses
Sponsorship or licensing fees for events/programs
Out-of-state travel
Conferences and symposiums
Food or beverages (e.g., as part of meetings, workshops, or events)
Travel costs exceeding the state-approved rates for mileage, per diem, lodging,
etc.
o Refer to the Memorandum
(https://www.calhr.ca.gov/employees/Pages/travel-reimbursements.aspx)
for travel policies.
o Reimbursement rates are subject to change at any time by the State of
California without prior notification.
Personnel costs not directly related to grant activities
Fines or penalties due to violation of federal, state, or local laws, ordinances, or
regulations
Any costs for construction projects by charter cities prohibited by Labor Code
section 1782
Any costs not consistent with local, state, or federal laws, guidelines, and
regulations
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The total amount of indirect costs charged to the grant shall not exceed 10
percent of the grant funds reimbursed. These costs are expenditures not
capable of being assigned or not readily itemized to a particular project or activity
but considered necessary for the operation of the organization and the
performance of the program. The costs of operating and maintaining facilities,
accounting services, and administrative salaries as well as contractor’s indirect
costs in their contracts, are examples of indirect costs. All indirect costs charged
to the grant must be associated with grant activities.
Costs deemed unreasonable or not related to the project by the Grant Manager
Modifications
The grantee must submit any proposed revision(s) to the project in writing to the Grant
Manager. The grantee may not incur costs or make expenditures based on the revision
without first receiving the Grant Manager’s written approval. Proposed revisions must
be accompanied by a summary of proposed changes or modifications, including
justification for the proposed changes. If approved, the Grant Manager will upload the
final revised changes to GMS and notify the grantee. The grantee should retain the
approval document(s) for audit purposes. See the “Audit Record/Access” section of the
Terms and Conditions (Exhibit A).
Acknowledgements
The grantee shall acknowledge CalRecycle’s support each time a project is funded, in
whole or in part, by this Agreement is publicized in any medium, including news media,
brochures, or other types of promotional materials. The acknowledgement of
CalRecycle’s support must incorporate the CalRecycle logo. Initials or abbreviations for
CalRecycle shall not be used. The Grant Manager may approve deviation from this
requirement on a case-by-case basis where such deviation is consistent with
CalRecycle’s Communication Strategy and Outreach Plan.
The following items require acknowledgement of funding from CalRecycle and pre -
approval from the CalRecycle Grant Manager prior to incurring the expense:
All television, radio and video scripts
Functional premiums, if the per unit price is greater than $6.00
Advertisements
Audio and/or visual material
Brochures
Newspaper ads
Pamphlets
Other outreach
All publicity and education materials must include the following:
1. “Funded by a grant from CalRecycle.” Exception: The acknowledgement line is
not required on small items where space constraints would not allow for this line
or if it would interfere with the message.
o There are two acceptable Spanish translations: “Financiado por una beca
del CalRecycle” or “Patrocinado por fondos del CalRecycle.” For other
languages, the Grantee must work with a certified translator or person
fluent in reading and writing that language. All exceptions must be pre-
approved in writing by the CalRecycle Grant Manager.
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2. CalRecycle logo (https://www.calrecycle.ca.gov/gallery/) as reflected on the
CalRecycle website, can be obtained from the Office of Public Affairs at
opa@calrecycle.ca.gov.
3. Press Releases – the only requirement is to place the name of “CalRecycle” as
an acknowledgement in the body of the release.
Reporting Requirements
The Grant Agreement requires a Final Report; however, the Grant Manager may require
additional status information at any time during the Grant Term. Failure to submit the
Final Report with appropriate documentation by the due date may result in forfeiture by
the grantee of any unspent funds received under this agreement, and repayment of all
funds to CalRecycle.
The grantee must upload all reports in GMS. For further instructions regarding GMS,
including login directions, see the “Grants Management System” section (above).
To upload a report:
1. Go to the Reports tab.
2. Click on the appropriate Report Type.
3. Click on the Add Document button.
4. Choose the Document Type, enter a document title, click the Browse button to
search and upload the document, and then Save.
Select the Back button to upload another document and continue the
process until all required documents as listed below are uploaded.
The maximum allowable file size for each document is 35MB.
5. Click the Submit Report button to complete your report submittal. The Submit
Report button will not be enabled until all required reporting documents are
uploaded.
Failure to comply with the specified reporting requirements may be considered a breach
of the Grant Agreement and may result in the termination of the Grant Agreement,
and/or forfeiture by the grantee of claims for costs incurred that might otherwise have
been eligible for grant funding. The grantee must report any problems or delays
immediately to the Grant Manager.
Electronic and Original Signatures
CalRecycle now allows for certified e-Signature or original wet signature on documents
or forms that certify legally binding information.
Note: E-signatures must include the first and last name of the Signature Authority, be in
the Adobe Digital ID format (or through another certified digital signature program) and
cannot be the “Fill and Sign” function within Adobe. Any documents using the “Fill and
Sign” method is considered incomplete and may be sent back to the grantee.
If you have questions, email grantassistance@calrecycle.ca.gov.
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Progress Report
Grantees with awards over $1,000,000 will need to collect and submit information on
any jobs created or paid by the grant on a bi-annual basis. Grant Managers will work
with Grantees on when and how to submit the information. CalRecycle will provide a
report template at a later date. Progress reports must include the following:
Jobs
o Provide number of jobs created and paid for in whole or in part by this
grant during the reporting period. Include job title or classification, job
permanence, total project work hours, hourly pay rates or salaries, as
well as benefits from the job, such as healthcare, paid vacation or sick
leave and hiring strategy.
Jobs provided to members of Priority Populations.
o In addition to the item, above, provide the same jobs information for
any positions filled by members of priority populations. More
information about Priority Populations can be found at California Air
Resources Board Priority Population Investments webpage
(www3.arb.ca.gov/cc/capandtrade/auctionproceeds/communityinvestm
ents.htm).
Note: This requirement is subject to change at CalRecycle’s discretion. If any reporting
requirement changes, Grant Managers will notify the Awardees.
Final Report
The Final Report is due April May 2, 2024 (report template will be provided at a later
date). This report should cover grant activities from April 1, 2022 the Term Start Date
through April May 2, 2024. The grantee must include the following items in the Final
Report:
1. The Grant Number, grantee’s name, and Grant Term.
2. The following disclaimer statement on the cover page:
“The statements and conclusions of this report are those of the grantee and not
necessarily those of the Department of Resources Recycling and Recovery
(CalRecycle), its employees, or the State of California. The state makes no
warranty, express or implied, and assumes no liability for the information
contained in the succeeding text.”
Note: This requirement is subject to change at CalRecycle’s discretion. If any reporting
requirement changes, Grant Managers will notify the Grantees.
Grant Payment Information
CalRecycle will make grant payments to only the grantee. It is the grantee’s
responsibility to pay all contractors and subcontractors for purchased goods and
services. CalRecycle will make payments to the grantee as promptly as fiscal
procedures permit.
The grantee must provide a Reliable Contractor Declaration (CalRecycle 168)
(https://www.calrecycle.ca.gov/Funding/forms/) signed under penalty of perjury
by the grantee’s contractors and subcontractors in accordance with the “Reliable
Contractor Declaration” section of the Terms and Conditions (Exhibit A). The
declaration must be received and approved by the Grant Manager prior to
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commencement of work. See the “Reliable Contractor Declaration” section in
Terms and Conditions (Exhibit A) for more information.
Expenditure Itemization Summary and Documentation
The grantee must submit the EIS and Certification Document (a template will be
provided at a later date) in GMS. For further instructions regarding GMS, including login
directions, see the “Grants Management System” section (above). Please refer to the
“Milestones” section (above) for required due dates.
Expenditure Itemization Summary (EIS)
o All expenditures must be itemized and arranged by the reporting and
expenditure categories as contained in the grantee’s Budget tab.
o Grantees are required to maintain supporting documentation pertaining to
the EIS and may be required to provide them at the request of the Grant
Manager at any time.
Certification Document
o The Signature Authority will need to certify under penalty of perjury that
information provided in the EIS is correct.
Note: This requirement is subject to change at CalRecycle’s discretion. If any
expenditure reporting requirement changes, Grant Managers will notify the
Awardees.
Failure to submit the EIS and Certification Document by the due date may result in the
forfeiture by the grantee of claims for costs incurred that might otherwise have been
eligible for grant funding.
To submit an EIS:
1. Go to the Payment Request tab.
2. Click on the Create a Payment Request button.
a. Choose Advance Reconcile for the Transaction Type and enter the
amount spent in each budget subcategory.
b. When the transaction is complete, click the Save button.
c. After the transaction is saved, the Upload Supporting Documents button
will appear in the lower right corner.
3. Click the Upload Supporting Documents button.
a. Choose the Document Type, enter a document title, click the Browse
button to search and upload the document, and then Save.
b. Select the Back button to upload another document and continue this
process until all required supporting documents as listed below are
uploaded.
c. The maximum allowable file size for each document is 35MB.
4. Click the Submit Transaction button, located on the transaction page, to
complete your payment request. The Submit Transaction button will not be
enabled until all required supporting documents are uploaded.
Note: Once a transaction is saved, select the transaction number from the
Payment Request tab to access it again. Please do not create multiple
transactions for the same requested funds.
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Unspent Funds
Funds that are unspent at the end of the grant term must be returned by check to
CalRecycle by June 15, 2024 May 16, 2024. Checks should be made payable to the
Department of Resources Recycling and Recovery. Checks must contain the Grant
Number (i.e., OWR1-21-xxxx), specify “SB 1383 Local Assistance Grant Unspent
Funds,” and be mailed to:
CalRecycle Accounting
SB 1383 Local Assistance Grant Unspent Funds
PO Box 4025
Sacramento, CA 95812-4025
Unspent funds due to CalRecycle but left unpaid may result in ineligibility for future
grant and payment program funding. If there are questions or other issues related to
expenditures, work with your Grant Manager to resolve these issues.
Audit Considerations
The grantee agrees to maintain records and supporting documentation pertaining to the
performance of this grant subject to possible audit for a minimum of three (3) years after
Final Report approval date or Grant Term end date, whichever is later. CalRecycle may
stipulate a longer period of records retention in order to complete any action and/or
resolution of all issues which may arise as a result of any litigation, dispute, or audit,
whichever is later.
Examples of audit documentation include, but are not limited to, competitive bids, grant
amendments, copies of any agreements with contractors or subcontractors if utilized,
expenditure ledger, payroll register entries, time sheets, Expenditure Itemization
Summary forms, payment supporting documentation, paid warrants, contracts and
change orders, samples of items and materials developed with grant funds, invoices ,
and cancelled checks. Please refer to the Terms and Conditions (Exhibit A) f or more
information.
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Resolution No. 12 99 1
RESOLUTION NO. 1299
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
ROLLING HILLS AUTHORIZING ACCEPTANCE OF
GRANT FUNDING FROM CALRECYCLE IN THE AMOUNT
OF $20,183; AND AUTHORIZING THE CITY MANAGER,
OR DESIGNEE, TO EXECUTE ANY NECESSARY
DOCUMENTS TO MEET THE GRANT REQUIREMENTS
FOR THE SB 1383 LOCAL ASSISTANCE GRANT
PROGRAM
THE CITY COUNCIL OF THE CITY OF ROLLING HILLS, CALIFORNIA DOES
HEREBY RESOLVE, DECLARE, DETERMINE, AND ORDER AS FOLLOWS:
Section 1. Recitals.
A. The City of Rolling Hills (“City”) applied to the Department of Resources
Recycling and Recovery (“CalRecycle”) for the SB 1383 Local Assistance Grant Program
for a one-time grant meant to aid in the implementation of regulations adopted by
CalRecycle.
B. The SB 1383 Local Assistance Grant Program is a non-competitive grant
program that provides $57,000,000 of funding to local jurisdictions to assist with the
implementation of regulation requirements associated with SB 1383.
C. CalRecycle awarded the City a one-time grant in the amount of $20,183 to
aid in the implementation of the SB 1383 requirements.
D. The City Council desires to accept the grant funds from CalRecycle and to
direct the City Manager, or designee, to execute any necessary documents to meet the
grant requirements.
Section 2. The City Council hereby accepts the award of the SB 1383 Local Assistance
Grant Program grant in the amount of $20,183 from CalRecycle to be used for
implementation of the SB 1383 requirements.
Section 3. The City Council hereby authorizes the City Manager, or her designee, to
execute any necessary documents to meet the grant requirements. The City Manager, or
her designee, is also authorized to take necessary action to comply with the grant
requirements.
Section 4. This Resolution shall take effect immediately upon its adoption by the City
Council, and the City Clerk shall certify to the passage and adoption of this Resolution
and enter it into the book of original resolutions.
PASSED, APPROVED, AND ADOPTED this 23rd day of May, 2022.
376
Resolution No. 12 99 2
______________________________
JAMES BLACK, M.D.
MAYOR
ATTEST:
___________________________
CHRISTIAN HORVATH
CITY CLERK
377
Resolution No. 12 99 3
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) §§
CITY OF ROLLING HILLS )
The foregoing Resolution No. 1299 entitled:
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROLLING
HILLS AUTHORIZING ACCEPTANCE OF GRANT FUNDING FROM
CALRECYCLE IN THE AMOUNT OF $20,183; AND AUTHORIZING THE
CITY MANAGER, OR DESIGNEE, TO EXECUTE ANY NECESSARY
DOCUMENTS TO MEET THE GRANT REQUIREMENTS FOR THE SB
1383 LOCAL ASSISTANCE GRANT PROGRAM
was approved and adopted at a regular meeting of the City Council on the 23rd day of
May, 2022, by the following roll call vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
___________________________
CHRISTIAN HORVATH
CITY CLERK
378
Agenda Item No.: 7.L
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:ROBERT SAMARIO, FINANCE DIRECTOR
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:REPORT BY BUDGET/AUDIT/FINANCE COMMITTEE ON MEETING
HELD ON MAY 9, 2022
DATE:May 23, 2022
BACKGROUND:
Annually, the City Manager presents a budget to the Finance/Audit/Budget Committee
followed by a budget workshop with the City Council. In preparing the proposed budget for
Fiscal Year 2022-2023, the priorities and goals discussed at the 2022 City Council Strategic
Planning Session were taken into consideration and programmed accordingly.
DISCUSSION:
The Committee met on May 9th to receive a presentation of the FY 22/23 proposed budget..
REVENUE PROJECTIONS FOR FISCAL YEARS 2021/22 AND 2022-2023
The development of the fiscal year 2022/23 projected revenues began with a projection of
current year revenues. With only nine months of revenues recorded, the year-end revenue
totals were projected based on several factors, including prior year results, current year
trends, and other pertinent data.
By far, the largest General Fund revenue is derived from property taxes. The current year
adopted budget of $1,249,800 assumed a 4% growth. Staff expects actual revenues at year
end will be $1,281,715 representing a growth of 4.8%. For fiscal year 2022/23, staff
recommends again using a growth rate assumption of 4%, which would translate into a
projected revenue of $1,333,000. The 4% growth rate consists of a CPI factor of 2%, which is
the maximum increase allowed under Proposition 13, plus another 2% growth based on re-
assessments for resales and home improvements.
A related revenue is Property Transfer Tax. Whenever a real estate property is sold in the City
of Rolling Hills, a transfer tax is levied at $1.10 for every $1,000 in the sale price. The tax is
split 50/50 between the City of Rolling Hills and Los Angeles County. In fiscal year 2020/21,
revenues totaled $96,433. This fiscal year revenues are expected to reach $117,986. For
379
fiscal year 2022/23, staff recommends an assumed growth of 2% as a conservative approach
given the recent spike in mortgage rates will likely result in fewer home sales.
The second largest General Fund revenue is from Building & Other Permits. These revenues
have experienced a dramatic decline as a result of the pandemic, dropping to $183,378 in
fiscal year 2020/21. Before the pandemic, building-related permit revenues exceeded
$700,000. With the pandemic seemingly waning, revenues have experienced a moderate
rebound. Based on revenues received through March 31, 2022, staff estimates revenues at
year end at $472,969. Accordingly, staff proposes estimated revenues for fiscal year 2022/23
of $475,000, recognizing that if the current trend continues, revenue could be higher.
Motor Vehicle In Lieu (MVIL) tax revenues are fairly flat from the prior year. Projected fiscal
year 2021/22 revenues of $246,694 are 4.2% higher than last year. Staff recommends a
assuming a 2% growth and total revenues for next fiscal year $252,000. The unknown is to
what degree higher interest rates, which affect rates offered on car loans, will affect new car
sales. Otherwise, MVIL taxes trend downward absent new car sales as the tax rate is applied
on a depreciating scale.
In total, staff recommends total General Fund budgeted revenues of $2,399,289, which are
$274,989 higher than fiscal year 2021/22 adopted revenues, buoyed primarily by the increase
in property taxes and building permit revenues.
The committee had no concerns with the revenue projections as presented.
GENERAL FUND EXPENDITURE PROJECTION FOR FISCAL YEAR 2022-2023
The proposed budget for the upcoming fiscal year projects $3,137,956 in expenditures. The
proposed expenditures would result in a deficit of $738,667 before transfers and a deficit of
$2,008,167 after transfers in and out. The following highlights the proposed expenditures:
Increased allocations to Emergency Preparedness for wildfire mitigation measures,
Block Captain Program, fire fuel abatement in the Preserve, citywide emergency alert
drill, Emergency Information System (EIS) support, Alert Southbay subscription and as-
needed consulting services.
3.5% Cost of Living Adjustment to salaries
Increased City Attorney fee based on BBK's activities of the last two fiscal years
Fees for the November 2022 Municipal Election
Fees for records management
Increased Finance Department fee for grants management, reimbursement support,
restricted funds management, benefits/pension activities for city personnel, and
technology implementation.
Update to the 1990 General Plan and companion environmental assessment.
Contracted code enforcement services.
Fee for a grant writer to pursue fund for sewer project
Budget for expanded resident services (i.e., outdoor movie night).
Budget for Human Resource support.
Anticipated subsidy to absorb the cost increase to residents' refuse fees.
Capital Improvement Cost for the City Hall ADA design, and construction.
380
OTHER FUNDS FOR FISCAL YEAR 2022-2023
Majority of the restricted funds such as Proposition C, Measure R, Measure M, and Measure A
are expected to roll the revenue to future years to save up for eligible projects. The following
summarizes the anticipated activities of the other restricted funds for next fiscal year:
Measure W's expenditure plan for FY 2022-2023 was previously approved by the City
Council in March 2022 and submitted to the Los Angeles County for approval. It is
anticipated that $80,000 of Measure W would be spent on eligible storm water
compliance measures.
The City of Beverly Hills expressed interest in $45,200 of Prop A exchange.
The Coronavirus State and Local Fiscal Recovery funds (American Rescue Plan Act -
ARPA) is expected to provide half of the overall allocation.
The Capital Projects fund includes $96,000 for Pacific Architecture Engineers' design fee
recently approved by the City Council for the development of layout Option 3 and $1M
for construction of the City Hall ADA Improvement project.
The Refuse fund anticipates absorbing the expected refuse rate increase for residents.
The newly established Fund 16 Cal OES captures the grants awarded to the city in the
last two years with transfers from the Utility Fund (Southern California Edison Rule 20
credits) for grant match.
The committee expressed concern with some expenditure numbers specific to employees.
Staff has corrected those items and they will be presented as part of the Budget Workshop.
The committee asked for clarifications on expense line item fluctuations. Staff explained that
they were re-assigning expenditures to more appropriate categories to ensure clarity and
transparency. The committee expressed concerns about proposed election costs being high.
Staff has been able to subsequently converse with Los Angeles County's Registrar, Recorder
and County Clerk and has modified the projected costs based on their input. The committee
expressed concern about more clearly understanding the difference between what constitutes
as core budget ongoing expenditures versus one-time capital expenses. Staff has broken out
these numbers to help present a clearer picture during the workshop. The committee
expressed concerns about stormwater compliance costs. Staff explained that the number do
not necessarily reflect Measure W offsets which come later and replenish monies expended
by the general fund. The committee requested seeing fund sources and expenditures broken
out. The committee expressed concern about expenditures related to the general plan
updates and recommend delaying the process of updating elements for the time being unless
absolutely required. The Committee expressed concerns with the overall budget and projected
deficit spending.
FISCAL IMPACT:
None.
RECOMMENDATION:
Receive and File
ATTACHMENTS:
381
Agenda Item No.: 7.M
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH, CITY CLERK / EXECUTIVE ASSISTANT TO
CITY MANAGER
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:ADOPT RESOLUTION NO. 1298 MEMORIALIZING A REDUCTION IN
THE SELF-INSURANCE FUND RESERVES FROM $500,000 TO
$250,000
DATE:May 23, 2022
BACKGROUND:
At the May 9, 2022 City Council meeting, the Council unanimously voted to reduce the
Municipal Self-Insurance Reserve Fund Balance to $250,000 and directed staff to prepare a
resolution memorializing the reduction.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
ResolutionNo1298_AdministrativeFinancialPolicy.pdf
FN_POL_220518_AdminProcedures_BudgetDebtPolicies.pdf
382
1
RESOLUTION NO. 1298
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
ROLLING HILLS APPROVING THE FINANCIAL, BUDGET
AND DEBT POLICIES IN THE ADMINISTRATIVE
POLICY/PROCEDURES
THE CITY COUNCIL OF THE CITY OF ROLLING HILLS, CALIFORNIA, DOES
HEREBY RESOLVE, DECLARE, DETERMINE, AND ORDER AS FOLLOWS:
Section 1. Recitals.
A. Each year, the City Council reviews the City’s policies to identify whether
changes need to be made.
B. The Finance Committee considered the Financial, Budget and Debt
Policies in the Administrative Policy/Procedures and recommended reducing the
self-insurance fund from $500,000 to $250,000.
C. On May 9, 2022, the City Council considered the Finance Committee’s
recommendation to amend the Financial, Budget and Debt Policies.
Section 2. The City Council hereby approves the Financial, Budget and
Debt Policies in the Administrative Policy/Procedures, attached hereto as Exhibit A
and incorporated herein by reference.
Section 3. This Resolution shall take effect immediately upon its adoption by
the City Council, and the City Clerk shall certify to the passage and adoption of this
Resolution and enter it into the book of original resolutions.
PASSED, APPROVED, AND ADOPTED this 23rd day of May, 2022.
______________________________
JAMES BLACK, M.D.
MAYOR
ATTEST:
___________________________
CHRISTIAN HORVATH
CITY CLERK
383
2
EXHIBIT A
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65277.00001\40089220.1
FINANCIAL POLICIES 05/23/2022 1
CITY OF ROLLING HILLS ADMINISTRATIVE
POLICY/PROCEDURES
FINANCIAL, BUDGET AND DEBT POLICIES
Original Version Effective: 09/24/2007 See end of document for complete policy
history
Current Version Effective: 05/23/2022
Policy Framework:
The purpose of the Financial, Budget and Debt Policies is to guide the City Council and
other City officials in developing sustainable, balanced budgets and managing the City’s
finances in a prudent manner consistent with best practices. The City’s commitment to
adopting and operating within a balanced budget is a core financial value and policy of
the City.
The City of Rolling Hills Financial Policies represents the City’s framework for planning
and management of the City’s fiscal resources. Adherence to the Financial Policies
promote sound financial management which can lead to unqualified annual audits,
provide assurance to the taxpayers that tax dollars are being collected and spent per City
Council direction and provide a minimum of unexpected impacts upon taxpayers and
users of public services.
The City Council Finance / Budget Committee shall serve as the City’s audit committee
for the purpose of recommending the selection of an auditor to the City Council, meeting
with the City Auditor, reviewing the annual audit and necessary financial statements,
responding to conflicts between management and the auditor and responding to
fraudulent activities. The City Council will conduct a competitive process for the selection
of the independent external auditor every 6 years to be in conformance with California
Government Code Section 12410.6(b). Any non- audit work performed by the
independent external auditor, if allowed, will be done under a separate contract approved
by the City Council.
The City Manager shall be responsible for developing and, as appropriate, implementing
and managing these policies as well as subsidiary policies that execute the City’s
Financial Policies.
The City’s Financial Policies shall be in conformance with all state and federal laws,
generally accepted accounting principles (GAAP) and standards of the Governmental
Accounting Standards Board (GASB) and the Government Finance Officers Association
(GFOA).
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FINANCIAL POLICIES 05/23/2022 2
1. Financial Reporting Entity:
The City of Rolling Hills was incorporated in 1957 under the general laws of the State of
California. The City operates under the Council-Manager form of government. The City
Council consists of five members elected at large for overlapping four-year terms. The
Mayor and Mayor Pro-Tem are selected from the City Council members and serve a one-
year term. The City Council appoints a City Manager, City Attorney and City Treasurer.
In addition, the City Council appoints the members of advisory Commissions and
Committees.
The City, directly or by contract, provides municipal services as authorized by statute.
Services provided include:
• Public safety through the Los Angeles County Sheriff and Fire Department
• Refuse collection by contract with a private hauler
• Water through California Water Service Company
• Sewer through Los Angeles County Sanitation Districts
• Recreation
• Public improvements
• Planning and zoning
• General administrative and support services
2. Financial Reporting Policies:
The City’s accounting and financial reporting systems will be maintained in conformance
with all state and federal laws, generally accepted accounting principles (GAAP) and
standards of the Governmental Accounting Standards Board (GASB) and the
Government Finance Officers Association (GFOA). Further, the City will make every
attempt to implement all changes to governmental accounting practices at the earliest
practical time.
• The financial report should be in conformity with GAAP, demonstrate
compliance with finance related legal and contractual provisions, disclose
thoroughly with detail sufficient to minimize ambiguity and potential for
misleading interferences.
• An annual audit will be performed by an independent public accounting
firm with an audit opinion to be included with the City’s published
Comprehensive Annual Financial Report.
• The City’s budget should satisfy criteria as a financial and programmatic
policy document, as a comprehensive financial plan, as an operations
guide for all organizational units and as a communications device for all
significant budgetary issues, trends, and resource choices.
• The City shall evaluate the fiscal impact of proposed changes in employee
benefits to be provided. Prior to assuming liability for expanded benefits,
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FINANCIAL POLICIES 05/23/2022 3
a viable funding plan with estimates of long term impacts shall be
incorporated into the analysis.
• The City shall endeavor to avoid committing to new spending for operating
or capital improvement purposes until an analysis of all current and future
cost implications is completed.
• The City shall endeavor to maintain cash reserves sufficient to fully fund
the next present value of accruing liabilities, obligations to employees for
vested payroll and benefits and similar obligations as they are incurred.
• The City shall prepare and present to the City Council monthly interim
revenue and expenditure reports and a Mid-Year Review to allow
evaluation of potential discrepancies from budget assumptions.
3. Internal Control Accounting Policies:
To provide a reasonable basis for making management’s required representations
concerning the finances of the City.
• Accounting Records – Maintain accounting records in accordance with
Generally Accepted Accounting Principles (GAAP).
• Monthly Posting – Post a monthly record, which maintains each month’s
activities separate and distinct from another month’s work. This provides
visibility in locating errors and fixing corrections. Accounting ledgers will
be reviewed and reconciled on a monthly basis to supporting
documentation – Cash Receipts, Accounts Payable, Payroll and Monthly
Journal Entries.
• Sequential Number – Sequentially numbered instruments will be used for
checks and cash receipts. Pre-numbered receipts are controlled and
accounted for by an individual with no accounting handling responsibilities.
The City’s pre-numbered checks and pre-numbered cash receipts should
be safeguarded in the Vault. All copies of voided receipt forms are
retained, accounted for, and documented.
• Audit Trail – The City’s accounting records and systems shall provide an
audit trail (e.g. paper document) that allows for the tracing of each
transaction from its original document to completion.
4. Operating Management Policies:
The budget process is intended to weigh all competing requests for City resources within
expected fiscal constraints. Requests for new, on-going programs made outside the
budget process will be discouraged.
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FINANCIAL POLICIES 05/23/2022 4
• Budget development will consider multi-year implications of current
decisions and allocations and use conservative revenue forecasts.
• Revenues will not be dedicated for specific purposes, unless required by
law or Generally Accepted Accounting Practices (GAAP). All non-
restricted revenues will be deposited in the General Fund (or other
designated fund as approved by the City Manager) and appropriated by
the City Council.
• Current revenues will fund current expenditures. City revenues will be
managed to protect programs from short-term fluctuations that impact
expenditures.
• The City will endeavor to identify entrepreneurial solutions to cover or
recover costs of operating program.
• The City shall strive to avoid returning to the City Council for new or
expanded appropriations during the fiscal year. Exceptions may include
emergencies, unforeseen impacts, mid-year adjustments or new
opportunities.
• Additional personnel will be requested after service needs have been
thoroughly examined and is substantiated for new program initiatives or
policy directives.
• All non-Enterprise user fees and charges will be evaluated at least every
three years to determine the direct and indirect cost recovery rate. The
analysis will be presented to the City Council.
• The City shall endeavor to maintain adequate cash reserves to fund 100%
replacement of capital equipment. Replacement costs will be based upon
equipment lifecycle financial analysis developed by the Finance Director
and approved by the City Manager.
• Balanced revenue and expenditure forecasts will be prepared to examine
the City’s ability to absorb operating costs due to changes in the economy,
service demands, and capital improvements. The forecast will be updated
annually and include a four-year outlook.
• Cash and investment programs will be maintained in accordance with the
Government Code and the adopted investment policy will ensure that
proper controls and safeguards are maintained. City funds will be
managed in a prudent and diligent manner with an emphasis on safety of
principal, liquidity, and financial return on principal, in that order. Pursuant
to State law, the City, at least annually, revises and the City Council affirms
a detailed investment policy.
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FINANCIAL POLICIES 05/23/2022 5
5. Capital Management Policies:
• Capital improvement projects are defined as infrastructure or equipment
purchases or construction which results in a capitalized asset and having a useful
(depreciable) life of at least one year with a cost of $5,000 or more per the City’s
resolution Number 953.
• The Finance Department shall utilize the straight-line method of calculating
depreciation over the estimated useful life for all classes of assets.
• The capital improvement plan will attempt to include, in addition to current
operating maintenance expenditures, adequate funding to support, repair and
replace deteriorating infrastructure and avoid a significant unfunded liability.
• Capital improvement lifecycle costs will be coordinated with the development of
the City’s operating budget. Future operating, maintenance, and replacement
costs associated with new capital improvements will be forecast, matched to
available revenue sources and be included in the operating budget. Capital project
contract awards or purchases will include a fiscal impact statement disclosing the
expected operating impact of the project or acquisition and when such cost is
expected to occur.
6. Reserve Policies:
It is the goal of the City to obtain and maintain a General Fund operating reserve (Rainy
day fund) in the form of cash, of at least 40% of prior year audited annual General Fund
revenues to cover normal seasonal cash flow variations, as well as unforeseen
emergency or catastrophic impacts upon the City.
• One-time revenue windfalls should be designated as a reserve or used for one-
time expenditures. The funds should not be used for on-going operations. For
purposes of this policy, one-time revenue windfalls shall include:
CalPERS rebates
Tax revenue growth in excess of 10% in a single year
Unexpected revenues (e.g., litigation settlement)
Any other revenues the City Council may elect to designate as
extraordinary
• All unexpended General Funds from the prior fiscal year will be deposited in the
General Fund Reserve Fund (Rainy Day Fund.)
• The City will strive to maintain the Municipal Self-Insurance Fund with a July 1
balance of $250,000.
• The City will strive to transfer $250,000 annually into the Utilities Fund for the
purpose of building up the necessary balance for underground projects.
• Enterprise Fund (e.g., for refuse collection) user fees and charges will be examined
annually to ensure that they recover all direct and indirect costs of the service,
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FINANCIAL POLICIES 05/23/2022 6
provide for capital improvements and maintenance and maintain adequate
reserves. Moreover, maintenance of cash reserves will provide a de facto rate
stabilization plan. Rate increases shall be approved by the City Council following
formal noticing and public hearing. Rate adjustments for enterprise operations will
be based on five-year financial plans unless a conscious decision is made to the
contrary. The current cash reserves shall be adjusted annually and will be equal
to the proposed annual General Fund subsidy to the Refuse Fund and will be
budgeted as a Transfer into the Refuse Fund.
• The City has established a PARS Pension Rate Stabilization Program Section 115
Trust. The Trust was created to fund the City’s unfunded PERS Pension Liability
and as funds are available they would be deposited into the Trust in order to
maintain adequate reserves.
7. Budget Policies:
The function of the City of Rolling Hills is primarily administrative.
A. Categories of Funds
• The City’s annual budget contains fifteen different funds managed in
conformance with the City’s Fund Balance Policy:
General Fund
Community Facility Fund
Self-Insurance Fund
Refuse Fund Traffic Fund Transit Fund - Proposition A
Transit Fund - Proposition C
Transit Fund – Measure R
Transit Fund – Measure M
LA County Measure W
Capital Projects Fund
Citizens Options for Public Safety Fund (COPS) Fund
California Law Enforcement Equipment Program (CLEEP) Fund.
Utility Fund
OPEB (Post-Employment Benefits Other Than Pensions) Fund
• Each fund is considered to be a separate accounting entity for budgeting and
financial reporting purposes.
• The operations of each fund are accounted for by providing a separate set of self-
balancing accounts which are comprised of each fund’s assets, liabilities, equity,
revenues and expenditures, as appropriate.
• The City resources are allocated to and for individual funds based upon the
purpose of the spending activities.
• All funds and reserves will be evaluated annually for long-term adequacy and use
requirements in conjunction with development of the City’s long-term budget
assumptions.
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FINANCIAL POLICIES 05/23/2022 7
• For approved capital projects unexpended budget appropriations would be
reviewed annually by the Finance/Budget/Audit Committee for recommendation
for carryover to the following fiscal year.
B. Operating Budget Guidelines
• The Budget is detailed - Expenditures are authorized line by line, item by item. Line
items are used to limit precisely the amount and narrowly define what can be spent.
• The Budget is annual - The annual budget period is from July 1 to June 30. The
time span of the authority to spend is restricted to one year. Each year the regular
cycle of budgeting is repeated.
• The budget is comprehensive – The budget is prepared for all funds expended by
the City.
• The City adopts a budget by June 30 of each year.
• Comparative Data - Comparative data from the prior year is presented in the
annual budget in order to provide an understanding of changes in the City’s
financial position and operation.
• Public Hearing - The City Council reviews a tentative budget and adopts the final
budget. A public hearing is conducted to receive comments prior to adoption.
C. Financial Review
Throughout the fiscal year, monthly financial reports comparing actual
amounts with budgeted amounts are prepared by the Finance Director
and submitted to the City Manager and members of the City Council. As
these reports are reviewed, attention is drawn to variances between
budgeted amounts and actual amounts.
D. Budgeted Revenues & Expenditures
The City reviews fees and charges to keep pace with the cost of providing
the service.
8. Debt Management Policies:
The City will seek to avoid incurring debt. While the City is disposed to funding capital
improvements and expenditures on a cash basis, the City will consider, and when
necessary, enter into debt financing for citywide public improvement projects such as
sewers and utility undergrounding.
• Lease Equipment - Office Equipment has been leased on a monthly basis with
the expense incurred at the time of payment.
Policy Administrative History:
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FINANCIAL POLICIES 05/23/2022 8
Adopted September 24, 2007
Revised and Adopted March 24, 2008
Revised and Adopted February 23, 2009
Revised and Adopted March 8, 2010
Reviewed and Adopted February 28, 2011
Revised and Adopted May 23, 2011
Reviewed and Adopted May 14, 2012
Reviewed and Adopted April 22, 2013
Revised and Adopted September 9, 2013
Reviewed and Adopted March 24, 2014
Reviewed and Adopted April 27, 2015
Reviewed and Revised April 25, 2016
Reviewed and Adopted April 24, 2017
Reviewed and Adopted April 22, 2019
Reviewed and Adopted May 11, 2020
Reviewed and Adopted May 23, 2022
392
Agenda Item No.: 7.N
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH, CITY CLERK / EXECUTIVE ASSISTANT TO
CITY MANAGER
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:UPDATE ON RESTRICTED TRANSPORTATION FUND PROJECTS
DATE:May 23, 2022
BACKGROUND:
The Proposition A, Proposition C, and Measure R and Measure M Local Return programs are
four one-half cent sales tax measures approved by Los Angeles County voters to finance a
countywide transit development program.
By ordinance, Metro is responsible for administering the programs and establishing guidelines.
The Proposition A tax measure was approved in 1980, the Proposition C tax measure was
approved in 1990, Measure R was approved in 2008 and Measure M was approved in 2016.
Collection of the taxes began on July 1, 1982; April 1, 1991; July 1, 2009; and July 1, 2017,
respectively, while each year, more than $1 billion is generated in local transportation
revenue.
As a condition of voter approval, 25 percent of the Proposition A tax revenues, 20 percent of
the Proposition C tax revenues, 15 percent of Measure R and 17 percent of Measure M tax
revenues are earmarked for the Local Return Programs to be used by cities and the County of
Los Angeles in developing and/or improving local public transit, paratransit and related
transportation infrastructure.
Local Return funds are allocated and distributed monthly to jurisdictions on a “per capita”
basis by Metro.
Transportation Development Act (TDA) Article 3
Transportation Development Act (TDA) Article 3 bicycle and pedestrian funds are available to
local agencies in Los Angeles County (all cities and the County) on an annual basis. The final
amount is subject to revision based on actual receipts. These funds may be used for
operations, maintenance, design, and construction of pedestrian and bicycle facilities and
393
amenities (including wheelchair ramps).
TDA Article 3 local funds are allocated to local agencies on a per-capita basis. The amount of
each agency’s allocation is detailed in Metro’s Funding Allocation Procedure (FAP). Fifteen
(15) percent of the total annual allocation amount will be designated to the City and the County
of Los Angeles, with 30 percent going to the City and 70 percent going to the County, to cover
their maintenance costs on seven pre-determined regionally significant Class I bicycle
facilities. These percentages were Metro Board approved and are based on previous
maintenance expenditures on these facilities by the City and the County.
TDA Article 3 funds may be used for the following activities relating to pedestrian and bicycle
facilities (including sidewalk wheelchair ramps):
Engineering expenses leading to construction.
Maintenance of bicycling trails
Right-of-way acquisition.
Construction and reconstruction.
Retrofitting existing bicycle and pedestrian facilities, including installation of signage, to
comply with the Americans with Disabilities Act (ADA).
Route improvements such as signal controls for cyclists, bicycle loop detectors,
rubberized rail crossings and bicycle-friendly drainage grates.
Purchase and installation of bicycle facilities such as secure bicycle parking, benches,
drinking fountains, changing rooms, rest rooms and showers which are adjacent to
bicycle trails, employment centers, park-and-ride lots, and/or transit terminals and are
accessible to the general public.
DISCUSSION:
Measures R & M
On March 24, 2022, in order to avoid allocated Measure R & M local return funds from lapsing,
staff filed for Capital Reserves Projects. The intent was to ensure that funds could be
preserved for upcoming capital re-investments to the City Hall Campus that better serve the
Rolling Hills Community while meeting Metro's Active Transportation guidelines. The project
description written by staff was as follows: This project is meant to improve community access
for use of the city hall campus. Aspects include creating a pedestrian "ring pathway" around
the perimeter, asphalt replacement, drainage improvements, re-evaluating parking striping and
ADA accessibility amongst other potential ways for the community to actively engage.
Prop A & C
As the City does not have any potential Prop A projects due to our boundaries and unique
nature, it has been customary to exchange our lapsing funds to jurisdictions that could benefit
from them. This year, the City is exploring an exchange of funds with the City of Beverly Hills.
Any proceeds go to the General Fund.
TDA3
Metro staff has also communicated that they have some flexibility for communities like Rolling
Hills to tie-in other non-vehicle based modes that a pedestrian/equestrian community may
use. As such, staff is currently applying for a project related to both the overall future vision for
394
the City Hall campus pedestrian and mobility improvements combined with the requests of the
Rolling Hills Needs of Seniors Committee. The project description provided to Metro is as
follows:
As a result of COVID-19, the Rolling Hills Needs of Seniors Committee (NSC) has requested
improvements to the City Hall Campus in order to provide usable community outdoor space
and walking track for pedestrians who want to exercise, improved equestrian hitching posts
and /or bicycle racks, and adjacent gathering/sitting areas (both shaded and unshaded). They
have also requested improved lighting for early morning or evening hour usage. This project
will require the city to perform a topographic survey, enlist a landscape architect, contractors
and materials.
At the time of Agenda preparation, staff does not know if the project submitted will be
approved as presented or require modification.
FISCAL IMPACT:
None.
RECOMMENDATION:
Receive and file.
ATTACHMENTS:
395
Agenda Item No.: 10.A
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH, CITY CLERK / EXECUTIVE ASSISTANT TO
CITY MANAGER
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:DISCUSS 2022 SCE RELIABILITY REPORT AND WILDFIRE
DETECTION CAMERAS ON THE PENINSULA (DIERINGER)
DATE:May 23, 2022
BACKGROUND:
On May 9, 2022, during her meeting with the City Manager, Councilmember Dieringer
requested a representative from Southern California Edison (SCE) attend the May 23, 2022
City Council meeting to answer her questions on the 2022 Reliability Report and installation of
wildfire cameras on the Peninsula.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
None.
ATTACHMENTS:
396
Agenda Item No.: 10.B
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH, CITY CLERK / EXECUTIVE ASSISTANT TO
CITY MANAGER
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:DISCUSS EXISTING CELLULAR SERVICE ISSUES (BLACK)
DATE:May 23, 2022
BACKGROUND:
At a recent Council Meeting Mayor Black requested to agendize this item for further
discussion.
DISCUSSION:
None.
FISCAL IMPACT:
None.
RECOMMENDATION:
None.
ATTACHMENTS:
397
Agenda Item No.: 11.A
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:ROBERT SAMARIO, FINANCE DIRECTOR
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:CITY COUNCIL FISCAL YEAR 2022-23 BUDGET WORKSHOP
DATE:May 23, 2022
BACKGROUND:
On May 9, 2022, staff presented the proposed fiscal year 2022-23 revenue and expenditure
budgets for all funds to the Budget Committee, with the focus of the presentation being on the
General Fund. The recommended budget for the General Fund included $4,407,456 in
expenditures, including $1,269,000 in transfers to other funds, of which $1,096,000 was a
transfer to the Capital Improvement Fund primarily for the City Hall Improvements Capital
Project. With estimated revenues of $2,399,289, the recommended budget presented to the
Budget Committee would have resulted in an operating deficit of $738,667 and an overall
deficit of $2,008,167.
The Budget Committee directed staff to break down the recommended budget between on-
time and ongoing components, and make whatever adjustments are needed to eliminate the
ongoing deficit. This will allow Council to determine which one-time costs, such as capital, can
be appropriately funded from the use of reserves.
DISCUSSION:
REVENUE PROJECTIONS FOR FISCAL YEARS 2021/22 AND 2022-2023
The development of the fiscal year 2022/23 projected revenues began with a projection of
current year revenues. With only nine months of revenues recorded, the year-end revenue
totals were projected based on several factors, including prior year results, current year
trends, and other pertinent data.
By far, the largest General Fund revenue is derived from property taxes. The current year
adopted budget of $1,249,800 assumed a 4% growth. Staff expects actual revenues at year
end will be $1,281,715 representing a growth of 4.8%. For fiscal year 2022/23, staff
recommends again using a growth rate assumption of 4%, which would translate into a
projected revenue of $1,333,000. The 4% growth rate consists of a CPI factor of 2%, which is
398
the maximum increase allowed under Proposition 13, plus another 2% growth based on re-
assessments for resales and home improvements.
A related revenue is Property Transfer Tax. Whenever a real estate property is sold in the City
of Rolling Hills, a transfer tax is levied at $1.10 for every $1,000 in the sale price. The tax is
split 50/50 between the City of Rolling Hills and Los Angeles County. In fiscal year 2020/21,
revenues totaled $96,433. This fiscal year revenues are expected to reach $117,986. For
fiscal year 2022/23, staff recommends an assumed growth of 2% as a conservative approach
given the recent spike in mortgage rates will likely result in fewer home sales.
The second largest General Fund revenue is from Building & Other Permits. These revenues
have experienced a dramatic decline as a result of the pandemic, dropping to $183,378 in
fiscal year 2020/21. Before the pandemic, building-related permit revenues exceeded
$700,000. With the pandemic seemingly waning, revenues have experienced a moderate
rebound. Based on revenues received through March 31, 2022, staff estimates revenues at
year end at $472,969. Accordingly, staff proposes estimated revenues for fiscal year 2022/23
of $475,000, recognizing that if the current trend continues, revenue could be higher.
Motor Vehicle In-Lieu (MVIL) tax revenues are fairly flat from the prior year. Projected fiscal
year 2021/22 revenues of $246,694 are 4.2% higher than last year. Staff recommends a
assuming a 2% growth and total revenues for next fiscal year $252,000. The unknown is to
what degree higher interest rates, which affect rates offered on car loans, will affect new car
sales. Otherwise, MVIL taxes trend downward absent new car sales as the tax rate is applied
on a depreciating scale.
In total, staff recommends total General Fund budgeted revenues of $2,619,971, which
includes one-time revenues for the ARPA grant of $220,682. As such, ongoing revenues of
$2,399,289 are $274,989 higher than fiscal year 2021/22 adopted revenues, buoyed primarily
by the increase in property taxes and building permit revenues.
GENERAL FUND EXPENDITURE PROJECTION FOR FISCAL YEAR 2022-2023
The revised recommended budget, as shown in the attached schedule, totals $4,369,997
which is made up of $2,983,131 in on-going costs and $1,386,266 in one-time costs. The
ongoing costs in many cases have been trimmed to what essential costs and services.
The one-time costs include a $1,096,000 transfer to the Capital Improvement Fund primarily
for the City Hall Improvements Capital Project. The balance of $285,200 in one-time costs
were identified within the various expenditure accounts, including the following:
Project Management - $45,000
Grant Writer - $17,000
Agenda system Granicus enhancements - $19,400
399
Information Technology enhancements - $8,800
Records Management - $45,000
Special Project Study & Consulting (General Plan update) - $150,000
The following highlights the proposed expenditures:
Block Captain Program, fire fuel abatement in the Preserve, Emergency Information
System (EIS) support, Alert Southbay subscription
3.5% Cost of Living Adjustment to salaries
Increased City Attorney fee based on BBK's activities of the last two fiscal years
Fees for the November 2022 Municipal Election
Increased Finance Department fee for grants management, reimbursement support,
restricted funds management, benefits/pension activities for city personnel, and
technology implementation.
Contracted code enforcement services.
Anticipated subsidy to absorb the cost increase to residents' refuse fees.
Capital Improvement Cost for the City Hall ADA design, and construction.
OVERALL GENERAL FUND BALANCING
Based strictly on ongoing revenues and ongoing costs, the General Fund deficit is now down
to $480,984. The one-time costs of $1,386,266 would be offset by one-time ARPA revenues
of $220,682, leaving a one-time deficit of $1,165,584. On a combined basis, including all
revenues and expenditures, the General Fund budget would require the use of reserves of
$1,646,568 to balance.
OPTIONS FOR BALANCING THE GENERAL FUND
Staff have developed several options for addressing the projected operating deficit $480,984,
which are included in the attached schedule of balancing options. The balancing options
provide a number of cost reductions and revenue enhancements that in total range from
approximately $535,000 to $610,000. With respect to one-time costs of $1,386,266, Council
can choose which, if any, can be funded from reserves. From a policy perspective, the use of
reserves (a one-time source) can appropriately be used to fund one-time costs, such as
capital. Given General Fund reserve balances are currently in excess of 150% of the operating
budget, Council has some latitude in the use of reserves for any one-time cost deemed to be a
high priority.
OTHER FUNDS FOR FISCAL YEAR 2022-2023
Majority of the restricted funds such as Proposition C, Measure R, Measure M, and Measure A
are expected to roll the revenue to future years to save up for eligible projects. The following
summarizes the anticipated activities of the other restricted funds for next fiscal year:
Measure W's expenditure plan for FY 2022-2023 was previously approved by the City
Council in March 2022 and submitted to the Los Angeles County for approval. It is
anticipated that $80,000 of Measure W would be spent on eligible storm water
compliance measures.
The City of Beverly Hills expressed interest in $45,200 of Prop A exchange.
The Coronavirus State and Local Fiscal Recovery funds (American Rescue Plan Act -
400
ARPA) is expected to provide half of the overall allocation.
The Capital Projects fund includes $96,000 for Pacific Architecture Engineers' design fee
recently approved by the City Council for the development of layout Option 3 and $1M
for construction of the City Hall ADA Improvement project.
The Refuse fund anticipates absorbing the expected refuse rate increase for residents.
The newly established Fund 16 Cal OES captures the grants awarded to the city in the
last two years with transfers from the Utility Fund (Southern California Edison Rule 20
credits) for grant match.
FISCAL IMPACT:
The fiscal impact will be determined when the Fiscal Year 2022/23 Budget has been adopted.
RECOMMENDATION:
Review the proposed Fiscal Year 2022/23 budget and provide staff with comments. With the
Council’s direction, staff will bring the Fiscal Year 2022/23 Budget and the three-year CIP to
the City Council Meeting for adoption on June 13, 2022.
ATTACHMENTS:
CL_AGN_220523_FY2023_Revenue Budget Recommendations.pdf
CL_AGN_220523_FY2023_Recommended Budget_General Fund Exp.pdf
CL_AGN_220523_FY2023 Summary of Sources and Uses of Funds_General Fund.pdf
CL_AGN_220523_Twelve Year History_ Rev Exp and Reserves.pdf
CL_AGN_FY22-23_OptionsToCloseBudgetDeficit_v2.pdf
CL_AGN_220523_FY2023 Recommended Budget - Other Funds.pdf
CL_AGN_220523_CC_BlueFolderItem_11A_01_Redacted.pdf
401
FY 2022 FY 2022 FY 2023
FY 2021 Adopted Revenues Year-End Projected FY 2023 Projected
Revenues Budget 03/31/22 Projection Growth Projection Growth
Property Taxes 1,222,947$ 1,249,800$ 775,950$ 1,281,715$ 4.8%1,333,000$ 4.0%
Sales Taxes 23,262 4,800 18,014 18,550 -20.3%19,300 3.0%
Property Transfer Tax 93,449 40,200 96,433 117,986 26.3%121,500 2.0%
Disaster Grants 50,000 20,000 13,040 13,040 -73.9%- N/A
Motor Vehicle In Lieu 236,725 246,100 124,694 246,694 4.2%252,000 2.0%
Building & Other Permits 183,378 300,000 354,727 472,969 157.9%475,000 Flat
Variance, Planning & Zoning 49,158 22,000 14,596 19,461 -60.4%20,000 Flat
Animal Control Fees 472 1,000 160 213 -54.9%250 Flat
Franchise Fees 10,753 14,900 10,274 13,699 27.4%14,000 Flat
Fines & Traffic Violations 4,293 14,300 3,712 4,950 15.3%4,500 Flat
RHCA Lease Revenue 68,988 68,000 51,743 68,991 0.0%69,000 Flat
Interest on Investments 90,251 80,000 22,670 30,227 -66.5%60,239 N/A
Public Safety Aug Fund 1,003 800 895 1,193 19.0%1,000 Flat
Burglar Alarm Response 500 600 - - -100.0%500 Flat
Miscellaneous Revenue 3,275 37,800 35,071 36,000 999.2%5,000 Flat
Transfers In - ARPA 220,682 100.0%220,682 Flat
Transfers In - Refuse Fund 24,000 24,000 18,000 24,000 0.0%24,000 Flat
TOTALS 2,062,454$ 2,124,300$ 1,539,978$ 2,570,369$ 24.6%2,619,971$
CITY OF ROLLING HILLS
General Fund Revenues
FY 2022 and 2023 Projection
402
Adopted Year-End Presented to
Budget Projections FAB - May 9 Ongoing One-Time Total
01 - CITY ADMINISTRATOR
702 Salaries -Full Time 429,100$ 408,639$ 451,448$ 474,258$ -$ 474,258$
710 Retirement CalPERS-Employer 29,000 36,431 30,508 39,769 - 39,769
712 CalPERS Unfunded Liability 59,026 57,063 65,095 65,095 - 65,095
715 Workers Compensation Insurance 7,700 7,271 8,100 8,100 - 8,500
716 Group Insurance 55,000 76,111 11,446 71,316 - 71,316 8100 0.669 12673 8491
717 Retiree Medical 30,300 37,159 35,231 35,231 - 35,231 4000 12700
718 Employer Payroll Taxes 28,400 25,071 29,876 36,997 - 36,997 12100 8500
719 Deferred Compensation 4,300 3,732 4,523 4,559 - 4,559 4200
720 Auto Allowance 4,800 5,067 4,800 4,800 - 4,800
XXX Phone Allowance 1,300 - 1,300 1,970 - 1,970
740 Office Supplies 38,040 25,184 11,000 11,000 - 11,000
745 Equipment Leasing Costs 14,850 11,048 11,450 11,450 - 11,450
750 Dues & Subscriptions 15,240 4,596 16,240 16,240 - 16,240
755 Conference Expense 10,000 9,052 10,000 10,000 - 10,000
757 Meetings Expense 2,000 3,357 2,000 2,000 - 2,000
759 Training & Education 5,000 - 5,000 5,000 - 5,000
761 Auto Mileage 500 - 500 500 - 500
765 Postage 20,000 12,468 21,100 21,000 - 21,000
770 Telephone 5,700 5,959 - - - -
775 City Council Expense 10,000 2,440 10,000 10,000 - 10,000
776 Miscellaneous Expenses - 564 6,200 6,200 - 6,200
780 Communications/Newsletters and Outreach 6,000 3,007 26,560 5,000 - 5,000
785 Codification 5,000 3,749 5,000 5,000 - 5,000
790 Advertising 1,000 - 2,400 2,400 - 2,400
795 Other Gen Admin Expense 4,900 2,422 1,050 1,050 - 1,050
801 City Attorney 91,000 119,887 120,000 120,000 - 120,000
802 Legal Expense - Other 3,000 - 3,000 3,000 - 3,000
820 Website 6,000 12,179 6,000 6,000 - 6,000
850 Election Expense City Council - 222 36,000 15,000 - 15,000
890 Consulting Fees 161,400 69,903 62,000 - 62,000 62,000
XXX Records Management 46,700 1,700 45,000 46,700
955 Disaster Emergency Equipment - 2,784 - - -
Total City Administrator 1,048,556 945,366 1,044,527 994,635 107,000 1,102,035
Revised - Version 2
CITY OF ROLLING HILLS
General Fund
Projected FY 2021-22 and Recommended FY 2022-23 Expenditures
FY 2021-22 FY 2022-23 Recommended
Department/Object Account
1 Page: 1403
Adopted Year-End Presented to
Budget Projections FAB - May 9 Ongoing One-Time Total
Revised - Version 2
CITY OF ROLLING HILLS
General Fund
Projected FY 2021-22 and Recommended FY 2022-23 Expenditures
FY 2021-22 FY 2022-23 Recommended
Department/Object Account
05 - Finance
750 Dues & Subscriptions 200 - 2,000 2,000 2,000
810 Annual Audit 17,630 17,110 18,500 18,500 18,500
890 Consulting Fees 99,500 116,167 120,000 120,000 - 120,000
Total Finance 117,330 133,277 140,500 140,500 - 140,500
15- PLANNING & DEVELOPMENT
702 Salaries 237,200 189,687 234,237 236,748 - 236,748
703 Salaries - Part-Time 26,600 26,587 - 26,587
710 Retirement CalPERS-Employer 17,750 14,345 18,673 18,100 - 18,100
715 Workers Compensation Insurance 3,800 3,581 4,000 4,000 - 4,200
716 Group Insurance 30,900 23,162 32,510 44,275 - 44,275
718 Employer Payroll Taxes 18,790 14,663 19,672 20,237 - 20,237
719 Deferred Compensation 1,200 - - - - -
720 Auto Allowance 2,400 1,467 2,400 1,200 - 1,200
XXX Phone Allowance 600 - 600 600 - 600
758 Planning Commission Meetting - 1,415 -- - -
761 Auto Mileage - 50 300 300 - 300
770 Telephone - 1,281 - - - -
776 Miscellaneous Expense 2,000 1,301 - - - -
750 Dues & Subscription 850 - 1,000 1,000 - 1,000
755 Conference Expense 5,000 - 5,000 5,000 - 5,000
759 Training & Education 1,000 - 1,000 1,000 - 1,000
790 Publication - 3,208 15,000 15,000 - 15,000
801 City Attorney - 811 - - -
802 Legal Expenses-Other - 23,169 20,000 20,000 - 20,000
872 Property Development-Legal Exp 100,000 33,336 80,000 80,000 - 80,000
878 Build Inspect. LA County 150,000 191,785 150,000 150,000 - 150,000
xxx Willdan Building 50,000 50,000 - 50,000
881 Storm Water Management 275,800 231,435 280,000 97,142 - 97,142
882 Variance & CUP Expense 7,000 10,613 - - - -
884 Special Project Study & Consulting 180,000 79,584 170,000 20,000 150,000 170,000
886 Consulting Fees - - 87,880 87,880 - 87,880
2 Page: 2404
Adopted Year-End Presented to
Budget Projections FAB - May 9 Ongoing One-Time Total
Revised - Version 2
CITY OF ROLLING HILLS
General Fund
Projected FY 2021-22 and Recommended FY 2022-23 Expenditures
FY 2021-22 FY 2022-23 Recommended
Department/Object Account
950 Capital Outlay 26,400 - - - - -
Total Planning & Development 1,060,690 824,891 1,198,872 879,069 150,000 1,029,269
25 - Public Safety
830 Law Enforcement 220,380 181,251 225,000 225,000 - 225,000
833 Other Law Enforcement Expenses 3,000 3,651 4,000 4,000 - 4,000
837 Wild Life Mgmt & Pest Control 50,000 1,883 10,000 10,000 - 10,000
838 Animal Control Expense 6,000 4,398 6,000 6,000 - 6,000
Total Public Safety 279,380 191,183 245,000 245,000 - 245,000
65 - NON-DEPARTMENTAL
895 Insurance & Bond Expense 30,260 21,816 25,000 29,657 - 29,657
901 South Bay Comm. Organization 20,100 4,017 15,000 15,000 - 15,000
915 Community Recognition 16,000 5,624 20,000 20,000 - 20,000
916 Civil Defense Expense 650 - - - - -
917 Emergency Preparedness 137,360 195,894 218,845 188,200 - 188,200
985 Contingency 25,000 - - - - -
Total Non-Departmental 229,370 227,351 278,845 252,857 - 252,857
75 - CITY PROPERTIES
925 Utilities 33,810 35,493 85,212 85,212 - 85,212
930 Repairs & Maintenance 36,963 26,793 35,000 35,000 - 35,000
932 Area Landscaping 28,500 12,760 25,000 12,500 - 12,500
XXX Capital Outlay - Buildings & Equip 250,000 - - - - -
XXX IT Services - - 50,000 54,000 8,866 62,866
XXX Granicus Services - - 30,000 8,000 19,400 27,400
XXX Computer Hardware Fund - - 5,000 5,000 - 5,000
Total City Properties 349,273 75,046 230,212 199,712 28,266 227,978
TOTALS BEFORE TRANSFERS 3,084,599 2,397,113 3,137,956 2,711,773 285,266 2,997,639
OPERATING TRANSFERS OUT
699 Traffic Safety Fund 10,000 10,000 5,000 - 5,000 5,000
Capital Improvement Fund 88,000 88,000 1,096,000 - 1,096,000 1,096,000
3 Page: 3405
Adopted Year-End Presented to
Budget Projections FAB - May 9 Ongoing One-Time Total
Revised - Version 2
CITY OF ROLLING HILLS
General Fund
Projected FY 2021-22 and Recommended FY 2022-23 Expenditures
FY 2021-22 FY 2022-23 Recommended
Department/Object Account
Refuse Collection Fund 159,200 159,200 168,500 168,500 - 168,500
Total Transfers Out 257,200 257,200 1,269,500 168,500 1,101,000 1,269,500
GENERAL FUND TOTALS 3,341,799$ 2,654,313$ 4,407,456$ 2,880,273$ 1,386,266$ 4,267,139$
4 Page: 4406
FY 2022-23
Recommended
ONGOING
Operating Revenues - Ongoing 2,399,289$
Operating Expenditures - Ongoing 2,880,273
Net Operating Surplus (Deficit)(480,984)
ONE-TIME
One-time Revenues
ARPA Grant 220,682
One-Time Costs
Operating Expenditures 290,266
Capital Improvements 1,096,000
1,386,266
Net Use of Reserves for One-Time Costs (1,165,584)
TOTAL USE OF RESERVES (1,646,568)$
CITY OF ROLLING HILLS
Summary of Proposed One-Time vs Ongoing Revenues and Expenditures
GENERAL FUND
407
408
$3,321,129
$3,110,058
$3,340,499
$3,831,115
$4,372,689
$4,600,994
$4,806,155 $5,120,797
$5,795,780
$5,617,133
$5,650,328
$4,432,829
$5,345,702
$3,595,676
$-
$1,000,000
$2,000,000
$3,000,000
$4,000,000
$5,000,000
$6,000,000
$7,000,000
2010-11
Actual
2011-12
Actual
2012-13
Actual
2013-14
Actual
2014-15
Actual
2015-16
Actual
2016-17
Actual
2017-18
Actual
2018-19
Actual
2019-20
Actual
2020-21
Actual
2021-22
Budget
2021-22
Projected
2022-23
Proposed
CITY OF ROLLING HILLS
HIstory of Revenues, Expenditures and Fund Balance
General Fund
Fund Balance Revenues Expenditures
409
Description Amount Impact
1 Eliminate funding of contracted part-time Code
Enforcement services
$87,880 Workload will be spread among the current
positions, prolonging the processing of
cases, reducing productivity on all other
positions, and reducing the overall service
level to residents.
2 Delay fire fuel abatement in the Preserve slated
for FY 22-23 to future years when projected
revenue is more aligned with projected
expenditures.
$82,000 Not leverage the fire fuel abatement work
performed to date and will not diminish
risk of wildfires originating from the
Preserve.
3 Reduce support for the Block Captain Program $25,000 Constrain Block Captain Program initiatives
such as educational programs for
community, support for zone meetings,
and community emergency prepardness
events.
4 Reinstate building permit multiplier to 2.5% pre
FY18-19 level. Multiplier was reduced to 2.25%
commencing in FY 2018-2019.
$20,000 - $75,000 Financial burden on development
applicants. Revenue level depends on the
level of building activities.
5 Cost recover publication expenses associated
with development projects.
$15,000 Financial burden on development
applicants.
6 Cost recover staff time on processing
development applications.
$30,000 - $50,000 Financial burden on development
applicants. Could deter development
activities and or improve submittal quality
and ultimately improve efficiency on the
developers' activities.
7 Use of one-time ARPA revenues $220,682 No impact
8 Eliminate funding for Community Recognition $20,000 Eliminate holiday open house, and
appreciation lunch for volunteers. There
would be no community events sponsored
by the city. Lost opportunity for city
officials to engage the community socially.
9 Eliminate Repairs & Maint $35,000 Deferr repairs needed at City Hall and the
campus. Lost of functionality, and heavier
financial burden from anticipated increases
in improvement cost over time.
10 Fund deficit using reserves As needed Short term solution, reducing rainy day
fund.
11 Defer capital improvements As Needed Liability associated with deferred
maintenance and heavier financial burden
from anticipated increases in improvement
costs over time.
Total $535,562 - $610,562
Ongoing Budget Deficit $480,984
CITY OF ROLLING HILLS
Schedule of Proposed Options for Balancing the General Fund Ongoing Budget
Fiscal Year 2022-23
410
411
Actuals FY 2022
FY 2021 Adopted Amended Thru Year-End FY 2023
Actuals Budget Budget 03/31/22 Projection Recomm'd
10 - COPS FUND
Revenues
570 COPS Allocation 156,727$ 160,000$ 160,000$ 163,403$ 165,000$ 165,000$
670 Interest Earned 147 - - - - -
156,874 160,000 160,000 163,403 165,000 165,000
Expenditures
840 COPS Program Expenditures 176,180 160,000 160,000 104,914 179,852 165,000
Revenues Over (Under) Expenditures (19,453)$ -$ -$ 58,489$ (14,852)$ -$
11 - CLEEP FUND
Revenues
670 Interest Earned 27$ 50$ 50$ -$ 1,100$ 2,000$
Expenditures
840 CLEEP Technology Program - 1,100 1,100 2,000 1,100 2,000
Revenues Over (Under) Expenditures 27$ (1,050)$ (1,050)$ (2,000)$ -$ -$
13 - TRAFFIC SAFETY FUND
Revenues
699 Transfers In - General Fund 5,460$ 10,000$ 10,000$ -$ 4,390$ 5,000$
Expenditures
927 Road Striping - Delineators 5,460 10,000 10,000 4,390 4,390 5,000
Revenues Over (Under) Expenditures -$ -$ -$ (4,390)$ -$ -$
15 - ARPA FUND
586 American Rescue Plan Act -$ -$ 220,682$ 220,682$ 220,682$
16 - CAL OES FUND
CITY OF ROLLING HILLS
Fiscal Year 2022 Projections and FY 2023 Recommended Budget
412
Actuals FY 2022
FY 2021 Adopted Amended Thru Year-End FY 2023
Actuals Budget Budget 03/31/22 Projection Recomm'd
Revenues
588 Crest Road FEMA Grant - 4434-526-112R -$ -$ 1,145,487$ -$ 75,000$ -$
590 Vegetation Management FEMA Grant - HMGP-4382-175-13R - - 242,625 - 75,000 -
591 Eastfield Undergrounding FEMA Grant - DR-4382-177-7R-CA - - 1,971,882 - - -
589 Safety Element Disaster Grants - DR 4344 PL0521 - - - 13,040 13,040 -
699 Transfers In - Utility Fund - 4434-526-112R - - 381,819 - 25,000 -
699 Transfers In - Utility Fund - DR4382-177-7R - - 657,294 - - -
699 Transfers In - General Fund - - 80,875 - 25,000 -
Total Revenues - - 4,479,982 13,040 213,040 -
Expenditures
957 Crest Road East Project - 4434-526-112R - - 1,527,306 - 100,000 -
959 Veg. Mgmt Mitig. Proj. - HMGP-4382-175-13R - - 323,500 99,787 100,000 -
960 Eastfield Drive Utility U.G. - 4382-177-7R - - 2,629,176 - - -
958 Safety Element DR4344-PL0521 - - - 11,258 11,258 -
Total Expenditures - - 4,479,982 111,045 211,258 -
Revenues Over (Under) Expenditures -$ -$ (98,005)$ 1,782$ -$
25 - PROPOSITION A FUND
Revenues
500 Grant Revenues 38,067$ 38,000$ 38,000$ 35,462$ 47,283$ 45,000$
670 Interest Earned 165 600 600 - 200 200
Total Revenues 38,232 38,600 38,600 35,462 47,483 45,200
Expenditures
905 Prop A Exchange 84,000 - - - 45,200
Revenues Over (Under) Expenditures (45,768)$ 38,600$ 38,600$ 35,462$ 47,483$ -$
26 - PROPOSITION C
Revenues
501 Grant Revenue-Prop C 31,575$ 31,500$ 31,500$ 29,416$ 39,221$ 37,000$
670 Interest Earned 125 650 650 - 200 200
Total Revenues 31,700 32,150 32,150 29,416 39,421 37,200
Expenditures
906 Prop C Gifted 65,000 - - - - -
Revenues Over (Under) Expenditures (33,300)$ 32,150$ 32,150$ 29,416$ 39,421$ 37,200$
27- MEASURE R TRANSIT
Revenues
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Actuals FY 2022
FY 2021 Adopted Amended Thru Year-End FY 2023
Actuals Budget Budget 03/31/22 Projection Recomm'd
502 Measure R Grant Revenues 23,714$ 24,000$ 24,000$ 22,061$ 29,414$ 28,000$
670 Interest Earned 206 1,000 1,000 - 200 200
Total Revenues 23,920 25,000 25,000 22,061 29,614 28,200
Expenditures
907 Measure R Gifted - - - - - -
Revenues Over (Under) Expenditures 23,920$ 25,000$ 25,000$ 22,061$ 29,614$ 28,200$
29 - MEASURE M
Revenues
507 Measure M Local Return 26,869$ 26,500$ 26,500$ 24,966$ 33,288$ 31,000$
670 Interest Earned 167 1,100 1,100 - 200 200
Total Revenues 27,036 27,600 27,600 24,966 33,488 31,200
Expenditures
909 Measure M Gifted - - - -
Revenues Over (Under) Expenditures 27,036$ 27,600$ 27,600$ 24,966$ 33,488$ 31,200$
30 - MEASURE W
Revenues
508 Grant Revenues 103,577$ 110,000$ 110,000$ 104,742$ 104,742$ 105,000$
670 Interest Earned - 900 900 -
Total Revenues 103,577 110,900 110,900 104,742 104,742 105,000
Expenditures
907 Storm Water Management - 38,750 38,750 2,926 50,000 80,000
Revenues Over (Under) Expenditures 103,577$ 72,150$ 72,150$ 101,817$ 54,742$ 25,000$
35 - MEASURE A
Revenues
502 Grant Revenue -$ 26,100$ 26,100$ -$ -$ -$
670 Interest Earned - 900 900 - - -
Total Revenues -$ 27,000$ 27,000$ -$ -$ -$
40 - CAPITAL PROJECTS FUND
Revenues
699 Transfers from General Fund -$ 88,000$ 121,235$ -$ 88,000$ 1,096,000$
Expenditures
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Actuals FY 2022
FY 2021 Adopted Amended Thru Year-End FY 2023
Actuals Budget Budget 03/31/22 Projection Recomm'd
890 Consulting Fees 800 - - - - 96,000
XXX 1 Middleridge Lane South Storm Drain - - 33,235 32,616 75,000 -
947 Non-Building Improvements - 300,000 300,000 - - -
948 City Hall Improvements 33,561 - - 13,673 13,673 1,000,000
Total Expenditures 34,361 300,000 333,235 46,289 88,673 1,096,000
Revenues Over (Under) Expenditures (34,361)$ (212,000)$ (212,000)$ (46,289)$ (673)$ -$
41- UTILITY FUND
Revenues
550 Rule 20A Power Utility Grant Project -$ 763,638$ -$ -$ -$
Expenditures
803 Legal & Other Outside Counsel - - - 1,452 -
883 Sewer Feasibility Study 2,560 - - - -
886 Underground Utility Project 4,560 763,638 - - -
887 Sewer Feasibility Project 41,585 - - 40,321 40,321
999 Transfers Out - Cal OES Fund - - 1,039,113 - 25,000 -
Total Expenditures 48,705 763,638 1,039,113 41,773 65,321 -
Revenues Over (Under) Expenditures (48,705)$ -$ (1,039,113)$ (41,773)$ (65,321)$ -$
50 - REFUSE FUND
Revenues
441 Construction & Demo Permits 31,450$ 24,000$ 24,000$ 11,550$ 15,400$ 20,000$
665 Service Charges 753,500 753,500 753,500 565,128 753,504 780,000
618 Transfers In - General Fund 68,706 159,200 159,200 - 159,200 168,500
Total Revenues 853,656 936,700 936,700 576,678 928,104 968,500
Expenditures
776 Misc Expense 3,918 - - - -
815 Refuse Service Contract 886,143 912,700 912,700 684,522 912,700 944,500
999 Transfers Out 24,000 24,000 24,000 18,000 24,000 24,000
Total Expenditures 914,061 936,700 936,700 702,522 936,700 968,500
Revenues Over (Under) Expenditures (60,405)$ -$ -$ (125,844)$ (8,596)$ -$
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Agenda Item No.: 12.A
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH, CITY CLERK / EXECUTIVE ASSISTANT TO
CITY MANAGER
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:PRESENTATION OF EDUCATIONAL VIDEOS ON FIRE FUEL
MANAGEMENT IN THE CANYON; RECOGNIZE LEAD BLOCK
CAPTAIN GENE HONBO, BLOCK CAPTAIN DEBRA SHRADER, AND
LOS ANGELES COUNTY FIRE DEPARTMENT FORESTRY DIVISION
TREVOR MOORE FOR THEIR LEADERSHIP IN COMPLETING THE
PROJECT; AND DIRECT STAFF TO DISSEMINATE THE VIDEOS
THROUGH THE BLOCK CAPTAIN PROGRAM.
DATE:May 23, 2022
BACKGROUND:
At the City Council meeting on October 25, 2021, lead Block Captain Gene Honbo received
approval of his storyboards depicting new educational videos for the Rolling Hills community
on "Fuel Load Management in the Canyons." The city engaged WorldWise Productions, who
had previously produced the Home Hardening Videos, to do three days of video shoots
including local canyon and property footage. Deputy Forrester Trevor Moore of the Los
Angeles County Fire Department was involved in the videos and together with the Forestry
Division, provided support on the content.
The videos have been vetted by the Block Captains, approved at the highest level of the Los
Angeles County Fire Department and are ready for official presentation to the City Council and
subsequent distribution to the community via the City Website https://www.rolling-hills.org
The six video series takes residents through an easy to follow education on how to identify
and cure potential fire fuel issues on their properties and in the canyons covering the following
topics:
1. Introduction to Canyon Management
2. Fire Risks
3. Creating Fire Safe Canyons
4. Techniques to Follow
5. Environmental Concerns
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6. Canyon Management Overview
DISCUSSION:
The production of the educational videos is a part of the Block Captain Program's initiative to
educate the community on best practices to mitigate wildfire risks.
In 2021, the Hardening the Home educational videos were well received by the community as
informative and easy to understand. Anecdotally, the Hardening the Home educational videos
sparked actions in the community with reports to City Hall noting many have made
improvements as outlined in the videos.
A similar effort is intended with fire fuel management best practices for the canyons to further
reduce wildfire risks. To repeat the model of the Hardening the Home effort, the City Council
allocated budget and engaged the services of Wildland Res Management to provide private
property complimentary inspections by fire experts on vegetation management measures for
properties with canyons. As with the Hardening the Home complimentary inspections by Los
Angeles County Fire Department Trevor Moore, the complimentary inspections by Wildland
Res Management are recommendations and not enforceable by any agency.
The educational videos on fire fuel management in the canyons will be available on the City's
website. Staff recommends that the City Council roll out the educational videos through the
Block Captain Program.
Spearheading the education video series are Lead Block Captain Gene Honbo, Block Captain
Debra Shrader and Los Angeles County Fire Department Deputy Forester Trevor Moore.
These individuals donated, and dedicated their time and expertise to completing the project.
The City thanks the leaders of this project for their generous offering, their expertise, and
community minded efforts in keeping Rolling Hills prepared.
FISCAL IMPACT:
The production of the educational videos cost $25,000 funded with the budget allocated in the
Emergency Preparedness account.
RECOMMENDATION:
Approve as presented.
ATTACHMENTS:
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Agenda Item No.: 12.B
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:JOHN SIGNO, DIRECTOR OF PLANNING & COMMUNITY SERVICES
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:APPROVE AMENDED PROFESSIONAL SERVICES AGREEMENT WITH
CHAMBERS GROUP TO PREPARE A CEQA DOCUMENT FOR THE
6TH CYCLE HOUSING ELEMENT TO ADDRESS COMMENTS FROM
THE DEPARTMENT OF FISH AND WILDLIFE
DATE:May 23, 2022
BACKGROUND:
On November 22, 2021, the City Council approved an agreement with Chambers Group to
provide environmental consulting services for the City's 6th Cycle Housing Element and
Safety Element update. Chambers Group was selected as the environmental consultant to
assist the City with preparation of the environmental document for adoption of the City's
updated Housing and Safety elements because of the firm's high level of experience and
expertise.
The City had initially planned a single environmental document covering the Housing Element
and Safety Element, but this was bifurcated at the time the Safety Element was adopted in
March 28, 2022, due to comments received from an agency to include mitigation measures
that address potential housing development described in the Housing Element. Chambers
Group will be preparing an environmental document for the Housing Element that will consider
mitigation measures to address the concerns. Specifically, the concerns involved the potential
impacts of housing to be developed on vacant lots. As such, Chambers Group will do a
reconnaissance level biological survey/report on the vacant lots to be included in the
environmental document. Once completed, the environmental document will be circulated for
public review and brought to the Planning Commission and City Council at the same time as
the Housing Element.
DISCUSSION:
At the direction of the City Council, a mitigated negative declaration (MND) is being prepared
in accordance with the California Environmental Quality Act (CEQA) Guidelines that includes
mitigation measures to address potentially significant impacts on biological resources. Much of
the MND will be based on the environmental document prepared before the original document
was bifurcated, however, Chambers Group will be refining the entire document as it pertains
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to development of housing. Chambers Group is currently preparing the proposal which will be
delivered to the Council at the meeting. An amendment to the agreement will also be brought
to Council for consideration.
FISCAL IMPACT:
If approved, the City will fund the amended agreement with Chambers Group from the General
Fund reserves. The estimated amount is $50,000. Staff's recommendation includes a 20%
contingency up to $60,000.
RECOMMENDATION:
Authorize the preparation of a contract amendment approved to form by the City Attorney in a
not to exceed amount of $60,000; and authorize the City Manager to execute such an
agreement.
ATTACHMENTS:
Agreement for Planning Services - Chambers-EXECUTED.pdf
CL_AGN_220523_CC_BlueFolderItem_12B_IS-MND_ChangeOrder.pdf
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ID Task Name Duration Start Finish Predecessors
1 Task 1: Project Initiation 7 days Thu 12/2/21 Fri 12/10/21
2 Initial Meeting 1 day Wed 12/2/20Wed 12/2/20
3 Project Description 1 wk Thu 12/2/21 Wed 12/8/21 2
4 City Review of Project
Description
1 day Thu 12/9/21 Thu 12/9/21 3
5 Task 2: Preparation of the
Appropriate CEQA Document
and Supporting Technical
Studies
13 days Thu 12/9/21 Mon 12/27/21
6 Prepare Admin Draft
IS/MND
2 wks Thu 12/9/21 Wed 12/22/21 3
7 City Review of Admin Draft
IS/MND
3 days Thu
12/23/21
Mon 12/27/21 6
8 Tasks 3: Tribal Consult 90 days Fri 12/10/21 Thu 4/14/22
9 SB 18 90 days Fri 12/10/21 Thu 4/14/22 4
10 AB 52 30 days Fri 12/10/21 Thu 1/20/22 4
11 Task 4: Public Draft IS/MND
and Notices
28 days Tue
12/28/21
Thu 2/3/22
12 Prepare Public Draft
IS/MND and Notices
1 wk Tue
12/28/21
Mon 1/3/22 7
13 City Review of Public Draft
IS/MND And Notices
1 day Tue 1/4/22 Tue 1/4/22 12
14 Public Circulation 30 edays Tue 1/4/22 Thu 2/3/22 13
15 Task 5: Response to
Comments and Final IS/MND
11 days Mon
1/24/22
Mon 2/7/22
16 Prepare Draft Final IS/MND
with Response to
Comments and MMRP
9 days Mon
1/24/22
Thu 2/3/22
17 City Review of Draft Final
IS/MND with Response to
Comments and MMRP
1 day Fri 2/4/22 Fri 2/4/22 16
18 Prepare Final MND with
Response to Comments
and MMRP
1 day Mon 2/7/22 Mon 2/7/22 17
19 Task 6: Public Hearings 10 days Mon 2/7/22 Fri 2/18/22
20 Planning Commission 1 day Mon 2/7/22 Mon 2/7/22
21 City Council 1 day Fri 2/11/22 Fri 2/11/22
22 Prepare and submit NOD 1 wk Mon 2/14/22Fri 2/18/22 21
D J F M A
Half 1, 2022
Task
Split
Milestone
Summary
Project Summary
Inactive Task
Inactive Milestone
Inactive Summary
Manual Task
Duration-only
Manual Summary Rollup
Manual Summary
Start-only
Finish-only
External Tasks
External Milestone
Deadline
Progress
Manual Progress
Page 1
Project: City of Rolling Hills
Date: Fri 12/3/21
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"P:\CLIENT Change Order form.doc"
Rolling Hills Housing Element Update Project: Change Order Request 1
Date 5/20/2022 Change Order No. 1 Project Name Rolling Hills Housing Element
Client Contract No. Project No. 21330
Original Contract Amount $45,493.62
Net Amount of Previous Changes 0
Amount of this Change Order $53,765.62 (Amount @ Fixed Price) $53,765.62
Revised Contract Total $99,259.24
This Change Order was prepared for the following reason(s):
Due to a comment letter received during the public review period from the California Department of Fish and
Wildlife (CDFW) on the Initial Study / Negative Declaration (IS/ND) prepared for the City of Rolling Hills (City)
Housing Element Update, the City has opted to prepare a Mitigated Negative Declaration (MND) for the
Housing Element Update to address concerns brought forth by CDFW. As discussed with the City, Chambers
Group proposes to update the Project Description, complete a reconnaissance level biological survey/report,
and update the California Environmental Quality Act (CEQA) document to evaluate the sites on a
programmatic level. While the intent is to include mitigation measures for biological resources, looking at all
resources areas from a programmatic level may result in a need for mitigation in other resources areas. See
proposal attached.
Schedule: See attached. Project approval set for early October.
The work covered by this Change Order shall be performed in accordance with the same terms and conditions as
included in the original contract.
CHANGE AUTHORIZED BY:
CHAMBERS GROUP, INC.
(Client Company Name)
By By
(Printed) (Printed)
Signature Signature
Title Date Title Date
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Scope of Work
Approach to the Scope of Work
Due to a comment letter received during the public review period from the California Department of Fish and Wildlife
(CDFW) on the Initial Study / Negative Declaration (IS/ND) prepared for the City of Rolling Hills (City) Housing Element
Update, the City has opted to prepare a Mitigated Negative Declaration (MND) for the Housing Element Update to
address concerns brought forth by CDFW. As discussed with the City, Chambers Group proposes to update the Project
Description, complete a reconnaissance level biological survey/report, and update the California Environmental Quality
Act (CEQA) document to evaluate the sites on a programmatic level. While the intent is to include mitigation measures
for biological resources, looking at all resources areas from a programmatic level may result in a need for mitigation in
other resources areas. Chambers Group will commence work on these additional tasks as soon as we receive written
Notice to Proceed (NTP). We will accomplish the scope of work, which consolidates the tasks, as described below.
Task 1: Project Description Update
Chambers Group will update the Project description to include a more detailed discussion of the vacant sites that are
available for future housing development. The MND will be analyzed based on the updated Project Description.
Deliverables: One electronic portable document format (PDF) copy and one electronic copy in Microsoft Word format
of the Project Description for one round of review by the City.
Task 2: Technical Reports / Updates
Task 2.1: Tribal Consultation Update
As discussed with the City and the City’s legal counsel, it is not necessary for AB 52 or SB 18 consultation periods to be
re-opened. Nonetheless, as a courtesy to the consulting Tribes, an updated letter will be sent noting that, from a policy
perspective, nothing is changing and the Project still does not entitle any specific development. Chambers Group will
prepare this letter for the City to send to both of the consulting Tribes.
Deliverables: One draft electronic copy in Microsoft Word format of the letter.
Task 2.2: Biological Reconnaissance Constraints Survey and Letter Report
Chambers Group will conduct a biological reconnaissance survey for 20 vacant lots identified in the 2021-2029 Housing
Element. The sites proposed for a literature search and field survey include 1, 3, 4, 18-34, as identified in Table 4.2 of
the Rolling Hills Housing Element Draft for HCD Review (December 3, 2021). The purpose of the preliminary biological
study is to document existing conditions at each site and determine if there are any records of listed and/or sensitive
plant and wildlife species and communities occurring on or in the immediate vicinity of the 20 vacant lots proposed for
development. This task will include a review of the California Natural Diversity Database (CNDDB), the California Native
Plant Society’s Electronic Inventory (CNPSEI), the United States Fish and Wildlife Service (USFWS) Sensitive Species
Occurrences and National Wetland Inventory and National Hydrography Database maps, and aerial images.
After conducting the literature search, biologists familiar with the resources known or expected to occur in the project’s
vicinity will conduct a general reconnaissance-level survey of the biological resources in each of the proposed sites.
During the survey, the biologists will map plant communities and record photographs to document the current
conditions of the sites. The biologists will evaluate each lot for the potential for sensitive wildlife species that are known
to occur in the surrounding area including coastal California gnatcatcher (Polioptila californica californica), coastal
cactus wren (Campylorhynchus brunneicapillus), Palos Verdes blue butterfly (Glaucopsyche lygdamus palosverdesensis),
El Segundo blue butterfly (Euphilotes battoides allyni), western spadefoot (Spea hammondii), Lyon’s pentachaeta
(Pentachaeta lyonii), aphanisma (Aphanisma blitoides), south coast saltscale (Atriplex pacifica), Catalina crossoma
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(Crossosoma californicum), Island green dudleya (Dudleya virens ssp. insularis), Santa Catalina Island desert-thorn
(Lycium brevipes var. hassei), and woolly seablite (Suaeda taxifolia). An analysis of the habitats to potentially support
the presence of federal- and state-listed or otherwise sensitive plant and wildlife species within each lot will be
performed. This task does not include a formal jurisdictional delineation; however, the sites will be assessed for the
potential of waters under agency jurisdiction.
After completing the biological survey, Chambers Group will prepare one Biological Letter Report that will include
an introduction, methods used to conduct the surveys, results of the existing conditions of biological resources
within the survey areas, a discussion of sensitive species and plant and wildlife communities, and references cited.
The letter report will include a discussion of the potential for sensitive species to occur within the vacant lot sites.
The report will include current photographs and maps documenting existing site conditions. The report will also
discuss any waters or wetland habitats that may occur within each vacant lot. The report will identify potential
mitigation measures to avoid or reduce impacts as a result of project activities. The report will contain up to 40
pages of text and tables and up to 20 pages of appendices.
Assumptions:
• This scope of work assumes two biologists working two full days to survey and map the 20 vacant lots. If
additional surveys other than the biological reconnaissance surveys are required by the City, Chambers Group
will be pleased to provide these services under a separate cost and scope of work.
• This scope of work includes a general vegetation mapping effort and is not intended for impact analysis. If
impact analysis is required, detailed mapping to account for impacts at a square-foot level can be accomplished
under a change order.
• This scope of work does not include a formal jurisdictional delineation; however, the sites will be assessed for
the potential of waters under agency jurisdiction.
• This scope of work and cost does not include any costs associated with habitat mitigation. If required, Chambers
Group will be pleased to provide these services under a separate cost and scope of work.
• This scope of work does not include protocol-level surveys for listed or otherwise sensitive species. If required,
Chambers Group will be pleased to provide these services under a separate cost and scope of work.
• Additional meetings, agency consultations, permitting and additional sensitive species memos are not included
in this scope of work. If required, Chambers Group will be pleased to provide these services under a separate
cost and scope of work.
Deliverables: One electronic copy of the letter report will be provided for review within four weeks of completing the
survey. Chambers Group will incorporate one round of comments into the final report within two weeks of receiving
comments on the draft report. Electronic copies of the final report will be submitted.
Task 3: Preparation of the Updated CEQA Document
Based on discussions with the City and legal counsel, under this task Chambers Group will update the existing IS/ND to
include the results of the biological reconnaissance level survey and report and to evaluate the 20 vacant sites on a
programmatic level for each CEQA environmental checklist discipline item. This will result in an IS / MND and will include
mitigation measures for each resource area as appropriate.
For each CEQA environmental checklist discipline item, the existing environmental setting of the project site and
surroundings will be characterized from the existing literature base and additional technical study. An environmental
impacts analysis will be prepared for each checklist entry. Based on CEQA-defined significance criteria, Chambers Group
will determine the potential for any adverse or significant adverse impacts and present mitigation measures to reduce
any such impacts to a level below significance. It should be noted that while the intent is to include mitigation measures
for biological resources, looking at all resources areas from a programmatic level may result in a need for mitigation in
other resources areas.
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Assumptions: This task does not include any evaluation of any zone changes if requested by HCD. This task does not
include any additional technical studies as was the direction provided during discussions with legal counsel.
Deliverables: One electronic PDF copy and one electronic copy in Microsoft Word format of the Administrative Draft
MND for one round of review by the City.
Task 4: Public Review MND and Corresponding Notices
After receipt of one set of integrated comments on the Administrative Draft MND from the City, Chambers Group will
then revise the MND accordingly. Chambers Group will prepare and distribute copies of the Draft MND to the City,
State Clearinghouse, County Clerk, and affected public agencies.
For submittal to the State Clearinghouse (Office of Planning and Research [OPR]), Chambers Group will draft a Notice
of Intent (NOI), Notice of Completion (NOC), Summary Form, and the MND with associated appendices. Chambers
Group can submit these electronically on behalf of the City. The City must approve Chambers Group as a submitter on
the OPR CEQANet Web portal. For submittal to the County Clerk, documents will be sent via mail pending the status of
public access to County buildings. This proposal assumes no other agencies or interested parties would receive a copy
of the NOI. To comply with the CEQA guidelines, the City must distribute the NOI through at least one of the following
methods:
• Publication at least one time in a newspaper of general circulation in the area affected by the Project.
• Posting of the notice on and off-site in the area where the project is located.
• Direct mailing to the owners and occupants of property contiguous to the project.
Fees associated with coordinating and publishing to public newspapers, websites, or posting of a physical notice at the
Project will require a change order as these tasks are not included in this scope and associated fees for newspaper
postings vary.
Deliverables: An electronic PDF copy with appendices for the City. One electronic copy of the NOC, NOI, and Summary
Form for OPR submittal. One NOI to be filed with the County Clerk.
Task 5: Responses to Comments and Final CEQA Document
Chambers Group will prepare responses to comments received from public review. A draft of these responses will be
provided to the City for review. It is assumed that Chambers Group will coordinate with City to address public comments
received, and comments will be addressed based on available data. We anticipate no more than 15 comment letters
with an average of five comments each (75 comments total) will be received and addressed. The cost estimate for this
task is based on the assumption that no new technical analysis will be required in response to the public comments. If
more comments than assumed are received or additional analysis will be required to respond to comments, Chambers
Group will coordinate with the City to identify comments to be addressed by the Chambers Group team and/or provide
these services under a separate scope and fee.
Upon receipt of one complete set of comments from the City on the responses, a Final MND will be prepared. This
document combined with the Draft MND will constitute the Final MND to be used by the City when considering approval
of the project.
Deliverables: One electronic Microsoft Word copy of the Draft Response to Comments for one round of review by the
City. One electronic PDF copy of the Final MND with appendices for the City.
Task 6: Mitigation Monitoring and Reporting Program
Following preparation of the MND, Chambers Group will prepare a Draft Mitigation Monitoring and Reporting Program
(MMRP) as required by CEQA for review by the City. The Final MMRP incorporating the City’s comments will be
incorporated into the Final MND.
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Deliverables: One electronic PDF copy and one Microsoft Word copy of the Draft MMRP for one round of review by the
City. The Final MMRP will be incorporated into Final MND.
Task 7: Findings and Filings
The Notice of Determination (NOD) is filed following the City’s decision to carry out or approve the project for which
the MND has been prepared. Chambers Group will prepare the NOD and will file the NOD with the State Clearinghouse
and the County Clerk.
Assumption: The City would be responsible for providing the check to the County Clerk for the NOD filing fee.
Deliverables: An electronic PDF copy of the NOD for the City. One NOD to be filed with the State Clearinghouse and
one with the County Clerk.
Task 8: Attendance at Public Hearings
Chambers Group’s Senior Project Manager, Meghan Gibson, or Project Manager, Victoria Boyd, will attend one Planning
Commission hearing and one City Council hearing to answer any questions that decision makers have on the Proposed
Project’s environmental document and impacts analysis. If needed, technical staff may also join in attendance at
hearings at an additional cost. This scope assumes that hearings would be no longer than three hours each. Chambers
Group may also attend any other additional meetings requested by the City on a time and materials basis.
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Project Schedule
The following schedule is outlined with the assumption that the anticipated services will begin June 1, 2022.
Project Action Project Duration Approximate Dates
NTP 1 Day 6/1/22
Update Project Description 1 Week from the NTP 6/1/22 – 6/8/22
City Review of Project Description 2 Days 6/8/22 – 6/10/22
Tribal Consultation Update 1 Week 6/8/22 – 6/15/22
Biological Reconnaissance Level Survey and Report 5 Weeks 6/13/22 – 7/18/22
Prepare Updated CEQA Document 6 Weeks 6/13/22 – 7/25/22
City Review of Updated CEQA Document 1 Week 7/25/22 – 8/1/22
Prepare/Distribute the IS/MND and Notices 1 Week 8/1/22 – 8/8/22
Public Circulation 30 Days 8/8/22- 9/7/22
Prepare Draft Final IS/MND with Response to Comments
and MMRP
2 Weeks 9/1/22 -9/15/22
City Review of Final IS/MND, Response to Comments
and MMRP
2 Days 9/15/22 – 9/19/22
Prepare Final MND with Response to Comments and MMRP 2 Days 9/19/22 – 9/20/22
Planning Commission Hearing 1 Day 9/20/22
City Council Hearing 1 Day 9/26/22
NOD 1 Week 9/26/22 – 10/3/22
Approximate Total 17 weeks
Note: Some tasks will occur simultaneously.
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City of Rolling Hills
6
21330/63836
Fee Schedule
The services described in each task will be performed on a fixed fee basis. The costs for each task are shown below. A
Standard Rate Sheet is provided on the following page.
Task Fee
Task 1: Project Description Update $1,650.00
Task 2: Technical Reports / Updates
Task 2.1: AB 52 Letter $278.00
Task 2.2: Biological Reconnaissance Level Survey and Report $18,250.00
Task 2: Preparation of the Appropriate CEQA Document $6,272.59
Task 3: Public Review MND and Corresponding Notices $5,294.75
Task 4: Responses to Comments and Final CEQA Document $7,785.00
Task 5: Mitigation Monitoring and Reporting Program (if required) $2,224.00
Task 6: Findings and Filings $2,583.50
Task 7: Attendance at Public Hearings $4,540.00
Subtotal $48,877.84
Contingency Fee (10%) $4,887.78
Total without Optional Task $53,765.62
460
Agenda Item No.: 12.C
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:CHRISTIAN HORVATH, CITY CLERK / EXECUTIVE ASSISTANT TO
CITY MANAGER
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:ADOPT RESOLUTIONS NOS. 1295 AND 1296 PERTAINING TO A
GENERAL MUNICIPAL ELECTION CONSOLIDATED WITH THE
STATEWIDE GENERAL ELECTION TO BE HELD ON TUESDAY,
NOVEMBER 8, 2022
DATE:May 23, 2022
BACKGROUND:
The California Voter Participation Rights Act prohibits a political subdivision, such as the City
of Rolling Hills, from holding an election other than on a statewide election date if holding an
election on a non-concurrent date has previously resulted in a significant decrease in voter
turnout, being at least 25% less than its average voter turnout in the previous 4 statewide
general elections.
The City of Rolling Hills did not meet the qualifying criteria to continue to conduct stand-alone
elections on a non-concurrent date and therefore moved its elections to coincide with the date
of the statewide election. On October 24, 2016 the City Council of the City of Rolling Hills
adopted Ordinance No. 347 moving the date of the City’s General Municipal Election from the
first Tuesday after the first Monday in March of odd-numbered years to the first Tuesday after
the first Monday in November of even-numbered years beginning in November 2020.
The City’s next General Municipal Election will be held on Tuesday, November 8, 2022 for the
purpose of electing three members of the City Council to four-year terms. The seats are
currently held by Mayor James Black, Mayor Pro Tem Patrick Wilson and Councilmember
Leah Mirsch.
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DISCUSSION:
Enclosed with this staff report are two routine in nature Resolutions relating to the General
Municipal Election to be held on Tuesday, November 8, 2022. The first resolution is required
to call and give notice of an election for November 8, 2022, and to request that the Los
Angeles County Board of Supervisors direct the Registrar-Recorder/County Clerk to provide
full services. The second resolution establishes the regulations for candidates for elective
office. The Resolutions are as follows:
A Resolution of the City Council of the City of Rolling Hills requesting the Board of
Supervisors of the County of Los Angeles to order the consolidation of a General
Municipal Election to be held on November 8, 2022 with the Statewide General Election
to be held in the County of Los Angeles the same day; to authorize the Board of
Supervisors of the County of Los Angeles to canvass the returns of said General
Municipal Election; and to request that the Registrar-Recorder/County Clerk of said
County be permitted to render full services to the City of Rolling Hills relating to the
conduct of said General Municipal Election pursuant to California Elections Code Section
10403; and
A Resolution of the City Council of the City of Rolling Hills, California, adopting
regulations for candidates for elective office pertaining to candidate statements
submitted to the voters at an election to be held on Tuesday, November 8, 2022.
The City Clerk’s Office will handle all candidate filings and publishing of notices. All other
elements of the election would be administered by the Los Angeles County Registrar-
Recorder/County Clerk’s office.
FISCAL IMPACT:
The County has provided an unofficial conservative estimated cost for the November 8, 2022
General Election including any potential ballot measure(s) of $15,000. The $15,000 will be
included in the General Fund Account for FY 2022/23.
RECOMMENDATION:
Adopt Resolution Nos. 1295 and 1296 pertaining to the General Municipal Election to be held
on November 8, 2022 as presented.
ATTACHMENTS:
ResolutionNo1295_CallElection2022_CountyServices.pdf
ResolutionNo1296_EstablishRegulations_CandidateStatement.pdf
462
Resolution No. 1295
1
RESOLUTION NO. 1295
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROLLING
HILLS REQUESTING THE BOARD OF SUPERVISORS OF THE
COUNTY OF LOS ANGELES TO ORDER THE CONSOLIDATION OF A
GENERAL MUNICIPAL ELECTION TO BE HELD ON NOVEMBER 8,
2022 WITH THE STATEWIDE GENERAL ELECTION TO BE HELD IN
THE COUNTY OF LOS ANGELES THE SAME DAY; TO AUTHORIZE
THE BOARD OF SUPERVISORS OF THE COUNTY OF LOS ANGELES
TO CANVASS THE RETURNS OF SAID GENERAL MUNICIPAL
ELECTION; AND TO REQUEST THAT THE REGISTRAR-
RECORDER/COUNTY CLERK OF SAID COUNTY BE PERMITTED TO
RENDER FULL SERVICES TO THE CITY OF ROLLING HILLS
RELATING TO THE CONDUCT OF SAID GENERAL MUNICIPAL
ELECTION PURSUANT TO CALIFORNIA ELECTIONS CODE SECTION
10403
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF ROLLING HILLS,
CALIFORNIA, DOES HEREBY RESOLVE, DECLARE, DETERMINE AND ORDER AS
FOLLOWS:
Section 1. RECITALS.
A. A General Municipal Election has been called by the City of Rolling Hills to be
held in the City of Rolling Hills on November 8, 2022.
B. A Statewide General Election to be held in the County of Los Angeles has
been or will be called to be held on November 8, 2022.
C. It is desired, pursuant to the authority found in California Elections Code
section 10403, to consolidate said General Municipal Election with said Statewide
General Election to be held in the County of Los Angeles.
Section 2. The Board of Supervisors of the County of Los Angeles is hereby
respectfully requested to order the consolidation of said General Municipal Election to
be held on November 8, 2022, with the Statewide General Election to be held in the
County of Los Angeles on November 8, 2022.
Section 3. The Board of Supervisors of the County of Los Angeles is hereby further
respectfully requested to place upon the same ballot as that provided for said Statewide
General Election to be held in the County of Los Angeles on November 8, 2022, the
names of the candidates for the offices of three (3) Councilmembers for the full term of
four years, to be submitted to the electors of the City of Rolling Hills at said General
Municipal Election.
463
Resolution No. 1295
2
Section 4. The City of Rolling Hills acknowledges that the consolidated election will be
held and conducted in the manner prescribed in Section 10418 of the California
Elections Code.
Section 5. The Board of Supervisors of the County of Los Angeles is hereby authorized
and respectfully requested to canvass the returns of said General Municipal Election.
Section 6. The Board of Supervisors of the County of Los Angeles is hereby authorized
and respectfully requested to authorize and permit the Registrar-Recorder/County Clerk
of the County of Los Angeles to:
a) Print and supply ballots for said City of Rolling Hills General Municipal
Election;
b) Mail the City’s sample ballots and candidate statements of qualifications
to the electors of the City of Rolling Hills as part of the same material that
will be mailed to the voters of the Statewide General Election to be held in
the County of Los Angeles;
c) Perform such other services as may be required for the consolidation and
conduct of said City of Rolling Hills General Municipal Election with said
Statewide General Election to be held in the County of Los Angeles.
Section 7. The vote centers for the election shall be open as required during the
identified voting period pursuant to California Elections Code sections 4007 and 14401.
Section 8. The City shall reimburse the County of Los Angeles in full for the services
performed on behalf of the City upon the presentation of a bill by the County.
Section 9. The City Clerk is hereby directed to deliver a certified copy of this resolution
to the Board of Supervisors of the County of Los Angeles and to transmit an electronic
copy to the Board of Supervisors and the Registrar-Recorder/County Clerk of the
County of Los Angeles.
PASSED, APPROVED AND ADOPTED this 23rd day of May, 2022.
___________________________________
JAMES BLACK, M.D.
MAYOR
ATTEST:
464
Resolution No. 1295
3
___________________________________
CHRISTIAN HORVATH
CITY CLERK
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) SS
CITY OF ROLLING HILLS )
465
Resolution No. 1295
4
The foregoing Resolution No. 1295 entitled:
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROLLING
HILLS REQUESTING THE BOARD OF SUPERVISORS OF THE
COUNTY OF LOS ANGELES TO ORDER THE CONSOLIDATION OF A
GENERAL MUNICIPAL ELECTION TO BE HELD ON NOVEMBER 8,
2022 WITH THE STATEWIDE GENERAL ELECTION TO BE HELD IN
THE COUNTY OF LOS ANGELES THE SAME DAY; TO AUTHORIZE
THE BOARD OF SUPERVISORS OF THE COUNTY OF LOS ANGELES
TO CANVASS THE RETURNS OF SAID GENERAL MUNICIPAL
ELECTION; AND TO REQUEST THAT THE REGISTRAR-
RECORDER/COUNTY CLERK OF SAID COUNTY BE PERMITTED TO
RENDER FULL SERVICES TO THE CITY OF ROLLING HILLS
RELATING TO THE CONDUCT OF SAID GENERAL MUNICIPAL
ELECTION PURSUANT TO CALIFORNIA ELECTIONS CODE SECTION
10403
was approved and adopted at a regular meeting of the City Council on the 23rd day of
May, 2022, by the following roll call vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
___________________________
CHRISTIAN HORVATH
CITY CLERK
466
65277.00001\40089942.1
Resolution No. 1296 -1-
RESOLUTION NO. 1296
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
ROLLING HILLS, CALIFORNIA, ADOPTING
REGULATIONS FOR CANDIDATES FOR ELECTIVE
OFFICE PERTAINING TO CANDIDATE STATEMENTS
SUBMITTED TO THE VOTERS AT AN ELECTION TO BE
HELD ON TUESDAY, NOVEMBER 8, 2022.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF ROLLING HILLS,
CALIFORNIA, DOES HEREBY RESOLVE, DECLARE, DETERMINE AND ORDER AS
FOLLOWS:
Section 1. RECITALS. Section 13307 of the Elections Code of the State of
California provides that the governing body of any local agency adopt regulations
pertaining to materials prepared by any candidate for a municipal election, including costs
of the candidate’s statement.
Section 2. GENERAL PROVISIONS. Pursuant to §13307 of the Elections Code
of the State of California, each candidate for elective office to be voted for at an Election
to be held in the City of Rolling Hills on November 8, 2022, may prepare a candidate’s
statement on an appropriate form provided by the City Clerk. The statement may include
the name, age and occupation of the candidate and a brief description of no more than
400 words of the candidate's education and qualifications expressed by the candidate.
The statement shall not include party affiliation of the candidate, nor membership or
activity in partisan political organizations. The statement shall be filed in typewritten form
in the office of the City Clerk at the time the candidate's nomination papers are filed. The
statement may be withdrawn, but not changed, during the period for filing nomination
papers and until 5:00 p.m. of the next working day after the close of the nomination period.
Section 3. FOREIGN LANGUAGE POLICY
A. Pursuant to the Federal Voting Rights Act, candidate statements will be
translated into all languages required by the County of Los Angeles Registrar-
Recorder/County Clerk. The County is required to translate candidate’s statements into
the following languages: Armenian, Chinese Farsi, Hindi, Japanese, Khmer, Korean,
Russian, Spanish, Tagalog/Filipino, Vietnamese, and other required languages as
identified.
B. The County will mail sample ballots and candidate statements in a particular
language to only those voters who are on the county voter file as having requested a
sample ballot in a particular language. The County will make the sample ballot and
candidate statements in the required languages available at all vote centers, on the
County’s website, and in the Election Official’s office.
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65277.00001\40089942.1
Resolution No. 1296 -2-
Section 4. PAYMENT
A. Translations
1. The candidate shall not be required to pay for the cost of translating the
candidate statement into any required foreign language as specified in (A)
of Section 2 above pursuant to Federal and\or State law.
2. The candidate shall be required to pay for the cost of translating the
candidate statement into any foreign language that is not required as
specified in (A) and/or (B) of Section 2 above, pursuant to Federal and\or
State law, but is requested as an option by the candidate.
B. Printing
1. The candidate shall be required to pay for the cost of printing the candidate
statement in English in the main voter pamphlet.
2. The candidate shall be required to pay for the cost of printing the candidate
statement in a foreign language requested by the candidate per (B) of
Section 2 above, in the main voter pamphlet.
The City Clerk shall estimate the total cost of printing, handling, translating, and
mailing the candidate’s statements filed pursuant to this section, including costs incurred
as a result of complying with the Voting Rights Act of 1965 (as amended), and require
each candidate filing a statement to pay in advance to the local agency his or her
estimated pro rata share as a condition of having his or her statement included in the
voter’s pamphlet. In the event the estimated payment is required, the estimate is just an
approximation of the actual cost that varies from one election to another election and may
be significantly more or less than the estimate, depending on the actual number of
candidates filing statements. Accordingly, the City Clerk is not bound by the estimate and
may, on a pro rata basis, bill the candidate for additional actual expense or refund any
excess paid depending on the final actual cost. In the event of underpayment, the City
Clerk may require the candidate to pay the balance of the cost incurred. In the event of
overpayment, the City Clerk shall prorate the excess amount among the candidates and
refund the excess amount paid within 30 days of the election.
Section 5. MISCELLANEOUS.
A. All translations shall be provided by professionally-certified translators.
B. The City Clerk shall not allow bold type, underlining, capitalization, indentations,
bullets, leading hyphens to the same extent and manner as in previous City elections.
C. The City Clerk shall comply with all recommendations and standards set forth
by the California Secretary of State regarding occupational designations and other
matters relating to elections.
Section 6. ADDITIONAL MATERIALS. No candidate will be permitted to include
468
65277.00001\40089942.1
Resolution No. 1296 -3-
additional materials in the sample ballot package.
Section 7. That the City Clerk shall provide each candidate or the candidate's
representative a copy of this Resolution at the time nominating petitions are issued.
Section 8. That all previous Resolutions establishing City Council policy on
payment for candidate’s statements are repealed.
Section 9. That this Resolution shall apply only to the election to be held on
November 8, 2022 and shall then be repealed.
Section 10. That the City Clerk shall certify to the passage and adoption of this
Resolution and enter it into the book of original Resolutions.
PASSED, APPROVED AND ADOPTED this 23rd day of May, 2022.
___________________________________
JAMES BLACK, M.D.
MAYOR
ATTEST:
CHRISTIAN HORVATH
CITY CLERK
469
65277.00001\40089942.1
Resolution No. 1296 -4-
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) SS
CITY OF ROLLING HILLS )
The foregoing Resolution No. 1296 entitled:
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
ROLLING HILLS, CALIFORNIA, ADOPTING
REGULATIONS FOR CANDIDATES FOR ELECTIVE
OFFICE PERTAINING TO CANDIDATE STATEMENTS
SUBMITTED TO THE VOTERS AT AN ELECTION TO BE
HELD ON TUESDAY, NOVEMBER 8, 2022.
was approved and adopted at a regular meeting of the City Council on the 23rd day of
May, 2022, by the following roll call vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
___________________________
CHRISTIAN HORVATH
CITY CLERK
470
Agenda Item No.: 13.A
Mtg. Date: 05/23/2022
TO:HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
FROM:JOHN SIGNO, DIRECTOR OF PLANNING & COMMUNITY SERVICES
THRU:ELAINE JENG P.E., CITY MANAGER
SUBJECT:SUBMITTAL OF "ADOPTION DRAFT" 2021-2029 ROLLING HILLS
HOUSING ELEMENT TO HCD
DATE:May 23, 2022
BACKGROUND:
State law requires all cities and counties in California to adopt a Housing Element as part of
their General Plans. The Housing Element must be updated every eight years and certified by
the State. Through the Housing Element, each jurisdiction must demonstrate that it is
accommodating its fair share of the region’s housing needs and taking proactive measures to
accommodate housing of all types for persons of all incomes. All cities and counties are
subject to this requirement, regardless of their size, physical constraints, or real estate market
characteristics.
The current Housing Element cycle (referred to as the “6 th Cycle”) extends from October 15,
2021 through October 15, 2029. To comply with State law, Rolling Hills must show that it has
the capacity to add 45 housing units during this period, including 29 that are affordable to low-
and very low-income households. The City is not required to build 45 housing units; rather, it
must demonstrate that it has created the opportunity for the private and non-profit sectors to
do so. There are numerous other Housing Element requirements, including a mandate to
affirmatively further fair housing, programs to remove government constraints to housing
development, and requirements to allow specific housing types (such as emergency shelters)
in every jurisdiction.
The City’s housing strategy is to meet its 45-unit Regional Housing Needs Allocation (RHNA)
through a combination of an affordable housing overlay zone on the Rancho Del Mar School
site (16 units) and the development of accessory dwelling units (ADUs—at a rate of roughly
five units a year). The City published its Draft 6th Cycle Element on December 3, 2021 and
circulated this draft for a State-mandated 30-day review period. The Planning Commission
convened a hearing on December 16, 2021 to discuss the Draft and provide an opportunity for
public comment during the 30-day period.
471
On January 10, 2022, the Rolling Hills City Council directed staff to submit a working draft of
the 2021-2029 Housing Element to the State Department of Housing and Community
Development (HCD) for their review. All California cities are required to have their documents
reviewed by HCD before adopting them. Once HCD receives the Draft, it has 90 days to issue
a “findings” letter indicating the revisions to the document that are needed to receive State
certification. Rolling Hills submitted its draft on January 11, 2022 and received its State
comments on April 11, 2022. The State indicated that the City had met many of the statutory
requirements but indicated the Element required revision before it could be certified. Their
findings letter requested 34 changes, some of which were specific and others that were more
generalized. The HCD comment letter is included as Attachment “A” of this staff report.
On April 22, 2022, City staff and its Housing Element consultant met with the HCD reviewer by
Zoom to go over the State’s comments. The reviewer provided guidance on how the City
could respond to some of the comments. The City then prepared written responses to each of
the 34 HCD comments. The City’s responses are included as Attachment “B” of this staff
report. Concurrently, the City revised the December Draft to incorporate all changes
requested by the State. Both a “tracked change” and “clean” copy were produced, making it
easier for City officials, the public, and State reviewers to see the changes between the two
documents. The new version of the document is referred to as the “Adoption Draft.” (the prior
version was referred to as the “HCD Draft).” The tracked change and clean versions are
included with this staff report and are referred to as Attachments C and D, respectively.
On May 17, 2022, the Rolling Hills Planning Commission convened a public hearing on the
proposed revisions to the Housing Element. The hearing provided an opportunity for public
comment as well as an opportunity to discuss proposed changes. No public comments were
received at the meeting. At the conclusion of the item, the Commission voted unanimously to
forward the latest version of the Housing Element to the City Council, and then on to HCD.
HCD has been much more stringent in its review of 6 th Cycle Housing Elements than it has
been during earlier cycles. Housing Elements for the Southern California Association of
Governments (SCAG) region, which consists of 190 cities and six counties, were due on
October 15, 2021. As of May 10, nearly seven months later, only 13 of the 196 jurisdictions
have received State certification. The status of Elements in the SCAG region are as follows:
13 are certified
100 have been reviewed by HCD, revised, adopted, and then found out of compliance
26 are on their second drafts, after their first draft was found out of compliance
46 have yet to be adopted, but their first drafts have been found out of compliance
(Rolling Hills is in this group)
3 are awaiting HCD’s responses on their first drafts
8 have submitted nothing to HCD yet
DISCUSSION:
The City’s comment letter includes a two-page cover letter and an eight-page appendix. The
two-page cover letter is “standard” and is almost identical to what every other city has received
following HCD’s review of their initial draft. The letter reiterates the October 15, 2021 due
date, reminds the City that any zoning required to meet the RHNA must be completed by
October 15, 2022, and identifies the financial benefits of having a certified element (eligibility
for grants).
472
The “Appendix” to the Element lists HCD’s specific findings. It is organized according to the
requirements of the Government Code. To facilitate responses to the State’s questions, the
City’s consultant reviewed responses from the 13 jurisdictions that have been found in
compliance with Housing Element law, as well as the edits made by these cities in response to
HCD.
Comment 1 asked the City to document the effectiveness of its past efforts to help persons
with special needs. In response, the City has amended Chapter 2 to describe efforts to assist
seniors and facilitate “aging in place” through home retrofits.
Comments 2 through 6 address the AFFH analysis (Appendix A). HCD asked for additional
information on how the City complies with fair housing laws, additional tables and maps
comparing Rolling Hills to the region, additional explanation of how public input is reflected in
the Housing Element, and additional evidence that housing on the Rancho Del Mar site would
not result in the concentration of lower income people in a single area. Staff edited Appendix
A with responses to all of these comments. HCD is looking for a particular format that links
the AFFH analysis to the City’s policies and programs, and the City has provided that format
(see pages A-44 to A-47 in the tracked change version).
Comments 7, 8, and 9 address various aspects of the Needs Assessment. This is Chapter 3
of the Housing Element. HCD requested a projection of the future number of “extremely low
income households” in Rolling Hills and an analysis of how many lower income homeowners
and renters are paying more than 30% of their incomes on rent. They also asked for an
estimate of the number of substandard housing units in the city. Chapter 3 of the Element
was revised to address these requests.
Comments 10, 11, and 14 address Chapter 4, which is the Sites Inventory. Comment 10
questions the City’s ability to meet its lower income housing needs through ADUs, and
specifically asks for more data on the units that were approved in 2021. The City has
provided this data. Comment 11 reminds the City that it needs to enter its list of housing sites
in an on-line State data base (after adoption). Comment 14 asks the City to show that the 31-
acre Rancho Del Mar site is large enough to accommodate an emergency shelter, single room
occupancy hotel, and 16-unit affordable housing development. The City has responded to all
of these comments through edits to Chapter 4.
Comments 12, 13, and 15-17 address Chapter 5, which is the Constraints Analysis. Comment
12 asks for more detail on the parking requirements for emergency shelters, and the exact
wording of the city’s requirement than shelters must be 300 feet apart. Comment 13 reminds
the City that it must allow supportive and transitional housing in its residential zones under
state law (there is already a Program in the Housing Element to comply). Comment 15
indicates that the City’s ADU requirements need to be updated, but do not specify what needs
to change. The City has added a program to its Housing Element to update the standards.
Comment 16 reminds the City of its obligation to send the adopted Housing Element to water
and sewer service providers. Comment 17 asks for an analysis of dry utilities (gas and
electricity). The City has amended Chapter 5 to address Comments 12 and 17 and has
amended Chapter 6 to address Comments 13 and 15.
Comments 18-25 also address Chapter 5 (and to a lesser extent, Chapter 6). Comment 18
473
asks the City to provide more information on the development approval process, including the
site plan review process and approval findings. We have edited Chapter 5 (p 5-17) in
response. Comment 19 asks for more information on site improvement requirements
(specifically with respect to the Rancho Del Mar site). This has been added to P 5-18.
Comment 20 reminds the City that it must allow residential care facilities (group homes) under
State law. The City has added a program to Chapter 6 to meet this requirement. Comment
21 asks the City to explain its reasonable accommodation procedure. This has been added to
Page 5-13. Comment 22 asks the City to identify any other local ordinances that impact the
cost and supply of housing. We have added a new section (P 5-22) in response.
Comment 23 requests that the City confirm that it complies with AB 1483, which requires fee
information to be posted on line (it does). Comment 24 asks the City to create a written
procedure for SB 35 applications (we have added this as a new program in Chapter 6).
Comment 25 asks the City to add an analysis of the lag time between when projects are
approved and when they are actually constructed. This has been added to Chapter 5 (page 5-
24).
Comments 26-34 primarily relate to Chapter 6, which contains the City’s housing goals,
policies, and programs. Many of these comments are quite vague, as they simply say that
because the analysis in Chapters 2-5 did not address the issues in the earlier comments, the
State cannot confirm that the programs are adequate.
Comment 26 asks the City to assign timelines and metrics to some of its programs. The City
has done this through revisions to Chapter 6. Comment 27 is a global statement that indicates
the City may not have identified adequate sites. This is followed by more specific comments
on the Rancho Del Mar site (Comment 28) and ADUs (Comment 29). The City has asked the
City to provide more information supporting its plan to rely on these sites to meet its need for
29 lower income units. This includes a request to monitor ADU production and actively
facilitate development of the school site. Comment 30 links back to the earlier comment (13)
that a program is needed to allow supportive and transitional housing.
Comments 31 and 32 are general statements that additional programs might be needed to
address constraints and AFFH, but nothing specific is requested. The City has strengthened
its programs in response to earlier comments, effectively addressing these two comments.
Comment 33 is moot, since HCD retracted it after sending it. Comment 34 asks the City to
show how it has incorporated public input. Chapter 1 has been edited to provide a few
examples.
None of the proposed revisions to the document substantively change the City’s approach to
meeting its RHNA, which is to rely on ADUs and the Rancho Del Mar site.
NEXT STEPS:
The City Council hearing on May 23 is an opportunity to discuss the HCD comments, the City’s
responses, and edits to the document. It is also an opportunity for public comment, which is
an important part of the Housing Element process. The Commission may recommend specific
actions to the Council related to the contents of the document, the HCD comments, and the
HCD review and approval process.
On May 23, the Council will be asked to authorize a re-submittal of the “Adoption Draft” to
HCD. Assuming this direction is provided, the document will be sent to HCD on May 24.
474
State comments are expected back in late July. At that time, HCD may find that the Element
is substantially in compliance due to the changes made by the City or it may determine that
changes are still needed. If the latter occurs, the City expects a substantially smaller list of
objections. The City will meet with HCD again to discuss any remaining changes.
Following the second HCD review, the City will move ahead with Housing Element adoption.
A follow-up hearing with the Planning Commission and City Council will be required at that
time.
CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA):
Amendment of the Housing Element is considered a Project under CEQA. The City had
initially planned a single CEQA document covering the Housing Element and Safety Element,
but this was bifurcated at the time the Safety Element was adopted in March 2022 due to
comments received from an agency to include mitigation measures that address potential
housing development described in the Housing Element. An amended CEQA document is
being prepared for the Housing Element that will consider mitigation measures to address the
concerns. Although the Housing Element was expected to be adopted in May 2022, it cannot
be adopted without an accompanying CEQA document. Staff will be preparing the amended
CEQA document and circulating it for public review. In the meantime, staff is recommending
that the Draft Element be sent to HCD for a second review. The amended CEQA document
will be issued and circulated when the Housing Element is being considered for adoption.
FISCAL IMPACT:
The Housing Element is a planning document that establishes policies for the City of Rolling
Hills and will not have a direct fiscal impact on the City. Certification of the Element provides
an indirect positive fiscal impact by reducing legal risks and qualifying the City for State
planning grants. The City was awarded $65,000 from HCD through the Local Early Action
Planning Grants Program (LEAP) to help fund the Housing Element. Remaining costs are paid
through the FY2021-2022 General Fund.
RECOMMENDATION:
Authorize staff to submit the revised Draft Housing Element to HCD for their second review,
along with the responses to HCD’s comments.
ATTACHMENTS:
A. April 11, 2022 Comment letter from HCD
B. May 9, 2022 City Responses to HCD Comments
C. Tracked Change Adoption Draft Housing Element
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STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
April 11, 2022
John F. Signo, Director
Planning & Community Services Department
City of Rolling Hills
2 Portuguese Bend Road
Rolling Hills, CA 90274
Dear John F. Signo:
RE: City of Rolling Hill’s 6th Cycle (2021-2029) Draft Housing Element
Thank you for submitting the City of Rolling Hill’s draft housing element received for
review on January 11, 2022. Pursuant to Government Code section 65585, subdivision
(b), the California Department of Housing and Community Development (HCD) is
reporting the results of its review.
The draft element addresses many statutory requirements; however, revisions will be
necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code.
The enclosed Appendix describes revisions needed to comply with State Housing
Element Law.
As a reminder, the City’s 6th cycle housing element was due October 15, 2021. As of
today, the City has not completed the housing element process for the 6th cycle. The
City’s 5th cycle housing element no longer satisfies statutory requirements. HCD
encourages the City to revise the element as described above, adopt, and submit to
HCD to regain housing element compliance.
For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if
a local government fails to adopt a compliant housing element within 120 days of the
statutory deadline (October 15, 2021), then any rezoning to accommodate the regional
housing needs allocation, including for lower-income households, shall be completed no
later than one year from the statutory deadline. Otherwise, the local government’s
housing element will no longer comply with State Housing Element Law, and HCD may
revoke its finding of substantial compliance pursuant to Government Code section
65585, subdivision (i).
Public participation in the development, adoption and implementation of the housing
element is essential to effective housing planning. Throughout the housing element
process, the City should continue to engage the community, including organizations that
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John F. Signo, Director
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represent lower-income and special needs households, by making information regularly
available and considering and incorporating comments where appropriate.
Several federal, state, and regional funding programs consider housing element
compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill
(SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s
Affordable Housing and Sustainable Communities programs; and HCD’s Permanent
Local Housing Allocation consider housing element compliance and/or annual reporting
requirements pursuant to Government Code section 65400. With a compliant housing
element, the City meets housing element requirements for these and other funding
sources.
For your information, some general plan element updates are triggered by housing
element adoption. HCD reminds the City to consider timing provisions and welcomes
the opportunity to provide assistance. For information, please see the Technical
Advisories issued by the Governor’s Office of Planning and Research at:
http://opr.ca.gov/docs/OPR_Appendix_C_final.pdf and
http://opr.ca.gov/docs/Final_6.26.15.pdf.
HCD appreciates the hard work the City’s planning staff provided during the course of
our review. We are committed to assist the City in addressing all statutory requirements
of State Housing Element Law. If you have any questions or need additional technical
assistance, please contact Gianna Marasovich, of our staff, at
Gianna.Marasovich@hcd.ca.gov.
Sincerely,
Paul McDougall
Senior Program Manager
Enclosure
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APPENDIX
CITY OF ROLLING HILLS
The following changes are necessary to bring the City’s housing element into compliance with
Article 10.6 of the Government Code. Accompanying each recommended change, we cite the
supporting section of the Government Code.
Housing element technical assistance information is available on HCD’s website at
http://www.hcd.ca.gov/community-development/housing-element/housing-element-memos.shtml.
Among other resources, the housing element section contains HCD’s latest technical assistance
tool, Building Blocks for Effective Housing Elements (Building Blocks), available at
http://www.hcd.ca.gov/community-development/building-blocks/index.shtml and includes the
Government Code addressing State Housing Element Law and other resources.
A. Review and Revision
Review the previous element to evaluate the appropriateness, effectiveness, and progress in
implementation, and reflect the results of this review in the revised element. (Gov. Code, §
65588 (a) and (b).)
The element must provide a cumulative evaluation of the effectiveness of past goals,
policies, and related actions in meeting the housing needs of special needs populations
(e.g., elderly, persons with disabilities, large households, female-headed households,
farmworkers, and persons experiencing homelessness).
B. Housing Needs, Resources, and Constraints
1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with
Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing
in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).)
Enforcement and Outreach: The element must describe the City’s compliance with
existing fair housing laws and regulations. For additional information, please see
pages 28-30 on HCD’s AFFH Guidance Memo at https://www.hcd.ca.gov/community-
development/affh/index.shtml.
Regional Analysis: While the element generally describes some regional data, the
element must analyze Rolling Hills relative to the rest of the region regarding
integration and segregation (disability, familial status, and income), access to
opportunity (education, economic, and environmental), and disproportionate housing
needs (cost burdened, overcrowding, and homelessness).
Other Relevant Factors: The element must include other relevant factors that
contribute to fair housing issues in the jurisdiction. For instance, the element should
analyze historical land use, zoning, governmental and nongovernmental spending
including transportation investments, demographic trends, historical patterns of
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segregation, or other information that may have impeded housing choices and
mobility.
Sites Inventory: The element must identify sites throughout the community to foster
inclusive communities. While the element identifies and show sites and zoning
throughout the community, it also notes the plan to accommodate half of the regional
housing need for lower income households at the Palos Verdes Unified School District
(PVUSD). The element should discuss whether this strategy potentially isolates
housing need for lower income households and include actions as appropriate.
Goals, Actions, Metrics, and Milestones: Goals and actions must significantly seek to
overcome contributing factors to fair housing issues. Programs generally must
address enhancing housing mobility strategies; encouraging development of new
affordable housing in high resource areas; improving place-based strategies to
encourage community conservation and revitalization, including preservation of
existing affordable housing; and protecting existing residents from displacement.
Given that most of the City is considered a high and highest resource community (pg.
3-50), the element could focus on programs that enhance housing mobility and
encourage development of more housing choices and affordable housing. Programs
also need to be based on identified contributing factors, be significant and meaningful.
The element must add, and revise programs based on a complete analysis and listing
and prioritization of contributing factors to fair housing issues. Furthermore, the
element must include metrics and milestones for evaluating progress on programs,
actions, and fair housing results. For more information, please see HCD’s guidance at
https://www.hcd.ca.gov/community-development/affh/index.shtml.
2. Include an analysis of population and employment trends and documentation of
projections and a quantification of the locality's existing and projected needs for all
income levels, including extremely low-income households. (Gov. Code, § 65583,
subd. (a)(1).)
Extremely Low-Income Households: The element includes analysis regarding
extremely low-income (ELI) households such as the number of households and
overpayment but must also identify projected housing needs. The projected housing
need for ELI households can be calculated by using available census data to
determine the number of very low-income households that qualify as ELI households
or presume that 50 percent of the regional housing need allocation (RHNA) for very
low-income households qualify as ELI households. For additional information, see the
Building Blocks at http://www.hcd.ca.gov/community-development/building-
blocks/housing-needs/extremely-low-income-housing-needs.shtml.
3. Include an analysis and documentation of household characteristics, including level of
payment compared to ability to pay, housing characteristics, including overcrowding,
and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)
Overpayment: While the element identifies the total number of households overpaying
for housing, it must quantify and analyze the number of lower-income households
overpaying for housing by tenure (i.e., renter and owner).
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Housing Stock Condition: The element analyzed the age of the housing stock,
discussed code enforcement data, and stated that there are no code enforcement or
housing problems in the City. However, the element must estimate the number of units
in need of rehabilitation and replacement.
4. An inventory of land suitable and available for residential development, including
vacant sites and sites having realistic and demonstrated potential for redevelopment
during the planning period to meet the locality’s housing need for a designated income
level, and an analysis of the relationship of zoning and public facilities and services to
these sites. (Gov. Code, § 65583, subd. (a)(3).)
Progress in Meeting the RHNA – Accessory Dwelling Unit (ADUs): The element is
counting two ADUs as credit towards RHNA. First, the element must demonstrate the
availability of these units during the planning period. For example, the element could
discuss whether these units have pending or approved building permits. Second, the
element must demonstrate affordability based on actual or anticipated rents or other
mechanisms ensuring affordability (e.g., deed-restrictions).
Electronic Sites Inventory: For your information, pursuant to Government Code section
65583.3, the City must submit an electronic sites inventory with its adopted housing
element. The City must utilize standards, forms, and definitions adopted by HCD.
Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-
development/housing-element/index.shtml#element for a copy of the form and
instructions. The City can reach out to HCD at sitesinventory@hcd.ca.gov for
technical assistance.
Zoning for a Variety of Housing Types:
• Emergency Shelters: The element must demonstrate compliance with
emergency shelters parking requirements. Pursuant to AB 139 (Chapter 335,
Statutes of 2019) emergency shelters are only required to provide sufficient
parking to accommodate all staff working in the emergency shelter, provided
that the states do not requirement more parking for emergency shelters than
other residential or commercial uses within the same zone. Additionally, the
element states emergency shelters are not allowed to be within 300 ft from
each other; however, state law only allows a maximum of 300 ft separation
requirement. The element should describe compliance with these requirements
or include programs as appropriate.
• Permanent Supportive Housing: Supportive housing shall be a use by-right in
zones where multifamily and mixed uses are permitted, including nonresidential
zones permitting multifamily uses pursuant to Government Code section 65651.
The element must demonstrate compliance with this requirement and include
programs as appropriate.
• Emergency Shelters, Single Room Occupancy (SRO), and Multifamily Zoning:
The element identifies a 31-acre site with an overlay zone that will
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accommodate the City’s lower-income RHNA, allow for emergency shelters by-
right, and SROs with a CUP. The element should discuss and analyze the
suitability of this site to accommodate these various housing types and the full
spectrum of the housing needs (beyond RHNA).
• Accessory Dwelling Units (ADU): After a cursory review of the City’s ordinance,
HCD discovered several areas which were not consistent with State ADU Law.
This includes but is not limited to restricting bedroom count and permitting
procedures, among others. HCD will provide a complete listing of ADU non-
compliance issues under a separate cover. As a result, the element should add
a program to update the City’s ADU ordinance in order to comply with state law.
For more information, please consult HCD’s ADU Guidebook, published in
December 2020, which provides detailed information on new state
requirements surrounding ADU development.
Water Sewer Priority: Water and sewer service providers must establish specific
procedures to grant priority water and sewer service to developments with units
affordable to lower-income households. (Gov. Code, § 65589.7.) Local governments
are required to immediately deliver the housing element to water and sewer service
providers. The element should discuss compliance with these requirements and if
necessary, add or modify programs to establish a written procedure by a date early in
the planning period. For additional information and sample cover memo, see the
Building Blocks at http://www.hcd.ca.gov/community-development/building-
blocks/other-requirements/priority-for-water-sewer.shtml.
Availability of Infrastructure: While the element describes infrastructure capacity to
accommodate the regional housing need, the element must also provide an analysis
on access to dry utilities for the sites identified in the inventory.
5. An analysis of potential and actual governmental constraints upon the maintenance,
improvement, or development of housing for all income levels, including the types of
housing identified in paragraph (1) of subdivision (c), and for persons with disabilities
as identified in the analysis pursuant to paragraph (7), including land use controls,
building codes and their enforcement, site improvements, fees and other exactions
required of developers, and local processing and permit procedures. The analysis
shall also demonstrate local efforts to remove governmental constraints that hinder the
locality from meeting its share of the regional housing need in accordance with
Government Code section 65584 and from meeting the need for housing for persons
with disabilities, supportive housing, transitional housing, and emergency shelters
identified pursuant to paragraph (7). Transitional housing and supportive housing shall
be considered a residential use of property, and shall be subject only to those
restrictions that apply to other residential dwellings of the same type in the same zone.
(Gov. Code, § 65583, subd. (a)(5).)
Processing and Permit Procedures: While the element included some information on
approving single family homes, the analysis should address the approval body, the
number of public hearings, if any, approval findings, and any other relevant
information such as any design review requirements. The analysis should address
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impacts on housing cost, supply, timing, and approval certainty. For example, the
element mentioned the requirement of a site plan review for any proposed
development, the use of conditional use permit for single room occupancy units, and
that City Council and Planning Commission take field trips to the proposed site as part
of the review process. The element should specifically identify timing, approval
findings, and criteria for approvals.
On/Off Site Improvements: While the element stated that specific parcels zoned for
multifamily such as the PVUSD site will require ingress and egress improvements (p.
5-23), the element should identify typical site improvement requirements, such as
minimum street widths (e.g., 40-foot minimum street width), and analyze their impact
as potential constraints on housing supply and affordability. For additional information
and a sample analysis, see the Building Blocks at http://www.hcd.ca.gov/community-
development/building-blocks/constraints/codes-and-enforcement-on-offsite-
improvement-standards.shtml.
Constraints on Housing for Persons with Disabilities:
• Group Homes for Seven or More: The element must discuss how the City
defines and permits group homes for seven or more persons. For your
information, excluding these uses from residential zones or subjecting the uses
to conditional use permits (CUP) is generally considered a constraint and
programs should be modified as appropriate with specific commitment to allow
the use in residential zones with objectivity and certainty.
• Reasonable Accommodation: While the element briefly describes its
reasonable accommodation procedures, it must describe the process and
decision-making criteria such as approval findings and analyze any potential
constraints on housing for persons with disabilities.
Other Local Ordinances: The element must analyze any locally adopted ordinances
that directly impacts the cost and supply or residential development (e.g., inclusionary
requirements, short term rentals, growth controls).
Zoning, Development Standards and Fees: The element must clarify compliance with
new transparency requirements for posting all zoning, development standards and
fees on the City’s website and add a program to address these requirements, as
necessary.
SB 35 Streamlined Ministerial Approval Process: The element must clarify whether
there are written procedures for the SB 35 (Chapter 366, Statutes of 2017)
Streamlined Ministerial Approval Process and add a program to address these
requirements, if necessary.
6. An analysis of potential and actual nongovernmental constraints upon the
maintenance, improvement, or development of housing for all income levels, including
the availability of financing, the price of land, the cost of construction, the requests to
develop housing at densities below those anticipated in the analysis required by
subdivision (c) of Government Code section 65583.2, and the length of time between
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receiving approval for a housing development and submittal of an application for
building permits for that housing development that hinder the construction of a
locality’s share of the regional housing need in accordance with Government Code
section 65584. The analysis shall also demonstrate local efforts to remove
nongovernmental constraints that create a gap between the locality’s planning for the
development of housing for all income levels and the construction of that housing.
(Gov. Code, § 65583, subd. (a)(6).)
Approval Time: The element must analyze the length of time between receiving
approval for a housing development and submittal of an application for building
permits that potentially hinder the construction of a locality’s share of the regional
housing need.
C. Housing Programs
1. Include a program which sets forth a schedule of actions during the planning period,
each with a timeline for implementation, which may recognize that certain programs
are ongoing, such that there will be beneficial impacts of the programs within the
planning period, that the local government is undertaking or intends to undertake to
implement the policies and achieve the goals and objectives of the Housing Element
through the administration of land use and development controls, the provision of
regulatory concessions and incentives, and the utilization of appropriate federal and
state financing and subsidy programs when available. The program shall include an
identification of the agencies and officials responsible for the implementation of the
various actions. (Gov. Code, § 65583, subd. (c).)
To have a beneficial impact in the planning period and address the goals of the
housing element, programs must be revised with discrete timelines and specific
commitment. Several programs included various actions but still must include a
timeline for implementing each action including, Program 8 – Assist Senior and
Disabled Households, Program 9 – Assist Extremely Low-Income Households,
Program 12 – Facilitate Communication with Affordable Housing Service
Providers…Program 14 – Sewer Feasibility Studies and Phase One Construction,
Program 20 – Fair Housing Services Program Administration, Program 22 – Fair
Housing Training for Staff.
2. Identify actions that will be taken to make sites available during the planning period
with appropriate zoning and development standards and with services and facilities to
accommodate that portion of the city’s or county’s share of the regional housing need
for each income level that could not be accommodated on sites identified in the
inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and
to comply with the requirements of Government Code section 65584.09. Sites shall be
identified as needed to facilitate and encourage the development of a variety of types
of housing for all income levels, including multifamily rental housing, factory-built
housing, mobilehomes, housing for agricultural employees, supportive housing, single-
room occupancy units, emergency shelters, and transitional housing. (Gov. Code, §
65583, subd. (c)(1).)
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As noted in Finding B4, the element does not include a complete site analysis;
therefore, the adequacy of sites and zoning was not established. Based on the results
of a complete sites inventory and analysis, the City may need to add or revise
programs to address a shortfall of sites or zoning available to encourage a variety of
housing types. In addition, the element must be revised, as follows:
Program 2 – Rancho Del Mar Opportunity Site Monitoring: The element identifies one
site to accommodate a portion of its lower-income RHNA. While the program includes
several actions such as subdividing the site, coordination with the school district,
technical assistance and incentives, the program does not commit to these actions nor
provide a date for when these actions will occur. Specifically, the element should
include timelines for various actions and include commitments to outreaching,
coordination, and establishing incentives that facilitate development on this site, as
mentioned in the program.
Program 6 – Accessory Dwelling Unit (ADU) Production, Monitoring, and Incentives:
The element heavily relies on ADUs to accommodate most of the City’s RHNA for all
income levels. Given the City’s assumptions for ADUs exceed recent trends, the
element should include a program to monitor permitted ADUs and affordability every
other year and take appropriate action such as adjusting assumptions or rezoning
within a specified time period (e.g., six months).
Zoning for a Variety of Housing Types: The element identifies Program 4 and 5
committing to provide a variety of housing types (e.g., SROs, transitional and
supportive housing, employee housing, etc.,) and address constraints for people with
disabilities. These actions were also identified in the last planning period but have not
been completed. HCD encourages the City to utilize HCD’s technical assistance
resources and model ordinances to ensure effective and efficient implementation.
Please see the Housing Hub Site: Housing Planning Hub Site (arcgis.com)
3. Address and, where appropriate and legally possible, remove governmental and
nongovernmental constraints to the maintenance, improvement, and development of
housing, including housing for all income levels and housing for persons with
disabilities. The program shall remove constraints to, and provide reasonable
accommodations for housing designed for, intended for occupancy by, or with
supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
As noted in Finding(s) B5 and B6, the element requires a complete analysis of
potential governmental. Depending upon the results of that analysis, the City may
need to revise or add programs and address and remove or mitigate any identified
constraints.
4. Promote and affirmatively further fair housing opportunities and promote housing
throughout the community or communities for all persons regardless of race, religion,
sex, marital status, ancestry, national origin, color, familial status, or disability, and
other characteristics protected by the California Fair Employment and Housing Act
(Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008,
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and any other state and federal fair housing and planning law. (Gov. Code, § 65583,
subd. (c)(5).)
As noted in Finding B1, the element must include a complete analysis of affirmatively
furthering fair housing. Based on the outcome of that analysis, the element must add
or modify programs.
D. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed,
rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd.
(b)(1 & 2).)
While the element does include quantified objectives (p. 6-20), it must be revised to
include quantified objectives for number of housing units that will be rehabilitated for low,
moderate, and above moderate households.
E. Public Participation
Local governments shall make a diligent effort to achieve public participation of all
economic segments of the community in the development of the Housing Element, and
the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).)
While the element described various efforts to achieve public participation in the preparation of the
housing element update, it should also describe how comments were considered and
incorporated into the element.
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May 9, 2022
Revisions Made in Response to HCD Comments on 2021-2029 Rolling Hills Draft
Housing Element (HCD’s comments are numbered 1-34 in the left-hand margin)
A. Review of the Previous Element (Element Chapter 2)
The element must provide a cumulative evaluation of the effectiveness of past goals, policies, and
related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with
disabilities, large households, female-headed households, farmworkers, and persons experiencing
homelessness).
City Response: A new section has been added to Page 2-4 to evaluate the cumulative effectiveness of
past goals, policies, and actions in meeting the needs of special needs populations. See Section 2.3.5 of
Adoption document.
B1. Needs Assessment/ Affirmatively Fair Housing (Appendix A: AFFH Analysis)
Enforcement and Outreach: The element must describe the City’s compliance with existing fair housing
laws and regulations.
City Response: This has been added to Appendix A: Affirmatively Furthering Fair Housing. Please see
page A-4, which lists various federal and state programs which the City implements and abides by. The
Element includes a number of programs to increase awareness of fair housing laws (Chapter 6).
Regional Analysis: While the element generally describes some regional data, the element must analyze
Rolling Hills relative to the rest of the region regarding integration and segregation (disability, familial
status, and income), access to opportunity (education, economic, and environmental), and
disproportionate housing needs (cost burdened, overcrowding, and homelessness).
City Response: Each of the listed items is covered below:
Disability. A map showing the percentage of disabled residents by Census tract was included in the prior
draft (Figure A-3), and an analysis was provided. This analysis has been expanded to more deeply
interpret the data shown on the map. The City has a higher percentage of disabled residents than many
surrounding tracts due to its higher median age (55). In general, health indicators for Rolling Hills
confirm the community’s designation as a high resource area. See Page A-10.
Familial Status: A map showing familial status by Census tract has been added (Figure A-4) and an
analysis of this map has been provided. See Page A-15.
Income: Maps of income by Census tract were included in the prior draft (formerly Figures A-4 and A-5,
renumbered A-5 and A-6), and an analysis was provided. The analysis has been expanded by adding a
new map (Figure A-7) showing a larger geographic area. An analysis of the map has been added on
pages A-12 and A-13.
1
2
3
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Access to Education: A map showing regional data on education was included in the previous draft
(formerly Figure A-9, now Figure A-11). Additional text has been added interpreting the data on the
map for Rolling Hills, surrounding cities, and nearby parts of the region. See Page A-23.
Economic Opportunities: A map showing regional economic opportunity data was included in the
previous draft (formerly Figure A-8, now Figure A-10). Additional text has been added interpreting the
data on the map for Rolling Hills, surrounding cities, and nearby parts of the region. See Page A-22.
Environmental Factors: A map showing environmental outcomes was included in the previous draft
(formerly Figure A-7, now Figure A-9). Additional text has been added interpreting the scores for Rolling
Hills, surrounding cities, and nearby parts of the region. See Page A-22.
Cost Burdened: Two maps showing cost burdened households in the region (one for owners and one for
renters) were included in the previous draft (formerly Figures A-11 and A-12, now renumbered as Figures
A-13 and A-14). Data on these maps has been described in more detail through revisions to the text. See
Pages A-30 and A-31.
Overcrowding: A map showing overcrowding was included in the previous draft (formerly Figure A-13,
now Figure A-15). Data on the map has been described in more detail through revisions to the text. See
Pages A-32 and A-33.
Homelessness: A new map has been added based on data from the County of Los Angeles. It shows the
density of the homeless population throughout the County, providing a regional perspective (see new
Figure A-17.) A new text section has been added to discuss the data. See Pages A-39 and A-40.
In HCD’s subsequent clarification to this comment (correspondence from Gianna Marasovich on 4/26 at
4:38 PM), it was suggested that the City add the tables on pages 75-78 of HCD’s AFFH Guidance Memo in
response to this comment. We have done this and inserted eight new tables into the AFFH analysis
(Appendix A), with data for 2010 and 2020 for Rolling Hills and Los Angeles County in each table, as
requested. These tables are found on pages A-6, 7, 11, 13, 20, 29, 31, and 32 (page references are to the
tracked changes version). We have also added narrative text that interprets the data.
Other Relevant Factors: The element must include other relevant factors that contribute to fair housing
issues in the jurisdiction. For instance, the element should analyze historical land use, zoning,
governmental and nongovernmental spending including transportation investments, demographic
trends, historical patterns of segregation, or other information that may have impeded housing choices
and mobility.
City Response: Please see Page A-41 (tracked change version). Additional data on land use, zoning,
infrastructure, and historical patterns is included, and a table has been added showing tenure by race.
Information on historical patterns of segregation is included in the section under “local knowledge” on
page A-42.
4
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Sites Inventory: The element must identify sites throughout the community to foster inclusive
communities. While the element identifies and show sites and zoning throughout the community, it also
notes the plan to accommodate half of the regional housing need for lower income households at the
Palos Verdes Unified School District (PVUSD). The element should discuss whether this strategy
potentially isolates housing need for lower income households and include actions as appropriate.
City Response: Please see Page A-43 (tracked change version). We have added a new section called
“Distribution of Proposed Housing Sites.” Given the City’s physical constraints and the small size of the
RHNA (29 lower income units), the City’s strategy to meet its regional housing need is practical,
responsive to economic conditions, and the most effective way to meet State AFFH objectives. As noted
in the text, this strategy combines a vacant, developable affordable housing site (Rancho Del Mar) with
scattered site ADUs. A single 16-unit affordable housing development plus 40 scattered site ADUs would
not result in the isolation of lower income households.
Goals, Actions, Metrics, and Milestones: Goals and actions must significantly seek to overcome
contributing factors to fair housing issues. Programs generally must address enhancing housing mobility
strategies; encouraging development of new affordable housing in high resource areas; improving place-
based strategies to encourage community conservation and revitalization, including preservation of
existing affordable housing; and protecting existing residents from displacement. Given that most of the
City is considered a high and highest resource community (pg. 3-50), the element could focus on
programs that enhance housing mobility and encourage development of more housing choices and
affordable housing. Programs also need to be based on identified contributing factors, be significant and
meaningful. The element must add, and revise programs based on a complete analysis and listing and
prioritization of contributing factors to fair housing issues. Furthermore, the element must include
metrics and milestones for evaluating progress on programs, actions, and fair housing results. For more
information, please see HCD’s guidance at https://www.hcd.ca.gov/community-
development/affh/index.shtml.
City Response: Text edited. See text on pages A-44 to A-47 (tracked change version). The discussion of
contributing factors and priorities has been substantially rewritten in response to this comment, and in
response to our review of recently certified elements that were deemed to comply with AB 686. We have
documented the four categories of programs that address contributing factors (enhancing mobility, new
affordable housing development in high resource areas, etc.); we have established priorities in two of
these areas; we have ranked these priorities 1, 2, and 3 (disparities in access to opportunity, fair housing
education and outreach, access for persons with disabilities), we have identified contributing factors in
each case, and we have identified the significant and meaningful actions that are included in Chapter 6
of the Housing Element addressing each contributing factor.
B2. Needs Assessment/ Documentation of projections and existing/projected needs for all
income levels (Element Chapter 3)
Extremely Low-Income Households: The element includes analysis regarding extremely low-income
(ELI) households such as the number of households and overpayment but must also identify projected
housing needs. The projected housing need for ELI households can be calculated by using available
census data to determine the number of very low-income households that qualify as ELI households or
presume that 50 percent of the regional housing need allocation (RHNA) for very low-income
households qualify as ELI households. For additional information, see the Building Blocks at
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http://www.hcd.ca.gov/community-development/building-blocks/housing-needs/extremely-low-
income-housing-needs.shtml.
City Response: This information was provided in our December 2021 draft on page 6-20 (Table 6-1). As
indicated there, the City used the CHAS data (consistent with the link cited by HCD above) to determine
that 35 percent of the City’s very low income households were extremely low income. We have edited
Chapter 3 so that this same data and conclusion is referenced there. Please see Page 3-33 for new text.
B3. Needs Assessment/ Analysis of Household Characteristics, Overpayment, Housing
Condition (Element Chapter 3)
Overpayment: While the element identifies the total number of households overpaying for housing, it
must quantify and analyze the number of lower-income households overpaying for housing by tenure
(i.e., renter and owner).
City Response: We have edited the document so that this information appears in two places. First,
please see Table A-7, which was added to Appendix A (Affirmatively Furthering Fair Housing) to compare
cost-burdens among extremely low income and low income renter and owner households in Rolling Hills
and Los Angeles County. A new Table also has been added to Chapter 3 showing overpayment for
housing by tenure among lower income households (see Page 3-17 of tracked change document, Table
3.11) along with supplemental narrative interpreting the table. This is based on CHAS HUD User data.
Housing Stock Condition: The element analyzed the age of the housing stock, discussed code
enforcement data, and stated that there are no code enforcement or housing problems in the City.
However, the element must estimate the number of units in need of rehabilitation and replacement.
City Response: Text edited. There are approximately 700 homes in Rolling Hills. City staff is aware of
five houses in need of rehabilitation and replacement. This has been documented and is now included on
Page 3-27 (tracked change version). This represents 0.8 percent of the city’s housing stock.
B4. Sites Inventory (Element Chapter 4)
Progress in Meeting the RHNA –The element is counting two ADUs as credit towards RHNA. First, the
element must demonstrate the availability of these units during the planning period. For example, the
element could discuss whether these units have pending or approved building permits. Second, the
element must demonstrate affordability based on actual or anticipated rents or other mechanisms
ensuring affordability (e.g., deed-restrictions).
City Response: Text edited. ADU permits were issued for the units in question on October 27, 2020 and
May 20, 2021 respectively. Both of these projects involve converting existing two-story stables (located
on two separate parcels about a mile apart) into ADUs of approximately 600 square feet each. Neither
of these units has a finaled building permit yet. Given the eight year timeframe of the Housing Element,
both units are expected to be completed before 2029.
These are market rate units. The assumption that they will be affordable to low income households is
based on the size of the units and the fact that they are being created by repurposing existing space
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rather than building new space, which presumably would cost more. Current HCD income limits for Los
Angeles County indicate that the upper end of the low-income range for a two-person household is
$75,700. At 30 percent of household income, monthly housing costs would need to be $1,892 to be
considered affordable. The City’s survey of comparable properties in 2021 found that ADUs of 400 to 600
square feet in the Palos Verdes Peninsula sub-market were renting for $900 to $1,800 per month. The
two new ADUs can be reasonably presumed to rent for comparable rates. Moreover, SCAG’s ADU survey
for Los Angeles County found that 60% of all ADUs in the coastal region could be presumed affordable to
lower income households. As these two ADUs are the smallest of the nine approved units that are listed
in the Housing Element (see Table 4-1), it is reasonable to presume they would fall in this range.
This information has been added to Chapter 4 (see Page 4-2).
Electronic Sites Inventory: Pursuant to Government Code section 65583.3, the City must submit an
electronic sites inventory with its adopted housing element. The City must utilize standards, forms, and
definitions adopted by HCD.
City Response: The City intends to comply with this requirement immediately following adoption and
concurrently with submittal to HCD, consistent with the Government Code.
Emergency Shelters: The element must demonstrate compliance with emergency shelters parking
requirements. Pursuant to AB 139 (Chapter 335, Statutes of 2019) emergency shelters are only required
to provide sufficient parking to accommodate all staff working in the emergency shelter, provided that
the states do not requirement more parking for emergency shelters than other residential or
commercial uses within the same zone [sic]. Additionally, the element states emergency shelters are not
allowed to be within 300 ft from each other; however, state law only allows a maximum of 300 ft
separation requirement. The element should describe compliance with these requirements or include
programs as appropriate.
City Response: Text edited, see Chapter 5 (P 5-11, tracked change version). The City’s emergency shelter
standards were reviewed by HCD in December 2020 and were determined to be legally compliant.
Rolling Hills does not require more parking for emergency shelter than for other residential and
commercial uses in this zone. This statement has been added to the text. The RDMO overlay is a
residential zone, and the parking standards for other uses (multi-family housing and SROs) in this zone
are based on the number of units and or bedrooms, which would be substantially higher than the
requirements for a shelter. The separation standard used by the City is consistent with State law and is
the same as the standard used by other jurisdictions with recently-certified Housing Elements. The
current standard would allow two shelters to be 300 feet apart, as required by the Government Code.
The wording in Chapter 5 has been amended for clarity. Please see Page 5-10 (tracked change version)
for these edits.
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Permanent Supportive Housing: Supportive housing shall be a use by-right in zones where multifamily
and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to
Government Code section 65651. The element must demonstrate compliance with this requirement and
include programs as appropriate.
City Response: Text edited, See Chapter 5 (P 5-12). The City acknowledges this requirement and intends
to comply with it. It was previously documented on Page 5-12 and also on Page 6-6, where there is a
Program to address it (Program 4). The program will be implemented within six months.
Emergency Shelters, Single Room Occupancy (SRO), and Multifamily Zoning: The element identifies a
31-acre site with an overlay zone that will accommodate the City’s lower-income RHNA, allow for
emergency shelters by-right, and SROs with a CUP. The element should discuss and analyze the
suitability of this site to accommodate these various housing types and the full spectrum of the housing
needs (beyond RHNA).
City Response: We have added text to Page 4-10 which highlights the findings of Appendix B.
Appendix B (included in the HCD Draft) demonstrates the suitability of this site for emergency shelters,
SROs, and multi-family housing. As a 31-acre property, the site has the capacity for any one of these
uses on its own, any combination of these uses, or all three uses (multi-family housing, SRO, and shelter),
either in a single development or in three entirely separate developments within the property. As
Appendix B notes, the parcel includes multiple subareas, some of which may be more conducive to
shelters and SROs and some of which may be better suited for multi-family housing.
Accessory Dwelling Units (ADU) (Addressed in Chapter 5): After a cursory review of the City’s
ordinance, HCD discovered several areas which were not consistent with State ADU Law. This includes
but is not limited to restricting bedroom count and permitting procedures, among others. HCD will
provide a complete listing of ADU non-compliance issues under a separate cover. As a result, the
element should add a program to update the City’s ADU ordinance in order to comply with state law.
For more information, please consult HCD’s ADU Guidebook, published in December 2020, which
provides detailed information on new state requirements surrounding ADU development.
City Response: Text edited. See Chapter 5 (P 5-7) As of May 9, 2022, the City has not received
supplemental correspondence from HCD regarding ADU non-compliance issues. However, the ADU
provisions in the Municipal Code were last updated in February 2020 and the City recognizes that State
ADU legislation has changed in the last two years. Accordingly, we have added a new Program to
Chapter 6 (see Program 6, new Program 6.10) to update the Municipal Code no later than October 15,
2022 to ensure that it complies with all current ADU regulations. This includes eliminating references to
the two-bedroom maximum and updating the permitting procedures so that they are compliant with
State law.
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Water Sewer Priority: Water and sewer service providers must establish specific procedures to grant
priority water and sewer service to developments with units affordable to lower-income households.
(Gov. Code, § 65589.7.) Local governments are required to immediately deliver the housing element to
water and sewer service providers. The element should discuss compliance with these requirements and if
necessary, add or modify programs to establish a written procedure by a date early in the planning period.
City Response: Text edited. See Chapter 1, page 1-8 (tracked change version). The following language
has been added. The City will follow through as described:
In addition, as required by SB 1087, the City sent an electronic copy of its Housing Element
to the appropriate water and sewer providers immediately after adoption. The document
was accompanied by a letter reminding these agencies they must have adopted written
policies and procedures that grant a priority for service hook-ups to developments that help
meet the community’s share of the regional need for lower-income housing.
Availability of Infrastructure: While the element describes infrastructure capacity to accommodate the
regional housing need, the element must also provide an analysis on access to dry utilities for the sites
identified in the inventory.
City Response: Text has been added to Chapter 5, P 5-29 (tracked change version). All of the housing
opportunity sites would be able to receive gas, electric, and telecommunication services if they are
developed. The Rancho Del Mar site currently has access to these services, as it is a former school.
B5. Constraints Analysis (Element Chapter 5)
Processing and Permit Procedures: While the element included some information on approving single
family homes, the analysis should address the approval body, the number of public hearings, if any,
approval findings, and any other relevant information such as any design review requirements. The
analysis should address impacts on housing cost, supply, timing, and approval certainty. For example,
the element mentioned the requirement of a site plan review for any proposed development, the use of
conditional use permit for single room occupancy units, and that City Council and Planning Commission
take field trips to the proposed site as part of the review process. The element should specifically
identify timing, approval findings, and criteria for approvals.
City Response: Text edited. See Chapter 5, P 5-17 and -18 (tracked change version). The City has
provided more information on the approval body for single family homes (Planning Commission), the
number of public hearings (minimum one hearing, plus one field trip, although more hearings typically
occur), and the approval findings (these are described in the text). Design review is conducted privately
by the RHCA, and is addressed as a non-governmental constraint on Pages 5-22 and 5-23. The text
concludes that the processing and permit procedures do not substantially affect the cost, supply, timing
or approval certainty for affordable units, ADUs, or multi-family housing, since these housing types are
permitted by right (provided they comply with the objective standards in the Municipal Code) and would
be exempt from these requirements. The text also documents the high rate of approval for site plan
review applications for single family homes. As the text notes, single family homes are typically multi-
million dollar construction projects requiring extensive grading and development on sites with geological
hazards and very high fire danger. The review process provides an important opportunity to address
public health and safety issues, respond to community concerns regarding construction, and establish
approval conditions where necessary.
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On/Off Site Improvements: While the element stated that specific parcels zoned for multifamily such as
the PVUSD site will require ingress and egress improvements (p. 5-23), the element should identify
typical site improvement requirements, such as minimum street widths (e.g., 40-foot minimum street
width), and analyze their impact as potential constraints on housing supply and affordability.
City Response: Text added. See Page 5-18 (tracked change version). Site improvement requirements are
documented in the previously submitted draft. The edited text confirms that there would be no special or
unique site improvement requirements imposed on the PVUSD site. Off-site improvements are not typically
required for new homes. Site improvements are associated with extension of electric service, installation of
a septic system, and conformance to lighting standards (there are no street lights). The newly added text
describes the site improvements specifically associated with subdivision of land, including street width
standards, and requirements to install on-site water and storm drainage systems and to dedicate
easements for gas and electric services. The text notes that all streets in Rolling Hills are private.
Constraints on Housing for Persons with Disabilities:
• Group Homes for Seven or More: The element must discuss how the City defines and permits group
homes for seven or more persons. For your information, excluding these uses from residential zones or
subjecting the uses to conditional use permits (CUP) is generally considered a constraint and programs
should be modified as appropriate with specific commitment to allow the use in residential zones with
objectivity and certainty.
City Response: Text added. See Page 5-14 (tracked change version). The City does not reference either
large or small group homes in its Municipal Code, and treats these uses the same as other residential
uses, as required by State law. The newly added text acknowledges that the absence of a definition and
explicit listing of large and small residential care facilities as a permitted use could be a constraint. We
have also added language to Program 4 (Chapter 6) calling for Code changes to add definitions or large
and small residential care facilities, and to list these as permitted uses as required by State law.
• Reasonable Accommodation: While the element briefly describes its reasonable accommodation
procedures, it must describe the process and decision-making criteria such as approval findings and
analyze any potential constraints on housing for persons with disabilities.
City Response: Text added. See Page 5-13 (tracked change version). As requested, we have added a
description of the process and decision-making criteria, including approval findings. No constraints have
been identified.
Other Local Ordinances: The element must analyze any locally adopted ordinances that directly impacts
the cost and supply or residential development (e.g., inclusionary requirements, short term rentals,
growth controls).
City Response: Text added. See Page 5-22 (tracked change version). We have added a new Section 5.2.9
called “Other Local Ordinances.” There are no other ordinances that directly affect the cost or supply of
housing in the city.
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Zoning, Development Standards and Fees: The element must clarify compliance with new transparency
requirements for posting all zoning, development standards and fees on the City’s website and add a
program to address these requirements, as necessary.
City Response: Text added. See Page 5-22 (tracked change version). The newly added Section 5.2.9 now
includes a summary of AB 1483, requiring the posting of the referenced information on the City’s website.
The analysis concludes that the City complies with the requirements. In addition, a new program has
been added to Chapter 6 to reorganize this information, including a dedicated landing page on ADUs.
SB 35 Streamlined Ministerial Approval Process: The element must clarify whether there are written
procedures for the SB 35 (Chapter 366, Statutes of 2017) Streamlined Ministerial Approval Process and
add a program to address these requirements, if necessary
City Response: Text added. See Page 5-22 (tracked change version). The newly added Section 5.2.9 now
also addresses the requirement to have written procedures for SB 35 projects. The revised Element now
includes a program to prepare written procedures for SB 35 projects and include them on the City’s website.
B6. Nongovernmental Constraints (Element Chapter 5)
Approval Time: The element must analyze the length of time between receiving approval for a housing
development and submittal of an application for building permits that potentially hinder the
construction of a locality’s share of the regional housing need.
City Response: We have added a new section 5.3.4 to the Element that addresses this issue. See Page 5-
24. This constraint is beyond the City’s control, but we acknowledge that inflated construction costs,
shortages of labor and materials, rising interest rates, and factors such as the COVID-19 pandemic, have
caused several property owners to postpone their plans, re-evaluate or redesign their projects, or sell
their properties. Please note that we have also expanded Program 6 to add a new Action relating to
follow-up communication with ADU permit recipients.
C. Programs (Element Chapter 6)
C1. Schedule of Actions
To have a beneficial impact in the planning period and address the goals of the housing element,
programs must be revised with discrete timelines and specific commitment. Several programs included
various actions but still must include a timeline for implementing each action including, Program 8 –
Assist Senior and Disabled Households, Program 9 – Assist Extremely Low-Income Households, Program
12 – Facilitate Communication with Affordable Housing Service Providers…Program 14 – Sewer
Feasibility Studies and Phase One Construction, Program 20 – Fair Housing Services Program
Administration, Program 22 – Fair Housing Training for Staff.
City Response: The comment references Programs 8, 9, 12, 14, 20, and 22. The following edits have been
made to Chapter 6 in response:
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• Program 8 currently includes a commitment to update the City’s website to add a dedicated
page with “senior resources” by June 2023. We have added a second timeline and commitment,
which is to convene a City Council study session before December, 2023 to discuss the needs of
seniors, in collaboration with the RHCA Needs of Seniors Committee and non-profit senior
organizations (such as Peninsula Seniors).
• Program 9 currently includes a commitment to establish a roster of ADUs offered to Extremely
Low Income (ELI) households by 2024. A new quantified objective and timeline has been added
to the Program, which is to facilitate assistance to 3 ELI homeowners by 2025.
• Program 12 currently includes a commitment to facilitate a meeting with affordable housing
service providers by December 2022. The Program has been modified to facilitate such a
meeting at least once a year during the planning period.
• Program 14 has a discrete timeline and specific commitment, which is to complete the Phase 1
project by 2024. The feasibility of future phases depends in the availability of grants. Additional
timeline and commitment data has been added to the program.
• Program 20 has been modified, as the City seeks to determine the costs and benefits of different
fair housing outreach and enforcement strategies. The program commits to a Fair Housing
outreach and enforcement strategy by the end of 2022, thus providing a discrete timeline and
specific commitment.
• Program 22 previously indicated a measurable objective of one staff training per year, starting in
2022. This has been reiterated through an edit to the text.
C2. Programs relating to Sites
As noted in Finding B4, the element does not include a complete site analysis; therefore, the adequacy
of sites and zoning was not established. Based on the results of a complete sites inventory and analysis,
the City may need to add or revise programs to address a shortfall of sites or zoning available to
encourage a variety of housing types. In addition, the element must be revised, as follows:
City Response: See responses to HCD comments numbered 10 through 17, as labeled in the left-hand
margins of this document. The City has provided additional analysis demonstrating that the identified
sites, which include the 31-acre RDMO site, vacant sites zoned for single family homes, and potential
ADUs, are adequate to meet the RHNA of 45 housing units. In response to HCD’s comments and the
supplemental analysis, we have also added Programs 6.10 and 6.11 to further improve the production of
ADUs and Program 23 to support SB 35 applications (see responses to comments 15, 24, and 25 above).
Program 2 – Rancho Del Mar Opportunity Site Monitoring: The element identifies one site to
accommodate a portion of its lower-income RHNA. While the program includes several actions such as
subdividing the site, coordination with the school district, technical assistance and incentives, the
program does not commit to these actions nor provide a date for when these actions will occur.
Specifically, the element should include timelines for various actions and include commitments to
outreaching, coordination, and establishing incentives that facilitate development on this site, as
mentioned in the program.
City Response: Text modified, see Chapter 6, Program 2 (P. 6-4 and 6-5 of tracked change version). We
have edited the program to provide a timeline for subdivision, coordinate with the school district and
prepare a fact sheet for the site, all of which will facilitate its development.
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Program 6 – Accessory Dwelling Unit (ADU) Production, Monitoring, and Incentives: The element
heavily relies on ADUs to accommodate most of the City’s RHNA for all income levels. Given the City’s
assumptions for ADUs exceed recent trends, the element should include a program to monitor
permitted ADUs and affordability every other year and take appropriate action such as adjusting
assumptions or rezoning within a specified time period (e.g., six months).
City Response: The Element is presuming five ADUs per year, which is a lower number of ADUs than
were permitted in 2021. The City has expanded Program 6.2 to add provisions for monitoring ADU
production, including taking action within six months in the event the number of ADUs approved is falling
short of the projected need during any calendar year. We have also added Program 6.11 to monitor
permitted ADUs to support their construction after they are approved.
Zoning for a Variety of Housing Types: The element identifies Program 4 and 5 committing to provide a
variety of housing types (e.g., SROs, transitional and supportive housing, employee housing, etc.,) and
address constraints for people with disabilities. These actions were also identified in the last planning
period but have not been completed. HCD encourages the City to utilize HCD’s technical assistance
resources and model ordinances to ensure effective and efficient implementation. Please see the
Housing Hub Site: Housing Planning Hub Site (arcgis.com)
City Response: Staff appreciates HCD’s references to the technical assistance and model ordinances and
will follow up on available resources. The City’s Fifth Cycle Element was certified in July 2021, and there
has been insufficient time to adopt all of the program recommendations in its first year while
concurrently completing the Sixth Cycle Element. As noted in the revised Program 4, the City intends to
adopt provisions for transitional and supportive housing, large and small residential care facilities, and
employee housing in its Municipal Code by July 2022. Program 5 addresses density bonuses and is
proposed for implementation by the end of 2022.
C3. Programs Relating to Constraints
As noted in Finding(s) B5 and B6, the element requires a complete analysis of potential governmental
(sic). Depending upon the results of that analysis, the City may need to revise or add programs and
address and remove or mitigate any identified constraints.
City Response: See responses to HCD’s numbered comments 12, 13, 15, 17, 18, 19, 20, 21, 22, 23, 24,
and 25, as labeled in the left-hand margins of this document. The City has now provided a complete
analysis of potential governmental constraints, as requested by HCD. Please note that as a result of the
additional analysis, we have expanded Programs 4 and 6 (see Chapter 6 in the tracked change version),
including the addition of new programs supporting ADU monitoring and development. We have also
added programs 23 and 24 related to SB 35 and AB 1483.
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C4. Programs Relating to AFFH
As noted in Finding B1, the element must include a complete analysis of affirmatively furthering fair
housing. Based on the outcome of that analysis, the element must add or modify programs.
City Response: See responses to HCD’s numbered comments 2 through 6, as referenced in the left-hand
margins of this document. The City has now provided a complete analysis of AFFH, as requested by HCD.
Please note that as a result of the additional analysis, pages A-44 to A-47 have been added to link the
AFFH priorities and contributing factors to the specific programs listed in Chapter 6.
D. Quantified Objectives
While the element does include quantified objectives (p. 6-20), it must be revised to
include quantified objectives for number of housing units that will be rehabilitated for low, moderate,
and above moderate households.
City Response: In an email from HCD’s Housing Policy Analyst Gianna Marasovich sent on April 27 (4:37
PM), we were advised that “we determined that Rolling Hills can disregard the Quantified Objectives
finding”. Accordingly, no edits have been proposed in response to this comment.
E. Public Participation
While the element described various efforts to achieve public participation in the preparation of the
housing element update, it should also describe how comments were considered and incorporated into
the element.
City Response: Text has been added to Page 1-8 indicating how comments were considered and
incorporated into the element. Several examples are provided, including the selection of the Rancho Del
Mar site for rezoning, the focus on accessory dwelling units as a strategy to meet the RHNA, and the
importance of programs to help seniors age in place, given the large number of older adults in the
community.
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CITY OF ROLLING HILLS
2021-2029
HOUSING ELEMENT
Adoption Draft
Published May 9, 2022
TRACKED CHANGES VERSION
498
As required by State law, an initial draft of this document (referred to as the
“HCD Draft”) was circulated for public comment and review for 30 days,
beginning on December 3, 2021. More than 30 local agencies and organizations
providing housing and related supportive services were notified and invited to
comment on the Draft.The Draft was also discussed at a Planning Commission
public hearing in December 2021 and a City Council hearing that occurred on
January 10, 2022. On January 10, the City Council authorized submittal of the
Draft to the California Department of Housing and Community Developlment
(HCD) for review. Under State law, HCD had 90 days to issue its findings.
Comments from the State Department of Housing and Community Development
(HCD) were received on April 11, 2022. City staff/consultants met with HCD to
review the comments on April 22, 2022. This “Adoption Draft” incorporates
revisions that directly respond to and address the HCD comments, A revised
document was issued on May 9, 2022. This document was made available for
two weeks prior to Council action on the document (seven days is required).
Once adopted, this document will be re-submitted to HCD, inclusive of any
changes made during Planning Commission and Council hearings (including
changes responding to public comments). HCD will then have 60 days to issue its
findings.
499
ROLLING HILLS
HOUSING ELEMENT
2021-2029
Adoption Draft:
Tracked Change Version
CONTACT:
City of Rolling Hills
2 Portuguese Bend Road
Rolling Hills, CA 90274
Contact: John Signo, AICP
jsigno@cityofrh.net
Published May 9, 2022
All changes between the January 2022 version and the May 2022 version of
this document are highlighted in redlined (tracked changes) font
500
ACKNOWLEDGMENTS
Rolling Hills City Council
James Black, M.D., Mayor
Bea Dieringer, Councilmember
Leah Mirsch, Councilmember
Jeff Pieper, Councilmember
Patrick Wilson, Councilmember
Rolling Hills Planning Commission
Brad Chelf, Chair
Greg Kirkpatrick, Vice-Chair
Sean Cardenas, Commissioner
Jana Cooley, Commissioner
Abby Douglass, Commissioner
City Staff
Elaine Jeng, P.E., City Manager
John Signo, Planning and Community Services Director
Michael Jenkins, City Attorney
Jane Abzug, Assistant City Attorney
Consultants
Barry Miller, Barry Miller Consulting
501
i
FOREWORD
This document has been prepared to comply with the requirements of California Government
Code Sections 65580-65589, which mandate that all California cities and counties adopt a
Housing Element to address local and regional housing needs. The Housing Element is part
of the Rolling Hills General Plan and covers the time period 2021-2029. State law requires
that the Housing Element is updated every eight years and submitted to the State Department
of Housing and Community Development for certification.
Certification of the Housing Element is based on a determination that the City has complied
with a variety of State laws addressing regional issues such as affordability, fair housing,
density, housing type, overcrowding, and homelessness. These laws apply universally to all
cities, including those with limited services and land capacity.
As a community within the Greater Los Angeles region, the City of Rolling Hills is obligated to
provide for its “fair share” of regional housing needs as determined by the Southern
California Association of Governments. Cities without certified Housing Elements are subject
to legal and financial penalties, the loss of eligibility for grants which help fund City
operations, and even the potential loss of local control over building and land use decisions.
For these reasons, it is in the City’s best interest to strive for a compliant element.
In adopting this Element, the City has endeavored to balance State mandates with the
overarching goal of preserving the semi-rural, equestrian character of Rolling Hills. The
Housing Element responds to local as well as regional needs, including the need to preserve
the community’s environment, minimize further exposure to wildfire and landslide hazards,
and recognize infrastructure and public facility constraints.
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Rolling Hills Housing Element
2021-2029
TABLE OF CONTENTS
Section Page
FOREWORD .................................................................................................................... i
TABLE OF CONTENTS .................................................................................................. ii
1. INTRODUCTION .............................................................................................. 1-1
1.1 Purpose ................................................................................................................... 1-1
1.2 Community Overview ............................................................................................ 1-2
1.3 Legislative Requirements ...................................................................................... 1-3
1.4 Relationship to Other General Plan Elements.................................................... 1-5
1.5 Relationship to Private Land Use Restrictions ................................................... 1-6
1.6 Public Participation and Project Timeline ........................................................... 1-6
1.7 Data Sources ........................................................................................................ 1-98
2. EVALUATION OF PRIOR HOUSING ELEMENT ............................................... 2-1
2.1 Purpose ................................................................................................................... 2-1
2.2 2014-2021 RHNA and Actual Housing Production ........................................... 2-1
2.3 Review of Prior Housing Element Goals and Policies ....................................... 2-2
2.4 Implementation Status of Prior Housing Element Programs ......................... 2-54
3. HOUSING NEEDS ASSESSMENT ................................................................... 3-1
3.1 Introduction ............................................................................................................. 3-1
3.2 Population Characteristics .................................................................................... 3-2
3.3 Household Characteristics ................................................................................... 3-9
3.4 Populations with Special Needs......................................................................... 3-17
3.5 Housing Stock Characteristics ........................................................................... 3-26
3.6 Future Housing Needs ...................................................................................... 3-332
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iii
Section Page
4. HOUSING OPPORTUNITIES AND RESOURCESSITES ................................... 4-1
4.1 Introduction ............................................................................................................. 4-1
4.2 Approved or Pending Development .................................................................... 4-1
4.3 Vacant Sites ............................................................................................................ 4-2
4.4 Lot Splits ................................................................................................................. 4-6
4.5 Non-Vacant Sites ................................................................................................... 4-6
4.6 Accessory Dwellings ........................................................................................... 4-12
4.7 Summary of Ability to Meet RHNA .................................................................. 4-154
4.8 Opportunities for Energy Conservation .......................................................... 4-165
4.9 Financial Resources .......................................................................................... 4-187
5 CONSTRAINTS TO HOUSING PRODUCTION ................................................ 5-1
5.1 Introduction ............................................................................................................. 5-1
5.2 Governmental Constraints .................................................................................... 5-1
5.3 Non-Governmental Constraints ..................................................................... 5-2319
6 HOUSING GOALS, POLICIES, OBJECTIVES, AND PROGRAMS ................... 6-1
6.1 Goals and Policies ................................................................................................ 6-1
6.2 Housing Implementation Plan, 2021-2029 ......................................................... 6-4
6.3 Summary of 2021-2029 Quantified Objectives ............................................... 6-21
APPENDIX A:
Affirmatively Furthering Fair Housing (AFFH) Analysis ........................................................ A-1
Overview ........................................................................................................................ A-1
Duty of All Agencies to Affirmatively Further Fair Housing .................................... A-3
Integration and Segregation ..................................................................................... A-54
Access to Opportunity .......................................................................................... A-2214
Disproportionate Housing Needs .......................................................................... A-290
Other Relevant Factors .............................................................................................. A-41
Local Data and Knowledge .................................................................................. A-4227
Distribution of Proposed Housing Sites .................................................................. A-43
Identification and Prioritization of Contributing Factors ................................... A-4428
Summary of Fair Housing Issues and Additional Fair Housing Concerns ..... A-4930
APPENDIX B:
Analysis of Palos Verdes Unified School District (PVUSD) Site ......................................... B-1
APPENDIX C:
Accessory Dwelling Unit Survey Findings ............................................................................. C-1
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iv
Figures Page
1.1 Vicinity Map ................................................................................................................. 1-21
4.1 Vacant Residentially Zoned Sites ............................................................................... 4-5
4.2 Non-Vacant Sites Evaluated ..................................................................................... 4-87
5.1 Slope Setbacks on PVUSD Site ................................................................................. 5-9
5.2 Landslide Hazard Areas in Rolling Hills ............................................................... 5-3127
5.3 Earthquake Faults in the Rolling Hills Vicinity ..................................................... 5-3228
5.4 CalFIRE Very High Fire Hazard Severity Zone ................................................... 5-3329
A-1 AFFH Percentage of Residents who are Non-White ............................................. A-86
A-2 AFFH Diversity Index ................................................................................................. A-97
A-3 AFFH Percentage of Residents with a Disability ................................................. A-108
A-4 Familial Status ............................................................................................................. A-15
A-54 Low Moderate Income (LMI) Areas ...................................................................... A-160
A-65 Median Income by Census Tract Block Group ................................................... A-171
A-7 Regional Income by Census Tract in Greater Los Angeles ................................. A-18
A-86 Racially and Ethnically Concentrated Areas of Poverty (R/ECAP) ................... A-192
A-97 Environmental Outcomes ..................................................................................... A-2516
A-108 Economic Outcomes ............................................................................................. A-2617
A-119 Education Outcomes ............................................................................................. A-2718
A-120 Composite Opportunity Map................................................................................ A-2819
A-131 Cost-Burdened Homeowners .............................................................................. A-3422
A-124 Cost-Burdened Renters ........................................................................................ A-3523
A-153 Incidence of Overcrowding .................................................................................. A-3624
A-146 Percent of Households with One or More Severe Housing Problems .......... A-3725
A-157 Sensitive Communities ......................................................................................... A-3826
A-18 Density of Homeless Population in 2020 in Los Angeles County ........................ A-40
505
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Tables
2.1 Implementation Status of 2014-2021 Housing Element Programs ........................ 2-54
3.1 Rolling Hills Population, 1970-2021 .............................................................................. 3-2
3.2 Comparison of Rolling Hills Growth with Nearby Cities and Region ........................ 3-3
3.3 Race and Ethnicity in Rolling Hills, Peninsula Cities, LA County, and State .......... 3-5
3.4 Rolling Hills Employed Residents by Occupation ....................................................... 3-8
3.5 Rolling Hills Employed Residents by Industry.............................................................. 3-8
3.6 Income Limits for Los Angeles County, 2021 ............................................................ 3-13
3.7 Affordable Monthly Housing Costs Based on 2021 Income Limits ........................ 3-13
3.8 Rolling Hills Households by HUD Income Category ................................................. 3-14
3.9 Household Income in Rolling Hills, Peninsula Cities, and LA County .................... 3-15
3.10 Percent of Income Spent on Housing in Rolling Hills and LA County .................... 3-16
3.11 Overpayment among Lower Income Households in Rolling Hills ........................... 3-17
3.112 Older Adults in Rolling Hills and Nearby Jurisdictions ...................................... 3-187
3.123 Percent of Rolling Hills Residents with a Disability ................................................... 3-20
3.143 Number of Persons in Family and Non-Family Household ...................................... 3-23
3.154 Homes for Sale in Rolling Hills, July 2021 ................................................................ 3-321
3.165 RHNA by City and Comparison to Fifth Cycle ......................................................... 3-332
3.167 Comparison of 6th Cycle RHNA by Income Category ............................................. 3-343
4.1 Committed Development for the 2021-2029 RHNA Period ....................................... 4-1
4.2 Vacant Residentially Zoned Sites .................................................................................. 4-3
4.3 Summary of Housing Opportunities, 2021-2029 .................................................... 4-154
5.1 Summary of Rolling Hills Zoning Standards ................................................................ 5-4
5.2 City of Rolling Hills Major Development Fees .......................................................... 5-197
6.1 Quantified Objectives by Income Group for Rolling Hills, 2021-2029 .................. 6-210
6.2 Housing Element Action Plan Summary................................................................... 6-220
A-1 Population Share by Race and Ethnicity, Rolling Hills and LA County .................... A-6
A-2 Percentage of Residents with a Disability, Rolling Hills and LA County .................. A-7
A-3 Population by Familial Status, Rolling Hills and LA County ..................................... A-11
A-4 Household Share by Income, Rolling Hills and LA County ...................................... A-13
A-5 Housing Units by Type, Rolling Hills and LA County ................................................ A-20
A-6 Housing Tenure in Rolling Hills and LA County ........................................................ A-29
A-7 Percentage of Cost-Burdened Households, Rolling Hills and LA County ............. A-31
A-8 Overcrowded Households, Rolling Hills and LA County .......................................... A-32
A-9 Rolling Hills Home Ownership Rates by Race and Ethnicity ................................... A-41
A-10 Fair Housing Priorities, Issues, Contributing Factors and Strategies ..................... A-47
Charts
3.1 Age Distribution of Rolling Hills Residents, 2000 and 2020....................................... 3-4
3.2 Racial Distribution of Rolling Hills Residents, 2000 and 2020 ................................... 3-4
3.3 Household Type in Rolling Hills and Los Angeles County, 2021 ............................ 3-10
3.4 Household Size in Rolling Hills and Other Jurisdictions, 2010 and 2021 .............. 3-11
3.5 Total Number of Housing Units in Rolling Hills, 1990-2020 ..................................... 3-26
3.6 Year of Construction for Rolling Hills Homes ............................................................ 3-27
3.7 Percent of Housing Units by Number of Bedrooms, Rolling Hills and LA County3-298
3.8 Home Prices in Rolling Hills, Peninsula Cities, and LA County ............................. 3-310
A-1 Summary of AB 686 Requirements ............................................................................ A-21
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Introduction Page 1-1
1.0 Introduction
1.1 Purpose
The purpose of the Housing Element is to ensure that a safe, decent supply of housing is
provided for current and future Rolling Hills residents. The Element strives to conserve existing
housing while providing opportunities for new housing serving a variety of income levels.
State law mandates that all municipal governments prepare and maintain a Housing Element as
a component of their General Plans. The following five sections are required:
1. Evaluation of the previous Housing Element
2. Assessment of local housing needs based on demographics, economic, and housing
conditions
3. Inventory of potential sites for housing development
4. Analysis of City regulatory framework related to housing development
5. Goals and policies for housing, coupled with specific action programs to be implemented
in the coming years.
In addition, the Element must demonstrate the steps the City is taking to promote fair housing
practices, and to proactively develop housing for all income groups. The Housing Element
describes how the City will provide for its fair share of the region’s housing needs over the eight-
year planning period (2021 to 2029). It identifies new programs to be implemented, along with
on-going programs that create housing opportunities in Rolling Hills.
The Housing Element is the only part of the General Plan that is subject to review and
certification by a State agency. Adopted Elements must be submitted to the California
Department of Housing and Community Development (HCD). HCD determines if the Element
meets the requirements of the California Government Code, which apply equally to all cities and
counties of the state regardless of the community’s size, physical constraints, or resources. A
compliance determination is important to maintain eligibility for State grants, avoid costly
lawsuits, and maintain local control over local land use and building decisions.
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Figure 1.1: Vicinity Map
1.2 Community Overview
The city of Rolling Hills is a rural, equestrian residential community, consisting entirely of large
lot residential parcels of one acre or more. The community encompasses 2.99 square miles of
land (approximately 1,910 acres) on the Palos Verdes Peninsula in the County of Los Angeles
(Refer to Figure 1.1, Vicinity Map). The 2020 Census indicates a citywide population of 1,739
residents, making Rolling Hills the fifth smallest of the 88 cities in Los Angeles County.
The land use pattern in Rolling Hills was established in 1936 with the original subdivision and
sale of parcels. American landscape architect A.E. Hanson designed the community in the
1930s, establishing an historic Southern California design aesthetic that remains today, 85 years
later. Well-known architects like Cliff May and Wallace Neff designed some of the early homes,
contributing to the community’s historic context.
The entire city is characterized by single-story California ranch-style homes on large lots with
three-rail fences and equestrian facilities. There are three points of ingress and egress to the
city, each of which has a controlled entry gate. Rolling Hills was planned and conceived to
balance development with nature and respect the area’s rugged topography. The community
was laid out on hilly terrain, with narrow, winding roads traversing steep, wooded canyons.
Minimum lot size requirements were established to recognize the area’s many natural
constraints, including geologic hazards, wildfire, and sensitive biological resources.
Source: Google Maps, 2021
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The natural landscape is characterized by steep slopes of 25 to 50 percent. Underlying this
terrain are ancient landslides, occasionally causing damage or even destroying property, roads,
and infrastructure. The City carefully regulates grading and earth movement to protect public
safety and minimize the potential for property damage. Geologic studies and grading
requirements also add to housing costs.
The entire city lies within a Very High Fire Hazard Severity Zone. This is the most constrained
designation used by the California Department of Forestry and Fire Protection (Cal Fire) and
requires restrictive construction standards such as the boxing in of eave projections and use of
construction materials approved by the California Fire Marshal. Professionally designed
landscaping meeting Fire Department fuel reduction standards (i.e., fire-resistant plants around
structures) also is required. Fire hazards are complicated by an aging water distribution system,
and the high cost of water system improvements on steep terrain.
Rolling Hills is also home to a number of sensitive plant and animal species, several of which are
listed or being considered for listing by the U.S. Department of Fish and Wildlife and/or the
California Department of Fish and Wildlife. These species include the Palos Verdes Blue
butterfly, the California Gnatcatcher, the Pacific Pocket Mouse, the San Diego Horned Lizard,
and Brackishwater Snail. The community is also underlain with blue-line streams that are under
the jurisdiction of the Army Corps of Engineers.
The City’s infrastructure is scaled to meet the needs of a mature, rural community with severe
natural hazards. Its water distribution system is designed for very low-density residential land
uses. Wastewater treatment generally occurs through private septic tanks. Only a few parcels
on the western periphery of the city have access to sanitary sewer. All roads in the community
are private and many were built 60 to 80 years ago before modern emergency vehicle
standards were in place.
Housing policies and programs in Rolling Hills reflect the city’s natural hazards, lack of
developable land, and infrastructure limitations. In the past, the City has complied with
Government Code housing requirements in ways that respond to these inherent physical
constraints. For example, Rolling Hills has adopted provisions for accessory dwelling units in all
of its zoning districts, permitted manufactured housing units, and created an affordable housing
overlay zone on its most developable land. Its policies also emphasize conservation and
maintenance of the existing housing stock, much of which is over 60 years old.
1.3 Legislative Requirements
The provision of adequate housing for families and individuals of all economic levels is an
important public goal and has been a focus for state and local governments for more than five
decades. Local governments have been required to prepare Housing Elements since 1969. The
required contents of the Element have expanded significantly over this time, in response to rising
housing costs, increasing competition for resources, and a growing population of individuals with
special needs that cannot be met by the private sector alone.
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1.3.1 Government Code Requirements
State law requires each municipality to perform the
following tasks:
• Identify and analyze the current and projected
housing needs of all economic segments of the
community.
• Evaluate current and potential constraints to
meeting those needs, including constraints due
to the marketplace and those imposed by the
government.
• Promote and affirmatively further fair
housing opportunities and promote housing
throughout the community for all persons
regardless of race, religion, sex, marital
status, ancestry, national origin, color,
familial status, or disability.
• Inventory and assess the availability of land
suitable for residential use.
• Establish goals, objectives, policies and programs aimed at responding to identified housing
needs, market and governmental constraints, and housing opportunities.
1.3.2 Regional Housing Needs Allocation
As part of the Housing Element process, the State of California determines the total need for
housing in each region of California. For the 2021-2029 period, the State determined that the
need for the six county Southern California region was 1,341,827 housing units. The Southern
California Association of Governments (SCAG) is responsible for allocating this total to each of
the six counties and 191 cities in the SCAG area. This process is known as the Regional
Housing Needs Allocation (RHNA) and occurs every eight years.
SCAG calculates each city and county’s “fair share” of the regional need using a computer
model that weighs factors such as existing population and employment, growth potential,
proximity to transit, and social equity. For each jurisdiction, SCAG distributes the RHNA among
four different income groups. This ensures that each city or county is planning for housing that
meet the needs of all economic segments of the community, including lower income
households.
Each city in California is required to plan for its RHNA. This does not mean the cities must
acquire land or construct housing. Rather, it means that they must identify sites where the
RHNA can be accommodated and adopt policies and regulations which facilitate housing
construction on those sites. Ultimately, the responsibility for constructing housing falls to the
private market and non-profit housing developers. Cities are expected to assist by adopting
“The availability of housing is of
vital statewide importance, and
the early attainment of decent
housing and a suitable living
environment for every
Californian, including
farmworkers, is a priority of the
highest order. The early
attainment of this goal requires
the cooperative participation of
government and the private
sector in an effort to expand
housing opportunities and
accommodate the housing needs
of Californians of all economic
levels.”
California Government Code,
Section 65580
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development standards that support housing at a variety of densities, providing technical
assistance and infrastructure, and adopting policies that encourage housing production,
conservation, and assistance to persons with special needs.
In Rolling Hills, the RHNA for 2021-2029 is 45 units. This includes 20 very low income units, 9
low income units, 11 moderate income units, and 5 above moderate income units.1 The 2021-
2029 Housing Element demonstrates that the City has the capacity to accommodate this
assignment.
1.3.3 HCD Review Authority and Compliance Requirements
Once the Housing Element is adopted, it is submitted to HCD to determine whether, in HCD’s
view, the Housing Element “substantially complies” with state Housing Element Law. HCD’s
compliance determination is based in part on a detailed checklist corresponding to specific
requirements set forth by the Government Code. Once certified, HCD still has the authority to
find a city out of compliance if it finds that city is taking actions that are inconsistent with its
Housing Element or failing to implement the programs listed in its Element.
Localities without an HCD-certified Housing Element are subject to a growing number of
penalties and potential risks. This includes litigation from housing organizations, developers,
and HCD itself. In addition to legal costs, potential consequences include suspension of local
control of building matters and court approval of housing development. Courts can also levy
costly fines on local governments and mandate streamlined and less rigorous approvals. Cities
also become ineligible for numerous state local funding programs, including those supporting
infrastructure and roads, as well as housing and planning.
1.4 Relationship to Other General Plan Elements
The Government Code requires internal consistency among the various elements of a General
Plan. Section 65300.5 of the Government Code states that “the General Plan and the parts and
elements thereof shall comprise an integrated and an internally consistent and compatible
statement of policies.”
The Rolling Hills General Plan contains the following six elements: 1) Land Use; 2) Housing; 3)
Circulation; 4) Open Space and Conservation; 5) Safety; and 6) Noise. The General Plan is
internally consistent, meaning that the policies in different elements complement and support
one another. The Housing Element reflects the policy direction provided by the other General Plan
elements. For example, it references the residential densities established in the Land Use
Element and the natural constraints identified in the Safety Element. The City amended its Land
Use Element in early 2021 to maintain consistency with its new Housing Plan. It is also adopted
a revised revising its Safety Element in March 2022 to comply with new provisions of the
Government Code that are triggered by amendments to the General Plan, including adoption of
a new Housing Element.
1 See Section 3.2.5 of this document for a definition of these income categories
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Pursuant to Government Code Section 65400, the City will annually review its progress in
implementing this Housing Element. This review will help ensure consistency between this
Element and the other General Plan Elements.
1.5 Relationship to Private Land Use Restrictions
Most of the developable property in Rolling Hills is subject to covenants, conditions, and
restrictions (CC&Rs) adopted by the Rolling Hills Community Association (RHCA), a non-profit
California Corporation and homeowners association. RHCA is governed by elected Rolling Hills
residents and oversees and enforces implementation of the CC&Rs. The CC&Rs run with each
property in perpetuity and cover all properties in the City except those listed below:
1. City Hall Complex
2. Tennis Court Facility
3. Palos Verdes Peninsula Unified School District property
4. Daughters of Mary and Joseph Retreat Center
CC&Rs represent private contractual obligations between homeowners and are usually
established at the time a subdivision or community is built. Development in Rolling Hills has
been governed by CC&Rs since the community was planned in the 1930s. The RHCA and the
CC&Rs were in force prior to the City’s incorporation, which occurred in 1957. The City of
Rolling Hills has no jurisdiction over the RHCA or the content or implementation of the CC&Rs.
The CC&Rs limit the density on most parcels in Rolling Hills to one residence per one-acre or
two-acre lot. In addition, any construction, remodel, or grading for a building, fence or structure
is required under the CC&Rs to adhere to traditional or California ranch and equestrian
architectural styles and aesthetics. The uses and purposes of all perimeter easements around
each property are required to be dedicated to the RHCA and maintained for the purposes of
ingress, egress, construction, and maintenance of all infrastructure constructed as roadways,
bridle trials, storm drains, utility access and drainage.
In some instances, State law may supersede the authority of CC&Rs. For example, AB 670 (Cal
Civil Code 4751—effective January 1, 2020) limits CC&Rs from placing unreasonable limitations
on accessory dwelling units (ADUs). To the greatest extent feasible, the programs in this
Housing Element reflect the requirements of State law while maintaining the integrity of the
CC&Rs. CC&Rs that directly conflict with State or Federal law are not enforceable.
1.6 Public Participation and Project Timeline
The City of Rolling Hills has made a diligent effort to engage the community in the Housing
Element update. The process was structured as a continuation of the previous (2014-2021)
Housing Element update, which included an initial phase in 2013-14 when the Element was
adopted and a second phase in 2020-2021 when the adopted Element was amended and
resubmitted to the State for a compliance determination. The 2020-2021 amendments
coincided with the Sixth Cycle engagement processes that were underway throughout Southern
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California cities at that time. Although the focus of the 2020-2021 effort was on Fifth Cycle
compliance, the process provided an opportunity to engage the community in a broader
conversation about housing, the RHNA process, and new State requirements.
SCAG began the RHNA process for the Sixth Cycle in Fall 2019, exploring different
methodologies for allocating the regional need to individual cities and counties. As other cities
began work on their Sixth Cycle Elements, Rolling Hills was required to first amend its Fifth
Cycle Element to accommodate both the current (Fifth) cycle and the prior (Fourth) cycle
RHNA allocations due to its non-compliant status. The combined RHNA for the two cycles was
28 units. Accommodating this need meant that Rolling Hills was also required to amend its
General Plan and zoning to create additional housing capacity.
The City held a public hearing on the Housing Element on November 25, 2019. The meeting
focused on potential sites for rezoning and related development impacts. The meeting was
widely noticed through advertisements in the Palos Verdes Peninsula News, an announcement
in the City newsletter, posting at City Hall, and an email to the City’s interested parties list.
The Draft RHNA numbers were published in March 2020. Rolling Hills did not appeal its
allocation, instead focusing its efforts on continued outreach and engagement to certify the
Fifth Cycle Element and lay the groundwork for the Sixth Cycle. This outreach included nine
public hearings related to the Housing Element on the following dates:
• October 20, 2020 (Planning Commission)
• November 9, 2020 (City Council)
• December 22, 2020 (Planning Commission)
• January 25, 2021 (City Council)
• February 5, 2021 (Planning Commission)
• February 8, 2021 (City Council)
• February 22, 2021 (City Council)
• March 8, 2021 (City Council)
• March 16, 2021 (Planning Commission)
The outcome of these meetings included adoption of the Rancho Del Mar Overlay Zone, new
provisions for by-right affordable multi-family housing and emergency shelter, amendments to
the Land Use Element of the General Plan, and various changes to the Municipal Code to
facilitate housing production. On June 1, 2021, the Planning Commission recommended that
the City Council adopt the amended Fifth Cycle Housing Element. The Council took action on
June 14, 2021. The Element was submitted to HCD and found to be in compliance on July 7,
2021. As a result of the compliance determination, the City does not have to carry over its prior
allocation and may plan only for the 45 units identified in the Sixth Cycle RHNA.
In addition to the public hearings described above, staff conducted direct outreach to Rolling Hills
residents in 2020 and 2021 through newsletters, including a survey on Accessory Dwelling Units
(ADUs) administered to every household in the city. More than 30 percent of the city’s households
completed the survey, and a report on the findings was prepared (it is included as Appendix C to
this Element).
The City continued its public outreach efforts after adoption of the revised Element in July 2021.
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A special session of the Planning Commission was convened on October 19, 2021 to provide an
overview of the Sixth Cycle Element and solicit input from the entire community. In addition,
public hearings on the HCD Draft Element were convened by the Planning Commission on
December 16, 2021 and by the City Council on January 10, 2022. In March 2022, the City
convened a public meeting on the Annual Progress Report, providing another opportunity for
public input on housing issues as well as an opportunity to evaluate progress in Housing
Element implementation. Additional public hearings were will be held on May 17 (Planning
Commission) and May 23 (City Council) after the document was is revised and presented for
adoption.
The City has endeavored to solicit input from all economic segments of the community,
including local renters as well as homeowners. It has also incorporated this input in the Housing
Element. In surveys and public hearings, the community generally supported the Rancho Del
Mar site as the preferred location for accommodating denser housing, and also supported
meeting the RHNA primarily through accessory dwelling units (ADU). Both of these concepts
are reflected in this document. Housing advocacy groups also provided letters to the City
encouraging ADU development, which helped shape Housing Element programs. In addition,
the community was especially concerned about the housing needs of older adults. Thus,
policies relating to special needs populations and lower income households focus on the needs
of seniors, particularly those who may need assistance with the maintenance of their homes and
properties, or adaptive changes to facilitate aging in place.
City staff has also engaged service providers, the development community, and partner
agencies such as the School District in the process. As a small community, most residents rely
on the City newsletter for information on local government affairs. The City has featured the
Housing Element in newsletter articles and encouraged residents to share their views on
proposed housing policies. Publication of the “HCD Review Draft” was announced in the City’s
newsletter during the first week of December 2021. More than 30 stakeholder organizations on
the Palos Verdes Peninsula, and in the South Bay, Los Angeles, and Long Beach regions were
notified of the document’s availability for 30-day review and comment. These agencies were
also notified when the document was brought back to the Planning Commission and City
Council for adoption.
In addition, as required by SB 1087, the City sent an electronic copy of its Housing Element to
the appropriate water and sewer providers immediately after adoption. The document was
accompanied by a letter reminding these agencies they must have adopted written policies and
procedures that grant a priority for service hook-ups to developments that help meet the
community’s share of the regional need for lower-income housing.
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1.7 Data Sources
The Housing Element is a data-driven document, with policies and programs that are based on
analyses of demographics, housing conditions, resource constraints, and forecasts. The primary
data sources consulted were:
• Rolling Hills General Plan, as amended
• Rolling Hills Municipal Code
• Southern California Association of Governments (SCAG) Final Regional Housing Needs
Allocation Plan, adopted March 4, 2021
• SCAG “pre-approved” Housing Element data set for Rolling Hills, 2020
• City of Rolling Hills Planning Department records (building permits, etc.)
• American Community Survey, 2015-2019
• US Census (1990, 2000, 2010)
• US Census August 12, 2021 data release from the 2020 Census
• Department of Finance Table E-5, population and housing estimates, 2010-2021
• California Economic Development Department (EDD) Labor Force Data
• Rolling Hills Local Hazard Mitigation Plan
• County of Los Angeles (data on homelessness)
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Evaluation of Previous Housing Element Page 2-1
2.0 Evaluation of Prior Housing Element
2.1 Purpose
Government Code Section 65588 requires each local government to periodically review its
housing element to:
(1) Evaluate the appropriateness of the housing goals, objectives, and policies in contributing to
the attainment of the state housing goal, which is to provide decent housing and a suitable living
environment for every Californian.
(2) Evaluate the effectiveness of the housing element in attainment of the community's housing
goals and objectives.
(3) Discuss the progress of the city or county in implementation of the housing element.
2.2 2014-2021 RHNA and Actual Housing Production
The City’s Regional Housing Needs Allocation (RHNA) for the prior (2014-2021) period was six
units. This included two very low income units, one low income unit, one moderate income unit,
and two above moderate income units. Rolling Hills also had a “carry-over” requirement of 22
units from the prior (2006-2013) planning period, including six very low, four low, four moderate,
and eight above moderate income units. The 2014-2021 Housing Element identified the
capacity to meet the combined two-cycle (2006-2021) need.
Actual housing construction during 2014-2021 was five units. There were four new market rate
(e.g., “above-moderate income”) single-family homes completed on previously vacant lots over
the 2014-2021 period.1 Another three single family homes were approved on vacant lots but have
not yet been constructed. There was one accessory dwelling unit (ADU) completed. It is
estimated to be a moderate-income unit based on its size (720 square feet). Another six ADUs
were approved between September 2020 and September 2021.2 Three more were pending as of
October 15, 2021. All of these units will become available for occupancy during the Sixth Cycle.
There were no new low or very low-income units recorded during the Fifth Cycle, although lower
income households may have secured housing in the city through room rentals, on-site
employment (caregivers, etc,), or housing provided at nominal or no charge (family members,
domestic staff, etc.). Production of deed-restricted lower-income housing units during the 2014-
2021 planning period was constrained by the high cost of land and construction, limited
opportunities for multi-family housing, and limits to Accessory Dwelling Unit (ADU) development
during the first half of the planning period. The latter two constraints were removed over the
course of the planning period, placing the City in a better position to meet its targets during the
upcoming 2021-2029 period.
1 There were also 12 new homes built on sites that previously included single family homes, with no net gain in units (e.g., “tear
downs”)
2 The six ADUs approved in 2020-2021 were in various states of completion in October 2021 and are all counted toward the Sixth
Cycle RHNA rather than the Fifth Cycle.
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2.3 Review of Prior Housing Element Goals and Policies
The next section of this chapter systematically evaluates the policies and actions of the previous
Housing Element and reports on implementation progress. The 2014-2021 Element included
four goals, each of which included related policies. The goals and policies are evaluated below.
2.3.1 Progress on Goal 1: Housing that Meets the Needs of Rolling Hills Residents
This goal expresses one of the main purposes of the Housing Element. It remains relevant and
should be carried forward. The City worked to accomplish this goal throughout the 2014-2021
planning period through its planning, zoning, building, code enforcement, and fire safety
programs.
Policy 1.1 called for evaluating ways to assist special needs populations. The largest population
with special needs in Rolling Hills consists of seniors, including those with disabilities. The City
continues to implement programs to assist seniors with housing, transportation, emergency
preparedness, and access to social services. The policy should be carried forward. Policy 1.2
called for working with other governmental entities to explore providing affordable housing in
the South Bay region. This occurs on an ongoing basis through the city’s participation in SCAG,
communication and liaison with developers, and meetings with planners and housing
organizations on the Palos Verdes Peninsula and throughout Los Angeles County. Policy 1.3
called for encouraging energy conservation and weatherization. The City implements this policy
through its planning and building regulations, including Title 24. It also works with residents
interested in solar installation and weatherization.
Policy 1.4 expresses the City’s commitment to facilitating a variety of housing types. The City
made significant progress through its creation of the Rancho Del Mar Overlay zone, permitting
of accessory dwelling units by right, and allowance of emergency shelter and single room
occupancy dwellings. Given community context, constraints, and development costs, ADUs and
home sharing provide the best solution for meeting the needs of all income groups. Policy 1.5
recommends effective community participation. The City produces a twice-monthly newsletter
which is delivered to all households and uses its website to keep the community informed. It
has used a variety of methods, such as surveys and workshops, to involve the public. Given the
community’s small size and engaged population, there is a very high level of awareness of
housing issues and requirements. Policy 1.6 calls for the City to participate in countywide
programs to meet the needs of unsheltered residents. This continues on an ongoing basis.
2.3.2 Progress on Goal 2: Maintain and Enhance the Quality of Residential
Neighborhoods
Maintaining the city’s neighborhoods as great places to live is the fundamental purpose of the
City’s General Plan. As a built out community with extreme natural hazards and constraints, this
goal is primarily covered by the Land Use and Safety Elements. Nonetheless, it is appropriate to
include policies in the Housing Element addressing conservation of the existing housing stock,
as well as management of home alterations and additions. There are five policies in the 2013-
2021 Element, and they all remain relevant.
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Policy 2.1 is to encourage and assist in the maintenance and improvement of existing homes.
The City does this through its planning and building processes, and works closely with
homeowners to support home improvements. Policy 2.2 requires housing that complies with
building code requirements. This could be restated in the updated Element, since compliance
with the building code is required under State law. Policy 2.3 requires “compatible design” that
minimizes impacts on adjacent neighborhoods. This remains valid, but should reference the
zoning ordinance as the source of objective design standards that clarify the meaning of
“compatible design.”
Policy 2.4 calls for code enforcement to maintain housing, which is still relevant. Policy 2.5
allows for ADUs and Junior ADUs (JADUs) in all residential zones. Consistent with State law, the
City implemented regulations allowing ADUs in all zones in 2018 and amended those regulations
in 2020. The policy should be retained, as it provides the foundation for related regulations in
the Municipal Code.
2.3.3 Progress on Goal 3: Provide Housing Services to Address the Needs of the
City’s Seniors
Seniors/older adults are the predominant special needs group in Rolling Hills. The Housing
Element Needs Assessment confirms that a significant number of the city’s seniors have
disabilities, are living alone, and may have difficulty covering their housing expenses.
Policy 3.1 calls for housing reference and referral services for seniors, which is still relevant and
implemented on an ongoing basis. The Rolling Hills Community Association formed a
committee in 2014 to specifically focus on the needs of seniors. Policy 3.2 calls for more
information on shared housing, which remains valid. Policy 3.3 recommends reverse mortgage
loans for seniors with limited incomes. Given the mixed success of reverse mortgage programs,
the City should consider replacing this policy with others relating to the needs of seniors. For
instance, it could indicate that affordable senior housing be considered on the Rancho Del Mar
site. Policy 3.4 promotes opportunities for live-in care or family members who can assist
mobility-impaired or elderly residents. This remains relevant and should be carried forward.
Other policies addressing the housing needs of seniors could be considered.
2.3.4 Progress on Goal 4: Fair Housing
Goal 4 directs the city to “Promote housing opportunities for all persons regardless of race,
religion, sex, marital status, ancestry, disability status, or national origin.” The importance of this
goal has been elevated by AB 686, and it should be retained. There are four policies listed in
the Fifth Cycle Element to implement this goal.
Policy 4.1 indicates the City should “affirm a positive action posture” and enforce all applicable
laws and policies. This policy could potentially be simplified to focus on enforcement. Policy 4.2
specifically covers the needs of persons with disabilities. It should be carried forward. Policy 4.3
relates to making information on housing laws available to the community at City Hall. It is
implemented on an ongoing basis but should be clarified to include information on the City’s
website as well as City Hall. Policy 4.4 expresses a commitment to investigate alleged violations
of fair housing laws. This should be carried forward, with reference to the partner entities the
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City works with on such investigations. Additional policies on fair housing related to economic
inclusion and opportunities for lower income households should be considered.
2.3.5 Cumulative Evaluation of Effectiveness of Prior Element in Addressing Special
Housing Needs
The State Department of Housing and Community Development has requested that the City
include an “a cumulative evaluation of the effectiveness of past goals, policies, and related
actions in meeting the housing needs of special needs populations (e.g., elderly, persons with
disabilities, large households, female-headed households, farmworkers, and persons
experiencing homelessness).”
As a small city with only 640 households and a staff of six full-time employees, the City’s
capacity for providing services to special needs populations is limited. The greatest emphasis
has been on seniors, who are present in 56 percent of the city’s households and represent one-
third of the population. The City’s 5th Cycle Housing Element included a goal addressing the
needs of seniors but it did not include a more generalized goal addressing special needs
populations. This has been addressed in the 6th Cycle Element by broadening the goal to
address other special needs categories.
As noted on P. 2-3, Rolling Hills has worked effectively to meet the needs of seniors through its
partnerships with the Rolling Hills Community Association (and their Senior Committee), its
support for shared housing and ADU programs, and its code provisions allowing live-in care
providers throughout the city. Many older Rolling Hills residents have been able to age in place,
retrofit their homes, and continue living in the city as a result of these policies and programs.
The 2014-2021 Element also included a policy related to unhoused residents (Policy 1.6) and a
policy related to persons with disabilities (Policy 6.2). As noted in Chapter 3, there are no
unhoused residents in the city according to the annual “point in time” count, but Rolling Hills
continues to participate in intergovernmental meetings, forums, and councils of government
activities that recognize the regional nature of homelessness and the importance of regional
solutions. The City has also amended its codes to allow emergency shelter by right in at least
one zoning district. The City also has adopted a Reasonable Accommodation ordinance for
persons with disabilities and supports home improvements to facilitate aging in place and
access for residents with disabilities. On a cumulative basis, these measures have contributed
to the health, safety, and welfare of all Rolling Hills residents and to the quality of life and
condition of housing in the city.
Both the 2014-2021 Needs Assessment and the 2021-2029 Needs Assessment determined that
there were not significant housing needs associated with large households, female-headed
households, or farmworkers in the city.
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2.4 Implementation Status of Prior Housing Element Programs
The 2014-2021 Housing Element included 24 implementation programs. Table 2-1 below
indicates the status of each program as of October 2021. The table indicates whether the
program has been accomplished or should be carried forward, revised, or deleted.
Table 2-1: Implementation Status of 2014-2021 Housing Element Programs
Prog. Description Status
1 Prepare an annual housing progress
report
CARRY FORWARD. The City filed its annual Housing
Progress Report for 2021 on March 29, 2022 in 2020
and should continue to do so in future years.
2 Amend the Land Use Element to
permit a variety of housing types
ACCOMPLISHED. This program may be removed from
the Housing Element, as it was accomplished in March
2021. The City amended its General Plan to permit by
right multi-family development, emergency shelter, and
single room occupancy housing in the Rancho Del Mar
Overlay Zone.
3 Create an Affordable Housing
Overlay Zone (AHOZ)
ACCOMPLISHED. This program may be removed from
the Housing Element or merged with the program to
periodically evaluate the Overlay Zone and determine if
changes are needed (See Program 13). The City
adopted a 31-acre Overlay in February 2021 (known as
the Rancho Del Mar Overlay zone), allowing for by-right
development of up to 16 units of affordable multi-family
housing (20 units per acre) on the Rancho Del Mar site
on Crest Road West.
4 Determine next steps for PVUSD
housing opportunity
CARRY FORWARD. The City Manager meets with the
PVUSD Superintendent regularly to discuss issues of
concern, including the future of the PVUSD property.
Other aspects of Program 4, including meeting with
developers and providing input to parties interested in
this site, should be retained and implemented on an
ongoing basis.
5 Adopt zoning for emergency
shelter.
ACCOMPLISHED. This action was completed in
February 2021. The City permits emergency shelter up
to 12 beds by right in the Rancho Del Mar Overlay
Zoning district. A replacement program should be
included, identifying ongoing measures the City will
take to address the needs of unhoused residents.
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Prog. Description Status
6 Adopt zoning for single room
occupancy (SRO) units.
ACCOMPLISHED. This action was completed in
February 2021. The City permits SROs of 6-8 units as a
conditional use in the Rancho Del Mar Overlay Zoning
district, subject to objective operational and
performance standards.
7 Adopt a Reasonable
Accommodation Policy
ACCOMPLISHED. The City of Rolling Hills adopted a
Reasonable Accommodation policy in October 2020.
The policy establishes a formal procedure through a
which a person with disabilities may request reasonable
accommodation in order to have equal access to
housing. This program may be replaced with other
actions to assist residents with disabilities .
8 Add definitions of Transitional/
Supportive Housing and Employee
Housing to Municipal Code
CARRY FORWARD. This program has not yet been
implemented. The 2014-2021 Housing Element
clarifies that supportive and transitional housing may
not be subject to requirements or standards other than
those that apply to similar dwelling unit types in the
same zones. However, the program must still be
codified through a Municipal Code amendment.
9 Adopt density bonus requirements CARRY FORWARD. This program has not yet been
implemented. Any project including units eligible for a
density bonus would be subject to State density bonus
rules. The City should amend its Municipal Code for
consistency with these rules, and expressly identify
opportunities and rules for density bonuses.
10 Adopt and periodically update
accessory dwelling unit (ADU)
regulations
REVISE. The City adopted ADU regulations in 2018
and amended these regulations in January 2020 to
incorporate new State laws. This action should be
replaced with one or more new actions related to ADUs,
including incentives to promote their use as affordable
housing.
11 Implement ADU education,
outreach, and community
engagement measures
REVISE. The City has provided information on ADUs to
the community since 2018 and should continue to do so
in the future. Newsletter articles and web-based
information have been provided and a citywide survey
on ADUs was administered in 2020. Potential outreach
measures are listed in the 2014-2021 Element and
should be carried forward. Staff time should be
allocated to these activities to ensure they are
implemented. This includes coordination with Rolling
Hills Community Association to ensure that design
review practices do not constrain ADU production or
add to their cost. Future activities could include proto-
type floor plans and designs, FAQs, community
workshops, and tenant matching services.
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Prog. Description Status
12 Develop incentives to encourage
ADU production
REVISE. This program suggested reaching out to at
least five cities and two non-profits to develop a suite of
best practices for incentivizing ADUs. Based on the
findings, the program recommended incentives such as
fee reductions, streamlined permitting, and funding for
septic system expansion to make it easier and more
affordable to add ADUs. The City has begun
implementing this program by participating in a South
Bay Cities Council of Governments collaborative that
helps residents calculate the cost and revenue for
adding an ADU (see https://southbaycities.aducalculator.org/).
Additional measures will be considered in the future.
has not yet been implemented due to lack of staff but it
remains relevant.
13 Monitor the effectiveness of the
Affordable Housing Overlay Zone
(AHOZ) and consider future multi-
family housing opportunities
REVISE. There are two parts to this program. The first
is monitoring the effectiveness of the Rancho Del Mar
Overlay Zone to determine if it is achieving its intended
purpose. This should be retained. The second part of
the program is to evaluate other multi-family housing
opportunities. This is occurring through preparation of
the Sixth Cycle Element and should continue through
2029.
14 Assist Extremely Low Income (ELI)
households
CARRY FORWARD. This program is implemented by
facilitating housing for family members, caregivers and
domestic employees, and by assisting elder Rolling Hills
homeowners on fixed incomes with home maintenance,
home sharing, ADU construction, and other actions that
reduce housing cost burdens. The program should be
carried forward.
15 Facilitate communication with
affordable housing service
providers, developers, and
advocates
CARRY FORWARD. The program recommends
coordinating with affordable housing organizations to
facilitate housing assistance and production for lower
income households. The City implements this program
on an on-going basis and should continue to do so in
the future.
16 Provide public information on home
sharing programs
CARRY FORWARD. This program references a number
of home sharing programs in Los Angeles County and
suggests that Rolling Hills provide information about
these programs on its website and at City Hall. This is a
relatively low-cost measure that can help seniors, young
adults, and local employees find housing options in the
city. It should be retained.
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Prog. Description Status
17 Provide information about reverse
mortgages
DELETE. While reverse mortgages may be helpful for
some households, there may also be downsides
associated with high closing costs, fees, and
unfavorable repayment terms. There is also a risk of
fraud. The City may not wish to take an advocacy
position promoting reverse mortgages due to the risks
involved. Local homeowners may still consider this
option should they choose to do so. The program could
also be revised to focus on consumer protection issues
related to reverse mortgages.
18 Undertake sewer feasibility and
design studies
REVISE. This program should be updated to reflect the
current status of sewer feasibility and design studies. A
feasibility study was initiated in 2020 and design plans
are nearing completion. The updated Housing Element
program should reflect the findings of these studies, as
well as Council direction.
19 Implement Best Management
Practices to improve stormwater
REVISE. The City has continued to implement
municipal storm water management measures to
reduce urban runoff pollution. It will continue to do so
in the future as conditions and requirements change.
This program could potentially be deleted or combined
with Program 18.
20 Maintain code enforcement
procedures
REVISE. This program called for hiring a full-time Code
Enforcement Officer, which was accomplished in 2019.
There is an ongoing need for enforcement of planning
and building codes in order to conserve housing quality
and correct structural deficiencies. Violations have
been consistently abated in order to maintain public
safety and community standards. The program should
be updated and retained.
21 Encourage energy conservation CARRY FORWARD. This program continues to be
relevant and informs City actions relating to
weatherization, solar installations, and other steps to
reduce home energy costs and promote clean energy.
The program references various links on the City’s
website to energy conservation programs, and financial
assistance for home energy costs. It should be carried
forward.
22 Facilitate new construction and
remodels
CARRY FORWARD. This is a general program that
encourages the City to work with applicants, builders,
property owners, and others to produce new market
rate housing and to facilitate permits for home
improvements. It supports permit streamlining and
efficiency, and transparency in the planning and
building processes. It should be carried forward.
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Prog. Description Status
23 Explore solutions to ground stability
and landslide problems
CARRY FORWARD. The City implements this program
on an ongoing basis through requirements for soils and
geology reports, as well as grading standards and
grading permit requirements. It continues to allow and
support repair work on landslide damaged homes and
unstable hillsides. Given past damage caused by
landslides and the vulnerability of parts of the city to
future damage, this program should be retained.
Reference could also be made to programs that reduce
wildfire risk and promote defensible space.
24 Make Fair Housing information
available to the public
REVISE. This program reflects the City’s ongoing
commitment to making fair housing information
available to the public. Given HCD’s guidelines for
implementing AB 686 (Affirmatively Furthering Fair
Housing), additional fair housing programs should be
developed.
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3.0 Housing Needs Assessment
3.1 Introduction
Each community’s housing plan must be based on an analysis of local housing needs. This
analysis is expressly required by the State Government Code (Section 65583(a)), and includes a
comprehensive evaluation of local demographics, housing conditions, and market conditions.
The analysis includes an assessment of household characteristics in the city, including
household type, tenure (rent vs own), overcrowding, and percent of income spent on housing. It
also evaluates the special housing needs of older adults, persons with disabilities, large families,
and persons in need of emergency shelter.
The needs assessment helps ensure that the city is not only planning for its “fair share” of the
region’s housing needs, but also responding to its own local needs. Where appropriate, local
conditions are compared to regional conditions or conditions in nearby cities to provide
appropriate context. Rolling Hills is a very unique community and it is important to recognize
that when planning for housing conservation and production.
Most of the data presented in this chapter is from the American Community Survey (ACS), an
ongoing survey performed by the US Census to gauge population and housing conditions in
between the decennial censuses. Because most 2020 Census data was not available at the time
this report was prepared, the ACS data provides the most accurate information on local
demographics. ACS data for Rolling Hills in 2021 is based a five-year average covering 2015-
2019. However, the ACS is based on a sample of the population, so there is a margin of error in
some of the tables. Other data sources include the California Department of Finance, the
County of Los Angeles, and the City of Rolling Hills. In addition, SCAG provided a “pre-HCD
certified” data profile for each city in the Los Angeles region in 2019. This is referenced as
appropriate throughout this chapter.
The Needs Assessment is broken into five sections as follows:
• Section 3.2 covers population characteristics, such as age, race, and total rate of growth
• Section 3.3 covers household characteristics, such as presence of children and home
ownership
• Section 3.4 addresses special housing needs
• Section 3.5 covers housing stock characteristics
• Section 3.6 covers growth forecasts and the RHNA for the 2021-2029 period
The Needs Assessment is supplemented by Appendix “A”, which looks specifically at the recent
State mandate to “affirmatively further fair housing” through the Housing Element. Appendix A
focuses on regional patterns of segregation and inequity in order to inform local fair housing
policies.
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3.2 Population Characteristics
3.2.1 Total Population
Table 3.1 shows population data for Rolling Hills over a 50-year period. The City’s population
was 2,050 in 1970 and has declined by more than 300 residents since then. Between 1980 and
1990, Rolling Hills lost nearly 9 percent of its population. The decline was the result of several
factors, including smaller households, fewer children, and the loss of homes due to wildfire and
landslides. Change between 1990 and 2010 was minimal. There were 1,871 residents in 1990
and 1,860 residents in 2010. The August 12, 2021 US Census data release reported a
population of 1,739 residents, a 6.5 percent drop relative to 2010. The Census figure is
substantially lower than the Department of Finance estimate of 1,866, which was made on
January 1, 2021.
Table 3.1: Rolling Hills Population, 1970-20211
Population Percent Change
1970 2,050 --
1980 2,049 0
1990 1,871 -8.7%
2000 1,871 0
2010 1,860 -0.6%
2021 (DOF) 1,866 0.3%
2020 (Census) 1,739 -6.5%
Sources: US Decennial Census, 1970-2010. California Dept. of Finance, 1/1/21 estimate, 2020 Census (8/12/21 release)
Table 3.2 compares population change in Rolling Hills with the region, the County, and the other
cities on the Palos Verdes Peninsula using data from the California Department of Finance. The
six-county Los Angeles region grew 14.4 percent between 2000 and 2021, from 16.5 million
residents to nearly 19 million residents. Los Angeles County grew by 5.2 percent, reflecting its
more urbanized character and larger population base. By contrast, the rate of growth on the
Palos Verdes Peninsula during this 21-year period was just 1.1 percent. While Rolling Hills
Estates grew by 5.5 percent, the other three cities have roughly the same number of residents
today as they did 20 years ago. The Peninsula communities are mature, with limited vacant and
re-developable land, high land costs, and environmental constraints that limit population growth.
1 The ACS data sets for Rolling Hills for 2015-2019 show a citywide population of 1,513 residents. This is 15 percent below the
actual population, which was reported to be 1,739 residents in the 2020 Census data released on August 12, 2021. In addition,
SCAG reported the population at 1,939 residents (in 2018), while the State Department of Finance reported 1,866 residents. These
discrepancies are due to sampling errors resulting from the small size of Rolling Hills’ population. As a result, charts are used (rather
than tables) for some of the variables discussed below. This allows the analysis to focus on change over time rather than total
values.
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Table 3.2: Comparison of Rolling Hills Growth with Nearby Cities and Region, 2000-2021
Population Percent Change 2000 2021
Rolling Hills 1,871 1,866(*) -0.3
Rolling Hills Estates 7,676 8,098 5.5
Rancho Palos Verdes 41,145 41,541 0.9
Palos Verdes Estates 13,340 13,286 -0.4
Los Angeles County 9,542,000 10,044,458 5.3
SCAG Region 16,547,000 18,954,083 14.4
Sources: US Decennial Census, 2000. California Dept. of Finance, 1/1/21 estimate
(*) August 12, 2021 Census data release shows 1,739 residents, which is a 7.1 decrease since 2000
3.2.2 Age
The age structure of the population has a strong influence on housing needs. For example, if a
city is experiencing an outmigration of young adults (ages 25-34), it often indicates a shortage of
rental housing or entry-level housing opportunities. If a city has a high percentage of residents
over 75, it often indicates a need for special housing types, such as assisted living or single-
story homes---or programs to assist with home rehabilitation.
Chart 3.1 shows the age distribution of Rolling Hills residents in 2000 and 2020. The chart
illustrates significant shifts, including a decrease in the number of children (from 28% of the
population in 2000 to 20% in 2020) and an increase in the number of persons over 65 (from
22% of the population in 2000 to 33% in 2020). The percentage of residents aged 20-34 nearly
doubled over the 20-year period, likely as a result of adult children moving back home or
delaying entry into the housing market due to high housing costs. The percent of residents 35-
44 dropped significantly, likely because of limited local housing options for young families and
mid-career adults.
The median age in Rolling Hills has steadily increased over the last 40 years. In 1980, it was
38.2. It increased to 45.5 in 1990, 48 in 2000, and in 52 in 2010. By 2020, the median age was
55.3, meaning that half of all residents are older than 55 and half are 55 or younger. By
contrast, the median age in Los Angeles County is 36.5. Rolling Hills also has a higher median
age than the other cities on the Palos Verdes Peninsula (Rolling Hills Estates: 50.1; Palos Verdes
Estates: 52.2; Rancho Palos Verdes: 50.0).
Census data indicates that one-third of Rolling Hills’ residents over 65 are 80 or older. This
cohort represents more than 10 percent of the City’s population, a substantially higher share
than in most communities in California.
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Chart 3.1: Age Distribution of Rolling Hills Residents, 2000 and 2020
Source: US Census, 2000. ACS, 2021 (for 2015-2019 sample period)
Chart 3.2: Racial Distribution of Rolling Hills Residents, 2000 and 2020
Source: US Census, 2000 and ACS, 2021 (for 2015-2019 sample period)
0-19
20%
20-34
9%
35-44
4%45-54
16%
55-64
18%
65+
33%
0-19
28%
20-34
5%35-44
12%
45-54
18%
55-64
15%
65+
22%
Hispanic
(any race)
6%
White
Non-
Hispanic
70%
Multi-
racial
6%
Black
2%
Asian
15%
Other
1%
2020
2000 2020
Hispanic
(any race)
3%
White
Non-
Hispanic
80%
Multi-
racial
2%
Black
2%
Asian
13%
2000
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3.2.3 Race and Ethnicity
Racial and ethnic composition may affect housing needs due to the cultural preferences of
certain groups (including extended families, multi-generational families, etc). In addition, certain
groups have historically faced discrimination due to the lending policies of financial institutions,
former covenants and ownership restrictions, and past racial bias.
Chart 3.2 shows the racial distribution of Rolling Hills residents in 2000 and 2020. The city has
become more diverse over time, with the Non-Hispanic White population declining from 80
percent to 70 percent of the total. The Hispanic population (any race) roughly doubled over the
20-year period, although relative to the total population, the numbers are still small.
Approximately 6 percent of the City’s residents are Hispanic.
The percentage of African-American residents remained at about 2 percent of the population
between 2000 and 2020. During this same period, the number of residents of Asian or Pacific
Island descent increased from 13 percent to 16 percent of the city’s total. According to the
Census, the largest Asian ethnic groups in the city are Chinese (6.5 percent) and Korean (5.1
percent). The number of residents indicating they were more than one race more than doubled
between 2000 and 2020, with multi-racial residents representing about 6 percent of the 2020
population.
Relative to the County of Los Angeles and the State of California, Rolling Hills and the four cities
on the Palos Verdes Peninsula have a substantially higher White Non-Hispanic population.
Table 3.3 compares race and ethnicity in Rolling Hills, the Peninsula cities, Los Angeles County,
and the State as a whole. Nearly half of the County’s residents, and more than one-third of the
State’s residents, are Hispanic. By contrast, less than 10 percent of the residents in the
Peninsula cities are Hispanic. The Peninsula cities tend to have higher percentages of Asian
and Pacific Islander residents, and more multi-racial residents.
Table 3.3: Race and Ethnicity in Rolling Hills, Peninsula Cities, Los Angeles County, and
State, 2020
Percent of Total
Rolling Hills Palos Verdes
Peninsula*
Los Angeles
County
State of
California
Non-Hispanic White 71.3% 54.4% 26.2% 37.2%
Hispanic (all races) 5.8% 9.7% 48.5% 39.0%
Black/ African American 1.5% 1.6% 7.8% 5.5%
Native American/Alaskan N/A 0.1% 0.2% 0.4%
Asian 15.6% 28.8% 14.4% 14.3%
Pacific Islander/Hawaiian N/A 0.6% 0.2% 0.4%
Other N/A 0.1% 0.3% 0.3%
Multi-Racial 5.8% 4.7% 2.3% 3.0%
TOTAL 100.0% 100.0% 100.0% 100.0%
Sources: US Decennial Census, 2020.
(*) Rolling Hills, Rolling Hills Estates, Rancho Palos Verdes, Palos Verdes Estates
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The August 2021 release of 2020 Census data shows that the ACS may have underestimated
the diversity of Rolling Hills’ population. The 2020 Census indicated that 66 percent of the city’s
residents are White, 20.5 percent are Asian, 10.4 percent are more than one race, 1.3 percent
are Black, and 1.9 percent are Other. The Census further indicated that 7.0 percent of the city’s
residents were Hispanic (includes all races).
3.2.4 Language
Based on ACS data for 2015-2019, 79 percent of the City’s residents speak only English at
home.2 Of the roughly 300 Rolling Hills residents speaking a language other than English at
home, 18 percent speak Spanish, 56 percent speak an Asian language, and 26 percent speak
another Indo-European language. Most of these residents are bilingual and are fluent in English.
About 66 percent of those speaking a foreign language at home indicated they also spoke
English “very well.” Of the remaining 34 percent, about half spoke an Asian language. Korean
and Chinese were the most commonly spoken languages in those households.
Relative to other cities in Los Angeles County and the region, the percentage of “linguistically
isolated” persons (i.e., those with limited English) is very low in Rolling Hills. Whereas about 6
percent of Rolling Hills’ population is linguistically isolated, the percentage in Los Angeles
County is about 24 percent.
3.2.5 Educational Attainment
Rolling Hills residents are highly educated. Among residents 25 or older, 97.6 percent have a
high school degree. More than 70 percent have a bachelor’s degree or higher, and 39 percent
have a graduate or professional degree. These percentages are substantially higher than in the
County as a whole.
3.2.6 Health Indicators
Health can impact housing needs both by limiting the income earning potential of residents and
by creating the need for supportive services or special housing design. Based on data provided
to the City by the Southern California Association of Governments, Rolling Hills health indicators
are consistently better than the County as a whole. The City’s obesity rate is 16.5 percent,
compared to a countywide average of 28.2 percent. Its asthma rate is 10.1 percent, compared
to the countywide average of 15.1 percent and its diabetes rate is 8.3 percent, compared to 12.1
percent countywide. On the other hand, Rolling Hills has a higher rate of heart disease than the
County as a whole, with 9.7 percent of the population diagnosed with a heart ailment compared
to 6.6 percent countywide. This is likely due to the higher percentage of older residents in the
city.
2 American Community Survey 2015-2019, based on residents 5 years of age or older.
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3.2.7 Employment
Employment affects the demand for housing and the dynamics of the housing market. In most
cities, the types of jobs that are present affect the wages paid and the ability of the local
workforce to pay for housing in the city. Rolling Hills is unique in this regard, as it has no major
employers or land zoned for employment uses. In 2018, the Southern California Association of
Governments estimated that there were only 110 jobs in the city.3 Employers include the City,
the School District, Rolling Hills Community Association, the County Fire Department, and the
Palos Verdes Transit Authority. The figure excludes construction workers, landscapers,
housekeepers, child care providers, care givers, delivery workers, and others who travel to the
city intermittently for work.
Data from SCAG collected prior to the COVID-19 pandemic indicates that a majority of
employed residents in Rolling Hills commuted to jobs elsewhere in Los Angeles County. The
largest percentages of residents commuted to Los Angeles (28.2%), Torrance (8.3%), and Long
Beach (5.0%). Beyond Los Angeles County, the next largest commute destination was Orange
County, including Anaheim (1.5%) and Huntington Beach (1.5%).
A relatively large percentage of Rolling Hills residents work from home. Prior to the COVID-19
pandemic, census data reported that about 18 percent of the city’s employed residents worked
from their homes. While data after March 2020 is not available, the percentage likely increased
dramatically during the second quarter of 2020 and remained high for the rest of the year. The
long-term effects of the pandemic on commute patterns are still unknown. However, the
relatively large home sizes in Rolling Hills and the high percentage of the workforce in
professional-sector jobs suggests that a substantial number of workers will continue to work
remotely in the future.
Recent data from the California Employment Development Department (EDD) indicates there
are 600 Rolling Hills residents in the labor force. EDD indicates an unemployment rate of 9.3
percent in June 2021, compared to a countywide average of 10.5 percent. The average annual
unemployment rate in Rolling Hills was reported as 4.0 percent in 2019, when the countywide
average was 4.4 percent. 4
Tables 3.4 and 3.5 provides an overview of the Rolling Hills labor force, based on census data.
The first table identifies the occupation of residents in the city by category, and the second
classifies employed residents by industry.
A majority of the city’s residents are in higher-wage professional and management occupations.
Approximately 18 percent work in health care. About 13 percent work in education, legal
services, arts, and media. Only a small percentage work in the service sector, and even smaller
percentages work in the construction, maintenance, and transportation sectors. The largest
economic sectors associated with the Rolling Hills workforce are finance, insurance, real estate,
health care, and professional, scientific, and management services. The percentage of residents
employed in retail sales, wholesaling, and manufacturing is much smaller than in the county as a
whole.
3 Based on data from the California Employment Development Department
4 California EDD “Labor Force and Unemployment Rate for Cities and Census Designated Places” accessed July 2021
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Table 3.4: Rolling Hills Employed Residents by Occupation
Number of
Residents
Employed
Percent of
Total
Management, business, and financial services occupations 185 32.9%
Computer, engineering, and science occupations 39 6.9%
Education, legal, community service, arts, and media occupations 72 12.8%
Healthcare practitioners and technical occupations 104 18.5%
Service occupations 24 4.3%
Sales and office occupations 115 20.4%
Natural resources, construction, and maintenance occupations 22 3.9%
Production, transportation, and material moving occupations 2 0.4%
TOTAL 563 100.0%
Sources: American Community Survey, 2021 (2015-2019 characteristics)
Table 3.5: Rolling Hills Employed Residents by Industry
Number of
Residents
Employed
Percent of
Total
Construction 24 4.3%
Manufacturing 29 5.2%
Wholesale trade 43 7.6%
Retail trade 30 5.3%
Transport/ warehousing/ utilities 4 0.7%
Information 12 2.1%
Finance/ insurance/ real estate 132 23.4%
Professional, scientific, and management, and administrative and
waste management services 85 15.1%
Educational services, and health care and social assistance 146 25.9%
Arts, entertainment, and recreation, and accommodation and food
services 39 6.9%
Other services, except public administration 12 2.1%
Public Administration 7 1.2%
TOTAL 563 100.0%
Sources: American Community Survey, 2021 (2015-2019 characteristics)
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There are approximately six times more employed residents in Rolling Hills than jobs in Rolling
Hills. The City is not expected to become an employment center in the future. Rolling Hills is
currently a housing “reservoir” in that it provides far more housing than employment relative to
other cities in Los Angeles County. Nearby communities with large employment bases rely on
Rolling Hills to some extent to meet their housing needs, particularly at the upper range of the
housing market.
3.3 Household Characteristics
The Bureau of the Census defines a "household" as “all persons who occupy a housing unit.
This may include persons living alone, families related through marriage or blood, and unrelated
individuals living together. Persons living in retirement or convalescent homes, dormitories, or
other group living situations are classified as living in “group quarters” and are not considered
households. On the other hand, a property with an occupied accessory dwelling unit may be
considered to consist of two households.
Household characteristics provide important indicators of housing needs. These characteristics
include household structure (families with and without children, single persons, persons sharing
homes, etc.), household size (number of persons per household), tenure (renter vs owner), and
household income and poverty status. Again, the US Census 2021 American Community
Survey (providing sample data for 2015-2019) is regarded as the definitive source for household
data and is referenced in the tables and narrative below. At the time this report was prepared,
2020 Census data for households (other than total number of households) was not yet available.
3.3.1 Household Type
Census data for Rolling Hills indicates that there is no group quarters population in the city and
that all residents reside in households. Data from the California Department of Finance for
January 1, 2021 indicates that there were 667 households in Rolling Hills, an increase of four
households from the 2010 Census. The August 2021 release of US 2020 Census data indicates
that there are 639 households in the city, which is a decrease of 24 households from 2010. The
US Census data is considered more accurate, as it is based on an actual count and not an
estimate.
Just over 81 percent of all households in Rolling Hills are classified as families. This percentage
remained constant between 2010 and 2020. Non-family households include persons living
alone and unrelated persons living in shared homes.
Chart 3.3 shows the distribution of households by category for Rolling Hills and the County of
Los Angeles. Relative to the County, Rolling Hills has a much higher percentage of married
couple families (74% of all households compared to 45% countywide). The City has smaller
percentages of single parent households and non-married couple households than the County
and the other cities on the Palos Verdes Peninsula. A much smaller share of Rolling Hills’
residents live alone than in the County as a whole.
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Chart 3.3: Household Type in Rolling Hills and Los Angeles County, 2021
Source: American Community Survey, 2021 (2015-2019 data)
The data for Rolling Hills reflects the community’s single family housing stock. For decades, the
city has attracted families with children. Couples tend to keep their homes when their children
are grown, resulting in a significant number of homes (more than half) occupied by older
couples with adult children and empty nesters. In fact, the Census indicates that 60 percent of
the married couple households in Rolling Hills include at one person over 60 years old,
compared to 38 percent in the county as a whole.
Household type in Rolling Hills has changed over the last 20 years. The percentage of people
living alone has been increasing, growing from 12 percent of the population in 2000 to 16
percent in 2020. The percentage of households with children living at home has been
decreasing. It was 33 percent in 2000 and 23 percent in 2020.
3.3.2 Household Size
In 2020, the State Department of Finance reported the average household size in Rolling Hills as
2.80 persons. This is almost the same as it was in 2010, when average household size was
reported at 2.81 persons. In general, average household size has been falling over time. It was
2.90 in 2000 and was reported as being 3.2 in the Rolling Hills General Plan (1989). Preliminary
releases from the US Census (August 2021) show actual household size has fallen even further,
and is now 2.72.
ACS data indicates that 16 percent of all households in the City are comprised of one person, 52
percent have two people, 10 percent have three people, and 21 percent have four or more
people. By contrast, in Los Angeles County as a whole, 26 percent are comprised of one
person, 28 percent of two persons, 17 percent of three persons, and 29 percent of four or more
Married w/
children
under 18 at
home
22%
Married, no children
<18 at home
52%
Single
parent, w/
children < 18
at home
1%
Non-
married
couples
2%
Living
alone
16%
Other
7%
Married w/
children
under 18 at
home
19%
Married, no children
<18 at home
26%
Single parent, w/
children < 18 at home
6%
Non-
married
couples
7%
Living
alone
26%
Other
16%
City of Rolling Hills County of Los Angeles
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persons. Rolling Hills has a much higher share of two-person households and smaller shares of
one-person households and large households.
Chart 3.4 compares average household size in Rolling Hills, the County, the State and the other
three cities on the Palos Verdes Peninsula. Data is shown for 2010 and 2021 for each city,
based on California Department of Finance statistics.
Chart 3.4: Household Size in Rolling Hills and Other Jurisdictions, 2010 and 2021
Source: California Department of Finance, Table E-5, 2021
3.3.3 Overcrowding
Overcrowding may result when high housing costs prevent households from buying or renting
homes that provide sufficient space for their needs. The Census defines overcrowded
households as those with more than 1.01 persons per room, excluding bathrooms, hallways, and
porches. Households are considered to be “severely” overcrowded if they have more than 1.51
persons per room.
Although Rolling Hills has a higher number of persons per household than the other cities on the
Palos Verdes Peninsula, it does not experience overcrowding. ACS data for 2015-2019 indicate
that 98.9 percent of the homes in the city have 1.0 persons per room of less. There are no
households with more than 1.51 persons per room. By contrast, in the county at large, 11.3
percent of the households have more than 1.01 persons per room and 4.7 percent have more
than 1.51 persons per room. Homes in Rolling Hills are generally large and owner-occupied,
reducing the likelihood of future overcrowding.
2.4
2.5
2.6
2.7
2.8
2.9
3
3.1
Rolling Hills LA County California Rolling Hills
Estates
Rancho Palos
Verdes
Palos Verdes
Estates
2010 2021
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3.3.4 Tenure
Tenure refers to a household’s status as an owner or renter. ACS data for 2015-2019 indicate
that 95.3 percent of Rolling Hills’ households are homeowners and 4.7 percent are renters. This
percentage has remained relatively constant over the last two decades. The 2010 Census
indicated that 95.7 percent of the city’s households were homeowners and that 4.3 percent
were renters. This equated to 28 renter households in the entire city. Because there are no
multi-family units at this time, these households are presumed to be renting single family homes.
Renter households in the city are slightly larger than owner-occupied households. The ACS
data for 2015-2019 indicates an average household size of 3.07 for renters and 2.60 for owners.
3.3.5 Household Income
Income is the single most important factor in determining housing affordability. While upper
income households have more discretionary income to spend on housing, lower income
households are more constrained in what they can afford. The State and federal government
have developed metrics for classifying households into income categories. These metrics are
used to quantify what is considered an “affordable” housing unit and to determine eligibility for
housing subsidies and assistance programs. All metrics are benchmarked against the areawide
median income, or AMI.
State-Defined Income Categories
The commonly used income categories are as follows:
• Extremely low income 0-30% of AMI
• Very low income 30% to 50% of AMI
• Low income 50% to 80% of AMI
• Moderate income 80% to 120% of AMI
• Above Moderate income More than 120% of AMI
“Affordable housing cost” is defined by State law as being not more than 30 percent of gross
household income. “Housing cost” in this context includes rent or mortgage payments, utilities,
property taxes, and homeowners (or renters) insurance. The income limits are updated annually
by the California Department of Housing and Community Development.
For each income category, a sliding scale is used based on the number of persons per
household. This recognizes that larger households must dedicate greater shares of their
income for food, health care, transportation, and other expenses. The income categories are
calculated by county, resulting in different median incomes from place to place within California.
Table 3.6 shows income categories for Los Angeles County that became effective in April 2021.
A two-person household earning less than $75,700 a year would be considered low income.
The same household would be considered very low income if it earned less than $47,300 a year.
For a household of four people, the threshold is $94,600 for low income and $59,100 for very
low income.
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Table 3.6: Income Limits for Los Angeles County, 20215
Income Category
Household Size
1 2 3 4 5 6 7 8
Extremely Low Income $24,850 $28,400 $31,950 $35,450 $38,300 $41,150 $44,000 $46800
Very Low Income $41,400 $47,300 $53,200 $59,100 $63,850 $68,600 $73,300 $78,050
Low Income $66,250 $75,700 $85,150 $94,600 $102,200 $109,750 $117,350 $124,900
Moderate Income $67,200 $76,800 $86,400 $96,000 $103,700 $111,350 $119,050 $126,700
Source: California Department of Housing and Community Development, 2021
Table 3.7 indicates the monthly housing cost that would be considered “affordable” for
households of different sizes in each income category. Using the state’s definition of
affordability, a low income household of four would be able to afford a monthly housing cost of
$2,365. A very low income household of four could afford a monthly housing cost of $1,478. If
these households are pay in excess of this amount, they are considered to be “cost-burdened.”
In a high-priced market like the Palos Verdes Peninsula, many low income households pay
significantly more than 30 percent of their incomes on rent or mortgages. Those employed in
low-wage professions in the area may commute long distances from areas with more affordable
housing.
Table 3.7: Affordable Monthly Housing Costs Based on 2021 Income Limits
Income Category
Household Size
1 2 3 4 5 6 7 8
Extremely Low Income $621 $710 $799 $886 $958 $1,029 $1,100 $1,170
Very Low Income $1,035 $1,183 $1,330 $1,478 $1,596 $1,715 $1,833 $1,951
Low Income $1,656 $1,893 $2,129 $2,365 $2,555 $2,744 $2,934 $3,123
Moderate Income $1,680 $1,920 $2,160 $2,400 $2,593 $2,784 $2,976 $3,168
Source: Barry Miller Consulting, 2021. Based on 30% of monthly income for each household
Market-rate ownership housing in the Los Angeles area is generally not affordable to
households who are moderate income or below. With an income of $100,000, a household of
four could potentially spend $2,500 a month on their housing cost without experiencing a cost-
burden. Assuming a 10 percent down-payment and 3 percent interest rate, an “affordable”
home would be about $360,000. While there are a few condominiums at this price point in the
region’s larger cities (Long Beach, Los Angeles, etc.), there is no housing on the Palos Verdes
Peninsula in this range. Consequently, “below market” housing programs typically focus on
rental housing for low and very low income households, and a mix of subsidized ownership
housing and rental housing for moderate income households.
5 Income limits for low, very low, and extremely low income are set by the federal Department of Housing and Urban Development.
However, income limits for moderate income households are set by HCD based on mathematical averages of County income.
Consequently, the moderate income numbers are only marginally different from the low income numbers in Los Angeles County.
This is not the case in all counties.
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Some market-rate rental units are “affordable by design”—meaning they are not subsidized but
have rental prices that fall within the affordability ranges of low and moderate income
households. For example, a one-bedroom apartment renting for $1,700 a month would be
considered affordable to a two-person low-income household. While the supply of such units is
limited on the Palos Verdes Peninsula, there are opportunities for market-rate accessory
dwellings and small apartments to fill some of this need.
Household Income in Rolling Hills
The federal Department of Housing and Urban Development (HUD) receives custom tabulations
of Census data each year to evaluate housing needs for lower income households. The data is
referred to as “CHAS” (Comprehensive Housing Affordability Strategy) data and includes
documentation of the current number of owner and renter households in each HUD income
category for each jurisdiction. At the time the 2021-2029 Housing Element was prepared the
CHAS data set was based on 2013-2017 conditions. Table 3.8 provides CHAS data for the City
of Rolling Hills.
Table 3.8: Rolling Hills Households by HUD Income Category
Income Category Owners Renters Total (*)
Extremely Low 25 0 25
Very Low 35 10 45
Low 45 0 45
Moderate 25 0 25
Above Moderate 465 15 480
Total 595 25 620
Source: HUD User Portal CHAS data, based on 2013-2017 ACS. Accessed July 2021
(*) Total number of households does not match Census and DOF totals due to sampling methods. CHAS data is also rounded to the
nearest “five” by HUD.
Table 3.8 indicates that 77 percent of the households in Rolling Hills are “above moderate”
income (more than 120% of Areawide Median Income). There are 25 “extremely low” income
households and 45 “very low” income households in the city, representing four percent and
seven percent of total households respectively. Another seven percent meet “low” income
criteria.
Table 3.9 provides additional data on income in Rolling Hills, using 2015-2019 American
Community Survey data rather than CHAS data. Rolling Hills is among the most affluent cities in
California, with a median income exceeding $250,000 a year, and a mean household income of
$434,685. The Census indicates that 57.5 percent of the city’s households have annual incomes
exceeding $200,000, compared to 37.8 percent for all of the Palos Verdes Peninsula cities and
10.2 percent for Los Angeles County.
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Table 3.9: Household Income in Rolling Hills, Peninsula Cities, and Los Angeles County
Income Category
Percent of Households in Income Category
Rolling Hills
Palos Verdes
Peninsula Cities Los Angeles County
Less than $10,000 1.2% 3.0% 5.6%
$10,000-$14,999 2.6% 1.6% 4.8%
$15,000-$24,999 2.6% 3.4% 8.4%
$25,000-$34,999 1.2% 3.4% 8.1%
$35,000-$49,999 6.1% 4.7% 11.2%
$50,000-$74,999 3.8% 9.2% 15.9%
$75,000-$99,999 4.2% 9.0% 12.3%
$100,000-$149,999 12.7% 15.5% 15.8%
$150,000-$199,999 8.1% 12.6% 7.8%
$200,000 or more 57.5% 37.8% 10.2%
Median Income $250,000+ $154,165 $68,044
Mean Income $434,685 $210,231 $99,133
Source: American Community Survey, 2021 (for 2015-2019)
Data for Palos Verdes Peninsula cities represents weighted average of Rolling Hills, Rolling Hills Estates, Rancho Palos Verdes, and
Palos Verdes Estates
While a majority of households are “above moderate” income, the ACS data indicates that 6.4
percent of Rolling Hills’ households (or approximately 42 households) have annual incomes of
less than $25,000 a year. This compares to 8.0 percent for the Palos Verdes Peninsula and 18.8
percent for Los Angeles County. Approximately 7.3 percent of Rolling Hills’ households have
incomes between $25,000 and $50,000 a year, compared to 8.1 percent on the Peninsula and
19.3 percent countywide.
The Census also disaggregates household income data by family households, married couples,
and non-family households. Non-family households include persons living alone and unrelated
individuals in shared homes. Family and married couple household incomes in Rolling Hills are
higher than non-family households. Census data indicate that 27 percent of the non-family
households in the city (or about 30 households) have annual incomes below $35,000 compared
to just 3.1 percent for families and married couples.
An important qualifier about the Census income data is that it does not account for accumulated
wealth or savings and is based only on annual income. Given the high cost of housing in Rolling
Hills, the very high rate of owner-occupancy (95 percent), and the large number of retired adults
in the city, it is likely that most of the lower income households in the city are seniors on fixed
incomes. In fact, 68 of the 108 non-family households in the city are comprised of persons over
65 living alone. Many of these households have no mortgage and their housing costs are
primarily associated with property taxes, insurance, maintenance, and utilities. Despite
accumulated wealth and home equity, a subset of the population on fixed incomes may lack the
resources to meet these expenses without financial hardship.
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3.3.6 Overpayment
Overpayment refers to the incidence of households spending more than 30 percent of their
incomes on housing costs. As noted earlier, this includes monthly utility bills, taxes, HOA dues,
and insurance as well as mortgage or rent payments. Overpayment occurs in all income
categories but is more challenging for lower income households given the limited resources to
pay for other household expenses. As previously indicated, such households are defined by the
US Department of Housing and Urban Development as being “cost-burdened.”
ACS data indicates that 30.6 percent of all homeowners in Rolling Hills and 32 percent of all
renters are paying more than 30 percent of their incomes on housing. About 18 percent of
Rolling Hills homeowners are paying more than 50 percent of their incomes on housing. This
compares to 16 percent in the county as a whole. Table 3.10 compares rates of overpayment in
Rolling Hills with those of Los Angeles County as a whole. At the countywide level, the rate of
overpayment is somewhat higher for homeowners and substantially higher for renters. In Los
Angeles County, approximately 35.7 percent of all homeowners and 57.6 percent of all renters
pay more than 30 percent of their incomes on housing.
Table 3.10: Percent of Income Spent on Housing in Rolling Hills and Los Angeles County
Percent of
Income Spent
on Housing
Homeowners with no
Mortgage
Homeowners with a
Mortgage Renters
Rolling
Hills
LA
County
Rolling
Hills
LA
County
Rolling
Hills
LA
County
Less than 20 % 64.3% 73.4% 37.1% 30.0% 54.5% 19.7%
20-24.9 % 10.5% 6.4% 10.1% 14.5% 0 11.5%
25-29.9% 5.0% 4.2% 14.0% 12.1% 13.6% 11.2%
30-34.9% 0.8% 3.0% 7.8% 9.1% 0 9.5%
More than 35% 19.3% 12.9% 30.9% 34.4% 31.8% 48.1%
Source: American Community Survey, 2021 (for 2015-2019)
Not surprisingly, the incidence of overpayment is much greater for homeowners with a
mortgage than for those without a mortgage. In Rolling Hills, approximately 44 percent of all
homeowners have paid off their mortgages, while 56 percent have a mortgage. For those
without mortgages, 20.1 percent pay more than 30 percent of their incomes on housing. For
those with mortgages, the figure is 38.6 percent.
Even homeowners without mortgages may still face a cost burden associated with taxes,
maintenance, and other home expenses. The ACS reports that 93 percent of Rolling Hills’
homeowners with no mortgage payments still have monthly housing costs exceeding $1,000 a
month. The median monthly cost for homeowners without mortgages in the city is over $1,500 a
month. The comparable figures for Los Angeles County are just 20.3 percent and $608 a
month. The data suggests that Rolling Hills seniors on fixed incomes may be particularly cost-
burdened due to limited income, monthly HOA fees, and the high cost of maintaining a home in
the city.
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For homeowners with mortgages, monthly costs are substantially higher. ACS data shows that
89.9 percent of the city’s homeowners with mortgages spend over $3,000 a month on housing,
with a median well above $4,000 a month (the maximum reported by the Census). This
compares to 34.2 percent in Los Angeles County, with monthly median of $2,498.
Data on the City’s renter households indicates that a majority are above moderate income
households spending more than $3,000 a month on housing. However, the ACS indicates
seven renter households paying $1,000 to $1,499 a month, which indicates that at least a few
renters in the city occupy guest houses or unregistered accessory dwelling units.
Table 3.11 shows the incidence of overpayment among owners and renters in Rolling Hills who
are lower income. Among lower income homeowners, 78 out of 90 are considered cost-
burdened, while among the city’s 10 lower income renters, eight are considered cost-burdened.
About two-thirds of the city’s lower income owners are severely cost-burdened, paying more
than half of their incomes on housing. While the income data does not fully account for savings
and accrued wealth, it does suggest that some of these households might benefit from
assistance with home maintenance and monthly housing expenses (for example, through home
sharing and ADUs).
Table 3.11: Overpayment among Lower Income Households in Rolling Hills
Total
Households
Number Paying More than
30% of Income on Housing
Number Paying More than
50% of Income on Housing
Homeowners
Income Under 80%
of Areawide Median
90 78 60
Income Under 30%
of Areawide Median
25 19 15
Renters
Income Under 80%
of Areawide Median
10 8 4
Income Under 30%
of Areawide Median
0 0 0
Source: HUD User CHAS data, 2014-2018
3.4 Populations with Special Needs
The California Government Code recognizes that some segments of the population have more
difficulty finding decent, affordable housing than others due to their circumstances. Populations
with special needs include older adults, persons with disabilities, large families, farmworkers,
families with female heads of households, and persons experiencing (or at risk of)
homelessness. These groups are more likely than the population at large to spend a
disproportionate amount of their incomes on housing. They are also more likely to face
discrimination based on their specific needs or circumstances.
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3.4.1 Older Adults
The special needs of older households result from limited income, higher rates of physical
disability and health care costs, and changing life circumstances which may require assistance
from others. This is the single largest special needs group in Rolling Hills, and it is growing
rapidly as the population ages. Table 3.121 compares the number of older adults in Rolling Hills
with the other cities on the Palos Verdes Peninsula, along with Los Angeles County.
Table 3.112: Older Adults in Rolling Hills and Nearby Jurisdictions
Jurisdiction
Percent of all
Residents over 65
Percent of all
Residents over 75
Percent of households
with at least one
member over 65
Rolling Hills 32.9% 18.4% 56.0%
Rolling Hills Estates 25.2% 13.9% 46.5%
Palos Verdes Estates 27.0% 13.3% 46.8%
Rancho Palos Verdes 15.5% 13.6% 44.7%
Los Angeles County 13.3% 5.7% 29.7%
California 14.0% 5.9% 30.8%
Source: American Community Survey, 2021 (for 2015-2019)
The percentage of residents over 65 in Rolling Hills was 22 percent in 2000, 28 percent in 2010,
and 33 percent in 2020. Moreover, 56 percent of the households in Rolling Hills include at least
one person who is 65 years or older. This is almost double the rate for Los Angeles County as a
whole. The percentage of Rolling Hills residents over 85 has doubled in the last 20 years, with
this cohort representing 4.7 percent of the population in 2020.
The percentage of older residents is likely to continue increasing in the next decade. Nearly one
in five Rolling Hills residents is in the 55-64 age cohort (compared to one in nine countywide),
and most of this cohort will reach retirement age during the timeframe of this Housing Element.
Some of these residents, as well as those already over 65, may seek to “downsize” or adapt
their homes to meet changing mobility needs and financial resources.
Older adults in Rolling Hills are more likely to live alone, have one or more disabilities, and be
cost-burned by housing than the population at large. Census data indicates that there are 68
households, representing roughly 10 percent of all households in Rolling Hills, comprised of a
person over 65 living alone. About 70 percent are female-headed households and 30 percent
are male-headed. There may be opportunities among these households for home sharing and
accessory dwelling unit (ADU) development. This can provide financial benefits, social benefits,
and an added sense of security, as well as housing opportunities for low- and moderate-income
workers or other retirees in the community.
At the same time, the City should anticipate an increase in homeowners seeking to adapt their
homes to facilitate aging in place. This would include addition of ramps, handrails, kitchen and
bath retrofits, and interior changes that improve access for wheelchairs and walkers. The
Rolling Hills housing stock is well suited for these improvements, as it is limited to single story
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construction. Demand for on-site caregiver quarters, and living space for other domestic
employees, will likely increase. At the same time, the substantial cost and demand associated
with maintaining a large home and property may compel some residents to seek living
arrangements that are not currently available in Rolling Hills, such as condominiums and
townhomes. Some of these residents will relocate out of Rolling Hills due to diminished mobility
(capacity to drive) or the need for higher levels of care.
Because of resource limitations and the city’s small size, the City of Rolling Hills does not
provide direct services to seniors. It works with other agencies, non-profits, and the private
sector to address the housing needs of local seniors, and to connect residents with service
providers. This includes maintaining a comprehensive list of facilities and service providers at
City Hall, and a dedicated page on the City’s website listing available services for seniors.
Rolling Hills has partnered with other Peninsula cities and local non-profits to produce a Senior
Resources Guide for the Palos Verdes Peninsula.
Nearby local services include:
• Palos Verdes Peninsula Village, located in Rolling Hills Estates, provides social and
educational activities, transportation, and advocacy for seniors in the vicinity. They
provide trained volunteers to assist with routine home maintenance activities, computer
troubleshooting and set-up, and other day to day activities.
• PV Peninsula Transit Authority Dial-A-Ride, which provides services for persons 62 or
older on the Peninsula, and free taxis for medical appointments in the South Bay area.
• Peninsula Seniors, a non-profit 501(c)(3) that has served the four cities on the Palos
Verdes Peninsula (including Rolling Hills) since 1982. They primarily provide social
activities, health and wellness programs, special events, and educational programs.
• Volunteer block captains within Rolling Hills, providing wellness checks for seniors as
well as emergency preparedness and response.
• Homeshare South Bay matches seniors and others in the community with local housing
opportunities. Homeshare South Bay is a project of the South Bay Cities Council of
Governments, which includes Rolling Hills.
• HELP (Health Care and Elder Law Programs) is a Torrance-based organization that
provides counseling to area seniors on elder care, finance, law, and consumer
protection. The organization is dedicated to empowering older adults and their families.
• Palos Verdes Peninsula Library District and the Peninsula Center Library (in Rolling Hills
Estates) provides programs and resources for seniors.
• There are senior centers in the nearby communities of Torrance, Carson, Wilmington,
Harbor City, San Pedro, Manhattan Beach, Redondo Beach, Hawthorne, and El
Segundo.
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In addition, the Rolling Hills Community Association (RHCA) created a “Needs of Seniors”
Committee in 2014 to address the needs of aging Rolling Hills residents. The Committee
collects information and makes recommendations to the RHCA Board. Their recent efforts have
focused on transportation, health and wellness, home improvement and maintenance, and social
events.
3.4.2 Persons with Disabilities
The number of disabled residents is increasing nationwide due to increased longevity and the
aging of the population. Physical and mental disabilities can hinder access to housing as well as
the income needed to pay for housing. Those with disabilities often have special housing needs
related to their limited earning capacity, higher health care costs, mobility or self-care limitations,
or need for supportive services.
The Census recognizes six disability types in its data tabulation: hearing, vision, cognitive,
ambulatory, self-care, and independent living. These categories are not mutually exclusive and
disabled residents may have more than one of these conditions. Current ACS data (2015-2019)
for Rolling Hills indicates that 10.6 percent of the City’s population has one or more disabilities.
This compares to 8.1 percent in the 2000 Census, with the increase attributable to the greater
number of older adults. Rolling Hills has a slightly higher percentage of disabled residents than
the county as a whole, with the ACS reporting that 9.9 percent of Los Angeles County’s
residents were disabled in 2020.
The city’s older residents are more likely to be disabled than its younger residents. ACS data
shows 23 percent of all residents over 65 have one or more disabilities, whereas only 5.5
percent of those aged 18-64 have one or more disabilities and only 1.4 percent of those under
18 have disabilities. The “over 75” population has the greatest incidence of disability, with 33.8
percent affected.
Table 3.132 shows the incidence of disabilities among persons in different age groups in Rolling
Hills. The most common disabilities are ambulatory (movement), with older adults most
impacted. There were 103 residents reporting an ambulatory difficulty, 66 of whom were over
75. There were 56 residents reporting a hearing difficulty, 46 of whom were over 75. Cognitive
difficulties were more likely to affect the younger population (particularly 18-34). This was the
only category where rates among older adults were lower than among younger age cohorts.
Table 3.123: Percent of Rolling Hills’ Residents with a Disability
Disability Type Under 18 18-64 Over 65 Total
Hearing Difficulty 0 1.0% 10.0% 3.7%
Vision Difficulty 0 1.0% 2.6% 1.3%
Cognitive Difficulty 1.5% 2.3% 2.0% 2.1%
Ambulatory Difficulty 0 2.9% 16.5% 6.9%
Self-care Difficulty 0 0.5% 6.0% 2.3%
Independent Living Difficulty N/A 2.3% 8.8% 5.0%
Source: American Community Survey, 2021 (for 2015-2019)
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There were 61 residents, including 34 residents over 75 and another 11 aged 65-74, who
indicated an independent living difficulty. This represents roughly 5 percent of the City’s
population and is comparable to the countywide average of 5.4 percent. These residents may
require daily assistance from caregivers or family members.
There is an ongoing need to adapt housing to meet the needs of those with disabilities, and to
design new homes so they are accessible for all people. This may require widened doorways
and hallways, access ramps, larger bathrooms, lowered countertops, grab bars, walk-in baths
and showers, and other design changes. It is important that planning and building codes
support such changes, and accommodate the needs of those who are disabled or become
disabled while living in the homes they currently occupy. Barrier free design is particularly
important in any multi-family housing that may be constructed in the future.
In 2020, the City of Rolling Hills amended its municipal code to provide “reasonable
accommodation” for persons with disabilities. This complies with state and federal laws and
enables those with disabilities to request modifications from standard practices or codes to meet
their housing needs.
3.4.3 Persons with Developmental Disabilities
SB 812 requires that each jurisdiction’s housing element include an analysis of housing needs
for persons with developmental disabilities. This is defined by federal law as a “severe, chronic
disability” that:
• Is attributable to a mental of physical impairment or combination of mental and physical
impairments
• Is manifested before the individual attains age 18
• Is likely to continue indefinitely
• Results in substantial functional limitations in three or more of the following areas of major
life activity:
o Self-care
o Receptive and expressive language
o Learning
o Mobility
o Self-direction
o Capacity of independent living
o Economic self-sufficiency
• Reflects the need for a combination and sequence of special, interdisciplinary, of generic
services, individualized support, or other forms of assistance that are of lifelong or extended
duration and are individually planned and coordinated.
Examples of developmental disabilities include cerebral palsy, epilepsy, and autism. Many
developmentally disabled persons can live and work independently. More severely disabled
individuals may require a group living environment with training and supportive services. The
most severely disabled individuals may require an institutional environment where medical
services and physical therapy are provided. Because developmental disabilities exist in
childhood, the transition from living with one’s family to living independently is an important
consideration in meeting local housing needs.
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Data on the number of persons with developmental disabilities is maintained by the California
Department of Developmental Services (DDS). DDS coordinates the efforts of a network of 21
non-profit regional centers around the state and provides funding for a variety of programs and
services. Rolling Hills is served by the Harbor Regional Center, which is located in Torrance.
The Harbor Center serves over 15,000 people with developmental disabilities, with a service
area that includes Long Beach, the South Bay, the Palos Verdes Peninsula, and other parts of
southern Los Angeles County. About half are children and half are adults.
Data from the DDS is provided by ZIP code. Rolling Hills city represents 7.4 percent of the
25,061 residents in ZIP code 90274. The last available report posted by DDS on their website
(June 2017) indicates 154 clients served in 90274, including 65 under age 18 and 89 over age
18. If Rolling Hills’ share of the total is pro-rated, this would be equivalent to 12 clients, including
five children and seven adults. ZIP code data is also disaggregated by the type of housing
occupied by clients. The data indicates that 149 clients in ZIP Code 90274 live with their
families or guardians and “fewer than 11” clients live in supported living, care facility, or foster
home environments. Overall, about 87 percent of the Harbor Center’s clients live with their
families.
The Harbor Regional Center is an important resource for those with developmental disabilities,
and their families. It provides health assessments, advocacy, family support and training,
individual case management and support, early intervention and prevention services, and
assistance in finding stable and secure independent living arrangements. Additional resources
in the area include the Disability Community Resource Center in Torrance and Southern
California Resources Services for Independent Living.
3.4.4 Female-Headed Households with Children
Single-parent households require special consideration and assistance because of their greater
needs for day care, health care, and other facilities. In particular, female-headed households
with children tend to have lower incomes, thus limiting housing affordability for this group. In
most communities, female-headed households are considered to be at greater risk of
displacement, poverty, and housing overpayment.
The 2019 ACS indicates that there were five single parent female households with children in
Rolling Hills, representing less than one percent of the City’s households. The comparable
figure for Los Angeles County was 5.1 percent, as the composition of households is substantially
more diverse at the countywide level.
ACS data for the small number of female-headed households with children in Rolling Hills may
not be entirely reliable due to the small sample size. Nonetheless, the data indicate that these
households were above the poverty level, and did not receive supplemental security income,
SNAP/food stamps, or other public assistance income in the past 12 months.
Because the very small number of female-headed households in Rolling Hills, as well as their
income characteristics, they are not expected to have special housing needs that require City
programs.
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3.4.5 Large Households
Large households are defined as those with five or more members. Such households are
identified in State housing law as a group with special housing needs based on the limited
availability of adequately sized, affordable housing units. In instances where large households
have lower incomes, they may be more likely to live in overcrowded dwelling units or in units
that are substandard. The problem is more acute for large households who are renters, who
may face the added risk of eviction or displacement.
Table 3.143 shows data on household size in Rolling Hills. The data is broken down for family
and non-family households. About 12.3 percent of all households in Rolling Hills have five or
more members, including 2.6 percent with seven or more members. All of these households
are families. Countywide, 14.3 precent of all households have five or more members and 2.8
percent have seven or more members.
The average number of rooms per unit in a Rolling Hills home is 8.3, compared to 4.6 for Los
Angeles County. ACS data indicates the median annual income for large households in Rolling
Hills exceeds $250,000. Given the large home sizes in Rolling Hills, the low incidence of
overcrowding, and the relatively small percentage of large households, this is not a priority
special needs group within the city. Larger households will continue to be housed in the city’s
larger single family homes.
Table 3.143: Number of Persons in Family and Non-Family Households
Household
Size Family Percentage
Non-
Family Percentage Total Percentage
1 N/A N/A 94 87.0% 94 16.3%
2 287 61.2% 14 13.0% 301 52.2%
3 59 12.6% 0 0 59 10.2%
4 52 11.1% 0 0 52 9.0%
5 51 10.9% 0 0 51 8.8%
6 8 1.7% 0 0 8 1.4%
7 or more 12 2.6% 0 0 12 2.1%
Total 469 100.0% 108 100.0% 577 100.0%
Source: American Community Survey, 2021 (for 2015-2019)
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3.4.6 Residents Living in Poverty or With Extremely Low Incomes
Census data indicates that 1.7 percent of Rolling Hills’ population—or about 25 residents—are
below the federal poverty line. This compares to 14.9 percent for the county as a whole.
According to the 2015-2019 ACS, Rolling Hills residents living below the poverty include 14
people aged 18-59 and 11 people over 60. There are no children under 18 below the poverty
line in the city. The data further indicates that the 25 residents include 12 white non-Hispanic
persons, four Asian persons, and nine Latino persons.6
Census data indicates that only five of the residents below the poverty line are in the labor force,
suggesting that some of those tallied by the Census have other sources of income not reported
here. Census data indicates that a majority of the adults below the poverty level in Rolling Hills
are 18-34 year olds—this likely represents adult children not in the labor force who are living at
home. This is further supported by the even lower poverty rate for family households in Rolling
Hills—reported at 0.4 percent by the ACS, which is equivalent to three households.
Although Rolling Hills has a very small number of households in poverty, and some of its
extremely low income residents have supplemental sources of income, the city is located in a
region with significant very low income housing needs. In February 2021, the City amended its
zoning regulations to create the Rancho Del Mar Overlay District. Affordable housing and
emergency shelter are both permitted by right in this district, subject to specific development
standards. Single room occupancy hotels are conditionally permitted. The City also permits
home sharing, room rentals, and accessory dwelling units, all of which are beneficial to meeting
extremely low income housing needs.
3.4.7 Farmworkers
The special housing needs of farmworkers are a result of low wages and the seasonal nature of
agricultural employment. Migrant farmworkers face particular challenges, including severe
overcrowding. Farmworker needs are difficult to quantify due to fear of job loss, language
barriers, and the documentation status of the farmworker labor force.
The 2015-2019 ACS data indicates that there are no Rolling Hills residents employed in
“Farming, Fishing, and Forestry” occupations. This data further indicates that there are no
residents in the city employed in the “Agriculture, Forestry, Fishing, Hunting, and Mining” sector.
There are also no farmworker jobs in the city, as there is no agricultural land. As a result, the
City does not have active programs or policies to address farmworker housing needs.
6 As noted earlier, the ACS is based on a sample of the population (roughly 15% for the five-year period). In a small city such as
Rolling Hills, the margin of error is high, particularly for the breakdown of poverty status by age, race and ethnicity.
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3.4.8 Homelessness
Homelessness has become an increasing problem throughout California and the entire United
States. In Southern California, factors contributing to the rise in homelessness include the lack
of housing affordable to low- and very low-income persons, loss of employment and benefits—
particularly for low wage workers, health care costs and related personal disabilities, reductions
in public subsidies, increasing rates of addiction and substance abuse, and a lack of mental
health services.
State law requires that cities address the special needs of unhoused residents within their
jurisdictional boundaries. For this purpose, homelessness is defined as including individuals
who lack a fixed, regular and adequate nighttime residence, as well as individuals living in
shelters and in places not designed for sleeping. The definition does not include those living in
substandard or overcrowded housing or persons who are temporarily staying with family and
friends. Such individuals are considered to be “at risk” of homelessness.
A “point in time” count of homeless residents in Greater Los Angeles is conducted annually by
the Los Angeles Homeless Services Authority (LAHSA). In January 2020, the count identified
54,291 persons experiencing homelessness in Los Angeles County. This is an increase of about
10 percent from 2019, when the count was 49,521. It is an increase of 37 percent from 2016,
when the count was 39,587. The 2020 figures precede the onset of the COVID-19 pandemic
and its impacts on homelessness.
Data provided by the LAHSA indicates the 2020 count for the city of Rolling Hills was zero. The
count for all prior years in the survey (2016-2019) also counted no unsheltered residents in the
city. The nature of homelessness and the method of data reporting make it difficult to evaluate
the full extent of the challenge of adequately housing the entire population. While there are no
unsheltered residents in Rolling Hills, there may be residents who are temporarily staying with
friends or relatives because they lack the resources or have underlying conditions which make it
difficult to find permanent housing.
There are no emergency shelters in Rolling Hills. The closest facilities are in San Pedro and
Wilmington and are less than five miles away. Harbor Rose Lodge (San Pedro) provides
homeless support services for individuals and families in Los Angeles County, with no
geographic restrictions. It assists with temporary housing and provides support services and
referrals. Harbor Interfaith (San Pedro) provides a 90-day emergency shelter and an 18-month
transitional housing program. Also in San Pedro, Shawl House and House of Hope provide
shelter, transitional housing, counseling specifically for women. The Doors of Hope Shelter in
Wilmington also serves single women. The Beacon Light Mission in Wilmington provides a 10-
bed men’s shelter, as well as food, clothing, and supportive services to men, women, and
children.
In February 2021, the City of Rolling Hills amended its zoning regulations to allow emergency
shelter “by right” in the Rancho Del Mar Overlay Zone. The 31-acre site overlay zone includes
multiple areas of underutilized land that provide opportunities for emergency shelter or
supportive service facilities.
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The City is committed to coordinating with supportive service providers and meeting the needs
of local unhoused residents. A list of nearby social service agencies and shelters is maintained
by the City Clerk.
3.5 Housing Stock Characteristics
Government Code Section 65583(a) requires the Housing Element to describe the
characteristics of the local housing stock, including structural condition. This section of the
Element provides an overview of Rolling Hills’ housing stock, including the age of structures, the
types of structures, the number of bedrooms, and vacancy characteristics. It also includes
information on home values and rents.
3.5.1 Housing Unit Count
The US Census reported 674 housing units in the city in 1990, 675 units in 2000, and 693 units
in 2010 (see Chart 3.5). The California Department of Finance estimated 719 units in the city as
of 2021. However, the August 12, 2021 data release from the 2020 Census indicates the total
unit count is 702, which is more consistent with City records. The net number of housing units
in the city has increased at a rate of about one unit a year for the last 30 years.
While the increase in units has been nominal, additional residential development has been
occurring through the replacement and expansion of existing single family homes. Much of
Rolling Hills was developed in the 1950s and was typified by 2,000 to 4,000 square-foot ranch
style homes. As in many desirable older communities, the original housing stock is gradually
being replaced with much larger units. These units average 6,000 to 9,000 square feet in size,
according to City building permit records. This trend of residential recycling can be expected to
continue and potentially increase as less vacant land is available for development.
Chart 3.5: Total Number of Housing Units in Rolling Hills, 1990-2020
0
100
200
300
400
500
600
700
800
674 675 693 702
1990 2000 2010 2020
Source: Census 1990,
2000, 2010, 2020
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Chart 3.6: Year of Construction for Rolling Hills Homes
3.5.2 Age and Condition of Housing Stock
Chart 3.6 shows the age of the housing stock in Rolling Hills. About half of the housing stock in
the community is more than 60 years old. About 35 percent was built in the 1960s and 70s and
the remainder has been built in the last 40 years. About 8 percent of the city’s housing stock is
less than 20 years old—however, most of these homes are “replacements” and were built on
previously developed lots.
The older housing stock in the city is in excellent condition. Census data indicates there are no
units in the city without plumbing or kitchen facilities. The City strongly encourages
reinvestment in the existing housing stock, and homeowners take pride in their homes and
properties. Common repairs include new roofs, new siding, plaster and stucco repair, upgraded
electrical systems, and plumbing improvements. Home additions, kitchen and bathroom
upgrades, and solar energy installations are also common.
No significant code enforcement or housing problems have been observed in the city. The city
has a Code Enforcement Officer who makes complaint-based site visits. In the event a violation
is identified, the City works with the property owner to resolve the issue.
The City estimates that five units, or 0.8 percent of its housing stock, is in need of rehabilitation
or replacement. These properties include:7
• A home that has been red tagged and in need of foundation repair
• A home in a landslide area with a stop work order due to work being done without
permits
7 Addresses can be provided to HCD upon request but are not disclosed here.
Before 1950
11%
1950s
36%
1960s
21%
1970s
14%
1980s
7%
1990s
3%Post 2000
8%
Source: American Community Survey 2021
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• An older home where the owner is seeking approval to demolish and rebuild
• A home with an approved application to demolish and rebuild
• A home with an approval for a major remodel and addition
In any given year, the City also receives “tear down and rebuild” applications for one to two
older homes as well as dozens of applications to modernize, expand and update older homes.
In almost all cases, these homes are habitable, but they are outdated and do not provide the
amenities expected in high-end construction.
3.5.3 Housing Type
Rolling Hills is comprised entirely of single family homes. The 2021 ACS indicates there are no
multi-family units in the city. ACS data further indicates seven units that are “single family
attached” which presumably are accessory dwelling units (ADUs) or other separate living
quarters that are ancillary to a primary residence.
Census data does not typically classify “guest houses” as dwelling units unless they have been
legally permitted as separate residences. Rolling Hills classifies guest houses differently than
ADUs; the latter are permitted by right to be independent dwellings provided they meet certain
adopted zoning standards. By contrast, occupancy of guest houses is limited to persons
employed on the premises, the family of the occupants of the main residence, or the temporary
guests of the occupants of the main residence. Guest houses may not be used as rental
housing, but an owner may apply for a permit to convert a guest house to an ADU, which can
then be rented.
3.5.4 House Size
Homes in Rolling Hills are large. Chart 3.7 below shows the distribution by number of
bedrooms. About 74 percent of the homes in the city have four or more bedrooms. Another 21
percent have three bedrooms and only five percent have two bedrooms or fewer. By contrast,
among homes in Los Angeles County as a whole, 16 percent of all housing units have four or
more bedrooms and 56 percent have two bedrooms or fewer.
Data for total house size shows a similar difference between Rolling Hills and the County as a
whole. Countywide, the median number of rooms per home is 4.5. It Rolling Hills, it is 8.3. Only
4.7 percent of the homes in Los Angeles County have nine or more rooms. In Rolling Hills, 46
percent of the homes have nine or more rooms.
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Chart 3.7: Percent of Housing Units by Number of Bedrooms, Rolling Hills and Los Angeles
County
Source: American Community Survey 2021 (for 2015-2019)
0.0%0.8%
4.4%
20.7%
39.8%
34.3%
7.1%
19.7%
29.4%28.3%
12.3%
3.3%
0.0%
5.0%
10.0%
15.0%
20.0%
25.0%
30.0%
35.0%
40.0%
45.0%
No bedrooms 1 bedroom 2 bedrooms 3 bedrooms 4 bedrooms 5 or more
bedrooms
Rolling Hills Los Angeles County
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3.5.5 Vacancy Characteristics
The August 12, 2021 data release from the US Census indicates that 63 of the city’s 702 homes
were vacant at the time of the 2020 Census. This is a nine percent vacancy rate. By contrast,
2020 Census data indicates that the vacancy rate for the Palos Verdes Peninsula as a whole was
about five percent. Countywide, ACS data indicates that six percent of the housing stock in Los
Angeles County is vacant.
ACS data provides an indication of the characteristics of vacant units in Rolling Hills. The ACS
reports that 30 percent of the vacant units in the city were for sale, 26 percent were used
seasonally (and were not occupied at the time of the census), and five percent were for rent.
The remainder were classified as “other.” ACS data further indicates that the vacancy rate
among for-rent units was three times higher than the vacancy rate among for-sale units,
although the sample size is very small.
In 2010, the Census reported that 5 percent of the homes in the city were vacant, indicating a
significant increase between 2010 and 2020. The higher vacancy may be a result of changes in
the housing market, including significantly higher home prices, and an increase in the number of
homes that are used seasonally. The city’s housing market serves a unique market niche.
3.5.6 Home Values and Prices
A variety of sources were used to analyze housing market prices and trends in Rolling Hills,
including on-line real estate data vendors, current real estate listings, and the US Census.
According to on-line real estate service Zillow.com, the median value of a home in Rolling Hills is
$3,733,468. Rolling Hills home values have gone up 19.7% over the past year. Chart 3.8
compares the local median home value with values in the three other Palos Verdes Peninsula
cities and with Los Angeles County as a whole. Homes in Rolling Hills are valued at 50 percent
higher than those in Palos Verdes Estates ($2.45 M), 126 percent higher than those in Rancho
Palos Verdes ($1.65M), and over four times higher than the countywide median ($790,000).
The ACS 2021 data indicates that 95 percent of all homes in Rolling Hills have a value of over
$1,000,000. The Census-reported median is over $2 million, which is the highest interval on the
Census scale. The ACS shows the median in Los Angeles County at $583,200. This is
substantially lower than the Zillow data, which is only based on homes recently sold.
The website realtor.com indicates that the average time on the market for a home in Rolling Hills
in July 2021 was 120 days. However, the sample size is small, and similar data for earlier in the
year indicates a median sale time of 45 days (December 2020 and January 2021). Realtor.com
indicates that homes in the city sold for 4.98 percent below asking price in July 2021. This figure
is highly variable depending on market listings at any given time.
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In July 2021, there were 14 homes for sale in Rolling Hills (including properties with pending
offers). These ranged in size from a 1,467 square foot home to a 13,000 square foot home.
Prices ranged from $2,499,000 to $15,975,000. The median price was $5.02 million and the
mean was $6.15 million. This is substantially higher than the average for surrounding cities on
the Palos Verdes Peninsula and in Los Angeles County. The higher priced homes were typically
new construction, while the two lowest priced homes were built in 1954 and 1957.
Data on rentals in the city is more difficult to characterize because the number of available
properties is so small. In July 2021, there was only one home being advertised for rent in the
city. The asking monthly rent was $16,000. The property has five bedrooms, seven bathrooms,
and is 5,035 square feet. Zillow also reported a 2-bedroom, 1-bath detached 1,000 square foot
accessory dwelling unit for rent for $3,950. In addition, two ADUs were being advertised on
Craigslist (listed as Rolling Hills but likely in Rolling Hills Estates or Rancho Palos Verdes). One
was a 500 square foot studio for $1,250 and the other was a 400 square foot guest house for
$1,800. The Census indicates that seven of the renter households in the City pay less than
$1,500 a month in rent, and the remainder pay more than $3,000 a month.
Chart 3.8: Home Prices in Rolling Hills, Peninsula Cities, and Los Angeles County, 2012-2021
Source: Zillow.com, 2021
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Table 3.154: Homes for Sale in Rolling Hills, July 2021
Asking Price Square Footage
Cost per
Square Foot
Year
Constructed
$15,975,000 7,136 $ 2,239 2016
$11,100,000 13,000 $ 854 2007
$8,765,000 5,100 $ 1,719 1951
$7,750,000 4,000 $ 1,938 1968
$7,499,000 8,000 $ 937 2002
$5,800,000 4,453 $ 1,302 1986
$5,795,000 5,884 $ 985 1956
$4,250,000 4,101 $ 1,036 1941
$4,200,000 3,527 $ 1,191 1940
$3,950,000 5,560 $ 710 1989
$3,495,000 3,414 $ 1,024 1947
$2,630,000 3,444 $ 764 1974
$2,500,000 1,467 $ 1,704 1957
$2,499,000 1,752 $ 1,426 1954
MEAN: $6,150,000 $1,273
MEDIAN: $5,020,000 $1,030
Source: Realtor.com, Trulia, Zillow, 2021
Table 3.154 indicates the cost per square foot of those homes currently for sale in Rolling Hills,
along with the asking price, square footage and year of construction. The median cost per
square foot is $1,030, which is substantially higher than the statewide median of $438 per
square foot. Cost per square foot ranged from $710 to $2,239.
3.5.7 Units at Risk of Conversion from Affordable to Market Rate
State law requires the City to identify, analyze and propose programs to preserve any deed-
restricted lower-income housing that could be lost as these deed restrictions expire. However,
there are presently no low-income or income-restricted units in Rolling Hills. As a result, there is
no housing at risk of losing its subsidized status.
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3.6 Future Housing Needs
3.6.1 2021-2029 Regional Housing Needs Allocation (RHNA)
The eight-year housing need for the six-county Southern California region is calculated by the
California Department of Housing and Community Development (HCD). This need was
determined to be 1,341,827 units for the 2021-2029 Sixth Cycle planning period. The total
regional need represents a 225 percent increase over the need calculated for the 2013-2021
Fifth Cycle.
The total regional need is disaggregated to the six counties and 191 cities in the region by the
Southern California Association of Governments (SCAG) through a process known as the
Regional Housing Needs Allocation (RHNA). About 60 percent of the regional need was
assigned to Los Angeles County, which had 53 percent of the region’s population in 2020.
Concentrating the RHNA in Los Angeles County is a response to the greater availability of
transit, urban services, and housing need within the core of the region. If the 1.3 million unit
need was fully constructed, it would represent a 20 percent increase in the region’s housing unit
count in eight years.
The City of Rolling Hills was allocated 45 units of the countywide total, or about .006 percent.
Allocations for nearby cities on the Palos Verdes Peninsula were 191 for Rolling Hills Estates,
199 for Palos Verdes Estates, and 639 for Rancho Palos Verdes. As shown in Table 3.165,
these allocations are significantly higher than they were in the Fifth Cycle, particularly when
compared to the county and region. This represents a shift in the methodology used to allocate
units, with less consideration given to growth potential as defined by local governments and
more consideration given to population, proximity to job centers, and equity factors. Despite
the large increases compared to the last cycle, the RHNA targets for the four Peninsula cities
combined represent one-tenth of one percent of the countywide allocation. The RHNA for each
of the four cities is equal to between four and six percent of each city’s existing housing stock,
compared to 20 percent for the region.
Table 3.165: RHNA by City and Comparison to Fifth Cycle
Jurisdiction
5th Cycle
RHNA
6th Cycle
RHNA
Percent
Increase,
5th to 6th
Cycle
Existing
(2021)
Housing
Units
6th cycle RHNA
as percentage
of existing
inventory
Rolling Hills 6(*) 45 650% 702 6%
Rolling Hills Estates 5 191 3720% 3,157 6%
Palos Verdes Estates 16 199 1144% 5,303 4%
Rancho Palos Verdes 31 639 1961% 16,340 4%
Los Angeles County 179,881 812,060 351% 3,614,809 22%
SCAG Region 412,137 1,341,827 226% 6,679,283 20%
Source: SCAG 2012 and 2021, plus DOF Table E-5 and US Census 2020
(*) In addition to planning for its 5th Cycle allocation, the 2015-2023 Rolling Hills Housing Element includes the 4th Cycle allocation of
22 units, which was carried over. The 45- unit assignment is a 60 percent increase over the prior 28 unit two-cycle total.
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The 6th Cycle allocation by income group is shown in Table 3.167. In Rolling Hills, about 64
percent of the RHNA is for low and very low income households. The figure is comparable to
the other cities on the Palos Verdes Peninsula (ranging from 62 to 65 percent). In Los Angeles
County, only 42 percent of the assigned need is for low and very low income households, and
regionally, it is 41 percent. The greater allocation of lower income housing to the Peninsula cities
reflects the statewide and regional focus on encouraging fair housing and discouraging
economic segregation.
Table 3.167: Comparison of 6th Cycle RHNA by Income Category
Jurisdiction
Very Low %
of total
Low % of
total
Moderate %
of total
Above
Moderate %
of total
Rolling Hills 44% 20% 24% 11%
Rolling Hills Estates 43% 22% 20% 15%
Palos Verdes Estates 41% 22% 24% 13%
Rancho Palos Verdes 40% 22% 20% 19%
Los Angeles County 27% 15% 16% 42%
SCAG Region 26% 15% 17% 42%
Source: SCAG, 2020
The City’s “very low” income housing allocation for 2021-2029 is 20 units. The State
Government Code requires that this total be further allocated between “extremely low” income
households (earning less than 30% of areawide median income) and other “very low” income
households (earning 30-50% of areawide median income). This distribution may be based on
Census income data showing the current percentages of households in these two categories.
According to the most recent HUD Comprehensive Housing Affordability Strategy data, there
are 65 very low income households in Rolling Hills. CHAS indicates 25 are extremely low
income and 40 are very low income. Applied to the 20 unit RHNA, these proportions equal
roughly 7 extremely low income units and 13 other very low income units.
3.6.2 Growth Forecasts
As the regional planning agency for the Los Angeles region, SCAG is responsible for preparing
jurisdiction-level forecasts for each city and county in the region. The latest forecasts were
adopted in September 2020 and describe conditions in a base year (2016) and forecast year
(2045). The six-county region as a whole is expected to grow from 6.012 million households
(2016) to 7.633 million households (2045), an increase of over 1.3 million households in the 29-
year period. Average household size is projected to decline from 3.1 to 2.9 during this period.
SCAG forecasts indicate that Rolling Hills growth will be flat during through 2045. The latest
published forecasts (Connect SoCal Demographics and Growth Forecast, September 2020)
show 700 households in 2016 and 700 households in 2045. However, the numbers are rounded
to the nearest hundred and it is likely that some marginal change will occur. Population over the
equivalent period is shown as increasing from 1,900 to 2,000, a growth rate of about 5 percent
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over 29 years. As noted on page 3.1, the 2020 Census indicates the City lost over 100 residents
between 2010 and 2020, so the SCAG forecasts will need to be adjusted in the future. An
increase of 100 residents would bring the City closer to its 2010 total of 1,860 residents.
3.6.3 Locally Identified Needs
While Rolling Hills is obligated by the Government Code to identify capacity for 29 low and very
low income units and to develop programs to meet this need, the City also has an opportunity to
tailor its housing programs to meet local needs. Based on the Assessment in this chapter, some
of the key findings regarding local needs are:
• The City has a large and growing population of seniors. Some of these residents are on
fixed or limited incomes and face relative high housing costs, including home
maintenance, property taxes, HOA dues, utilities, etc. These residents could benefit
from more senior housing options, ranging from fully independent to assisted living.
• Although there are very few people who list Rolling Hills as their permanent place of
employment, the City supports a relatively large population of service workers, including
caregivers, domestic employees, child care workers and au pairs, landscapers and
gardeners, and others in construction and home maintenance. In addition, there are
public sector workers, firefighters, and teachers/counselors (at Rancho Del Mar)
employed within the city, with incomes that are far below what would be required to buy
a home in Rolling Hills. A limited number of affordable rental units serving these workers
could reduce commute lengths and vehicle miles traveled.
• Adult children of Rolling Hills residents (particularly those in the 18-30 age range) have
limited housing options in the city, other than remaining at home. ADUs could provide
additional options.
• The City’s housing stock is well suited to ADUs and home sharing. More than two-thirds
of the non-vacant housing units in the city have only one or two occupants, despite
homes that are substantially larger than the regional average. There are also 300 fewer
residents in Rolling Hills today than there were 50 years ago, despite larger homes and
more square feet of living space. Additional residents would have a lower impact on
infrastructure, services, and the environment if accommodated in the footprint of existing
homes as opposed to new construction.
• Creating an ADU or deciding to share one’s home is a personal choice and is entirely at
the discretion of the homeowner. However, the City can create incentives that make it
easier and more affordable for homeowners to consider this option.
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4.0 Housing Opportunities and Resources
4.1 Introduction
This section of the Housing Element evaluates potential opportunities to meet the City’s
Regional Housing Needs Allocation (RHNA). It includes an inventory of potential housing sites in
the city and an evaluation of Accessory Dwelling Unit (ADU) and Junior ADU potential. The
analysis in this section demonstrates that Rolling Hills has the capacity to accommodate its
RHNA assignment of 45 additional housing units, including 29 units that are affordable to low
and very income households.
Two other topic areas are covered in this chapter. As required by State law, this chapter
discusses opportunities for energy conservation in the city. Reducing energy costs can reduce
overall housing costs, contributing to affordability. This chapter also identifies potential financial
resources to support the provision of affordable housing and the maintenance of existing
housing in the city.
4.2 Approved or Pending Development
There are 12 housing units in the city that are approved or pending and not yet constructed. All
of these units are expected to become available for occupancy during the 2021-2029 period and
therefore count toward meeting the RHNA. These units include three market-rate single family
homes and nine ADUs. These units are listed in Table 4.1 below, including an assignment of
each unit by income category.
Table 4.1: Committed Development for the 2021-2029 RHNA period
ID Assessor’s Parcel
Number (APN)
Address Description Income Category
A 7567-011-020 23 Crest Road E New SF home on vacant lot Above Moderate
B 7567-001-018 1 Poppy Trail New SF home on vacant lot Above Moderate
C 7569-020-004 8 Middleridge Ln S. New SF home on vacant lot Above Moderate
D 7567-011-020 23 Crest Road E ADU (1000 SF) Above Moderate
E 7569-001-031 2950 Palos Verdes N ADU (1000 SF) Above Moderate
F 7569-026-008 13 Buggy Whip Dr. ADU (997 SF) Above Moderate
G 7569-023-006 33 Crest Road W ADU (946 SF) Above Moderate
H 7569-026-012 27 Buggy Whip Dr. ADU (800 SF) Moderate
I 7567-006-036 23 Chuckwagon ADU (800 SF) Moderate
J 7567-005-028 79 Eastfield Dr. ADU (799 SF) Moderate
K 7567-014-022 23 Georgeff Road ADU (620 SF) Low
L 7567-008-009 63 Crest Rd E ADU (580 SF) Low
Sources: US Decennial Census, 1970-2010. California Dept. of Finance, 1/1/21 estimate, 2020 Census (8/12/21 release)
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The assignment of the ADUs by income category is based on the size of the unit. Units larger
than 800 SF are presumed to be “above moderate”; units 650-800 SF are presumed to be
“moderate”; units 500-650 SF are presumed to be “low”; and units smaller than 500 SF are
presumed to be “very low.” This is based on local rental data for comparably sized ADUs (see
Section 4.6 and the footnote below).1
4.3 Vacant Sites
Table 4.2 identifies vacant residentially zoned sites in Rolling Hills. These sites are shown
graphically on Figure 4.1. For each site, the table indicates the theoretical number of units
permitted by zoning (based on acreage and minimum lot size requirements) and the “realistic”
number of units based on lot configuration, access, and terrain.2 Some of the vacant parcels are
characterized by physical constraints that preclude their development, including steep or
unstable slopes or landslide hazards. A few are landlocked and have no access. The acreage
data for each site is based on assessor parcel maps and subtracts out unbuildable easements
such as flood hazard areas and roads.
There are 34 parcels identified totaling, 124.8 acres. All of these parcels are in private
ownership. Twenty are estimated to be developable and 14 are severely constrained and
presumed undevelopable for the 2021-2029 planning period. The constrained parcels include
five lots that are landlocked with no street frontage and nine that are in the Flying Triangle
Landslide Hazard Overlay area. Several of the lots in the landslide area had homes that were
destroyed by earth movement in the 1980s and early 1990s.
For the 20 remaining vacant lots, Table 4.2 indicates the “realistic” potential for 20 single family
homes. This excludes accessory dwelling units, which are addressed later in this chapter.
1 In this case, the assignment of two smaller units as “low” income is further supported by the fact that they are both
conversions of existing structures rather than new construction. This facilitates greater affordability.The City is
presuming that the two smallest ADUs listed in Table 4-1 will be affordable “by design” to lower income households.
ADU permits were issued for these two units on October 27, 2020 and May 20, 2021 respectively. Both of these
projects involve converting existing two-story stables (located on two separate parcels about a mile apart) into ADUs
of approximately 600 square feet each. Neither of these units has a finaled building permit yet. Given the eight year
timeframe of the Housing Element, both units are expected to be completed before 2029.
These are market rate units. The assumption that they will be affordable to low-income households is based on the
size of the units and the fact that they are being created by repurposing existing space rather than building new
space, which presumably would cost more. Current HCD income limits for Los Angeles County indicate that the
upper end of the low-income range for a two-person household is $75,700. At 30 percent of household income,
monthly housing costs would need to be $1,892 to be considered affordable. The City’s survey of comparable
properties in 2021 found that ADUs of 400 to 600 square feet in the Palos Verdes Peninsula sub-market were renting
for $1,800 per month or less. The two new ADUs are presumed to rent at comparable rates. Moreover, SCAG’s ADU
survey for Los Angeles County found that 60% of all ADUs in the region could be presumed affordable to lower
income households. As these two ADUs are the smallest of the nine that are listed in the Housing Element (see Table
4-1), it is reasonable to presume they would fall in this range.
2 Excludes additional units that could be permitted under SB 9.
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Table 4.2: Vacant Residentially Zoned Sites (sorted by APN) (see note at end of table)
Site APN Address or Location Zoning General
Plan
Acres
(*)
Theoretical
Unit Yield
Realistic
Yield, excl.
ADUs
Comments
1 7567-006-001 15 Chuckwagon Road RAS-1 LDR 2.27 2 1
2 7567-006-014 Behind 6 Chesterfield RAS-1 LDR 1.22 1 0 Landlocked (no road access)
3 7567-009-007 5 Southfield Drive RAS-1 LDR 1.61 1 1
4 7567-010-013 East of 3 Packsaddle Rd W RAS-1 LDR 1.24 1 1
5 7567-010-015 North of 3 Packsaddle Rd W RAS-1 LDR 1.49 1 0 Landlocked (no road access)
6 7567-011-017 54 Portuguese Bend Road RAS-2 VLDR 2.67 1 0 Severely constrained - slide hazards
7 7567-012-019 SW of 56 Portuguese Bend RAS-2 VLDR 0.96 1 0 In landslide hazard area
8 7567-012-020 53 Portuguese Bend Road RAS-2 VLDR 1.46 1 0 In landslide hazard area
9 7567-012-026 4 Wrangler Road RAS-2 VLDR 1.82 1 0 Severely constrained - slide hazards
10 7567-012-035 66 Portuguese Bend Road RAS-2 VLDR 1.64 1 0 Severely constrained - slide hazards
11 7567-012-036 64 Portuguese Bend Road RAS-2 VLDR 1.71 1 0 Severely constrained - slide hazards
12 7567-012-038 62 Portuguese Bend Road RAS-2 VLDR 1.84 1 0 Severely constrained - slide hazards
13 7567-013-005 End of Portuguese Bend Rd RAS-2 VLDR 19.81 1 0 Flying Triangle Landslide
14 7567-013-007 2 Running Brand RAS-2 VLDR 7.09 1 0 Severely constrained - slide hazards
15 7567-014-005 West of 5 El Concho Ln RAS-1 LDR 2.12 2 0 Landlocked (no road access)/ canyon
16 7567-014-011 West of 24 Georgeff Rd RAS-1 LDR 1.66 1 0 Landlocked (no road access)/ canyon
17 7567-014-013 North of 27 Georgeff Rd RAS-2 VLDR 3.79 1 0 Landlocked (no road access)/ canyon
18 7567-014-031 Access b/w 1 and 3 Poppy Tr. RAS-2 VLDR 6.85 3 1 Rear of 8 Reata Lane
19 7567-015-036 North of 1 Georgeff RAS-2 VLDR 4.56 2 1
20 7567-017-017 Between 4 and 5 Ranchero RAS-2 VLDR 3.52 2 1 Access at end of Ranchero cul-de-sac
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Table 4.2, continued
Site APN Address or Location Zoning General
Plan
Acres
(*)
Theoretical
Unit Yield
Realistic
Yield, excl.
ADUs
Comments
21 7567-017-045 17 Cinchring Rd RAS-1 VLDR 1.52 1 1 Driveway access b/w 15 and 20 Cinchring
22 7569-001-020 B/w 2954 and 2958 PV Dr N RAS-1 LDR 1.03 1 1
23 7569-001-036 B/w 6 and 14 Roadrunner RAS-1 LDR 1.00 1 1
24 7569-004-026 B/w 35 and 45 Saddleback RAS-1 LDR 3.39 3 1
25 7569-005-008 80 Saddleback RAS-1 LDR 6.52 6 1 This parcel is currently for sale
26 7569-012-022 W of 25 Portuguese Bend RAS-2 VLDR 2.30 1 1
27 7569-012-025 N of 25 Portuguese Bend RAS-2 VLDR 3.51 1 1
28 7569-013-017 North of 10 Pine Tree Lane RAS-2 VLDR 2.41 1 1 One of three adj. vacant lots
29 7569-013-018 South of 18 Pine Tree Lane RAS-2 VLDR 2.20 1 1 One of three adj. vacant lots
30 7569-013-020 18 Pine Tree Lane RAS-2 VLDR 2.13 1 1 One of three adj. vacant lots
31 7570-024-019 Storm Hill Lane, Parcel 1 RAS-2 VLDR 6.04 3 1 7.6 ac parcel with 1.6 acres of easements
32 7570-024-020 Storm Hill Lane, Parcel 2 RAS-2 VLDR 11.64 5 1 34.7 ac parcel with 23 acres of easements
33 7570-024-021 Storm Hill Lane, Parcel 3 RAS-2 VLDR 10.10 5 1 17.3 ac parcel with 7.2 acres of easements
34 7570-025-022 N/ end of Johns Canyon Road RAS-2 VLDR 1.68 1 1
TOTAL 124.8 57 20
Sources: Barry Miller Consulting, 2021; LA County GIS Portal, 2021
(*) Acreages generally exclude unbuildable easements
Note: This is a roster of existing vacant residentially zoned land in Rolling Hills. No changes to the zoning of these parcels is proposed, and no specific projects are proposed on these
sites. Future development applications on these properties would be subject to environmental review or applicable exemptions, consistent with the requirements of California
Environmental Quality Act.
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Figure 4.1: Vacant Residentially Zoned Sites
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Several of the sites, such as those on Storm Hill Lane, are quite large and could potentially be
subdivided. However, the “realistic” estimates are intended to be conservative and do not
presume subdivision of any of the sites. These estimates also reflect the absence of sewer
services on these sites, their very steep topography, and the severe risk of wildfire.
The vacant lots have the potential to completely meet the regional need for above moderate
income units assigned to Rolling Hills. As noted, this need is five units for the 6th Cycle. Since
three new single family homes are already in the pipeline (see Sec 4.2), the remaining need is
two units. Several of the vacant sites are currently for sale, making it likely that the City will
exceed its above moderate income allocation for 2021-2029.
Table 4.2 indicates the General Plan and zoning designations for each vacant site. Of the
developable parcels, eight are in the RAS-1 zone (one acre minimum) and 12 are in the RAS-2
zone (two-acre minimum). No zoning changes are proposed or required to meet the above
moderate income or moderate income allocations.
4.4 Lot Splits
There are a number of parcels in Rolling Hills with lot sizes that are more than double the
minimum acreage required by zoning. Some of these parcels could theoretically be subdivided
into two or more lots. Moreover, SB 9 (effective January 1, 2022) includes provisions to allow
single family lots to be divided to allow new homes.
The potential for lot splits in Rolling Hills is very limited due to the configuration of the lots as
well as environmental hazards, evacuation constraints, and the lack of a sewer system. Many of
the city’s larger lots have limited street frontage and irregular dimensions that would make it
difficult to divide them. Moreover, the platting pattern responds to topography, and the larger
lots are often steep and geologically constrained, making them difficult to subdivide. Their
division could result in lots with no buildable area, street frontage, or access.
Although a limited number of new homes could conceivably occur as a result of future lot splits,
a capacity estimate has not been made due to the constraints inherent in the community’s
topography and hazards. In addition, the reliance on septic tanks makes subdivision infeasible
from a public health perspective, even on many larger lots. The supply of vacant lots is
sufficient to meet the above moderate income RHNA without relying on lot splits.
4.5 Non-Vacant Sites
While Rolling Hills’ above moderate income (or “market rate”) RHNA can be met on vacant
residentially-zoned land, the City’s moderate, low, and very low income RHNA will need to be
accommodated through a combination of development on non-vacant sites and accessory
dwelling units (ADUs). The text below addresses non-vacant sites. ADUs and Junior ADUs
(JADUs) are discussed in Section 4.6.
The sites described below provide the potential for 16 units of low- and very low-income
housing. This potential is associated with the 31-acre Palos Verdes Peninsula Unified School
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District (PVPUSD) site, where an overlay zone was created in 2021 to facilitate affordable
housing. Other non-vacant properties addressed here are the City Hall complex, the Tennis
Court Facilities, the Los Angeles County Fire Station, and the Daughters of Mary and Joseph
Retreat Center parking lot. These properties have been determined to not be viable as potential
housing sites. Non-vacant housing sites are shown in Figure 4.2.
4.5.1 PVPUSD Site/ Rancho Del Mar Overlay Zone (APN 7569-022-900)
In March 2021, the City of Rolling Hills adopted the Rancho Del Mar Overlay Zone on the 31-
acre Palos Verdes Peninsula Unified School District (PVPUSD) property located at 38 Crest
Road. Although the site is technically non-vacant, roughly three-quarters of the property (23
acres) is open space. The remaining areas are underutilized and could be repurposed.
Appendix B of this Housing Element provides a detailed evaluation of the site, demonstrating
that it is the most suitable location for multi-family housing in Rolling Hills. The site also provides
the City’s best opportunity to meet its requirements for low- and very low-income units. It is
located outside the jurisdiction of the Rolling Hills Community Association, outside the Rolling
Hills security gates, and is one of the largest properties in the city. It includes multiple areas that
are vacant and underutilized, relatively flat, and well buffered from adjacent uses. The site is
also one of the only properties in Rolling Hills that is served by a public sewer system. This
substantially reduces multi-family development costs and addresses an infrastructure constraint
that makes affordable housing cost-prohibitive in almost all of the city. The site is also ½ mile
from the corner of Crenshaw and Crest Roads in Palos Verdes Estates, which is served by four
bus lines.
Existing uses on the PVPUSD site include Rancho Del Mar Continuation High School and a
maintenance facility leased to the Palos Verdes Peninsula Transit Authority (PVPTA). Each of
these activities is discussed below.
Rancho Del Mar School was initially developed as an elementary school in 1960. The school
closed in 1980 and was repurposed as a continuation school in 1986. The continuation school
was initially intended as a temporary use but has been in place for 35 years. The possibility of
residential development on the site has been considered in the past. Enrollment at Rancho Del
Mar has been steadily declining and was just 32 students in the 2020-2021 school year
(California Department of Education, DataQuest). Enrollment has declined every year since
2014 and is now less than half of what it was just five years ago.3
The Beach Cities Learning (BCL) Center uses four classrooms in the school building. BCL
serves students aged 11-22 with emotional, behavioral, and learning disabilities that cannot be
addressed in public school settings. Students participate in individual and group counseling run
by licensed therapists on-site. Total enrollment in 2019-20 was 17 students, with two teachers
on-site (School Accountability Report Card, 2021).
3 California Department of Education indicates the following enrollment figures: 2020-21 (32 students); 2019-20 (46
students); 2018-19 (47 students); 2017-18 (58 students); 2016-17 (69 students); 2015-16 (72 students); 2014-15 (79
students)
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Figure 4.2: Non-Vacant Sites Evaluated
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The school building is adjoined by a lawn, playing fields, and school parking lot. The complex
serves only a fraction of the number of students for which it was designed. Moreover it
occupies just 1.9 percent of the 31-acre site. Sale of the school property could generate
significant revenue for the School District.
The only other active use on the property is the PVPTA maintenance facility, which occupies 4.5
acres. The PVPTA facilities include maintenance buildings and administrative offices and are
self-contained in the west central part of the site. While PVPTA has no immediate plans to
relocate, the site could be sold in the future or repurposed by the School District. In any event,
the facilities occupy only 15 percent of the 31-acre site and have co-existed with the nearby
school and adjacent residential uses for many years.
Roughly 75 percent of the PVUSD site is vacant, and at least five developable areas have been
identified on the campus. These include the school itself (in the event it is closed), the ballfield
east of the school, the large lawn adjacent to the school, a vacant area between the school and
the PVPTA facility, and the undeveloped area west of the PVPTA facility. Each of these areas is
at least one acre in size. The area west of the PVTPA facility is the largest of the five areas and
the one deemed most viable as a multi-family housing site. It is the closest location to Crest
Road and could easily be developed without affecting activities at either the school or the transit
facility. Accordingly, the Rancho Del Mar Overlay Zone identifies this area as the location for
future affordable housing.
The entire Rancho Del Mar site has a General Plan designation of Very Low Density Residential
and an underlying zoning designation of RAS-2. The designation permits 16 units on the site,
based on the site area of 31 acres and the density of one unit per two acres (31/2 = 15.5,
rounded up to 16). However, the General Plan (as amended in 2021) requires that the allowable
density for this site be transferred to a single location on the property where a density standard
of 20-24 units per acre applies. This is reinforced and codified by the Rancho Del Mar Overlay
Zone (RDMO). The RDMO effectively takes the 16 units of housing and transfers it to a single
location on the west side of the parcel. The RDMO further mandates that any housing built on
the site be 100% affordable to very low and/or low income households. Such development is
permitted by right, provided that the development complies with the objective development and
design standards contained in the RDMO.
The RDMO also provides opportunities for emergency shelter and single room occupancy
(SRO) hotels. Emergency shelter is permitted by right, subject to objective development
standards that have been adopted by the City. SROs require a conditional use permit and are
also subject to objective design standards. These provisions create opportunities for extremely
low income households as well as low and very low income households.
Creation of the RDMO occurred collaboratively with the School District. District staff confirmed
that there are no prohibitions on the application of this zoning overlay or the use of the property
for affordable housing. Moreover, the District has expressed interest in developing housing for
teachers in the past; such units would likely meet income criteria for lower income housing.
Programs in this Housing Element support active communication with the School District
regarding the disposition of the area west of the PVPTA for affordable housing.
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The PVUSD site also meets the “carry-over” criteria established by the State for sites that were
counted in the prior cycle Element. It is zoned with a minimum density of 20 units per acre and
permits “by right” development of affordable housing, subject to objective design and
development standards. The current zoning was put in place just six months before the end of
the Fifth Cycle planning period and was principally intended to provide a housing opportunity for
the Sixth Cycle.
For the 2021-2029 Housing Element, the capacity figure of 16 lower income units is being used
for the site. Under State Density Bonus law, a 100% affordable project would be eligible for an
80 percent density bonus. This could potentially result in 29 units of lower income housing,
which is equal to the total number of units assigned to the City under the Sixth Cycle RHNA.
However, State law precludes the City from counting potential density bonus units when
determining its RHNA capacity. As explained in Section 4.6, the remaining 13 units will be met
through Accessory Dwelling Units.
As indicated in Appendix B, the PVUSD site is large enough to accommodate multi-family
housing, emergency shelter, and an SRO on the same property, either in the same sub-area or
independently in different parts of the site. Neither the shelter beds nor the SRO rooms would
be counted as independent “dwelling units” so they could be accommodated under existing
General Plan densities. Moreover, all three of these uses are permitted by right, provided they
meet the Municipal Code objective standards (which were previously reviewed by HCD in 2020).
As noted above, the preferred location for the multi-family housing is in the western part of the
property, near the access drive and closest to public transit and other urban services (see
Figure 4 on Page B-8 in the Housing Element Appendix—this is labeled Area 5). This area is
four acres. Only about one acre would be required for multi-family housing, leaving three
vacant acres for the SRO and/or emergency shelter if all three uses are located in this area.
An SRO or emergency shelter could also locate in areas 1, 2, 3, or 4, as shown in Figure 4 in
Appendix B, page B-8. As the map and text indicate, Area 1 is a 1.6-acre site that is flat and
vacant. Area 2 is a 1.0-acre site that is flat and vacant. Area 3 is a 1.75-acre former school
building that is mostly vacant and underutilized. Portions of this building could be easily be
converted to group residential uses. Area 4 includes a ballfield and parking lot which
collectively occupy 2.5 acres. There are no limitations in the housing overlay ordinance that
limit where shelters or SROs can locate within the 31 acres. Areas 1, 2, 3, 4, or 5 all have
adequate space for these uses.
4.5.2 Rolling Hills City Hall (APN 7569-003-904)
This site is located at the southeast corner of Palos Verdes Drive North and Portuguese Bend
Road. Palos Verdes Drive North is a major thoroughfare and provides access from Rolling Hills
to surrounding communities and the regional roadway network. Portuguese Bend Drive is a
local street but the primary north-south route through the city, connecting to Crest Drive. This is
one of the only sites in Rolling Hills that is located outside the security gates, and adjacent to a
transit line. An elementary school and park are nearby in the City of Rolling Hills Estates.
The property is 1.22 acres and is roughly rectangular in shape. It has a General Plan
designation of Civic Center and a zoning designation of Public Facilities (PF). Neither of these
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designations permits housing, so a General Plan amendment would be required to enable its
development. The site is owned by the City of Rolling Hills.
The parcel currently contains three structures: City Hall, the Rolling Hills Community Association
Administration Building, and an accessory structure that houses an emergency generator. The
site is relatively flat, although it is adjoined by a steep canyon to the east. There is a single
family residence located to the south. To the west, there is a guardhouse in the median of
Portuguese Bend Road, and a public tennis court on the west side of the road. Site ingress and
egress is from Portuguese Bend Road. Direct access to Palos Verdes Drive North is not feasible
due to high speeds and volumes and the existing traffic signal at the corner of Portuguese Bend.
Given the existing uses on the site and its function as the only civic building in Rolling Hills, the
site is not a practical location for multi-family housing. Its rezoning is not recommended at this
time.
4.5.3 Rolling Hills Tennis Court Facility (APN 7569-015-900)
This site is located immediately west of City Hall on the southwest corner of Palos Verdes Drive
North and Portuguese Bend Road. It is adjoined by a residence and horse stables on the west
and south and by street frontage on the north and east. The site is 0.86 acres and is one of the
few properties located outside the City security gates. It is currently in use as a community
tennis facility, with three tennis courts in total.
Like City Hall, the property has a General Plan designation of Civic Center and a zoning
designation of Public Facilities (PF). Neither of these designations permits housing, so a
General Plan amendment would be required to facilitate residential development. The site is
owned by the City of Rolling Hills. Parking for the tennis courts is provided on the City Hall
property to the east.
The site could potentially be converted to housing. At a density of 20 units per acre, it would
yield 17 units. However, the community would lose parkland, which is already in short supply,
as well as a well-used recreational amenity and gathering place. As a result, no rezoning is
recommended.
4.5.4 Los Angeles County Fire Station (APN 7567-017-900)
This is a 2.2-acre site owned by the County of Los Angeles located at 12 Crest Road East. It is
currently developed with Battalion 14 Fire Station 56, which provides fire and rescue services
for Rolling Hills and nearby communities on the Palos Verdes Peninsula. While much of the
parcel is open space, it occupies a steep downslope and would require costly grading and
construction. Moreover, the Fire Station is an essential community asset and long-term use.
This site is also located in an area that is far from services and amenities, not served by transit,
and under the oversight of the Rolling Hills Community Association. Rezoning to allow housing
is not recommended.
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4.5.5 Daughters of Mary and Joseph Retreat Center (APN 7569-022-006)
The parcel is located on the western edge of the City, immediately west of the Rancho Del Mar
(PVPUSD) site. It is outside the western City gatehouse at 5300 Crest Road and forms part of
the 8-acre Daughters of Mary and Joseph Retreat Center, which straddles the border between
Rolling Hills and Rancho Palos Verdes. The Retreat Center consists of two parcels—a 5.95-acre
parcel located entirely in Rancho Palos Verdes that contains the buildings, gardens, and a
portion of the parking lot, and a 1.96-acre parcel located entirely in Rolling Hills that contains
parking, landscaping, and unimproved property.
The parcel has a General Plan designation of Very Low Density Residential and is zoned RAS-2.
These designations would allow a single dwelling unit on the site. A General Plan Amendment
and rezoning could be considered to allow multi-family housing on the property, or on a portion
of the property. The unimproved portion of the site is about 0.67 acres, which could hypo-
thetically support 13 units if developed at a density of 20 units per acre. This area has a 15-30
percent slope and would require grading to support multi-family construction. The flatter portion
of the site (i.e., the parking lot) is larger and would be easier to develop but is currently in active
use.
The City has had prior conversations with the Retreat owners regarding the possibility of
housing on this site. While there are no plans to redevelop the property, it remains a potential
long-term opportunity.
4.5.6 Conclusions
Based on the analysis above, only the Rancho Del Mar site is considered a viable housing site at
this time. Consistent with the General Plan and Zoning amendments completed in 2021, the site
is viable for 16 units of low/very income housing.
4.6 Accessory Dwellings
The City of Rolling Hills has estimated the potential for 40 ADUs and JADUs over the eight-year
planning period, or approximately five (5) ADUs per year. This projection is based on the
permitting of nine ADUs in 2021 alone, and the implementation of Housing Element program
that encourage ADUs in the coming years. It is further based on a citywide survey conducted in
October 2020 (with a 30 percent response rate) indicating that:
• 25 percent of the survey respondents indicated they had a secondary building on their
property with a kitchen, bath, and sleeping area. Another 25 percent indicated their
home had two kitchens or an area that could be “easily converted” into an ADU.
• 24 percent of the survey respondents indicated they would consider developing an ADU
on their property now, with another 15 percent indicating they would consider this at
some point in the future.
• 8 percent of the survey respondents indicated they would rent their ADU to a tenant
while 24 percent said they would use it for a caregiver or employee and 31 percent said
they would use it for a family member.
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Extrapolating these results to the citywide total of 639 households, the results suggest that:4
• An estimated 153 households might be interested in developing an ADU on their
properties, with another 95 potentially interested at some future date.
• An estimated 51 households would rent their ADU to a tenant, 153 would be interested in
using their ADUs for a caregiver or domestic employee, and 198 would consider using
an ADU for a family member.
The survey, combined with physical characteristics of the City’s large lots and building stock,
indicate significant potential for ADU development. ADUs could be created through new
construction, conversion of existing guest houses and barns, and reconfiguration of interior
spaces in primary residences. The latter category includes Junior ADUs (JADUs), which are
often affordable to very low income tenants “by design” given their small size.
A majority of the 2020 survey respondents indicated they would use their ADU for a family
member, caregiver, or other domestic employee. A substantial number of these households
would likely pay reduced rent, or no rent at all. Some would likely meet HCD criteria for
extremely low income households.
In order to demonstrate the suitability of ADUs and JADUs to satisfy the RHNA, the City must
estimate the affordability of ADUs by income category. This requires data on occupancy and
rents. The 2020 ADU survey conducted by the City identified 12 ADU tenants, including two
extremely low income, two very low income, one low income, and seven who were moderate or
above moderate income (see Appendix C). This is based on data provided by survey
respondents and the HUD income categories by household size for Los Angeles County. The
City’s 2020 ADU survey produced only two data points for rents—one unit renting for $950 and
another for $1,500. Both of these were market-rate units with no deed restrictions.
In addition, weekly scans of Craigslist ads in 2021 identified two ADUs in Rolling Hills and two in
Rolling Hills Estates, with rents of $895 for a “basement apartment”, $1,200 (for a JADU at an
unidentified address), $1,800 (for a one-bedroom one bath “guest house”), and $3,950 for a
two-bedroom one bath, 1,000 square foot guest house. Assuming a household size of two, the
rents for these six units correspond to two very low-income units, three low income units, and
one above moderate income unit. This is a limited sample size, however, and it excludes units
that may be occupied “rent free” or without advertising.
In 2020, the Southern California Association of Governments conducted a survey of ADU rents
in multiple jurisdictions across the region. The stated purpose of the survey was to “provide
local governments with assumptions for ADU affordability that can be used to assign ADUs to
income categories for the purpose of Sixth Cycle Housing Elements.”5 The SCAG study was
organized by geographic sub-area, including one sub-area corresponding to Coastal Los
Angeles County. The survey included an estimate of the percentage of ADUs that would be
affordable to “Extremely Low Income” households, which included units that were available for
4 The numbers in the three bullets below this sentence have been developed by applying the percentages from the
survey to the total citywide housing stock. This assumes that the 192 households who responded are representative
of the 639 households that live in Rolling Hills.
5 SCAG Regional Accessory Dwelling Unit Affordability Analysis, published by SCAG in 2020
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little or no rent and were not advertised (for instance, a detached in-law unit occupied by the
elder parents of the homeowner).
The distribution identified in the SCAG survey (for Coastal LA County) was as follows:
Extremely Low: 15%
Very Low: 2%
Low: 43%
Moderate: 6%
Above Moderate: 34%
This distribution is roughly consistent with the sample taken by the City of Rolling Hills and the
survey data collected in 2020. Applied to the City’s projection of 40 units, the allocation using
SCAG’s methodology would be:
Extremely Low: 6 units
Very Low: 1 unit
Low: 17 units
Moderate: 2 units
Above Moderate: 14 units
This is equivalent to 24 lower income units and 16 moderate and above moderate units.
All of the ADUs permitted to date have been “full” ADUs, meaning they are at least 500 square
feet in size. Among the City’s Housing Element programs is an initiative to create at least five
JADUs. Given the small size of these units and the fact that they are created by repurposing
existing space, they are more likely to be affordable to very low income households, thus shifting
the distribution shown above so that more “very low” income units are produced.
In addition, based on actual production of ADUs in 2021, the City anticipates a smaller share of
“Low” income units and a larger share of “Moderate” income units. Moderate income units
represented one-third of the production in 2021, which suggests something closer to the
following distribution for 2022-2029:
Extremely Low: 7 units (occupied rent-free or at minimal charge)
Very Low: 5 units
Low: 6 units
Moderate: 8 units
Above Moderate: 14 units
Housing Element programs have been developed to ensure that the City reaches its very low/
extremely low income ADU targets.
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4.7 Summary of Ability to Meet RHNA
As shown in Table 4.3 below, the combination of recently approved housing units (expected to
be occupied in 2022), future affordable units on the Rancho Del Mar site, and new ADUs can
accommodate the RHNA allocation in all income categories. The table illustrates a surplus
capacity of seven lower income units based on projected ADU production over the planning
period.
Table 4.3: Summary of Housing Opportunities, 2021-2029
Income Category TOTAL
Extremely Low/
Very Low Low Moderate
Above
Moderate
Approved Development -- 2 3 7(*) 12
Vacant Residential Lots -- -- -- 20 20
Rancho Del Mar site (**) 8 8 -- -- 16
Accessory Dwelling Units 12 6 8 14 40
TOTALS 20 16 11 41 88
RHNA 20 9 11 5 45
Surplus/ Deficit 0 +7 0 +36 +43
Adequate Sites? YES YES YES YES YES
Source: Barry Miller Consulting, 2021
(*) includes 3 new homes and 4 large ADUs, see Table 4.1.
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4.8 Opportunities for Energy Conservation
Home energy costs, including electric and natural gas utility bills, are considered part of monthly
housing expenses. The large floor area of many Rolling Hills homes suggests that this may be
an important consideration in the city. Home energy bills can be substantial, particularly for
senior households on fixed incomes. Government Code Section 65583(a)(7) requires the
Housing Element to include an analysis of opportunities for residential energy conservation and
reduced energy costs.
The US Department of Health and Human Services provides funding for a program known as
the Low-Income Home Energy Assistance Program (LIHEAP). In California, the program is
administered by the Department of Community Services and Development. LIHEAP is aimed at
assisting low-income households that pay a high portion of their incomes to meet their energy
needs. This is achieved through one-time financial assistance grants covering the utility bills of
eligible households, an energy crisis intervention program to help low-income households in
danger of having their utilities turned off, free weatherization and energy efficiency upgrades to
qualifying households, and energy education and budget counseling. Low income customers
are also eligible for reduced rates through the California Alternative Rates for Energy (CARE)
and Family Electric Rate Assistance (FERA) programs.
Southern California Edison (SCE) and the Southern California Gas Company offer energy
conservation and assistance programs. These include home energy audits, rebates on energy-
efficient appliances, and weatherization assistance to qualified low-income companies. SCE has
an energy management assistance program for qualifying households.
While the measures above are aimed at meeting day to day utility bills, there are also more
systemic long-term ways to reduce home energy costs. Nearly half of the homes in Rolling Hills
were built before 1960, many without consideration given to the cost and availability of energy.
Weatherization and insulation can provide significant reductions in home energy use and reduce
monthly utility bills. Replacement of older appliances can likewise provide significant long-term
savings. A variety of rebates and other financial incentives are available for homeowners.
In addition, all new construction in California is subject to State building code and energy
standards, including Title 24. These requirements apply to most remodeling projects, creating
opportunities to retrofit older homes. The standards are periodically updated to reflect new
technology and targets for reducing greenhouse gas emissions. The latest standards
incorporate the California Green Building Code, including energy-saving design standards for
walls, ceilings, and floor installations, as well as heating and cooling equipment and systems, gas
cooling devices, window glazing, and the use of renewable energy sources such as solar
energy. These standards are incorporated in Title 15 of the Rolling Hills Municipal Code (the
Building Code).
The City also encourages the use of solar panels to maximize energy efficiency, as well as the
application of passive solar design principles that reduce heating and cooling costs. These
measures include home orientation and siting, landscaping to reduce direct sunlight, placement of
windows to support home heating and cooling, the use of skylights, and incorporation of overhangs
and shade structures. In addition, home energy costs can be reduced by incorporating some or all of
the measures listed below:
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• Solar heating for swimming pools
• Flow restrictors on hot water faucets and showerheads (to reduce natural gas use)
• Tankless water heaters
• Attic ventilation systems that reduce attic temperatures during summer months.
• Insulation, caulking, and weatherstripping to guard against heat gain in the summer and
prevent heat loss in the winter. These measures can reduce energy use for air-conditioning
up to 55 percent and for heating as much as 40 percent.
• Proper maintenance and use of stoves, ovens, clothes dryers, washing machines,
dishwashers, and refrigerators.
• Purchase of air-conditioning units and refrigerators on the basis of efficiency ratings (the
State prepares a list of air-conditioning and refrigerator models that detail the energy
efficiency ratings of the product)
Indoor and outdoor lighting also impacts home energy costs. The City has adopted standards
for outdoor lighting through its Municipal Code (Section 17.16.190(E)). Energy efficient lighting
is required in most cases, and outdoor lighting is prohibited in many instances to retain dark
skies and the community’s rural character. For interior spaces, the costs of lighting can be
reduced through purchase of light bulbs which produce the most lumens per watt, avoidance of
multi-bulb mixtures, and use of long-life bulbs and clock timers.
As a member of SCAG, the City also participates in the Regional Comprehensive Plan to
achieve a sustainable future. The City also has joined ICLEI, which is a membership association
of local governments committed to advancing climate protection and sustainable development.
Rolling Hills also is a participant in the South Bay Cities Council of Governments Environmental
Services Center. The Center serves as a clearinghouse for information on energy efficiency,
renewable energy, and sustainability. It assists residents, businesses, and public agencies with
incorporating energy-saving practices in their daily lives and operations.
Water conservation provides another opportunity to reduce home utility costs. The City has
adopted a Water Efficient Landscape Ordinance (Chapter 13.18 of the Municipal Code), and
encourages the use of low-flow plumbing fixtures and products to reduce water use.
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4.9 Financial Resources
This section of the Housing Element summarizes financial resources for affordable housing in
Rolling Hills. An overview of federal and State programs, as well as tax credit programs, is
provided below.
4.9.1 Federal Programs
A major source of housing assistance in many communities is the Community Development
Block Grant (CBDG) program (including the Los Angeles County Urban County CDBG program,
which provides federal funds to about 50 participating small cities). Rolling Hil ls no longer
participates in this program, as the cost of its administration made it infeasible. When the City
did participate, it received approximately $6,000 per year. The City transferred these funds to
Rancho Palos Verdes, an adjacent city which has a population roughly 25 times larger than
Rolling Hills.
Opportunities for funding through other federal programs is limited. For example, the federal
Home Investment Partnership (HOME) program is designed to increase home ownership and
affordable housing opportunities for low and very low-income Americans. The funds are
distributed to jurisdictions based on need. They support programs such as loans to assist low-
income families with down payments to purchase homes, tenant-based rental assistance,
rehabilitation of affordable housing, and relocation assistance for low-income tenants. The high
cost of land and construction, limited opportunities for home ownership, absence of a sewer
system, and very high incomes in Rolling Hills, make the City non-competitive for these
applications.
Likewise, HUD’s Section 202 program provides funding for construction, rehabilitation, and
acquisition of structures for supportive housing for very low-income seniors. It offers interest-
free capital advances, as well as rental assistance funds. The funds are provided to private and
non-profit organizations and consumer cooperatives and are highly competitive. Use of these
funds in Rolling Hills is constrained by the community’s natural hazards, lack of infrastructure,
and high land costs. The use of project-based federal Section 8 funding for new affordable
housing and substantial rehabilitation of existing housing is infeasible in Rolling Hills for these
same reasons.
The federal government also operates the Section 8 Housing Choice Voucher Program. This
program assists very low-income families, the elderly, and the disabled in securing housing in
the private market. Participants may choose any housing that meet the requirements of the
program. A housing subsidy is paid directly to the property owner, and the tenant pays the
difference between the actual rent charged and the amount subsidized by the program.
Housing choice vouchers could potentially be used on ADUs, but this is rarely done in practice.
HUD also operates the Section 203(k) program, which facilitates the rehabilitation and repair of
single-family residential properties by insuring homeowner loans for purchase or refinancing. It
can enable homebuyers to purchase homes that need significant repairs and can also be used
for a variety of other improvements. These funds can also be used to enhance accessibility for
people with disabilities, and to eliminate health and safety hazards. Eligibility for this program in
Rolling Hills is limited due to the factors cited earlier.
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Other HUD programs include Section 811 Supportive Housing for Persons with Disabilities
(interest-free capital advances, operating subsidies, and/or project rental assistance for eligible
projects developing affordable housing for persons with disabilities) and the Federal Housing
Finance Agency’s Affordable Housing Program (AHP). These programs are most viable in areas
with lower land and development costs, as well as available infrastructure and services.
4.9.2 State Programs
The State of California provides resources for affordable housing construction, rehabilitation, and
assistance. Many of these programs are oriented toward populations in need of assistance or
housing stock requiring repair or rehabilitation. The absence of these populations, coupled with
the cost of land and construction in Rolling Hills and the excellent quality of the Cit y’s housing
stock, render the City ineligible for many types of assistance. The only site where State financial
resources could likely be feasible is the PVUSD site, given that it is publicly owned and has
infrastructure and public street access.
In 2017, the State approved SB 2, which established a $75 recording fee on real estate
documents to increase the supply of affordable homes in California. The State subsequently
established the Local Early Action Planning (LEAP) grant program which provides funding for
local planning activities aimed at supporting housing production. In 2020, the City of Rolling
Hills received a $65,000 LEAP grant, which was used to fund preparation of the Housing
Element. The City may be eligible for future planning grants and other SB 2 funds that facilitate
housing affordability and promote projects and programs to implement the Housing Element.
The California Housing Finance Agency (CHFA) provides loans for construction of affordable
housing projects and could be a source of revenue for future affordable housing development in
the Rancho Del Mar Overlay Zone. The State provides a pre-development loan program for low-
income housing projects, and low-interest long-term deferred payment loans through the Multi-
Family Housing Program. These sources could potentially be used on the PVPUSD site. CHFA
also provides financing for rehabilitation of housing by low- and moderate-income households,
which would generally not be viable in Rolling Hills due to housing conditions, costs, and local
income levels.
The State Department of Housing and Community Development provides funding for a variety of
programs to prevent homelessness and assist those who are unhoused. These programs can
fund construction of shelters and provide direct subsidies to individuals. HCD programs also
help support supportive and transitional housing.
4.9.3 Resources for the Private and Non -Profit Sectors
The primary affordable housing financing resources for the private and non -profit sectors are
tax credits and mortgage revenue bonds. Developers can also take advantage of various state
regulatory tools, such as density bonuses and reduced parking requirements for projects
incorporating affordable units.
The federal Low Income Housing Ta x Credit (LIHTC) Program was created by the Tax Reform
Act of 1986 to provide an alternate method of funding affordable housing. Each state receives
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a tax credit based on its population—that credit is then used to leverage private capital into
new construction or acquisition and rehabilitation projects. The California Tax Credit Allocation
Committee (TCAC) competitively administers credits to projects based on priorities they set
each year. Once constructed, a specific percentage of the units must remain rent-restricted,
and occupancy of those units is limited to people meeting specific income criteria.
The California Public Finance Agency administers an Affordable Housing Bond program,
which provides developers with access to tax -exempt bonds to finance lower-income multi-
family and senior projects. A qualified developer can finance a project at a lower interest rate
because the interest paid to bond holders is exempt from federal income tax. This program is
often done in tandem with tax credits.
Individual home buyers may also be eligible for Mortgage Credit Certificates (MCC), working
through a lender and the Los Angeles County Development Authority. This program provides
a federal tax credit for income -qualified homebuyers equivalent to 15 percent of annual
mortgage interest. Generally , the tax savings are calculated as income to help buyers qualify
to purchase a home. Buyers in Rolling Hills would generally be ineligible due to the very high
income required to purchase a home in the city.
4.9.4 Summary of Prospective Financing Sources
Due to the City’s small population, low density, very high fire hazards, and lack of infrastructure,
government resources for housing are extremely limited. The City’s residents are generally
ineligible for State and federal housing assistance based on income and home ownership status.
The City does not have a housing department, and has no regular local, state, or federal
revenue source for housing. The use of traditional approaches to financing affordable housing
are also limited by the relatively small number of units that would be contained in an individual
development project in the city.
Despite these constraints, the City is amenable to exploring future funding sources and
supporting applications that would facilitate housing rehabilitation and development. Given the
absence of a sewer system in the city, one of the most important financial resources potentially
available to the City is State and federal funding for sanitary sewer and storm drainage
improvements. The City is continuing to pursue grants to extend sewer service and improve
water quality; this could potentially create future housing opportunities on sites that are not
viable today.
Low-income housing tax credits could be considered to facilitate housing on the PVPUSD site.
Eligible projects on this site could also use State density bonus provisions, thereby increasing
the potential number of units. Other programs that could be considered include those that assist
lower income seniors with energy conservation, septic system improvements, and minor home
repair.
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5.0 Constraints to Housing Production
5.1 Introduction
Government Code Sections 65583(a)(5) and (6) require the Housing Element to contain an
analysis of governmental and non-governmental constraints on the maintenance, improvement,
and development of housing for all income levels. Governmental constraints include land use
controls, building codes and code enforcement practices, site improvement requirements, fees
and other exactions required of developers, local processing and permit procedures, and any
locally adopted ordinances that directly impact the cost and supply of residential development.
Non-governmental constraints include the availability of financing, the price of land, the cost of
construction, requests to develop at densities below what is allowed by zoning, community
opposition, and similar factors.
In each case, the Housing Element is required to demonstrate local efforts to remove constraints
that are identified, thus improving the City’s ability to meet its Regional Housing Needs
Allocation. The extent to which these constraints are affecting the supply and affordability of
housing in Rolling Hills is discussed below, along with past (or proposed future) efforts to
eliminate those constraints.
5.2 Governmental Constraints
Governmental constraints include activities imposed by local government on the development of
housing. These activities may impact the price and availability of housing, the ability to build
particular types of housing, and the time it takes to get housing approved and constructed.
While these requirements are intended to improve housing quality and protect public safety,
they may have unintended consequences.
5.2.1 Rolling Hills General Plan
Every city and county in California is required to adopt a General Plan for its long-term
development. This Housing Element is actually part of the General Plan but it stands on its own
as a separate document since it is updated on a schedule set by the State of California. The
other elements of the General Plan are updated as needed. Most cities update their plans every
15 to 20 years.
Most of the Rolling Hills General Plan was drafted in 1990. In addition to the Housing Element,
the Plan includes a Land Use Element, a Circulation Element, an Open Space/ Conservation
Element, a Safety Element, and a Noise Element. An update to the Safety Element was
prepared concurrently with the Housing Element, in response to recent State requirements.
The Rolling Hills Land Use Element includes a Land Use Policy Map illustrating the types of uses
permitted throughout the city. When the Map was adopted in 1990, it reinforced existing parcel
patterns and responded to the infrastructure, geologic, wildfire, and environmental constraints in
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the city. Four categories are shown: Very Low Density Residential (2 acres per unit), Low
Density Residential (1 acre per unit), Civic Center, and Publicly-owned Open Space.
Prior to 2020, the City did not allow development at densities greater than one unit per acre and
had no General Plan provisions for multi-family housing. As part of 5th Cycle Housing Element
implementation, the City amended its Land Use Element to add the Rancho Del Mar Housing
Opportunity Overlay designation to the Map (corresponding to the 31-acre Rancho Del Mar
school site). At the same time, the City adopted new Land Use Element standards and policies
allowing multi-family housing in the Overlay area, along with policies allowing a diverse mix of
housing units, as required by state law.
The Land Use Element recognizes Rolling Hills’ heritage as an equestrian community comprised
of large lots on steep terrain. Its policies call for buffering between uses, preservation of views,
and minimizing exposure to landslides, wildfires, and other hazards. These policies remain
appropriate given the safety hazards in the community. The Element specifically discusses the
150-acre Flying Triangle landslide hazard area, noting that the area is subject to a moratorium
due to unstable geologic conditions. It also notes that many existing parcels are constrained by
steep slopes and have only small areas that are suitable for building pads and construction.
Recent amendments to the Safety Element further emphasize environmental hazards in the city,
as well as constraints associated with evacuation, water supply, and emergency vehicle access.
These constraints make most of Rolling Hills poorly suited for additional development or zoning
changes that would result in increased density and population.
As it currently stands, the General Plan is not a development constraint.
5.2.2 Zoning Standards
The Rolling Hills Zoning Ordinance (Chapter 17 of the Municipal Code) implements the General
Plan and provides objective development standards for all parcels in the City. There are three
zoning districts in the City:
• Residential Agricultural Suburban 1 (RAS-1), which has a one-acre minimum lot size
• Residential Agricultural Suburban 2 (RAS-2), which has a two-acre minimum lot size
• Public Facilities (PF)
The RAS-1 zone roughly corresponds to the “Low Density Residential” General Plan designation
The RAS-2 zone roughly corresponds to the “Very Low Density Residential” General Plan
designation.1 The PF zone corresponds to the “Civic Center” General Plan designation. Parcels
with a General Plan designation of “Publicly-owned Open Space” are zoned RAS-1 or RAS-2,
whichever is prevalent on private parcels in the vicinity.
There are also two overlay districts. Overlays are mapped “on top” of one of the three base
zones listed above and apply additional regulations specific to subareas of the city. The first
overlay district (OZD-1) provides more lenient setback standards in an area of the city
characterized by smaller lots. Roughly 70 lots along Middleridge Lane, Williamsburg Lane,
Chesterfield Road and Chuckwagon Road, are covered. The second overlay district (RDMO) is
1 Parcels along Spur Lane and Cinchring Road have a General Plan designation of Very Low Density Residential but a zoning
designation of RAS-1.
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the Rancho Del Mar Overlay, which is mapped on the Rancho Del Mar School site in the RAS-2
district. The RDMO requires the transfer of General Plan density for the property as a whole
(which yields 16 units) to a single location in order to facilitate the production of multi-family
housing. This overlay also includes objective standards for multi-family housing and emergency
shelter, which are permitted by right.
The zoning ordinance includes definitions of terms (Chapter 17.12). At this time there are no
definitions of transitional and supportive housing, both of which must be permitted in every
residential district under state law. An action program in this Element has been included to
make that Code amendment. The definitions expressly acknowledge manufactured and mobile
homes as being the same as detached single family dwellings, provided they are located on a
foundation.
The zoning regulations indicate permitted and prohibited uses in each zoning district. Single
family residences and accessory dwelling units are permitted “by right” in RAS-1 and RAS-2.
The only expressly prohibited uses are short-term rentals (less than 30 days), commercial
cannabis activities and cannabis dispensaries. Numerous types of accessory structures are
permitted by right, including stables, pools, sheds, and small (under 200 SF) cabanas, guest
houses, pool houses, garages, greenhouses, and similar structures. Such structures generally
require conditional use permits when they exceed 200 SF (accessory dwelling units are
excluded from this requirement). Other conditional uses include schools, fire stations, and
similar public buildings and utilities. Site plans are required when development is proposed.
Table 5.1 summarizes the development standards in the RAS-1 and RAS-2 zones, starting with
the minimum lot size requirements of one acre and two acres. The Code states that existing
parcels of record that are smaller than the minimum lot size requirements are considered to be
conforming. Minimum dimensional standards are established for new lots, including the ratio of
width to depth and a requirement for a minimum width of 150 feet. There are also standards for
minimum street frontage, keeping in mind that most streets are private and contained within
easements. These standards are more flexible on cul-de-sacs, depending on turning radius.
As indicated in Table 5.1, building coverage is limited to 20 percent of the net lot area in both the
RAS-1 and RAS-2 zones. Total impervious surface coverage (structures and hardscape) is
limited to 35 percent of the net lot area; maximum disturbed area is limited to 40 percent of the
net lot area; and building height is restricted to one story. The code identifies 2:1 (50%) as the
maximum buildable slope. A minimum dwelling size of 1,300 square feet is established for the
primary unit on the site. The Code includes setback standards of 50’ for front and rear yards,
and 20’ for side yards in RAS-1 and 35’ for side yards in RAS-2. Lower standards apply in the
OZD-1 overlay zone and exceptions are provided for lots along street easements.2
The zoning code affirms the one-story construction requirement established by the Rolling Hills
Community Association (the RDM Overlay area is subject to a two-story requirement). The
finished floor of structures must be no more than five feet above grade. Basements are
permitted and storage areas may be located above or below a story. The code also provides
standards for graded building pads and requirements for stables and corral sites.
2 The City is currently developing standards to implement SB 9, which allows the division of existing lots into two parcels and the
construction of two dwellings on each parcel, subject to specific objective standards and other considerations.
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Table 5.1: Summary of Rolling Hills Zoning Standards(1)
RAS-1 RAS-2 OZD overlay
Minimum Lot Size 1 acre 2 acres N/A
Setbacks
Front 50’ from front easement line (2) 30 feet from front
roadway easement
Side 35 feet (3) 20 feet (3) 20 feet, reduced to 10’ for
street side yards
Rear 50 feet
Structure Coverage (4) 20%
Impervious Surface Coverage 35%
Building Pad Coverage 30%
Maximum Disturbed Area 40% of net lot area (excl. easements)
Maximum Height One-story
(1) Standards for the RDM Overlay Zone and standards for ADUs are addressed in Section 5.3.2 of the Housing
Element.
(2) Most property is Rolling Hills is subject to easements varying in width around each property boundary and road
easements, granted by the property owner to the RHCA, a private corporation, or another person or entity for the
purpose of construction and/or maintenance and use of streets, driveways, trails, utility lines, drainage facilities, open
space, and/or a combination of these uses. The RHCA requires that all easements must be kept free of buildings,
fences, plantings or other obstructions.
(3) Reduced to 20’ in RAS-2 and 10’ in RAS-1 and OZD if there is a private street along the side property line.
(4) The percentage figures in Table 5.1 apply to the “net lot area” on each parcel, which excludes these easements.
Additional standards in the Zoning Code prohibit reflective outdoor siding, limit outdoor lighting
(to maintain dark skies), and require Class “A” roofing. Conditions are established for specific
accessory uses, such as greenhouses, pools, and playgrounds. This includes a requirement
that guest houses (which are different from ADUs) may not exceed 800 square feet. Whereas
guest houses may not be rented and typically require a conditional use permit, ADUs are
permitted by right and subject to different standards (see P. 5-5).
A minimum of two garage parking spaces are required for each single family dwelling unit. An
additional space is required for homes with guest houses (as noted above, guest houses are
treated differently than ADUs). Homes are also required to have driveways, which are generally
limited to 20 feet in width and one per lot, though exceptions apply. The parking requirement is
not a development constraint and is appropriate given the size of parcels, the high number of
automobiles per household3, and the fact that the streets lack sidewalks and are too narrow to
permit on-street parking. There is also no public transit service in the city.
3 The 2015-2019 US Census American Community Survey indicates that 63% of all households in Rolling Hills own
three or more vehicles.
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The development standards in Table 5.1 do not present constraints to the construction of single
family homes. Even a “small” substandard lot of 200’ x 200’ (40,000) square feet would be
allowed 16,000 square feet of buildable area after required setbacks are subtracted. The
allowable structure coverage on such a lot would be 8,000 square feet, providing more than
enough space for a residence and detached accessory structures. The requirement for single-
story construction has not constrained single family construction, given the ample building
footprint accommodated on each site. In fact, single-story construction has enabled many older
adults in Rolling Hills to age in place.
State law also requires the Housing Element to include an analysis of requests to develop
housing at densities below those anticipated in the sites inventory. No such requests have been
received in Rolling Hills, as development typically occurs on existing lots rather than through
subdivision or multi-unit construction.
5.2.3 Standards for Different Housing Types
Section 65583 and 65583.2 of the Government Code require cities to plan for a “variety of types
of housing, including multi-family rental housing, factory-built housing, mobile homes, housing for
agricultural employees, supportive housing, single room occupancy units, emergency shelters,
and transitional housing.” Accordingly, the Rolling Hills Housing Element includes provisions for
each of these housing types in the city, with the exception of housing explicitly reserved for
agricultural employees, since this was not identified as being a need in the city.
Accessory Dwelling Units
An Accessory Dwelling Unit—or ADU—is an attached or detached dwelling unit that provides
complete independent living facilities for one or more persons and is located on a lot with a
proposed or existing primary residence. ADUs are commonly known as in-law units, second
units, or granny flats. A “Junior” Accessory Dwelling Unit (or JADU) is an ADU that it is no more
than 500 square feet in size, contained entirely within the footprint of an existing or proposed
single family dwelling, and has an efficiency kitchen. JADUs often have their own bathrooms but
they may also share bathrooms with the primary residence. State law now requires that all cities
and counties permit ADUs and JADUs meeting certain standards “by right”—in other words,
without a public hearing or discretionary approval.
Prior to 2018, ADUs and JADUs were not permitted in Rolling Hills. However, the zoning
regulations allowed the construction of non-rentable guest houses for family members, visitors,
and domestic employees on all residential properties. The large size and high value of
properties in Rolling Hills has supported the development of guest houses in the past, resulting
in a large inventory of structures that could potentially be converted from guest houses to ADUs
in the future. The city also has a large number of accessory structures such as barns, pool
cabanas, studios and workshops that could be converted to ADUs. Because of the single story
construction requirement, there are also a substantial number of homes with floor plans
conducive to Junior ADUs, as many homes have wings, additions, or rooms that could easily be
partitioned as independent living units.
In January 2018, the City Amended Chapter 17.28 of the Municipal Code to allow for the
construction of Accessory Dwelling Units and Junior Accessory Dwelling Units (ADUs and
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JADUs). Consistent with State law (Government Code 65852.2 and 65852.22), the City allows
ADUs and JADUs ministerially (e.g., without a discretionary public hearing) provided the units
meet specific standards and design criteria established in the zoning code. The City has also
created a discretionary review path for projects that do not meet these standards.
Chapter 17.28 establishes that an ADU and JADU may be allowed with a simple building permit
if it is within the space of an existing single family dwelling or accessory structure, including an
allowance for up to 150 additional square feet for ingress and egress. The unit must also have
exterior access independent of the single family dwelling and side and rear setbacks that meet
building and fire codes. In addition, detached ADUs are permitted with a building permit (and no
additional permit) if they are 800 square feet or less, no more than 16 feet tall, and have side
and rear setbacks of at least four feet.
A second permitting path has been created for units that are between 800 and 1,000 square
feet. Such units require an ADU Permit, which like the building permit is issued ministerially,
with no discretionary review. These units are subject to a size limit of 850 square feet for a
studio or one bedroom and 1,000 square feet for a two-bedroom unit. If attached to the primary
dwelling, the unit is subject to a requirement that it may not exceed 50 percent of the floor area
of the existing primary dwelling. The ADU may not cause the lot coverage on the property to
exceed 50 percent or cause the FAR to exceed 0.45. Setback standards also apply.
The City’s ADU ordinance incorporates State standards for parking, which waive parking
requirements for JADUs and units created by converting habitable accessory structures.
Parking is also waived for units near public transit stops or car-share vehicles. This is generally
not applicable in Rolling Hills, since the community is not served by transit or car-share services.
Per State law, the Code allows for carports and garages to be converted to ADUs without
replacement parking. Where this situation does not apply, one space is required for each ADU,
and tandem parking is permitted.
ADUs are subject to general requirements, such as fire sprinklers (if the unit is in the primary
residence) and a prohibition on short-term rentals (less than 30 days). They are also subject to
permit streamlining requirements, including a requirement to act on the application within 60
days after it is deemed complete. This time period may be extended at the applicant’s request,
or if the ADU is located within a new single family dwelling on the lot. The City allows both the
ADU and the primary residence to be rented, although there are limitations on renting JADUs if
the primary residence is not owner occupied.4 The City’s Ordinance also prohibits the sale of an
ADU separately from the lot and primary dwelling.
ADUs are also subject to basic architectural standards, including compatibility with the design of
the primary dwelling. This is objectively quantified, for instance by specifying that the roof pitch
must match the primary dwelling, and that the entry be on the side or rear elevation. The ADU
is also subject to a minimum length and width standard of 10 feet, and a minimum ceiling height
of seven feet. Landscape screening requirements apply to units that are near adjacent parcels.
If the ADU changes the building exterior or involves a new structure, it is subject to design
review by the Rolling Hills Community Association Architectural Committee (see next section for
further discussion).
4 JADUs (units created within the floorplan of an existing home) are subject to an owner-occupancy requirement
unless the property is owned by a government agency, land trust, or housing organization.
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ADUs smaller than 750 square feet are exempt from all impact fees. Units larger than 750
square feet may only be charged impact fees that are proportionally related to the square
footage of the unit. The Code also includes waivers for utility connection fees for most ADUs,
thereby reducing construction and operating costs. Moreover, the Code provides the option for
a conditional use permit for ADUs that do not conform to the basic development standards of
Chapter 17.28.
Overall, these requirements do not constrain or inhibit ADU or JADU construction. The
regulations reflect State regulations and create ample opportunities for homeowners to earn
extra income while providing a new dwelling unit for a tenant, employee, caregiver or family
member. Given the large lot sizes in the city, the setback standards, FAR standards, and lot
coverage limits still allow for generous ADU footprints. Likewise, the single story requirement is
consistent with the requirement for single family homes. The “bonus” 150 square feet for JADU
ingress/egress creates an incentive for such units. The requirement to provide a parking space
is consistent with State law, since there is no transit in Rolling Hills—and is not a constraint given
the large lot sizes and substantial driveway space available on most lots.
While no constraints have been identified, there are opportunities to provide incentives for ADUs
that have yet to be realized. Because of recent changes to State law, there are opportunities for
ADUs to be conveyed separately or operated by non-profits and/or affordable housing
providers. As noted in Chapter 6, the City will pursue future programs to encourage ADU
construction, including ADUs for very low and low income households. This includes creating a
roster of ADUs and an inventory of units that meet “extremely low income” needs by providing
housing for family members, domestic employees, or other long-term occupants.
Additionally, State law for ADUs was amended in 2020 and 2021. Several provisions in the
City’s regulations must be updated for consistency. This includes eliminating the prohibition on
ADUs with more than two bedrooms, and adding a provision that completed applications be
deemed approved if they are not acted upon within 60 days. The City will work with the State
Housing and Community Development Department to determine if there are other provisions of
the ordinance that require updating. Program 6.10 in Chapter 6 identifies this as a high priority
action, to be completed by October 15, 2022.
Multi-Family Housing
In February 2021, the City amended its General Plan and zoning regulations to allow multi-family
housing within the City limits. This was a key implementation measure in the Fifth Cycle
Housing Element. New policies in the General Plan Land Use Element expressly support a
range of housing types in the city, including multi-family housing. Chapter 17.19 of the
Municipal Code creates the Rancho Del Mar Overlay (RDMO) Opportunity Overlay Zone, which
has the following objectives:
• Create “by right” opportunities for multi-family housing
• Implement state laws that require cities to demonstrate available land capacity and zoning to
accommodate the City’s current and projected need for housing
• Facilitate well-designed development projects
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• Encourage development that provides attractive features that integrate the public realm with
development on adjacent private property.
The zone is mapped on the 31-acre Rancho Del Mar school site, which as noted in Chapter 4
and Appendix B, is the most viable location for multi-family housing in Rolling Hills. The zone
allows 16 units of multi-family housing on the site (excluding potential density bonus units), with
a requirement that this housing be constructed at a density of 20 to 24 units per acre. The 20
unit per acre minimum density requirement corresponds to the “default density” under AB 2348,
while the 16-unit requirement is based on the number of units permitted by the underlying
General Plan and RAS-2 zoning designations. It is also a threshold used by HCD to identify
viable housing sites.
Affordable multi-family housing is permitted by right in this zone, provided it is affordable to low
and very low-income households and meets objective design standards that are included in the
zoning code. These include minimum dwelling unit sizes of 250 square feet for a studio, 400
square feet for a one-bedroom, 650 square feet for a two-bedroom, and 900 square feet for a
three-bedroom. Higher minimums had been proposed initially but were lowered to the adopted
standards based on direction from HCD that the above figures would not constrain development.
As noted above, the allowable density range for the Zone is 20-24 units per acre. Numerous
projects—both market-rate and affordable—have been developed in this density range in Los
Angeles County in recent years. The range can accommodate apartments, condominiums,
townhomes, row houses, clustered units, manufactured homes, and small detached cottages.
All of these housing types would be permitted under the regulations prescribed by the Overlay
Zone.
Development standards for multi-family housing within the Overlay Zone are conducive to higher
density construction. These standards require 5-foot front and side setbacks and a 10-foot rear
setback. Encroachments such as decks, balconies, awnings, porches, and stairways may
extend into the setback areas, and architectural features such as eaves and cornices are also
permitted in the setbacks. There are no lot coverage standards or Floor Area Ratio limits. A 28’
height applies, allowing two-story construction. This is the only place in Rolling Hills where two-
story construction is permitted.
Development is subject to a requirement that 100 square feet of common open space be
provided for each dwelling unit. Thus a 16-unit project would be required to set aside 1,600
square feet of shared open space, which is equivalent to about 5 percent of the development
site (assuming a density of 20 units per acre). When drafting the Ordinance, the City initially
proposed a common open space standard of 150 square feet per unit, but this was reduced to
100 square feet during HCD’s review of the draft to eliminate the potential for a constraint.
One parking space per unit is required, plus one guest parking space for every 10 units. For
senior housing, one space per unit is required for the first 10 units, and 0.5 spaces per unit are
required for any additional units. The RDMO zone allows surface parking, with no requirements
for garages or carports. At 180 square feet per parking space, the total area dedicated to
parking in a 20 unit per acre project would be 3,240 square feet, or about nine percent of the
site. Even with driveway lanes, the total area of the site required for parking would be small.
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Moreover, the ordinance includes provisions for reduced parking where certain conditions exist
(shared parking agreements with nearby uses, available street parking, etc.).
No parking is permitted in the 20’ front setback area (at the driveway location). This would not
be a constraint given the large size of any parcel that would be created in the future to
accommodate multi-family development. Moreover, the front yard setback for structures is only
five feet, which creates more space for the building envelope and encourages parking to be
placed to the rear or side of the parcel, potentially within the setback.
The development standards require that multi-family housing be located at least 50 feet from the
toe of the slope associated with a hillside area within the Overlay District. Figure 5.1 shows the
sloped area and indicates that the linear distance between the toe of the slope and the access
road serving the multi-family development site is 337 feet. Thus the area where structures are
acceptable extends 287 linear feet back from the access road (minus a 5-foot front setback).
While the rear 50 feet may not include structures, it could include open space and other
amenities, including parking and driveways. The 50’ setback does not affect parcel width (i.e.,
the east-west dimension), and still leaves room for a substantial development site on the
property.
Because affordable multi-family housing is permitted by right in the Overlay Zone, the City has
adopted objective design standards to ensure that new development is compatible with adjacent
uses. These address residential frontages (facades, etc.), usable open space standards, public
space amenity requirements, and operational standards. Such standards have the potential to
create a development constraint if they are too onerous or add to the cost of housing.
Figure 5.1: Slope Setbacks on PVUSD Site
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The residential frontage standards require that the ground floor be no more than five feet above
the ground surface. This is easily attained, since the site is relatively flat. The standards
establish a 10’ floor to floor height, which is consistent with the overall 28’ height limit as well as
typical residential construction standards and interior ceiling heights. Entrances and windows
are required along the front façade, and entrances to individual units may either be direct to the
exterior, or to an interior hallway. Stoops and porches may be located on the exterior, and
projecting elements (bay windows, eaves, balconies) may extend into setback areas. Street
tree, landscaping, and lighting requirements apply, but these do not constrain development.
The usable open space standards likewise do not represent a constraint. These requirements
call for an amenity such as a children’s playground or clubhouse in multi-family projects. The
amenity may be indoors or outdoors and may not include parking areas, streets, or driveways.
Projects are also expected to include amenities such as pedestrian walkways, landscaping, bike
storage racks, and screened trash enclosures, and would need to comply with building code
standards for interior noise. These are common requirements in California communities and do
not represent a constraint.
Mobile and Manufactured Homes
As required by State law, the City Zoning Ordinance allows for manufactured housing units to
reduce residential construction costs. Section 17.12.130 of the Rolling Hills Municipal Code
defines manufactured homes and mobile homes as “single family dwellings”; as such, they are
subject to the same standards as wood-frame construction.
Emergency Shelters
Every city in California is required to identify a zone where at least one year-round emergency
shelter is permitted without a conditional use permit or other discretionary permit (Govt Code
Section 65583(a)(4)(A)). The Government Code further requires that emergency shelters be
subject to the same standards that apply to residential and commercial development in that
zone, except that certain objective standards prescribed by the State may apply.
In February 2021, the City of Rolling Hills amended its zoning regulations to permit emergency
shelters “by right” in the Rancho Del Mar Overlay (RDMO) Zone. Rolling Hills has adopted
standards for shelters that meet the requirements of the Government Code and facilitate
emergency shelter construction or conversion. The RDMO Zone encompasses over 31 acres of
public property, most of which is underutilized. There are opportunities to create shelters by
converting existing buildings, constructing new buildings, or using temporary facilities such as
portables or tiny homes. This use is permitted by right, with no discretionary permit required by
the City. There are no limitations on where shelters may locate within the boundary of the
RDMO Zone. Since shelter beds do not constitute “dwelling units”, an emergency shelter would
not be considered part of the 16 dwelling units permitted by the Overlay Zone and would not
affect the number of allowable multi-family units in the Zone.
The City submitted preliminary standards to HCD for review in December 2020 and
subsequently revised those standards to ensure that they are compliant with the Government
Code and do not present a constraint to emergency shelter development. The adopted
standards include:
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• Shelters must be at least 300 feet apart, as allowed by the Government Code Shelters
may be 300 feet apart, consistent with Government Code 65583(a)(4)(A)(v)
• One parking space for each staff person must be provided. There are no supplemental
parking requirements based on the number of beds. The requirements are consistent
with Government Code 65583(a)(4)(V)(A)(ii) and are no greater than those that apply to
other land uses and activities in the RDMO zoning district.
• A maximum of 12 beds applies. This is comparable to the maximums that apply in
nearby cities, including those with unsheltered populations.
• 50 square feet of personal living space is required for each occupant, excluding common
areas.
• The standards allow, but do not require, shelters to include a dining room, commercial
kitchen, laundry room, recreation room, child care facilities, and support services (the
Code indicates these may be provided, but they are not mandatory)
• At least five percent of the shelter area must be dedicated for on-site waiting and intake,
and an equivalent (or larger) area is required for exterior waiting
• Shelters must comply with building code, plumbing code, and trash enclosure
requirements—the same standards that apply to other uses in the Overlay Zone and in
the underlying base RAS-2 Zone.
Consistent with the Government Code, an application to operate an emergency shelter requires
submittal of a management and operations plan that addresses hours of operation, staffing
levels, maximum length of stay, and security procedures. The application would require
approval by the City Administrator, based on satisfaction of the conditions listed above and
review for compliance with Building, Fire, and other applicable regulations.
The regulations do not constrain emergency shelter development and are compliant with
Government Code requirements. As they were just put into effect in 2021, the City will monitor
their effectiveness over the 2021-2029 planning period to determine if changes are needed.
Single Room Occupancy (SRO) Hotels
In February 2021, the City of Rolling Hills amended its zoning regulations to allow Single Room
Occupancy (SRO) housing in the RDMO Zone. These are facilities with individual rooms or
small efficiency apartments designed for very low-income persons. There are no limitations on
where SROs may locate within the boundary of the RDMO Zone. A Conditional Use Permit is
required.
In December 2020, the City submitted preliminary standards to HCD for review and
subsequently revised those standards to ensure that they do not present a constraint to SRO
development. The adopted standards include:
• A minimum of six units and a maximum of eight units
• Maximum occupancy of two persons per unit
• Floor area of 250-350 square feet per unit
• Each room must include a water closet (Toilet plus sink)
• Each room must include a kitchen sink with a disposal (but not necessarily a full kitchen)
• Each unit must have a closet
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• Full kitchens (i.e., with range, refrigerator, dishwasher, etc.) and full bathrooms (with
shower/bath) may be provided in each unit but are not required. If these facilities are not
included in each unit, then shared facilities are required on each floor.
• 0.5 parking spaces are required per unit, plus one space for each employee on duty
• Occupancy is for 30 days or more
The City initially proposed including a requirement for 24-hour on-site management, and a
requirement for elevators in the event the building was two stories. Both of these requirements
were removed following HCD’s feedback that they were potential constraints. Requiring 24-hour
management requirement could be a constraint for a 6-8 unit facility. As a result, on-site
management is not required on a 24-hour basis. Given that the building would only be two
stories, the requirement for elevators was removed. Since SRO rooms would not be classified as
independent “dwelling units”, they would not be considered part of the 16 units permitted by the
Overlay Zone and would not reduce the number of allowable multi-family units in the Zone.
Supportive, Transitional, and Employee Housing
Supportive housing is a type of rental housing that includes on-site services such as medical
assistance or treatment of chronic health conditions or disabilities. Transitional housing is a type
of supportive housing but is specifically intended for unsheltered residents who are transitioning
to permanent housing. Supportive and transitional housing is not associated with a specific
structure type—single family homes can be used in this manner, and so can multi-family
buildings.
Government Code Section 65583(a)(5) requires cities to treat transitional and supportive
housing as residential uses that are only subject to those restrictions that apply to other
residential uses of the same type in the same zone. In other words, a City cannot hold a single
family home used as supportive housing to a different standard for parking, setbacks, floor area,
etc. than a single family home occupied by a family or other type of household.
Public Health and Safety Code Section 17021.5 requires the City to treat employee housing for
six or fewer people the same as other single family housing in each zoning district. For example,
if a corporation in another city purchased a home in Rolling Hills and allowed its employees to
live there, the use would be treated like any other single family home.
Rolling Hills presently has no Code language that limits transitional, supportive, or employee
housing or imposes any special restrictions on such housing. However, these housing types are
not expressly acknowledged in the Municipal Code. The 2021-2029 Housing Element includes
an action item to add definitions of transitional, supportive, and employee housing to the
Municipal Code within six months of Housing Element adoption, acknowledging that such
housing is permitted or conditionally permitted in the same manner as other residential
dwellings of the same type in the same zone, as required by State law.
Housing Constraints for Persons with Disabilities
Government Code Sections 65583(a)(4) requires the Housing Element to include “an analysis of
potential and actual governmental constraints upon the maintenance, improvement of
development of housing…for persons with disabilities. AB 686 also requires the City to
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affirmatively further fair housing, which includes housing that meets the needs of persons with
disabilities.
In November 2020, the City Council approved reasonable accommodation procedures,
including application requirements, review procedures, findings, and provisions for noticing and
advertising the opportunity. These procedures establish a process through which persons with
disabilities can request reasonable accommodations (or modifications) to the City’s codes, rules,
policies, practices or services so that they have an equal opportunity to enjoy or use a dwelling.
The City has also adopted a resolution recognizing the Americans with Disabilities Act, including
a commitment to assist disabled residents.
A request for reasonable accommodation may be made by any individual with a disability, his or
her representative, or a developer or provider of housing for individuals with disabilities, when
the application of a land use, zoning, or building regulation, policy, practice, or procedure acts
as a barrier to fair housing opportunities. The City has posted notices at City Hall informing the
public of its right to make such a request, including application forms for those making a
request. Requests are generally made to the City Manager.
Once a completed application is received, the City Manager has 45 days to make a written
determination. Additional information may be requested of the applicant in order to make an
informed determination. An alternative solution to the one proposed by the applicant may be
considered if it would reduce impacts and still achieve the intent of the request.
The request is granted, with or without conditions, if the City Manager finds that the housing will
be occupied by an eligible individual, the requested accommodation is necessary to provide the
individual with equal opportunity to use and enjoy a dwelling, the requested accommodation
would not impose an undue financial or administrative burden on the City, or fundamentally alter
the City’s zoning or building laws or undermine the General Plan, and there are no other
reasonable accommodation methods that would allow the applicant to enjoy the dwelling that
would be less impactful on the surrounding area.
Conditions of approval may be replaced on the application. These may include periodic inspection
to verify compliance, recordation of a deed restriction requiring removal of the improvements when
it is no longer needed, time limits, measures to reduce off-site impacts, and measures that respond
to the unique physical attributes of the property. Decisions may be appealed.
Rolling Hills has adopted the Los Angeles County Building Code. As long as construction is
consistent with the Building Code, residents are permitted to provide any disabled access or
amenity improvements necessary to reduce barriers. Access to homes via ramps is permitted.
One-story construction throughout the community removes a major barrier for persons with
disabilities and facilitates access for persons with mobility limitations. Accessibility
improvements, universal design changes, and other accommodations for persons with
disabilities are processed administratively in conjunction with the building permit process and
are permitted in both of the City’s residential zones.
No constraints to housing for persons with disabilities were identified in this analysis. As noted
in Chapter 3, the city’s large population of older adults requires ongoing efforts to facilitate
retrofitting of existing homes for residents with physical limitations, and their caregivers.
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Residential Care Facilities and Definition of “Family”
The Lanterman Developmental Disabilities Services Act requires that small licensed residential
care facilities for six of fewer clients be treated as regular residential uses and permitted by right
in all residential districts. Care facilities with seven or more clients (e.g., “large” residential care
facilities) may be subject to additional requirements but must be treated the same as other
residential uses in that zoning district. Cities that require conditional use permits for large
residential care facilities are required to mitigate this constraint in their housing elements.
Rolling Hills complies with this requirement in practice and has no minimum distance
(separation) or siting requirements for residential care facilities. However,
At this point in time, the Rolling Hills Zoning Code does not expressly mention or define small
residential care facilities, nor does it distinguish between “large” and “small” facilities. It The
Code should be amended to expressly indicate that this use is permitted by right in all zones
where housing is allowed, and is subject to the same standards, fees, and procedures as other
residential uses in those zones. This is required by State law. . As required by California Health
and Safety Code Section 1566.2, the City does not collect business taxes, registration fees, or
other fees for small residential care facilities.
The Rolling Hills Municipal Code includes a definition of “family” in its zoning regulations. Overly
restrictive definitions may pose a housing constraint, but in this instance the definition is broad
and inclusive. According to the Rolling Hills Municipal Code, “family” means:
“one or more persons living as a single housekeeping unit, as distinguished from
a group occupying a boarding, rooming or lodging house, hotel or club. Family
may include domestic servants.”
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5.2.4 Cumulative Impacts of Land Use Controls
State law requires the City to consider not only the impact of individual development standards,
but also the cumulative effects of these standards on the cost and supply of housing. For example,
it is possible that a particular setback requirement may appear reasonable on its own b ut may
limit development opportunities when combined with height and lot coverage limits. Sometimes,
the combined effect of different development controls can require more expensive construction
or result in frequent zoning variances.
Because of the very large lot sizes in Rolling Hills, the zoning standards do not create an adverse
cumulative impact on development costs or the housing supply. As previously noted (pages 5-2
and 5-4), a special zoning overlay (OZD-1) was created in 2012 to recognize that some parts of
the city have prevailing lot sizes that are smaller than the one-acre minimum required by the RAS-
1 district. Roughly 10 percent of the City’s parcels are covered by this zone, which allows reduced
setbacks in order to avoid the need for zoning variances.
As noted earlier, the combination of front, rear, and side yard setbacks on a rectangular one-acre
lot would still allow for a buildable area of over 16,000 square feet. Most parcels are considerably
larger than one acre and have buildable areas that exceed 20,000 square feet. FAR and lot
coverage limits likewise allow ample structure coverage, and homes larger than 10,000 square
feet can be built without Variances on most lots. The one-story height limit tends to produce
building footprints that are quite large—but still within the 20% structure coverage requirement.
Each residence is required to have two covered parking spaces (three, if an ADU or guest quarters
are on-site). This requirement is modest given the typically large home size and does not
constrain building construction.
The land use controls also do not present a cumulative constraint to ADU construction. Almost
every parcel in the City has the land area or existing built floor area to support an ADU, and
many homes already have spaces that could be easily converted to ADUs. The ADU and JADU
regulations adopted in 2018 and revised in 2020 were drafted to work in tandem with the
controls for the RAS-1 and RAS-2 districts and have laid the foundation for substantial ADU
production.
There are no cumulative land use constraints to multi-family development. The Rancho Del Mar
Overlay (RDMO) Zone standards have been tested to ensure they are internally consistent and
can support housing in the 20-24 unit/acre range. The RDMO Zone allows multi-family housing
to be either owner or renter occupied. New housing units in this zone must be affordable. The
affordability requirement is not a constraint to development, as the site is publicly owned and
represents a unique opportunity for reduced land and construction costs. There are no
comparable opportunities in the city, as this is the only property in Rolling Hills that is flat,
vacant, served by public sewer, and walking distance from public transit.
One notable omission from the City’s zoning regulations a provision for density bonuses. State
law requires that the City offer a density bonus for projects that set aside various percentages of
units for affordable housing, senior housing, and other types of special needs housing. The
number of bonus units is based on a sliding scale and can be up to 50 percent above the base
density permitted by zoning. For projects where all units are affordable to low and very low
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income households, the density bonus rises to 80 percent. A density bonus could be requested
for the Rancho Del Mar site, since the overlay requires that any multi-family housing is 100
percent affordable. This would allow 28 units on the site instead of the 16 allowed by the
General Plan and zoning.
The Housing Element includes a program recommendation that the City amend the Municipal
Code to adopt density bonus provisions or adopt the State provisions by reference.
5.2.5 Building Code Standards
The City of Rolling Hills adopted the Building Code for Los Angeles County in effect on January
1, 2020 as its Building Code. A number of local amendments to the Code were made. This
includes an allowance for the City Council to hold a public hearing to review decisions of the
County Board of Appeals, Code Enforcement Appeals Board, or Building Rehabilitation Appeals
Board. Other local amendments include a modified definition of “basement” (to avoid the
appearance of multi-story buildings), adjusted provisions for grading and cut slopes, limits on
driveway slope, and limits on developing slopes over 50 percent. The City has also adopted the
Los Angeles County Plumbing Code, Mechanical Code, Electrical Code, Residential Code, Fire
Code, and Green Building Code.
Effective July 1, 2008, all land in the City of Rolling Hills was deemed to be a “Very High Fire Hazard
Severity Zone” (VHFHSZ). As a result, several more restrictive fire safety standards have been
adopted. The City also has adopted standards for hours of construction, and requirements for geological
surveys and investigations.
5.2.6 Permit Processing Times and Approval Procedures
Processing and permit procedures can be a constraint to the production and improvement of
housing due to the time they add the development process. Unclear permitting procedures,
layered reviews, multiple discretionary review requirements, and costly conditions of approval
can increase the cost of housing, create uncertainty in the development process, and increase
the financial risk assumed by the developer.
In Rolling Hills, the time required to process a project varies depending on the size and
complexity of the proposal, and the volume of projects being reviewed. Not every project must
complete every possible step in the process. In addition, certain review and approval
procedures may run concurrently.
For smaller projects, permit processing times tend to be faster than in most cities.
Administrative review applications (i.e., those that do not require public hearings) typically take
only a few days to process. However, the City’s capacity is limited, requiring that some permit
processing functions are contracted out. Even smaller projects that are approved ministerially
typically require review by the Rolling Hills Community Association and the Los Angeles County
Building and Safety Department, in its role as the contracted building authority of the City.
The City collects no fees for over the counter review—such fees are assessed when the project
is submitted to the Department of Building and Safety. Administrative review processes have
been created for residential additions less than 1,000 square feet, accessory dwelling units and
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junior accessory dwelling units, remodels, foundation repair, and re-roofing. Such projects are
required to submit two sets of plans, various checklists, and calculations of existing and
proposed square footage, lot coverage, and impervious surface coverage. The City’s website
provides comprehensive information for applicants seeking permits, including on-line portals for
applications, payment, and checking progress on permit status.
Larger projects such as new homes take longer, but they are less common. New homes in
Rolling Hills are multi-million dollar projects that often require demolition, site preparation and
grading, and new driveways before construction may begin. Larger projects may also require
review by the LA County Health Department for the adequacy of the septic system, and the Fire
Department for fuel modification.
Unless specifically exempted by State law, large projects such as new homes and residential
additions of 1,000 square feet or larger are subject to Site Plan Review. An initial consultation
with staff is strongly encouraged at the start of the process. Once an application is received, it is
reviewed for completeness, including required calculations, elevations, and site plans. When the
application is deemed complete, it is forwarded to the Planning Commission for a hearing,
including a recommendation from staff. The Planning Commission conducts an initial project
review meeting, a field trip, and a meeting to forward the application to the City Council.
Likewise, the Council conducts an initial meeting, a field trip, and a meeting to forward the plans
to the Rolling Hills Community Association (RHCA).
The Site Plan review process typically takes three to six months from start to finish, including a
field trip by Planning Commissioners to the project site at the start of the process. The process
may be completed in a single hearing but on occasion may take two to three hearings so that
issues raised by the Commission and public can be addressed. Additionally, project applicants
may modify their site plans after approval and return to the Commission for approval of major
revisions.
The Planning Commission has the authority to approve Site Plan Review applications. The
decision of the Commission is considered final unless an appeal is filed with the City Council or
the City Council decides to take the application under its jurisdiction. The decision becomes
effective 30 days after the adoption of the resolution.
Approval of a Site Plan Review application requires findings related to compliance with the
General Plan and adopted lot coverage standards, preservation of topography and vegetation,
grading that follows natural contours or does not adversely modify natural drainage channels,
the use of drought-tolerant landscaping, impacts to pedestrian movement, and compliance with
CEQA.
The Planning Commission does not expressly perform design review as part of this process, as
its findings are principally related to address public health, safety, and welfare. Design review
occurs privately, through the Rolling Hills Community Association (RHCA). The RHCA has an
Architectural Committee that reviews plans for new homes and large additions to ensure that
easements are kept free and clear of structures, including fences and other obstructions.5
5 School District and City-owned property is exempt from this requirement. Thus, any development in the RDMO
Housing Opportunity Zone would not be subject to RHCA review.
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Projects are submitted to LA County Building and Safety following RHCA review. RHCA
maintains its own design guidelines, covering such topics as roofs, walls, windows, doors, and
lighting. Because RCHA is a non-governmental agency, these guidelines are described later in
this report under non-governmental constraints (see discussion of CC&Rs on page 5-22).
Projects that require Variances to development standards or Conditional Use Permits (CUPs)
also require Planning Commission hearings. CUPs are required for large horse stables and
corrals, detached garages, tennis courts, and a number of other large-footprint site features.
From start to finish, the process from submittal of plans to approval of permits may take six
months or longer for a brand new home. Applications for ADUs, major remodels, residential
additions, and accessory structures are more common, and are processed more rapidly. ADUs,
JADUs, and other ministerially approved projects take approximately two to four weeks to
process.
The City regularly seeks ways to expedite processing and improve the timeliness of its services.
At the present time, permitting and processing time is not considered a constraint and the City
complies with the time limit requirements established by Sections 65943 and 65950 of the
Government Code. The Site Plan Review requirements and other permitting requirements are
not a constraint to the development of multi-family or affordable housing as they would not apply
to projects on the Rancho Del Mar site nor would they apply to ADUs that meet the City’s adopted
standards. As such, they have no impact on the cost, supply, timing, or approval certainty of these
projects. For new single family homes, the review requirements result in processing times that
may take several months. However, they do not affect the supply approval certainty. In a review
of applications over the past eight years, only one application was denied (requesting a height
modification to approved addition in 2017) and another application had a partial denial (for stairs
and walls, in 2014).
5.2.7 Site Improvement Requirements
The principal site improvements required upon development of a vacant property are the
undergrounding of electrical lines to the structure, installation of a septic system, and
conformance to the City’s outdoor lighting standards. Road and emergency access (fire safety)
improvements may be required for properties that do not have street frontage or have other
access constraints. New development in Rolling Hills consists almost entirely of custom homes
on existing vacant or previously developed lots, rather than subdivision of “raw land,” which
tends to reduce overall improvement requirements. At the Rancho Del Mar affordable housing
site, installation of curb and gutter improvements would be required prior to development, but
the site already has road access, storm drainage, and water and sewer facilities in place. There
would be no special or unique site improvement requirements imposed on development of this
site.
Projects requiring the subdivision of land would be subject to the standards set forth by the
City’s subdivision regulations, which are specified in Title 16 of the Municipal Code. These
standards establish a 24-foot road width for streets. A 32-foot turning radius is required on
dead-end streets, and grades may not exceed six percent. The standards recognize that all
streets in Rolling Hills are private. The City Council has the discretion to require additional site
improvements adjacent to sites where land is being subdivided, including widening existing
roads to meet neighborhood traffic and drainage needs. The subdivider may also be required to
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provide drainage improvements, in accordance with standards set by the City Engineer and with
the city’s MS4 permit (see P 5-26). The subdivision ordinance further specifies that water mains
and fire hydrants may be required when new lots are created, and that easements for gas and
electric services may be required.
The cost of installing a new septic system is generally not a constraint for brand new homes but
can be an impediment for ADUs and smaller additions, particularly for homeowners with limited
incomes. At minimum, the County Health Department requires a feasibility study for any project
that could result in septic tank capacity being exceeded. Older homes may face costly septic
installation requirements that could render a home addition or ADU infeasible. Programs to
assist lower income or senior homeowners with septic tank replacement could be considered,
particularly where an ADU is being added.
5.2.8 Development and Permitting Fees
Fees are charged by the City and other agencies to cover the costs of processing permits and
providing services and facilities, such as utilities, schools, and infrastructure. Most of these fees
are assessed through a pro rata system based on the square footage or value of the project, the
staff time required for processing, and the magnitude of the project’s impact. If fees become
excessive, they can become a constraint on development and make it more difficult to build
housing affordably. They can also place a burden on lower income homeowners seeking to
modify their homes or add an Accessory Dwelling Unit.
A summary of residential development fees charged by the City of Rolling Hills is presented in
Table 5.2. Most projects do not require payment of these fees, as they would not typically
require use permits, Variances, Zoning changes, General Plan amendments, CEQA review, lot
line adjustments, and so on. However, Site Plan Review is commonly required for all new
homes and major additions, and ADU permits are required for larger ADUs. For projects
complying with City standards and requirements, the fees are not a development constraint.
Table 5.2: City of Rolling Hills Major Development Fees1
Fee Type Fee Amount Notes
Site Plan Review $1,500
Conditional Use Permit $1,500
Variance $1,250
Minor Variance
$750 Encroachments from main
structure that do not extend
more than 5’ into required
setbacks
Zoning Change or Code Amendment $2,000
General Plan Amendment $2,000
Accessory Dwelling Unit application $375
Major Remodel Review $375
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View Impairment Review
$2,000 Processing fee for Committee
review of impacts on trees and
views
Water Efficient Landscape Review $1,500 Unused balance refunded
Traffic Commission Review $300 Required for new driveways
Lot Line Adjustment $1,500 Plus County fee
Tentative Parcel Map $1,500 Plus County fee
Final Parcel Map -- County fee only
Environmental Review Determination $200 Plus Fish and Game Fee
Environmental Impact Reports Consultant fee
plus 10%
Only required as needed
Appeal Fee 2/3 of original
application fee
Only required as needed
Source: City of Rolling Hills, 2021. Barry Miller Consulting, 2021
1 This is not a comprehensive list of all fees but covers the major development-related categories in the City’s fee
schedule. The fee schedule also covers records searches, inspections, and review of grading plans.
Rolling Hills is one of 13 cities that contracts with the Los Angeles County Department of
Building and Safety (LACDBS) for plan checking, building permits, and building inspection. The
County issues building, plumbing, mechanical, and electrical permits on the City’s behalf. The
cost schedules for the incorporated cities served by LACDBS are higher than the schedules for
the unincorporated area but are comparable to nearby cities with full-service building
departments. A residential project with an assessed valuation of $100,000 would be subject to a
plan check fee of $3,413 and a permit fee of $4,029. This includes required energy and
disabled access checking costs. As the value of a project increases, the fees decline as a
percentage of total project costs. They represent 7 percent of a $100,000 project but less than
5 percent of a $500,000 project.
The fee schedules for other permits varies by type. Electrical permits are subject to a base fee
of $74.70, plus a cost per square foot ($0.20/SF for multi-family and $0.50/SF for single family
and duplexes). Separate fees are collected for swimming pools, branch circuits, lighting
fixtures, appliances, and electrical plan checking. Mechanical permits are collected for HVAC
systems, compression units, boilers, refrigeration systems, etc. Plumbing permits are based on
the number of fixtures and also cover projects requiring connection to septic tanks and work
such as solar water heaters, sprinkler systems, and backflow protection devices. Relative to the
other 12 cities that contract with Los Angeles County, the fee schedule in Rolling Hills is slightly
higher. However, the fees are lower in Rolling Hills than in nearby Rolling Hills Estates.
The County also collects fees for projects requiring geotechnical review. This would apply to
most new housing units in Rolling Hills. The fee ranges from $2,752 to $17,746, with the actual
amount based on 0.50% of the value of the proposed structure. Additional fees are charged for
geotechnical site inspections and geotechnical review of grading plans.
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Los Angeles County typically updates its fees annually based on the consumer price index and
other factors. The increase in 2021 was 2.2 percent for all cities served by the County. Rolling
Hills updates its fee schedule less frequently, although fees are considered as part of the annual
budgeting process. Some of the City’s fees—such as the fees for parcel maps and lot line
adjustments—have not been updated in many years.
There are no local surcharges or special fees associated with multi-family housing. On a per unit
basis, permitting costs would be substantially lower for multi-family units than for new single family
units. This is due to the smaller size of multi-family units and to multi-family housing being
permitted “by right” within the Rancho Del Mar Overlay Zone, with no applicable administrative
fees. The City’s fee structure has not historically distinguished between single and multi -family
construction, as multi-family housing only recently became a permitted use.
A number of other fees apply in Rolling Hills; these are typically associated with new residences
and are intended to offset the additional cost of providing services. These include:
• A Park and Recreation Fund Fee, which is equivalent to 2% of the first $100,000 in
building evaluation, plus an additional 0.5% of the remaining balance. The fee for a $1
million construction project would be $6,000. This fee is only charged for new primary
homes---ADUs are exempt.
• A School Impact Fee, which is paid to the Palos Verdes Unified School District. In
2020, the fee was $3.79 per square foot for new residential construction.
• A fee collected by the Rolling Hills Community Association (RHCA), equivalent to $0.20
per $100 of assessed valuation (i.e., $2,000 for a project with a construction value of
$1,000,000)
• Additional architectural review fees collected by the RHCA, including a $165 flat fee
plus $1 per square foot for new construction, additions and major remodels. In
addition, RHCA collects fees ranging from $25 to $500 for individual features such as
swimming pools, tennis courts, gazebos, and new roofs.
There are no sewer connection fees in the city, since there are no sewers. There is no water
connection fee; water service charges are determined by the size of the meter and the number
of fixtures, plus the amount of water used. The City likewise has no impact fees for housing,
transportation, public art, or other services. Projects in the RDMO Zone would be exempt from
the RHCA fee, since they are outside the HOA boundary.
In total, fees for a typical new home are roughly equivalent to 7-8 percent of total construction
costs. This is comparable to other cities on the Palos Verdes Peninsula, though somewhat
higher than in other urbanized parts of Los Angeles County. The higher fees are associated in
part with the terrain and hazards in Rolling Hills and the size and complexity of applications for
new homes, many of which require extensive grading and multiple inspections. Fees do not
constrain development in Rolling Hills, but they do add to the cost of housing, which is already
expensive in the City. Programs to reduce processing and permitting fees for ADUs could be
considered, as they could incentivize ADU production.
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5.2.9 Other Local Ordinances and Disclosure Requirements
No other local ordinances were identified that could present potential constraints to housing
needs. The City does not have an inclusionary zoning requirement, growth control ordinance or
limits on the number of units that may be constructed in a given year, or other locally-imposed
requirement impacting the cost of residential development. The City prohibits the rental of
rooms and houses for periods of less than 30 days, effectively disallowing short-term rentals.
This supports the City’s goal of using Accessory Dwelling Units as rental housing, rather than for
transient occupancy.
The City also complies with AB 1483 (2019), which requires that agencies publish specific
information on their websites starting January 1, 2021. This information includes:
• All current fees and exactions applicable to housing
• All zoning ordinances, design and development standards
• Current and five previous annual financial reports
• An archive of nexus studies for impact fees conducted after January 1, 2018
The City of Rolling Hills maintains a Planning and Community Services landing page on its
website that contains all of this information. This landing page includes a link to all planning and
development fees, the Zoning Map, the Municipal Code (which includes the zoning ordinance
and all applicable development standards), the General Plan, the Local Hazard Mitigation Plan,
Landscape Design Standards, the Water Efficient Landscape Ordinance, Planning and
Development forms and application materials, the Planning Commission calendar, technical
information for developers (related to stormwater management), permitting requirements,
guidelines for equestrian facilities, information on solar panels and rainwater harvesting, and
guidance on septic system installation. The City is also updating its environmental programs
page. An action program in the Housing Element calls for this information to be reorganized and
updated, with new information added on Accessory Dwelling Units and links to the RHCA Design
Guidelines.
Every annual budget and audited financial report for the City since 2010 is available on the
City’s website. There have been no nexus studies for impact fees since 2018, but such studies
would be posted if conducted in the future.
Disclosure requirements related to SB 35 also apply to Rolling Hills. In 2018, California adopted
SB 35, which establishes streamlining provisions for multi-family projects meeting certain criteria
related to affordability and payment of prevailing wages to construction workers. As of 2021,
projects in Rolling Hills in which 10% of more of the units are affordable are eligible for SB 35.
Article III Section 300 (b) of HCD’s Guidelines for SB 35 requires that cities in this situation must
provide “information, in a manner readily accessible to the general public, about the locality’s
process for applying and receiving ministerial approval, materials required for an application as
defined in Section 102(b), and relevant objective standards to be used to evaluate the
application.” An action program in this Housing Element recommends creating an SB 35
information sheet and application and including it on the Planning and Community Services
Website.
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5.3 Non-Governmental Constraints
Non-governmental constraints significantly affect the affordability of housing in Rolling Hills.
Specifically, the high cost of real estate in the city, its heritage as a rural, gated equestrian
community, and its limited infrastructure and severe environmental constraints, make it
extremely challenging to build traditional affordable housing units. The city is one of the most
expensive and highly constrained communities in California. To be economically viable,
affordable housing must be tailored to community context—for example, through accessory
dwelling units.
5.3.1 Land Costs
Land in Rolling Hills is expensive. The city features dramatic topography, with sweeping views
of the Pacific Ocean and Los Angeles basin. Property in the city is marketed as a location for
prestigious estates. The supply of acre-plus homesites on the Palos Verdes Peninsula is limited,
making demand for such properties very strong. A scan of Zillow.com in Fall 2021 shows two
vacant lots for sale in the city—one for $7.5 million and another with geologic constraints for $1
million. Data on recent sales shows a vacant single family parcel that sold for $6.85 million in
November 2020 and another that sold for $1.84 million in 2019. These properties have been
marketed and sold as sites for large single family homes.
The economic viability of affordable housing on these sites is further challenged by the cost of
the site improvements that would be required to facilitate safe development. The vacant parcels
described above lack public sewer; are accessed by narrow, winding, private roads traversing
an area with very high wildfire severity; and have slopes that exceed 50 percent in some cases.
The cost of road widening, grading and earth movement, and installation of community-wide
sewer and storm drainage construction make most types of multi-family housing economically
infeasible. There is no public revenue source to make these improvements. The absence of
commercial land uses in the city limits the City’s ability to sponsor programs that would reduce
or underwrite land or site improvement costs.
5.3.2 Construction Costs
The cost of construction, including labor and materials, is a significant constraint to housing
development in Rolling Hills. While high costs have impacted the entire state, Rolling Hills is
particularly impacted by the high cost of mitigating environmental constraints, including fire and
geologic hazards. New home construction requires grading and earth movement, often with
costly retaining walls and engineered drainage systems. Many homes in the city feature high-
end finishes, as well as amenities that result in higher costs. The city is also vulnerable to
elevated or inflated costs that reflect its reputation as a high-end, high-income market.
In 2014, the Rolling Hills Housing Element estimated that construction costs were approximately
$330 to $500 per square foot. Based on recent projects in the city, costs have doubled since
then. The National Association of Homebuilders estimated that costs increased 26 percent
between June 2020 and June 2021 alone. There have been rapid increases in the price of
lumber, copper, steel, aluminum, concrete, and other building materials, resulting in some
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projects being placed on hold and others being cancelled altogether. Construction costs for
home additions now regularly exceed $800 per square foot.
Construction of septic tanks represents a unique expense in Rolling Hills that is not common in
surrounding cities. Anecdotally, homeowners in the city report costs of well over $25,000 to
install new septic systems, which in some cases can be an impediment to adding an accessory
dwelling unit or expanding an older home.
5.3.3 Financing
Financing is not a constraint to housing development in Rolling Hills, but the high cost of housing
makes it infeasible for most households to buy a home in the community. Home mortgage
interest rates were remain relatively low at the time the Housing Element was drafted, with rates
at around 3.0 percent for a 30-year mortgage in Fall 2021. Income and down payment
requirements have become more stringent than they were following the mortgage crisis of a
decade ago, and there are fewer flexible loan programs to bridge the gap between the amount
of a required down payment and a potential homeowner’s available funds.
Given the very high cost of housing in Rolling Hills, significant capital is required to purchase a
home. A 20 percent down-payment on the median priced home in the City would be nearly
$750,000, with monthly mortgage payments of nearly $19,000. A very high income would be
required to qualify. First time buyers face particular challenges in the city, given the lack of
equity from prior home ownership.
5.3.4 Delays Between Approval and Construction
Given the high cost of construction and rising interest rates, there may be delays between the
time a project is entitled and when it is actually constructed. Applicants may postpone their
projects due to high material costs, supply shortages and shipping delays, and a lack of skilled
construction workers and contractors. Rising interest rates can also add to the cost of a project,
leading to postponement. The economic uncertainty and upheaval of the COVID-19 pandemic
has also caused some projects to stall over the last two years. In some cases, projects may be
cancelled altogether, or the property may be sold to a new owner who may modify or abandon
previously approved plans.
These factors are out of the City’s control but can have a real impact on housing supply and
construction. The City is particularly interested in the completion of permitted ADUs, as these
units are critical to achieving affordable housing goals. As noted in Chapter 6, Rolling Hills
intends to establish a monitoring program for permitted ADUs to facilitate their construction.
This would include reaching out to those who receive ADU permits and monitoring construction
progress on those units. The monitoring program includes follow-up conversations with any
applicants who do not complete their projects to understand the factors leading to that decision,
and any steps the City can take to improve completion rates.
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5.3.45 Conditions, Covenants, and Restrictions (CC&Rs)
Development in Rolling Hills is controlled through both municipal zoning and privately enforced
CC&Rs. The CC&Rs are considered a non-governmental constraint because they are enforced
by the Rolling Hills Community Association (RHCA), a private entity. The CC&Rs were
established by the Palos Verdes Corporation in 1936 upon the initial development of the
community. They apply to all property in the city except the City Hall Campus, Tennis Court
Facilities, PVP Unified School District site (Rancho Del Mar), and Daughters of Mary and Joseph
Retreat Center. The RHCA does not have design review or building permit review authority on
these sites.
Elsewhere in Rolling Hills, the CC&Rs restrict the development and use of property to single
family homes and limited public uses. They do not allow multi-family housing, commercial, office
or industrial activity. One of the stated purposes of the CC&Rs is to preserve and maintain the
rural character of the community, including regulating the architectural design of structures.
The CC&Rs authorize the RHCA Board to appoint and maintain a five-member Architectural
Review Committee to carry out this objective. The Committee is comprised of three Association
members and two licensed architects.
The RHCA Board has adopted a Building Regulations manual that is used by homeowners and
their architects/ contractors, and by the Committee to evaluate projects. Committee review is
required for all new residences and accessory structures, and for all projects that modify the
exterior of existing structures. Committee meetings occur twice monthly, on the first and third
Tuesdays. The meetings are not considered “public hearings” since RHCA is not a public
agency, but they are open to all members of the Association and are subject to Association
bylaws.
RHCA’s Building Regulations require that all homes under RHCA’s jurisdiction be one-story,
ranch-style construction. The Regulations identify three permissible style types: traditional
ranch, contemporary ranch, and early California Rancho. Specific standards are provided for
each style, including allowable exterior siding materials, roof materials (and colors), roof pitch,
building height (25 feet), and floor to ceiling plate heights (8’6” maximum in at least 50 percent
of the structure). Regardless of style, all buildings must be painted white, conform to the natural
grade, and have consistently designed doors and windows. A minimum floor area of 1,300
square feet, plus a two-car garage, is required for all residences.
The regulations align with the City of Rolling Hills zoning regulations—in fact, the CC&Rs
expressly state that the Architectural Committee must comply with applicable provisions of the
Rolling Hills Municipal Code. This includes allowing Accessory Dwelling Units (ADU), which are
not mentioned in the Association’s Building Regulations. Under AB 670 and AB 68 (effective
January 2020), CC&Rs may not be used to deny ADU applications, and prohibitions on ADUs by
homeowner associations are not enforceable.
State law does allow homeowner associations to review the design of ADUs, provided their
process is fair, reasonable, and expeditious. This has been occurring in Rolling Hills for the last
three years with no adverse effects on ADU construction.
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As noted earlier in this chapter, the City has developed a ministerial process for ADU approval
as required by state law. Projects meeting the dimensional requirements in the Municipal Code
(which are consistent with State standards) are approved without a public hearing or
discretionary review by the City. If an ADU does not affect the exterior of a home (for instance,
a Junior ADU entirely within the footprint of an existing home, or the conversion of a detached
guest house to an ADU), then no RHCA review is required. The Architectural Committee does
review ADUs that modify the exterior, add square footage to a structure, or result in a new
accessory structure. The purpose of this review is to verify that the structure meets the
objective design requirements in the RHCA Building Regulations rather than to evaluate the
merits of the project or its off-site impacts. According to the Committee’s own guidelines, it “will
not require modifications to working drawings that materially change the massing of the
project.”
City staff has worked closely with RHCA staff to ensure that their design review process is
coordinated with City permitting, streamlined, and does not impose unreasonable restrictions on
applicants. The RHCA office is adjacent to City Hall and there is ongoing coordination between
the two entities. When an application for an ADU is submitted to the City, the City advises the
applicant to proceed to RHCA immediately afterwards to initiate project review. Projects are
typically forwarded to the RHCA Architectural Committee within two weeks and are typically
approved at the initial meeting; if modifications are required, the plans are typically approved at
the second meeting two weeks later. The review occurs concurrently with the City permitting
process, avoiding potential delays.
In practice, every ADU application approved by City staff has subsequently been approved by
the RHCA Architectural Committee. Nonetheless, an action program in this Element
recommends that the City work with RHCA to update the 2017 Building Guidelines to
acknowledge ADUs and provide guidance for homeowners seeking to add an ADU.
5.3.56 Infrastructure
Another factor adding to the cost of new construction is the limited availability of infrastructure,
specifically streets, sewer, storm water and water facilities.
Streets
Rolling Hills has no public roads or streets. Since the 1930s, the community’s internal street
network has been designed to establish a rural, equestrian character. This historic aspect of the
city’s infrastructure is one of Rolling Hills’ defining features. The road network is typified by
winding roads with a 15- to 25-foot paved cross-section and no curbs, gutters, sidewalks, or
streetlights. Narrow road width, coupled with steep grades and very low densities, effectively
precludes public transit within the city. Access is also gate-controlled at three entry points.
The city's circulation infrastructure is not conducive to uses generating high trip volumes, such
as higher-density housing. Given the entire city’s designation as a very high wildfire hazard
severity area, the capacity to evacuate the population is also a limiting factor. Most streets in the
community are “dead ends” without emergency vehicle access alternatives in the event that
ingress and egress is blocked.
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A number of properties—including City Hall, the Retreat Center, and the PVUSD site, are
accessed from roads outside the City gates. These parcels are less constrained by street access
but could require ingress and egress improvements (resurfacing, driveways, etc.) in the event a
change of use was proposed. Such improvements are typical for any development and would
not adversely affect expected construction costs.
Wastewater Disposal
With the exception of the school site and thirteen residences that have individually or collectively
(through the creation of a small sewer district) connected to an adjacent jurisdiction's sewer
systems, there is no sanitary sewer system in Rolling Hills. Residences are served by individual
septic tanks and seepage pits. These systems are designed to serve single family residences
and are not conducive to multi-family housing. This is particularly true given the geologic, slope,
and soil constraints in Rolling Hills. To meet water quality and runoff requirements, high-density
housing typically requires a viable sewer connection.
Over the past 35 years, the City has conducted multiple sewer system feasibility studies. In
2019, the City received approval from the Los Angeles County Public Works and Sanitation
District to discharge effluent from up to 235 existing homes in Rolling Hills. The City is in the
process of completing design drawings for Phase One, which is a 1,585-foot long 8-inch
diameter sewer line along Rolling Hills Road/Portuguese Bend Road. This will provide service to
City Hall, the RHCA offices, and the Tennis Courts. Future phases of the project could provide
service to residences but would require significant grant funding and potentially special
assessments.
In 2021, the City surveyed all households to determine the level of support for developing a
sewer system. Roughly 16 percent of the City’s households participated. The survey found that
about three-quarters of the residents’ septic tanks were more than 20 years old. More than 80
percent supported construction of a sewer system, though many responses were contingent on
the cost. Past engineering studies have concluded that the terrain and unstable geological
conditions in the city make a conventional gravity sewer system infeasible in the city, meaning
the cost to property owners could be significant.
The Palos Verdes Unified School District site is an exception. It is connected to a wastewater
treatment line that was installed when the school was initially constructed. Collection lines were
sized to accommodate a school campus with several hundred students, and associated
maintenance facilities—a higher level of demand than is associated with current uses on the
site. Given the availability of sewer service to this site and the high cost of extending sewer
services elsewhere, it is the most suitable property for multi-family housing in the City.
In some instances, septic systems may present a constraint to ADU development. This is
generally not an issue for JADUs or smaller ADUs that repurpose existing habitable space, but a
new detached ADU that adds floor space may require increasing the capacity of a septic
system. As noted earlier in this chapter, a program in this Housing Element proposes further
evaluation of this constraint, and possible ways to assist homeowners in addressing it.
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Storm Water Run-off
As a rural community without public streets, Rolling Hills does not have a municipal storm sewer
system or continuous network of storm drains. Drainage follows topography, with stormwater
flowing into steep ravines through the community. Water percolates into the ground along
canyon bottoms, with runoff flowing to the ocean, or to larger streams and detention basins
downstream, depending on location.
To comply with federal National Pollutant Discharge Elimination System (NPDES) requirements
and maintain its Municipal Separate Storm Sewer System (MS4) permit, the City is required to
screen and monitor its runoff to avoid compromising downstream water quality standards. It
also required to implement a number of programs, such as an Illicit Discharge Elimination
Program. The City also requires Best Management Practices (BMP) for construction in order to
avoid erosion, pollution, sedimentation, and runoff that would degrade water quality. These
requirements are not a development constraint but may add to the cost of construction.
Moreover, the lack of a municipal storm drainage system represents another constraint to higher
density housing in most of the city.
The Rancho Del Mar site is outside the area covered by the MS4 monitoring program and drains
west toward Rancho Palos Verdes. Unlike the rest of Rolling Hills, it is served by an improved
storm drainage system. A 2017 facility evaluation reported the storm drains and inlets on the
site as being in good condition.
Water
Water infrastructure in Rolling Hills is owned, maintained, and operated by California Water
Service (CalWater). The city is within CalWater’s Palos Verdes District, which also serves the
other cities on the Palos Verdes Peninsula. Facility planning is governed by an Urban Water
Management Plan (UWMP), which evaluates anticipated demand and the water resources
available to meet that demand.
Projections of future water use are based in part on expected population growth, which is
derived from SCAG forecasts and local general plans. Water demand is projected to increase
by 6 percent by 2045, reflecting very slow population and housing growth in the Peninsula cities.
Development beyond that anticipated by SCAG forecasts could reduce water pressure,
compromise firefighting capabilities, and curtail domestic water availability. This is a problem
throughout California, made worse by persistent drought conditions. The UWMP provides water
shortage contingency plans, including measures to reduce demand and procure emergency
supplies.
Water storage facilities and pipelines in Rolling Hills are generally adequate to meet local needs.
However, many of the city’s water facilities are aging and the system as a whole is vulnerable to
damage during earthquakes and landslides. Storage and distribution facilities reflect the rural
density of the city and are not sized to accommodate significant growth. The Palos Verdes
Unified School District site provides a unique opportunity in this regard, as its water system was
designed for a public school campus with several hundred students.
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The introduction of ADUs in Rolling Hills could potentially impact water demand in the City. The
California Water Company has no plans to upgrade the aging water system. As ADUs are
created, it will be important to consider potential impacts on water distribution lines and fire
fighting capacity. Several factors work to mitigate the impacts of ADUs on the water system.
First, the population of Rolling Hills has declined by roughly 300 since 1980. Thus, the addition
of 40 or so ADUs over eight years may not increase the total number of residents in the City.
Second, water conservation measures have been implemented—and continue to be
implemented—to reduce water flows and water demand. These measures include water-
efficient landscaping requirements, as well as requirements for more efficient plumbing fixtures.
Dry Utilities
Rolling Hills residences are also served by dry utilities. Electric services are generally provided
by Southern California Edison while natural gas is provided by Southern California Gas
Company. A range of private vendors provide phone, internet, and cable services. Capacity is
available to serve new development, and all of the vacant and underutilized sites identified in
Chapter 4 would have access to these services if they were developed. The Rancho Del Mar
site currently has access to these services as it is a former school.
5.3.76 Environmental Constraints
Rolling Hills has severe environmental constraints to development. Slopes exceeding 25
percent are present on almost every remaining undeveloped parcel in the city. Geotechnical
studies are required when new homes are constructed, and mitigation is often required to
reduce the potential for future damage. The City’s Site Plan Review Process and grading
requirements are intended to strictly limit recontouring of existing terrain. Most grading occurs
through “cut and fill” procedures that retain materials on site. This adds to local housing costs
and limits the viability of multi-family housing on most properties in the city.
Landslide Hazards
Figure 5.2 shows landslide zones in Rolling Hills, as mapped by the California Geological Survey
(CGS). Large portions of the city are considered hazardous and major slides have occurred in
the past. This includes the Flying Triangle Landslide, which has impacted roads, homes, and
properties in the southern part of the city for the last 50 years. These areas are poorly suited for
development and are susceptible to slope failure. Human modifications to slopes (through
development) can exacerbate the problem and the risk.
Building at the head of a landslide can decrease the bedrock strength along an existing or
potential rupture surface and “drive” the landslide down slope. Improper grading practices can
also trigger existing landslides. Because of these geologic hazards, the City limits land
disturbance and other actions that would exacerbate soil instability. Ground instability would
contribute to potential risks to human life as well as to physical structures. The Safety Element of
the General Plan sets forth policies to restrict new development and expansion of existing
development in areas susceptible to landslides.
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Earthquake Hazards
Like most of Southern California, Rolling Hills is vulnerable to earthquakes. Large earthquakes
can cause building damage and collapse, as well as damage to roads and utilities. The City of
Rolling Hills is crossed by the Cabrillo Fault, which is part of the Palos Verdes Fault Zone. It is
also vulnerable to earthquakes on the Whittier Fault, the Newport-Inglewood Fault, the Malibu
Fault, the Santa Monica Fault, the Redondo Canyon Fault. The location of these faults is shown
on Figure 5.3.
The Whittier and Newport-Inglewood Faults are considered capable of generating earthquakes
with magnitudes greater than 7.0 and have the potential to cause catastrophic damage. In the
event of a major earthquake on either fault, the city of Rolling Hills would be vulnerable to
ground shaking. Secondary hazards include liquefaction, earthquake-induced landslides and
differential settlement. Fault rupture is not a significant hazard in the city, and there are no
Alquist Priolo “special studies” zones within the city limits.
Wildfire
As shown on Figure 5.4, the entire city of Rolling Hills has been designated a “Very High Wildfire
Hazard Severity Zone” by CalFire. The city’s terrain creates challenges for vegetation
management and presents conditions where a fire can travel quickly up and down canyon
slopes. Despite defensible space requirements, the city’s rural nature and equestrian heritage
means that extensive areas are covered by dense scrub and brush. The Palos Verdes
Peninsula has a history of destructive wildfire, including fires that destroyed homes in 1973,
1993, 2009, and 2018.
The City has taken measures to reduce fire hazards, including preparing a Community Wildfire
Protection Plan in 2020. The Plan outlines measures to harden infrastructure, improve
vegetation management, underground electric power lines, and improve inspections and
enforcement. It also includes provisions for evacuation. Additionally, the City (and Los Angeles
County) require special building safety measures, including standards for roofing, eaves,
exterior finishes, and buffer zones that respond to the higher fire hazard levels.
Despite these measures, the risks of wildfire cannot be eliminated entirely. Moreover, the city
continues to face evacuation constraints resulting from its narrow roads, limited ingress and
egress points, and the presence of livestock on many properties.
Biological Resources
Rolling Hills supports a variety of plant and wildlife species, including some that are listed or
under consideration for listing by the U.S. Department of Fish and Wildlife and/or the California
Department of Fish and Wildlife. These species include the Palos Verdes Blue butterfly, the
California Gnatcatcher, the Pacific Pocket Mouse, the San Diego Horned Lizard, and
Brackishwater snail. Development that could adversely impact the habitat of these species must
undergo review and approval by the overseeing federal and state agencies. Typical mitigation
measures include preservation of habitat, further restricting the potential land available for
development. This constraint is likely to continue throughout the planning period.
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Figure 5.2: Landslide Hazard Areas in Rolling Hills Source: Draft Rolling Hills Amended Safety Element, 2021
Updated Map-shows Flying
Triangle Landslide Area
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Figure 5.3: Earthquake Faults in the Rolling Hills Vicinity
Source: Draft Rolling Hills Amended Safety Element, 2021
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Figure 5.4: CalFire “Very High” Fire Hazard Severity Zones
Source: Draft Rolling Hills Amended Safety Element, 2021
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6. Housing Goals, Policies, Objectives, and Programs
Chapter 6 provides the City’s housing plan for the next eight years. The plan has three
components:
• A statement of the City’s goals and policies for housing. The goals and policies balance
State mandates and Government Code requirements with local needs and priorities.
• An action program. The action program identifies the specific, measurable steps the City
will take during 2021-2029 to implement the policies.
• Measurable objectives for housing production. These objectives correspond to the
City’s Regional Housing Needs Allocation (RHNA) and also include numeric targets for
housing rehabilitation and conservation.
6.1 Goals and Policies
The following goals and policies reflect the City’s continued commitment to actively support
residential development and plan for the City’s fair share of regional housing needs:
GOAL 1: Provide housing opportunities which meet the needs of existing and
future Rolling Hills' residents.
Policy 1.1: Accommodate Rolling Hills’ share of the region’s housing needs in a way that
protects public safety, responds to infrastructure constraints and natural hazards,
recognizes market conditions, and respects the historic context and land use
pattern in the city.
Policy 1.2: Allow the development of a variety of housing types in the city, including multi-
family housing. While Rolling Hills will remain a rural equestrian community,
housing opportunities will be provided for all income groups as required by State
law.
Policy 1.3: Facilitate development on the remaining vacant buildable lots in the city in a
manner consistent with adopted zoning standards.
Policy 1.4: Allow Accessory Dwelling Units (ADUs) and Junior Accessory Dwelling Units
(JADUs) in all residential zones. Maintain objective standards to ensure that
ADUs and JADUs are compatible with the community; minimize visual, parking,
traffic, and other impacts; and respect neighborhood context.
Policy 1.5: Explore incentives to create and maintain Accessory Dwelling Units that are
affordable to low and very low income households.
Policy 1.6: Encourage the conversion of existing guest houses and other habitable
accessory buildings into legal ADUs.
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Policy 1.7: Work with other governmental entities and the non-profit community to support
the development of affordable or senior housing on the Palos Verdes Peninsula
and in nearby South Bay cities.
Policy 1.8: Maintain planning and building procedures that maximize efficiency and reduce
permit processing times and high fees. Encourage public understanding of the
planning and building processes to reduce project costs and delays.
GOAL 2: Maintain and enhance the quality of residential neighborhoods in
Rolling Hills.
Policy 2.1: Encourage and facilitate the maintenance and improvement of existing homes.
Policy 2.2: Ensure that new housing and home improvements comply with building code and
fire safety requirements.
Policy 2.3: Maintain a code enforcement program, including procedures to remediate
violations.
Policy 2.4: Require the design of home improvements, additions, ADUs, and infill housing to
minimize impacts on existing residences. Include objective standards in the
zoning ordinance that protect visual quality, privacy, and community character.
Policy 2.5: Mitigate hazards that could potentially cause a loss of housing units in the city,
including wildfires, landslides, and earthquakes. Encourage home hardening and
defensible space to minimize the potential for housing loss during a natural
disaster.
Policy 2.6 Prohibit the use of ADUs as short-term rentals in order to maintain their viability
as permanent housing units.
Policy 2.7: Encourage weatherization, energy conservation, and renewable energy to
increase energy efficiency and reduce home energy costs.
GOAL 3: Address the housing needs of older adults and others in the
community with special housing needs.
Policy 3.1: Provide reference and referral services for seniors, such as in-home care and
counseling for housing-related issues.
Policy 3.2: Support shared housing programs and room rentals as options for seniors to
remain in the community without financial hardship.
Policy 3.3: Encourage housing opportunities for live-in care givers, domestic employees, and
family members who may assist elderly or mobility-impaired residents who wish
to age in place.
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Policy 3.4: Consider participation in state and federal programs that assist lower income and
senior households in home repair and maintenance.
Policy 3.5: Strive to meet the needs of extremely low-income Rolling Hills residents,
including seniors on fixed incomes.
Policy 3.6: Encourage the retrofitting of existing Rolling Hills homes so they are accessible to
the disabled, including persons with developmental disabilities. Provide
reasonable accommodations in rules, policies, practices, and procedures for
disabled persons to ensure equal access to housing.
Policy 3.7: Participate in countywide programs to meet the needs of unsheltered residents
and others who may need emergency housing assistance.
GOAL 4: Promote housing opportunities for all persons regardless of race,
religion, sex, marital status, ancestry, disability status, or national
origin.
Policy 4.1: Affirmatively further fair housing by ensuring that housing opportunities for
persons of all income levels, races and ethnicities, and physical abilities are
available in Rolling Hills.
Policy 4.2: Enforce all applicable laws and policies pertaining to equal housing opportunity
and discrimination. Maintain third party agreements to follow-up on and correct
alleged violations.
Policy 4.3 Make information on fair housing laws available to residents and realtors in the
City by providing information on the City’s website and print media at the City
Hall public counter.
Policy 4.4: Ensure effective and informed community participation in local housing decisions.
This should include special efforts to include traditionally underrepresented
groups, including persons working or providing services in Rolling Hills.
Policy 4.5: Distribute affordable housing opportunities around the city by focusing on ADUs
as a housing strategy.
Policy 4.6: Participate in regional forums and initiatives to promote fair housing.
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6.2 Housing Implementation Plan, 2021-2029
The goals and policies set forth in the Housing Element will be implemented through a series of
housing programs. Some of these programs are already underway and others will be
implemented over the next eight years. This section of the Housing Element provides a brief
description of each program, including measurable objectives, responsible entities, and
implementation timeframes. Each of these programs has been developed consistent with HCD
guidelines and State Government Code requirements.
Program 1: Annual Progress Report
As required by State law, the City will prepare and file an annual report on the progress made
toward implementing its Housing Element using forms and definitions adopted by the California
Department of Housing and Community Development (HCD). Guidance on the content of the
report is provided by the State Office of Planning and Research. It documents the City’s
progress toward meeting its share of regional housing needs and efforts to remove government
constraints to housing production. The report must be presented to the City Council prior to its
submittal (it may be approved as a consent item).
Quantified Objective: Provide one report per year
Funding Source: City General Fund
Responsible Agency: Planning and Community Services Department
Implementation Time Frame: File by April 1 of each year
Program 2: Rancho Del Mar Opportunity Site Monitoring
In February 2021, the City adopted the Rancho Del Mar Overlay Zone on the 31-acre Rancho
Del Mar (RDM) campus owned by the Palos Verdes Unified School District. As documented in
Chapter 4 and Appendix B of this Housing Element, large parts of the RDM site are unimproved
and vacant. The new zoning permits 16 affordable multi-family units on the site, which may be
developed “by right” at a minimum density of 20 units per acre.
The City Manager will meet at least once annually with the School Superintendent to discuss the
future of the site, including future development opportunities. Next steps to be pursued on the
site include:
• Exploring the feasibility of sSubdividing the site to create a separate parcel west of the
PVPTA transit facility. This site could potentially be more easily marketed as a
development opportunity than the 31-acre site as a whole.1
• Preparation of a “fact sheet” for the site, for review by the School Superintendent and
School Board, highlighting the potential for multi-family housing
• Further discussions with the School Board regarding opportunities for teacher housing
and/or senior housing on the site.
1 Subdivision is not required to develop the site—it can also be developed “as is” in 2022. However, subdivision could provide an
incentive for future development during the planning period.
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• In collaboration with the School District, make information on the site (e.g., the “Fact
Sheet”) available to affordable housing developers.
• Further discussions with non-profit developers regarding the opportunity to construct
housing on the site, including technical assistance to developers where requested.
• Consideration of permit streamlining, CEQA clearance, and fee reductions for future
affordable housing development on the site. Multi-family housing is already permitted
“by right” subject to objective design standards adopted in February 2021, but further
steps could be taken to reduce future development costs.
Quantified Objectives: (1) 16 units of affordable housing on the RDM site
(2) Annual meeting between the City Manager and School
Superintendent
Funding Source: City General Fund
Responsible Agency: City Manager
Implementation Time Frame: Once annually, beginning in 2021
(1) Meeting with School Superintendent by end of 2022 and once
annually thereafter
(2) Preparation of site “fact sheet” for review by School District
and School Board by June 2023
(3) Subdivision creating “western” parcel by end of 2023, subject
to School Superintendent and Board approval
Program 3: No Net Loss Monitoring and Other Multi-Family Housing Opportunities
The City has identified adequate capacity to accommodate 45 units of housing, as required by
the Regional Housing Needs Allocation. Sixteen of these units are on the Rancho Del Mar Site.
Five are new single family homes on vacant lots (three of which are already approved). The
remainder are Accessory Dwelling Units. Rolling Hills will continue to maintain General Plan and
zoning designations that facilitate development of the required number of units and will continue
to comply with the Housing Accountability Act in the event projects are proposed.
SB 166 (2017) requires that every city maintain “adequate sites” to accommodate its RHNA by
income category at all times during the eight-year Housing Element period. If a designated
housing opportunity site becomes unavailable, the city must demonstrate that it still has
adequate capacity on its remaining sites (e.g., “no net loss”). In the event the Rancho Del Mar
site becomes unavailable to produce the housing units envisioned by the overlay zone, the City
would need another suitable site to accommodate those units.
Cities generally meet the no net loss mandate by providing one or more “buffer” sites in addition
to their primary sites. These sites must meet HCD criteria, including the ability to accommodate
16 units at a density of at least 20 units per acre. As demonstrated in Chapter 4, due to the lack
of sewer and the community’s natural hazards, Rolling Hills does not have a buffer site available.
The City will continue to explore potential housing sites that could supplement the RDM site,
particularly where sanitary sewer service could be made available in the future. The City will
continue to rely on accessory dwelling units to meet the balance of its lower-income housing
assignment, regardless.
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Quantified Objectives: No net loss of housing capacity to meet RHNA at all times
Funding Source: City General Fund/ Permitting Fees
Responsible Agency: Planning and Community Services Department
Implementation Time Frame: Continuous through 2029
Program 4: Add Definitions of Transitional and Supportive Housing, Residential
Care Facilities, and Employee Housing, to Municipal Code
To comply with Government Code Section 65583(c)(3), the City of Rolling Hills must clarify that
residential care facilities, transitional housing, and supportive housing are considered residential
uses and are subject to the same restrictions that apply to the other residential uses that are
allowed in a given zoning district. In other words, a single family home used as a group home
for persons with disabilities is subject to the same planning and zoning requirements that apply
to a single family home used by a traditional family. Most local governments have addressed
this requirement by adding definitions to their zoning codes for transitional and supportive
housing, as well as large and small residential care facilities.
The purpose of this program is to add those definitions to the Rolling Hills Municipal Code
(Chapter 17). The definitions would acknowledge that such housing is permitted or conditionally
permitted in the same manner as other residential dwellings of the same type in the same zone
as required by State law. The Code amendments will ensure that no special requirements are
placed on residential care facilities with seven or more occupants, as required by State law.
Definitions of small licensed residential care facilities (for six of fewer residents) and low barrier
navigation centers also will be added to the Code and referenced in other zoning regulations, as
required by State law.
This program also includes a Municipal Code Amendment to add a definition for employee
housing in accordance with the California Health and Safety Code (HSC). HSC Section 17021.5
states that employee housing providing accommodations for six or fewer people shall be
deemed a single family structure with a residential land use designation. It further states that
employee housing may not be considered a boarding house, rooming house, hotel, dormitory,
or similar term that implies that such housing is a business run for profit or differs in any other
way from a single family dwelling. State law precludes a city from requiring a conditional use
permit, zoning variance or other zoning variance for such housing, and stipulates that the use of
a single family dwelling for six of fewer employees does not constitute a change of occupancy
for building code purposes.
Quantified Objectives: Council Action Adopting Definitions
Funding Source: City General Fund
Responsible Agency: Planning and Community Services Department/ City Attorney
Implementation Time Frame: Complete by December 2022
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Program 5: Density Bonus Ordinance
Section 65915 of the California Government Code establishes mandatory statewide provisions
for density bonuses for affordable and senior housing projects. Rolling Hills does not currently
have density bonus provisions in its Municipal Code. Historically, the City has not had multi-
family housing, nor any site where multi-family housing could be constructed. With the creation
of the Rancho Del Mar Overlay Zone, a developer could request a density bonus and related
concessions from a developer. State standards would apply in this instance. The City should
adopt provisions in its Municipal Code acknowledging the applicability of State density bonus
laws in the event a request is received.
Quantified Objectives: Municipal Code amendment related to Density Bonuses
Funding Source: General Fund
Responsible Agency: Planning and Community Services Department
Implementation Time Frame: Complete by December 2022
Program 6: Accessory Dwelling Unit (ADU) Production, Monitoring, and Incentives
As noted in Chapter 4, the City intends to meet its Regional Housing Needs Allocation of 29
lower income units through a combination of affordable housing on the Rancho Del Mar site (16
units) and privately constructed and rented ADUs on scattered sites throughout the city. At
least 13 ADUs should meet affordability thresholds for low and very low income households.2
Creating opportunities for lower income households on scattered sites supports one of the main
objectives of the State’s Affirmatively Further Fair Housing (AFFH) requirements, which is to
avoid the concentration of lower income housing in a single location. An ADU-centered strategy
also responds to the lack of sanitary sewer, storm drainage, and public streets in Rolling Hills
and the community’s rural densities and absence of supportive services.
As stated in Chapter 4, the City approved nine ADUs in 2021 alone, including two that are
projected to be affordable to lower income households based on their small size. Thus, creating
another 11 ADUs affordable to lower income households over the next eight years is an
attainable goal. The Annual Housing Progress Report should address the City’s progress
toward meeting this goal; if the City is falling short after two years, the strategy should be
revisited and additional incentives should be developed.
Program 6 includes a number of specific elements, which are listed below:
6.1 Develop Citywide Roster of ADUs. The City developed an ADU roster in October 2021
and will expand the roster as new units are created. Currently, the roster (or data base)
contains fields such as Address, Owner, month approved, square footage, and a description
of each unit. This should be expanded to include information on whether the unit is
occupied, the number of occupants, and the rent charged—this information would be
requested from homeowners on a voluntary basis. Tracking occupancy and affordability is
intended to determine how many units are serving very low- and low-income households,
and to demonstrate that the City is meeting its RHNA.
2 Two ADUs meeting affordability criteria for low/very low are already under construction (see Table 4.1), leaving a balance of 11
needed.
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6.2 Annual ADU Survey and Monitoring. The City will send an annual letter to households on
the ADU roster requesting information on the status of the unit. The information will be used
to prepare a summary that can be referenced as part of the City’s Annual Progress Report.
As part of this task, the City will also identify instances where very low or extremely low
income households (including family members, domestic employees, caregivers, etc.) are
residing on Rolling Hills properties and paying below market rent (or no rent). To the extent
these households are occupying independent living quarters, this data provides evidence
that the City is accommodating its RHNA target for very low income households.
As part of this effort, the City will also implement an annual monitoring program to ensure
that the Housing Element targets for ADUs are being achieved. A determination of the City’s
progress toward meeting its RHNA target of 40 units over 2021-2029 shall be made once
per year. In the event the City is not on track to meet its target, it will consider alternative
means of meeting its RHNA goals within six months of this determination. These could
include additional ADU incentives, modifications to the affordable housing overlay zone, and
other actions that would facilitate production of additional affordable units.
6.3 Develop Inventory of Potential ADUs. Over time, the City will develop a parcel data base
of potential (or “unintended”) ADUs, which are existing habitable spaces that could
potentially be converted into independent dwelling units. This would include guest houses,
pool houses, and similar accessory structures that are used by the primary residence. As
the inventory is completed, owners would be advised of the opportunity to convert the space
into a legal ADU.
6.4 Incentives for ADU Construction. The City will develop incentives for ADU construction.
Different incentives may be developed for those building new homes (i.e., reduced fees for
including an ADU in a new residence), those adding a new ADU on their property, and those
converting existing habitable floor space into an ADU. In accordance with California Health
and Safety Code (HSC), Section 65583(c)(7) (effective January 1, 2021), the City will
explore the use of State CalHome, LEAP, REAP, and SB 2 funding to help local homeowners
build or finance ADUs on their properties. Access to these funds typically requires rents that
are affordable to low and very low-income households.
6.5 Pre-Approved ADU Plans. The City will determine its eligibility for State grant funding to
develop “pre-approved” plans for ADUs that can be used by Rolling Hills residents. These
architect-developed plans would be specifically tailored to meet the RHCA design guidelines
and would respond to the topography and access constraints found on most Rolling Hills
lots. Enabling homeowners to use pre-approved plans may reduce architectural design
costs, and potentially reduce construction costs. This can make ADUs more feasible and
allow them to be rented more affordably.
6.6 Coordination with RHCA. The City will coordinate with the Rolling Hills Community
Association to ensure that RHCA’s design review practices and procedures do not constrain
ADU construction or add to their costs. City staff will meet with RHCA staff and the RHCA
Architectural Committee regularly to coordinate review, advise RHCA of State laws relating
to ADUs, and address any issues that may arise in the future. The City will also work with
the Rolling Hills Community Association to explore reduction of annual HOA fees for
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property owners agreeing to limit rents on their ADUs.
6.7 Septic Tank Replacement Grants or Financial Assistance. The City will pursue funding
for a grant which can be used to assist homeowners with septic tank replacement when
paired with the addition of an ADU. The grants would be targeted to lower income seniors
who may seek to add an ADU but lack the financial resources to replace their septic tanks.
6.8 Non-Profit Construction of ADUs. The City will explore the possibility of engaging a non-
profit housing developer in a program to develop ADUs in partnership with interested Rolling
Hills property owners. Participation could be limited to qualifying lower income residents, or
to homeowners who agree to limit rents to levels that are affordable to lower income
households. Such a program was successfully implemented by the City of Santa Cruz, in
collaboration with Habitat for Humanity, and could be considered locally.
6.9 Monitor Best Practices in ADUs. The City will continue to track statewide and national
trends in ADU management, incentives, and regulations. The focus will be on cities in
California that are comparable to Rolling Hills in density, character, and constraints, with an
eye toward cities that are relying on ADUs to meet a substantial share of their RHNA for
lower income households. Programs that are potentially transferable to Rolling Hills will be
considered for local implementation.
6.10 Update Municipal Code Provisions for ADUs. By October 15, 2022, the City will update
its ADU ordinance to reflect changes to State law made since the last revision to the
ordinance in February 2020. This includes eliminating references to a maximum bedroom
count in an ADU and including provisions for complete applications to be deemed
approved if they are not acted upon within 60 days.
6.11 Outreach to ADU Permit Recipients. The City will monitor ADU approvals, including six-
month “check-ins” with all applicants receiving ADU permits until the units are completed.
These check-ins will include status updates on the projects, including whether a building
permit has been issued and what progress is being made. In the event an applicant
chooses not to follow through on an approved ADU, staff will make an effort to document
the reasons and evaluate any changes that might be made to the City’s ADU program to
improve completion rates. This information should be part of the City’s annual housing
progress report.
In addition to the specific measures listed above, City staff will continue to assist homeowners
who are interested in adding an ADU, and will work with applicants to facilitate ADU review,
permitting, and approval.
Quantified Objectives: (1) Citywide ADU roster of 40 ADUs by 2029, including at least 13
ADUs rented at levels meeting affordability criteria for lower
income households
(2) ADU Survey, administered once a year
(3) Inventory of potential ADUs
(4) ADU Incentives
(5) Two to four pre-approved ADU architectural plans
(6) Municipal Code Revisions (see 6.10 above)
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(7) 100% completion of ADUs receiving permits
Funding Source: City General Fund/ State grants
Responsible Agency: Planning and Community Services Department/ City Attorney
Implementation Time Frame: (1) Rosters and Surveys prepared by 2022 and updated annually
(2) ADU incentives by 2023
(3) Approved architectural plans by 2024, or as funding allows
(4) Amend Municipal Code Chapter 17.28 (Accessory Dwelling
Units) for consistency with State law by October 15, 2022
(5) Establish protocol for 6-month check-ins with ADU permit
recipients by January 1, 2023
(6) Annual monitoring report on ADU production
Program 7: Accessory Dwelling Unit (ADU) Outreach, Education, and Information
Program 7 addresses public outreach, education, and information on ADUs. Like Program 6, it
has multiple elements.
7.1 Biennial Mailing. The City will send a mailing to all households in Rolling Hills at least
once every two years advising them of the opportunity to create an ADU, the potential
benefits of having an ADU, and potential incentives in the event the ADU will be
occupied by a household worker, caregiver, family member, or other household meeting
the definition of a low or very low income household. The mailing may consist of an
article in the City’s monthly newsletter.
7.2 Website. The City will develop a landing page on its website with information on ADU
opportunities (“Thinking about building an ADU?”). The website landing page will
include information on the types of ADUs an owner may consider (detached, attached,
junior, etc.), the typical cost and cost considerations, financing options, tax implications,
development standards, tenant selection, and so on. The information should also be
provided in printed form for interested homeowners.
7.3 RHCA Design Guidelines Update. The City will work with the Rolling Hills Community
Association to facilitate an update of the RHCA Design Guidelines so that they address
ADUs. Currently, the Guidelines do not acknowledge ADUs at all. The Update would
provide objective design standards for ADUs that are consistent with Rolling Hills zoning
standards as well as the design guidelines that currently apply.
Quantified Objectives: (1) Mailings to all Rolling Hills households (at least once every 2
years)
(2) Updated City website
(3) Updated Design Guidelines document
Funding Source: City General Fund, State grants
Responsible Agency: Planning and Community Services Department
Implementation Time Frame: (1) First mailing by December 2022
(2) Website update by June 2023
(3) Update of design guidelines by 2024
Program 8: Assist Senior and Disabled Households
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The City will continue to address the housing needs of seniors and persons with disabilities by
connecting those in need with social service agencies, non-profits, volunteer organizations, and
other service providers, and by coordinating with the RHCA in the services and programs it
provides. As noted in the Needs Assessment, more than one-third of the city’s residents are
over 65 and about 10 percent have one or more disabilities. The City will work with seniors,
especially those on fixed incomes, to evaluate housing needs and resources. Within 18 months
of Housing Element adoption, the City Council will convene a study session jointly with the
RHCA Needs of Seniors Committee and at least one local non-profit serving seniors (such as
Peninsula Seniors) to discuss the needs of Rolling Hills seniors and potential programs to
address these needs.
Several of the programs listed elsewhere in this Element (shared housing, assistance with home
maintenance, reduced utility rates, etc.) are primarily intended to benefit lower income seniors.
The City also will support expanded opportunities for persons with disabilities, including the use
of universal design principles and accessibility standards in new construction and ADUs. As
part of this program, Rolling Hills will also work with the Harbor Regional Center to implement
outreach services to Rolling Hills families on services available to persons with developmental
disabilities. The City’s website will be updated to include links to housing and supportive
services for seniors and disabled persons.
Quantified Objectives: Website landing page with senior housing resources
Facilitate age-in-place retrofits for 10 senior households
City Council study session on needs of seniors and potential
actions to assist Rolling Hills seniors
Funding Source: City General Fund
Responsible Agency: Planning and Community Services Department/ City Manager
Implementation Time Frame: June 2023 (for website)
Council Study Session before December 2023
Program 9: Assist Extremely Low-Income Households
Extremely Low Income (ELI) households have incomes that 30 percent or less of the County
median. In 2021, the income thresholds for ELI were $24,850 for a household of one; $28,400
for a household of two; $31,950 for a household of three; and $34,450 for a household of four.
Based on CHAS data, there are 25 ELI households in Rolling Hills, representing about 3.5
percent of the city’s households. The CHAS data indicated that all 25 of these households were
homeowners, suggesting they are primarily seniors on fixed incomes. The City will explore ways
to assist elder Rolling Hills homeowners on fixed incomes with home maintenance, repair, and
retrofit activities. It will also direct these households to appropriate resources, such as shared
housing services and programs to reduce utility costs.
There are additional ELI households in Rolling Hills that may not be counted in the Census data,
including extended family members living in independent quarters on a property, or domestic
employees (housekeepers, au pairs, personal assistants, etc.) living in guest houses, accessory
buildings, or in separate quarters within the primary residence. The City will address the needs
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of these households by prioritizing applications for ADUs and encouraging homeowners to
create opportunities for domestic employees and family members to live “on site.”
A study sponsored by SCAG in 2020 determined that 15 percent of the ADUs in the coastal Los
Angeles area were likely to be available at rents affordable to Extremely Low Income
Households.3 A 2018 study further found that 17% of the ADUs in Portland, Seattle, and
Vancouver were occupied by a friend or family member for free.4 A 2014 study found that 18%
of the ADUs in Portland were occupied for free or extremely low cost.5 A 2012 UC Berkeley
publication indicates that up to half of all ADUs are occupied at no cost.6
Based on these analyses, the City is estimating that seven “rent free” or extremely low income
rentals will be added to the Rolling Hills housing stock by 2029. It will seek to document and
measure progress toward this objective by soliciting voluntary reporting of such units by
individual homeowners. As noted in Program 6.2, an annual survey is proposed to be
administered to all registered ADU owners in the city. This would enable tracking of rent-free or
reduced rent ADUs.
Quantified Objectives: Provide seven housing units affordable to Extremely Low Income
Funding Source: City General Fund/ Permitting Fees
Responsible Agency: Planning and Community Services Department
Implementation Time Frame: Prepare inventory of Extremely Low Income (ELI) units by 2024,
update annually
Facilitate housing assistance to at least three ELI senior
homeowners by 2025
Program 10: Support Regional Efforts to End Homelessness
Extremely low-income persons also include those who are homeless or may be at risk of
becoming homeless. Although the point-in-time surveys for the last five years have not counted
any homeless residents in Rolling Hills, the City recognizes that homelessness is a regional
problem that requires regional solutions. Rolling Hills will continue to allow emergency shelters
and single room occupancy hotels in the Rancho Del Mar Overlay Zone and will monitor the
effectiveness of its regulations in its Annual Housing Progress Report.
The City will continue to work with adjacent communities on emergency shelter referrals. As a
member of SCAG and the South Bay Cities COG, staff and elected officials participate in forums
and discussions of homelessness, and potential programs and resources to end homelessness
and increase the supply of shelter, transitional, and supportive housing in Greater Los Angeles.
Quantified Objectives: Participation in point in time surveys; participation in at least one
regional meeting annually on strategies to end homelessness
Funding Source: City General Fund/ Permitting Fees
Responsible Agency: Planning and Community Services Department/ City Manager
Implementation Time Frame: Ongoing, 2021 through 2029
3 SCAG Regional Accessory Dwelling Unit Affordability Analysis, 2020
4 Jumpstarting the Market for ADUs. Terner Center (for ULI), San Francisco, 2018
5 ADUs in Portland OR. Environmental Solutions Management, 2014
6 Scaling Up Secondary Unit Production in the East Bay. Berkeley Institute of Regional Development, 2012
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Program 11: Permit Streamlining
The City will continue its efforts to expedite permit processing, ensure efficiency, and reduce
administrative and processing costs for new development. This could include provisions for
reduced fees for ADUs that are rented at below market levels, or occupied by qualifying lower
income households. As part of the annual budgeting process, the City will ensure that fees are
appropriate for the services provided, and will consider ways to improve the permitting and
entitlement processes.
Quantified Objectives: Compliance with all provisions of the Permit Streamlining Act
Funding Source: City General Fund/ Permitting Fees
Responsible Agency: City Manager/ Finance Director/ Planning and Community
Services Department/ LA County Building and Safety
Implementation Time Frame: Ongoing, 2021 through 2029
Program 12: Facilitate Communication with Affordable Housing Service Providers,
Developers, and Advocates
The City of Rolling Hills periodically receives requests from housing advocates, non-profit
developers, and service providers to disseminate information on affordable housing needs and
opportunities and work collaboratively to address housing issues. City planning staff regularly
field requests from for-profit and non-profit developers, participate in regional housing meetings
and discussions, and work with other cities to explore creative, effective ways to meet housing
needs. In the event a non-profit agency or developer wishes to submit a grant application that
will increase housing affordability for senior or low income Rolling Hills residents, staff will
provide administrative support wherever possible.
Quantified Objective: Hold at least one meeting a year with one or more non-profit
housing sponsors to discuss housing opportunities and needs in
Rolling Hills
Funding Source: General Fund
Responsible Agency: Planning and Community Services Department
Implementation Time Frame: Convene one meeting before December 2022. Convene additional
meetings at least once a year from 2023 to 2029.
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Program 13: Shared Housing
Shared housing enables homeowners to offset their housing costs by receiving rent, or get
additional help in managing housing duties. It also creates a resource for lower income
households in the community, including college-aged students and young adults, caregivers,
domestic workers, landscapers and building industry workers, child care workers, teachers, and
other public service employees. It can also be a resource for seniors, some of whom may no
longer wish to live alone or lack the financial resources to live alone.
Residents in Rolling Hills have access to two nearby shared housing programs: Focal Point at
the South Bay Senior Services Center in Torrance and the Anderson Senior Center in San
Pedro. Both these centers offer resources to assist seniors locate roommates interested in
sharing housing. These programs make roommate matches between seniors based on
telephone requests.
Numerous other home sharing services have emerged over the last decade. These include
SHARE! Collaborative Housing, a public-private partnership supporting shared single family
housing for persons with disabilities in Los Angeles County; Affordable Living for the Aging,
which matches younger single tenants with seniors in Los Angeles County; and Los Angeles
County HomeShare, which serves residents of all ages throughout the County. There are also
private services such as Silverleaf (Long Beach) that facilitate home sharing for a fee.
The City will continue to apprise residents about shared housing programs by providing information
at the public counter and online.
Quantified Objectives: Continue to provide informational brochures advertising shared
housing programs at City Hall and on the City’s website
Funding Source: City General Fund
Responsible Agency: Planning and Community Services Department
Implementation Time Frame: Establish website links by December 2022
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Program 14: Sewer Feasibility Studies and Phase One Construction
As indicated in Section 5.3.5 of this Housing Element, Rolling Hills does not have a sanitary
sewer system. With a few exceptions, the entire city is served by private septic systems. Septic
system installation is costly and requires customized design to reflect steep terrain. The cost of
installing sanitary sewers and storm drains would be even more costly, as it would likely require
easements, force mains, and lift stations.
The City recently completed design drawings for a sanitary sewer extension through adjacent
Rolling Hills Estates that will bring service to Rolling Hills City Hall and the Tennis Courts. A
future phase of this project could continue southward along Portuguese Bend Road, allowing
some Rolling Hills homes and a number of vacant properties to be served by sewer. A survey
done by the City in 2021 indicated there was strong support for a sewer extension project,
contingent on the cost to each homeowner. There is currently no funding source for such an
extension. Grant funding would be required, as it would reduce the cost burden on
homeowners and make the project more feasible.
The City will continue to work toward addressing this constraint during the 2021-29 planning
period. This includes:
• Developing the initial phase of the project, serving City Hall and the Tennis Courts
• Conducting feasibility and cost studies for a future phase to serve privately owned
homes and parcels in the northern part of Rolling Hills
• Pursuing funding for future phases
• Continuing to poll Rolling Hills residents on their level of support for the project
In addition, the City continues to monitor water quality issues related to its MS 4 permit for
stormwater discharge. Efforts to address runoff quality and implement best management
practices to reduce pollution are ongoing and will continue.
Quantified Objective: (1) Complete 1,585-foot sanitary sewer extension to City Hall/
Tennis Courts (Phase I)
(2) Complete feasibility / cost study of sanitary sewer extension
(3) Obtain grants for Phase I project construction
Funding Source: General Fund/ State grants
Responsible Agency: City Manager
Implementation Time Frame: Complete Phase I by 2024
Determine viability of future phases and available grants by 2023
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Program 15: Consider Participation in CDBG Urban County Program
At least once every two years, the City should re-evaluate the feasibility of joining the Los
Angeles Urban County CDBG program in order to create a funding source for home
improvements for qualifying lower income Rolling Hills residents. The decision should consider
the potential amount of funding that could be received by the city, and potential uses for that
funding, as well as the administrative costs, reporting requirements, and staff resources required
to carry out the program. In the event the City receives CDBG grants, it could consider using
the funding to assist qualifying lower income households with energy efficiency improvements,
housing rehabilitation and improvements, or septic tank replacement.
Quantified Objectives: Prepare staff report to City Council regarding participation in
Urban County CDBG program
Funding Source: City General Fund
Responsible Agency: City Manager/ Finance Director
Implementation Time Frame: By 2023, and every two years thereafter
Program 16: Code Enforcement
The City will continue code enforcement and nuisance abatement activities to ensure the safety
and habitability of housing in Rolling Hills. While property maintenance in Rolling Hills is
excellent, there is a need for ongoing enforcement of planning and building codes. The City has
a “Code Enforcement” webpage with online forms for reporting suspected violations, including
those relating to vegetation management and outdoor lighting as well as unpermitted
construction or nuisances. Periodic information on code enforcement resources and
requirements is also provided to residents through the City’s monthly newsletter.
Quantified Objective: Respond to 100 percent of resident Code Enforcement inquiries
Funding Source: General Fund
Responsible Agency: Planning and Community Services Department
Implementation Time Frame: Ongoing, 2021-2029
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Program 17: Reduce Home Energy Costs
Energy bills can be a significant cost burden, particularly for households on fixed incomes with
large homes to heat and cool. The City has adopted the Green Building Code and enforces Title
24 energy efficiency requirements through its contract with the Los Angeles County Department
of Building and Safety. New residential projects, including new homes, ADUs, renovations, and
additions, will continue to be required to meet Title 24 standards. These requirements result in
energy savings which reduce gas and electric consumption and home utility bills.
Rolling Hills also works with Southern California Edison to distribute information to residents on
energy conservation and weatherization, including information on financial assistance and lower
utility rates for low-income customers. The City will provide links on its website to assist lower
income residents in accessing information on reduced utility rates. Rolling Hills is also a
member of the South Bay Environmental Services Center, which provides information on energy
incentives, audits and rebates. These programs will continue in the future.
The City will also support resident installation of solar energy systems. A growing number of
Rolling Hills homeowners have installed photovoltaic panels, increasing energy independence
and resilience while reducing home energy costs.
Quantified Objective: (1) Provide links on City website related to energy conservation,
weatherization, and financial assistance
(2) Adopt updated Building Code standards for energy efficiency
Funding Source: General Fund, LIHEAP
Responsible Agency: Planning and Community Services Department
Implementation Time Frame: Website Update, with links: Complete by January 2023
Program 18: Facilitate New Construction and Home Improvements
The City will continue to work with property owners, architects, and builders to enable new
housing to be built in the City. Continued cooperation and communication between City staff,
applicants, and neighbors will facilitate the construction of new housing. The City is committed
to efficient planning, building, and inspection procedures, and regularly seeks ways to improve
the process and reduce delays.
With few vacant lots remaining, most construction projects in Rolling Hills consist of home
additions, repairs and modernization, or replacement of existing dwellings. Continued
investment in Rolling Hills housing stock is strongly encouraged and will continue to be
supported in the future. Although the City does not provide direct financial assistance to lower
income homeowners, it assists owners in keeping costs down through permit streamlining and
fees that are generally below average compared to other cities in Los Angeles County.
Quantified Objective: 5 new single family homes (above moderate income)
Funding Source: Private Funds (Permitting Fees)
Responsible Agency: Planning and Community Services Department, LA County
Building and Safety
Implementation Time Frame: Objective covers the period from 2021 through 2029
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Program 19: Remediate Geologic Hazards
The City will continue to explore solutions to ground stability and landslide problems. Grading,
new structures and additions typically require a soils and geology report along with grading and
building permits. The City has developed strict grading practices that limit grading to no more
than 40 percent of the lot and require maintenance of natural slopes. These practices are
necessary to safeguard the public against ground instability.
The City will support repair work on landslide-damaged homes and hillsides that have been
damaged or compromised by past landslides. The City will strive to avoid further loss of its
housing stock as a result of natural disasters, including landslides and wildfires.
Quantified Objective: Geologic studies for new development and major grading permits
Funding Source: City General Fund
Responsible Agency: Planning and Community Services Department/ City Manager
Implementation Time Frame: On-going, 2021 to 2029
Program 20: Fair Housing Services Program Administration
The City will complete a Fair Housing Outreach and Enforcement Options Memorandum to
determine options for ensuring that existing and prospective residents have access to fair
housing services, and that property owners are apprised of Fair Housing laws and practices.
This could include an agreement contract with a third party fair housing services provider to
promote and affirmatively further fair housing opportunities for all persons regardless of race,
religion, sex, marital status, ancestry, national origin, color, familial status, disability, or other
characteristics protected by state and federal fair housing law. Other alternatives for outreach,
education, and enforcement may be considered. Based on the findings of the Memorandum,
the City will implement Fair Housing measures, including Programs 21 and 22 described below.
City will also contact the fair housing service provider annually to obtain information on cases
and referrals originating in Rolling Hills.
Quantified Objective: Fair Housing Outreach and Enforcement
Memorandum Active contract with a fair housing
services provider
Funding Source: General Fund
Responsible Agency: City Manager
Implementation Time Frame: Complete memorandum Bby December 2022; renew Agreement
as needed
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Housing Goals, Policies, Objectives, and Programs Page 6-19
Program 21: Fair Housing Outreach
The City will provide information on fair housing resources on its website, including a links to the
fair housing services provider. Other outreach measures to be implemented include posting
regulations regarding housing discrimination, as well as phone contacts, at City Hall and
periodically providing this information in the City’s newsletter.
The City will also provide a referral process for any person who believes they have been denied
access to housing because of their race, sex, marital status, ancestry, national origin, color,
familial status or disability. In the event a complaint is received, the City will refer the party to a
fair the City’s housing service provider for follow up and work with the complainant to resolve the
issue.
Quantified Objective: Active contract with fair housing services provider
Funding Source: General Fund
Responsible Agency: City Manager
Implementation Time Frame: Ongoing, 2021-2029. Website update by December 2022.
Program 22: Fair Housing Training for Staff
At least one City staff member will attend an on-line fair housing certification training class on an
annual basis. These classes are typically three-hour sessions in which participants are informed
and educated about federal and California fair housing laws, compliance, and illegal housing
practices. The trainings cover prohibited and best practices, including language guid ance for
advertising housing for sale or for rent, and protected classes under federal and California law.
In addition, the City will regularly evaluate the need for multi-lingual services, including
translation of material on its website into other languages. It will also continue to implement its
reasonable accommodations ordinance and monitor data on persons with disabilities in the city
to ensure that barriers to mobility are eliminated to the greatest extent possible.
Quantified Objective: Annual staff training
Funding Source: General Fund
Responsible Agency: City Manager
Implementation Time Frame: Initiate in 2022 and continue annually through 2029
Program 23: Written Procedures for SB 35 Projects
As required by State law, the City will prepare written procedures and application materials for
projects seeking to use SB 35. Affordable multi-family housing development on the Rancho Del
Mar site would be potentially eligible. The procedures would follow the provisions established
by the Affordable Housing Overlay Zone, and include the objective standards and application
procedures identified when that zone was adopted. Once completed, the information will be
included as a PDF link on the Planning and Community Services Department website for easy
access.
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Housing Goals, Policies, Objectives, and Programs Page 6-20
Quantified Objective: Posted information on SB 35, including application
form
Funding Source: General Fund
Responsible Agency: Planning and Community Services Department
Implementation Time Frame: Complete by December 31, 2022
Program 24: Updating of Linked Files on Planning and Community Services
Department Landing Page
AB 1483 requires that every city post current information on fees, zoning standards, design
guidelines, processes and procedures, nexus studies and other pertinent information on its
website. Although Rolling Hills complies with this requirement today, reorganization of the
material could provide greater clarity and easier access to this information. For example, the
website could include a link to the RHCA design guidelines, as well as updated flow charts and
graphics showing approval processes. As noted under Program 7.2, the website also should
include dedicated information about Accessory Dwelling Units (ADUs) and the steps residents
can take to add an ADU on their property.
Quantified Objective: Reorganized and updated Planning and Community
Services Department website
Funding Source: General Fund
Responsible Agency: Planning and Community Services Department
Implementation Time Frame: Complete by December 31, 2023
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Housing Goals, Policies, Objectives, and Programs Page 6-21
6.3 Summary of 2021-2029 Quantified Objectives
Table 6.1 provides quantified objectives for housing construction, rehabilitation, and
conservation by income group. The new construction objectives align with the RHNA numbers
that appear earlier in the Housing Element. The rehabilitation objective aims to assist 10 very
low-income senior households over the eight year period. The conservation and preservation
objectives correspond to the approximate number of households in Rolling Hills by income
group based on Census data. The objectives aim to preserve housing for 100 percent of these
households. There are no housing units in Rolling Hills that are at risk of conversion from
affordable to market-rate.
Table 6.1: Quantified Objectives by Income Group for Rolling Hills (20 21-2029)
Income Category New
Construction Rehabilitation Conservation/
Preservation
Extremely Low [1] 7 5 25
Very Low 13 5 45
Low 9 45
Moderate 11 25
Above Moderate 5 500
Total Housing Units 45 10 640
Source: SCAG Adopted Regional Housing Needs Determinations (November 2012)
[1] City’s RHNA for “Very Low” income is 20 units. This has been allocated proportionally to “Extremely Low” and “Very
Low” based on Table 3.8, which indicates the current proportion of “Very Low” income households in these two groups.
Extremely low income households represent 35% of the “very low” total.
Table 6.2 summarizes the 2422 Housing Element programs listed in this chapter. It includes a
quantified objective and timeframe for each program, as presented above.
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Housing Goals, Policies, Objectives, and Programs Page 6-22
Table 6.2: Housing Element Action Plan Summary
# Program Timing Quantified Objective
1 Prepare Annual Progress Report on
Housing Element implementation
Annually, by April 1 One Report per year
2 Facilitate affordable housing on Rancho
Del Mar Housing Opportunity site
Annual meeting with
School Superintendent
Subdivision by 2024
16 lower-income units by
2029
3 No net loss monitoring/ other housing
opportunities
Continuous, through
2029. Address in
Annual Report.
No net loss of housing
capacity for duration of
planning period
4 Add definitions of transitional,
supportive, employee housing and
residential care facilities to Municipal
Code
December 2022 Council action adopting
definitions and
identification of permitted
uses
5 Adopt density bonus provisions in
Municipal Code
December 2022 Council action adopting
density bonus provisions
6 Accessory Dwelling Unit production,
monitoring, and production
• Updated ADU
ordinance by 10/15/22
• ADU Roster in 2021
• Annual ADU survey,
starting in 2022
• Pre-approved plans in
2024
• ADU incentives in
2023
• Annual monitoring
program (2023)
40 ADUs by 2029,
including at least 13 ADUs
affordable to lower income
households
7 Accessory Dwelling Unit Outreach,
Education, and Information
• First biennial mailing
by end of 2022
• Website update by
6/23
• Update of design
guidelines by 2024
• Outreach mailer to 639
households
• ADU website landing
page
• ADU section added to
RHCA Guidelines
8 Assist senior and disabled households • Website update by
6/23
• Housing assistance
during 2021-2029
Assist 10 lower income
senior households with
age in place retrofits
9 Assist extremely low income households • Prepare inventory of
ELI units by 2024
7 ADUs affordable to ELI
households
10 Support regional efforts to end
homelessness
Ongoing • Participate in point-in-
time surveys
• Attend one mtg a year
11 Permit streamlining Ongoing Compliance with Permit
Streamlining Act
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Housing Goals, Policies, Objectives, and Programs Page 6-23
# Program Timing Quantified Objective
12 Facilitate communication with affordable
housing service providers, developers,
and advocates
By December 2022 • Convene at least one
meeting a year
13 Shared housing By December 2022 • Provide information on
website, plus print media
resources
14 Sewer feasibility studies and Phase I
construction
Phase I construction
(serving City Hall) by
2024
• Sewer extension to City
Hall/ Tennis Courts
• Feasibility study for
sewer extension
15 Consider participation in Urban County
CBDG Program
By 2023 Staff report and Council
discussion
16 Code enforcement Ongoing 100% follow up
17 Reduce home energy costs By 2023 Website update
18 Facilitate new construction and home
improvements
Ongoing 5 market-rate single family
homes (including 3 already
approved)
19 Remediate geologic hazards Ongoing Geologic studies for new
development
20 Fair housing services contract and
program administration
Develop fair housing
compliance program by
December 2022 Develop
agreement in 2022;
renew annually or as
needed
Contract with fair housing
service provider Fair
Housing Planning Memo
21 Fair housing outreach Website update by
December 2022
• Contract with fair
housing service provider
• Website links or landing
page
22 Fair housing training for City staff Initiate in 2022 Annual training for at least
one staff member
23 Prepare written instructions for SB 35
applications
Complete by December
31, 2022
Guidance memo and
application form
24 Update Planning and Community
Services website
Complete by December
31, 2023
Updated website
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APPENDICES
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-1
Appendix A:
Affirmatively Furthering Fair Housing (AFFH) Evaluation
Overview
In 2018, the Governor signed Assembly Bill 686, adding a requirement that local housing
elements address each community’s obligation to “affirmatively further fair housing.” AB 686
defined this is as:
“taking meaningful actions, in addition to combatting discrimination, that overcome
patterns of segregation and foster inclusive communities that restrict access to
opportunity based on protected characteristics. Specifically affirmatively
furthering fair housing means taking meaningful actions that, taken together,
address significant disparities in housing needs and in access to opportunity,
replacing segregated living patterns with truly integrated and balanced living
patterns, transforming racially and ethnically concentrated areas of poverty into
areas of opportunity, and fostering and maintaining compliance with civil rights
and fair housing laws.”
In April 2021, the California Department of Housing and Community Development issued
its formal guidance memo on how local governments should address this new
requirement in their housing elements. The guidance memo indicates the ways in which
the AFFH mandate affects outreach and community engagement, data collection and
analysis, the site inventory, identification and prioritization of “contributing factors,” and
the goals, policies, and programs of the housing element. It also includes data sources
and other resources for local governments.
Chart A-1 summarizes the AFFH mandate; the requirements are extensive. As a result,
the City of Rolling Hills has provided this appendix to address the mandatory components
rather than including this information in the body of the Housing Element. The findings of
this assessment have informed the policies and programs in the Housing Element.
There are limitations to the analysis presented here. Rolling Hills is a small community,
comprised of a single Census Tract Block Group. It is affluent and homogenous and does
not have pockets of poverty or notable disparities between its neighborhoods. Many of
the AFFH maps developed by HCD simply affirm this, rather than revealing spatial
patterns within the city limits. The underlying goal, which is to reduce impediments to fair
housing in the city and improve housing opportunities for lower-income households,
remains relevant.
In addition, Rolling Hills does not participate in the federal CBDG program as a member of
the Los Angeles County Urban County designation. As such, it is not directly covered by
the Analysis of Impediments to Fair Housing Choices prepared by the County Community
Development Commission and Housing Authority. Some of the findings of the County
Analysis are cited here, as they apply more broadly to the Palos Verdes Peninsula (Rolling
Hills Estates and Rancho Palos Verdes are both members).
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-2
Chart A-1: Summary of AB 686 Requirements
Source: HCD, April 2021
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-3
The remainder of this report provides the data that is generally referred to as the AFFH analysis.
This includes trends and patterns related to segregation, racially or ethnically concentrated
areas of poverty, disparities in access to opportunity (including persons with disabilities), and
disproportionate housing needs. Unless otherwise indicated, all maps in this chapter were
prepared using the AFFH data viewer from the California Department of Housing and
Community Development.
Duty of All Public Agencies to Affirmatively Further Fair Housing
Federal law already requires that federal agencies administer programs in a way that
affirmatively furthers fair housing. This also extends to all local governments receiving funds
from the federal government. AB 686 further extended the obligation to all public agencies in
the State of California. This mandate applies to administration of all programs and activities
relating to housing and community development. The statute requires an examination of
policies, programs, rules, practices, and activities, and where necessary, changes to promote
more inclusive communities.
Outreach
The City of Rolling Hills has worked to engage all economic segments of the community in the
Housing Element Update process. This included conducting more than 11 housing-focused
public meetings on Zoom in 2020 and 2021, delivering newsletters with information on the
Housing Element to every household in the city, and providing housing-related surveys (both
paper and electronic) to every housing unit in Rolling Hills. By reaching out to every household
in the city, Rolling Hills has engaged its lower income residents in the process.
Meetings have been held in the evenings to facilitate participation. The public was invited to
participate in each meeting as “panelists” rather than “attendees,” giving them equal footing to
staff and Councilmembers/ Commissioners rather than the more limited opportunities offered by
webinars. Drafts of the Housing Element were made available at City offices and on-line, with at
least 30 days provided between the release of the Draft and action by the City Council.
Site Inventory
AB 686 requires that a jurisdiction identify sites throughout the community in a manner that is
consistent with its duty to affirmatively further fair housing. The sites identified by the City must
work to replace segregated living patterns with integrated living patterns. Rolling Hills has done
this by focusing on Accessory Dwelling Units (ADUs) to meet its housing needs, rather than by
zoning scattered sites throughout the city for multi-family housing. By definition, ADUs provide
an effective way to achieve economic integration as they enable low and very low income
households to live throughout the community rather than in segregated living patterns.
As noted throughout the Housing Element, the City currently has no multi-family housing units—
thus, the designation of the Rancho Del Mar property as an affordable housing opportunity zone
would not constitute a “concentration” of poverty. As the only site in the city that has sewer and
storm drainage, flat buildable land, road and transit access, and relatively few natural hazards, it
is the only suitable site in the city for multi-family housing (see Chapter 4). Placing multi-family
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-4
housing elsewhere in Rolling Hills---on hazardous sites prone to landslides and wildfires, without
public street access or sewer facilities—would be inconsistent with the objectives of AB 686.
Fair Housing Enforcement
Fair housing enforcement is presently handled on a case-by-case basis. The State of California
has an Office of Fair Housing and Equal Opportunity (FEHO) that enforces the Fair Housing Act
and other civil rights authorities that prohibit discrimination. In the event a fair housing
complaint is received by the City, the involved party would be referred to FEHO for investigation.
There are no pending lawsuits, enforcement actions, judgements, settlements, or findings
related to fair housing and civil rights in Rolling Hills. There are currently no local fair housing
laws in the City, but Rolling Hills complies with all applicable state and federal laws. These
include:
• The City is committed to complying with tThe federal Fair Housing Act, Title VIII of the Civil
Rights Act of 1968, as amended by the Fair Housing Amendments Act of 1988, 42 U.S.C. §§
3601 et seq., which the City complies with by ensuring that housing is available to all
persons without regard to race, color, religion, national origin, disability, familial status, or
sex.
• The federal Americans with Disabilities Act (ADA), which the City complies with through its
building code, permit review procedures, and reasonable accommodation procedures
• The California Fair Employment and Housing Act, which the City complies with through its
protocols for hiring, decision-making, staff training, advertising, and legal counsel
• Government Code Section 65008 and 11135, which guide the City’s procurement protocols,
provide preferential treatment for affordable housing, provide equal access to housing
assistance, and ensure that multi-family housing is treated fairly relative to single family
housing
• Government Code Section 8899.50, which specifies AFFH requirements
• Government Code Section 65913.2, which precludes excessive subdivision standards
• Government Code Section 65302.8, which precludes certain types of municipal growth
control laws (the City has none)
• Government Code Section 65583, which includes the requirement to have a housing
element
• Housing Accountability Act, which is implemented through the City’s development review
and zoning procedures
An action program in the 2021-2029 Housing Element recommends that the City contract with a
third party non-profit to promote the enforcement of fair housing laws, respond to complaints,
and resolve complaints through conciliation, mediation, referrals, and litigation where necessary.
Most cities in the region have agreements with third party non-profits that provide this service.
These entities also provide on-line workshops for city staff and landlords, and offer phone and
on-line counseling.
HCD’s AFFH data viewer reports that there were zero (0) fair housing enforcement and outreach
inquiries in Rolling Hills between 2013 and 2021. The City is unaware of any fair housing cases
that may have occurred without being formally reported, and has not received complaints or
inquiries from residents. The City is likewise unaware of any Section 8 housing choice vouchers
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A D O P T I O N D R A F T
Appendix A: Affirmatively Furthering Fair Housing Analysis A-5
in use within Rolling Hills, or any instance of a prospective applicant being denied the
opportunity to use a voucher within the city.
Due to the small size of the City’s staff, there is not a formal fair housing training program and
there is limited expertise on fair housing issues. An action program in this Element directs the
City to provide fair housing training to staff, and to improve web-based and print media
resources to inform residents of their rights and obligations under the Fair Housing Act. Fair
housing information will also be included in the City’s newsletter.
The City is committed to complying with the Fair Housing Act, Title VIII of the Civil Rights Act of
1968, as amended by the Fair Housing Amendments Act of 1988, 42 U.S.C. §§ 3601 et seq., by
ensuring that housing is available to all persons without regard to race, color, religion, national
origin, disability, familial status, or sex.
Integration and Segregation
Race and Ethnicity
Chapter 3 of the Housing Element provides an overview of the racial composition of Rolling Hills
and the surrounding region. In addition, Table A-1 below shows race and ethnicity data for
Rolling Hills and the region (in this case Los Angeles County) for 2010 and 2020.
Relative to Los Angeles County and the greater Los Angeles region, Rolling Hills has a higher
percentage of White and Asian residents, and a lower percentage of Black and Hispanic
residents. This is also true of the other cities on the Palos Verdes Peninsula. Rolling Hills has
have seen an increase in Asian and multi-racial residents over the last 20 years, but the
aggregate Black and Hispanic population is 8.37.3 percent compared to a countywide figure of
55.656.3 percent. The percentage of residents who are two or more races more than doubled
in Rolling Hills between 2010 and 2020, which is a much faster rate of increase than the county
as a whole. However, given the city’s small population, even a few households can cause
percentages to shift noticeably. The most significant change is that the number of White, Non-
Hispanic households in the city declined from 74.1 percent to 64.9 percent over the decade.
Countywide, this percentage dropped from 27.8 percent to 25.6 percent, a smaller rate of
decrease .
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-6
Table A-1: Population Share by Race and Ethnicity, Rolling Hills and Los Angeles County
Percent of Residents by Race
in Rolling Hills
Percent of Residents by Race
in Los Angeles County
2010 2020 2010 2020
White Non-Hispanic 74.1% 64.9% 27.8% 25.6%
Hispanic/Latino 5.5% 7.0% 47.7% 48.0%
Black 1.5% 1.3% 8.3% 7.6%
Native American 0.0% 0.1% 0.2% 0.2%
Asian 16.2% 20.4% 13.5% 14.7%
Native Hawaiian/
Pacific Islander 0.1% 0.1% 0.2% 0.2%
Other 0.2% 0.7% 0.3% 0.6%
Two or More Races 2.4% 5.6% 2.0% 3.1%
Sources: US Decennial Census, 2010 and 2020.
Since the City is comprised of a single Census tract block group, this data is most useful on a
regional basis. Census tracts located several miles to the east and north of Rolling Hills, in
Lomita, and in the San Pedro and Wilmington neighborhoods of Los Angeles, are more diverse.
Some of the Census tracts on the Palos Verdes Peninsula have larger percentages of Asian
residents, making them majority non-White.
Figure A-2 shows the “diversity index” for Census tract block groups in and around Rolling Hills.
The index is an indicator of racial and ethnic diversity within a given geographic area. It
considers both race and ethnicity (Hispanic or Non-Hispanic). The higher an area’s number, the
more diverse it is. The index ranges from zero (no diversity) to 100 (complete diversity). An
area’s diversity is 100 when the population is evenly divided into different race/ethnic groups.
The Table indicates an index of 48.4 for Rolling Hills, indicating it is somewhat diverse. The
rating is comparable to many other census tracts on the Palos Verdes Peninsula. Some tracts in
Rolling Hills Estates and Rancho Palos Verdes are more diverse, while several tracts in Palos
Verdes Estates are less diverse. The diversity index is considerably higher in the more
urbanized tracts in San Pedro and the Harbor neighborhoods to the east.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-7
Persons with Disabilities
Chapter 3 of the Housing Element provides information on the number of people with disabilities
by disability type in Rolling Hills. Roughly 10.6 percent of the city’s population has one or more
disabilities compared to 9.9 percent in Los Angeles County as a whole. The higher local
percentage is likely a result of the older population in Rolling Hills, where the median age is 55
compared to the County average of 36.5. This is further supported by the data shown in Table
A-2, which indicates that the percentage of residents with a hearing disability and an ambulatory
disability is higher in Rolling Hills than in the county as a whole. Conversely, a smaller
percentage of Rolling Hills residents have cognitive disabilities, vision disabilities, and self-care
limitations.
Table A-2: Percentage of Residents with a Disability, Rolling Hills and Los Angeles County
Percent of Residents
in Rolling Hills
Percent of Residents
in Los Angeles County
2010 2020 2010 2020
Total with a Disability N/A 10.6% 9.3% 9.9%
Hearing N/A 3.7% 2.3% 2.5%
Vision N/A 1.3% 1.8% 2.0%
Cognitive N/A 2.1% 3.6% 4.1%
Ambulatory N/A 6.9% 5.2% 5.8%
Self-Care N/A 2.3% 2.6% 3.0%
Independent Living N/A 5.0% 4.1% 5.6%
Sources: US Decennial Census, American Community Survey, Five Year Averages for 2010 and 2020. ACS 2010 indicates no data
for Rolling Hills (“X”).
Figure A-3 shows census tract maps for Rolling Hills and the surrounding area indicating the
percentage of residents who are disabled. As Figure A-3 indicates, Rolling Hills appears within
the 10-20 percent interval on the map, which is comparable to the percentage in Rancho Palos
Verdes, Lomita, and the San Pedro and Wilmington neighborhoods in Los Angeles. Most of the
other Census tracts in the vicinity, including those comprising the majority of Rolling Hills
Estates, Palos Verdes Estates, and Torrance, are in the less than 10 percent interval. However,
the difference is marginal, with Rolling Hills being less than one percentage point above the 10
percent threshold. Given that the population of Rolling Hills is significantly older than the county
as a whole, the rate of disability in the city is relatively low. Compared to the disabled population
in the region at large, the city’s disabled residents have greater access to medical care and
supportive services as a result of higher household incomes and the generational wealth
accrued through home ownership and equity.
The special housing needs of persons with disabilities are addressed in Section 3.3.2 of the
Housing Element.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-8
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-9
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-10
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-11
Familial Status
The federal Fair Housing Act prohibits discrimination on the basis of familial status. This refers
to the presence of children in a household, regardless of the relationship of the child to the adult
members of the household. It also includes pregnant women and persons in the process of
obtaining legal custody of a child. Housing that is exclusively reserved for seniors is exempt
from these requirements.
Examples of familial status discrimination include refusing to rent to someone because they
have a child or are a single parent, evicting a tenant if they have a child, or requiring families
with children to live in a specific part of a multi-family building. Advertising that prohibits
children also is prohibited.
Relative to Los Angeles County as a whole, Rolling Hills has about the same percentage of
married couples with children but much lower percentages of single parent households. The
2015-2019 ACS indicated there are five single parent female households with children in Rolling
Hills. Despite the small number, single parent households may have special needs due to
having only one income, as well as greater needs for child care and other supportive services
(see Housing Element Section 3.3.4). These obstacles can limit net income and prevent most
single parents from being able to live in Rolling Hills.
Table A-3 shows familial status in Rolling Hills relative to Los Angeles County. The table
compares the percentage of households in different categories, including families, married
couples, other households, and non-families (including persons living alone).
Table A-3: Population by Familial Status, Rolling Hills and Los Angeles County
Percent of Total
in Rolling Hills
Percent of Total in
Los Angeles County
2010 2020 2010 2020
Family Households 81.9% 78.7% 67.3% 66.4%
Married Couples (75.2%) (68.5%) (44.5%) (44.8%)
With children
under 18 at home 30.1% 17.8% 21.6% 18.8%
Without children
under 18 at home 45.1% 50.7% 22.9% 26.0%
Other Families (6.7%) (10.2%) (22.9%) (21.5%)
With children
under 18 at home 2.8% 3.1% 11.2% 8.8%
Without children
under 18 at home 2.9% 7.1% 11.7% 12.7%
Non-family Households 18.1% 21.3% 32.7% 33.6%
Sources: American Community Survey, Five Year Averages for 2010 and 2020. All percentages refer to the percentage of total
households in Rolling Hills in the listed category. Because the categories are “nested”, the numbers add up to more than 100
percent.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-12
Relative to Los Angeles County as a whole, Rolling Hills has a much higher percentage of
married couples. However, the percentage of married couples with children at home is about
the same as the countywide average, and has declined substantially since 2010. More than half
of the city’s households are married couples with no children living at home, compared to 26
percent countywide. Only 10 percent of the city’s households are “other” families (mostly single
parent households), which is less than half the countywide average. Rolling Hills also has a far
smaller percentage of non-family households than Los Angeles County, representing 21 percent
of the city compared to 34 percent countywide. The city’s demographics are indicative of a
relatively stable, older population with smaller households than the county as a whole.
Figure A-4 shows familial status in Rolling Hills and surrounding areas. As the map indicates,
the entire Palos Verdes Peninsula is in the same category as Rolling Hills, which corresponds to
80 percent or more of all children living in married couple households. The rate is considerably
lower in adjacent cities in Los Angeles County but is still at least 60 percent in most of the South
Bay cities. Rates below 60 percent occur in some of the census tracts in the Harbor area of Los
Angeles, including San Pedro. Rates below 60 percent are also found beyond the South Bay, in
locations such as Compton, Inglewood, Carson, Northern and Central Long Beach, and South
Central Los Angeles. These are generally lower resource areas, with higher rates of poverty
and unemployment, and lower rates of home ownership.
Income Level
Activities funded by federal community development and housing programs are typically
designed to benefit low- and moderate-income (LMI) persons. For example, activities qualify for
Community Development Block Grant (CDBG) funding if they benefit the residents of a primarily
residential area where at least 51 percent of the residents are low- and moderate-income.
Accordingly, HCD has used Census income data to map these areas by Census block group.
This is shown in Figure A-45.
The Figure illustrates that there are no LMI areas in Rolling Hills or in any of the adjacent
communities on the Palos Verdes Peninsula. Fewer than 25 percent of Rolling Hills’ residents
are LMI. While there are a few block groups in Rancho Palos Verdes that are 25-50 percent,
none exceed 51 percent. There are multiple LMI block groups in San Pedro and the Harbor
neighborhoods east of the Palos Verdes Peninsula. There are also LMI areas in Lomita and
Torrance to the north.
Figure A-56 shows median income by Census block group. The Palos Verdes Peninsula is one
of the most affluent parts of Los Angeles County, with Rolling Hills among the highest income
census tracts in the County.
Figure A-7 shows median income for a larger geographic area, including most of the urbanized
part of Los Angeles and Orange Counties. At the regional level, the Palos Verdes Peninsula
stands out as an affluent area with incomes above $100,000. The Beach cities of Manhattan,
Hermosa, and Redondo Beaches are also in this category, as are numerous census tracts on the
west side of Los Angeles, the base of the San Gabriel Mountains, and Orange County. The
lower income areas are generally located in central and south Los Angeles County, East Los
Angeles, the southeast part of the San Fernando Valley, and the older suburbs in Orange
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County. Many of these areas include high concentrations of persons of color who historically
faced discrimination in the housing market.
Comparative income data between the city and region is shown in Table A-4. As the table
indicates, Rolling Hills has a substantially higher income profile than the county, with well over
half of its population earning over $200,000 a year, compared to 11 percent in the county as a
whole. By contrast, only 15 percent of the city’s households earn less than $50,000 a year,
compared to 36 percent countywide. However, it is notable that the percentage of households
in Rolling Hills earning less than $25,000 a year grew from 4.5 percent of the population in 2010
to 6.4 percent in 2020. This is likely due to the growing number of households aging in place
and living on fixed incomes. Countywide, the percentage of households in this category
declined over the decade, from 24 percent to 18 percent.
Table A-4: Household Share by Income, Rolling Hills and Los Angeles County
Percent of Residents by Income
in Rolling Hills
Percent of Residents by Income
in Los Angeles County
2010 2020 2010 2020
Less than $10,000 1.5% 1.5% 6.8% 5.5%
$10,000-$14,999 0.7% 2.7% 6.1% 4.6%
$15,000-$24,999 2.3% 2.2% 11.1% 7.8%
$25,000-$34,999 4.8% 4.7% 9.7% 7.6%
$35,000-$49,999 2.5% 4.5% 13.5% 10.7%
$50,000-$74,999 4.9% 3.3% 17.4% 15.8%
$75,000-$99,999 4.9% 3.5% 11.7% 12.3%
$100,000-$149,999 14.1% 12.0% 12.8% 16.3%
$150,000-$199,999 11.0% 12.0% 5.3% 8.2%
$200,000 or More 53.3% 53.6% 5.5% 11.1%
Median Income $219,688 $250,000+ $52,684 $71,358
Sources: American Community Survey, Five-Year Averages, 2010 and 2020
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-14
Racially and Ethnically Concentrated Areas of Poverty (R/ECAP) and Affluence
Racially/ethnically concentrated areas of poverty –or R/ECAPs—are census tracts identified by
HUD with a majority non-White population (greater than 50 percent) and poverty rates that
exceed 40 percent or are three times the average tract poverty rate for the metropolitan area,
whichever is lower. Figure A-86 shows the location of R/ECAP areas in southern Los Angeles
County, including the City of Los Angeles.
The largest concentration of R/ECAP areas in the County are in and around Downtown Los
Angeles, the neighborhoods south of Downtown, and a few tracts in the Harbor area and Long
Beach. There are no R/ECAP areas on the Palos Verdes Peninsula.
HCD also has identified “racially concentrated areas of affluence” (RCAAs). These are areas
that exhibit both high concentrations of White residents and high concentrations of wealth. With
a population that is 70 percent White, Non-Hispanic and a median income of over $250,000, all
of Rolling Hills is considered an RCAA. Large areas of Rancho Palos Verdes, Rolling Hills
Estates, and Rancho Palos Verdes also meet the RCAA criteria. Other parts of Los Angeles
County considered to be RCAAs include Malibu, Santa Monica, Bel Air/ Brentwood, Westwood,
Beverly Hills, and adjacent parts of the West Side, as well as La Canada-Flintridge and several
other outlying communities.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-15
Figure A-4:
Familial Status
NEW MAP
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Historic Context
Like many communities in Southern California, Rolling Hills reflects cultural and social norms of
the era in which the city was founded and initially developed. These norms predated the Fair
Housing Act and civil rights movement and included practices that excluded certain racial and
ethnic groups from purchasing property.
As Table A-5 indicates, Rolling Hills is almost exclusively comprised of single family homes.
Even between 2010 and 2020, the composition of the City’s housing stock did not change
significantly. In Los Angeles County, fewer than half of the housing units are single family
detached homes and more than one-third are in multi-family buildings. The county as a whole
has seen the share of multi-family units go up over time. By contrast, the California Department
of Finance reports that 99.9 percent of the dwelling units in Rolling Hills are single family homes.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-20
Table A-5: Housing Units by Type, Rolling Hills and Los Angeles County
Number/Percent of Total
in Rolling Hills
Number/Percent of Total
In Los Angeles County
2010 2020 2010 2020
Single Family Detached 715
99.9%
718
99.9%
1,717,448
49.9%
1,732,045
48.2%
Single Family Attached 0 0 228,560
6.6%
234,107
6.5%
2-4 units 0 0 282,178
8.2%
295,700
8.2%
5+ units 1
0.01%
1
0.01%
1,156,648
33.6%
1,270,425
35.4%
Mobile Homes 0 0 58,253
1.7%
58,297
1.6%
TOTAL 716 719 3,443,087 3,590,574
Source: California Dept of Finance Table E-5, 2010 and 2020.
Note: (*) The State’s data indicates that there is a building with five or more units in Rolling Hills. This is incorrect, as there are no
multi-family units in Rolling Hills at this time.
The history of Rolling Hills is linked to broader early 20th Century efforts to develop the 16,000-
acre Palos Verdes Peninsula as a master planned community. Prior to 1910, the entire area was
farm and ranchland. Several development concepts were proposed in the 1910s and 20s,
including a plan to divide the peninsula into large estates (Vanderlip, 1914) and the “Palos
Verdes Project,” which eventually became the City of Palos Verdes Estates. Long before Rolling
Hills was subdivided, the Peninsula had gained a reputation as the “Riviera of America” and was
renowned as an exclusive and beautiful place to live.1
A.E. Hanson became manager of the Palos Verdes Corporation in 1931. He laid out the
boundaries of a development named Rolling Hills, just beyond the boundaries of the Palos
Verdes Project. The community was initially marketed to residents of Los Angeles and Beverly
Hills as 10 to 50 acre “dude ranches.”2 In 1936, it was reimagined as an equestrian community
of one- to five-acre homesites. The initial development included 100 homesites on 600 acres.
All homes were required to be one-story ranches, painted white, a requirement that remains in
place today. The Covenants, Codes, and Restrictions (CC&Rs) were a strong part of the
community’s appeal, as they assured maintenance and uniformity throughout the years.
Rolling Hills was subdivided by a single large owner. In that respect, it is more akin to a large
residential subdivision, rather than a traditional city or town with multiple land uses, developers,
and housing types. Moreover, its first generation of housing consisted of modest one-story
ranch-style homes, including homes smaller than 2,000 square feet. Multi-family housing was
excluded from the community to retain its rural, equestrian character and to recognize what was
1 Morgan, Delane. The Palos Verdes Story, 1982
2 Rolling Hills General Plan Land Use Element, 1990
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-21
then a remote and rugged location with no services. As a community of small horse ranches
with no sewer system, high fire danger, and private streets, construction of multi-family housing
would not have made economic sense.
As the Palos Verdes Peninsula was built out at suburban densities in the 1950s and 60s, Rolling
Hills retained its very low density zoning. Some of the adjacent cities on the Peninsula added
multi-family housing, but the established lot pattern in Rolling Hills and its CC&Rs made this
infeasible. In this respect, the CC&Rs had an exclusionary impact on the community. The City
incorporated in 1957 to further protect its very low-density character. As this became a rarer
commodity in southern Los Angeles County, real estate values increased substantially. Much of
the original 1930s and 40s era housing stock was replaced with newer, larger housing with
many more amenities. The city became a “location of choice” and became less affordable.
These changes were largely economic and driven by the dynamics of the private real estate
market. They occurred after the passage of the Fair Housing Act and the era of redlining.
However, the conditions were compounded by historic inequities in access to capital among
racial monitories and a legacy of discriminatory lending practices in the United States. Housing
opportunities for lower income households have not historically existed in the city. The city’s
identity and history is rooted in its low density, rural character and equestrian heritage.
Fair housing solutions that reflect the City’s history and character can and should be pursued.
These include creating housing opportunities on the recently rezoned Rancho Del Mar site, and
encouraging greater production of accessory dwelling units in the community. They also
include enforcement of fair housing laws and increased awareness of fair housing rights and
practices, as well as the history of housing practices in California.
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Access to Opportunity
California HCD and the California Tax Credit Allocation Committee (TCAC) convened a task
force to advance fair housing through research and policy recommendations. One of the
products of this effort was a series of “opportunity maps” that identify resource levels across the
state. The intent of these maps is to improve the eligibility of “high resource areas” for low-
income housing tax credit funding. Improving access to these funds makes it more viable to
build affordable housing in these areas.
The opportunity maps depict composite data on environmental conditions (vulnerability to
pollution, etc.), economic conditions (poverty, job proximity, home values), and educational
conditions (graduation rates, math and reading proficiency, etc.). HCD has made these maps
available through its AFFH data viewer. Conditions in Rolling Hills are depicted in Figures A-97
through A-120. On all of these maps, each census tract is assigned a value based on its level of
resources. The higher the value, the more positive the outcome.
TCAC Environmental Outcomes
In this context, environmental conditions refers to environmental health and exposure to man-
made hazards such as vehicle exhaust, industrial emissions, and cancer-causing chemicals. It
does not refer to natural environmental hazards such as wildfire and landslides.
Figure A-97 indicates that outcomes in Rolling Hills are positive, as the community does not
have industrial land uses or major pollution sources. Rolling Hills has an environmental score of
0.97, which is close to the highest possible score of 1.0. All of the Census tracts on the Palos
Verdes Peninsula have scores of 0.75 or greater. Rolling Hills Estates also receives a 0.97
rating, while Rancho Palos Verdes varies from 0.82 to 0.98. Just two miles east of the city limits,
near the Phillips 66 refinery, the environmental score is 0.03. Refineries and heavy industrial
uses along the 110 Freeway and in the Port of Los Angeles vicinity result in low environmental
rankings in a number of Census tracts around San Pedro and Wilmington. Scores are also
below 0.50 around the Zamperini Airfield in Torrance, and in parts of Downtown Long Beach.
The City also is in the highest-ranking category using the Cal EnviroScreen maps and is highly
ranked on the Public Health Alliance of Southern California “Healthy Places Index.”
Environmental outcome values are also high in the other Peninsula cities. Exposure to
environmental hazards is much higher along the freeways and in the Harbor area, where
industrial uses and refineries are more prevalent.
TCAC Economic Outcomes
Figure A-108 shows economic outcomes in southern Los Angeles County. This is generally a
measure of wealth and access to jobs. Rolling Hills and all of the Peninsula cities are in the
highest category, reflecting high rates of home ownership, high home values, and high incomes.
The census tracts to the east have more diverse ratings, with low ratings in Northwest San
Pedro and Wilmington.
The TCAC Opportunity Score for Rolling Hills is 0.86, which is in the highest of the four quartiles
shown on the opportunity map. Neighboring census tracts in Rolling Hills Estates and Rancho
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Palos Verdes have comparable scores, generally ranging from 0.75 to 0.95. Just to the east, in
the Harbor neighborhoods of Los Angeles, the economic index is as low as 0.04 in some census
tracts. Areas of strongly positive and much less positive economic outcomes exist in close
proximity in this area, a legacy of historic land use and development patterns. To the north of
Rolling Hills, the City of Torrance has economic opportunity scores that are comparable to the
Palos Verdes Peninsula, despite a more moderate-income profile. Torrance is predominantly
White and Asian, while the Harbor neighborhoods are primarily Latino, an indication that race
and ethnicity have influenced economic opportunity in the area.
TCAC Educational Outcomes
Educational outcomes are shown in Figure A-119. Rolling Hills is in highest quartile, with
positive educational outcomes. The City’s score is 0.96, on a scale of zero to 1.0. This reflects
the community’s high wealth and access to education. Adjacent neighborhoods in Rolling Hills
Estates and Rancho Palos Verdes have identical scores, while scores in the beach cities to the
north are even higher. Conversely, scores step down in several bands moving to the east, with
the third quartile just east of Rolling Hills, then the second quartile, and then the lowest quartile
in San Pedro roughly four miles east. Low outcomes also appear in Wilmington and the Less
positive outcomes appear in the census tracts to the east, with the lowest outcomes in the San
Pedro area and in the neighborhoods around the Port of Los Angeles.
Transportation
Public transportation to and from Rolling Hills is poor and there is no transit service at all within
the city limits. The Palos Verdes Peninsula Transit Authority operates buses along Palos Verdes
Road North, which serve the northern edge of the city and provide service to the Peninsula’s
commercial centers as well as San Pedro. Connecting service is available along those routes to
other transit systems (including the Metro Silver Line in San Pedro), providing connections to
Los Angeles and other regional destinations. However, given the distance and travel time, these
are not generally viable means of transport to workplaces. US Census data indicates that zero
percent (0.0%) of the city’s residents use public transit to commute to work.
Composite Opportunity Map
Figure A-120 is a composite of the TCAC analysis, taking the three above variables into
consideration. The Figure affirms what is shown in Figures A-97, -108, and -119. Rolling Hills is
a high-resource, high opportunity area, with positive environmental health indicators, positive
economic outcomes for its residents, and access to quality education. Because of the city’s
small size, these opportunities are homogenously distributed across the community. The same
conditions are found in the other Palos Verdes Peninsula neighborhoods, some of which have
even higher composite scores than Rolling Hills.
Figure A-120 provides a more regional perspective than Figures A-97, -108, and -119. The
pattern immediately evident on this map is that the coastal communities of Los Angeles County
are almost all in the highest resource category. There is a swath of moderate and low resource
neighborhoods extending from Downtown Los Angeles southward to the Port of Los Angeles.
Areas extending from Central LA southward are highlighted on the map as having high
segregation and poverty rates, corresponding with the lowest level of opportunity. Moving
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further east, the pattern becomes more diffuse, with a patchwork of high, moderate, and low
resource areas extending toward the San Gabriel Valley and Orange County.
The high opportunity ranking given to Rolling Hills was part of SCAG’s rationale for assigning the
city a large allocation in the 6th Cycle RHNA. The base number of units assigned to the city by
SCAG was calibrated upward based on their “social equity adjustment,” resulting in Rolling Hills’
45 units (compared to six units in 2013-2021). This reflects several mandated objectives of the
RHNA methodology, including promoting socio-economic equity and balancing disproportionate
household income distribution across the region.
As indicated earlier in this analysis, the Rancho Del Mar School site provides the best location to
improve access to opportunity and affirmatively further fair housing within Rolling Hills. The site
has the potential to improve economic outcomes for lower income households by providing
affordable housing in a high-resource area.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-25
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Disproportionate Housing Needs
“Disproportionate housing needs” refer to conditions in which members of a protected class
within a defined geographic area experience much higher housing needs than the population at
large.3 Following HCD guidance, the analysis to identify disproportionate needs considers cost
burden, overcrowding, and substandard housing conditions. Much of this data also is contained
in the Housing Element Needs Assessment (Chapter 3), but the focus here is on extremely low-
income residents, tenure, and persons of color. As noted in earlier sections of this Appendix,
the analysis for Rolling Hills is hampered by the small size of the community and the fact that it
contains only one Census Block Group. The margin of error for American Community Survey
(ACS) data for the city is high, and the number of residents in protected classes is small. Where
available, maps are used to compare data for Rolling Hills with data for surrounding
communities.
Tenure and Tenure by Race
Table A-6 shows tenure in Rolling Hills and Los Angeles County as a whole. Relative to the
region, Rolling Hills has a much higher rate of homeownership. The rate exceeded 95 percent in
2020, compared to 46 percent regionally. As in the County, the percentage of renters increased
slightly between 2010 and 2020, but the number remains very small.
Rates of home ownership often vary by race and ethnicity. Regionally and nationally, the rate of
home ownership is substantially lower for Black/African-American households than it is for White
households. This is not the case in Rolling Hills. The 2015-2019 ACS indicates that 100 percent
of the Hispanic, Black, and multi-racial households in the city are homeowners. For White
households, 95 percent are homeowners and 5 percent are renters. Among Asian households,
98 percent are homeowners and 2 percent are renters.
Table A-6: Housing Tenure in Rolling Hills and Los Angeles County
Percent of Households
in Rolling Hills
Percent of Households
in Los Angeles County
2010 2020 2010 2020
Owners 96.9% 95.1% 46.9% 46.0%
Renters 3.1% 4.9% 53.1% 54.0%
Sources: American Community Survey Five-year averages for 2010 and 2020
3 The protected classes are race, color, religion, national origin, sex, familial status, and disability.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-30
Cost Burden
As noted in Chapter 3, a household is considered cost burdened if more than 30 percent of its
income is spent on housing (including utilities). Figures A-131 and A-142 depict the incidence
of cost burden for owners and renters in Rolling Hills and surrounding communities. Table 3.9
(in Chapter 3) indicates the percent of income spent on housing for homeowners with a
mortgage, homeowners without a mortgage, and renters. Roughly 31 percent of the city’s
households are considered cost-burdened, but most have above moderate incomes.
The US Department of Housing and Urban Development publishes data on the number of
households that are cost-burdened in each community using federally-defined income
categories. This is referred to as the CHAS (Comprehensive Housing Affordability Strategy)
data. According to the CHAS 2014-2018 data, there are 100 low- and very low-income
households in Rolling Hills (i.e., earning 80 percent or less of the areawide median income
[AMI]). These households include 83 who were cost-burdened, including 65 who were defined
as being “severely” cost-burdened (spending more than half their incomes on housing).
CHAS data indicates that 78 of the cost-burdened lower-income households were homeowners
and the remainder were renters. The relatively high number of cost-burdened low-income
homeowners is likely associated with retired seniors on fixed incomes, who must still pay
property taxes, utilities, insurance, HOA dues and other housing costs—even after their
mortgages are paid off. These expenses may be several thousand dollars a month. In fact, the
CHAS data indicates that there are 25 extremely low-income households in Rolling Hills (earning
less than 30% of AMI), all of whom are homeowners. The most recent available CHAS data
indicates that there are no extremely low-income renters in the city.
CHAS data identifies 10 very low-income renter households in the city (30-50% of AMI), along
with 30 very low-income owners. Seventy-five percent of these households pay more than 30%
of their incomes on rent.
As illustrated in Figures A-113 and A-142, the incidence of cost burden is somewhat lower in
Rolling Hills than it is in adjacent communities, including those on the Palos Verdes Peninsula.
Figure A-13, which is based on American Community Survey (ACS) data for 2015-2019,
identifies Rolling Hills as being in the 20-40% overpayment interval for homeowners. In other
words, between 20 and 40 percent of its owner-occupied households spend more than 30
percent of their incomes on housing. The city is surrounded on all sides by census tracts with
rates in the 40-60% interval. This is not an indication that homes in Rolling Hills are more
affordable, but rather a reflection of the length of residency and the large number of
homeowners in Rolling Hills who have no mortgages. About 37 percent of the city’s
homeowners have lived in their homes for over 30 years. Rates of homeowner overpayment are
higher in the San Pedro area of Los Angeles, several miles east of Rolling Hills and in lower
income census tracts throughout Central Los Angeles County. On the other hand, the rate in
Rolling Hills is comparable to many cities in the county, including Torrance, Carson, Palos
Verdes Estates, and the Beach cities to the north.
Figure A-14, which is also based on ACS data for 2015-2019, identifies Rolling Hills as also
being in the 20-40% overpayment interval for renters. However, this is based on a sample of a
very small demographic, since there are only 27 renter households in the entire city. As Figure
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A-14 indicates, the rate of overpayment is significantly higher in the portion of Rancho Palos
Verdes located immediately east of the city, and in the portion of Rolling Hills Estates located
immediately west of the city. There are also nearby tracts with overpayment rates that are less
than 20 percent. On a regional basis, the percentage of renter overpayment in Rolling Hills is
low. Most tracts in Los Angeles, Long Beach, and the larger suburban cities have rates in the 40
to 60 percent range. Rolling Hills renters tend to be more affluent, and are typically renting
single family homes rather than apartments.
Cost-burden data is also shown in Table A-7 below. As the table indicates, most extremely low-
income households in Rolling Hills were considered severely cost-burdened in both 2010 and
2020. Most lower income homeowners and many lower income renters (i.e., those earning 80
percent of areawide median or lower) were also cost-burdened. Rates of cost-burden were
even higher in Rolling Hills than in the county as a whole. However, the data for Rolling Hills in
Table A-7 is based on a very small number of households, leading to a high statistical margin of
error (for instance there are only 10 lower income renter households in the city). At a
countywide level, about 63 percent of all low-income homeowners and 75 percent of all low-
income renters are cost-burdened.
Table A-7: Percentage of Cost-Burdened Households, Rolling Hills and Los Angeles
County
Percent of Households
in Rolling Hills (*)
Percent of Households
in Los Angeles County
2008-2012 2014-2018 2008-2012 2014-2018
Cost-burdened households earning less than 80% AMI (low income)
Owners
Paying > 30% 78.8% 86.7% 66.3% 63.1%
Paying > 50% 61.2% 66.7% 44.3% 40.2%
Renters
Paying >30% 100.0% 80.0% 73.3% 75.1%
Paying > 50% 0% 40.0% 43.0% 44.5%
Cost-burdened households earning less than 30% AMI (extremely low income)
Owners
Paying > 30% 100.0% 76.0% 74.7% 75.4%
Paying > 50% 100.0% 60.0% 62.4% 63.0%
Renters
Paying > 30% 100.0% 0% 82.4% 81.7%
Paying > 50% 0% 0% 70.4% 70.2%
Sources: CHAS HUD User website, data for 2008-2012 and 2014-2018. Data for Rolling Hills indicates 4 lower income renter
households in 2008-2012 and 10 lower income renter households in 2014-2018
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Overcrowding
As noted in Chapter 3, a household is considered overcrowded it the housing unit it occupies
has more than one person per room, excluding kitchens and bathrooms. As noted on page 3-
11, only one percent of the city’s households meet this definition. There are no households in
the city that meet the definition of “severe” overcrowding, which is more than 1.5 persons per
room. Moreover, the data indicates that none of the renter-occupied households in the city
were overcrowded. There were six owner-occupied units with more than one person per room.
Figure A-135 shows this information spatially, illustrating that units on the Palos Verdes
Peninsula are generally not overcrowded. All of the tracts in all four Peninsula cities have
overcrowding rates below 8.2 percent, which is the statewide average. Units in the more
urbanized areas to the east, with higher percentages of renters and smaller housing units, are
more likely to be overcrowded. Tracts in the Wilmington and San Pedro areas have rates
exceeding 20 percent in some cases. Further north, tracts in South Central Los Angeles,
Compton, Southgate, Lynwood, Compton, and other more diverse and lower income
communities have higher rates of overcrowding.
Table A-8 shows household overcrowding in Rolling Hills and the region.
Table A-8: Overcrowded Households, Rolling Hills and Los Angeles County
Percent of Households
in Rolling Hills
Percent of Residents
in Los Angeles County
2010 2020 2010 2020
Owner Households
Less than 1.0
persons per room 99.5% 99.4% 93.9% 94.3%
1.01-1.50 persons
per room 0.5% 0.6% 4.6% 4.1%
1.51-2.00 persons
per room 0 0 1.1% 1.1%
2.01 or more
persons per room 0 0 0.3% 0.5%
Renter Households
Less than 1.0
persons per room 100.0% 100.0% 82.4% 84.0%
1.01-1.50 persons
per room 0 0 9.8% 8.5%
1.51-2.00 persons
per room 0 0 5.2% 5.3%
2.01 or more
persons per room 0 0 2.6% 2.2%
Sources: American Community Survey Five-Year averages for 2010 and 2020
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Table A-8 confirms that rates of overcrowding are much lower in Rolling Hills than in Los
Angeles County, with no overcrowded rental units and only 0.5 percent of the owner-occupied
units meeting the Census definition of overcrowding. Moreover, the data indicates almost no
change between 2010 and 2020. By contrast, the countywide data shows that about 6 percent
of owner-occupied units and 16 percent of rental units are considered overcrowded. In most
cases, the percentages did not change significantly between 2010 and 2020.
Housing Problems
The HUD CHAS data indicates how many households in each community experience one of four
specific housing problems—these problems are (a) lack of a complete kitchen; (b) lack of
complete plumbing facilities; (c) overcrowding; and (d) severe cost burden (paying more than 50
percent of income on housing). According to CHAS data for 2014-2018, there are about 110
owner-occupied households in Rolling Hills and four renter households in Rolling Hills with one
or more of these problems. Since all housing units in the city have kitchens and baths, and only
six are overcrowded, the primary problem experienced is a severe housing cost burden. The
CHAS data indicates there are 105 owner-occuped households with a severe housing cost
burden. Most of these are lower-income senior households
Figure A-146 shows this data on a regional level. The rate of housing problems is higher in
Rolling Hills than it is in the other Palos Verdes Peninsula cities, due to the high percentage of
senior homeowners living on fixed incomes and paying substantial portions of their incomes on
housing. However, the city’s rate is comparable to other affluent areas on the west side of Los
Angeles and is lower than in the neighborhoods and communities immediately south and
immediately east of Los Angeles.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-38
Displacement Risk
Figure A-175 illustrates “sensitive communities” in the southern half of Los Angeles County.
These are communities with relatively high risks of displacement due to rising rents and a lack of
tenant protection. None of the Palos Verdes Peninsula cities are shown as vulnerable. On the
other hand, most of the tracts in the City of Los Angeles, including the San Pedro and
Wilmington communities, are shown as vulnerable. The entire South-Central area of Los
Angeles is vulnerable, as are nearby communities such as Compton, Inglewood, and Hawthorne.
As depicted on Figure A-175, vulnerable communities are communities in which at least 20
percent of the population is low income and two or more of the following conditions are present:
• Renters are over 40% of all households
• People of color are 50% or more of the population
• Share of severely cost-burdened very low income renters is above county median
• Rents have been increasing at faster rate than county median
• Larger than average gap between local rents and rents in surrounding tracts
These conditions are not present in Rolling Hills.
Figure A-175: Sensitive Communities
Census tracts in
purple are
designated as
“vulnerable” due
to displacement
risk
ROLLING HILLS
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-39
Due to the very high percentage of home ownership, Rolling Hills does not face displacement
risk. Displacement may occur due to other reasons, such as an aging household unable to
maintain their property or afford the modifications needed to age in place.
Homelessness
Homelessness in Rolling Hills is addressed in Section 3.4.8 of the Housing Element (Chapter 3).
As indicated there, the annual point-in-time count for Los Angeles residents identified no
unhoused residents in the city in 2016, 2017, 2018, 2019, or 2020. Figure A-18 shows the
spatial extent of homelessness at a regional level based on data provided by the County of Los
Angeles. The table shows that there were three unhoused residents per square mile in all four
of the Palos Verdes Peninsula cities. The density is highest in Downtown Los Angeles, Venice,
and various neighborhoods on LA’s West Side and South Central areas. Some of these areas
have more than 500 unhoused residents per square mile. The relatively low densities on the
Palos Verdes Peninsula reflect the absence of shelter facilities, supportive services, non-
residential land, and public lands where outdoor camping might occur.
Other Populations with Special Needs
Chapter 3 of the Housing Element identifies special needs populations in Rolling Hills. The
principal special needs group is older adults, with one-third of the city’s population over 65. As
noted in Section 3.3.1, 56 percent of the households in Rolling Hills include at least one person
who is 65 or older. Most of the persons with disabilities and all of the extremely low income
households in the city are seniors. Rolling Hills has a very small number of single parents and
large households, and it does not have unhoused residents or farmworkers.
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NEW MAP
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-41
Other Relevant Factors
The State’s guidance for AFFH requires that other relevant factors contributing to fair housing
issues be evaluated as part of this analysis. As explained in the next section, the principal
contributing factor is that Rolling Hills was developed as an equestrian community in which
multi-family residential uses were not permitted. The city’s single family character was
reinforced by minimum lot size requirements (one acre) and a (now repealed) prohibition on
Accessory Dwelling Units which made it difficult for low and moderate income persons to afford
housing in the community. These requirements effectively limited the rental housing supply to
very expensive single family homes and resulted in a tenure pattern in which more than 97
percent of the households in the city are homeowners.
Governmental spending on affordable housing and the implementation of housing programs is
severely limited by the small size of the city (fewer than 700 homes), the lack of any tax-
generating land uses other than housing, the high cost of land and construction, and severe
environmental hazards in the community. Historically, there have no instances of transportation
or infrastructure improvements causing the displacement of lower income households. As
documented in Chapter 5 of the Housing Element, there are no public streets in the city and
almost no properties served by sanitary sewers. This has been an impediment to the
development of multi-family housing.
The high cost of housing in Rolling Hills has historically precluded low- and moderate-income
households from living in the city, unless they were home care providers, domestic employees,
persons renting a room, family members, or seniors without a mortgage. Additionally, lending
practices historically favored White borrowers, making the city less diverse than the county and
region. This has changed in the past few decades and Rolling Hills has become more racially
diverse. However, the city has not become economically diverse.
Based on Census (ACS 2015-2019) data, there are not significant differences in the rates of
home ownership among different race and ethnic groups in Rolling Hills. As shown in Table A-9,
the data indicates that all Black and Latino households in the city are homeowners, and that all
renter households in the city are White or Asian. However, the findings are based on sample
data and the sample sizes are very small. The greater takeaway is that housing in the city
continues to be affordable only to very high income households.
Table A-9: Rolling Hills Home Ownership Rates by Race/Ethnicity
Race/Ethnicity Owners Renters Total % Owners
White, Non-Hispanic 360 8 368 98%
Asian, Non-Hispanic 101 16 117 86%
Black, Non-Hispanic 9 0 9 100%
Hispanic/Latino 28 0 28 100%
Two or more races 35 3 38 92%
Source: American Community Survey, 2015-2019 (2022)
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-42
Local Data and Knowledge
HCD’s guidance for the AFFH analysis indicates that cities should use local data and knowledge
to analyze fair housing issues, including information obtained through community participation
or consultation. The regional demographic data help show spatial patterns but do not expressly
explain why problems exist. An additional screen of local insights is necessary to complement
federal and state data sources.
While there is no specific local data on fair housing specific to Rolling Hills, the circumstances
behind the spatial patterns shown throughout this analysis are mostly self-evident. The city was
master planned more than 80 years ago as a low-density equestrian community with large
parcels marketed to prospective homeowners. Rental housing was not included in these plans
and CC&Rs were drafted and enforced to maintain single family character. The lack of sewers,
risk of wildfire and landslides, and absence of public streets created further disincentives for
multi-family housing, while also increasing construction costs. More recently, the high cost of
land has made affordable housing construction economically infeasible, which will continue to
be an impediment in the future.
Rolling Hills is also an entirely residential community. There are no private businesses in the city
limits, except for a handful of home-based occupations. Employment is associated with the
PVPTA maintenance yard, the Rancho Del Mar school building, the Fire Station, and the City
Hall/ Rolling Hills Community Association buildings, which collectively employ just over 100
people. Housing demand is not generated by businesses within the city. There are no
underused commercial sites to be repurposed for housing, since there have never been
commercial land uses in the city.
Rolling Hills does generate demand for services that create jobs, including low-income jobs.
Local homeowners provide employment for caregivers and home health care workers, au pairs
and home child care providers, landscapers and domestic workers, personal assistants, and
those in the construction trades. Housing for this workforce has been largely unavailable in the
city, although some of these employees may live on-site and are considered part of the primary
household.
Local data and knowledge supports a fair housing strategy that is heavily focused on housing
this population in ADUs, potentially at reduced rents. The service industry population is
generally more racially and ethnically diverse than the city at large. Providing additional ADU
and JADU opportunities would help contribute to the State’s integration and equity goals while
improving access to housing in a high-resource area. It can also reduce commuting and
associated congestion and greenhouse gas emissions.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-43
Distribution of Proposed Housing Sites
This section of the AFFH analysis evaluates the City’s site inventory to ensure that the
distribution of sites does not exacerbate patterns of segregation, access to opportunity, and
disproportionate housing needs. The site inventory must be consistent with each community’s
duty to affirmatively further fair housing.
Rolling Hills presents a unique situation in this regard, as the entire city consists of just one
census block group. Data for this one tract indicates that the entire city is in the highest
resource category. The land use pattern is homogenous and consistent in all parts of the city,
and there are no observable disparities in housing condition, demographics, or income at the
neighborhood level.
Additionally, the city’s lower income RHNA is 29 units. While the State mandate calls for
distributing opportunities on multiple sites in each city, the economics of affordable housing
development make this impractical in Rolling Hills. The City is more likely to see affordable units
developed on a single site capable of supporting a critical mass of at least 16 units than on
multiple sites capable of accommodating a few units each.4 The City will distribute affordable
opportunities through a strategy that relies on its housing opportunity site and about a dozen
accessory dwelling units (ADUs) on scattered sites.
The development of affordable housing on the Rancho Del Mar site furthers the goals of AB 686
by providing a viable opportunity for affordable housing in a very high resource area. This
opportunity did not exist prior to 2020 when the site was rezoned. Moreover, the City has
adopted provisions to allow the development “by right” creating a path to expedited approval.
As documented in Chapter 4, this is the only viable site in Rolling Hills for higher density housing
given the lack of sewer and a public road system. It is also one of the few sites that is accessible
to transit and evacuation routes.
Meeting the remaining lower income need for affordable units through ADUs is a practical,
effective way to meet the intent of AB 686 while dispersing opportunities across a large
geographic area. By definition, ADUs distribute affordable housing opportunities across the
community rather than concentrating them in a single location. They are also responsive to very
real opportunities in Rolling Hills, resulting from large house sizes, numerous accessory
buildings, a large number of one- and two-person households, and an aging population. The
City’s new ADU program has a demonstrated track record of success, with nine units permitted
in 2021. Continued efforts to support ADUs will allow Rolling Hills to achieve AFFH goals in a
way that is realistic, practical, responsive to local conditions, and produces real results.
4 While the base density for the Rancho Del Mar site is 16 units, the City requires that the site be developed with 100% affordable
housing. Thus, it will be eligible for an 80% State density bonus which would enable 29 units in total.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-44
Identification and Prioritization of Contributing Factors
“Contributing factors” are the underlying forces that create, contribute to, perpetuate, or
increase the severity of fair housing issues. In its AFFH Guidance Memo (2021), HCD has
identified eight contributing factor topic areas, including general outreach, fair housing
enforcement and outreach capacity, segregation and integration, racially and ethnically
concentrated areas of poverty, disparity in access to opportunity, disparity in access for persons
with disabilities, disproportionate housing needs and displacement risks, and the site inventory.
Under each of these topic areas, the Guidance memo lists individual issues which can
potentially be addressed by a Housing Element action. According to HCD, examples of
contributing factors are community opposition to affordable housing, housing discrimination,
land use and zoning laws, lack of regional cooperation, lack of affordable housing, and lack of
public or private investment in areas of opportunity or affordable housing choices.
AB 686 requires that the City strategically prioritize the contributing factors and develop
programs that mitigate these these factors through its goals, policies, and actions. The Housing
Element must include programs that mitigate discrimination and improve fair housing choices
and access to opportunities in high resource areas. HCD generally groups these actions into
the following four categories:
• Housing Mobility Strategies, which consist of removing barriers to housing in areas of
opportunity
• New Housing Choices and Affordability, which include strategies to promote more
housing supply and choices in areas of high opportunity and outside areas of
concentrated poverty
• Place-based strategies to Encourage Community Conservation and Revitalization, which
include approaches to conserve and improve assets in areas with concentrated poverty
and lower opportunities
• Protecting Residents from Displacement, which includes strategies to preserve housing
choices and affordability for residents within low and moderate opportunity areas.
Given that Rolling Hills is a high-resource, high-opportunity area, all of the City’s AFFH strategies
fall in the first two of these categories.
Following is an assessment of factors that could contribute to fair housing issues in Rolling Hills,
along with strategies that mitigate these factors.
Priority 1: Address Disparities in Access to Opportunity
Contributing Factors:
• Land Use and Zoning Laws
• Lack of Public Investment in Services and Amenities
The City’s highest AFFH priority is to address disparities in access to opportunity. These
disparities have been created primarily by land use and zoning laws, coupled with economic
conditions and environmental hazards that precluded multi-family housing in Rolling Hills.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-45
The City historically has had no rental housing and no housing opportunities for lower and
moderate income households. It has begun to remove land use and zoning barriers by allowing
and encouraging accessory dwelling units, promoting home sharing, rezoning land for multi-
family and special needs housing, and supporting public investments in infrastructure that will
facilitate future housing development. The 2021-2029 Housing Element identifies additional
steps the City will take to mitigate this contributing factor.
Specific Programs (described in Chapter 6) aimed at mitigating land use and zoning as a
contributing factor include:
• Program 2 supporting the development of affordable multi-family housing on the
Rancho Del Mar Housing Opportunity Site
• Program 4 adding definitions of transitional and supportive housing to the Municipal
Code, to clarify that these uses are subject to the same standards that apply to the other
residential uses in each zoning district
• Program 5 adopting a density bonus ordinance
• Program 6 creating incentives for ADUs
• Program 7 promoting community education on ADUs
• Program 12 supporting outreach to affordable housing service providers and
developers
• Program 13 supporting a shared housing program
Specific Programs (described in Chapter 6) aimed at mitigating lack of public investment in
services and amenities as a contributing factor include:
• Program 14 calling for sewer feasibility studies and phase one construction of a
sanitary sewer system that would serve City Hall and the community tennis courts and
potential future expansions
• Program 15 calling for potential participation in the CDBG Urban County program,
which could provide a public funding source for infrastructure and housing
improvements
This contributing factor is also mitigated by the designation of the Rancho Del Mar site for multi-
family housing, since this is the only site in the city that has sanitary sewers and access to a
public street. As noted throughout the Housing Element, most of Rolling Hills does not sewer or
public street access.
All of the above programs fall into the “New Housing Choices and Affordability” category, as
they promote more housing supply and choices in areas of high opportunity.
Priority 2: Increase Fair Housing Outreach, Education and Enforcement Capacity
Contributing Factors:
• Lack of local private fair housing outreach and enforcement
The second AFFH priority area is to improve fair housing outreach, education, and enforcement
capacity. While public agencies do not directly control the actions of private property owners
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-46
related to fair housing, they can influence outcomes. Rolling Hills has limited staff (6 FTEs) and
a severely constrained budget, no tax-generating commercial land uses, and with limited
revenue to fund new programs. The capacity to do pro-active outreach and enforcement of fair
housing complaints is constrained. As a result, owners seeking to rent property may be
unaware of fair housing laws and discriminatory practices. Likewise, tenants (or prospective
tenants) may be unaware of their rights and may face discrimination without awareness of the
opportunity for recourse. At present, there is not a formal private fair housing outreach and
enforcement program and resources for such a program are limited.
Specific Programs (described in Chapter 6) aimed at increasing fair housing outreach,
education, and enforcement include:
• Program 20 recommends that the City increase its capacity for fair housing outreach,
education, and enforcement. This would include education to those choosing to rent
their homes or ADUs regarding state and federal laws on discrimination and the
acceptance of housing vouchers.
• Program 21 calls for increased information on fair housing on the City’s website,
including a dedicated landing page with fair housing information and links to fair housing
resources.
• Program 22 calls for fair housing training for City staff.
All of the applicable strategies to address this priority fall are in the “Housing Mobility” category,
in that they are aimed at removing barriers in a high opportunity area.
Priority 3: Disparities in Access for Persons with Disabilities
Contributing Factors:
• Lack of assistance for housing accessibility modifications
• Lack of affordable in-home or community-based supportive services
As noted earlier in this Appendix and in Chapter 3 of the Housing Element, more than one-third
of Rolling Hills residents are over 65 and most of the City’s households include at least one
person over 65. This demographic has the highest rate of disability in the city, primarily
associated with mobility limitations. Sight and hearing impairments and cognitive impairments
also may affect older adults. As a rural community with very large lots and no public
transportation, persons with these limitations and impairments may face housing challenges as
well as other challenges such as the ability to evacuate in an emergency.
Specific Programs (described in Chapter 6) aimed at reducing disparities in access for persons
with disabilities include:
• Programs 6 and 7 supporting ADU development, including units for live-in caregivers
and health care providers
• Program 8 to assist senior and disabled households, including home retrofits for aging
in place. This also includes housing resources for persons with developmental
disabilities.
• Program 12 supporting home sharing, especially for senior and disabled households
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-47
All of the above programs fall into the “New Housing Choices and Affordability” category, as
they promote better choices in high opportunity areas.
Summary
Table A-10 summarizes AFFH priorities, contributing factors, fair housing issues, and applicable
housing programs.
Table A-10: Fair Housing Priorities, Issues, Contributing Factors and Strategies
Priority Fair Housing
Issue
Contributing
Factors
Program
Category
Relevant Program (see Chapter 6)
1 Disparities to
Access in
Opportunity
• Land Use and
Zoning Laws
New
Housing
Choices and
Affordability
• Program 2: Affordable multi-family housing
development on Rancho Del Mar site
• Program 4: Definitions of transitional and
supportive housing in the Municipal Code,
• Program 5: Density bonus ordinance
• Program 6: ADU incentives
• Program 7: ADU education and outreach
• Program 12: outreach to housing service
providers
• Program 13 supporting a shared housing
program
• Lack of Public
Investment in
Services and
Amenities
• Program 14: sewer feasibility studies
• Program 15: CDB Urban County Program
2 Fair Housing
Outreach,
Education,
and
Enforcement
• Lack of local
private fair
housing
outreach and
enforcement
Housing
Mobility
• Program 20: Increase capacity for fair
housing outreach, education, enforcement
• Program 21: Increased fair housing
information on City’s website
• Program 22: Fair Housing training for staff
3 Disparities in
Access for
Persons with
Disabilities
• Lack of
assistance for
housing
accessibility
modifications
• Lack of
affordable in-
home or
community-
based
supportive
services
New
Housing
Choices and
Affordability
• Program 6: ADU incentives
• Program 7: ADUs outreach for live-in
caregivers and health care providers
• Program 8: Assistance to senior and
disabled households
• Program 12: Home sharing
Environmental Constraints
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-48
The entire city is designated a Very High Wildfire Hazard Severity area. In the past, wildfires
have destroyed homes in Rolling Hills and endangered life and property. Wildfires are likely to
become a greater threat in the future due to global climate change and continue to limit the
viability of land in Rolling Hills for higher-density construction. Much of the city is landslide
prone. Landslides have destroyed Rolling Hills homes in the past and will remain an impediment
to multi-family development in the future. The City has responded to this contributing factor by
identifying the opportunity for multi-family housing on one of the only unconstrained sites in the
city.
Economics
Economic factors will continue to present a challenge to the achievement of fair housing goals in
Rolling Hills. Land and construction costs are prohibitively expensive, making it difficult to build
affordable housing. To the extent that members of protected classes often have lower incomes,
they will continue to be disproportionately affected by high housing costs. The City has little
direct control over economic pressure, as these are driven by the regional economy and real
estate market. Nonetheless, by creating the housing overlay zone on the Rancho Del Mar site, it
has created an opportunity for affordable project in a location that is less impacted by these
factors.
Land Use and Zoning Laws
Land use policies and zoning laws in Rolling Hills allow only very low densities on most sites,
recognizing the city’s identity and heritage as an equestrian community, and the infrastructure
and environmental constraints cited above. The City has worked creatively to allow for ADUs
and multi-family housing within the context of these constraints. Nonetheless, limited
opportunities for higher density housing may cause many of the conditions identified in this
analysis to continue. Various Housing Element programs are included to address this issue.
This includes adding provisions for transitional and supportive housing to the zoning regulations,
as well as density bonus regulations. It also includes proactive support for ADUs, including units
serving lower income residents and workers.
Lack of Participation in Countywide Programs
Rolling Hills does not participate in the Countywide Urban County CDBG Program. This may
limit access to some of the fair housing resources available to other cities.
Community Opposition
The 2020 Rolling Hills Housing Survey, which was focused on ADUs, indicated mixed views on
affordable housing, concerns about community character, and tremendous concern about the
city’s ability to absorb additional housing and evacuate additional residents. The survey was
anonymous and allowed for open-ended comments. While some were supportive, there were
also negative views expressed about affordable housing, renters, ADUs, and the State’s housing
mandates. This will continue to be an issue in the future and requires an ongoing community
dialogue about housing issues and the benefits of having greater housing choices.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-49
Summary of Fair Housing Issues and Additional Fair Housing Concerns
According to the California Code of Regulations, a land use practice has a discriminatory effect
where it actually or predictably results in a disparate impact on a group of individuals, or creates,
increases, reinforces, or perpetuates segregated housing patterns, based on membership in a
protected class. Such practices may still be lawful--however, the State has determined that they
should be mitigated to the extent that they increase, reinforce, or perpetuate segregated
housing patterns. In this context, the State has found that single family zoning itself has had
unintended (and in some cases, intended) discriminatory effects. In response, the legislature
has taken steps requiring local governments to accommodate additional housing units on single
family zoned sites.
Rolling Hills has adopted regulations permitting accessory dwelling units and is currently
considering legislation reflecting recently adopted SB 9. Both of these measures provide
potential opportunities for rental housing, smaller units, and more affordable units that did not
previously exist in the city. New ADU production and affordability programs affirmatively further
fair housing and promote new housing opportunities throughout the community.
Strategies to enhance mobility (i.e., transit access to Rolling Hills), preserve existing affordable
housing, and protect residents from displacement are less applicable in Rolling Hills. However,
the City’s policies and programs do aim to address disparities and create new affordable
housing opportunities in high-resource areas. The City has required that any multi-family
construction be affordable to low and very low income households, ensuring opportunities for
economic diversification rather than further concentration of affluence. Allowing market-rate
multi-family housing would only exacerbate existing concentrations of affluence and run counter
to the purpose and intent of AB 686.
Rolling Hills also has made fair housing outreach and education a priority, not only for Rolling
Hills residents but for those who may seek to move to Rolling Hills in the future. Current efforts
will be expanded in the future by making more information available and strengthening
communication with fair housing service providers.
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Appendix A: Affirmatively Furthering Fair Housing Analysis A-50
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APPENDIX B: Supplemental Analysis of the PVUSD Site Page B-1
APPENDIX B
Analysis of Palos Verdes Unified School District (PVUSD) Site
(APN 7569-022-900)
The intent of this Appendix is to provide supplemental analysis supporting the designation of the
Palos Verdes Unified School District (PVUSD) site as an opportunity site for “by right” affordable
housing in the City of Rolling Hills. This analysis was requested by the State Department of
Housing and Community Development to demonstrate the site’s capacity to provide 16 multi-
family units at a density of 20 units per acre. Land use regulations supporting such
development are required to meet the City’s 6th Cycle affordable housing allocation. Based on
existing land uses, access, infrastructure, topography and hazards, land ownership, and site
utilization, the City has determined that this represents the most viable site in Rolling Hills for
such development.
The 31-acre property is also known as the Rancho Del Mar site, as it is home to Rancho Del Mar
High School, a small continuation school with an enrollment of 32 students in 2021. The Beach
Cities Learning Center (17 students) also occupies a portion of the school building. Excluding
the adjacent playing fields and lawn, the school campus occupies just six percent of the 31-acre
site. The only other active use on the property is a Palos Verdes Peninsula Transit Authority
maintenance facility. A majority of the site is vacant.
Location and Surroundings
The PVUSD site is located at 38 Crest Road. Figure B-1 provides an aerial photo of the site to
provide context, orientation, and an overview of adjacent uses. Figure B-2 is an assessor parcel
map. Its exact area is 31.14 acres, including a 3.56-acre street internal to the site that provides
access to Crest Road, at a point outside the controlled access entryway to the Rolling Hills (but
within the city limits). The net acreage of the site without the street is 27.58 acres.
The site is oblong in shape, with a panhandle area at its western edge that extends to the Crest
Road access point. Excluding this panhandle area, the site extends roughly 2,600 feet from east
to west and averages more than 600 feet from north to south. Within this area are numerous
flat, graded surface areas with no structure coverage and minimal programmed activities.
The City of Rancho Palos Verdes lies immediately south and west of the site. The area to the
south is developed with single family homes at densities of 2-3 units per acre. This area is
roughly 80 to 100 feet higher in elevation than the site itself, as there is a graded downslope
between the residential neighborhood and the school property (the downslope is on the school
property). Residential uses also abut the west side of the site, with densities around 3-4 units
per acre.
There are no road or driveway connections between the PVUSD site and the Rancho Palos
Verdes neighborhoods to the south and west. A 15’ riding and hiking trail easement exists along
the southern and western edges of the site but it is undeveloped. The difference in topography
reduces the potential for visual impacts associated with future development.
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APPENDIX B: Supplemental Analysis of the PVUSD Site Page B-2
The entire northern perimeter of the site is defined by the Crest Road right-of-way. There are
large lot homes on the northern side of Crest Road, set back more than 100 feet from the
School District property line and more than 200 feet from the improved area of the PVUSD site.
The area to the north is well buffered not only by large setbacks and Crest Road, but also by an
internal street on the PVUSD property. Effectively, there are two streets between homes in
Rolling Hills and the developable area—Crest Road, and the parallel internal street within the
PVUSD site.
On its eastern edge, the site is abutted by large lot residences. The home closest to the site is
heavily screened from the PVUSD site by vegetation, as well as a private tennis court between
the residence and the property line. The residence itself is more than 200 feet from the PVUSD
ballfield and more than 550 feet from the school.
The site context creates effective buffering from adjacent uses, mitigating land use compatibility
concerns such as privacy, noise, and visual impacts. At the same time, the site is easily
accessible from Crest Road and is outside of the gated area of the city. A fire station is located
1,000 feet to the east, and major shopping facilities and services are located just over a mile
away in the City of Rancho Palos Verdes. Crest Road is one of Rolling Hills’ major thoroughfares
and one of the few “through-streets” that bisects Rolling Hills and connects the city to adjacent
cities and regional highways.
History of the Site and Current Uses
The site was initially home to Cresta Elementary School, which was constructed in 1960. A
School District warehouse and maintenance facility was part of the original campus. The school
closed in the early 1980s and was repurposed as Rancho Del Mar Continuation High School,
which opened in 1986. At the time, there were discussions between the City and the School
District to rezone the property and sell the site for residential development. However, Rancho
Del Mar has remained on the site for the last 35 years. Given the value of the land and the low-
intensity and limited extent of the existing use, residential development remains viable, even if
the school does not relocate.
The Rancho Del Mar Campus consists of three one-story buildings totaling 20,000 square feet of
floor area. Figure B-3 shows the campus layout, as well as six photos of the school and adjacent
areas. The campus consists of an L-shaped building (divided by a breezeway) with eight
classrooms, a rectangular building with a classroom, multi-purpose room restroom, and
custodial area, and a small building facing the parking lot with the main office. Classrooms at
the school are open to the exterior and there are no interior hallways. The PVUSD shares its
classroom and administrative facilities with the Beach Cities Learning Center. The Learning
Center has 17 students aged 11-18 with emotional, behavioral, and learning challenges.
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Rancho del Mar itself serves students ages 16-18 who were unsuccessful in a traditional high
school setting. Students are referred to the school for a myriad of reasons, including poor
attendance, personal crisis, behavioral issues, or other factors creating a high risk of drop-out.
Enrollment at Rancho del Mar has been steadily declining and was just 32 students in the 2020-
21 school year. Enrollment was 79 students in 2014-15, 72 students in 2015-16, 69 students in
2016-17, 58 students in 2017-18, 47 students in 2018-19, and 46 students in 2019-20. There
are also six teachers on site and three other personnel.
Thus, the combined enrollment (Beach Cities and Rancho Del Mar) is fewer than 50 students on
a 31-acre site. By contrast, Palos Verdes Peninsula High School and Palos Verdes High School
enroll roughly 2,300 and 1,700 students respectively, on sites of similar size. Sale of the school
property could generate significant revenue for the School District. Sale of a portion of the
property also is possible, as the site is configured in such a way that easily facilitates its
subdivision.
A comprehensive structural evaluation of the school was completed in 2016 as part of the
PVUSD Facilities Master Plan. Beach Cities Learning Center likewise prepared a facility
condition status report in 2019 as part of its annual reporting requirements. Both evaluations
found the building(s) to be in good condition. The buildings were last renovated in 2008. The
2016 evaluation called for resurfacing the parking area, upgrading the HVAC system, and
upgrading the electrical system. Total capital needs were estimated at $1.9 million. All utilities
were found to be in good condition, and drainage issues were minimal.
The school campus is adjoined by an approximately 100-space parking lot on its north and east
sides. To the west of the buildings, there is a large flat lawn area. To the east, there is an
athletic field area that includes a basketball court and ballfield. The 2016 facility evaluation
determined that the Floor Area Ratio of the school campus was just 0.03, as it defined the
campus area as being 15.2 acres (including athletic fields, lawns, and other open areas on the
perimeter of the site). The square footage of floor space per student is well below District
averages.
Beyond the 15.2-acre area associated with the school, the PVUSD has leased approximately 4.5
acres of the site (roughly 15 percent of the 31 acres) to the Palos Verdes Peninsula Transit
Authority. The PVPTA facilities include maintenance buildings and administrative offices and are
self-contained in the west central part of the site. The Housing Element analysis presumes this
part of the site will not be available for development and that the transit district will remain a
long-term tenant. However, the PVPTA site could potentially be sold and redeveloped in the
future, leased to a new third party, or repurposed by the School District.
Potential Development Areas
Figure B-4 shows potential development areas on the Rancho Del Mar site. These are
summarized below:
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• Area 1 is located between the transit facility and the school campus. It is an unimproved,
almost completely flat rectangular area of 1.6 acres. Its dimensions are approximately
250 x 300, with 250 feet of frontage along the internal access street. The site is well
situated for multi-family development and has no visible physical constraints.
• Area 2 is located immediately adjacent to the school and is 1.0 acre. The dimensions
are approximately 200 x 200, with a “stem” area providing access to the interior street.
The area is currently an unimproved lawn with a few mature trees. It is almost
completely flat and has no physical development constraints. The site could easily
support up to 16 to 20 multi-family units at a density of 20 units per net acre.
• Area 3 is the school itself, which occupies roughly 1.75 acres including parking,
landscaped areas, courtyards, and classroom buildings. This option would be most
viable if the school relocates and the site is sold, as co-location of a school and multi-
family housing or emergency shelter would be unlikely. However, certain special needs
housing types (such as housing for teachers) would be viable in this setting.
• Area 4 includes the area east of the school. It includes approximately three acres of
level ground, with 0.5 acres of parking, a two-acre ballfield serving the school, and other
paved areas used for basketball and recreation. There are several areas within the three
acres where 16-20 units could be built without impacting use of the site for parking and
school recreation.
• Area 5 includes approximately four acres and is located west of the PVPTA facility. It is
regarded by the City as the best location on the 31-acre site for multi-family housing, as
it would have the least impact on the school campus and transit facility. It is also the
largest of the five areas and the most buffered from adjacent development. There are a
number of extant foundations on the site from prior uses, and internal roadways that are
not in use. The area has gently sloping terrain and has not been improved for school
use, parking, or recreation, as the other portions of the site have.
Figures B-5 through B-7 provide a bird’s eye view of each of the five areas.
Physical Constraints to Site Development
Approximately nine acres of the 31-acre site consists of a graded slope along the south side of
Altamira Canyon. This area is shown in Figure B-8. The slope exceeds 30 percent, making it
poorly suited for development. The sloped areas also have the potential for landslides and other
seismic stability issues, which limit their suitability for further grading and construction. The
sloped area is not considered suitable for multi-family development or special needs housing. It
occupies roughly 29 percent of the site, all of which has been excluded from consideration in
the definition of Areas 1-5 above.
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The central portion of the site has historically been used for general maintenance activities, first
by PVUSD and more recently by PVPTA. A search of the California State Water Resources
Control Board (SWRCB) GeoTracker data base identified two leaking underground storage
tanks (LUST sites) at this location. The sites were determined to contain gasoline and
hydrocarbons resulting from leaking underground storage tanks. Both sites have been cleaned
per SWRCB standards and are now designated by the SWCRB as "complete” and “case
closed.”
As noted elsewhere in the Housing Element, the City of Rolling Hills—including the PVUSD
site—has been designated as a Very High Fire Hazard Severity Zone by the State of California.
Rolling Hills is implementing a Community Wildfire Protection Plan to mitigate this hazard and is
implementing vegetation management measures and programs to make structures more
resilient. In the event of a housing proposal on this site, the need for an emergency-only access
connection between the existing access road and Crest Road would be assessed.
An analysis of infrastructure and utilities on the site conducted as part of the Housing Element
found no constraints associated with redeveloping this site with residential uses or special needs
housing. The site is used less intensively now than when it was actively used as an elementary
school and school maintenance facility. Water, drainage, and wastewater facilities are adequate
to support the number of units contemplated by the Housing Element.
Importantly, this is one of the only sites in the City of Rolling Hills that has access to a public
sewer system. As such, it is much more conducive to multi-family housing that sites elsewhere
in the city that are served by private septic systems.
Regulatory Constraints to Site Development
Prior to December 2020, the PVUSD opportunity site was subject to a range of planning and
regulatory constraints that limited the feasibility of multi-family housing. The site has historically
had a General Plan designation of Very Low Density Residential and a zoning designation of
RAS-2 (Residential Suburban 2-acre minimum lot size), which effectively limited uses to existing
community facilities or new large-lot residential development. While Accessory Dwelling Units
(ADUs) could conceivably be incorporated in new homes, the site would not have met State
requirements for the Housing Element.
In February 2021, the City of Rolling Hills amended its General Plan and zoning regulations to
allow multi-family housing and other special needs housing types “by right” on the PVUSD
property, subject to specific development standards. As noted elsewhere in the Housing
Element, the amendments included:
• Amending the Land Use Element of the General Plan to create the Rancho Del Mar
Housing Opportunity Overlay. The Land Use Element now explicitly states that multi-
family housing and emergency shelter are permitted by right in this area, subject to
objective development standards. The number of units on the site is based on a transfer
of the allowable General Plan density to a clustered area where 16 to 20 units could be
added.
• Amending the Rolling Hills Municipal Code (Zoning Regulations) to create the Rancho
Del Mar Housing Opportunity Overlay, and to map this Overlay on the entire PVUSD site.
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Appendix B: Supplemental Analysis of the PVUSD Site Page B-14
The Overlay establishes a minimum density of 20 units per acre and a maximum density
of 24 units per acre. Affordable housing is permitted “by right” subject to objective
development standards defined in the Ordinance. The Ordinance identifies the area
west of the PVPTA site as the location for future housing.
• Amending the Zoning Regulations to allow emergency shelter on the property by right,
subject to specific development standards specified in the Code.
• Amending the Zoning Regulations to allow single room occupancy (SRO) units on the
site, with a conditional use permit.
Other Constraints to Site Development
Development of multi-family housing, emergency shelter, or SRO uses on the PVUSD site could
occur either:
• by the School District itself (on its own or through a public-private partnership)
• through a long-term lease; or
• through sale of all or part of the property
The City has met with the School District and reviewed Board Policies and Codes. Current
policies accommodate all of these options—and that there are no prohibitions or limitations on
multi-family and special needs housing. Moreover, the School District has expressed interest in
developing housing for teachers in the past; such units would meet income criteria for low or
very low income units. There are ample opportunities for such housing on the property that
would not impact operations at either Rancho Del Mar School or PVPTA. Rancho Del Mar is a
logical location for these activities, given the size of the site and its significant underutilization.
The District is less likely to pursue development of an emergency shelter or SRO on its own, as
these are not as clearly mission-aligned. However, it could sell or lease property to a third party
who could develop these uses. SROs and emergency shelters would be unlikely to co-locate in
the school building or on the 1.75-acre school footprint area, given the possibility for use
conflicts. However, the 31-acre PVUSD property is large enough to accommodate multiple
uses. There are developable areas on the site that are 1,500 feet away from the school. The
District has already set a precedent by leasing a large portion of this site to a transit agency; it
could do the same for a social service agency or another agency providing a public benefit
service to the community.
Like most School Districts in California, the sale or lease of PVUSD property is subject to action
by the School Board. Section 3280 of the Board’s Policies allows the Superintendent or
designee to study the existing and projected use of facilities to ensure the efficient utilization of
space. A Board Committee is typically created prior to the sale of land (although teacher
housing is specifically exempted by Board policy from any Committee requirements). A Board
vote is required to approve the sale or lease terms. There are also requirements for how the
proceeds of a sale or lease may be used.
Once property is sold, the School District Board has no land use or decision-making authority
over a site. Thus, the District could sell all or part of the PVUSD site to a non-profit housing
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Appendix B: Supplemental Analysis of the PVUSD Site Page B-15
developer, for-profit housing developer, social service provider, or other third party who could
develop housing “by right” without further oversight by the Board or City Council. Subdivision
of the property would be required, creating a new legal parcel on which housing could be
developed.
Given its large size, the most likely scenario is only that a portion of the site would be sold,
rather than the entire site. In effect, the Housing Element is creating a unique opportunity for
the District to sell a vacant or underutilized subarea on its 31-acre site to a third party, who can
then produce teacher housing, senior housing, affordable family housing, or another type of
housing that meet local needs.
There are a number of examples of successful small affordable housing projects in the Los
Angeles region that meet the density and height criteria established for this site. For example,
Habitat for Humanity is currently developing a 10-unit affordable two-story townhome project in
Long Beach on a 0.5-acre site. Similar two-story projects by Habitat have been developed in
Lynwood, Burbank, Bellflower, and Downey.
In the event that the Rancho Del Mar School itself is closed in the future, the building could be
sold and repurposed for other uses. Once sold, the floor space could be reconfigured for
alternative uses, including special needs housing. The project would be subject to the objective
standards prescribed by the zoning regulations (covered elsewhere in this Housing Element),
but approval of the development would be ministerial.
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Appendix B: Supplemental Analysis of the PVUSD Site Page B-16
/intentionally blank/
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Appendix C: Accessory Dwelling Unit (ADU) Survey Findings Page C-1
APPENDIX C:
Accessory Dwelling Unit Survey Analysis
In Fall 2020, the City of Rolling Hills surveyed its residents to determine the viability of
Accessory Dwelling Units (ADUs) as a future affordable housing strategy. The survey was
formatted as an 11 x 17 folded sheet printed double-sided (four 8.5 x 11 pages) and was mailed
via the US Postal Service to approximately 700 addresses in the city. Return postage was
provided so the survey could be easily returned. Residents had roughly one month to complete
and return the survey. An option was provided to reply electronically via SurveyMonkey.
Approximately 190 surveys were returned, for a response rate of 27 percent.1 Another seven
surveys were received by SurveyMonkey, bringing the total response rate to 28 percent. The
survey represents the views and experiences of more than one in four Rolling Hills households.
This is a high response rate and is indicative of the community’s strong interest in the subject.
Demographic information about the respondents was collected as part of the survey.
Respondents tended to be older than Rolling Hills residents as a whole and were mostly long-
time residents. About two-thirds of the respondents were 65 or older and 25 percent were 50-
64. By contrast, about 42 percent of the City’s adult residents are over 65 and 36 percent are
50-64. About 42 percent of the respondents had lived in Rolling Hills for more than 30 years
and only 20 percent had lived in the city for less than 10 years. By contrast, about 27 percent of
all residents have lived in Rolling Hills for more than 30 years and 31 percent have lived in the
city for less than 10 years.
The distribution of respondents by household size was close to the citywide average.
Approximately 65 percent lived in one and two person households, which is similar to the
citywide average. Only seven percent lived in households with five or more residents, which is
just below the citywide average. Of the 194 respondents who indicated their housing tenure,
192 were owners and two were renters. This is equivalent to one percent of the respondents,
whereas renters represent about five percent of Rolling Hills households.
Figure C-1 compares demographics for the survey respondents and residents in the city as a
whole.
Responses to the survey was completely anonymous. Respondents were given the option of
phoning the City if they had questions or wanted more information about ADUs.
1 This estimated return rate was based on 700 households. In August 2021, Census data indicated there were 637
households in the City, so the actual return rate was 31 percent.
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Appendix C: Accessory Dwelling Unit (ADU) Survey Findings Page C-2
Figure C-1: Demographics of Survey Respondents Relative to All Rolling Hills Residents
0
10
20
30
40
50
Less than 10 yrs 10-20 yrs 20-30 yrs 30+ yrs
Length of Residency in Rolling Hills
Survey Respondents All Rolling Hills Residents
0
10
20
30
40
50
60
1 Person 2 Persons 3 Persons 4 Persons 5 Persons 6+ Persons
Household Size
Survey Respondents All Rolling Hills Residents
0
10
20
30
40
50
60
70
20-35 35-49 50-64 65+
Percent by Age Group
Survey Respondents All Rolling Hills Residents
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Appendix C: Accessory Dwelling Unit (ADU) Survey Findings Page C-3
Suitability of the Property for an ADU
Question 1 asked respondents to indicate if their property contained an ADU or other habitable
spaces which could potentially be used as an ADU. Respondents were asked to check “all
choices that apply,” so the results are not additive.
Thirteen of the respondents indicated they had a legally permitted ADU on their properties with
a separate kitchen, bath, and entrance. Some of these units may have been legally created in
2018-2020 after the City adopted its ADU Ordinance, but some likely already existed and are
legally classified as guest quarters.
Thirty-four respondents, or roughly 25 percent of the total, indicated they had a secondary
building on their properties with an indoor kitchen, bathroom, heat and plumbing. This included
guest houses/ casitas, pool houses, habitable barns, and similar features that could be
considered potential ADUs even if they are not used for habitation by another household. Ten
respondents indicated they had a second kitchen in their homes. Eighteen said they had
another space in their home that could “easily be converted” to a separate dwelling or junior
ADU. While some respondents may have counted the same space twice, roughly half indicated
they had spaces on their properties with the potential to be used as an ADU or JADU. This is
further supported by the responses to Question 2 below.
Current Use of ADUs and Spaces Suitable as ADUs
Question 2 asked how the spaces described in Question 1 were being used. Only three of the
respondents indicated they were renting ADUs to a paying tenant. Seven indicated that the
space was used by a caregiver or domestic employee, while eleven had a family member or
long-term occupant living on the property. Collectively, this represents 21 units, or just over 10
percent of the respondent households. The remainder of the respondents with potential ADU
space indicated they used these spaces for house guests or their own families, or that the space
was unoccupied or used as storage.
The survey findings indicate that ADUs (or “unintended” ADUs such as guest houses) already
represent a component of the Rolling Hills housing supply. The survey suggests that there is
potential to expand the number of permitted ADUs in the future, even without any new
construction. About 15 percent of the respondents (30 in total) indicated they had potential
ADU space on their properties that was vacant or used for storage.
Respondents were asked the square footage of the spaces they were describing. Figure C-2
shows the distribution. More than 100 responses were received, with a median size of about
600 square feet.
Respondents who had rented ADUs on their properties were given the option of reporting the
rent that was being charged. Two of the three households who indicated they had a paying
tenant replied. The monthly rents charged for these units were $950 in one case and $1,500 in
another. Based on HCD income limits for Los Angeles County, the $950 unit would be
considered affordable to a very low-income household of one or more persons. The $1,500 unit
would be considered affordable to a low-income household of one or more persons. These
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Appendix C: Accessory Dwelling Unit (ADU) Survey Findings Page C-4
units are presumed to have been created or legalized between 2018 and 2020, following
adoption of the ADU ordinance.
Figure C-2: Square Footage of Spaces Reported by Respondents as Potential ADUs on their Properties,
Including Guest Houses
Income Characteristics of Households in Occupied Units
Those who indicated their ADU (or “unintended” ADU/ guest house/ secondary space) was
occupied by someone who was not part of their household were asked to describe the number
of residents and total income of the occupants. The numeric HCD 2020 income limits (dollar
amounts) and number of persons in the household were used so that the occupants could be
easily identified using HCD’s income categories.
There were 12 responses to this question, or about six percent of all surveys returned. This
presumably includes the small number of units that are rented as ADUs, plus those occupied by
caretakers, domestic employees, and other long-term occupants. The distribution by HCD’s
income categories is shown below:
Household Size and Income of Households Occupying Formal or Unintended ADUs
Income 1 person 2 person 3 person 4 person 5 person 6+ person TOTAL
Extremely
Low 1 1 2
Very Low 2 2
Low 1 1
Moderate/
Above Mod 1 4 1 1 7
TOTAL 5 4 1 1 0 1 12
0
5
10
15
20
25
30
>300 301-450 451-650 651-800 801-1000 1000+Number of UnitsSquare Footage
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Appendix C: Accessory Dwelling Unit (ADU) Survey Findings Page C-5
The data indicates that roughly half of the survey respondents’ ADUs (including those which
may be unpermitted and used “informally” on a long-term basis) provided housing for low, very
low, and extremely low income households.
Interest in Developing an ADU
Question 4 asked respondents if they might be interested in developing an ADU if they didn’t
currently have one. There were 164 responses to this question, with 24 percent indicating
“Yes” and 15 percent indicating “Maybe.” Another 40 percent indicated “No” and 14 percent
indicated “Probably Not.” The responses are profiled in Figure C-3 below.
Figure C-3: Level of Interest in ADU development (N=164)
The chart above suggests that more than half of the City’s residents are not interested in
developing an ADU on their properties, and another quarter are undecided or not interested at
this time. To flesh out possible barriers, Question 4 included a follow up asking why
respondents were not interested. The responses suggest it is primarily a lifestyle choice rather
than the result of regulatory or cost barriers. About one-third (51) listed the loss of privacy as a
factor, and another one-third (48) indicated they didn’t want to deal with tenants. The number of
respondents listing the “permitting process” as a factor was relatively small (27 out of 164) and
the percentage listing “cost” as a factor (24 out of 164) was even smaller. About 10 percent of
the respondents cited lack of space as their reason.
Location of Possible ADUs
Those who expressed some interest in adding an ADU were asked where they might locate the
ADU on their properties. The responses can potentially help inform local programs that facilitate
ADUs in particular locations. There were 85 responses, representing more than 40 percent of
No (65)
40%
Probably Not
(23)
14%
Not Sure (11)
7%
Maybe, but not
now (25)
15%
Yes (40)
24%
Question: If you don’t have a
legal ADU on your property,
would you consider developing
one? (164 replies)
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Appendix C: Accessory Dwelling Unit (ADU) Survey Findings Page C-6
the total survey respondents. Conversion of an existing accessory building (such as a guest
house or barn) was the most commonly selected choice (38 responses), followed by a new
detached structure (21 responses) and conversion of existing space in the house (6 responses).
Only one respondent indicated they would build an addition to their home. Nineteen of the
respondents were not sure where they might locate an ADU. Again, a majority (about 115) were
not interested in adding an ADU.
The responses suggest stronger demand for traditional ADUs than Junior ADUs, given the large
number of respondents indicating they would built or convert an accessory structure, rather
than use space within their own homes.
Likely Use of Future ADUs
Respondents were asked how they would use an ADU on their property if they developed one in
the future. The responses to this question are important, as the objective of the program is to
create rental housing opportunities or opportunities for on-site care givers. Using the ADU as a
home office or space for occasional house guests would not accomplish State-mandated
housing program goals. Figure C-4 shows the responses to the question.
Figure C-4: Likely Use of Future ADUs (N=192)
The responses indicate that roughly one-third would use the ADU for another household,
including 16 who suggested they would rent it to a tenant and 48 who suggested they would use
it for a domestic employee or caregiver. The latter statistic is particularly important, as it
suggests a potential resource for health care workers, elder care professionals, construction and
landscape workers, and others who may work in Rolling Hills but lack the financial resources to
live here. Nearly a third of the respondents indicated they would use the ADU for a family
For rent to a tenant
(16)
8%
For a family
member
(60)
31%
For
myself
(18)
9%
For an employee or
caregiver (48)
24%
For occasional
visitors (50)
25%
Other (5)
3%
Question: If you had a legal
ADU on your property, how
would you most likely use it?
(192 replies)
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Appendix C: Accessory Dwelling Unit (ADU) Survey Findings Page C-7
member. The family member could be an extension of their own household or a relative or
relatives living independently as a separate household. It is worth noting that only a quarter of
the respondents indicated they would use the ADU for occasional visitors—historically, this has
been the intended use of guest houses in the city.
Use of ADUs as Affordable Housing
Respondents were asked if they would consider limiting the rent on an ADU so that the unit was
affordable to a lower income household. The question specifically asked if the respondent
would consider a deed restriction that maintained the rent at a reduced rate (such as $1,200/
month for a two-person household) to help the City meet its State-mandated affordable housing
requirements. Of the 194 surveys returned, 25 indicated they would consider this and another
20 indicated they might consider this (“maybe”). This represents nearly one-quarter of the total
respondents. Another one-quarter indicated they would need more information before deciding.
About 35 percent indicated they would not consider a lower income affordability restriction and
15 percent did not respond.
Figure C-5 shows the responses to this question. The data suggests that an “affordable” ADU
program could generate sufficient participation for the City to meet its entire lower-income
housing allocation through ADUs.
Figure C-5: Viability of ADUs to Meet Very Low Income Housing Assignment (N=194)
For the 98 respondents who answered “Yes”, “Maybe,” or “Need More Information”, the survey
asked a follow-up question, which is the maximum length of time the respondent would consider
acceptable for an affordability deed restriction. Two respondents did not reply, but the other 96
provided the answers below:
• 20 would consider a 5-year term
• 2 would consider a 10-year term
Yes (25)
13%
Maybe
(20)
10%
Need More Info
(53)
27%
No (68)
35%
Didn't reply (28)
15%
Question: If you
had a legal ADU
on your property,
would you
consider a deed
restriction that
maintained the
rent at a reduced
rate to help the
City meet its
State-mandated
affordable
housing
requirements?
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Appendix C: Accessory Dwelling Unit (ADU) Survey Findings Page C-8
• 3 would consider a 20-year term
• 17 would consider a deed restriction that ended when they sold the house
• 59 were not sure or answered “other”
The responses suggest that long-term deed restrictions (10 or 20 years) and affordability
contracts that “run with the land” would have limited participation. Residents are more open to
short-term arrangements such as five-year affordability terms, and flexible arrangements that
would not encumber the resale of their homes. This is an important consideration in the event a
program is established.
Incentives
The final question in the survey asked respondents to select from a menu of possible incentives
that might make a rent-restriction on an ADU more acceptable to them. Respondents were
invited to select as many of the choices as they wanted. The most frequently selected options
are shown in descending order in Figure C-6 below:
Figure C-6: Ranking of Potential Affordable ADU Incentives
The most frequently selected option was “nothing.” However, 55 respondents indicated that fee
waivers or reductions would be an incentive, and 50 said expedited permitting would be an
incentive. Many respondents were also supportive of the idea of rent-restricted ADUs serving
local essential service workers such as fire-fighters and teachers. The least popular incentive
was assistance in finding a tenant.
0
10
20
30
40
50
60
Question: What
incentives might
make a rent
restriction more
attractive to you?
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Appendix C: Accessory Dwelling Unit (ADU) Survey Findings Page C-9
Other Comments
The survey provided an opportunity for residents to make general open-ended comments on
ADUs and housing issues in Rolling Hills, as well as the factors the City should consider as new
ADU policies and regulations are developed. Feedback was provided by 52 of the respondents.
This is summarized below.
Most of the open-ended comments expressed negative views about ADUs and their potential
impacts on the character of Rolling Hills, as well as concerns with State housing mandates and
the erosion of local land use control. Numerous concerns were raised about safety, security,
and privacy. There were also concerns expressed about noise, parking, traffic, evacuation
capacity, and impacts on the community’s rural, equestrian feel. Some respondents expressed
concerns that they would not be able to choose their own tenants if they created an ADU or
would be penalized if they created an ADU but did not rent it. Questions were also raised about
property tax impacts, septic system impacts, and whether tenants would pay association dues
and have access to RHCA facilities.
There were also supportive comments, particularly from persons interested in creating ADUs for
aging parents, or for themselves to age in place while renting out their primary home. Several
respondents indicated an interest in renting space to a care giver. One respondent suggested
prioritizing rentals to employees of the RHCA. Some respondents expressed their support for
the idea of using the school property to meet affordable housing needs rather than relying on
ADUs.
Survey
A copy of the survey mailed to residents follows this page.
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A D O P T I O N D R A F T
Appendix C: Accessory Dwelling Unit (ADU) Survey Findings Page C-10
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A D O P T I O N D R A F T
Appendix C: ADU Survey Report Page C-11
City of Rolling Hills Accessory Dwelling Unit Survey
October 2020
Dear Resident:
Please take a few minutes to complete this survey about
Accessory Dwelling Units (ADUs) in Rolling Hills. Your
responses will help us understand community goals and
concerns and will be used to develop new policies for
consideration by the Rolling Hills Planning Commission and
City Council.
State law requires that all cities and counties allow ADUs,
provided they meet certain standards. Some of the
potential benefits of ADUs include rental income for
homeowners, on-site living space for caregivers or
household employees, and accommodation of extended
family (adult children, parents, etc.). ADUs can also help
residents “age in place,” particularly as homeowners need
more care or assistance.
The City’s objective in carrying out this survey is to
determine the level of interest in ADUs among Rolling Hills
residents and evaluate their potential to meet local housing
needs. Like all cities in California, Rolling Hills is required by
State law to provide for its “fair share” of the region’s
housing needs, including low- and very low-income
households. ADUs provide a way to do that without
significantly changing the character or appearance of the
community. Some communities even provide special
incentives for homeowners who rent ADUs at reduced rates
to very low-income households, including household
employees and local essential service employees.
The deadline for returning your survey is November 20,
2020. Please use the enclosed postage-paid envelope to
return the survey to City Hall by this date. If you would
prefer to complete the survey on-line, please visit
www.surveymonkey.com//rollinghillsADUsurvey.
Please do not include your name or address on the survey as
the intent is for all responses to be anonymous. If you have
questions about the survey or about ADUs in Rolling Hills,
please call Meredith Elguira at (310) 377-1521.
What are ADUs and JADUs?
Accessory Dwelling Units (ADUs) are
sometimes referred to as “in-law
apartments” or “second units.” They are
small independent dwelling units that exist
on single family properties, either in a
detached structure or as part of the
primary structure with a separate
entrance. ADUs include a bedroom or
sleeping area, a bathroom, and cooking
facilities.
Rolling Hills has adopted specific zoning
standards for ADUs as required by state
law. The maximum allowable size is 850
square feet for a studio or one-bedroom
and 1,000 square feet for a two bedroom.
Other standards also apply.
Junior Accessory Dwelling Units (JADUs)
are a type of ADU created by converting
existing living space inside a single-family
home (usually a bedroom) to a separate
living space. They have a maximum size
of 500 square feet. JADUs may have their
own kitchenette or bathroom, or they may
share the facilities in the primary
residence.
State law allows a property to have both
an ADU and a JADU if certain
requirements are met.
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A D O P T I O N D R A F T
Appendix C: ADU Survey Report Page C-12
Thank you for taking the time to complete the survey!
Accessory Dwelling Unit Survey
1. Does your property include any of the following features? (circle all that apply)
A. A legally permitted Accessory Dwelling Unit (ADU) with kitchen, bath, and separate entrance?
B. A guest house, pool house, casita, barn or other outbuilding that has heat and plumbing?
_____ Check here if the space has a kitchen or other cooking facilities
C. A space inside your house with a separate entrance from outside and independent living quarters,
including a bedroom/ sleeping area and bathroom?
_____ Check here if the space also has its own kitchen or cooking facilities
D. Another space within your house that could easily be converted into an accessory dwelling unit?
2. If you circled one of the choices above, how is the space currently used? (If you circled more
than one choice, please provide a response for each applicable space on your property. Use
the blank line to the right of each choice below to describe the space you’re referring to).
A. It is occupied by a tenant paying rent ____________________________________
B. It is occupied by a family member or long-term visitor who is not part of my household ___________
C. It is occupied by a caretaker or household employee(s) ____________________________________
D. It is used occasionally by guests or visitors ____________________________________
E. My own household uses the space ____________________________________
F. The space is currently not occupied by anyone, or is used for storage ___________________________
G. Not applicable
2A. About how large is the space of each applicable feature from Question 1 (in square feet)?
(please skip question if not applicable)
__________________ ___________________ _________________
2B. If rent is collected for the space, what is the monthly amount? (if multiple spaces are
rented, please indicate the rent for each area). (Please skip question if not applicable)
__________________ ___________________ _________________
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A D O P T I O N D R A F T
Appendix C: ADU Survey Report Page C-13
3. If you have space on your property occupied by a household other than your own, please circle
the category in the table below that most closely matches their annual income based on the
number of persons in their household, if you know that amount. Recent data from the US Census
indicates that 16 percent of Rolling Hills households have annual incomes below $50,000. ADUs (or
potential ADUs) may provide a resource for these households. If Question 3 does not apply to your
property, please skip to Question 4.
Number of Persons in the Household (for other occupants only, not your own household)
1 2 3 4 5 6 Annual Income $23,700 or less $27,050 or less $30,450 or less $33,800 or less $36,550 or less $39,250 or less
$23,700-
$39,450
$27,050-
$45,050
$30,450-
$50,700
$33,800-
$56,300
$36,550-
$60,850
$39,250-
$65,350
$39,450-
$63,100
$45,050-
$72,100
$50,700-
$81,100
$56,300-
$90,100
$60,850-
$97,350
$65,350-
$104,550
$63,100 or
more
$72,100 or
more
$81,100 or
more
$90,100 or
more
$97,350 or more $104,550 or
more
4. If you don’t currently have a legal ADU on your property, would you consider developing one?
(circle one answer)
No Probably Not Not Sure/ Neutral Maybe, but not at
this time Yes
4A. If you answered A, B, or C, what are the reasons? (Circle All that Apply)
No Interest Cost Loss of Privacy Permitting
Process
Don’t Want to
Deal with
Tenants
No Space
Other (please explain below)_____________________________________________________
____________________________________________________________________________
5. If you decided to build an ADU on your property, where would it be located? (circle one)
New
detached
structure
on my
property
Conversion of an
existing accessory
building on my
property (e.g., guest
house, barn, etc.)
An addition
to my house
Conversion of space
already within the
footprint of my house
Not sure
I would not add
an ADU on my
property
6. If you had a legally approved ADU on your property, how would you most likely use it? (circle one)
For rent to
a tenant For a family member
For myself
For a household
employee of caregiver
For occasional
visitors
Other
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A D O P T I O N D R A F T
Appendix C: ADU Survey Report Page C-14
7. If you had a legally approved ADU on your property, would you consider a deed restriction that
maintained the rent at a reduced rate (for example $1,200/month, which is considered the
threshold for an “affordable” housing unit for a two person very low income household) to help
the City meet its State-mandated affordable housing requirements? (circle one)
A. Yes
B. Maybe
C. I would need more information first
D. No
7A. If your answer to Question 7 was A-C, what would be the maximum length of time you would
consider for the rent restriction? (circle one)
A. Five years
B. 10 years
C. 20 years
D. Until I sell the house
E. Not Sure
F. Other _______________________
7B: What incentives might make a rent restriction more attractive to you? (circle all that apply)
A. No parking requirement
B. Reduced (or no) permit fees
C. Expedited permit processing
D. Assistance in finding a tenant
E. Rent supplement for the tenant
F. Local tenant (e.g., school teacher,
fire fighter, child care worker)
G. Senior tenant
H. Low-interest financing to create the ADU
I. Permission to build a unit larger
than 1,000 square feet
J. Nothing
K. Other _______________________
8. To ensure that we are hearing from a cross-section of the community, please tell us a little about you:
How Long Have You
Lived in Rolling Hills?
Less than 10 years
10-19 years
20-29 years
More than 30 years Circle one choice in each box Are you a Homeowner
or a Renter?
Homeowner
Renter
Age
Under 35
35-49
50-64
65+
How Many People Are
in Your Household?
1 4
2 5
3 6 or more
9. Please share any concerns you may have about ADUs in Rolling Hills, or factors you’d like us to
consider as new ADU policies and regulations are developed:
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