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Hermosa Beach planners receive mid-cycle housing element report; staff warns of legal risks from Redondo decision
Summary
City staff told the Planning Commission the city is meeting overall housing production targets but is short in very-low/low/moderate categories and must improve unit accounting and site monitoring; the city attorney flagged an appellate decision that decertified Redondo Beach———raising overlay-zone compliance questions.
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Hermosa Beach
Community Development Director Lisonbee Becker told the Planning Commission on Nov. 18 that the city
had a regional housing needs allocation (RHNA) of 558 units for the 2021
through-2029 cycle and, at mid-cycle, reported roughly 184 units in the pipeline with 116 completed.
"The city's regional housing needs allocation was a total of 558 units across all income categories," Becker said during her presentation, and added that the city is "right on target" from a total-production perspective but underperforming in very-low, low and moderate income categories.
Why it matters: state law requires jurisdictions to show realistically buildable sites and implementation of programs that produce units at the income levels in their RHNA allocations; failure to maintain a credible program can lead to legal challenges and the loss of HCD certification.
Becker outlined five program areas the housing element addresses: conserving existing housing resources (code enforcement, preservation of the city's mobile home and RV park spaces), incentivizing affordable production (density bonus compliance, regional partnerships), supporting multifamily housing through lot consolidation and administrative streamlining (including objective design standards and SB 35 procedures), improving ADU/JADU accounting, and affirmatively furthering fair housing. She said the city has completed necessary text and map amendments for an overlay zone but is behind on some initiatives, including advancing a project on city-owned land and completing the local coastal land-use plan.
The presentation flagged three near-term priorities: better ADU/JADU accounting (staff said current records mix technology and paper), closer monitoring of housing-element overlay sites to avoid "no net loss" of capacity, and pursuing rezones and zoning-code updates to maintain compliance.
"Improving our data systems for accurate accounting will really help us," Becker said, describing the ADU-counting shortfall as an "accounting issue." She urged annual or at least regular updates tied to the city's APR to HCD.
Legal context: interim Assistant City Attorney Sarah Laughlin briefed commissioners on an October appellate ruling in New Commune DTLA v. City of Redondo Beach, which the court used to decertify Redondo Beach
housing element because several overlay sites retained base commercial or industrial zoning and therefore could not meet the required minimum residential density or the statutory balance for lower-income units.
"Unfortunately, Redondo Beach's housing element is decertified," Laughlin said. She said the court concluded it could review a housing element even after HCD certification and that jurisdictions may need to rezone overlay sites to require residential development or otherwise demonstrate realistic capacity.
Becker and Laughlin emphasized Hermosa Beach's housing element remains certified, but staff said they are reviewing local overlay sites and may recommend additional rezones or site changes to ensure continued compliance.
Commission response and next steps: commissioners expressed concern about the imbalance in affordability categories and urged staff to prioritize site-specific tracking. Commissioner Hoffman used a driving metaphor to describe uncertainty about how to respond to the appellate decision but said the city will likely need to rezone many overlay parcels to meet density requirements.
The Planning Commission voted unanimously to receive and file the mid-cycle implementation report. Becker said staff will return with continued analysis and recommended the commission and council be kept informed as the city reviews inventory sites and consults with HCD if mid-cycle revisions are necessary.
What happens next: staff will improve ADU/JADU accounting, monitor inventory sites for "no net loss," pursue rezones and zoning updates in 2026-27, and consider city-owned sites for city-sponsored affordable housing projects.

