Agenda — Alhambra City Council, January 31, 2022 (part 1 of 8)

1 1-31-22

C I T Y O F A L H A M B R A

NOTICE OF SPECIAL MEETING
OF THE

ALHAMBRA CITY COUNCIL
(Notice No. N2M22-12)

NOTICE IS HEREBY GIVEN that a special meeting of the Alhambra City Council will be held on Monday, January 31, 2022 commencing at 6:00 p.m. in the Council Chambers of the Alhambra City Hall, 111 South First Street, Alhambra, California pursuant to the order of the Mayor of the City of Alhambra, the Alhambra City Charter, the Alhambra Municipal Code, and Sections 54955 and 54956 of the Government Code of the State of California.

Consistent with AB 361, the Alhambra City Council meeting will not be physically open to the public , although the public may participate by video conference or teleconference and some of the Council Members may choo se to participate via video conference or teleconference rather than attend in person.

An agenda of such special meeting is attach ed h ereto incorporated herein by reference and made a part hereof as though fully set forth herein.

LAUREN MYLES, CMC

CITY CLERK

Dated: January 27, 2022
Notice No. N2M22-12
2 1-31-22

CITY OF ALHAMBRA

CITY COUNCIL AGENDA
JANUARY 31, 2022
CORONAVIRUS (COVID-19) ADVISORY NOTICE

Consistent with AB 361, the Alhambra City Council meeting will not be physically open to the public, although the public may participate by video conference or teleconference and some of the Council Members may choose to pa rticipate via video conference or teleconference rather than attend in person.

To watch and listen to the meeting: To maximize public safety while still maintaining transparency and public access, members of the public can participate by using Zoom Webinar as follows:

Zoom Webinar direct link:
https://cityofalhambra-org.zoom.us/j/85919288652?pwd=Q0g1b01iS0phbzJLNERkeUNPVlRUZz09 Webinar ID: 859 1928 8652, Passcode: 907856

Or by telephone by dialing 888-475-4499 (Toll Free) or 833-548-0276 (Toll Free) or 833-548-0282 (Toll Free) or 877-853-5257 (Toll Free) or 1-669-900-9128 or 1-346-248-7799 or 1-253-215-8782 or 1-646-558-8656 or 1-301-715-8592 or 1-312-626-6799 and e ntering Webinar ID: 859 1928 8652 and Passcode: 907856. Please Note: All members of the public calling or logging into the meeting will be muted so that the meeting can proceed.

For those wishing to speak on an agenda or non -agendized item, yo u have 3 options for participation:

1) Pre-register to speak: Please email Van Nguyen at [email protected] by 5:00 p.m. prior to the meeting with the item number you wish to speak on and the phone number you will use when calling or the name you will use when logging into the meeting. You should then call or log into the meeting at l east 10 minutes prior to its start time . Staff will unmute you and announce you when it is your time to speak. You will have five minutes to speak, unless that time is adjusted by the Mayor. If you do not have access to a computer, please call 626 -570-3248 to request public comment.

2) “Raise your hand”: For those members of the public that wish to speak but did n ot make a request via email as described above, such members of the public may speak by using the “Raise Hand” function during the public comments portion, if on Zoom. Staff will unmute you and announce you when it is your time to speak. If participating v ia telep hone, the Mayor will ask anyone participating by telephone if they would like to speak after asking those on Zoom. Staff will unmute telephone callers and you may state you wish to speak.

3) Emailed comments to be read into the record : As an alternative t o speaking during the meeting, you can email your comments to the City C lerk at [email protected] by no later than 5:00 p.m. on January 31, 2022 to ensure that the City Clerk has time to print the emails prior to the beginning of the meeting . Comments will then be read into the record by the City Clerk , with a maximum allowance of 5 minutes per individual comment, subject to the Mayor’s discretion. If a comment is received after 5:00 p.m. but before the conclusion of the meeting based upon its time stamp, the comment will still be included as a part of the record of the meeting but will not be read into the record.

Any member of the public who needs accommodations or who needs their comments transla ted should email or call the City Clerk at [email protected] or (626) 570-5090 who will use their best efforts to provide reasonable accommodations to provide as much accessibility a s possib le while also maintaining public safety.
3 1-31-22

AGENDA AGENAGENDA
AGENDA
Special Meeting

ALHAMBRA CITY COUNCIL
Council Chambers, 111 South First Street
January 31, 2022
6:00 p.m.

ROLL CALL: Maza, Maloney, Andrade-Stadler, Pérez, Lee

CITY CLERK REPORT - NOTICE NO. N2M22-12

The Ci ty Clerk hereby reports that she duly gave notice of the special meeting of the City Council being held this morning pursuant to the order of the Mayor and in accordance with Section 54956 of the Government Code of the State of California.

CONTINUED PUBLIC HEARING

1. PUBLIC HEARING REGARDING ADOPTION OF THE 2021-2029 HOUSING

ELEMENT OF THE ALHAMBRA GEN ERAL PLAN (GENERAL PLAN AMENDMENT GPA-22-01) AND ADOPTION OF A RELATED NEGATIVE DECLARATION – F2M20- 37, N2M22-7, R2M22-7
This is the time and place set by Notice No. N2M22 -7 for the City Council to hold a public hearing, duly continued from the January 24, 2022 meeting, to consider adoption of the 2021 -2029 General Plan Housing Element Update and the adoption of a related Negative Declaration for the 2021 -2029 Housing Element . ECONorthwest, the City’s consultant for the Housing Element, will provide the City Council with an overview of the feedback received from the State Department of Housing and Community Development (HCD) in response to the City’s Draft Housing Element submitted for review on October 5, 2021. After receiving information and allowing the public to comment, it is recommended that the City Council conduct a public hearing and then consider approving a resolu tion a dopting the 2021 -2029 Housing Element and Negative Declaration and directing staff to submit the Housing Element to HCD no later than February 12, 2022. The adoption of the Housing Element will conclude a City -wide planning effort that started in Jul y, 202 0. Alhambra’s 2021 -2029 Housing Element addresses community housing needs for all income levels and strategizes ways to respond to and provide for those housing needs in accordance with state law. Over the course of the project, the City held a varie ty of public meetings to obtain input on the 2021-2029 Housing Element. Pursuant to the California Environmental Quality Act (CEQA), the project was reviewed pursuant to Section 15063 of CEQA. An Initial Study (IS) and Negative Declaration (ND) for this pr oject have been prepared in compliance with CEQA, the IS/ND identified that the project would not have a significant effect on the environment.

Recommended Action: City Council take the following actions:

1. Open the public hearing and take comment after a presentation provided by 4 1-31-22
Chris Blakney of ECONorthwest regarding the 2021-2029 Housing Element; and,

2. After the presentation and City Council discussion, close the public hearing and adopt Resolution No. R2M22-7 entitled: A Resolution of the Cit y Council of the City of Alhambra, California approving General Plan Amendment GPA -22-01 adopting the 2021 -2029 Housing Element of the Alhambra General Plan, approving a Negative Dec laration, and directing staff to submit the Housing Element to the State o f California Department of Housing and Community Development for certification

CONSENT AGENDA (Item No. 2)

All items listed under the Consent Agenda are considered by the City Council to be routine and will be enacted by one motion unless a citizen or Council member requests otherwise; in which case, the item will be removed for separate consideration.

2. RESOLUTION REAUTHORIZING THE CITY COUNCIL AND THE CITY’S BOARDS

AND COMMISSIONS TO IMPLEMENT TELECONFERENCE ACCESSIBILITY FOR CONDUCTING PUBLIC MEETINGS PURSUANT TO AB 361 – F2M20-33, R2M22-10

During COVID, the City has conducted meetings offering teleconferencing accessibility to members of the public, City Council, members of City boards and commissions, City staff and consulta nts. The executive orders authorizing such meet ings lapsed on September 30, 2021, replaced with legislation in the form of AB 361. AB 361 was signed into law by the Governor on September 16, 2021, which went into effect immediately as urgency legislation (codified under Government Code § 54953), and wa ived certain provisions of the Brown Act in order to allow local agencies to continue to meet remotely.

Specifically, the bill allows remote teleconference flexibility, but only when there is a state of emer gency that makes it unsafe to meet in person. The City has already implemented the requirements of AB 361 for conducting p ublic meetings and is in full compliance, thus there will be no change of the currently established procedures. The Council made the n ecessary findings for the conduct of teleconfere nced accessible meetings via Resolution No. R2M21 -42 adopted on October 25, 2021 . The proposed Resolution again makes the required findings under AB 361, and if adopted, it will allow the City to continue to offer teleconference accessibility for public me etings, to help mitigate the spread of COVID-19, as well as during other state-proclaimed emergencies, such as earthquakes or wildfires, where physical attendance may present a risk.

Recommended Action: City Council adopt Resolution No. R2M2 2-10: A Resolution of the City Council of the City of Alhambra reauthorizing the City Council, and the City’s Boards and Commissions to implement teleconference accessibility for conducting public meetings pursuant to AB 361

CLOSED SESSION & CITY ATTORNEY ANNOUNCEMENT re SAME - F2M22-14

The City Council will move into a closed session pursuant to applicable law, including the Brown Act (Government Code Sec. 54950, et seq.) for the purposes of conferring with the City’s Real Property negotiator, and/or conferring with the City Attorney on potential and/or existing litigation, and/or discussing matters covered under Government Code Section 54957 5 1-31-22
(Personnel), and/or conferring with the City’s Labor Negotiators as follows; provided, however, prior to moving into closed session, the City Attorn ey shall make any announcements required by the Brown Act pertaining to such closed session matters:

Conference with Real Property Negotiator (Govt. Code Section 54956.8):

Property: About 0.31 acres (13,750 square feet), with limited street frontage and currently used as a surface parking lot in the downtown district between West Main Street and Elgin Street, north of Main Street be tween Wysong Village Apartments and the Rioni buildin g under the Assessor Parcel Number (APN) 5337 -026-907; Negotiating parties: City Manager and The Related Company of California, LLC .

Under Negotiation: Instruction to negotiators will concern price, terms of payment or both.

Conference with Legal Counsel-Existing Litigation (Govt. Code Section 54956.9(d)(1)): ELITE-TRC Alhambra Community LLC; ELITE -TRC North Parcel LLC; The Corner Company, LLC v. City of Alhambra; LASC Case No. 22STCP00217

Conference with Legal Counsel - Anticipated Litigation: Significant exposure to litigation pursuant to Govt. Code Se ction 54956.9(d)(2): 1 matter.

RECONVENE & CITY ATTORNEY REPORT: In the event the City Council moves into a closed session, the City Council and the City Attorney shall report upon the closed session if required.

ADJOURNMENT

N O T I C E

Agenda Items: Copies of the sta ff reports or other written documentation relating to the ite ms listed on this age nda are available on the City’s website. If you would lik e to sign-up to receive the C ity C ouncil m eeting agenda and staff re ports packet, please v isit the City’s website at www.cityofalhambra.org and you will be able to submit your email address on the homepage to the subscription service.

LAUREN MYLES, CMC

CITY CLERK

ATTACHMENT 1

RESOLUTION NO. R2M22-7

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ALHAMBRA, CALIFORNIA APPROVING GENERAL PLAN AMENDMENT GPA-22-01
ADOPTING THE 2021-2029 HOUSING ELEMENT OF THE ALHAMBRA

GENERAL PLAN, APPROVING A NEGATIVE DECLARATION, AND

DIRECTING STAFF TO SUBMIT THE HOUSING ELEMENT TO THE STATE

OF CALIFORNIA DEPARTMENT OF HOUSING AND COMMUNITY

DEVELOPMENT FOR CERTIFICATION

THE PLANNING COMMISSION OF THE CITY OF ALHAMBRA DOES HEREBY RESOLVE AS FOLLOWS:

SECTION 1. FINDINGS OF FACT. The City Council does hereby make the following findings of fact:

A. Pursuant to state law, cities are required to prepare a Housing Element as a component of their General Plan and to revise it regularly on a schedule set forth in the law;

B. In accordance with state law, the City of Alhambra’s Community Development Department initiated an amendment to the Housing Element of the General Plan and prepared a proposed revision to the Housing Element for the 6
TH Cycle Housing Element covering the 2021-
2029 planning period, in accordance with Government Code Sections 65580 et seq., which replaces the Housing Element that covered the prior period from 2013 to 2021;

C. On July 13, 2020, the City retained ECONorthwest for professional consulting services to prepare the 2021-2029 Housing Element of the Alhambra General Plan;

D. California Government Code Section 65583 requires that the Housing Element contain (i) an assessment of the City's housing needs and an analysis of the resources and constraints, both governmental and non- governmental, relevant to the meeting of these needs; (ii) an inventory of land suitable and available for residential development and an analysis of the development potential of such sites; (iii) a statement of the community's goals, quantified objectives, and policies relative to the maintenance, preservation, improvement, and development of housing; and (iv) programs that set forth a schedule of actions the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element Update;

E. The City of Alhambra has been assigned a Regional Housing Needs Assessment (RHNA) of 6,825 new housing units for the 6
th Cycle planning period (2021-2029), including 1,774
very low income units, 1,036 low income units 1,079 moderate income units, and 2,936 above moderate income units;

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F. The Housing Element sets forth the housing policies for the City, facilitating the preservation and development of housing, and established programs to accommodate the City’s share of the regional housing need in Southern California;

G. Based on underutilized uses (e.g., parking lots, single -story buildings, uses with marginal economic viability), age of structures, improvement-to-land ratio, lot size, ratio of allowed to existing density, and in-place value compared to recent residential site transaction value, coupled with the significant demand for housing, market conditions supportive of redevelopment, and Housing Element programs to encourage redevelopment on non-vacant sites with greater density housing, the existing uses on sites identified in the site inventory to accommodate lower income RHNA are likely to be discontinued during the planning period, and therefore do not constitute an impediment to additional residential development during the period covered by the Housing Element;

H. The Draft 2021-2029 Housing Element was available for a public review period that took place from August 26, 2021 to September 26, 2021. A total of 19 written comments were submitted during the public comment review period and considered as part of the Housing Element update, as well as additional community input received throughout the project;

I. The 6
th Cycle Housing Element covering the 2021 to 2029 planning period was prepared based on input received from the public, Planning Commission and City Council. A total of 2 community meetings, 5 Town Hall meetings, 4 Planning Commission meetings, and 4 City Council meetings were held after notice to the public;

J. After consideration of public comment, input from the Planning Commission on September 20, 2021, and City Council on September 27, 2021, the City of Alhambra transmitted the Draft 2021 -2029 Housing Element to the California Department of Housing and Community Development (HCD) for review on October 5, 2021;

K. Pursuant to Government Code Section 65585, subdivision (b), HCD reported the results of its review through a written correspondence dated December 2, 2021, and stated that the Draft Housing Element addressed many statutory requirements, however revisions would be necessary to comply with State Housing Law;

L. The Draft Housing Element was revised to address the revisions from HCD as identified in their correspondence dated December 2, 2021;

M. The 6
th Cycle of the Housing Element was due October 15, 2021, and cities are required to adopt a compliant housing element within 120 days of the statutory deadline;

N. In accordance with CEQA, updated Housing Elements are subject to environmental review and an Initial Study was prepared for the updated Housing Element determining that the above referenced project will not have a significant effect on the environment;

O. The Initial Study/Negative Declaration was circulated for public review from December 17, 2021 through January 15, 2022;

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P. The Notice of the Planning Commission Public Hearing and Notice of Intent to Adopt a Negative Declaration was posted on the project website and emailed to interested parties on December 16, 2021, and published in the Pasadena Star News on December 17, 2021, in accordance with CEQA;

Q. On January 3, 2022, the Planning Commission of the City of Alhambra (“Planning Commission”) conducted a duly public hearing and received public comment on the Draft Housing Element . Pursuant to Assembly Bill AB 361, members of the Planning Commission may teleconference or video into the meeting due to the fact that we are in the midst of the COVID-19 pandemic;

R. The Planning Commission is an advisory body to the City Council with regard to the approval of General Plan Amendments. At the public hearing on January 3, 2022, the Planning Commission to ok action to recommend the City Council approve General Plan Amendment GPA -22-01 adopting the 2021- 2029 Housing Element with additional recommendations to replace the 2013- 2021 Housing Element, approve the Negative Declaration, and direct staff to submit the Housing Element to the State of California Department of Housing and Community Development for certification;

S. The Notice of the City Council of the City of Alhambra (“City Council”) Public Hearing schedule for January 24, 2022 was posted on the project website and emailed to interested parties on January 14, 2022 and published in the Pasadena Star News on January 14, 2022, in accordance with CEQA;

T. On January 24, 2022, the City Council continued the public hearing in order for additional information be incorporated into the Housing Element for City Council’s consideration;

U. At a Special Meeting on January 31, 2022, the City Council continued its January 24, 2022 Public Hearing. The City Council conducted a duly public hearing and received public comment on the Draft Housing Element. Pursuant to Assembly Bill AB 361, members of the City Council may teleconference or video into the meeting due to the fact that we are in the midst of the COVID-19 pandemic; and

V. At this hearing, the City Council considered the staff report, staff and consultant p
resentation, and public testimony.

SECTION 2. CALIFORNIA ENVIRONMENTAL QUALITY ACT . Based upon the Initial Study/Negative Declaration prepared for the project, the Planning Commission further finds and determines as follows:

A. An Initial Study and Negative Declaration for this project were previously prepared in compliance with the California Environmental Quality Act;

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B. The Initial Study and Negative Declaration were posted on the project website, made available at the Alhambra Civic Center Library and Alhambra City Hall, and notification sent to interested parties on December 16, 2021, and published in the Pasadena Star News on December 17, 2021, in accordance with CEQA. The public review period was open from December 17, 2021 through January 15, 2022;

C. The documents that consti tute the record of proceedings for General Plan Amendment GPA-22-01 upon which the decision of the Planning Commission is based on are located within the Community Development Department; and

D. The Planning Commission, based upon the findings set forth herein, finds the 2021-2029 Housing Element will not have any significant environmental impact. Pursuant to the California Environmental Quality Act, initial review of the project has determined it will not have a significant effect on the environment and is recommending the City Council adopt a Negative Declaration.

SECTION 3. GENERAL PLAN AMENDMENT. Based on the foregoing facts, the Planning Commission hereby determines as follows:

A. The General Plan Amendment for the 2021- 2029 Housing Element is consistent with all other goals, policies, and programs of the Alhambra General Plan and complies with the requirements of State Law;

B. The General Plan amendment promotes the public health, safety, and general welfare of the Alhambra community. The 2021 -2029 Housing Element is a policy -level document that will guide the development of a wide variety of housing types within the City and provides a strategy to address existing and future housing needs while furthering the State’s mandate for housing to address the housing crisis in California; and

C. The Planning Commission, based upon the findings set forth herein, recommends the City Council of the City of Alhambra approve General Plan Amendment GPA-22-01 adopting the 2021-2029 Housing Element of the Alhambra General Plan and direct staff to submit the Housing Element to the State of California Department of Housing and Community Development for certification.

SECTION 4. ADDITIONAL RECOMMENDATIONS REVIEWED BY THE CITY COUNCIL. The City Council considered specific recommendations of the Planning Commission, as contained in Pl anning Commission Resolution No. 22-03 adopted on January 3, 2022, an concurs with the recommended changes to help guide development of housing in the Alhambra community.

The City Council finds that the specific updates be incorporated into the 2021- 2029 H ousing Element to be submitted to th e State of California Department of Housing and Community Development.

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A. Recommendation: The addition of a new Program 27 to the Housing Plan to specifically address Special Housing Needs. This program will direct the C ity to continue to develop internal policies and coordinate with housing providers to address special housing needs for persons with disabilities, seniors, large families, single-parent households, and extremely low- income households. The program will include amendments to the zoning code that are required by state law to remove barriers to developing housing for households with special needs. It also recommends the continuation of the City’s Homeless Outreach Services Program and an update to the City’s Reasonable Accommodations Ordinance tha t is already under consideration.

B. Recommendation: Based on additional analysis requested by HCD, it is recommended the City expand on meaningful actions in its programs to Affirmatively Further Fair Housing. Actions in these programs address strengtheni ng community education and access to public participation, actions to improve housing mobility and access to opportunity, and actions to mitigate displacement risk as a result of economic and market pressures.

SECTION 5. NOW THEREFORE, BE IT RESOLVED, that the foregoing recitals are true and correct and made part of this resolution; and that the City Council of the City of Alhambra, California, hereby approves the Following related to General Plan Amendment GPA-22-01:

A. Resolution No. R2M2207, a Resolu tion of the City Council of the City of Alhambra approving General Plan Amendment GPA-22-01 adopting the 2021-2029 Housing Element of the Alhambra General Plan , approving a Negative Declaration, and direct ing staff to submit the Housing Element to the State of California Department of Housing and Community Development for certification.

PASSED, APPROVED, AND ADOPTED THIS 31
st day of January 2022.

_______________________________
Katherine Lee, Mayor

ATTEST:

_________________________________________
Lauren Myles, City Clerk

APPROVED AS TO FORM:

_________________________________________
JOSEPH M. MONTES, City Attorney

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STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) ss.

CITY OF ALHAMBRA )

I, Lauren Myles, City Clerk Planning Commission Secretary of the City of Alhambra, do hereby certify that forgoing Resolution No. R2M22-7was duly adopted by the City Council of the City of Alhambra at a regular meeting held on the 31
st day of January, 2022, and that the same was adopted
by the following vote:

AYES:

NOES:

ABSENT:

_______________________________
Lauren Myles, City Clerk

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ATTACHMENT 2

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ATTACHMENT 3

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Every
city and county in the Southern California Association of Government (SCAG) region is required to prepare a Housing Element update for the “Sixth Planning Cycle,” which spans the 2021-2029 period (October 15, 2021 - October 15, 2029). A major component of the Housing Element is planning for the ability to accommodate housing units required by the RHNA allocation. The City’s RHNA for this Sixth Planning C ycle is 6,825 units , which are distributed among four income categories that include extremely/very low, low, moderate, and above moderate income level units (Table 1).

Table
1:

City of Alhambra
6th Cycle 2021-2029 Regional Housing Needs Allocation (RHNA) Income Category
RHNA Allocation
Number of Dwelling Units Percentage of Total RHNA
Extremely/Very Low Income 1,774 26%
Low Income 1,036 15%
Moderate Income 1,079 16%
Above Moderate Income 2,936 43%
Total 6,825 100%
Housin
g Element Content
Califo
rnia legislature determined that a primary housing goal for the State is ensuring that all residents have a decent home and a suitable living environment. The State has extensive content requirements for the Housing Elements (Government Code Section 65582 et seq.). To meet S tate law, Alhambra’s the 2021-2029 Housing Element contains the required legal components and is arranged into the following chapters:
• Chap
ter 1: Introduction. This chapter provides background information and context for the Housing Element.
• Chapter 2: Housing Needs Assessment. This chapter provides data on the characteristics of the City’s population, economy, households, housing challenges, special needs housing, and housing stock. The assessment serves as the basis for identifying the appropriate goals, policies, and programs for the City to implement during the 2021-2029 Housing Element cycle. • Chapter 3: Constraints Analysis. This chapter is intended to identify and analyze potential and actual governmental and nongovernmental constraints.
• Chapter 4: Housing Resources. Providing for an adequate supply of housing across all income levels is challenging and requires a balance of resources. This chapter provides an overview of the resources available to the City.
• Chapter 5: Evaluation of Accomplishments u nder Adopted Housing Element . State law requires all Housing Elements to evaluate the effectiveness and progress of a city’s programs in meeting the community’s housing goals and implementing its’ Housing Plan. In this chapter, the programs and policies under the previous planning peri od (the 5th Cycle 2013-2021 planning period), are reviewed and evaluated.

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• Chapter 6: Housing Plan . The Housing P lan identifies long- term housing and shorter term policies to address housing needs in Alhambra. This is one of the most important chapters of the Housing Element because it describes the City’s policies, programs, and objectives for the 2021- 2029 planning period.
• Chapter 7: Sites Inventory and Methods. This chapter, another important component of the Housing Element, identifies how the City has demonstrated the ability to meet assigned housing needs through the provision of suitable sites and land zoned for residential development of 6,825 residential units.

PROJ
ECT BACKGROUND:

On Jul
y 13, 2020, the City approved a contract with ECONorthwest to assist in the preparation of the City of Alhambra’s 2021-2029 Housing Element that would address community housing needs for all income levels and to strategize ways to respond to and provide for those housing needs in accordance with state law . Background on community outreach, public comment, and events and milestones are discussed further in this section.

Commu
nity Outreach
The project commenced in 2020 during the first year of the COVID -19 pandemic which posed a challenge to the way traditional community outreach is conducted. Due to the COVID- 19 state-wide Safer At Home mandate issued by the California governor, community outreach had to prioritize strategies for meaningful public input within a virtual online environment, instead of in person meetings.

Diligent efforts were made to notify City residents, the business community , and various organizations about the project and to solicit input via print, direct email, social media, and verbal announcements at meetings. Diligent effort was also made to provi de translated materials in English, Spanish and Traditional Chinese. For detailed information on all outreach efforts, please refer to Attachment 4.

Pub
lic Comment
Over the course of the project, the City received a total of 46 written comment letters/emails commenting on various aspects of the Housing Element (Attachments 5 & 6). Of the total 47 comment letters, 19 were submitted during the official public review comment period on the Draft Housing Element that took place from August 26, 2021 to September 26, 2021. The remaining 28 comment letters were provided either prior to or after the comment period. Based on comments received, the City learned that (1) preserving single family neighborhoods and affordable housing is of importance; (2) there is mixed- support and concern about housing developments on East Main Street ; (3) there is preference for development in downtown area and along corridors; (4) there is community support for ADU’s; (5) there is mixed-support for solutions that add housing to new areas or upzone existing zones; and (6) there is a desire to support development on city owned sites.

Event
s & Milestones
The following provides a timeline summarizing events and major milestones in preparing Alhambra’s draft 2021-2029 Housing Element Update:
• City
Council Presentation (October 10, 2020): The City Council was provided with a presentation by ECONorthwest that included an overview of the project, including State mandates and the Regional Housing Needs Assessment (RHNA) process.

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• Planning Commission Presentation (October 19, 2020): The Planni ng Commission was provided with the presentation shared with the City Council at their October 1 0, 2021, meeting (see above).
• RHNA Appeal Filed by the City (October 26, 2021): The City of Alhambra submitted a formal appeal with the Southern California Association of Governments (SCAG) requesting that the RHNA appeals board consider a reduction in the number of residential units allocated to the City of Alhambra during the 6th Cycle (2021-2029).
• RHNA Appeals Board Hearing (January 11, 2021): The Southern California Association of Governments RHNA Appeals Board considered the City’s formal appeal and denied the City’s request to reduce the number of residential units allocated to Alhambra during the 6 th Cycle (2021-2029).
• Community Meeting #1 (February 17, 2021): The first virtual community meeting took place on February 17, 2021. Public notice of the meeting was advertised on social media, in the Around Alhambra (on the upper half of the front page), Chamber of Commerce email blast and social media, and verbal announcements at Planning Commission meetings. The project website and direct email also provided notice of the meeting in English, Spanish and Traditional Chinese.

The workshop was formatted to help educate the public about the Housing Element, RHNA process, and inform the community on how they can get involved and provide feedback. The presentation incorporated an interactive live survey designed to help gain input on various aspects related to housing and to gauge the community’s appetite and willingness to consider alternatives to help meet our RHNA.
• Availability of an Online Survey (February 18-March 12, 2021): For those unable to attend the community meeting on February 17, 2021, presentation materials were made available on the project website and the survey was made available through March 12, 2021, to allow for additional community input to be provided. The online survey was made available in English, Spanish, and Traditional Chinese.
• City Council Town Hall Meetings (April 2021): During the month of April, the Mayor and City Council members each hosted virtual Town Hall event s to discuss the Housing Element project with presentations including an overview of the RHNA and discussion of potential housing strategies for community input. Town Hall meetings were held on April 6, 8, 10, and 15, 2021.
• Planning Commission Presentation (May 3, 2021): The Planning Commission was provided with a presentation that had a strong focus on RHNA and was presented an analysis of various options available to the City for working towards RHNA compliance for the 2021-2029 Housing Element. The meeting was intended to solicit input from the Planning Commission as the Consultant and City staff began drafting the Draft Housing Element. The Planning Commission provided good feedback and took action to receive and file the informational report with no additional recommendations added or to delete any of the strategies presented. After this meeting, ECONorthwest, in conjunction with staff, refine d strategies presented and continue d to look at additional strategies to ensure the City will meet its RHNA target. • City Council Presentation (August 9, 2021): The City Council was provided with a presentation about the status of the City’s 2021-2029 Housing Element update. ECONorthwest shared an overview of outreach done to date, a schedule moving forward, a synopsis of what was heard from the community and stakeholders, and the approach to meeting the City’s RHNA

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allocation target. A good discussion ensued about the process and the various components of the Draft Housing Element that was anticipated to be released later in the month. • Release of the Draft Housing Element for Public Review (August 26, 2021) : The Draft Housing Element was released for public review on August 26, 2021, with the public comment period concluding on September 26, 2021. Public notice regarding the release of the Draft Housing Element was provided on social media, in the Around Alhambra, and verbal announcements at Planning Commission and Chamber of Commerce meetings. The project website and direct email also informed the community in English, Spanish, and Traditional Chinese about the release of the Draft Housing Element for public review . The Draft document was made available on project website, at City Hall and the Civic Center Library. • Community Meeting #2 (September 8, 2021): A virtual community meeting was held to inform the public with the status of the project and continue to update the community about the Housing Element process, key dates, and state requirements. Public notice of the meeting was advertised on social media, in the Around Alhambra, and verbal announcements at Planning Comm ission meetings. The project website and direct email also provided notice of the meeting in English, Spanish and Traditional Chinese. Given that the City was in the midst of the official public comment period for the Housing Element, the focus of the community meeting was on providing an overview of the chapters contained in the Draft Housing Element and highlighting key aspects of each chapter to help the public understand the document as they review ed it and submitted public comment. Information was also shared on how to provide feedback during the public review period before concluding on September 26, 2021.
• City Council Presentation ( September 13, 2021) : The City Council was provided with an update and overview of the status of the Housing Element, particularly focusing on feedback received at the second community meeting held on September 8, 2021. At this meeting, the City Council requested an additional update after a meeting with the Planning Commission on September 20, 2021 and before submitting the Draft Housing Element to HCD. • Planning Commission Presentation ( September 20 2021): ECONorthwest provided the Planning Commission with a presentation and facilitated an in-depth discussion on the components of the Draft Housing Element. After comments from the public and discussion and feedback by the Commissioners, the Planning Commission recommended to the City Council that they direct staff to submit the Draft Housing Element to the HCD to begin their formal sixty (60) day review of the document.
• End of the Official Public Review Comment Period for the Draft Housing Element (September 26, 2021): The Draft Housing Element was made available for a 32 -day public review comment period extending from August 26 to September 26, 2021. During this time , a total of 28 letters and emails were received and are included in Attachment 5. • Cit
y Council Presentation (September 27, 2021): ECONorthwest provided the City Council a presentation and facilitated an in -depth discussion on the components of the Draft Housing Element. After comments from the public and discussion and feedback by the councilmembers, the City Council directed staff to submit the Dr aft Housing Element to the HCD to begin their format (60) day review of the document.
• Document Submittal to HCD (October 5, 2021) : Based on the City Council’s direction on September 27, 2021, the 2021-2029 Draft Housing Element was submitted to HCD on Tuesday,

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October 5. HCD acknowledged receipt of the document and began its official 60- day review period.
• Response from HCD (December 2, 2021): On December 3, 2021, staff received a letter from HCD dated December 2, 2021 (Attachment 2) identifying results of their review of Alhambra’s Draft Housing Element . The letter addresses many statutory requirements, and areas that need modification prior to resubmittal to HCD. Comments from HCD and responses to their comments are discussed in more detail in the “Comments from HCD” section of this report and will be the sole focus of discussion at the January 3, 2022, Planning Commission meeting.

COMME
NT LETTER FROM HCD:

Aft
er the Planning Commission and City Council review (September 13 and September 20, 2021, respectively), the City of Alhambra submitted the Draft 2021-2029 Housing Elements to HCD on October 5, 2021, for review and comment. After their sixty (60) day review, HCD provided the City with a letter (Attachment 2) identifying areas the City will need to address prior to resubmittal to certification. Based on HCD’s letter, Alhambra’s Draft 2021 -2029 Housing Element has since been revised and are summarized in the table below. These revisions are also identified in a “redline” version of the Revised Draft (Attachment 3) to make it more convenient to review the revisions incorporated into the updated document. HCD’s letter and the proposed revisions will be the sole focus of discussion at the January 3, 2022, Planning Commission Public Hearing.

Tab
le 2:

HCD Comments and Summary Response to Comments
HCD Comment Response
A. Review and Revision
Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the r esults of this review in the revised element. (Gov. Code, § 65588 (a) and (b).) As part of the review of programs in the past cycle, the element must provide an evaluation of the effectiveness of 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). Programs should be revised depending on the outcomes of a complete evaluation of effectiveness of prior programs.

Completed Edits
Addition of a section to the review of the previous
housing element to specifically summarize the
city’s progress in addressing special housing
needs.

B. Housing Needs, Resources, and Constraints
Affirmatively furthering fair housing (AFFH )in accordance with Chapter15 (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 generally describes the outreach efforts related to the recent Analysis of Impediments to Fair Housing Choice (AI), various data sources (p. 111) and surveys. However, the element could also summarize the results of those outreach efforts to better formulate goals and actions. In addition, the analysis must address compliance with existing fair housing laws as well as any past or current fair housing lawsuits, findings, settlements, judgements, or complaints.

Completed Edits
Elaborate on section in AFFH analysis addressing
enforcement and outreach capacity to include a
summary of ongoing outreach efforts, the city’s
commitment to comply with fair housing laws,
and identification of pending fair housing issues.

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and familial status. For example, the City could utilize the HCD affirmatively furthering fair housing (AFFH) Data Viewer. In addition, the element should analyze dissimilarities at a regional scale (comparing city- wide data to regional level data) for disability and familial status.

Addition of analysis evaluating regional
comparisons and trends by race, disability, and
familial status.

Disproportionate Housing Needs, Including Displacement: The element includes some local data on cost burdened households (overpayment) and overcrowding. However, the element must also evaluate patterns and trends within the City and at a regional scale for overpayment, overcrowding and housing conditions and should address impacts on protected characteristics and access to opportunity for persons experiencing homelessness.

Completed Edits
Add regional comparison data to the AFFH
analysis for Disproportionate Housing Need.

Other Relevant Factors: The element must include other relevant factors that contribute to fair housing issues in the jurisdiction. For instance, the element can analyze historical land use, zoning, governmental and nongovernmental spending, including transportation investments, history of lending practices and demographic trends.

Completed Edits
Addition of a section to the AFFH analysis on
“Historic Trends and Other Factors”. This section
outlines historical redlining policies, barriers in
lending practices, and history of exclusionary
zoning.

Examples include community opposition to affordable housing, housing discrimination, land use and zoning laws, lack of regional cooperation, location and type or lack of affordable housing, and lack of public or private investment in areas of opportunity or affordable housing choices.

Completed Edits
Analysis and prioritization of contribution factors
to AFFH Issues
Sites Inventory and AFFH: The element discusses that most sites to accommodate housing for lower-income households is identified in moderate or high resource areas, but it should also address the number of units and impact of those units on existing patterns for all income groups (e.g., lower, moderate, and above-moderate) to better evaluate whether sites foster inclusive communities. In addition, this analysis should address the other components of the fair housing assessment (e.g., segregation and integration and disproportionate housing needs, including displacement risk).

Completed Edits
Expanded analysis of maps that cross reference
the sites inventory with other AFFH factors
including TCAC, Displacement, and LMI
populations.

Goals, Priorities, Metrics, and Milestones: Based on the outcomes of a complete analysis, the element must be revised to add or modify goals and actions accordingly. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have appropriate metrics and milestones and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection.

Competed Edits
Alignment of specific actions based on
contributing factors with revised DRAFT AFFH
program.

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 (ELI) Households: While the element reports some numerical information for extremely low-income households, it must still identify their projected housing needs and analyze existing housing needs.

This is particularly important given the unique and disproportionate housing needs of ELI households. For example, the element should analyze tenure, cost burden, overcrowding and other household characteristics then examine trends and the availability of resources to determine the magnitude of gaps in housing needs. The projected housing need for ELI households can be calculated by using available census data to determine the number of very Completed Edits:

Most of the data requested in this section was
included in various tables throughout the Housing
Needs Analysis. Addition of a section that
summarizes this data in one place and describes
ELI needs.

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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.

Amended projected housing needs estimates to
rely on the 50% allocation to ELI from very-low
income RHNA.

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).) Housing Conditions: The element identifies the age of the housing stock, but it should also include an estimate of the number of units in need of rehabilitation and replacement. For example, the analysis could include estimates from a recent windshield survey or sampling, estimates from the code enforcement agency, or information from knowledgeable organizations.

Completed Edits
Added a section to the Housing Needs analysis to
include an estimate of housing units in need of
rehabilitation based on data from the Code
Enforcement Division.

An inventory of land suitable and available for residential development, including vacant sit es and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated inco me level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).) Progress toward the (RHNA): The City’s RHNA may be reduced by the number of new units pending, approved, permitted, or built since July 1, 2021 by demonstrating availability and affordability based on rents, sale prices or other mechanisms ensuring affordability (e.g., deed restrictions). The element lists and describes several projects that represent 1,163 units (p. 167) but it still must demonstrate the affordability of these units as described above and address any inconsistency between the project listings and descriptions. In addition, the element must demonstrate the availability of these units in the planning period or remove sites or units as appropriate. This is particularly important given the recent denial of The Villages at The Alhambra that represents over two-thirds of the listed number of units.

Completed Edits
Amended table in the sites inventory
documenting pending projects to include the
current status to demonstrate likelihood of
development during the planning period. Clarified
mechanism ensuring lower income units.

Parcel Listing: The element lists parcels by various factors such as size and zoning. However, the listing must also include sites by general plan designation.

Completed Edits
General plan designation crosswalk has been
added to be included in final inventory.

Realistic Capacity: The element assumes 90 percent of maximum allowable densities to calculate residential capacity on identified sites and lists several examples of recent developments, but it should also list those sites by affordability (e.g., deed restricted, market rate). In addition, if future sites with anticipated zoning allow 100 percent non- residential uses, the element should include an analysis to account for the likelihood of 100 percent non- residential uses occurring on identified sites. The analysis should be based on factors such as development trends, performance standards or other relevant factors. For example, the element could analyze all recent development activity in comparable non-residential zones, how often residential development occurs and adjust residential capacity calculations, policies, and programs accordingly.

Completed Edits
Added clarity on the affordability level of recent
developments inventoried. Added analysis of
development trends on commercial sites. Clarified
the city’s commitment to amend the zoning code
to allow 100% residential in commercial zones
and to offer incentives for affordable housing in
commercial zones.

Nonvacant Sites: The element explains, among several other indicators, that the potential of additional development on nonvacant sites is based on (1) age of improvements, (2) redevelopment indicators (land to improvement value ratio), (3) residential redevelopment factors and (4) existing uses. While the inventory lists the value for redevelopment indicators, it should also list the value for the other indicators. In addition, the element should expand the discussion of redevelopment trends to support these assumptions and adjust calculations if appropriate.

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in the planning period (Gov. Code, § 65583.2, subd. (g)(2).). Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA.

Small Sites: The element identifies a significant number of sites at less than a half-acre. These sites are not eligible absent a demonstration that sites of equivalent size and affordability were successfully developed during the prior planning period or unless other evidence is provided. The element lists recent projects from throughout the broader area, but the listing does not address the projects’ affordability or relationship to the inventory. The element also states the necessity for lot consolidation and the inventory indicates which sites might have potential for consolidation. However, the element should include analysis to demonstrate the potential for consolidation. For example, the analysis could describe the conditions rendering parcels suitable and ready for lot consolidation, common ownership or information from the owners of each aggregated site. Based on the outcomes of this analysis, the element should add or modify programs.

Completed Edits
Clarified that no sites less than 0.50 acres are
included as lower income sites in the inventory.

Elaborated on the regional analysis of subsidized
affordable housing projects that are being
developed on sites less than 0.5 acres, including
two in Alhambra. Expanded analysis of lot
consolidation to identify recent trends. Expanded
on program for lot consolidation. Clarified that
capacity calculations for small sites assume a
lower 70 percent of maximum density consistent
with recent trends.

Environmental Constraints: While the element generally describes a few environmental conditions within the City (p. 101), it must include a discussion relative to identified sites and describe any known environmental or other conditions that could impact housing development on identified sites in the planning period.

Completed Edits
Elaborate on environmental constraints section to
include an evaluation of environmental
constraints in relation to the sites inventory.

Infrastructure: The element mentions the urban water management plan and sewer collection system. However, it must also clarify sufficient total water and sewer capacity (existing and planned) to accommodate the regional housing need.

In addition, 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, include a program to establish a written procedure by a date early in the planning period.

Completed Edits
Elaborated on section to include an evaluation of
water and sewer system capacity. Clarified that
the city has not denied or applied special
conditions on service connections for affordable
housing development. Added statement that the
city will develop written policies and procedures
that grant a priority for sewer hook-ups and
service to developments that include affordable
housing for lower-income households. Included a
statement that the city will distribute the Housing
Element to all required providers after adoption.

Outstanding Edits (at HCD submission)
The city will submit the housing element
inventory in the required format in its final
submittal to HCD.

Accessory Dwelling Units (ADUs): The element assumes 75 ADUs per year for a potential buildout of 600 units within the planning period. According to HCD records, the City has permitted an average of 16 units per year since 2018, which is far less than the 75 units assumed in the element. The trends used in the element appear inconsistent with HCD records and, further, do not support an assumption of 75 ADUs per year. To support assumptions for ADUs in the planning period, the element should reconsider assumptions, reconcile trends with HCD records, include additional information, such as more recent permitted units and inquiries, resources and incentives, other relevant factors, and modify policies and programs as appropriate.

Completed Edits
Amended the section on accessory dwelling units
to include city-tracked data on ADU applications
and permitting that substantiates the city’s
assumptions.

Zoning for a Variety of Housing Types:

Emergency Shelters: The element mentions emergency shelters are permitted in the Valley Boulevard Corridor Specific Plan and Industrial Planned Development Zones. The element should also clarify shelters are permitted Completed Edits
Elaborated on section to provide greater detail on
city’s treatment of emergency shelters and
transitional and supportive housing. Clarified the
city’s programs to ensure that it is compliant with
state law requiring that emergency shelters be

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without discretionary action and address proximity to transportation and services and any conditions inappropriate for human habitability.

Transitional and Supportive Housing: Transitional housing and supportive housing must be permitted as a residential use in all zones allowing residential uses and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. The element explains these uses are considered a residential use but then also indicates the uses are subject to a conditional use permit (CUP) if for seven or more persons, unlike other residential uses. The element should either demonstrate compliance with Government Code section 65583, subdivision (a)(5) or add or revise programs for compliance.
entitled without discretionary action and that
transitional and supportive housing will be
allowed at the same standards as other residential
dwellings in the same zone.

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 disabi lities 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. (Gov. Code, § 6558 3, subd. (a)(5).)
Land-Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types.

The analysis should analyze land use controls independently and cumulatively with other factors. The analysis should specifically address requirements related to multifamily parking requirements, including garages. The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints.

Completed Edits
Clarified location of the constraint summary for
land use controls. Expanded assessment of land
use control constraints to address specific
requested information.

Fees and Other Exactions: The element lists development fees for single family, multifamily and mixed-use development but it should also incorporate impact fees and evaluate impacts as potential constraints on housing cost and supply.

Completed Edits
Elaborated on section to include all impact fees
and discuss impact fees in the context of
development feasibility and potential constraints.

Local Processing and Permit Procedures: While the element briefly describes some local processing and permit procedures (p. 100), it must evaluate the processing and permit procedures’ impacts as potential constraints on housing supply, affordability, timing, and approval certainty. Specifically, the analysis should address approval procedures and findings for the Residential Planned Development permit including the number of public hearings, approval findings and any other discretionary approval procedures.

Completed Edits
Expanded section to clarify the impacts of
processing and permit procedures. Added analysis
of the timing of application approvals.

Constraints on Housing for Persons with Disabilities: Group homes for seven or more persons appear to be excluded from some zones allowing residential uses and are subject to a CUP. The element should evaluate these requirements as constraints and include programs as appropriate.

Completed Edits
Amended section to clarify approvals for small,
large, and rest homes. Clarified that large group
homes should be allowed by right where
multifamily development is allowed by right.

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, if necessary.

Completed Edits
Added section in constraints analysis clarifying
that the city is compliance with all transparency
requirements.

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 develo p 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 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... (65583, subd. (a)(6).) The element must be revised to include analysis of requests to develop housing at densities below those anticipated in the sites inventory and the Completed Edits

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length of time between receiving approval for a housing development and submittal of an application for building permits. The analysis must address any potential hinderances on the construction of a locality’s share of the regional housing need.

Added analysis of planning approvals by density
percentage.

Analyze existing assisted housing developments that are eligible to change to non-low- income housing uses during the next ten years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. ( Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).)
The element identifies assisted housing developments with funding sources that expire during the planning period (p. 49), but it must also provide an analysis. The analysis of “at-risk” units must include the following:

Listing of each development by project name and address; Type of governmental assistance received;
Earliest date of change from low-inc ome use;
Total number of elderly and non-elde rly units;
Estimated total cost for producing, replacing and preserving the units at -ris k; Identification of publi c and private non-profit corporations known to the City to have the legal and managerial capacity to acquire and manage at -risk units; and
Identification and consideration of use of federal, state and local financing and subsidy programs.

Completed Edits
Add information from city documenting missing
information for at-risk units.

C. Housing Programs
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 planni ng 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 regulator y 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 actio ns. (Gov.

Program 19 (City-owned Land): The Program should consider steps beyond “inventory and assess” and include a schedule of actions to facilitate development.

Program 22 (Lot Consolidation and Assemblage): Th
e Program should go
beyond exploring actions or exploring acquisition opportunities and identify and implement actions by a specified date. The Program should also include a specific date for adopting incentives.

Program 23 (ADUs): Th e element should include subsequent actions (e.g., rezone) within a specified time if ADUs are not permitted as assumed in the element.

Program 24 (Reduce Development Constraints for Affordable Housing): The element identifies several constraints such as development standards (p. 78), Completed Edits
Amended noted programs to add clarity to
timelines for achieving specific actions. Expanded
on specific actions and commitments on noted
programs.

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RPD (p. 79) and emergency shelter development standards (p. 88). In response, Program 24 lists standards that “may” be revised. However, this Program should include specific commitments to amend standards and procedure as noted in the element.

Program 26 (Development Streamlining): The Program should consider a timeline earlier in the planning period (e.g., 1-2 years) and actions beyond “explore” to streamline procedures.

Identify actions that will be taken to make sites available during the planning period with appropriate zoning and developmen t 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, mobile homes, housing for agricultural employees, supportive housing, single- room occupancy units, emergency shelters, and transitional housing. (65583, subd. (c)(1).) 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, Program 16 (Rezone and Upzone Strategies) should be amended to ensure compliance with all by-right requirements pursuant to Government Code section 65583.2, subdivisions (h) & (i).

Completed Edits
Add language to program 16 clarifying required
by-right requirements for capacity shortfall.

The housing element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income households. (Gov. Code, § 65583, subd. (c)(2).) While the element includes programs to assist in the development of very low-, low-, and moderate-income households, it must also include a program(s) to assist in the development of housing for ELI and all special needs households (e.g., elderly, homeless, farmworkers, persons with disabilities, female-headed households). Program actions could include proactive outreach and assistance to non-profit service providers and developers, prioritizing some funding for housing developments affordable to ELI and special needs households and offering financial incentives or regulatory concessions to encourage a variety of housing types.

Completed Edits
Draft a proposed program to address Special
Housing Needs and ELI Housing Needs.

Out
standing Edits
Finalize program components based on city input.

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. (65583, subd. (c)(3) .) As noted in Findings B5 and B6, the element requires a complete analysis of potential governmental and non-governmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs to address and remove or mitigate any identified constraints.

Completed Edits
Revised Program 26 to include more specific
actions to reduce identified constraints based on
complete analysis.

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 disabili ty, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Divi sion 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (65583, subd. (c)(5).)

Page 23 of 919 ends

As noted in Finding B1, the element does not contain programs that satisfy the AFFH requirements for specific and meaningful actions to overcome fair housing issues. Based on a complete analysis, the element must add or revise programs.

Completed Edits
Draft revised AFFH programs to address
contribution factors to AFFH
Out
standing Edits
Finalize program components based on city input.

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 includes quantified objectives for construction, rehabilitation and conservation, it must also address these objectives for extremely low-income households.

Completed Edits
Add column in quantified objectives to include
allocation to ELI 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)(8).) While the element includes a general summary of the public participation process, it must also summarize the public comments and describe how they were considered and incorporated into the element.

Completed Edits
Added section to summarize key themes from
public comments and the city’s approach to
incorporating them in the housing element.

NEXT S
TEPS:

This H
ousing Element update will amend the City’s General Plan adopted in 2015 and replace the existing 2013-2021 Housing Element with the 2021- 2029 Housing Element. Pursuant to s tate law, the City has 120 days from the statutory due date of October 15, 2021, which is February 12, 2022, to adopt the Housing Element . Subsequent to the January 3, 2022, Planning Commission meeting, a public hearing will be held by the City Council on January 24, 2022, to review the Planning Commission’s recommendation and consider adoption of the 2021-2022 Housing Element prior to submitting this revised Draft to HCD for certification. Once certification is achieved, the City of Alhambra will have a new, updated Housing Element that is compliant with State law.

ENVIRO
NMENTAL STATUS:

The pr
oject was reviewed pursuant to Section 15063 of the California Environmental Quality Act (“CEQA”). An Initial Study (“IS”) and Negative Declaration (“ND”) for this project have been prepared in compliance with CEQA. The IS/ND identified that the project would not have a significant effect on the environment. The Planning Commission will consider the IS/ND on January 3, 2022 and provide a recommendation to the City Council for adoption at their January 24, 2022 meeting.

PUBL
IC NOTICE:

On De
cember 17, 2021, a Notice of Public Hearing and Notice of Intent to Adopt a Negative Declaration was published in the Pasadena Star Newspaper. The Notice of Intent (NOI) to Adopt a Negative Declaration is to inform interested parties that, in accordance with California Environmental Quality Act (CEQA) Guidelines, Section 15070, the City of Alhambra has prepared an Initial Study - Negative Declaration (IS/ND) for the proposed 2021- 2029 Housing Element. This NOI provides information about the project and instructions for reviewing and submitting comments on the IS/ND. The Planning Commission will review the IS/ND on January 3, 2022, and provide a recommendation to the City Council. The City Council will consider the IS/MND for adoption on January 24, 2022.

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STAFF RE
COMMENDED ACTION:

It is r
ecommended that the Planning Commission:

1. Open the publ
ic hearing and take comment after a presentation provided by Chris Blakney of ECONorthwest regarding the 2021-2029 Housing Element; and

2. After
discussion, close the public hearing and Approve Resolution No 22-03 recommending that the City Council adopt a Resolution approving the Negative Declaration, approve the 2021-2029 Alhambra Housing Element, and direct staff to submit the 2021-2029 Alhambra Housing Element to the State Department of Housing and Community Development for certification.

ATTACHMEN
TS:

1. Planning C
ommission Resolution No. 22-03

2. Letter from HCD, dated December 2, 2021

3. Revised 2021-2029 Housing Element (redline version)

4. Community Outreach

5. Letters received during the official public comment period (8/26/21-9/26/21)

6. Additional public comment letters received

7. Initial Study and Mitigated Negative Declaration

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ATTACHMENT 4
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
Vanessa Reynoso, Deput
y Director
Community Development Department
City of Alhambra
111 South First Street
Alhambra, CA 91801
Dear Vanessa Reyno
so:

RE: City of Alham
bra’s 6th Cycle (2021-2029) Draft Housing Element
Thank you for submitt
ing the City of Alhambra’s (City) draft housing element received for review on October 5, 2021. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. In addition, HCD considered comments from Henry Fung; Paul Talbot; Our Future LA; Alexander M. DeGood-Cox; Castle Nicholson; Abundant Housing LA and YIMBY Law pursuant to Government Code section 65585, subdivision (c).

The draft element address
es 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 the revisions needed to comply with State Housing Element Law.

As a reminder, the C
ity’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 informati
on, 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 this statutory deadline, then any rezoning to accommodate the regional housing needs allocation (RHNA), 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).

December 2, 2021

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Sever
al federal, state, and regional funding programs consider housing element complianc
e 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 will meet housing element requirements for these and other funding sources.

Public par
ticipation 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 represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate.

HCD appr
eciates the dedication and hard work the housing element team provided during the review. We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions, please contact Gerlinde Bernd, of our staff, at [email protected] .

Sincere
ly,
Paul McD
ougall
Enclosure
Senior Program Manager

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APPENDIX
CIT

Y OF ALHAMBRA
The foll
owing 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.

Housi
ng 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).)
As par
t of the review of programs in the past cycle, the element must provide an evaluation of the effectiveness of 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). Programs should be revised depending on the outcomes of a complete evaluation of effectiveness of prior programs. For additional information and sample analysis, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/getting-started/review- revise.shtml.

B. Housing Needs, Resources, and Constraints

1. Aff
irmatively further[ing] fair housing (AFFH) 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 generally describes the outreach efforts related to the recent Analysis of Impediments to Fair Housing Choice (AI), various data sources (p. 111) and surveys. However, the element could also summarize the results of those outreach efforts to better formulate goals and actions. In addition, the analysis must address compliance with existing fair housing laws as well as any past or current fair housing lawsuits, findings, settlements, judgements, or complaints.

Integration and Segregation: While the element provides analysis utilizing dissimilarity and isolation indices, it should utilize additional data sources to evaluate patterns and trends within the City, specifically for race, disability, and familial status. For example, the City could utilize the HCD affirmatively furthering fair housing (AFFH) Data Viewer. In addition, the element should analyze dissimilarities at a regional scale (comparing city- wide data to regional level data) for disability and familial status.

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Contributing Factors: The element must list and prioritize contributing factors to fair housing issues. While the element lists some fair housing issues, it generally does not list and prioritize contributing factors. Contributing factors create, contribute to, perpetuate, or increase the severity of fair housing issues and are fundamental to developing adequate goals and actions. Examples include community opposition to affordable housing, housing discrimination, land use and zoning laws, lack of regional cooperation, location and type or lack of affordable housing, and lack of public or private investment in areas of opportunity or affordable housing choices.

Sites Inventory and AFFH: The element discusses that most sites to accommodate housing for lower-income households is identified in moderate or high resource areas, but it should also address the number of units and impact of those units on existing patterns for all income groups (e.g., lower, moderate, and above-moderate) to better evaluate whether sites foster inclusive communities. In addition, this analysis should address the other components of the fair housing assessment (e.g., segregation and integration and disproportionate housing needs, including displacement risk).

Goals, Priorities, Metrics, and Milestones: Based on the outcomes of a complete analysis, the element must be revised to add or modify goals and actions accordingly.

Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have appropriate metrics and milestones and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection. For further guidance, please visit HCD’s Affirmatively Furthering Fair Housing in California webpage 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 (ELI) Households: While the element reports some numerical information for extremely low-income households, it must still identify their projected housing needs and analyze existing housing needs. This is particularly important given the unique and

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dispropor
tionate housing needs of ELI households. For example, the element should analyze tenure, cost burden, overcrowding and other household characteristics then examine trends and the availability of resources to determine the magnitude of gaps in 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 addit
ional information, see the Building Blocks at http://www.hcd.ca.gov/community- development/building-blocks/housing-needs/extremely-low-income-housing-needs.shtml.

For example, the analysis could include estimates from a recent windshield survey or sampling, estimates from the code enforcement agency, or information from knowledgeable organizations.

Code, § 65583, subd. (a)(3).)
Progress toward the (RHNA): The City’s RHNA may be reduced by the number of new units pending, approved, permitted, or built since July 1, 2021 by demonstrating availability and affordability based on rents, sale prices or other mechanisms ensuring affordability (e.g., deed restrictions). The element lists and describes several projects that represent 1,163 units (p. 167) but it still must demonstrate the affordability of these units as described above and address any inconsistency between the project listings and descriptions. In addition, the element must demonstrate the availability of these units in the planning period or remove sites or units as appropriate. This is particularly important given the recent denial of The Villages at The Alhambra that represents over two-thirds of the listed number of units.

Parcel Listing: The element lists parcels by various factors such as size and zoning.

However, the listing must also include sites by general plan designation.

Realistic Capacity: The element assumes 90 percent of maximum allowable densities to calculate residential capacity on identified sites and lists several examples of recent developments, but it should also list those sites by affordability (e.g., deed restricted, market rate). In addition, if future sites with anticipated zoning allow 100 percent non- residential uses, the element should include an analysis to account for the likelihood of 100 percent non-residential uses occurring on identified sites. The analysis should be based on factors such as development trends, performance standards or other relevant factors. For example, the element could analyze all recent development activity in

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comparabl
e non-residential zones, how often residential development occurs and adjust residential capacity calculations, policies, and programs accordingly.

Small Sites: The element identifies a significant number of sites at less than a half-acre.

These sites are not eligible absent a demonstration that sites of equivalent size and affordability were successfully developed during the prior planning period or unless other evidence is provided. The element lists recent projects from throughout the broader area, but the listing does not address the projects’ affordability or relationship to the inventory.

The element also states the necessity for lot consolidation and the inventory indicates which sites might have potential for consolidation. However, the element should include analysis to demonstrate the potential for consolidation. For example, the analysis could describe the conditions rendering parcels suitable and ready for lot consolidation, common ownership or information from the owners of each aggregated site. Based on the outcomes of this analysis, the element should add or modify programs.

In addit
ion, 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, include a program 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.

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Electronic Sites Inventory Form: Pursuant to Government Code section 65583.3, subdivision (b), the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory. Please see HCD’s housing element webpage at https://www.hcd.ca.gov/community-development/housing-element/index.shtml for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance. Please note, upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to [email protected].

Zoning for a Variety of Housing Types:
• Emergency Shelters: The element mentions emergency shelters are permitted in the Valley Boulevard Corridor Specific Plan and Industrial Planned Development Zones. The element should also clarify shelters are permitted without discretionary action and address proximity to transportation and services and any conditions inappropriate for human habitability.
• Transitional and Supportive Housing: Transitional housing and supportive housing must be permitted as a residential use in all zones allowing residential uses and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. The element explains these uses are considered a residential use but then also indicates the uses are subject to a conditional use permit (CUP) if for seven or more persons, unlike other residential uses. The element should either demonstrate compliance with Government Code section 65583, subdivision (a)(5) or add or revise programs for compliance.

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. (Gov. Code, § 65583, subd. (a)(5).)
Land-Use Controls: The element must identify and analyze all relevant land use controls impacts as potential constraints on a variety of housing types. The analysis should analyze land use controls independently and cumulatively with other factors. The analysis should specifically address requirements related to multifamily parking requirements, including

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garages.

The analysis should address any impacts on cost, supply, housing choice, affordability, timing, approval certainty and ability to achieve maximum densities and include programs to address identified constraints.

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 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… (Gov. Code, § 65583, subd. (a)(6).)
The element must be revised to include analysis of requests to develop housing at densities below those anticipated in the sites inventory and the length of time between receiving approval for a housing development and submittal of an application for building permits. The analysis must address any potential hinderances on the construction of a locality’s share of the regional housing need.

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• List
ing of each development by project name and address;
• Type of governmental assistance received;
• Earliest date of change from low-income use;
• Total number of elderly and non-elderly units;
• Estimated total cost for producing, replacing and preserving the units at-risk; • Identification of public and private non-profit corporations known to the City to have the legal and managerial capacity to acquire and manage at-risk units; and • Identification and consideration of use of federal, state and local financing and subsidy programs.

For additional information and sample analysis, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/housing-needs/assisted- housing-developments.shtml and for more information on identifying units at-risk, see the California Housing Partnership Corporation at http://www.chpc.net.

C. Housing Programs

Code, § 65583, subd. (c).)
To have a benefi
cial impact in the planning period and address the goals of the housing element, programs must be revised with discrete timelines and specific commitment. Programs that should be revised with discrete timelines include Programs 1 (Housing Rehabilitation), 10 (Cooperation with Affordable Housing Developers), 11 (Expand Affordable Housing Funding), 20 (Adaptive Reuse), 24 (Reduce Development Constraints for Affordable Housing) and 25 (Housing Production Education). Programs to revised with specific commitment include:
• Progr
am 19 (City-owned Land): The Program should consider steps beyond “inventory and assess” and include a schedule of actions to facilitate development. • Program 22 (Lot Consolidation and Assemblage): The Program should go beyond exploring actions or exploring acquisition opportunities and identify and implement actions by a specified date. The Program should also include a specific date for adopting incentives.
• Program 23 (ADUs): The element should include subsequent actions (e.g., rezone) within a specified time if ADUs are not permitted as assumed in the element. • Program 24 (Reduce Development Constraints for Affordable Housing): The element identifies several constraints such as development standards (p. 78), RPD (p. 79) and emergency shelter development standards (p. 88). In response, Program 24 lists

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standards
that “may” be revised. However, this Program should include specific commitments to amend standards and procedure as noted in the element. • Program 26 (Development Streamlining): The Program should consider a timeline earlier in the planning period (e.g., 1-2 years) and actions beyond “explore” to streamline procedures.

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).) As not
ed 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 addit
ion, Program 16 (Rezone and Upzone Strategies) should be amended to ensure compliance with all by-right requirements pursuant to Government Code section 65583.2, subdivisions (h) & (i).

3. The housing element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income households. (Gov. Code, § 65583, subd. (c)(2).)
Whil
e the element includes programs to assist in the development of very low-, low-, and moderate-income households, it must also include a program(s) to assist in the development of housing for ELI and all special needs households (e.g., elderly, homeless, farmworkers, persons with disabilities, female-headed households). Program actions could include proactive outreach and assistance to non-profit service providers and developers, prioritizing some funding for housing developments affordable to ELI and special needs households and offering financial incentives or regulatory concessions to encourage a variety of housing types.

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 not
ed in Findings B5 and B6, the element requires a complete analysis of potential governmental and non-governmental constraints. Depending upon the results of that

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analysi
s, the City may need to revise or add programs to address and remove or mitigate any identified constraints.

5. 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, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).) As not
ed in Finding B1, the element does not contain programs that satisfy the AFFH requirements for specific and meaningful actions to overcome fair housing issues. Based on a complete analysis, the element must add or revise 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).)
Whil
e the element includes quantified objectives for construction, rehabilitation and conservation, it must also address these objectives for extremely low-income 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)(8).) Whil
e the element includes a general summary of the public participation process, it must also summarize the public comments and describe how they were considered and incorporated into the element.

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HCD Comment Response
A. Review and Revision

1. 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).)
As part of the review of programs in the past cycle, the element must provide an evaluation of the effectiveness of 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). Programs should be revised depending on the outcomes of a complete evaluation of effectiveness of prior programs.

Completed Edits
Addition of a section to the review of the previous housing element to specifically summarize the City’s progress in addressing special housing needs. This included details of the City’s processing of reasonable accommodations, its homeless outreach program, and the Mariposa project that will deliver 24 extremely low income units in addition to 25 lower income units. (page 167) B. Housing Needs, Resources, and Constraints

1. Affirmatively furthering fair housing (AFFH )in accordance with Chapter15 (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 generally describes the outreach efforts related to the recent Analysis of Impediments to Fair Housing Choice (AI), various data sources (p. 111) and surveys. However, the element could also summarize the results of those outreach efforts to better formulate goals and actions. In addition, the analysis must address compliance with existing fair housing laws as well as any past or current fair housing lawsuits, findings, settlements, judgements, or complaints.

Completed Edits
Elaborated on section in affirmatively furthering fair housing (AFFH) analysis addressing enforcement and outreach capacity to include a summary of ongoing outreach efforts, the City’s commitment to comply with fair housing laws, and identification of pending fair housing issues. This included data from the Housing Rights Center on housing inquiries and cases filed. (Page 126, 128- 29)
Integration and Segregation: While the element provides analysis utilizing dissimilarity and isolation indices, it should utilize additional data sources to evaluate patterns and trends within the City, specifically for race, disability, and familial status. For example, the City could utilize the HCD affirmatively furthering fair housing (AFFH) Data Viewer. In addition, the element should analyze dissimilarities at a regional scale (comparing city- wide data to regional level data) for disability and familial status.

Completed Edits
Addition of analysis evaluating regional comparisons and trends by race, disability, and familial status.
• This included dissimilarity index data by race between 1990 and current in Alhambra and the LA region. (pag e 130)
• It included data tables showing persons with disabilities by disability over time in Alhambra and LA County. (pa ge 133) • It included data tables comparing households by family status over time in Alhambra and LA County. (page 135)
• Because female-headed households with children were
identified as a shifting population segment, a map showing the existing concentration in Alhambra was also included. (page 136)
Disproportionate Housing Needs, Including Displacement: The element includes some local data on cost burdened households (overpayment) and overcrowding. However, the element must also evaluate patterns and trends within the City and at a regional scale for overpayment, overcrowding and housing Completed Edits
Added regional comparison data to the affirmatively furthering fair housing (AFFH) analysis for disproportionate housing need.

ATTACHMENT 5

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conditions and should address impacts on protected characteristics and access to opportunity for persons experiencing homelessness.
• This included a section on cost burdened households,
compared to the LA County. (page 140)
• It included maps displaying the distribution of overpayment renter and owner households in Alhambra. (page 140-41)
• It included a regional comparison of overcrowding in
Alhambra compared to LA County and some peer jurisdictions. (page 141)
• It included a map of the distribution of overcrowded
households in Alhambra. (page 142)
Other Relevant Factors: The element must include other relevant factors that contribute to fair housing issues in the jurisdiction. For instance, the element can analyze historical land use, zoning, governmental and nongovernmental spending, including transportation investments, history of lending practices and demographic trends.

Completed Edits
Addition of a section to the affirmatively furthering fair housing (AFFH) analysis on “Historic Trends and Other Factors”. Factors identified in this section include: (page 145)
• Alhambra’s history of redlining policies as a “C-rated community”.
• Barriers in lending practices and access to financial services. • A map showing the distribution of households without access to banking or credit.
• Narrative discussing Alhambra’s history of exclusionary zoning.

Contributing Factors: The element must list and prioritize contributing factors to fair housing issues.

While the element lists some fair housing issues, it generally does not list and prioritize contributing factors. Contributing factors create, contribute to, perpetuate, or increase the severity of fair housing issues and are fundamental to developing adequate goals and actions. Examples include community opposition to affordable housing, housing discrimination, land use and zoning laws, lack of regional cooperation, location and type or lack of affordable housing, and lack of public or private investment in areas of opportunity or affordable housing choices.

Completed Edits
Analysis and prioritization of contribution factors to affirmatively furthering fair housing (AFFH) Issues to include: (page 152) • Displacement of residents due to economic pressures
• Availability of units in a range of sizes
• Location of environmental health hazards
• Location and type of affordable housing
• Access to financial services
• Lack of fair housing outreach and enforcement
This assessment includes a table based on HCD’s guidance memo detailing housing issues, contributing factors, strategies, and a list of meaningful actions. These actions form the basis of the City’s AFFH programs and are detailed in the housing plan.

Sites Inventory and AFFH: The element discusses that most sites to accommodate housing for lower- income households is identified in moderate or high resource areas, but it should also address the number of units and impact of those units on existing patterns for all income groups (e.g., lower, moderate, and above-moderate) to better evaluate whether sites foster inclusive communities. In addition, this analysis should address the other components of the fair housing assessment (e.g., segregation and integration and disproportionate housing needs, including displacement risk).

Completed Edits
Expanded analysis of maps that cross reference the sites inventory with other affirmatively furthering fair housing (AFFH) factors. This included: (page 147)
• Sites inventory by TCAC opportunity composite score to include all sites not just lower income sites.
• Data table showing the share of sites by displacement typology
• Map showing the geographic concentration of sites by
displacement typology.

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• Data table showing the share of sites by low to moderate Income (LMI) quartile.
• Map showing the distribution of sites by LMI concentration. • Statement that Alhambra does not have any racially or ethnically concentrated areas of poverty (R/ECAP) and no need for a site map comparison is needed.

Competed Edits
Alignment of specific actions based on contributing factors with revised DRAFT Affirmatively Furthering Fair Housing (AFFH) program. (page 154, Program 28: page 190)

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 (ELI) Households: While the element reports some numerical information for extremely low-income households, it must still identify their projected housing needs and analyze existing housing needs. This is particularly important given the unique and disproportionate housing needs of ELI households. For example, the element should analyze tenure, cost burden, overcrowding and other household characteristics then examine trends and the availability of resources to determine the magnitude of gaps in 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.

Completed Edits:

Most of the data requested by HCD for this requirement was included in various tables throughout the Housing Needs Analysis.

This amendment included an addition of a section that
summarizes this data in one place, along with a table, and describes extremely low income (ELI) needs in the community. It also calls out the insufficiency of Alhambra’s classification of single-room occupancy (SRO) and draws attention to a program to expand the allowance of SRO housing to assist in meeting extremely low income housing need. (page 30)

This change also amended Alhambra’s presentation of projected housing need by relying on the default 50% allocation of very low income (VLI) need to account for extremely low income (ELI) consistent with HCD guidance. (page 11)

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).) Housing Conditions: The element identifies the age of the housing stock, but it should also include an estimate of the number of units in need of rehabilitation and replacement. For example, the analysis could include estimates from a recent windshield survey or sampling, estimates from the code enforcement agency, or information from knowledgeable organizations.

Completed Edits
Alhambra does not have a windshield survey of the housing stock.

This amendment added a section to the housing needs analysis to estimate the number of housing units in need of rehabilitation in a typical year. This analysis was based off: (page 50)
• Conversations with the Code Enforcement Division
• Review of the last two years of data on code complaints in categories with health and safety issues

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• Review of 5-year data on code violations for unsafe and unsanitary conditions and structures with deteriorated or health and safety conditions.

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 toward the (RHNA): The City’s RHNA may be reduced by the number of new units pending, approved, permitted, or built since July 1, 2021 by demonstrating availability and affordability based on rents, sale prices or other mechanisms ensuring affordability (e.g., deed restrictions). The element lists and describes several projects that represent 1,163 units (p. 167) but it still must demonstrate the affordability of these units as described above and address any inconsistency between the project listings and descriptions. In addition, the element must demonstrate the availability of these units in the planning period or remove sites or units as appropriate. This is particularly important given the recent denial of The Villages at The Alhambra that represents over two-thirds of the listed number of units.

Completed Edits
• The City amended the table in the sites inventory analysis to include the status of every project to demonstrate the high likelihood of development during the planning period. For the Villages at the Alhambra project, it was discussed with staff and the Planning Commission if “The Villages” should continue to be considered a project or be considered a potential redevelopment site. Staff and the Planning Commission
agreed on the possibility of the project being approved with appropriate mitigations or through a streamlining effort. Given the additional uncertainty, the units assumed for progress toward the RHNA were discounted by 30 percent. (page 207) • Amended programs to include a “backstop” provision to reassess the project as a site if not approved within two years of adoption. (Program 31: page 192)
Parcel Listing: The element lists parcels by various factors such as size and zoning. However, the listing must also include sites by general plan designation.

Completed Edits
Confirmed in conversations with HCD that the General Plan designation can be added to the final submittal in electronic format.

Realistic Capacity: The element assumes 90 percent of maximum allowable densities to calculate residential capacity on identified sites and lists several examples of recent developments, but it should also list those sites by affordability (e.g., deed restricted, market rate). In addition, if future sites with anticipated zoning allow 100 percent non- residential uses, the element should include an analysis to account for the likelihood of 100 percent non-residential uses occurring on identified sites. The analysis should be based on factors such as development trends, performance standards or other relevant factors. For example, the element could analyze all recent development activity in comparable non- residential zones, how often residential development occurs and adjust residential capacity calculations, policies, and programs accordingly.

Completed Edits
• This amendment added clarification in its inventory of recent and proposed development which projects were
affordable/lower income. (page 201)
• It added a section of analysis discussing recent development trends on commercial properties, drawing attention to existing standards that were prohibitive to developing residential in commercial zones. (page 199)
• Included a change to programs to strengthen the likelihood of residential development in commercial zones by amending the zoning code to allow 100% residential in commercial zones and incentivize residential development for lower income households in commercial zones through concessions and
incentives. (Program 24: page 186)
Nonvacant Sites: The element explains, among several other indicators, that the potential of additional development on nonvacant sites is based on (1) age of improvements, (2) redevelopment indicators (land to improvement value ratio), (3) residential redevelopment factors and (4) existing uses. While the inventory lists the value for redevelopment indicators, it should also list the value for the other Completed Edits
Included additional data in the sites inventory that represents the City’s analysis for calculating the likelihood of redevelopment, alongside a comprehensive methodology for determining

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indicators. In addition, the element should expand the discussion of redevelopment trends to support these assumptions and adjust calculations if appropriate.

In addition, the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower income households. For your information, the housing element must demonstrate existing uses are not an impediment to additional residential development and will likely discontinue in the planning period (Gov. Code, § 65583.2, subd. (g)(2).). Absent findings (e.g., adoption resolution) based on substantial evidence, the existing uses will be presumed to impede additional residential development and will not be utilized toward demonstrating adequate sites to accommodate the RHNA. achievable capacity and redevelopment likelihood (page 218). This methodology also calls attention to a large subset of properties that demonstrated redevelopment potential within the modeling framework but were not included in the inventory because the existing use as determined to be an impediment based on lease data, vacancy, tenant profile, and the character of the improvement. This process omitted 116 parcels. (page 218, page 221)

Because more than 50% of lower income capacity is on nonvacant sites, this section also includes substantial evidence that existing uses would not impede redevelopment. This data includes an update to the Site Inventory Appendix to include the following factors: (page 224)
• Lot size
• Land to improvement ratio
• Age of improvements
• Ratio of allowed to existing density (densification potential) • Comparison of in-place value to recent residential site transaction values.
• Existing use.

The City also completed draft resolution language finding existing uses are not likely to impede residential redevelopment based on the factor analysis.

Completed Edits
• Revised language to include a clarification that the Sites inventory does not include small sites for lower income RHNA. (page 197)
• Revised analysis to show that despite that the City did not use small sites for lower income, there is a precedent in the region and in the city for small site lower income development. Two of the regional small site projects are in Alhambra. (page 197) • Clarified that small sites in the inventory (for moderate/above moderate) had a much larger reduction assumed in realistic capacity (70% compared to 90%) consistent with recent
trends. (page 199)
• Expanded analysis of lot consolidation to identify recent or proposed residential projects that required lot consolidation. • Expanded Program 22 to strengthen efforts to promote lot consolidation. (Program 22: page 185)
Environmental Constraints: While the element generally describes a few environmental conditions within the City (p. 101), it must include a discussion relative to identified sites and describe any known Completed Edits

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environmental or other conditions that could impact housing development on identified sites in the planning period.
• The City used SCAG’s Housing Element Parcel Tool (HELPR) to assess all environmental constraints available through the tool. (page 114)
• Included a section on the location of soil and groundwater contamination associated with the San Gabriel Valley
Superfund Site 3 and the potential impacts on development and mitigation needs. (page 114)
Infrastructure: The element mentions the urban water management plan and sewer collection system.

However, it must also clarify sufficient total water and sewer capacity (existing and planned) to accommodate the regional housing need.

Completed Edits
• Elaborated on section to include an evaluation of water and sewer system capacity. (page 116)
• Clarified that the City has not denied or applied special conditions on service connections for affordable housing development and amended programs to direct the City to
develop written policies and procedures that grant a priority for sewer hook-ups and service to developments that include affordable housing for lower income households. (page 116, Program 31: page 192)
• Included a statement that the City will distribute the Housing Element to all required providers after adoption. (page 117) Electronic Sites Inventory Form: Pursuant to Government Code section 65583.3, subdivision (b), the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory.

Completed Edits
Confirmed in conversations with HCD that the City will submit the Housing Element inventory in the required format in its final submittal to HCD.

Completed Edits
• The City’s estimate of ADU capacity is based on data it tracks on ADU applications and permits that is different than HCD’s data for Alhambra. This amendment included a summary of trends according to Alhambra’s data through December 2021. (page 215)
• Included a link to the City’s ADU webpage that details ADU standards, the City’s application process, and links to its biannual report. (page 215)
Zoning for a Variety of Housing Types:
• Emergency Shelters: The element mentions emergency shelters are permitted in the Valley Boulevard Corridor Specific Plan and Industrial Planned Development Zones. The element should also clarify shelters are permitted without discretionary action and address proximity to transportation and services and any conditions inappropriate for human habitability. • Transitional and Supportive Housing: Transitional housing and supportive housing must be permitted as a residential use in all zones allowing residential uses and only subject to those restrictions that apply to other residential dwellings of the same type in the same zone. The element explains these uses are considered a residential use but then also indicates the uses are subject to a conditional use permit (CUP) if for seven or more persons, unlike other Completed Edits
• Elaborated on section to provide greater detail on City’s treatment of emergency shelters and transitional and
supportive housing. (page 97)
• Amended programs to ensure that the City will be compliant with state law requiring that emergency shelters be entitled without discretionary action and that transitional and
supportive housing will be allowed at the same standards as other residential dwellings in the same zone. (Program 24:
page 186, Program 27: page 189)

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residential uses. The element should either demonstrate compliance with Government Code section 65583, subdivision (a)(5) or add or revise programs for compliance.

Completed Edits
Identified land use control constraints were included in multiple sections of the constraints analysis. This amendment discussed each constraint in a single place and how constraints could collectively prohibit development under densities proposed in the rezoning program. This analysis also discussed how parking standards specifically would prohibit development. Based on this analysis the City strengthened its program to remove development constraints by directing the City to: (Page 87, Program 26: page 188)
• Repeal the Valley Boulevard Specific Plan and replace with a zone and development standards to achieve
assumed densities.
• Revise ADU standards to improve compatibility with local characteristics.
• Allow 100% residential in commercial zones
• Remove a calculation of density for multifamily uses that makes it difficult to achieve maximum densities.
• Amend height, setbacks, FAR, and parking standards as appropriate to achieve maximum densities as a part of
the Comprehensive Zoning Code update.

Fees and Other Exactions: The element lists development fees for single family, multifamily and mixed- use development but it should also incorporate impact fees and evaluate impacts as potential constraints on housing cost and supply.

Completed Edits
Included an expanded accounting of impact fees and updated calculations of fees per unit for a variety of unit types. (page 105) Local Processing and Permit Procedures: While the element briefly describes some local processing and permit procedures (p. 100), it must evaluate the processing and permit procedures’ impacts as potential constraints on housing supply, affordability, timing, and approval certainty. Specifically, the analysis should address approval procedures and findings for the Residential Planned Development permit including the number of public hearings, approval findings and any other discretionary approval procedures.

Completed Edits
• Added typical timelines for a range of development review applications as reported by the Planning Department. (page 111)
• Amended language to strengthen the determination that the City’s RPD permit and overreliance on subjective standards is inconsistent with the Permit Streamlining Act and Housing Accountability Act and is a likely constraint on development. (page 108, page 111)
• Amended programs to direct the City to ensure that its review process is compliant with state law and to develop a proposal for additional exemptions and revisions to the RPD permit process. (Program 26: page 188)

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Completed Edits
• Amended section to clarify approvals for group homes.

Clarified that to not be a constraint large group homes should be allowed by right where multifamily development is allowed by right. (page 97)
• Amended programs to ensure the removal of this constraint. (Program 27: page 189, Program 24: page 186)
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, if necessary.

Completed Edits
Added section in constraints analysis clarifying that the City is compliance with all transparency requirements. (page 117)

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 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... (65583, subd. (a)(6).)
The element must be revised to include analysis of requests to develop housing at densities below those anticipated in the sites inventory and the length of time between receiving approval for a housing development and submittal of an application for building permits. The analysis must address any potential hinderances on the construction of a locality’s share of the regional housing need.

Completed Edits
Included a new section on timing and density to evaluate: (page 62)
• The share of developments that have requested to
develop at below maximum densities. Included a finding
that requests are typically on small sites and this
informed the assumption in the sites inventory analysis that small sites with high allowable densities only include 70 percent of max density in the capacity analysis.
• Included an evaluation of typical time between project approvals and request for permit for projects at different scales. Clarified the City’s policy of offering extensions to try and encourage projects to move forward.
• Added an evaluation of the City’s current formula for evaluating the number of units in a property as constraint in achieving maximum density and discussed programs to
remove this constraint.

7. Analyze existing assisted housing developments that are eligible to change to non-low- income housing uses during the next ten years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).) The element identifies assisted housing developments with funding sources that expire during the planning period (p. 49), but it must also provide an analysis. The analysis of “at-risk” units must include the following:
• Listing of each development by project name and address; • Type of governmental assistance received;
• Earliest date of change from low-income use;
• Total number of elderly and non-elderly units;
Completed Edits
Included additional analysis documenting required data and analysis to assess the likelihood of at-risk projects converting to market rate. (page 55)

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• Estimated total cost for producing, replacing and preserving the units at-risk; • Identification of public and private non-profit corporations known to the City to have the legal and managerial capacity to acquire and manage at-risk units; and • Identification and consideration of use of federal, state and local financing and subsidy programs.

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. Programs that should be revised with discrete timelines include Programs 1 (Housing Rehabilitation), 10 (Cooperation with Affordable Housing Developers), 11 (Expand Affordable Housing Funding), 20 (Adaptive Reuse), 24 (Reduce Development Constraints for Affordable Housing) and 25 (Housing Production Education).

Programs to revised with specific commitment include:
• Program 19 (City-owned Land): The Program should consider steps beyond “inventory and assess” and include a schedule of actions to facilitate development. • Program 22 (Lot Consolidation and Assemblage): The Program should go beyond exploring actions or exploring acquisition opportunities and identify and implement actions by a specified date. The Program should also include a specific date for adopting incentives. • Program 23 (ADUs): The element should include subsequent actions (e.g., rezone) within a specified time if ADUs are not permitted as assumed in the element. • Program 24 (Reduce Development Constraints for Affordable Housing): The element identifies several constraints such as development standards (p. 78), RPD (p. 79) and emergency shelter development standards (p. 88). In response, Program 24 lists standards that “may” be revised.

However, this Program should include specific commitments to amend standards and procedure as noted in the element.
• Program 26 (Development Streamlining): The Program should consider a timeline earlier in the planning period (e.g., 1-2 years) and actions beyond “explore” to streamline procedures.

Completed Edits
Amended program timelines and specific actions to provide additional specificity to the timelines and specific actions as requested by HCD. (Housing Plan Chapter: page 169)

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, mobile homes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (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, Program 16 (Rezone and Upzone Strategies) should be amended to ensure compliance with all by-right requirements pursuant to Government Code section 65583.2, subdivisions (h) & (i).

Completed Edits
Amended the City’s rezoning program to include required rezoning language for lower income shortfall sites. The City’s approach goes beyond the minimum requirement and the program directs the City to rezone all lower income sites (not just shortfall sites) consistent with lower income shortfall requirements. (Program 16:
page 181)

3. The housing element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate- income households. (Gov. Code, § 65583, subd. (c)(2).)
While the element includes programs to assist in the development of very low-, low-, and moderate- income households, it must also include a program(s) to assist in the development of housing for ELI and all special needs households (e.g., elderly, homeless, farmworkers, persons with disabilities, female- headed households). Program actions could include proactive outreach and assistance to non-profit service providers and developers, prioritizing some funding for housing developments affordable to ELI and special needs households and offering financial incentives or regulatory concessions to encourage a variety of housing types.

Completed Edits
The City added a program specific to meeting the needs of persons with special housing needs. (Program 27: page 189)

4. 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. (65583, subd. (c)(3).) As noted in Findings B5 and B6, the element requires a complete analysis of potential governmental and non-governmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs to address and remove or mitigate any identified constraints.

Completed Edits
Revised Program 24 and 26 to include more specific actions to reduce identified constraints based on complete analysis. (Program 24: page 186, Program 26: page 188)

5. 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, and any other state and federal fair housing and planning law. (65583, subd. (c)(5).)
As noted in Finding B1, the element does not contain programs that satisfy the AFFH requirements for specific and meaningful actions to overcome fair housing issues. Based on a complete analysis, the element must add or revise programs.

Completed Edits
The City made significant changes to its Affirmatively Furthering Fair Housing (AFFH) programs to reflect findings of the AFFH analysis and actions to mitigate and overcome fair housing issues.

These actions had three focus areas: (Program 28: page 190) 1) Community Education
2) Housing Mobility and Improving Access to Opportunity 3) Mitigating Displacement Risk
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 includes quantified objectives for construction, rehabilitation and conservation, it must also address these objectives for extremely low-income households.

Completed Edits

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Added column in quantified objectives to include allocation to extremely low income (ELI) households. (page 193)
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)(8).) While the element includes a general summary of the public participation process, it must also summarize the public comments and describe how they were considered and incorporated into the element.

Completed Edits
Added section to summarize key themes from public comments and the City’s approach to incorporating them in the Housing Element. (page 8)

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DRAFT
City of Alhambra
2021- 2029 Housing Element
Initial HCD Review Draft Final
Draft
JanuaryOctober 20221
Prepared for: City of Alhambra
FinalDraft Report for Initial HCD ReviewAdoption
City of Alhambra
111 South 1st Street
Alhambra, CA 91801
626-570-5007
ECONorthwest
706 S Hill Street #1100
Los Angeles, CA 90014
213-218-6740
ATTACHMENT 6

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City of Alhambra Public Review Draft Housing Element ii Table of Contents
CHAPTER 1: INTRODUCTION ................................................................................................................................. 5 COMMUNITY CONTEXT ............................................................................................................................................... 5 ROLE OF THE HOUSING ELEMENT ................................................................................................................................. 5 SUMMARY OF STATE HOUSING LEGISLATION .................................................................................................................. 5 RELATIONSHIP TO OTHER GENERAL PLAN ELEMENTS ........................................................................................................ 6 PUBLIC PARTICIPATION ............................................................................................................................................... 7 SUMMARY RECONCILIATION OF RHNA ALLOCATION AND CAPACITY .................................................................................. 11 CHAPTER 2: HOUSING NEEDS ASSESSMENT ........................................................................................................ 12 POPULATION CHARACTERISTICS .................................................................................................................................. 12 ECONOMIC CHARACTERISTICS .................................................................................................................................... 16 HOUSEHOLD CHARACTERISTICS .................................................................................................................................. 20 HOUSING PROBLEMS ............................................................................................................................................... 25 SUMMARY OF NEEDS FOR EXTREMELY LOW-INCOME HOUSEHOLDS .................................................................................. 30 SPECIAL HOUSING NEEDS .......................................................................................................................................... 31 HOUSING STOCK CHARACTERISTICS ............................................................................................................................. 44 ESTIMATE OF HOUSING UNITS IN NEED OF REHABILITATION ............................................................................................ 50 HOUSING COST AND AFFORDABILITY ........................................................................................................................... 51 CHAPTER 3: CONSTRAINTS ANALYSIS .................................................................................................................. 58 NONGOVERNMENTAL CONSTRAINTS ........................................................................................................................... 58 GOVERNMENTAL CONSTRAINTS ................................................................................................................................. 66 CHAPTER 4: HOUSING RESOURCES ................................................................................................................... 118 LAND AND MARKET SUPPORT .................................................................................................................................. 118 ADMINISTRATIVE RESOURCES .................................................................................................................................. 118 FINANCIAL RESOURCES AND INCENTIVES .................................................................................................................... 119 AFFIRMATIVELY FURTHERING FAIR HOUSING ANALYSIS ................................................................................................. 125 CHAPTER 5: EVALUATION OF ACCOMPLISHMENTS UNDER ADOPTED HOUSING ELEMENT ................................ 155 SUMMARY OF QUANTIFIED OBJECTIVES ..................................................................................................................... 166 EFFECTIVENESS IN ADDRESSING SPECIAL HOUSING NEEDS ............................................................................................. 167 CHAPTER 6: HOUSING PLAN ............................................................................................................................. 169 ALHAMBRA HOUSING GOALS AND POLICIES ................................................................................................................ 169 IMPLEMENTATION PROGRAMS ................................................................................................................................. 174 SUMMARY OF QUANTIFIED OBJECTIVES ..................................................................................................................... 193 CHAPTER 7: SITES INVENTORY SUMMARY AND METHODS ............................................................................... 195 SUMMARY OF ALHAMBRA’S REGIONAL HOUSING NEED ................................................................................................ 195 SITE INVENTORY ORGANIZATION .............................................................................................................................. 195 ASSUMPTIONS AND METHODOLOGY ......................................................................................................................... 196 EXISTING CAPACITY ................................................................................................................................................ 205 POTENTIAL CANDIDATE CAPACITY ............................................................................................................................. 214 ADEQUACY OF SITE INVENTORY ................................................................................................................................ 223 APPENDIX A ..................................................................................................................................................... 224 CHAPTER 1: INTRODUCTION ................................................................................................................................. 4 Formatted: Default Paragraph Font, Font: Bold, Check spelling and grammar, All caps

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City of Alhambra Public Review Draft Housing Element iii COMMUNITY CONTEXT ............................................................................................................................................... 4 ROLE OF THE HOUSING ELEMENT ................................................................................................................................. 4 SUMMARY OF STATE HOUSING LEGISLATION .................................................................................................................. 4 RELATIONSHIP TO OTHER GENERAL PLAN ELEMENTS ........................................................................................................ 5 PUBLIC PARTICIPATION ............................................................................................................................................... 6 SUMMARY RECONCILIATION OF RHNA ALLOCATION AND CAPACITY .................................................................................... 7 CHAPTER 2: HOUSING NEEDS ASSESSMENT .......................................................................................................... 8 POPULATION CHARACTERISTICS .................................................................................................................................... 8 ECONOMIC CHARACTERISTICS .................................................................................................................................... 12 HOUSEHOLD CHARACTERISTICS .................................................................................................................................. 16 HOUSING PROBLEMS ............................................................................................................................................... 21 SPECIAL HOUSING NEEDS .......................................................................................................................................... 26 HOUSING STOCK CHARACTERISTICS ............................................................................................................................. 39 HOUSING COST AND AFFORDABILITY ........................................................................................................................... 45 CHAPTER 3: CONSTRAINTS ANALYSIS .................................................................................................................. 50 NONGOVERNMENTAL CONSTRAINTS ........................................................................................................................... 50 GOVERNMENTAL CONSTRAINTS ................................................................................................................................. 58 CHAPTER 4: HOUSING RESOURCES ................................................................................................................... 103 LAND AND MARKET SUPPORT .................................................................................................................................. 103 ADMINISTRATIVE RESOURCES .................................................................................................................................. 103 FINANCIAL RESOURCES AND INCENTIVES .................................................................................................................... 104 AFFIRMATIVELY FURTHERING FAIR HOUSING ANALYSIS ................................................................................................. 110 CHAPTER 5: EVALUATION OF ACCOMPLISHMENTS UNDER ADOPTED HOUSING ELEMENT ................................ 124 SUMMARY OF QUANTIFIED OBJECTIVES ..................................................................................................................... 135 CHAPTER 6: HOUSING PLAN ............................................................................................................................. 137 ALHAMBRA HOUSING GOALS AND POLICIES ................................................................................................................ 137 IMPLEMENTATION PROGRAMS ................................................................................................................................. 142 SUMMARY OF QUANTIFIED OBJECTIVES ..................................................................................................................... 157 CHAPTER 7: SITES INVENTORY SUMMARY AND METHODS ............................................................................... 158 SUMMARY OF ALHAMBRA’S REGIONAL HOUSING NEED ................................................................................................ 158 SITE INVENTORY ORGANIZATION .............................................................................................................................. 158 ASSUMPTIONS AND METHODOLOGY ......................................................................................................................... 159 EXISTING CAPACITY ................................................................................................................................................ 167 POTENTIAL CANDIDATE CAPACITY ............................................................................................................................. 173 ADEQUACY OF SITE INVENTORY ................................................................................................................................ 181 APPENDIX A ..................................................................................................................................................... 182

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City of Alhambra Public Review Draft Housing Element iv List of Acronyms
HCD California State Department of Housing and Community Development HNA Housing Needs Assessment
HUD U.S. Department of Housing and Urban Development
RHNA Regional Housing Needs Assessment
SCAG Southern California Association of Governments
CHAS Comprehensive Housing Affordability Strategy
ACS American Community Survey
AMI Area Median Income
LAHSA Los Angeles Homeless Services Authority
LA CADA Los Angeles Centers for Alcohol and Drug Abuse
CAPER Consolidated Annual Progress Report
ADU Accessory Dwelling Unit
JADU Junior Accessory Dwelling Unit
FAR Floor Area Ratio
AI Analysis of Impediments
AFFH Affirmatively Furthering Fair Housing
AAGR Average Annual Growth Rate

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City of Alhambra Public Review Draft Housing Element 5 Chapter 1: Introduction
Community Context
Alhambra remains a unique community with a small town feel in an urban setting. Often referred to as the “Gateway to the San Gabriel Valley,” it is situated on the western edge of the San Gabriel Valley. It shares a western boundary with Los Angeles and the northern terminus of the Long Beach Freeway (I -710). It is bordered by South Pasadena and San Marino to the north, San Gabriel to the east, and Monterey Park to the south. In the south, the San Bernardino freeway (I-10) traverses the city from east to west.

Housing in Alhambra originally consisted almost entirely of single-family homes. However, as the city grew, and vacant land became increasingly limited, higher-density housing was necessary to accommodate a growing population. During the 1960s, modern apar tment buildings began to replace single-family residential structures, and now nearly half of the housing stock in the city consists of multi-family housing (44 percent). Today, Alhambra is a built-out community with very little vacant land. Residential land uses account for 52 percent of the city’s current land area.

Role of the Housing Element
The 2021 Housing Element is the guiding document for Alhambra’s housing policy direction.

Grounded in the principals of the General Plan, The Housing Element ensures that the city establishes policies, procedures, and incentives in its land use planning and development activities that result in the maintenance and expansion of the housing supply to adequately accommodate households currently living and expected to l ive in Alhambra. Consistent with the General Plan, this Housing Element focuses on strong and stable residential neighborhoods and the recycling of land to higher densities in areas designated for high -density residential. With this Housing Element, the city is amplifying its commitment to provide a range of housing types that are suitable for the needs of all of its residents and provide equitable access to the resources the community has to offer.

Summary of State Housing Legislation
Background
The Housing Element of the General Plan identifies and analyzes the city’s existing and projected housing needs and contains a detailed outline and plan of the city’s goals, policies, quantified objectives, and programs for the preservation, improvement, and development of housing for a sustainable future. The Housing Element is one of the seven mandatory General Plan elements.

The Housing Element identifies ways in which housing needs of current and future residents can be met.

State Requirements
California State Housing Element Law (California Government Code Article 10.6) establishes the requirements for the Housing Element of the General Plan. Specifically, Government Code Section

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City of Alhambra Public Review Draft Housing Element 6 65588 requires that local governments review and revise the Housing Element of thei r comprehensive General Plans not less than once every eight years.

The California Legislature has determined that a primary housing goal for the State is ensuring every resident has a decent home and suitable living environment. Section 65580 of the Government Code describes the goals in detail:

A. 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.

B. The early attainment of this goal requires cooperative participation of government and the private sector in an effort to expand housing opportunities and accommodate the housing needs of Californians in all economic levels.

C. The provision of housing affordable to low- and moderate-income households requires the cooperation of all levels of the government.

D. Local and state g overnments have a responsibility to use the powers vested in them to facilitate the improvement and development of housing to make adequate provision for housing needs of all economic segments of the community.

E. The Legislature recognizes that in carrying out this responsibility, each local government also has the responsibility to consider economic, environmental, and fiscal factors ; examine community goals set forth in the general plan; and to cooperate with other local governments and the State in addressing regional housing needs.

F. Designating and maintaining a supply of land and adequate sites suitable, feasible, and available for the development of housing sufficient to meet the locality's housing need for all income levels is essential to achieving th e state's housing goals and the purposes of this article.

Relationship to Other General Plan Elements
The Alhambra General Plan was updated and adopted in 2019. It includes six chapters covering seven mandated elements. This Housing Element Update represe nts the eighth element of the Alhambra General Plan. The Housing Element is the primary blueprint for the city’s housing policies, programs, and resources, but other elements of the General plan influence housing. For example, both the Land Use and Circulation Elements set policies that impact how and where housing can be met.

Table 1. General Plan Elements and Chapters
Mandated General Plan Element Alhambra General Plan Chapter Land Use Land Use and Community Design
Covers Land Use
Circulation Mobility
Covers Circulation
Open Space Quality of Life
Covers Open Space and Environmental Justice
Conservation Resources
Covers Conservation
Safety Infrastructure and Services
Covers Conservation
Noise Health & Safety
Covers Safety, Noise, and Environmental Justice

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City of Alhambra Public Review Draft Housing Element 7 Environmental Justice Addressed in Health and Safety Section Housing N/A

The programs and policies in the Housing Element are directly related to , and build upon, the General Plan. All elements of the General Plan must maintain internal consistency. In the adoption process, the city will identify policies in other General Plan elements that require amendment to maintain internal consistency. In the future, as other elements of the General Plan are updat ed and revised, the Housing Element will also be reviewed to ensure General Plan consistency is maintained.

Public Participation
Public engagement is a critical part of the City of Alhambra’s 6th Cycle Housing Element Update.

Under State law, local govern ments are directed to be diligent in soliciting input from as many segments of the community as possible. Beyond requirements, this step is essential in the information gathering process so that the city’s programs and polices reflect the values of the community, within the context of city’s planning targets.

Early on, community engagement focused on disseminating information about the project. This included advertising the project, discussing the schedule, discussing what the project entails, and a large educational component. As the Housing Element is regulated by the State, it was important to educate the public about the lay of the land, rules and regulations the city is bound to, and consequences of failing to secure a certified Housing Element on time. Given that housing development can be a contentious topic, public education about the RHNA (how it is calculated, and the options available to the city to accommodate it) are important.

The latter half of the Housing Element Update focused on soliciting information from the public to ensure that draft products met their needs, goals, and desires for housing in the community— within the bounds of the Housing Element regulations set forth by the State.

The following community engagement tools were used for both information dissemination and solicitation.
§ A standalone project website was developed to post information about the project, updates, calendar dates, surveys, and previous presentation materials. Community members could sign up for the project distribution list and solicit comments to the project mailbox.
§ Project fliers were created for printing and posting at community-based organizations and at City Hall to build exposure for community members with challenging internet access.
§ Project information was distributed to curated lists of community organizations and existing media including:
§ The city’s “Alhambra Announcements” Newsletter and the Alhambra Chamber of Commerce’s “Around Alhambra” Newsletter.
§ Publication in the city Parks and Leisure Guide.
§ An email distribution list established for the city’s parallel zoning code update.

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City of Alhambra Public Review Draft Housing Element 8 § Over the course of the project the city’s marketing team promoted over 100 mentions on the city’s Social Media platforms.
§ Two public study sessions in Fall 2020 with the City Council and Planning Commission. § Two community workshops focusing on housing needs and suitability of housing policy alternatives.
§ An interactive live survey and online survey posted to the project website, offered in Spanish, English, and Traditional Chinese.
§ Five community town hall meetings in April 2021, one in each Council District and sponsored by the representative Councilor.
§ Planning Commission and City Council study sessions in May 2021, August 2021 and September 2021, respectively.

Impact of COVID-19
While every effort was made to ensure that the Housing Element Update process was inclusive and open, COVID -19 and the prohibition of in- person gatherings nonetheless impacted public participation. Relying on a mostly digital method of public engagement required the following enhancements to traditional public participation:
§ Expanded time between notice periods and meetings, as well as multiple notices. § Clearly crafted instructions for accessing call-in and videoconferencing links. § Call-in options for all videoconferences to assist residents without computer access. § Allowing public comment through email or video conferencing chat functions. § Recording and promptly posting meeting materials so they are available to the public Summary of Comments
The city received comments in both oral and written formats, in addition to responses to an online survey that was made available in English, Spanish, and Traditional Chinese. An initial set of comments were collected and received prior to drafting the housing element. These comments supported the initial development of the housing element. An additional set of comments were also received during the 60-day public review period. A summary of major themes from comments received is provided below:
§ While most residents expressed that they were at least somewhat satisfied with their housing situati on, most also reported affordability as a top concern. Residents are concerned about increases in home prices and rents. They expressed a desire to located more affordable housing near reliable transit.
§ The city has had a parallel project to explore the future of the East Main Corridor. This topic dominated many of the conversations throughout the update process. Alhambra contrasting community perspectives about East Main. One cont ingent does not want to allow housing at all on East Main . This was driven by preference for an “Old Town Alhambra” commercial district on East Main Corridor . Another contingent discussed that the East Main area is among the highest resource areas of Alham bra and not allowing housing would be exclusionary.

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City of Alhambra Public Review Draft Housing Element 9 § Concerns that development projects that are allowed and appropriate are being halted. § Residents expressed concerns over scale and density, specifically that large projects threatened the character of the community and could block territorial and mountain views.

This echoed a call for targeted historic preservation.
§ Enthusiasm for the City to develop a plan to to reflect a mixture of housing types, affordability, and diversity of residents as reflective of the region. This paralleled with survey results that supported a broad range of housing types. Middle housing types and mid-rise housing showed the strongest support. There was a general aversion to high-rise development.
§ Residents expressed a desire to locate new capacity broadly across the city. V alley Boulevard was often referenced as an underutilized asset for potential housing. Other areas identified for upzoning/rezoning included Garfield Avenue, East Main Street, and the Industrial Zones in west Alhambra.
§ Residents showed strong support for policies to support Accessory Dwelling Units (ADUs).

This was seen as the best alternative to promote additional capacity in existing low-density areas.
§ Residents and commissioners both expressed various concerns over the potential impacts of SB9 and SB10 on the R-1 zone.
§ Commenters expressed some concerns about the impacts of increased population on city services, specifically systemwide water capacity and traffic. § Support to leverage new legislation making it easier to consider housing development and capacity on church properties.
§ Questions of the appr opriateness to con sider broad rent stabilization and just cause eviction protections as a program.
§ Recommendations that the city explore the viability of an affordable housing overlay zone in targeted parts of the city.
§ Concerns over broad redevelopment impacts on displacement. § Finding in survey results that housing discrimination is still broadly present in Alhambra, and many residents that experience or witnessed housing discrimination do not know how to access resources and support.
§ Concerns that infill development that does not require additional parking will result into overflow parking on existing city streets in neighborhoods. § Support for the city to continue to look at its land assets as a resource to deliver sites for housing.
§ Support for a mix of rezoning and upzoning strategies across the city to create capacity necessary to accommodate regional housing need.
§ General support for the city’s existing inclusionary housing program, but mixed concerns over the appropriateness of set asides, calibration of in-lieu fees, and need for offsetting incentives.
§ Recommendations to explore a more comprehensive range of funding sources linked to development.

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City of Alhambra Public Review Draft Housing Element 10 § Recommendations that the city include a full mid -cycle Housing Element review to measure the effectiveness of programs and policies.

Integration of Comments into The Housing Element
Comments received during the public outreach process were used to refine the city’s understanding of housing needs, potential for housing problems, and to formulate and refine programs in the Housing Element. Key linkages were organized and communicated back to the public at a public workshop prior to the releas e of the Public Review Draft (see figure 1) .

Comments received during the public review period were collected through the review period.

The city organized these comments into a matrix representing key themes and relevant portions of the Housing Element. The city held a work session with its consultant team to determine actions and revisions where appropriate. General comments that were more questions and clarifications were responded to individually. Public review draft revisions were made prior to submitting an review draft to HCD. A summary of key linkages is included below.

Figure 1. Summary of Community Input and Housing Plan Linkage Source: Alhambra Community Workshop #2

§ Program 16 includes r ezoning and upzoning strategies that considered preferences for broad distribution throughout the city. Every zone with the exception of the R-1 zone saw a change in density or housing allowance.
§ A compromise between contrasting positions on East Main. The Housing Element includes rezoning a portion of East Main from Chapel to Granada at densities suitable for lower income housing. Housing was not allowed on properties east of Granada. Based on the parcellation of this segment and the character of existing buildings, this was determined the most appropriate segment for an “Old Town Alhambra” district. § Program 23 includes a comprehensive ADU program designed to remove barriers to ADU development, provided pre-approved plans, and incentives for ADU production. § Program 5 includes actions to monitor the effectiveness of the City’s inclusionary housing policy and adjust policies if ineffective.
§ Program 31 directs the city to conduct a full mid-cycle review.

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City of Alhambra Public Review Draft Housing Element 11 § Program 20 directs the city to implement ada ptive reuse standards to assist in the conversion of underutilized commercial and industrial buildings for housing. § Programs for the city to play an active role in site assembly and disposition of city owned land. The city will specifically look at the Alhambra Golf Course when its existing operating lease nears expiration.
§ Programs to prevent displacement through unit replacement. § Inclusion in programs to identify new affordable housing funding sources strategies linked to development (i.e. linkage fees, transfer tax).
§ A program to study the feasibility of development under proposed densities and development standards and the potential impacts of SB9 and SB10 on housing production. § A commitment to stud y the feasibility and appropriateness of an affordable housing overlay zone.
§ A community education program to maintain an on -going dialogue with the community on housing issue.

Additional data points and clarifications were considered throughout the Housing Element based on comments and feedback from the community, Planning Commission, and City Council.

Summary Reconciliation of RHNA Allocation and Capacity
The table below summarizes Alhambra, RHNA allocation by income category and capacity identified by type. Alhambra’s adequate sites inventory has capacity for 8,000 units, a 17% buffer over it’s RHNA.

Table 2: Site Capacity by Source and Income Level. RHNA Surplus/Shortfall Site/Capacity Type
Income Category
Ex./Very Low Income Low Income Moderate
Income
Above Mod.

Income Total
Proposed Projects 94 10655 3399 693907 9261,155
Specific Plan 0 24 14 19 57
Vacant 0 0 0 59 59
Existing Sites A 52 156 111 239 558
ADUs 141 267 14 178 600
New Sites 1,543 831 954 2,243 5,571
Total Sites 1,830 1,38433 1,12692 3,431645 78,771000
2021-2029 RHNA 1,7741 1,036 1,079 2,936 6,825
Surplus/Shortfall 56 348297 47113 495709 9461,175
A Includes capacity from increases in allowed density on existing sites

1 The City estimates 50% of the very low RHNA households would qualify as extremely low income (887 ELI households)
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City of Alhambra Public Review Draft Housing Element 12 Chapter 2: Housing Needs Assessment
This Housing Needs Assessment (HNA) is a required section of the Alhambra Updated Housing Element. This section of the Housing Element included data on the characteristics of the city’s population, economy, households, housing challenges, special needs housing, and housing stock.

Each of these components is presented in a regional context, and, where relevant, in the context of other adjacent communities. This assessment serves as the basis for identifying the appropriate goals, policies, and programs for Alhambra to implement during the 2021-2029 Housing Element cycle.

Data in this analysis are derived from a variety of sources. Where appropriate, the HNA leverages the data package produced by SCAG and pre-certified by HCD. However, additional analysis was required to build a more complete picture of housing needs in Alhambra. Additional data sources are cited throughout the document and include data from the U.S. Census Bureau’s Am erican Community Survey (ACS), the U.S. Department of Housing and Urban Development (HUD), data from the City of Alhambra, and third-party data sources.

Population Characteristics
A community’s population characteristics affect the amount and type of housing needed. Factors such as population growth, age, income, and employment trends influence the type of housing needed and households’ ability to afford housing. This section evaluates the various population characteristics that affect Alhambra’s housing needs.

Population Growth
According to the California Department of Finance , the population in Alhambra has steadily increased over time. In 2000, Alhambra had a population of 85,757. Unlike the SCAG region, the Great Recession had an impact on Alhambra’s population , reducing its population to 83,089 in 2010, while population in t he rest of the region grew. Since then population in Alhambra has steadily increased to 86,792 in 2020. Over the 2000 to 2020 period, Alhambra had an annual growth rate of 0.1%, a much lower rate compared to 0.7% for the region.

Figure 2. Population Growth, Alhambra and SAG Region, 2000-2020 Source: SCAG Analysis of California Department of Finance E-5 Population and Housing Units Estimates, Pre-certified Local Housing Data
Jurisdiction 2000 2010 2020
2000-2020 Change Annual
Growth
Rate Number Percent
Alhambra 85,757 83,089 86,792 1,035 1.2% 0.1%
SCAG 16,516,703 18,051,534 19,021,787 2,505,084 15% 0.7% Alhambra share of
SCAG Region 0.52% 0.46% 0.46%
Population Forecast
While population growth in Alhambra is expected to accelerate over the next 15 years, it is expected to remain well below the regional average. SCAG’s regional forecast estimates that

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City of Alhambra Public Review Draft Housing Element 13 Alhambra will add 5,400 residents over the next 15 years, an annual average increase of 0.4%.

The SCAG region is expected to grow twice that rate, at 0.8%, between 2020 and 2035.

Regional growth forecasting is completed by SCAG for the purposes of Regional Transportation Planning (RTP). The Connect SoCal RTP forecast was adopted in September 2020. The population projection covers the period from 2016 to 2045. Over this period, the City of Alhambra is expected to add 4,600 new residents, growing at an average annual rate of 0.18 percent. This rate is far lower than the regional forecast rate of 0.62 percent in the SCAG region. Among other San Gabriel Valley cities, Alhambra is projected by SCAG to have the lowest average annual growth rate (AAGR) in the region, trailing Glendale (0.22%), Monterey Park (0.22%), Pasadena (0.33%), San Gabriel (0.41%), and El Monte (0.64%).

Figure 3. Population Forecast, City of Alhambra and SCAG Region, 2016-2045 Source: SCAG Connect SoCal RTP Growth Forecast (2020)
Jurisdiction 2016 2045
2016-2045 Change
Number Percent
Alhambra 86,600 91,200 4,600 0.18%
SCAG 18,832,000 22,504,000 3,672,000 0.62%
Age Characteristics
The age characteristics of a community indicate current needs and future trends for housing.

Because different age groups have very different housing needs, housing demand correlates to the age of residents. For example , young adult households may choose to occupy apartments, condominiums, and small single-family homes because of affordability, location, and household size/presence of children. Middle-aged adults may prefer larger homes in which to raise families, while seniors may prefer smaller units that have lower costs, less maintenance, and are more proximate to services.

Figure 4 and Figure 5 show the age characteristics of Alhambra residents in 2018. Alhambra’s median age is 41.8 in 2018. Compared to the SCAG region, Alhambra’s residents tend to be older, with a larger population proportion being between the age of 20 to 64 years old. In 2018, Alhambra has a larger population proportion of younger residents (those age 19 years and under) than seniors (those 65 years and older). However, Alhambra’s senior population (those 65 years and older) is larger than the SCAG region’s share. This may translate into greater need for senior housing or multi-generational housing solutions like accessory dwelling units.

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City of Alhambra Public Review Draft Housing Element 14 Figure 4. Age Distribution Totals, City of Alhambra and SCAG Region, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Total
Alhambra SCAG
Number Percent Number Percent
Median Age 41.8 - - -
19 and Under 16,153 19% 4,903,838 26%
20 to 65 54,499 64% 11,457,825 61%
65 and Older 14,322 17% 2,447,598 13%

Figure 5. Age Distribution, City of Alhambra and SCAG Region, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Age Group
Alhambra SCAG
Number Percent Number Percent
Under 5 4,306 5% 1,193,126 6%
5 to 9 3,804 4% 1,193,271 6%
10 to 14 4,019 5% 1,244,937 7%
15 to 19 4,024 5% 1,272,504 7%
20 to 24 5,806 7% 1,370,418 7%
25 to 29 7,423 9% 1,487,672 8%
30 to 34 6,461 8% 1,361,873 7%
35 to 39 5,863 7% 1,267,296 7%
40 to 44 5,748 7% 1,241,074 7%
45 to 49 5,883 7% 1,274,771 7%
50 to 54 6,295 7% 1,257,723 7%
55 to 59 6,230 7% 1,182,327 6%
60 to 64 4,790 6% 1,014,671 5%
65 and older 14,322 17% 2,447,598 13%
Race and Ethnic Composition
Cultural preferences and needs for housing vary by racial and ethnic type. Alhambra remains a minority majority community where over 90% of the population is non-white. Alhambra has strong Asian and Hispanic community composition. The nature and extent of a community’s housing needs are, to a large extent, determined by the racial/ethnic composition of its

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City of Alhambra Public Review Draft Housing Element 15 population. The size and type of housing preferred, and the neighborhood desired, often vary by a person or household’s racial or ethnic background. Research has shown that some cultures (e.g.

Hispanic and Asian) tend to maintain extended families within a single household.2 This can lead to overcrowding or an increased demand for larger housing units.

Figure 6 shows that, according to the Census, more than half of Alhambra’s population identified as non-Hispanic Asian in 2019. This is 3.5 times the Los Angeles County average . An additional 31% of the population identifies as Hispanic or Latino of any race. The foreign -born population fell slightly over the last five years from 42,310 residents in 2013, to 41,872 in 2018.

Figure 6. Population by Race and Ethnicity, City of Alhambra and SCAG Region, 2019 Source: American Community Survey 2019 1-year estimates Race/ Ethnicity
Alhambra SCAG
Number Percent Number Percent
Hispanic/ Latino of
any race 26,298 31% 8,905,824 47%
Non-Hispanic White 7,110 8% 5,681,360 30%
Non-Hispanic
Black/African
American
2,247 3% 1,168,071 6%
Non-Hispanic
American Indian 383 0% 51,703 0%
Non-Hispanic Asian 45,165 54% 2,512,336 13%
Non-Hispanic
Hawaiian/ Pacific
islander
- 0% 47,749 0%
Non-Hispanic Other 959 1% 58,749 0%
Non-Hispanic Two or
More Races 1,570 2% 466,859 2%
Total 83,732 100% 18,892,651 100%
Areas of Minority Concentration
A minority concentration is defined as Census block group where the proportion of non -White residents is higher than the proportion of White residents. Non-White Asians, however, comprise the majority racial/ethnic group in Alhambra and are more distribute d throughout the city compared to other racial/ethnic groups. Figure 7 shows that there are still some concentrations of Asian non -white residents, more specifically near the southeast corner of Alhambra.

Concentrations of Hispanic/Latino residents can be found in the western portion of the city. No concentration of White or Black/African American residents exists in the city.

2 Pew Research Center. Second-Generation Americans: A Portrait of the Adult Children of Immigrants, February 7, 2013, Appendix 8, http://www.pewsocialtrends.org/2013/02/07/appendix-1-detailed-demographic-tables/.

National Association of Hispanic Real Estate Professionals. 2017 State of Hispanic Homeownership Report, 2017.

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City of Alhambra Public Review Draft Housing Element 16 Figure 7. Concentrations of Asian, Hispanic/ Latino, and White Population Groups, 2018 Source: American Community Survey 2014-2018 5-year estimates Note: NH = Non-Hispanic

Economic Characteristics
Employment by Industry
Labor and employment characteristics have a direct impact upon current and future housing needs within Alhambra. Incomes associated with different jobs, as well as the number of workers in a household, determine the type and size of housing a household can afford. In some cases, the types of jobs themselves can affect housing needs and demand (such as in communities with military installations, college campuses, and large amounts of seasonal agriculture). Employment growth typically leads to strong housing demand, while the reverse is true when employment contracts.

According to the Census, a total of 41,917 Alhambra residents were employed during the 2014- 2018 period. As shown in Figure 8, most of Alhambra residents were employed in three industries:
the Educational Services and Health Care and Social Assistance industry category; the Professional, Scientific, and Management, and Administrative, and Waste Management Services industry category; and the Arts, Entertainment, and Recreation, and Accommodation and Food Services industry category. Generally, managerial/professional positions earn higher incomes than other occupation categories. In 2018, the Information and Public Administration industries had the highest average wage of over $60,000 annually.

Figure 8 uses a location quotient to quantify and compare concentrations of industries in a particular area and is useful to underst anding an area’s economic strengths and weaknesses. A location quotient typically compares an area’s concentration to a larger region, in this case, to the SCAG region. A location quotient greater than 1.0 indicates an area has a higher concentration of a specialized industry. Alhambra has a location quotient exceeding 1.0 in four industries: Public

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City of Alhambra Public Review Draft Housing Element 17 Administration, Educational Services and Health Care and Social Assistance; Finance, Insurance, Real Estate, and Rental and Leasing ; and Other Services, Except Public Administration. These industries also offer some of the highest paying jobs within Alhambra.

Figure 8. Employment by Industry, City of Alhambra, 2018 Source: American Community Survey 2014-2018 5-year estimates Note: Location quotient compares Alhambra’s employment concentration relative to the SCAG region.

Industry Number Percent Location
Quotient Average Wage
Agriculture, Forestry, Fishing and Hunting,
and Mining 110 0% 0.28 $22,500
Construction 1,768 4% 0.67 $41,935
Manufacturing 3,521 8% 0.85 $44,436
Wholesale Trade 1,395 3% 1.00 $39,591
Retail Trade 3,892 9% 0.84 $35,041
Transportation, Warehousing, and Utilities 2,364 6% 0.98 $52,856 Information 1,207 3% 0.89 $62,656
Finance and Insurance, and Real Estate,
and Rental and Leasing 2,951 7% 1.11 $50,488
Professional, Scientific, and Management,
and Administrative, and Waste
Management Services
5,123 12% 0.98 $59,853
Educational Services and Health Care and
Social Assistance 9,975 24% 1.16 $51,048
Arts, Entertainment, and Recreation, and
Accommodation and Food Services 5,110 12% 1.11 $27,476
Other Services, Except Public
Administration 2,582 6% 1.09 $29,452
Public Administration 1,919 5% 1.26 $61,975
Total Employment 41,917 100% -
Employment by Occupation
By understanding the industries in which the residents of Alhambra work, it is also possible to analyze the types of jobs they hold. The most prevalent occupational category in Alhambra is Management, in which 16,387 (39% of total) employees work. The second-most prevalent type of work is in Sales, which employs 10,815 (26% of total) in Alhambra.

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City of Alhambra Public Review Draft Housing Element 18 Figure 9. Employment by Occupation, City of Alhambra, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Occupation
Alhambra
Number Percent Location
Quotient
Management, Business, Science, and Arts 16,387 39% 1.08 Service 7,862 19% 1.00
Sales and Office 10,815 26% 1.13
Natural Resources, Construction, and Maintenance 2,394 6% 0.69 Production, Transportation, and Material Moving 4,459 11% 0.77 Commute Patterns
Alhambra has a jobs- housing imbalance. Only about 12% of Alhambra residents (2,922) work and live in the city. This imbalance of jobs to housing impacts quality of life including how far Alhambra residents have to travel for work, increasing transportation costs, and reducing individual productivity. In general, a good balance of jobs to housing would occur where the jobs available in a community match the labor force skills, and where housing is available at prices, sizes, and locations suited to workers who wish to live in the area.

Figure 10. Job Inflow and Outflow, City of Alhambra, 2018 Source: U.S. Census Bureau, OnTheMap, Longitudinal Employer-Household Dynamics (LEHD), 2018

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City of Alhambra Public Review Draft Housing Element 19 As of 2018, there were an estimated 24,501 full - or part-time jobs in Alhambra. Of these, the most common jobs were in the following industries: Health Care and Social Assistance (20%), Retail (19%), and Accommodations and Food Services (16%). As shown in Figure 10, the vast majority (88%) of jobs in Alhambra are filled by s omeone who lives outside of the city.

Additionally, the majority of residents living in Alhambra work outside the city.

Figure 11 shows the concentration of employment in Alhambra. Jobs are concentrated in the industrial/manufacturing zone, central business district, and along major arterials like Valley Boulevard and Main Street.

Figure 11. Employment Density, City of Alhambra, 2018
Source: U.S. Census Bureau, OnTheMap, Longitudinal Employer-Household Dynamics (LEHD), 2018

Means of Transportation to Work
The City of Alhambra has a high share of its population located in regionally -designated “High Quality Transit Areas.” Because this is one of the criteria for SCAG’s regional housing needs allocation (RHNA), it impacts Alhambra’s share of future housing needs in the region. Figure 12 shows that in 2018, about 81% of Alhambra’s residents drove alone to work, about five percent higher than the region- wide average. Approximately 8% of Alhambra residents carpooled, two percent biked or wa lked, and one percent used public transportation. Approximately 6% of Alhambra residents worked from home. Compared to the SCAG region, Alhambra residents use alternative modes of transportation such as carpool, transit, bike, and walking far less to get to work.

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City of Alhambra Public Review Draft Housing Element 20 Figure 12. Means of Transportation to Work, City of Alhambra and SCAG Region, 2014 and 2018 Source: American Community Survey 2010-2014 and 2014-2018 5-year estimates

Household Characteristics
The characteristics of a community’s households impa ct the type of housing needed in that community. Household type, income levels, the presence of special needs populations, and other household characteristics are all factors that affect the housing needs of a community. This section discusses the househol d characteristics affecting the housing needs of Alhambra residents.

Household Type and Size
A household is defined by the U.S. Census Bureau as all persons who occupy a housing unit, which may include families, single persons, and unrelated persons shari ng a housing unit (such as roommates). Persons residing in group quarters such as dormitories or retirement homes are not considered households. The characteristics of a community’s households serve as important indicators of the type and size of housing n eeded in the city. For instance, single -person households often occupy smaller apartment units or condominiums, such as studios, one - bedroom units, or accessory dwelling units (ADUs). Married couples often prefer larger single - family homes, particularly if they have children. This underscores the need to provide a diversity of housing opportunities to provide households of different ages and types the opportunity to live in Alhambra.

Figure 13 shows the type of households in Alhambra. In 2018, there were 29,427 households in Alhambra. Alhambra continues to be a stable, family -oriented community, with 69% of all households identifying themselves as families. Average household size has remained stable over time at 2.86 persons. Over the 2010 and 2018 period, t he number of families has decreased slightly, while the number non -family households have increased. Non -family households are

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City of Alhambra Public Review Draft Housing Element 21 generally characterized as single households or households with more than one person living together (often roommates) and unrelated to each other.

Figure 13. Household Type and Size, City of Alhambra, 2010 and 2018 Source: American Community Survey 2014-2018 5-year estimates, Decennial Census 2010 Household Types
2010 2018 Change
(2010 to 2018)
Number Percent Number Percent Number Percent
Families 20,774 72% 20,416 69% -358 -2%
With Children 8,414 29% 7,429 25% -985 -12%
With no Children 12,360 43% 12,987 44% 627 5%
Non-Families 8,030 28% 9,011 31% 981 12%
Singles 6,457 22% 6,912 23% 455 7%
Other 1,573 5% 2099 7% 526 33%
Total Households 28,804 100% 29,427 100% 623 2%
Average Household Size 2.85 - 2.86 - - -
Multigenerational Households
Nationally, a growing family typology is the multigenerational household.3 Estimates from the Pew Research Center suggest this market segment grew by 21.6 million households between 2000 and 2016.4 The same research found Asian and Hispanic/Latino households to be 35% to 45% more likely than average to be multigenerational. In Alhambra, the combined Asian and Hispanic/Latino share of the population is 25 percentage points higher than the SCAG average.

To approximate multigenerational households in Alhambra, we evaluated two metrics from the American Community Survey:
§ The share of households with at least one grandparent and grandchild (5.2%).5 § The share of the population in households with non-spouse, non-child relatives (13.4%).6 The factors influencing growth in multigenerational households are social, cultural, economic, and demographic. The primary drivers include:

3 Defined by the Pew Research Center as households that include at least two adult generations, or grandparents and grandchildren younger than 25.
4 Pew Research Center (2018). Multigenerational Household Analysis. Retrieved from:
https://www.pewresearch.org/fact-tank/2018/04/05/a-record-64-million-americans-live-in-multigenerational- households/
5 Source: U.S. Census Bureau, 2015–2019 ACS 5-year estimate, Table S1002. 6 Source: U.S. Census Bureau, 2015-2019 ACS 5-year estimate, Table DP02.

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City of Alhambra Public Review Draft Housing Element 22 § Slower Household Formation: Young people are delaying marriage and continuing to live with supportive parents well into their 20s. This is driven in part by preference but also out of economic necessity due to rising housing costs and/or underemployment. § Immigration: As mentioned above, Asian and Hispanic/Latino households have a higher likelihood of living in multigenerational households. Some of this is cultural, but economic factors also contribute.
§ Ability of Kin to Support: In many markets , the Baby Boomers are more financially stable than previous generations and have a greater ability to support aging parents in addition to their own children. Further, an increasing number of Americans suffer from chronic illness and/or disabilities and need caregiving —much of which is provided by family members.
§ Economic Conditions: Housing costs are increasing at a rate well above incomes.

Economically-challenged households , or those on fixed -incomes, are formin g multi - generational households out of necessity.

Households by Tenure
Household tenure is an important component of housing needs, as it helps to determine whether future housing should be built as ownership units or rental units. In the 2012 -2016 period, only about 40% of all households in the city owned their homes, while 60% were renters. This is far below the national average of roughly 63.7% homeownership in 2016, and also below Los Angeles County’s homeownership rate of about 48.4% in 2016. In the U.S., homeownership remains one of the primary ways that households are able to build equity and generate wealth. However, for many households, the high costs of housing can be a barrier to becoming homeowners.

Household Income
The ability of a household to acquire adequate housing is related to household income, whether earned or from other sources. Household income is oftentimes the crucial factor in evaluating the size and type of housing available for any given household. Household income can vary grea tly across many demographic factors including race, gender, and household type. While higher - income households have more discretionary income to spend on housing, low - and moderate- income households often face limited choices in the housing they can afford.

In 2018, the median household income in Alhambra was $57,117, lower than the Los Angeles County median of $64,251. Figure 14 shows that, overall, the income distribution in Alhambra closely mirrors that of Los Angeles County. Compared to the County, Alha mbra has more households that make less than $49,999 annually.

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City of Alhambra Public Review Draft Housing Element 23 Figure 14. Household Income Distribution, City of Alhambra and Los Angeles County, 2018 Source: American Community Survey 2014-2018 5-year estimates Household Income
Income Distribution
Alhambra Los Angeles County
Less than $25,000 23% 20%
$25,000 to $49,999 21% 20%
$50,000 to $74,999 16% 16%
$75,000 to $99,999 11% 12%
$100,000 to $149,999 17% 15%
$150,000 or more 12% 17%
Median $57,117 $64,251

Figure 15 below shows the median household income of several nearby cities compared to Alhambra’s median household income for 2018. The median household income in Alhambra is in- line with neighboring cities —slightly higher than El Monte, in -line with Monterey Park and San Gabriel, and lower than Glendale, Pasadena, and the SCAG region as a whole ($67,329).

Figure 15. Median Household Incomes in Peer Cities, 2014-2018.

Source: American Community Survey 2014-2018 5-year estimates, American Community Survey PUMS 2014-2018 5-year estimates (for the SCAG median income)

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City of Alhambra Public Review Draft Housing Element 24 Area Median Income
To facilitate the analysis of income distribution among communities, each year the U.S.

Department of Housing and Urban Development (HUD) calculates affordability and income limits for metro areas and counties across the country, based on Census data. These data are calculated as a percentage of the Area Median Income (AMI) and then adjusted for household size. California HCD further groups these households into the categories shown in Figure 16 below.

The AMI shown here comes directly from HCD and HUD and differs from the median household incomes discussed in Figure 14 and Figure 15. The differences include the year analyzed, the geography analyzed, and the household type analyzed.
• Median household income (in Figure 14 and Figure 15) is calculated using Census data, the most recent of which is 2018. It is calculated for each city specifically, and is calculated as the median of all households (of all types and sizes). • Area median income (in Figure 16) is calculated by HUD each year; the most recent data comes from 2020. It is calculated for Los Angeles County as one geography, and is calculated for family households (where all household members are re lated). The standard 100% AMI for LA County is based on a family of four. HUD and HCD calculate percentages of this median, and also make adjustments based on different family sizes (not shown).

Figure 16. HCD Income Category, Description, and Limit, 2020 Source: California Department of Housing and Community Development (HCD) AMI
Income
Category
Description Income Limit
(2020)
Los Angeles County—100% Area Median Income (AMI) $77,300 Extremely
Low-
Income
Gross family income equal to 30% or less of AMI Less than $23,190
Very Low-
Income Gross family income between 30 and 50% of AMI $23,190 to $38,650
Low-
Income Gross family income between 50 and 80% of AMI $38,650 to $61,840
Moderate-
Income Gross family income between 80 and 120% of AMI $61,840 to $92,760
Above
Moderate-
Income
Gross family income over 120% of AMI Greater than
$92,760

Combined, the extremely low, very low, and low-income groups are referred to as “lower income.” The Census ACS does not collect information on the number of households belonging to each of the income categories described above. However, the Comprehensive Housing Affordability Strategy (CHAS) dataset, which is developed by the U.S. Census Bureau for HUD, does provide this information. This dataset provides detailed information on housing needs by income level for different types of households in Alhambra, as well as information relating to common problems relating to the condition of the housing stock (detailed in the next section).

Figure 17 shows the distribution of Alhambra households by AMI in 2016. In 2016, the majority of Alhambra households earned low -incomes, while 45% of Alhambra households earned moderate or above -moderate incomes. Like most communities across the country, renter

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City of Alhambra Public Review Draft Housing Element 25 households in Alhambra have lower incomes than do homeowners. This is caused by a number of factors, largely relating to the ability to save up for a down -payment and get approved for a mortgage—two prerequisites for homeownership. But the high costs of housing (both rental housing and homeownership housing) in Southern California are also a big factor in renters’ inability to make the switch.

Figure 17. Income Distribution by Tenure, 2012-2016
Source: CHAS based on 2013-2017 American Community Survey 5-year estimates Note: This figure uses the same underlying data categories as in Figure 16, but the years analyzed differ.

AMI Income Category
Total Households Owner Households Renter Households
Number Distribution Number Distribution Number Distribution Extremely Low-Income
(30% or less) 6,135 21% 1,590 14% 4,545 26%
Very Low-Income
(31% to 50%) 4,540 16% 1,200 10% 3,340 19%
Low-Income
(51% to 80%) 5,430 19% 1,900 16% 3,530 20%
Moderate and Above
Moderate (over 80%) 13,070 45% 7,080 60% 5,990 35%
Total 29,175 100% 11,770 100% 17,405 100%
Housing Problems
The CHAS dataset, developed by the Census for HUD, provides detailed information on housing needs by income level for different types of households in Alhambra, as well as information relating to common problems relating to the condition of a city’s housing stock. Housing problems considered by CHAS include:
§ Units with physical defects (lacking complete kitchen or bathroom). § Overcrowded conditions (housing units with more than one person per room). § Housing cost burden, including utilities, exceeding 30% of gross income; or § Severe housing cost burden, including utilities, exceeding 50% of gross income.

The latest CHAS data are based on 2013-2017 ACS data, as shown in

Figure 18. The types of problems vary according to household income, type, and tenure. Some key findings include:
§ Renter households experience a higher rate of housing problems, 60% compared to 37% of owner households that experienced housing problems. § Of all households who earned less than 80% of AMI, renters are more likely to experience at least one housing problem (53%) as compared to owner households (24%).
§ Overall, 51% of all households in Alhambra reported at least one housing problem.

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City of Alhambra Public Review Draft Housing Element 26

Figure 18. Renter Households with Housing Problems, City of Alhambra Source: CHAS based on 2013-2017 American Community Survey 5-year estimates AMI Income Category
Renter Households with No
Housing Problems
Renter Households with At
Least One Housing Problem Renter Total
Number Percent Number Percent
Extremely Low-Income
(30% or less) 415 2% 3,675 21% 4,545*
Very Low-Income
(31% to 50%) 130 1% 3,210 18% 3,340
Low-Income
(51% to 80%) 1,195 7% 2,335 13% 3,530
Moderate and Above
Moderate (over 80%) 4,680 27% 1,305 7% 5,985
Renter Totals 6,420 37% 10,530 60% 17,405*
Notes: * Total includes 455 households where cost burden data is unavailable, and the household has no other housing problems. HUD programs are available only to households with incomes at or below 80% AMI. Therefore, the CHAS data groups all households above that income threshold (both moderate and above moderate income) into one income group.

Figure 19. Owner Households with Housing Problems, City of Alhambra Source: CHAS based on 2013-2017 American Community Survey 5-year estimates AMI Income Category
Owner Households with No
Housing Problems
Owner Households with at
Least One Housing Problem Total
Number Percent Number Percent
Extremely Low-Income
(30% or less) 215 2% 1,225 11% 1,590*
Very Low-Income
(31% to 50%) 495 4% 700 6% 1,195
Low-Income
(51% to 80%) 980 8% 920 8% 1,900
Moderate and Above
Moderate (over 80%) 5,640 48% 1,440 12% 7,080
Owner Totals 7,335 62% 4,285 37% 11,770*
Notes: * Total includes 150 households where cost burden data is unavailable, and the household has no other housing problems. HUD programs are available only to households with incomes at or below 80% AMI. Therefore, the CHAS data groups all households above that income threshold (both moderate and above moderate income) into one income group.

Overcrowding
Overcrowding occurs when the relatively high cost of housing either forces a household to double- up with another household or live in a smaller housing unit in order to be able to afford food and other basic needs. An overcrowded household is defined by the Census as one with more than one person per room, excluding bathrooms, kitchens, hallways, and porches. Severely overcrowded households are households wit h more than 1.5 persons per room. Overcrowding can indicate that a community does not have an adequate supply of affordable housing, especially for larger families.

Figure 20 shows the prevalence of overcrowding in Alhambra by tenure. According to the Census, approximately 12% of all households in Alhambra were overcrowded (3,505 households). The

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City of Alhambra Public Review Draft Housing Element 27 incidence of overcrowding was slightly higher in Alhambra than in the SCAG region (10%).

Additionally, the incidence of overcrowding is higher for renter househol ds (16%) than owner households (6%) in Alhambra.

Figure 20. Overcrowding by Tenure, City of Alhambra and SCAG Region, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data

Cost Burden
State and federal standards specify that households spending more than 30% of gross annual income on housing experience a housing cost burden. Housing cost burdens occur when housing costs increase faster than household income. When a household spends more than 30% of its income on housing costs, it has less disposable income for other necessities, including health care, food, and clothing. In the event of unexpected circumstances such as the loss of employment or serious health problems, lower -income households with a burdensome housing cost are more likely to become homeless or be forced to double- up with other households.

Homeowners with a housing cost burden have the option of selling their homes and becom ing renters. Renters, on the other hand, are vulnerable and subject to constant changes in the housing market.

Overall, housing cost burden in Alhambra was most prevalent among extremely low-income households (85%), while very low-income households also experienced a high rate of cost burden (79%).

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City of Alhambra Public Review Draft Housing Element 28 Figure 21. Cost Burden by Income, City of Alhambra
Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Note: HAMFI connotes Household Area Median Family Income and MFI connotes Median Family Income

While the previous figure breaks down cost burden by area-relative income, the 2018 American Community Survey also allows for the analysis of Alhambra's 17,921 renter households (for which income data are available) by spending on rent by income bracket (dollar a mounts).7 As one might expect, the general trend is that low -income households spend a higher share of income on housing (e.g. over 50%) while high-income households are more likely to spend under 30% of income on housing.

Cost burdening is a measure of housing instability and vulnerability to displacement. Policymakers typically focus on renters when assessing cost burdening. It can signal a lack of affordable housing in a region. It is less of a focus for homeowners, because a lender will assess a buyer’s ability to pay for a mortgage before the household can buy a home, and because mortgage payments are typically fixed and do not fluctuate with the larger economy or housing market. While a homeowner’s property taxes can go up with rising home values, they are typically a small share of overall housing costs. For these reasons, homeowners are not as vulnerable to price changes in the housing market as are renters.

7 This estimate of renter households differs from those shown in prior figures as it comes from 2018 American Community Survey data rather than the 2013-2017 CHAS dataset.

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City of Alhambra Public Review Draft Housing Element 29 Figure 22. Spending on Rent by Income, City of Alhambra, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data

In Alhambra, homeowner households make up 40% of Alhambra’s total households and 52% of the SCAG region. In both Alhambra and the SCAG region, the most commonly occurring mortgage payment in Alhambra is $2,000-$3,000/month. However, the SCAG region as a whole has a very high share of homeowners paying over $4,000 per month on their mortgage payment. It is important to keep in mind that the mortgage payment is one part of total homeownership costs; other costs include taxes, insurance, and maintenance.

Figure 23. Monthly Owner Costs for Mortgage Holders, City of Alhambra and SCAG Region, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data

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City of Alhambra Public Review Draft Housing Element 30 Housing the extremely low -income population (below 30% of area median income) can be especially challenging. HUD's CHAS dataset provides a wealth of information on such households in Alhambra. Figure 24 provides a breakdown of extremely low-income households by race and ethnicity. Non-Hispanic Asian households 8 account for the highest share of all extremely low- income households in Alhambra—61% of total—but they only account for 52% of all households in the city. This means they account for a disproportionately large share of households with extremely low incomes.

Figure 24. Extremely Low-Income Housing Needs, City of Alhambra, 2016 Source: SCAG Analysis of HUD CHAS, 2012-2016, Pre-Certified Local Housing Data Demographic
Indicator
Total Households Households with Income 30% or Less
Number Share Number Share
Non-Hispanic
White 3,694 13% 714 11%
Non-Hispanic
Black 594 2% 75 1%
All other Non-
Hispanic races 15,248 52% 3,945 61%
Hispanic 9,620 33% 1,725 27%
Total 29,156 - 6,459 -
Renter
Households 17,365 60% 4,865 75%
Owner
Households 11,770 40% 1,595 25%
Total 29,135 - 6,460 -
Summary of Needs for Extremely Low-Income Households
State law requires that cities analyze the existing and projected housi needs for extremely low- income households (ELI). ELI households are those that earn 30 percent or less of area median income (AMI) adjusted for household size.

ELI households have a higher propensity to experience severe housing problems and have unique housing needs. Among the most common problems are cost burden and overcrowding.

Both factors have an outmeasured impact on health, safety, and mobility.

ELI characteristics have been included in the preceding analysis; they are summarized here. In Alhambra, there are currently 6,135 ELI households in Alhambra. Over the next planning cycle Alhambra assumes 50 percent of VLI households (887 ELI households) will qualify as ELI households. Among all ELI households, 85.2 percent are cost burdened or severely cost burdened. An estimated 4,545 renter households (26 percent of all renters), and 1,590 owner households (14 percent of all owners) are ELI households.

8 In Figure 24, this group is shown as “all other Non-Hispanic races,” but as shown in Figure 6, the vast majority of households in this race and ethnic group identify as Asian.

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City of Alhambra Public Review Draft Housing Element 31

Figure 25. Extremely Low-Income Housing Need Summary, City of Alhambra Source: SCAG Analysis of HUD CHAS, 2012-2016, Pre-Certified Local Housing Data Existing ELI Households 6,135
Projected ELI Households 887 (assumes 50% of VLI RHNA)
Renter % of Renters Owner % of Owners
ELI Households 4,545 26% 1,590 14%
Renter Owner
ELI with Any Housing Problem 3,675 1,225
Elderly/Senior ELI Households 1,705 1,060
% of ELI Households Cost Burdened 85.2%

The city currently classifies single-room occupancy (SRO) housing as part of the definition of boardinghouses in the Alhambra Zoning Ordinance . Boardinghouses are permitted outright in the R-3 zoning district. This is insufficient to assist in meeting the needs of the portion of ELI households that could utilize SRO housing. The establishment of siting regulations and expanded allowance of SRO housing is a priority of the ongoing comprehensive zoning code update that will be adopted under Program 18 in this Housing Element.

Special Housing Needs
Often some segments of the population have more difficulty finding decent, affordable housing due to differing needs for housing and specific circumstances. Special circumstances may be related to employment and income, family characteristics, disability , and household characteristics, among other factors. Consequently, certain residents in Alhambra may experience higher incidences of housing cost burden, overcrowding, or other housing problems. The special needs groups analyzed include:
§ Elderly households
§ People with disabilities
§ People experiencing homelessness
§ Single parents
§ Large households
§ People living in poverty
§ Farm workers
Many of these groups overlap; for example, single parents may have large households, and many elderly people have a disability of some type. The majority of these special needs groups would be assisted by an increase in affordable housing, especially housing located near public transportation and services.

Figure 26. Special Needs Groups (2014-2018)
Source: American Community Survey 2014-2018 5-year estimates Special Needs Groups Number of People or
Households
Percent of Total Households or
Population

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City of Alhambra Public Review Draft Housing Element 32 Households with Seniors
(includes at least one-person
age 65 or over)
9,502 32%
Senior Headed Households 6,995 24%
Seniors Living Alone 2,602 9%
Persons with Disabilities 15,892 19%
Large Households 2,936 10%
Single-Parent Household 2,001 7%
Female-Headed Households
with Children 1,373 5%
Persons living in Poverty 2,305 8%
Farmworkers 93 0%
People Experiencing
Homelessness 68 0%

The city’s 2020-2024 Consolidated Plan states that Alhambra has “extensive needs for supportive services, including housing, senior services, youth and childcare services, recreational activities, immigrant support services, health/medical care, counseling, employment, case management, transportation, and coordination and information/referral.” Elderly
Many senior-headed households have special needs due to their relatively low incomes, disabilities or limitations, and dependency needs. Specifically, people aged 65 years and older often have four main concerns:
§ Housing: Many seniors live alone and may have difficulty maintaining their homes. § Income: People aged 65 and over are usually retired and living on a limited income. § Healthcare: Seniors are more likely to have high healthcare costs. § Transportation: Many of the elderly—especially those with disabilities—rely on public transportation.

Figure 27 shows that an estimated 14,322 persons were age 65 and older in Alhambra in 2018.

This accounted for about 17% of the city’s total residents, higher than the percentage share in the SCAG region as a whole. Comparing Alhambra to nearby peer cities, Figure 27 shows that Monterey Park has the highest share of its population that are 65 years and ol der. Alhambra is second to Monterey Park in terms of having the highest share of elderly population amongst the peer cities.

Figure 27. Persons Age 65 Years and Older, City of Alhambra, Peer Cities, and SCAG Region, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Jurisdiction Population that is
Age 65 Years and Older
Percent of Population
Age 65 Years and Older
Alhambra 14,322 17%
El Monte 14,511 13%

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City of Alhambra Public Review Draft Housing Element 33 Glendale 34,318 17%
Monterey Park 12,892 21%
Pasadena 22,047 16%
San Gabriel 6,498 16%
SCAG 2,447,598 13%

While many in this cohort have the financial resources they need, many do not. Many elderly persons have limited incomes, such as small pensions, social security income benefits, or a few assets. This can make it difficult to find secure, stable, affordable housing in high cost areas .

Figure 28 shows that of Alhambra's 6,995 elderly households, 40% earn less than 30% of the area median income, (compared to only 24% of elderly households in the SCAG region), and 57% earn less than 50% of the area median income (compared to 31% in the SCAG region).

Figure 28. Elderly Households by Income and Tenure, City of Alhambra Source: HUD CHAS, 2012-2016
AMI Income Category Owner
Household
Renter
Household Total
Percent of Total
Elderly
Households
Extremely Low-Income
(30% or less) 1,060 1,705 2,765 40%
Very Low-Income
(31% to 50%) 605 585 1,190 17%
Low-Income
(51% to 80%) 595 525 1,120 16%
Moderate and Above
Moderate (over 80%) 1,400 520 1,920 27%
Total 3,660 3,335 6,995 100%
Note: HUD programs are available only to households with incomes at or below 80% AMI. Therefore, the CHAS data groups all households above that income threshold (both moderate and above moderate income) into one income group. HAMFI refers to HUD Area Median Family Income

Resources
The City of Alhambra’s Parks and Recreation Department offers a Community Services Senior Division that provides services, recreation, and programs for the city’s senior population (age 60+). The Joslyn Adult Recreation Center located in Alhambra is a designated Focal Point by the Los Angeles County Area Agency on Aging for the South west San Gabriel Valley Community Services Area. This recreational facility provides a centralized access point for people to find information and services, for themselves or their family members.

Importantly, this center also offers case management services focused on allowing Alhambra’s senior population to live independently and safely for as long as possible. The center also offers food and nutrition programs including: group grocery runs, meal delivery programs, and a senior weekday lunch program. Referral services include the following:
§ Referrals for medical, counseling, and mental health services; § Referrals for free legal consultations related to estate planning, trusts, and wills; § Referrals for in-home services, transportation, and nutrition; and

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City of Alhambra Public Review Draft Housing Element 34 § Referrals for caregiver resources.

The 2020 Analysis of Impediments to Fair Housing report also highlights a free curb -to-curb transportation service available to Alhambra’s seniors, the Se nior Ride Program. Transportation is available for any service within Alhambra city limits and for medical appointments up to two miles outside of the city. The city has a fleet of vehicles, expanded in 2018, for this program.

Rides can be scheduled in advance, scheduled on repeat, and are available (but not guaranteed) in emergency situations. This program is available to non-senior disabled participants as well.

The 2020 Analysis of Impediments to Fair Housing report also lists several age-restricted housing developments in Alhambra that serve seniors. These include Burke Manor, the Plaza on Main, TELACU Las Palmas Manor, 15 N. Valencia, and Wysong Plaza. In addition, the city has 12 residential care facilities that provide housing and services for adults and the elderly (5 for elderly specifically) with capacity for up to 274 individuals (described in the resources part of the next section, on page 32.

The 2020 -2024 Consolidated Plan lists elderly households as a high priority population for conserving a nd improving existing affordable housing options, a high priority population for supporting affordable housing opportunities, and a high priority population for providing community and supportive services.

Persons with Disabilities
Physical and developmental disabilities may influence the ability to access traditionally-designed housing units and may limit a person’s ability to earn income. Physical and/or developmental disabilities may deprive a person from earning income, restrict mobility, or make self-care difficult.

Thus, persons with disabilities often have special housing needs related to limited earning capacity, a lack of accessible and affordable housing, and higher health costs associated with a disability. Additionally, some residents may have disabilities that require living in a supportive or institutional setting.

The American Community Survey identifies six disability types: hearing disability, vision disability, cognitive disability, ambulatory disability, self -care disability, and independent living disability.

The US Census and the ACS provide clarifying questions to determine persons with disabilities and differentiate disability types within the population. The ACS defines a disability as a person reporting one of the six disabilities identified by the following questions:
§ Hearing Disability: Is this person deaf or does he/she have serious difficulty hearing? § Visual Disability: Is this person blind or do they have serious difficulty seeing even when wearing glasses?
§ Cognitive Difficulty: Because of a physical, mental, or emotional condition, does this person have serious difficulty concentrating, remembering, or making decisions? § Ambulatory Difficulty: Does this person have serious difficulty walking or climbing stairs?
§ Self-Care Difficulty: Because of a physical, mental, or emotional condition, does this person have serious difficulty concentrating, remembering, or making decisions? Does this person have serious difficulty walking or climbing stairs? Does this person have dif ficulty dressing or bathing?
§ Independent Living Difficulty: Because of a physical, mental, or emotional condition, does this person have difficulty doing errands alone such as visiting a doctor’s office or shopping?

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City of Alhambra Public Review Draft Housing Element 35 According to the 2018 American Community Survey, an estimated 19% of Alhambra’s residents had a disability. The majority of persons with at least one disability were aged 65 years or older (67%); disabilities are less prevalent in persons under the age of 18 (3%). Among the different types of disabilities, ambulatory difficulties were the most prevalent, about 25% of all reported disabilities, followed by independent living difficulties (23%), and then cognitive difficulties (16%).

Disability data also provides valuable context for assessing current and future need for accessible housing units. Note that since some disability types are not recorded for children below a certain age, calculating disability as a percentage of total population may not be accurate. Ambulatory difficulties and independent living difficulties were most prevalent amongst residents 65 years and older.

Figure 29. Disabilities Tallied by Age and Type, City of Alhambra, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Disability Type Age 5 to 17 Age 18 to 64 Age 65+ Total Share of total
Hearing Difficulty 47 484 1,565 2,096 13%
Vision Difficulty 78 608 687 1,373 9%
Cognitive Difficulty 168 959 1,379 2,506 16%
Ambulatory Difficulty 53 1,136 2,859 4,048 25%
Self-Care Difficulty 71 605 1,459 2,135 13%
Independent Living
Difficulty NA 1,095 2,639 3,734 23%
Total 417 4,887 10,588 15,892 100%

Four factors—affordability, design, location, and discrimination —significantly limit the supply of housing available to households of persons with disabilities. The most obvious housing need for persons with disabilities is housing that is adapted to their needs. § Most single-family homes are inaccessible to people with mobility and sensory limitations.

Housing may not be adaptable to widened doorways and hallways, access ramps, larger bathrooms, lowered countertops, and other features necessary for accessibility. § Incorporating “barrier-free design” in all new multi-family housing is especially important to provide the widest range of choices for the disabled. § Location of housing is also an important factor for many persons with disabilities, as they often rely upon public transportation to travel to necessary services and shops. “Barrier - free design” housing, accessibility modifications, proximity to services and transit, and group living opportunities are important in serving this group. § Housing advocacy groups report that people with disabilities are often the victims of discrimination in the home buying market. People with disabilities, whether they work or receive disability income, are often perceived to be a greater financial risk than persons without disabilities with identical income amounts.

The Housing Element must also discuss housing needs for people with developmental disabilities, which are federally defined to mean a severe, chronic disability of an individual that:

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City of Alhambra Public Review Draft Housing Element 36 § Is attributable to a mental or physical impairment or combination of mental and physical impairments;
§ Is manifested before the individual attains age 18 (Note: State of California has a manifestation age of 18 years of age; Federal is 22 years); § Is likely to continue indefinitely;
§ Results in substantial functional limitations in three or more of the following areas of major life activity: a) self-care; b) receptive and expressive language; c) learning; d) mobility; e) self-direction; f) capacity for independent living; or g) economic self- sufficiency; and that
§ Reflects the individual’s need for a combination of special, interdisciplinary, or generic services, individualized supports, or other forms of assistance that are of lifelong or extended duration and are individually planned and coordinated.

The California Department of Developmental Services provides data on developmental disabilities by age and type of residence. Th is data is collected at the ZIP- code level and joined to the jurisdiction level by SCAG. Figure 30 shows that in Alhambra, an estimated 663 residents had a developmental disability in 2019. Approximately 51% of individuals with a developmental disability were 17 years or younger, and 49% were 18 years and older. The majority of individuals with a developmental disability resided with a parent or guardian.

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City of Alhambra Public Review Draft Housing Element 37 Figure 30. Developmental Disabilities by Residence and Age, City of Alhambra, 2019 Source: CA DDS Consumer Count by CA ZIP, Age Group and Residence Type, June 2019 Developmental Disabilities Number of Individuals
Total 663
By Residence
Home of Parent or Family Guardian 591
Independent Supported Living 27
Community Care Facility 25
Intermediate Care Facility 0
Foster Family Home 10
Other 10
By Age
0 to 17 Years 341
18 Years and Older 321
Notes:

1. Data available in 161/197 SCAG jurisdictions.

2. Totals may not match as counts below 11 individuals are unavailable and some entries were not matched to a ZIP code, necessitating approximation.

Resources
The City of Alhambra has several resources available to people with disabilities. According to the 2020-2024 Consolidated Plan and the 2020 Analysis of Impediments to Fair Housing report, the city has three types of residential care facilities that provide supportive services , as shown in Figure 31 below.

Figure 31. State Licensed Community Care Facilities, City of Alhambra, 2019 Source: 2020 Draft Analysis of Impediments to Fair Housing Facility Type Number of Facilities Capacity
Adult Day Care 4 210
Adult Residential Facilities 7 30
Residential Care Facilities for the Elderly 5 244
Total 16 484

In addition to the supportive housing available through these 16 community care facilities, the City of Alhambra refers individuals with intellectual and developmental disabilities to an organization in Monterey Park called Mentally and Educationally Retarded Citizens, Inc. (MERCI), which can house and provide programming for up to 50 people.

In addition to these community care facilities currently available, the Consolidated plan suggests that the city will explore the use of Community Development Block G rant (CDBG) funding to

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City of Alhambra Public Review Draft Housing Element 38 provide additional case management services, while also relying on existing partnerships with community-based providers.

While the Adult Residential Facilities and the Residential Care Facilities for the Elderly provide housing, these housing units are not “permanent supportive housing” and do not offer wrap - around services intended to stabilize individuals coming out of homelessness, or exiting institutions such as jails or mental health facilities. The city’s 2020-2024 Consolidated Plan shows that there are no permanent supportive housing units in the city.

Federal Law requires the City of Alhambra to provide “reasonable accommodation to rules, policies, practices, and procedures where such accommodation may be necessary to afford individuals with disabilities equal housing opportunities.” The city has procedures in place to process reasonable accommodations when requested. These procedures allow for flexibility (or waivers) in relation to land use, zoning, or building code regulati ons to ensure equal housing opportunities.

People Experiencing Homelessness
State law (Section 65583(a)(7)) mandates that Housing Elements address the special needs of homeless persons. “Homelessness” as defined by HUD describes an individual (not imprisoned or otherwise detained) who:
§ Lacks a fixed, regular, and adequate nighttime residence; and § Has a primary nighttime residence that is:
o A supervised publicly- or privately-operated shelter designed to provide temporary living accommodations (including welfare, hotels, congregate shelters, and transitional housing for the mentally ill);
o An institution that provides a temporary residence for individuals intended to be institutionalized; or
o A public or private place not designed for, or ordinarily used as, a regular sleeping accommodation for human beings.

This definition does not include: persons living in substandard housing (unless it has been officially condemned), persons living in overcrowded housing (for example, doubled up with others) , persons being discharged from mental health facilities (unless the person was homeless when entering and is considered to be homeless at discharge), or persons who may be at risk of homelessness (for example, people living temporarily with family or friends, youth recen tly released from foster care settings, parolees recently released from jails or prison, or households who are extremely low income and severely cost burdened).

HUD mandates that jurisdictions conduct a point-in-time (PIT) count on a single night in January each year to estimate the size of their population experiencing homelessness. In even-numbered years (e.g., 2018, 2020) , the PIT only captures people experiencing sheltered homelessness, whereas unsheltered counts are done in odd-numbered years. The unsheltered counts are difficult and costly to do, often involving trained volunteers. Industry experts and homeless service providers often state that official PIT counts underestimate the true number of people experiencing homelessness in a given year. In Lo s Angeles County, the Los Angeles Homeless Services Agency (LAHSA) conducts the point-in-time counts.

The LAHSA point-in -time count conducted in 2019 shows that approximately 68 people experienced homelessness in Alhambra. Of these people experiencing homelessness, 53 (78%) were in unsheltered conditions. This is more than twice the number of people experiencing

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City of Alhambra Public Review Draft Housing Element 39 homelessness estimated during previous Housing Element Update (30 persons). When extrapolated to the full year, it was estimated that 85 people ex perienced homelessness in calendar year 2019. California is known to have a chronic issue with unsheltered homelessness, in large part due to its mild weather and high costs of housing.

Figure 32. Count of People Experiencing Homelessness, City of Alhambra, 2019 Source: SCAG Analysis of City and County Homelessness Point-in-Time Counts, Pre-certified Local Housing Data Jurisdiction Sheltered Unsheltered Total
Alhambra 15 53 68
El Monte 25 434 459
Glendale 96 147 243
Monterey Park 17 82 99
Pasadena 221 321 542
San Gabriel 0 28 28
Note: 2019 City and County homelessness point-in-time counts processed by SCAG. Jurisdiction-level counts were not available in Imperial County and sheltered population (and thus total) counts were not available in Riverside County. As a result, SCAG region totals from this compilation of data sources likely undercount true totals.

Resources
The city’s 2020-2024 Consolidated Plan lists zero permanent supportive housing units in Alhambra for people experiencing homelessness or exiting institutions (such as hospitals, jails , or mental health facilities). Permanent supportive housing units are low -barrier housing options for individuals and families with histories of chronic, long-term homelessness who need very low (or no cost) rents and wrap -around supportive services to remain stably housed (such as mental health services, addiction treatment services, employment support services, or others). In addition, the city has no transitional housing units which are intended to provide low -barrier housing and supportive services as indi viduals and families come off the streets or out of institutions and prepare to enter longer term housing. According to the 2020-2024 Consolidated Plan, Alhambra residents have access to 48 year -round emergency shelter beds for households with adults and children, 533 year-round beds for adult-only households, and 30 year-round beds for unaccompanied homeless youth.

Figure 33 lists the homeless services facilities and providers available to residents of Alhambra who are experiencing homelessness. While mos t homeless service facilities are located in Los Angeles and other parts of the metro area, t he City of Alhambra has cooperative relationships with non- profit organizations to provide information, services, and assistance for people experiencing homelessness.

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City of Alhambra Public Review Draft Housing Element 40 Figure 33. Homeless Facilities and Service Providers Available to Alhambra Residents, 2020 Source: 2020-2024 City of Alhambra Consolidated Plan, City of Alhambra Staff Facility Name Location Services Provided
New Image Project Fresh Start Los Angeles Shelter facility for clients with mental health issues; target population is single women or women with
children
Midnight Mission Los Angeles Shelter facility for up to 500 men per night Covenant House Los Angeles 30 bed shelter facility for homeless youth Emmanuel Baptist Rescue
Mission
Los Angeles Shelter facility for up to 33 men per night Salvation Army Safe Harbor Los Angeles Drug and alcohol rehabilitation services Higher Goals Los Angeles Drug and alcohol rehabilitation services Union Station Homeless
Services
Pasadena Homelessness outreach and rapid re-housing
Housing Rights Center Los Angeles Housing information and counseling such as civil rights, fair housing issues, evictions
Allen House Santa Fe
Springs
Adult residential treatment shelter through LA
CADA
Alice’s House Whittier Residential treatment center through LA CADA Casa De Corazon East Los
Angeles
Transitional housing through CHIRP Los Angeles
Meredith’s House Pasadena Two shelter beds

In addition, the city has funded a Homeless Outreach Services program since 2017 that provides people experiencing homelessness with information and referrals to service agencies. The outreach program is administered by the Union Station Homeless Services center in Pasadena.

The Union Station Homeless Services center also facilitates an emergency hotel and motel voucher program on behalf of the City of Alhambra. The city has also contracted with the Los Angeles Centers for Alcohol and Drug Abuse (LA CADA), which is a certified substance abuse and behavioral treatment provider offering critical services across the continuum of care (outpatient, intensive outpatient, and inpatient residential programs). LA CADA also contracts with other service providers and shelters in the region, opening up a larger network of resources.

Alhambra’s Homeless and Mental Evaluation Team (HOME Team) partners with LA CADA to conduct homelessness outreach, provide housing, assist in rapid -rehousing programming, and provide case management services. Alhambra also uses grant funding from Los Angeles County Measure H and from the San Gabriel Valley Council of Governments to provide emergency shelter services when LA CADA facilities are unavailable or do not meet an individual’s needs.

Lastly, Los Angeles County Department s provide additional services for people experiencing homelessness in the City of Alhambra. The Department of Health Services provides a range of physical and mental healthcare services and the County Regional Occupational Program offers services such as job training and career counseling. Low income Alhambra residents are also able to receive work readiness and skills training from the federal Workforce Investment Act (WIA) program administered through the County.

Single-Parent Households
Single parents with dependent children represent another important group with special housing needs. Single-parent households often require special consideration and assistance because they tend to have lower incomes and a greater need for daycare and related facilities. Figure 34 shows that in 2018, Alhambra had 2,001 single-parent households. Of these, the majority (69%) were female-headed households.

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City of Alhambra Public Review Draft Housing Element 41 Figure 34. Single-Parent Households, City of Alhambra, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Jurisdiction
Single Parent Household Female-headed Household with Children Number Percent of total
Households Number Percent of total
Households
Alhambra 2,001 7% 1,373 5%

Resources
Affordable housing options (such as regulated affordable housing units or rent assistance programs) and affordable childcare options are recognized as needed resources for the City of Alhambra’s population of single-parent households. The 2020 Analysis of Impediments to Fair Housing report, the 2020-2024 Consolidated Plan, and the 2020 CAPER all did not list resources available in the city that are specific to this population.

Large Households
Large households are defined as households with five or more members. Large households are identified as a group with special needs because of the limited availability of adequately sized, affordable housing units. Large households often have lower incomes and frequently live in overcrowded smaller dwelling units, which can result in accelerated unit deterioration. Figure 35 compares the number of large households in Alhambra to that in the SCAG region. In 2018, 10% of households in Alhambra consisted of five or more persons, compared to 15% in the SCAG region.

Figure 35. Large Households, City of Alhambra, SCAG Region, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Number of Persons in
Household
Alhambra SCAG Region
Number Percent Number Percent
5 Persons 1,917 7% 510,037 8%
6 Persons 651 2% 232,374 4%
7 Persons or More 368 1% 185,003 3%
Total 2,936 10% 927,414 15%

Figure 36 shows that in Alhambra in the 2012 -2016 time period, large renter households were more likely to have lower incomes than large owner households. However, a greater share of large owner households experienced cost burdening compared to renter households. One potential explanation for this could be that large owner households have more children present, whereas large renter households could have more adults present to assist in paying for housing costs and reducing the rate of cost burdening. More analysis is needed to uncover these trends.

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City of Alhambra Public Review Draft Housing Element 42 Figure 36. Large Households by Tenure and Income Level
Source: HUD CHAS, 2012-2016. HAMFI refers to HUD Area Median Family Income Household by Income
Owner Households Renter Households
Total
Households Large Related
(5 or More
Persons)
Total
Owners
Large Related
(5 or More
Persons)
Total
Renters
Household Income <=
30% AMI
30 (1.8%) 1,590 185
(4.0%) 4,545 6,135
Household Income
>30% to <=50%
50 (4.1%) 1,200 295
(8.8%) 3,340 4,540
Households by Cost Burdening
% Cost Burdened
>30%
165
(9.5%) 1,740 315
(8.0%) 3,940 5,680
% Cost Burdened
>50%
125
(6.2%) 2,014 220
(4.5%) 4,840 6,854

Resources
Affordable housing options (such as regulated affordable housing unit s or rent assistance programs) are recognized as needed resources for the City of Alhambra’s population of larger households. The 2020 Analysis of Impediments to Fair Housing report, the 2020-2024 Consolidated Plan, and the 2020 CAPER all did not list resources available in the city that are specific to this population, but these documents listed housing and community service resources that can benefit this population, in addition to other s (like the city’s Housing Rehabilitation Program).

The 2020-2024 Consolidated Plan lists large family households as a high priority population for conserving and improving existing affordable housing options, and a high priority population for supporting affordable housing opportunities.

People Living in Poverty
In 2018, 2,305 households (8 % of the city’s total households) were estimated to be living in poverty, defined as having an income under the Federal Poverty Line. Female-headed households with children are disproportionately affected by poverty. While female-headed households make up 27% of those in poverty, female- headed households with children make up the majority of female-headed households in poverty (about 55%). In 2018, there were an estimated 348 female-headed households with children living in poverty.

Figure 37. Households Living in Poverty, City of Alhambra, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Household Type Number of
Households
Share of Total
Households
Total households below poverty level 2,305 8%
Female-headed households with children below poverty level 348 1%

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City of Alhambra Public Review Draft Housing Element 43 listed resources available in the city that are specific to this population, but these documents listed housing and community service resources that can benefit this population, in addition to others (like the Housing Choice Voucher Program).

The 2020- 2024 Consolidated Plan lists extremely low -income9 households as a high priority population for the following housing and service needs:
§ Conserving and improving existing affordable housing options, § Supporting affordable housing opportunities,
§ Supporting code enforcement services,
§ Promoting equal housing opportunities,
§ Providing community and supportive services,
§ Providing for planning and administration activities, and § Providing community facilities and infrastructure.

In addition, the 2020-2024 Consolidated Plan’s Strategic Plan includes an Anti -Poverty Strategy that focuses on encouraging business growth and development to create em ployment opportunities. Tenets of this strategy include:
§ Assistance in locating and siting potential business tenants; § Streamlining procedures for opening new businesses;
§ Modest business and utility user fees;
§ Marketing programs to attract and retain businesses, residents, and customers; and § Low-cost public transit within the city.

The 2020 CAPER stated that in FY 2019 -2020, no CDBG funds were expended on economic development activities, but that this strategic plan was still in place.

Farmworkers
Statewide, farmworker housing is of unique concern and of unique importance. While only a small share of SCAG region jurisdictions have farmworkers living in them, they are essential to the region’s economy and food supply. Farmworkers are traditionally defin ed as persons whose primary incomes are earned through permanent or seasonal agricultural labor. Permanent farm laborers work in the fields, in processing plants, or support activities on a generally year -round basis. When workload increases during harvest periods, the labor force is supplemented by seasonal labor, often supplied by a labor contractor. For some crops, farms may employ migrant workers, defined as those whose travel distance to work prevents them from returning to their primary residence every evening.

Given the small number of persons employed in agriculture-related industries, the city can address the needs of the farm worker population through its overall affordable housing programs. Also, because Alhambra is an urban community in a metropolitan area, those persons identified as having agriculture jobs are most likely employed at plant nurseries and similar enterprises and

9 While households living in poverty have different income thresholds than households with extremely low incomes, the resources available would be similar.

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City of Alhambra Public Review Draft Housing Element 44 thus are not anticipated to have the seasonal housing needs associated with crop -related farm worker jobs.

Figure 38. Farmworkers by Occupation, City of Alhambra and SCAG Region, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Occupation Alhambra Share of Total
Alhambra Workers SCAG
Total Jobs: Farming, Fishing, and Forestry Occupation 93 0.22% 57,741 Full-time, Year-Round, Jobs: Farming, Fishing, and
Forestry Occupation 23 0.05% 31,521

Figure 39. Employment in the Agricultural Industry, City of Alhambra and SCAG Region, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Occupation Alhambra Share of Total
Alhambra Workers SCAG
Total in Farming, Agriculture, Forestry, Fishing, and
Hunting 98 0.23% 73,778
Full-time, Year-Round in Agriculture, Forestry, Fishing, and Hunting 46 0.11% 44,979

Resources
Affordable housing options (such as regulated affordable housing units or rent assistance programs) are recognized as needed resources for the City of Alhambra’s population of farmworkers. The 2020 Analysis of Impediments to Fair Housing report, the 2020 -2024 Consolidated Plan, and the 2020 CAPER all did not list resources available in the city that are specific to the farmworker population, but these documents listed housing and community service resources that can benefit this population.

Housing Stock Characteristics
A community’s housing stock is defined as the collection of all housing units located within the jurisdiction. The characteristics of the housing stock, including growth, tenure, vacancy rates, age, type, condition, and cost are important in determining the housing need for the community.

This section details the housing stock characteristics of Alhambra, in an attempt to identify how well the current housing stock meets the needs of the current and future residents of the city.

Housing Unit Growth
Alhambra is a built-out city that has experienced only minimal growth in its housing stock over the past 20 years. According to the California Department of Finance, there are 31,915 housing units in Alhambra as of 2020. This represents a 6% growth in housing units since 2000. The city’s growth rate is comparable to that of El Monte, Monterey Park, and San Gabriel, while residential development was greater in Pasadena and Glendale.

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City of Alhambra Public Review Draft Housing Element 45 Figure 40. Housing Unit Growth, City of Alhambra and Peer Cities, 2020 Source: SCAG Analysis of CA DOF E-5 Population and Housing Unit Estimates, Pre-certified Local Housing Data Jurisdiction
2000 2020 Change 2000-2020
Number Number Number Percent
Alhambra 30,045 31,865 1,820 6%
El Monte 27,758 29,588 1,830 7%
Glendale 73,713 81,019 7,306 10%
Monterey Park 20,209 21,155 946 5%
Pasadena 54,132 62,753 8,621 16%
San Gabriel 12,909 13,564 655 5%

Figure 41. Housing Unit Growth, City of Alhambra and Peer Cities, 2020 Source: SCAG Analysis of CA DOF E-5 Population and Housing Unit Estimates, Pre-certified Local Housing Data

Housing by Type and Tenure
Figure 42 shows that in 2020, the largest percentage of housing units in Alhambra was single - family detached (43%). Approximately 12% were single-family attached units, 12% were

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City of Alhambra Public Review Draft Housing Element 46 multifamily housing with two to four units, 33% were large multifamily housing with five or more units, and 0.1% were mobile home/manufactured housing.

Figure 42. Housing Type, City of Alhambra and SCAG Region, 2020 Source: SCAG Analysis of CA DOF E-5 Population and Housing Unit Estimates, Pre-certified Local Housing Data

Figure 43 shows who lives in these different types of housing units in Alhambra. In 2020, the majority of renter households in Alhambra live d in large multifamily housing with five or more units (46%) and smaller multifamily with two to four units. In comparison, owner households in Alhambra live in single-family detached housing (73%), followed by single-family attached (12%), and large multifamily with 5 or more units (12%).

Figure 43. Housing Type by Tenure, City of Alhambra, 2020 Source: SCAG Analysis of CA DOF E-5 Population and Housing Unit Estimates, Pre-certified Local Housing Data Housing Type
Owner-Occupied Housing Units Renter-Occupied Housing Units Number Percent Number Percent
Single-Family Detached 8,412 73% 4,487 25%
Single-Family Attached 1,340 12% 1,902 11%
Multifamily (2-4 units) 389 3% 3,223 18%
Multifamily (5+ units) 1,323 12% 8,262 46%
Total 11,464 100% 17,874 100%

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City of Alhambra Public Review Draft Housing Element 47 Housing Availability and Tenure
Housing tenure and vacancy rates are important indicators of the supply and cost of housing.

Housing tenure refers to whether a unit is owned or rented. Tenure is an important market characteristic because it is directly related to housing types and turnov er rates. The tenure distribution of a community’s housing stock can be an indicator of several aspects of the housing market, including the affordability of units, household stability, and residential mobility among others.

In most communities, tenure distribution generally correlates with household income, composition, and age of the householder: older households, higher -income households, and larger households tend to own their homes at greater rates than do younger households, lower- income households, or smaller households.

In 2018, the majority of Alhambra households were renters (61%), while 39% of households owned their homes. In contrast, the majority of households in the SCAG region own their homes (52%), while 48% rent.

Figure 44. Housing Tenure, City of Alhambra and SCAG Region, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Tenure Type
Alhambra SCAG
Number Percent Number Percent
Owner-Occupied 11,506 39% 3,150,310 52%
Renter-Occupied 17,921 61% 2,852,437 48%

Figure 45 shows tenure by household size in Alhambra. In 2018, owner -occupied units had a slightly higher average household size compared to renter -occupied units. Approximately 56% rental units were occupied by o ne- and two- person households compared to 51% of owner households. The average person per household in Alhambra was 2.86 in 2018, according to the Census.

Figure 45. Tenure by Household Size, City of Alhambra, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data Size
Owner-Occupied Housing Units Renter-Occupied Housing Units Number Percent Number Percent
1-Person 2,267 20% 4,645 26%
2-Person 3,539 31% 5,364 30%
3-Person 2,574 22% 3,696 21%
4+ Person 2,987 26% 3,987 22%
Total 11,506 100% 17,921 100%

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City of Alhambra Public Review Draft Housing Element 48 Housing Vacancy
Vacancy rates are an important housing indicator because they indicate the degree of choice available. High vacancy rates usually indicate low demand and/or high supply conditions in the housing market. Too high of a vacancy rate can be difficult for owners trying to sell or rent but may also indicate the presence of a substantial second home market. Low vacancy rates usually indicate high demand and/or low supply conditions in the housing market. Too low of a vacancy rate can force prices up , making it more difficult for low - and moderate-income households to find housing. Vacancy rates between 2% and 3% are usually considered healthy for single-family housing, and 5% to 6% for multi -family housing. However, vacancy rates are not the sole indicator of market conditions. They must be viewed in the context of all the characteristics of the local and regional market.

According to the 2014-2018 American Community Survey, the overall vacancy rate in Alhambra was 6.0%. However, about 62% of vacant units (almost 1,240 units) were vacant for an “other reason.” Seasonally-occupied vacation homes represent about 8% of all housing units in the city, compared to about 35% in the SCAG region. Vacant rental units represent 12% of all housing units in the city. Overall the vacancy rates reflected a relatively healthy housing market.

Figure 46. Vacancy Rates by Vacancy Type, City of Alhambra, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data

Housing Age and Condition
Housing age can be an important indicator of housing condition within a community. Like any other tangible asset, housing is subject to gradual physical or technological deterioration over time. If not properly and regularly maintained, housing can deteriorate and discourage reinvestment, depress neighboring property values, and eventually impact the quality of life in a

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City of Alhambra Public Review Draft Housing Element 49 neighborhood. Many federal and state programs also use the age of housing as one factor in determining housing rehabilitation needs. Typically, housing over 30 years of age is more likely to have rehabilitation needs that may include new plumbing, roof repairs, foundation work , and other repairs.

In Alhambra, approximately 76% of the housing stock may potentially require some improvements based on the age of the structure as shown in Figure 47. Approximately 52% of the housing stock in Alhambra is approaching 50 years of age or older , and is more likely to require major rehabilitation. The age of the city’s housing stock indicates a potential need for continued code enforcement, property maintenance, and housing rehabilitation programs to stem housing deterioration. Due to the fact that the majority of households in Alhambra earn low incomes, deferred maintenance could become an increasing issue.

The city allocates CDBG funds to the Code Enforcement program annually. During the 2019-2020 fiscal year, 913 code violations were investigated, of which 492 violations (53 percent) were in low- and moderate-income areas. Code enforcement staff made 506 referrals to the Housing Rehabilitation Program; all were for properties in low- and moderate-income areas.

Given the age of Alhambra’s housing stock, and that maintenance can be economically and physically difficult for some homeowners, the city offers an array of rehabilitation loans for low- income households to maintain their homes. To reach a broad range of participants in the program, flyers are distributed in three languages. City staff have emerging concerns about substandard housing among rental properties which are expected to be addressed in the 2021- 2029 Housing Element.

Figure 47. Year Housing Built, City of Alhambra and SCAG Region, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data

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City of Alhambra Public Review Draft Housing Element 50 Pre-1940 Housing
HUD may consider units substandard if they were built before 1940. Figure 47 shows that 7,589 housing units were built before 1940, approximately 24 percent of the total housing in Alhambra.

Region wide, about nine percent of units were built before 1940.

Lacking Telephone Service, Plumbing, and Kitchen Facilities A city can estimate the number of substandard housing units within its jurisdiction using a number of sources of information, such as the Census. The 2014-218 American Community Survey reports that 597 housing units had no telephone service available, 47 housing units were lacking complete plumbing facilities, and 470 housing units were lacking complete kitchens.

Figure 48. Substandard Housing Conditions, City of Alhambra and SCAG Region, 2018 Source: SCAG Analysis of American Community Survey 2014-2018 5-year estimates, Pre-certified Local Housing Data

Estimate of Housing Units in Need of Rehabilitation
Complementing the ACS data on age and available facilities, an assessment of code enforcement activities can provide additional insight on the overall condition of the City’s housing stock. Over the five-year period ending in November 202 1, Alhambra’s code enforcement division opened 7,342 cases, or 1,468 per year. Among those only 821 (11 percent) remain open and active. Most cases are for miner complaints unrelated to structural issues. Over time, housing units move into and out of various states of disrepair as a result of deferred maintenance, neglegence, or the natural aging process. Alhambra’s Code Enforcement Divisions estimates that in a typical year 400 to 500 complaints are received relating to health and safety issues (H&S) in buildings. Among all cases open, only a limited few are related to ser ious property maintenance issues. Over the last five years only 52 violations per ye ar fell into categories the city considers major property maintenance issues. These include all structures.

Since code enforcement activity is primarily complaint -driven, it is diff icult to make accurate assumptions about the overall condition of the Ccity’s housing stock based upon this data.

However, given that the city averages only 52 cases across all structures, and that a portion of these will be non-residential and a portion will not actually require substantial rennovations, it is reasonable to assume an upper bound of 100 units ann ually require some form of substantial rehabilitation.

2.03%

0.16%

1.60%

1.95%

0.39%

1.29%

0. 0%

0. 5%

1. 0%

1. 5%

2. 0%

2. 5%
No Telephone Service Available Lacking Plumbing Facilities Lacking C omplete Kitchen Facilities
Percent of Total Units
Alhambra SCAG
Formatted: Heading 2

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City of Alhambra Public Review Draft Housing Element 51 Figure 49. Code Enforcement, Health and Safety Issues in Buildings, City of Alhambra (FY 2019, 2020) Source: City of Alhambra
Category FY 2019-20 FY 2020-21
Complaints
Total Confirmed Complaints, as Stand-alone H&S Issues
in Buildings
129 125
Total Proactive Enforcement for Stand-alone H&S issues
in Buildings
175 446
Total Complaints received and proactive enforcement,
rental properties.
393 394
Example Cases 2016-2021
Total Violations Open Violations
Unsafe, substandard, or dangerous structure 22 4
Unsanitary conditions 17 5
Deteriorated exterior of building or structure 116 35
Building or premises violation H&S 105 25

Housing Cost and Affordability
Housing costs directly impact housing accessibility for all economic segments of the community.

In general, if housing supply exceeds housing demand, housing costs will decrease. If housing demand exceeds housing supply, housing costs typically increase. In Alhambra, housing costs tend to be higher than in the SCAG region as a whole. The high cost can be attributed to a low supply of homes for sale and a high demand for housing. This section summarizes the cost and affordability of the housing stock to Alhambra residents.

Homeownership Market
According to a 2020 California Association of Realtors (CAR) report, the average home on the market in November 2020 in Los Angeles County had a median price of $664,160, which was a 12% increase from November 2019. Based on a CAR First Time Buyer Housing Affordability Index, in the third quarter of 2020, the median value of a home in the Los Angeles Metropolitan Area was $518,500 with monthly payments (including taxes and insurance) of $2,560. This would require a qualifying income of at least $76,800 annually.

In comparison, these costs are much higher in Alhambra than in the Los Angeles Metropolitan Area. According to November 2020 data from Zillow, the median cost of a single-family home in Alhambra was $771,423, up 9% from $710,556 in 2018.

According to data provided by SCAG, b etween 2000 and 2018, median home sales prices in Alhambra increased 229% while prices in the SCAG region increased 151%. Prices in Alhambra have fluctuated across the regional average: they were only 86.1% of the SCAG region median in 2003 and but reached a high of 137% of the SCAG median in 2009. Despite these dramatic price increases, median home sales prices in Alhambra have consistently remained lower than some peer cities, such as Pasadena, Glendale, and San Gabriel.

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City of Alhambra Public Review Draft Housing Element 52 Figure 50. Median Home Sales Price, City of Alhambra and SCAG Region, 2000-2018 Source: SCAG Local Profiles, Core Logic/Data Quick, Pre-certified Local Housing Data Note: SCAG median home sales price calculated as household-weighted average of county medians.

Rental Market
CoStar10 is one of many source providers of commercial real estate data and analytics for multifamily, retail, office, industrial, hospitality, and other real estate classes across the Country.

CoStar provides insightful building-level information such as rent, vacancies, and other important information used for local market analyses. Figure 51 shows that in January 2021, the average monthly rents in Alhambra ranged from $1,335 for a studio apartment to $2,019 for a 3-bedroom apartment.

Figure 51. Multifamily Average Monthly Rent, City of Alhambra, 2021 Source: CoStar, January 2021.

Unit Type Average Monthly Rent (January 2021)
Studio $1,335
1-bedroom $1,438
2-bedroom $1,737
3-bedroom $2,019
Housing Production
Figure 52 shows the number of housing permits issued per every 1,000 residents in Alhambra.

Between 2000 to 2018, the number of housing permits Alhambra issued increased; the majority of these were for multifamily units. Permits per 1,000 Alhambra residents have been more stable

10 CoStar is a private, third-party, proprietary data provider commonly used in the real estate industry. Of its residential data, CoStar focuses on multifamily properties with four or more units. While CoStar is one of the best sources for multifamily data, it has gaps and limitations. Newer buildings and those that are professionally managed are more likely to have reliable information, while smaller, older buildings may have incomplete or missing data.

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City of Alhambra Public Review Draft Housing Element 53 in the 2000-2018 timeframe than in other neighboring cities. However, the permitting process for one large property can skew these data.

Figure 52. Housing Units Permitted Per 1,000 Residents, City of Alhambra and SCAG Region, 2000 to 2018
Source: SCAG Analysis of Core Logic/Data Quick, Pre-certified Local Housing Data Note: Additional detail available in SCAG 2019 Local Profiles.

Figure 53 below shows the share of h ousing permits issued in Alhambra and peer cities using data provided by SCAG. Beginning at the Great Recession and the years after, the majority of housing permits have been issued for multifamily units. Similarly, Pasadena, Glendale, and El Monte have also issued the majority of their housing permits for multifamily units.

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City of Alhambra Public Review Draft Housing Element 54 Figure 53. Share of Housing Permits Issued, City of Alhambra and Peer Cities, 2000 to 2018 Source: SCAG Analysis of Core Logic/Data Quick, Pre-certified Local Housing Data Note: Additional detail available in SCAG 2019 Local Profiles.

Affordable Rental Housing Stock
An important component of any community’s housing inventory is the stock of housing that is affordable to households earning lower incomes. This housing can be regulated or unregulated, and is most often rental housing.

Unregulated affordable housing is affordable to lower-income households by virtue of its location, age, condition, or amenities. Typically, unregulated affordable housing units are older, smaller, and/or lower-quality, with fewer amenities, older appliances, or older appearances. Often, these properties have some deferred maintenance or capital needs. Because there is not enough regulated affordable housing across the country, unregulated affordable housing is an important part of the housing stock in a community. But because it is unregulated, the rents charged at the properties can change suddenly and can be influenced by the larger real estate market. In addition, these properties can sometimes have habitability issues (see a discussion of common housing problems on page 21) if they are not well maintained by the landlord.

Regulated affordable housing often has public funding that restricts the maximum incomes of the tenants, or restricts the rents that can be charged to ensure that the housing is serving low - income households. This housing is sometimes referred to as government -assisted housing , referencing the public funds at the property. These restrictions vary by the type of funding and the affordability level at the property, and typically have a limited duration —the property is affordable for a specified period of time.

This section outlines the stock of regulated affordable housing in Alhambra and those units that are at risk of losing their restrictions and “converting” to market rate. This is an important issue for cities and local governments to monitor, as units that convert to market rate can include big rent increases for tenants— putting them at risk of housing instability, homelessness, or

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City of Alhambra Public Review Draft Housing Element 55 displacement—and can cause a permanent loss to the community’s inventory of regulated affordable housing.

Assisted Housing at Risk of Conversion
State law requires the city to identify, analyze, and propose programs to preserve existing multifamily rental units that are restricted to low -income households and that will become unrestricted and possibly be lost as low -income housing (i.e., “units at risk” or “at -risk units”).

State law requires the following:

1. An estimate of the number of units at risk of conversion within ten years of the Housing Element deadline,

2. An analysis of the costs of preserving and/or replacing the units at risk and a comparison of these costs,

3. An analysis of the organizational and financial resources available for preserving and/or replacing the units “at risk,” and

4. Programs for preserving the at-risk units.

The following discussion satisfies the first three requirements of State law listed above pertaining to the potential conversion of assisted housing units into market-rate housing between the 2021- 2029 planning periodthrough October 15, 2031. Program 3 in the Housing Action Plan describes a program for preserving these at-risk units.

According to data provided by t he California Housing Partnership , SCAG (using the HCD preapproved data), and the City of Alhambra, there arewere six properties in Alhambra in 2020 providing 366 affordable housing units. Over t he next teneight years (2021-2029), three properties that provide 215 affordable units have expiring affordability restrictions: 11 units at (non-elderly) 17. S. Olive Ave., 110 units (elderly) at Plaza on Main, and 94 units (elderly) at Wysong Plaza. city staff report that there are other affordable ownership units in the community built in the last 20 years with unknown covenant expirations that could be at risk over the planning period. An example of this is the Alhambra Regency project at 500 West Main Street, which has 16 owner-occupied affordable units. No additional covenants are expected to expire within the next ten years.

Figure 54. Assisted Rental Housing in Alhambra
Source: 2013-2021 Alhambra Housing Element; California Housing Partnership, 2021 Information from City of Alhambra Project Name
Tenant
Type
Low
Income
Units/Cons.

Type
LIHTC
Funding
Source
Affordability
End Date
Risk
Level
Wysong Village Apartments
111 N Chapel Ave
Elderly 94 (rehab) 4% HUD 202 2029 At risk
Section 8
Telacu Las Palmas
89 S Chapel Ave
Elderly 67
(unknown)
No HUD 202 2049 Not at
risk Section 8 2021
Burke Manor
15 N 3rd St.

Elderly 74
(unknown)
No HUD 202 2034 Not at
risk Section 8 2025
Plaza
on
Main
17 S. Olive Ave. Low
Income
11 (unknown)
No HOME and
Set-Aside 2027 At risk
15 N. Valencia St. Elderly 11
(unknown)
No HOME and
Set-Aside 2063 Not at
risk
333 W Main Elderly 110
(new)
4% HOME and
Set-Aside 2027 At risk

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City of Alhambra Public Review Draft Housing Element 56 Total 366
At Risk of Conversion 215

According the California Housing Partnership, Both Wysong Village and 333 w Main were funded with 4% LIHTC. Wysong is also funded with PCAC/202 funds, 333 W main also has funding from HOME. While these projects are technically eligible to convert to market rate housing over the next ten years, these projects are owned by non -profits and are not likely to convert to market rate, as these organizations’ mission is to provide affordable housing.

Cost Analysis
Preservation. Project-based rental assistance programs can achieve preservation of at -risk units. Most of the units at risk in Alhambra are senior units . Senior households tend to have smaller household sizes and lower incomes. Subsidies for these households can be very high. In LA County a two-person VLI household has an affordable rent of around $960. The average market rate rent for a one-bedroom unit in Alhambra is $2,580 per month 11. The difference between market rents and affordable rents for these units is $1,620 per month. This would result in an annual rent subsidy of $19,440 per unit and a total preservation subsidy of $4.1 million per year.

New Construction/Replacement. New construction of a new property or properties with the same number of units and similar quality a nd amenities would vary greatly depending on the location within the city, density, construction type, unit sizes, and a number of other factors. The cost to construct a new unit in the region ranges from $470,000 to $580,000. Initial estimates for Related’s proposal for the Chapel affordable housing project is over $600,000 per unit.

Replacing 215 at-risk units with new construction would cost anywhere from $101 to $129 million dollars. Due to the high cost of land and construction in Alhambra, preservation of units through rent subsidies and other mechanisms is far lower than through construction.

Resources

The financial resources section in Chapter 4 documents a range of partners and funding sources that could be leveraged to support affordable housing preservation in the unlikely event that existing owners seek to allow covenants to expire. The city is actively engaged with bother Related California and American Family Housing/Core on affordable housing projects. The city has previously worked with National Preservation Partners, and Habitat for Humanity. TELACU is another non-profit community development corporation that is active in developing and rehabbing affordable housing in the San Gabriel Valley.

Federal, State, and local financial resources could include (see Chapter 4 for details in these programs):
§ Alhambra's Housing Asset Fund (RDA carryover)
§ HOME
§ LACDA administered Housing Choice Voucher Program

11 CoStar. Properties in Alhambra with 25 or mor units, built since 1980 (2Q21) Formatted: Font: 12 pt
Formatted: Font: Bold
Formatted: Font: Bold
Formatted: Font: Gotham Narrow Book, 11 pt
Formatted: Bullet, No bullets or numbering

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City of Alhambra Public Review Draft Housing Element 57 § CoC
§ California PLHA
§ Inclusionary Housing Trust Fund (from In-lieu fees)
In addition to these resources, Program 10 and Program 11 implements actions to strengthen Alhambra's affordable housing finding and administrative capacity.

Formatted: Bullet
Formatted: Justified

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City of Alhambra Public Review Draft Housing Element 58 Chapter 3: Constraints Analysis
This section outlines the Opportunities and Constraints Analysis, which is a required component of the housing element update. HCD requires the following:
“The housing element must identify and analyze potential and actual governmental constraints to the maintenance, improvement, or development of housing for all income levels, including housing for people with disabilities. The analysis should identify the specific standards and processes of these constraints and evaluate their impact on the supply and affordability of housing. The analysis should determine whether local, regulatory standards pose an actual constraint and must also demonstrate local efforts to remove constraints that hinder a jurisdiction from meeting its housing needs.”
This section builds on the Opportunities and Constraints Analysis in the 2013 -2021 Housing Element, as well as prior work conducted by the City of Alhambra. Importantly, it provides an update to addr ess progress to leverage opportunities and remove constraints over the prior planning cycle.

Nongovernmental Constraints
Housing development relies on inputs set by numerous interrelated markets and players , from the cost and availability of land to the cost of labor and materials to the price of rents. Each input to development is its own market with supply and demand factors constantly in flux. These nongovernmental factors impact housing market dynamics in Alhambra and the region and may pose barriers to housing production and affordability. To a large degree, the city has limited-to- no control over these constraints. However, through its housing programs, the city can take steps to mitigate the effects of these constraints.

Land Availability
Natural limits on land—like slopes, wetlands or floodplains, or forested areas—constrain the areas that are available for housing development. Artificial limits on land—like zoning, protected areas, and public policies —are subject to governmental input and oversight and are discussed in the subsection on Governmental Constraints beginning on page 58.

On a given parcel of land, landowners and property developers evaluate a site for the economically highest and best use allowed, be that office, residential, commercial, or vacant land, depending on the parcel’s unique characteristics.

The City of Alhambra is a built -out, landlocked community. The City of Alhambra currently has less than 5.5 acres of vacant land zoned for residential uses in the community. This will limit the city’s ability to accommodate future housing need for redevelopment and reuse. This condition is not uncommon, with many communities in the San Gabriel Valley experiencing a similar situation.

Land scarcity is a direct cause of high land costs and contributes to lack of housing production.

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City of Alhambra Public Review Draft Housing Element 59

Constraints Summary:

Alhambra is a built-out community with only five acres vacant residentially -zoned land in the city. Nearly all of residential development in the future will have to come through infill, redevelopment, and residential recycle.

What can the City of Alhambra do?
There are only a few tools that the city can use to increase the amount of land available for development, and these types of changes may come at the expense of other public goals (such as economic development, open space, or fiscal benefits) or invite public pushback:
§ Change the zoning on non- residential parcels that are ripe for development or redevelopment.
§ Sell or donate publicly-owned buildable land for development. § Convert open space to residential uses. These conversions should be limited onl y to open space areas suited for development that are not planned for park, conservation, or recreational uses.

Among these options, changes to non -residential zoning is the most likely path to increasing Alhambra’s residential land supply.

Relevant Housing Action Plan Programs : Program 8, Program 15, Program 16, Program 19, Program 20, Program 21, Program 22.

Market Feasibility
When land is available for development, the type of development that is ultimately built is dependent on zoning and regula tions (discussed in the Governmental Constraints on Development section) and the feasibility/profitability from different development options.

Market feasibility is a robust process that assesses the demand for development—comparing the expected revenues a gainst the investment costs f or the desired and allowed types of development. Each development project has the potential to generate revenue from rents, leases, sales, parking, retail, and numerous other end uses. However, development projects are also costly and risky to build —most often requiring debt or equity (with return on investment requirements), raw materials, labor, fees and taxes, and other costs.

Development feasibility is assessed during a project’s due diligence process, where the developer compares sources of capital (and their required returns) against the uses of capital (development costs) and the developer’s own required return threshold for taking on the risk. If a development project is not feasible, it will not be built. A number of factors influence development feasibility, including (but not limited to):
§ Development costs (land, labor, raw materials);
§ Government costs (including taxes, permits, fees, and the time it takes to process); § Interest rates (including return thresholds);
§ Zoning and regulations governing what is allowed to be built; and

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Alhambra City CouncilJanuary 31, 2022

Alhambra City Council
January 31, 2022